NL-11-090, New York State (NYS) Pre-Filed Evidentiary Hearing Exhibit NYS000153, Entergy Response (NL-11-090) to Request for Additional Information for the Review of the Indian Point Nuclear Generating Unit Number 2 and 3 (Jul. 27, 2011) (Entergys Ju

New York State (NYS) Pre-Filed Evidentiary Hearing Exhibit NYS000153, Entergy Response (NL-11-090) to Request for Additional Information for the Review of the Indian Point Nuclear Generating Unit Number 2 and 3 (Jul. 27, 2011) (Entergys Jul

ML11349A114
Person / Time
Site:	Indian Point
Issue date:	07/27/2011
From:	Dacimo F Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Atomic Safety and Licensing Board Panel, Document Control Desk, Office of Nuclear Reactor Regulation
SECY RAS
References
RAS 21546, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01, NL-11-090
Download: ML11349A114 (25)

Text

Entergx Entergy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 788-2055 NL-11-090 July 27, 2011 Fred Dacimo Vice President Operations License Renewal U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Dear Sir or Madam:

Clarification for Request for Additional Information (RAI)

Aging Management Programs Indian Point Nuclear Generating Unit Nos, 2 & 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64

1. NRC Letter, "Request for Additional Information for the Review of the Indian Point Nuclear Generating Unit Numbers 2 and 3, License Renewal Application," dated June 15, 2011

2. Entergy letter (NL-11-032)," Response to Request for Additional Information (RAI) Aging Management Programs," dated March 28, 2011

3. Entergy letter (NL-11-074)," Response to Request for Additional Information (RAI) Aging Management Programs," dated July 14, 2011 Entergy Nuclear Operations, Inc is providing, in Attachment 1, clarifications of the responses in References 2 and 3. Attachment 2 provides the latest list of regulatory commitments including revised commitments contained in this letter.

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

NYS000153 Submitted: December 15, 2011

Docket Nos. 50-247 & 50-286 NL-11-090 Page 2 of 2 I decl~re,under penalty of perjury that the foregoing is true and correct. Executed on 1.J-7!'!o 1\\

I Si~

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FRD/cbr

Attachment:

1.

Attachment:

2.

Clarification for Request for Additional Information (RAI), Aging Management Programs IPEC List of Regulatory Commitments (Rev. 15) cc:

Mr. William Dean, Regional Administrator, NRC Region I Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel Mr. Dave Wrona, NRC Branch Chief, Engineering Review Branch I 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, Jr., President and CEO NYSERDA

ATTACHMENT 1 TO NL-ll-090 LICENSE RENEWAL APPLICATION CLARIFICATION FOR REQUEST FOR ADDITIONAL INFORMATION (RAil AGING MANAGEMENT PROGRAMS ENTERGY NUCLEAR OPERATIONS, INC.

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

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION CLARIFICATION FOR REQUEST FOR ADDITIONAL INFORMATION (RAI)

AGING MANAGEMENT PROGRAMS Changes are shown as strikethroughs for deletions and underlines for additions.

Clarification for RAI 3.0.3.1.6-1 Part 1 A.2.1.22 Non-EO Inaccessible Medium-Voltage Cable Program NL-11-090 Page 1 of 4 The Non-EO Inaccessible Medium-Voltage Cable Program is a new program that entails periodic and event EIR¥eR inspections for water collection in cable manholes, and periodic testing of cables. In scope medium-voltage cables (cables with operating voltage from 2kV to 35kV) and low-voltage power cables (400 V to 2 kV) exposed to significant moisture will be tested at least once every six years to provide an indication of the condition of the conductor insulation. Test frequencies are adjusted based on test results and operating experience.

The frequency of inspections for water accumulation in manholes is established based on plant specific operatinq experience with cable wettinq or submergence in manholes (Le., the inspection is performed periodically based on water accumulation over time and event driven occurrences, such as heavy rain or flooding).

The frequency will be program inoludes periodio inspeotions for '/Jater aooumulation in manholes at least once every year (annually). In addition to the periodio manhole inspeotions, inspeotion of event driven ooourrenoes, suoh as heavy rain or flooding will be performed. Inspection frequency will be increased as necessary based on evaluation of inspection results.

The Non-EO Inaccessible Medium-Voltage Cable Program will be implemented prior to the period of extended operation. This new program will be implemented consistent with the corresponding program described in NUREG-1 8001,Section XI,E3, Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 Environmental Oualification Requirements.

A.3.1.22 Non-EO Inaccessible Medium-Voltage Cable Program The Non-EO Inaccessible Medium-Voltage Cable Program is a new program that entails periodic and event GfiveA inspections for water collection in cable manholes, and periodic testing of cables. In scope medium-.

voltage cables (cables with operating voltage from 2kV to 35kV) and low-voltage power cables (400 V to 2 kV) exposed to significant moisture will be tested at least once every six years to provide an indication of the condition of the conductor insulation. Test frequencies are adjusted based on test results and operating experience.

The frequency of inspections for water accumulation in manholes is established based on plant specific operating experience with cable wetting or submergence in manholes (Le., the inspection is performed periodically based on water accumulation over time and event driven occurrences, such as heavy rain or flooding).

NL-11-090 Page 2 of 4 The frequency will be pregram includes periodic inspoctions for water accumulation in manholes at least once every year (annually). In addition to the periodic manhole inspoctions, inspection of event driven occurrences, such as heavy rain or flooding "'!Jill bo porformod. Inspection frequency will be increased as necessary based on evaluation of inspection results.

The Non-EQ Inaccessible Medium-Voltage Cable Program will be implemented prior to the period of extended operation. This new program will be implemented consistent with the corresponding program described in NUREG-1 8001,Section XI.E3, Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 Environmental Qualification Requirements.

Clarification for RAI 3.0.3.1.2-3 A.2.1.S Buried Piping and Tanks Inspection Program The Buried Piping and Tanks Inspection Program is a new program that includes (a) preventive measures to mitigate corrosion and (b) inspections to manage the effects of corrosion on the pressure-retaining capability of buried carbon steel, gray cast iron, and stainless steel components. Preventive measures are in accordance with standard industry practice for maintaining external coatings and wrappings. Buried components are inspected when excavated during maintenance. If trending within the corrective action program identifies susceptible locations, the areas with a history of corrosion problems are evaluated for the need for additional inspection, alternate coating, or replacement.

Prim to entering tho poriod of extendod oporation, plant operating expOFience will be reviewed and multiple inspections will bo completod within the past ten yoars. Additional poriodic inspections will bo performod within the first ten years of the period of oxtonded opOFation.

IP2 will perform 20 direct visual inspections of buried piping during the 10 year period prior the PE~. IP2 will perform 14 direct visual inspections during each 10-year period of the PEO. Soil samples will be taken prior to the PEO and at least once every 10 years in the PE~. Soil will be tested at a minimum of two locations at least three feet below the surface near in-scope piping to determine representative soil conditions for each system. If test results indicate the soil is corrosive then the number of piping inspections will be increa:sed to 20 during each 1 O-year period of the PEO.

A.3.1.S Buried Piping and Tanks Inspection Program The Buried Piping and Tanks Inspection Program is a new program that includes (a) preventive measures to mitigate corrosion and (b) inspections to manage the effects of corrosion on the pressure-retaining capability of buried carbon steel, gray cast iron, and stainless steel components. Preventive measures are in accordance with standard industry practice for maintaining external coatings and wrappings. Buried components are inspected when excavated during maintenance. If trending within the corrective action program identifies susceptible locations, the areas with a history of corrosion problems are evaluated for the need for additional inspection, alternate coating, or replacement.

Prior to entering the period of extended operation, plant operating experience will be reviewed and multiple inspections will be completed within the past ton years. Additional periodic inspections will be performed 'Nithin the first ton years of the period of extended operation.

IP3 will perform 14 direct visual inspections of buried piping during the 10 year period prior the PE~. IP3 will perform 16 direct visual inspections during each 10-year period of the PE~. Soil samples will be taken prior to the PEO and at least once every 10 years into the PE~. Soil will be tested at a minimum of two locations at least three feet below the surface near in-scope piping to determine representative soil conditions for each

NL-11-090 Att~chment 1 Page 3 of 4 system. If test results indicate the soil is corrosive then the number of piping inspections will be increased to 22 ;W during each 10-year period of the PEO.

Clarification for RAI B.O.4-1 A.2.1 Aging Management Programs and Activities The integrated plant assessment for license renewal identified aging management programs necessary to provide reasonable assurance that components within the scope of license renewal will continue to perform their intended functions consistent with the current licensing basis (CLB) through the period of extended operation. This section describes the aging management programs and activities required during the period of extended operation. All aging management programs will be implemented prior to entering the period of extended operation.

IPEC quality assurance (QA) procedures, review and approval processes, and administrative controls are implemented in accordance with the requirements of 10 CFR 50, Appendix B. The Entergy Quality Assurance Program applies to safety-related structures and components. Corrective actions and administrative (document) control for both safety-related and nonsafety-related structures and components are accomplished per the existing IPEC corrective action program and document control program and are applicable to all aging management programs and activities that will be required during the period of extended operation. The confirmation process is part of the corrective action program and includes reviews to assure that proposed actions are adequate, tracking and reporting of open corrective actions, and review of corrective action effectiveness. Any follow-up inspection required by the confirmation process is documented in accordance with the corrective action program. The corrective action, confirmation process, and administrative controls of the Entergy (10 CFR Part 50, Appendix B) Quality Assurance Program are applicable to all aging management programs and activities required during the period of extended operation.

The Operating Experience Program (OEP) and the Corrective Action Program (CAP) help to assure continued effectiveness of aging management programs through evaluations of operating experience. The OEP implements the reguirements of NRC NUREG-0737, "Clarification of TMI Action Plan Requirements,"Section I.C.5 and evaluates site, Entergy fleet, and industry operating experience for impact on IPEC. The CAP implements the requirements of 10 CFR 50, Appendix B, Criterion XVI and is used to evaluate and effect appropriate actions in response to operating experience relevant to I PEC that indicates a condition adverse to quality or a non-conformance._

A.3.1 Aging Management iPrograms and Activities NL-11-090 Page 4 of 4 The integrated plant assessment for license renewal identified aging management programs necessary to provide reasonable assurance that components within the scope of license renewal will continue to perform their intended functions consistent with the current licensing basis (CLB) through the period of extended operation. This section describes the aging management programs and activities required during the period of extended operation. All aging management programs will be implemented prior to entering the period of extended operation.

IPEC quality assurance (QA) procedures, review and approval processes, and administrative controls are implemented in accordance with the requirements of 10 CFR 50, Appendix B. The Entergy Quality Assurance Program applies to safety-related structures and components. Corrective actions and administrative (document) control for both safety-related and non safety-related structures and components are accomplished per the existing IPEC corrective action program and document control program and are applicable to all aging management programs and activities that will be required during the period of extended operation. The confirmation process is part of the corrective action program and includes reviews to assure that proposed actions are adequate, tracking and reporting.of open corrective actions, and review of corrective action effectiveness. Any follow-up inspection required by the confirmation process is documented in accordance with the corrective action program. The corrective action, confirmation process, and administrative controls of the Entergy (10 CFR Part 50, Appendix B) Quality Assurance Program are applicable to all aging management programs and activities required during the period of extended operation.

The Operating Experience Program (OEP) and the Corrective Action Program (CAP) help to assure continued effectiveness of aging management programs through evaluations of operating experience. The OEP implements the requirements of NRC NUREG-0737, "Clarification of TMI Action Plan Requirements,"Section I.C.5 and evaluates site, Entergy fleet, and industry operating experience for impact on IPEC. The CAP implements the requirements of 10 CFR 50, Appendix B, Criterion XVI and is used to evaluate and effect appropriate actions in response to operating experience relevant to IPEC that indicates a condition adverse to quality or a non-conformance.

ATTACHMENT 2 TO NL-11-090 LICENSE RENEWAL APPLICATION IPEC LIST OF REGULATORY COMMITMENTS Rev. 15 ENTERGY NUCLEAR OPERATIONS, INC.

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

List of Regulatory Commitments Rev. 15 The following table identifies those actions committed to by Entergy in this document.

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

COMMITMENT IMPLEMENTATION SOURCE SCHEDULE 1

Enhance the Aboveground Steel Tanks Program for IP2:

NL-07"039 IP2 and IP3 to perform thickness measurements of September 28, the bottom surfaces of the condensate storage tanks, 2013 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

. September 28, to clarify that actual yield strength is used in selecting 2013 materials for low susceptibility to SCC and clarify the prohibition on use of lubricants containing MoS2 for IP3:

NL-07-153 bolting.

December 12, The Bolting Integrity Program manages loss of 2015 preload and loss of material for all external bolting.

3 Implement the Buried Piping and Tanks Inspection IP2:

NL-07-039 September 28, Program for IP2 and IP3 as described in LRA Section 2013 B.1.6.

NL-07-153 This new program will be implemented consistent with IP3:

the corresponding program described in NUREG-December 12, 1801 Section XI.M34, Buried Piping and Tanks 12015 Inspection.

Include in the Buried Piping and Tanks Inspection.

NL-09-106 Program described in LRA Section 8.1.6 a risk NL-09-111 assessment of in-scope buried piping and tanks that includes consideration of the impacts of buried piping or tank leakage and of conditions affecting the risk for corrosion. Classify pipe segments and tanks as having a high, medium or low impact of leakage based on the safety class, the hazard posed by fluid contained in the piping and the impact of leakage on reliable plant operation. Determine corrosion risk through consideration of piping or tank material, soil resistivity, drainage, the presence of cathodic protection and the type 0f coating. Establish inspection priority and frequency for periodic inspections of the in-scope piping and tanks based on the results of the risk assessment. Perform inspections using direct visual inspection.

NL-11-090 Page 1 of 17 RELATED LRASECTION I AUDIT ITEM A.2.1.1 A.3.1.1 8.1.1 A.2.1.2 A.3.1.2 B.1.2 Audit Items 201,241, 270 A.2.1.5 A.3.1.5 B.1.6 Audit Item 173

COMMITMENT 4

Enhance the Diesel Fuel Monitoring Program to include cleaning and inspection of the I P2 GT -1 gas turbine fuel oil storage tanks, IP2 and IP3 EDG fuel oil day tanks, IP2 SBO/Appendix R diesel generator fuel oil day tank, and IP3 Appendix R fuel oil storage tank and day tank once every ten years.

Enhance the Diesel Fuel Monitoring Program to include quarterly sampling and analysis of the IP2 SBOI Appendix R diesel generator fuel oil day tank, IP2 security diesel fuel oil storage tank, IP2 security diesel fuel oil day tank, and I P3 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/1. 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 ta.nk, and diesel fire pump fuel oil storage tank.

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

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

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

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

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

IMPLEMENTATION SOURCE SCHEDULE IP2:

NL-07-039 September 28, 2013 NL-07-153 IP3:

December 12, 2015 NL-08-057 NL~11-090 Page 2 of 17*

RELATED LRASECTION I AUDIT ITEM A.2.1.8 A.3.1.8 B.1.9 Audit items 128, 129,

132, 491,492, 510

COMMITMENT 5

Enhance the External Surfaces Monitoring Program for IP2 and IP3 to include periodic inspections of systems in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4(a)(1) and (a)(3). Inspections shall include areas surrounding the subject systems to identify hazards to those systems. Inspections of nearby systems that could impact the subject systems will include SSCs that are in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4(a)(2).

6 Enhance the Fatigue Monitoring Program for IP2 to monitor steady state cycles and feedwater cycles or perform an evaluation to determine monitoring is not required. Review the number of allowed events and resolve discrepancies between reference documents and monitoring procedures.

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

7 Enhance the Fire Protection Program to inspect external surfaces of the IP3 RCP oil collection systems for loss of material each refueling cycle.

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

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

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

IMPLEMENTATION SOURCE SCHEDULE IP2:

NL-07-039 September 28, 2013 IP3:

December 12, 2015 IP2:

NL-07-039 September 28,

~013 NL-07-153 IP3:

December 12, 2015 IP2:

NL-07-039 September 28,

~013 IP3:

December 12, 2015 NL-11-090 Page 3 of 17 RELATED LRASECTION I AUDIT ITEM A.2.1.10 A.3.1.10 B.1.11 A.2.1.11 A.3.1.11 8.1.12, Audit Item 164 A.2.1.12 A.3.1.12 B.1.13

COMMITMENT 8

Enhance the Fire Water Program to include inspection of IP2 and IP3 hose reels for evidence of corrosion.

Acceptance criteria will be revised to verify no unacceptable signs of degradation.

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

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

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

Acceptance criteria will be enhanced to verify no significant corrosion.

IMPLEMENTATION SOURCE SCHEDULE IP2:

NL-07-039 September 28,

~013 NL-07-153 IP3:

December 12, NL-08-014

~015 NL-11-090 Page 4 of 17 RELATED LRA SECTION I AUDIT ITEM A.2.1.13 A.3.1.13 8.1.14 Audit Items 105,106

COMMITMENT 9

Enhance the Flux Thimble Tube Inspection Program for IP2 and IP3 to implement comparisons to wear rates identified in WCAP-12866. Include provisions to compare data to the previous performances and perform evaluations regarding change to test frequency and scope.

Enhance the Flux Thimble Tube Inspection Program for I P2 and I P3 tospecify the acceptance criteria as outlined in WCAP-12866 or other plant-specific values based on evaluation of previous test results.

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

IMPLEMENTATION SCHEDULE IP2:

September 28, 2013 IP3:

December 12, 2015 SOURCE NL-07-039 NL-11-090 Page 5 of 17 RELATED LRA SECTION I AUDIT ITEM A.2.1.15 A.3.1.15 B.1.16

COMMITMENT 10 Enhance the Heat Exchanger Monitoring Program for I P2 and I P3 to include the following heat exchangers in the scope of the program.

Safety injection pump lube oil heat exchangers RHR heat exchangers RHR pump seal coolers Non-regenerative heat exchangers Charging pump seal water heat exchangers Charging pump fluid drive coolers

• Charging pump crankcase oil coolers Spent fuel pit heat exchangers

• Secondary system steam generator sample coolers

• Waste gas compressor heat exchangers

• S80/ 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, fouling, or scaling.

11 Delete commitment.

IMPLEMENTATION SOURCE SCHEDULE IP2:

NL-07-039 September 28, 2013 NL-07-153 IP3:

December 12,.

2015 NL-09-018 NL-09-056 NL-11-090 Page 6 of 17 RELATED LRASECTION I AUDIT ITEM A.2.1.16 A.3.1.16 8.1.17, Audit Item 52

COMMITMENT 12 Enhance the Masonry Wall Program for IP2 and IP3 to specify that the IP1 intake structure is included in the program.

13 Enhance the Metal-Enclosed Bus Inspection Program to add I P2 480V bus associated with substation A to the scope of bus inspected.

Enhance the Metal-Enclosed Bus Inspection Program for IP2 and IP3 to visually inspect the external surface of MEB enclosure assemblies for loss of material at 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.

14 Implement the Non-EQ Bolted Cable Connections Program for I P2 and I P3 as described in LRA Section B.1.22.

IMPLEMENTATION SOURCE SCHEDULE IP2:

NL-07-039 September 28, 12013 IP3:

December 12, 12015 IP2:

NL-07-039 September 28, 12013 NL-07-153 IP3:

December 12, NL-08-057 12015 IP2:

NL-07-039 September 28, 2013 IP3:

December 12, 2015 NL-11-090 Page 7 of 17 RELATED LRASECTION I AUDIT ITEM A2.1.18 A3.1.18 B.1.19 A2.1.19 A3.1.19 B.1.20 Audit Items

124, 133,519 A.2.1.21 A3.1.21 B.1.22

COMMITMENT 15 Implement the Non-EQ Inaccessible Medium-Voltage Cable Program for IP2 and IP3 as described in LRA Section B.1.23.

This new program will be implemented consistent with the corresponding program described in NUREG-1801 Section XLE3, Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 Environmental Qualification Requirements.

16 Implement the Non-EQ Instrumentation Circuits Test Review Program for IP2 and IP3 as described in LRA Section B.1.24.

This new program will be implemented consistent with the corresponding. program described in NUREG-1801 Section XLE2, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits.

17 Implement the Non-EQ Insulated Cables and Connections Program for IP2 and IP3 as described in LRA Section B.1.25.

This new program will be implemented consistent with the corresponding program described in NUREG-1801 Section XLE1, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.

18 Enhance the Oil Analysis Program for IP2 to sample and analyze lubricating oil used in the SBO/Appendix R diesel generator consistent with oil analysis for other site diesel generators.

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

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

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

IMPLEMENTATION SOURCE SCHEDULE IP2:

NL-07-039 September 28, 2013 NL-07-153 IP3:

December 12, 12015 IP2:

NL-07-039 September 28, 12013 NL-07-153 IP3:

December 12, 2015 IP2:

NL-07~039 September 28, 12013 NL-07-153 IP3:

December 12, 2015 IP2:

NL-07-039 September 28,

~O13.

IP3:

December 12, 2015 NL-11-090 Page 8 of 17 RELATED LRASECTION I AUDIT ITEM A.2.1.22 A.3.1.22 B.1.23 Audit item 173 A.2.1.23 A.3.1.23 B.1.24 Audit item 173 A.2.1.24 A.3.1 ;24 8.1.25 Audit item 173 A.2.1.25 A.3.1.25 8.1.26

COMMITMENT IMPLEMENTATION SCHEDULE 19 Implement the One-Time Inspection Program for IP2 IP2:

September 28, and IP3 as described in LRA Section 8.1.27.

2013 This new program will be implemented consistent with the corresponding program described in NUREG-IP3:

1801, Section XLM32, One-Time Inspection.

December 12,

. 2015 20 Implement the One-Time Inspection - Small Bore IP2:

September 28, Piping Program for IP2 and IP3 as described in LRA 2013 Section B.1.28.

This new program will be implemented consistent with IP3:

the corresponding program described in NUREG-December 12, 1801,* Section XLM35, One-Time Inspection of ASME 2015 Code Class I Small-Bore Piping.

21 Enhance the Periodic Surveillance and Preventive.

IP2:

Maintenance Program for IP2 and IP3 as necessary September 28, to assure that the effects of aging will be managed 2013 such that applicable components will continue to IP3:

perform their intended functions consistent with the December 12, current licensing basis through the period of extended 12015 operation.

22 Enhance the Reactor Vessel Surveillance Program for IP2:

September 28, IP2 and IP3 revising the specimen capsule withdrawal 2013 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 IP2:

September 28, and I P3 as described in LRA Section B.1.33.

12013 This new program will be implemented consistent with the corresponding program described in NUREG-

• IP3:

1801, Section XLM33 Selective Leaching of Materials. December 12, 12015 24 Enhance the Steam Generator Integrity Program for IP2:

September 28, IP2 and IP3 to require that the results of the condition 12013 monitoring assessment are compared to the operational assessment performed for the prior IP3:

operating cycle with differences evaluated.

December 12, 12015 I

SOURCE NL-07-039 NL-07-153 NL-07-039 NL-07-153 NL-07-039 NL-07-039 NL-07-039 NL-07-153 NL-07-039 NL-11-090 Page 9 of 17 RELATED LRASECTION I AUDIT ITEM A.2.1.26 A.3.1.26 B.1.27 Audit item 173 A.2.1.27 A.3.1.27 B.1.28 Audit item 173 A.2.1.28 A.3.1.28 B.1.29 A.2.1.31 A.3.1.31 B.1.32 A.2.1.32 A.3.1.32 8.1.33 Audit item 173 A.2.1.34 A.3.1.34 B.1.35

COMMITMENT 25 Enhance the Structures Monitoring Program to explicitly specify that the following structures are included in the program.

• Appendix R diesel generator foundation (IP3)

Appendix R diesel generator* fuel oil tank vault (IP3)

• Appendix R diesel generator switchgear and enclosure (IP3) city water storage tank foundation

• condensate storage tanks foundation (IP3) containment access facility and annex (IP3) discharge canal (IP2/3) emergency lighting poles and foundations (IP2/3)

• fire pumphouse (IP2) fire protection pumphouse (I P3) fire water storage tank foundations (IP2/3) gas turbine 1 fuel storage tank foundation maintenance and outage building-elevated passageway (IP2) 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 (lP3)

• service water pipe chase (IP2/3) service water valve pit (IP3)

• superheater stack

• . transformerlswitchyard support structures (IP2)

• waste holdup tank pits (IP2/3)

Enhance the Structures Monitoring Program for IP2 and I P3 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 IMPLEMENTATION SOURCE SCHEDULE IP2:

NL-07-039 September 28,

~013 NL-07-153 IP3:

December 12,

~015 NL-08-057 NL-11-090 Page 10 of 17 RELATED LRA SECTION I AUDIT ITEM A.2.1.35 A.3.1.35 8.1.36 Audit items 86,87,88, 417

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

Enhance the Structures Monitoring Program for IP2 and IP3 to perform an engineering evaluation of groundwater samples to assess aggressiveness of groundwater to concrete on a periodic basis (at least once every five years). IPEG 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, IPEG 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 I P3 to perform inspection of normally submerged concrete portions of the intake structures at least once every 5 years. Inspect the baffling/grating partition and support platform of the IP3 intake structure at least once every 5 years.

Enhance the Structures Monitoring Program for IP2 and I P3 to perform inspection of the degraded areas of the water control structure once per 3 years rather than the normal frequency of once per 5 years during the PEO.

IMPLEMENTATION SOURCE SCHEDULE NL-08-127 NL-11-090 Page 11 of 17 RELATED LRA SECTION I AUDIT ITEM Audit Item 360 Audit Item 358

COMMITMENT Enhance the Structures Monitoring Program to include more detailed quantitative acceptance criteria for inspections of concrete structures in accordance with ACI 349.3R, "Evaluation of Existing Nuclear Safety~Related Concrete Structures" prior to the period of extended operation (PEO).

26 Implement the Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) Program for IP2 and IP3 as described in LRA Section B.1.37.

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

27 Implement the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program for IP2 and IP3 as described in LRA Section B.1.38.

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

28 Enhance the Water Chemistry Control-Closed Cooling Water Program to maintain water chemistry of the IP2 SBO/Appendix R diesel generator cooling system per EPRI guidelines.

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

29 Enhance the Water Chemistry Control-Primary and Secondary Program for IP2 to test sulfates monthly in the RWST with a limit of <150 ppb.

30 For aging management of the reactor vessel internals, IPEC will (1) participate in the industry programs for investigating and managing aging effects on reactor internals; (2) evaluate and implement the results of the industry programs as applicable to the reactor internals; and (3) upon completion of these programs, but not less than 24 months before entering the period of extended operation, submit an inspection plan for reactor internals to the NRC for review and approval.

IMPLEMENTATION SOURCE SCHEDULE NL-11-032 IP2:

NL-07-039 September 28, 2013 NL-07-153 IP3:

December 12, 2015 IP2:

NL-07-039 September 28, 2013 NL-07-153 IP3:

December 12, 2015 IP2:

NL-07-039 September 28,

~013 NL-08-057 IP3:

December 12,

~015 IP2:

NL-07-039 September 28, 12013 IP2:

NL-07-039 September 28, 2011 IP3:

December 12, 2013 NL-11-090 Page 12 of 17 RELATED LRASECTION I AUDIT ITEM A.2.1.36 A.3.1.36 B.1.37 Audit item 173 A.2.1.37 A.3.1.37 B.1.38 Audit item 173 A.2.1.39 A.3.1.39 B.1.40 Audit item 509

. A.2.1.40 B.1.41 A.2.1.41 A.3.1.41

COMMITMENT 31 Additional P-T curves will be submitted as required per 10 CFR 50, Appendix G prior to the period of extended operation as part of the Reactor Vessel Surveillance Program.

32 As required by 10 CFR 50.61 (b)(4), IP3 will submit a plant-specific safety analysis for plate B2803-3 to the NRC three years prior to reaching the RT PTS screening criterion. Alternatively, the site may choose to implement the revised PTS rule when approved.

33 At least 2 years prior to entering the period of extended operation, for the locations identified in LRA Table 4.3-13 (IP2) and LRA Table 4.3-14 (IP3), under the Fatigue Monitoring Program, IP2 and IP3 will implement one or more of the following:

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

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

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

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

4. An analysis using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case) may be pertormed 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.

IMPLEMENTATION SCHEDULE IP2:

September 28,

~013 IP3:

December 12, 12015 IP3:

December 12,

~015 IP2:

September 28, 12011 IP3:

December 12,

~013 Complete SOURCE NL-07-039 NL-07-039 NL-08-127 NL-07-039 NL-07-153 NL-08-021 NL-10-082 NL-11-090 Page 13 of 17 RELATED LRA SECTION I AUDIT ITEM A.2.2.1.2 A.3.2.1.2 4.2.3 A.3.2.1.4 4.2.5 A.2.2.2.3 A.3.2.2.3 4.3.3 Audit item 146

COMMITMENT 34 I P2 SBO / Appendix R diesel generator will be installed and operational by April 30, 2008. This committed change to the facility meets the requirements of 10 CFR 50.591(1) and, therefore, a license amendment pursuant to 10 CFR 50.90 is not required.

35 Perform a one-time inspection of representative sample area of I P2 containment liner affected by the 1973 event behind the insulation, prior to entering the extended period of operation, to assure liner degradation is not occurring in this area.

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

Any degradation will be evaluated for updating of the containment liner analyses as needed.

36 Perform a one-time Inspection and evaluation of a sample of potentially affected IP2 refueling cavity concrete prior to the period of extended operation.

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

. steel.

Additional core bore samples will be taken, if the 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 determine the composition of the fluid. If additional core samples are taken prior t6 the end of the first ten years of the period of extended operation, a sample of leakage fluid will be analyzed.

37 Enhance the Containment Inservice Inspection (CII-IWL) Program to include inspections of the containment using enhanced characterization of degradation (i.e., quantifying the dimensions of noted indications through the use of optical aids) during the period of extended operation. The enhancement includes obtaining critical dimensional data of degradation where possible through direct measurement or the use of scaling technologies for photographs, and the use of consistent vantage points for visual inspections.

IMPLEMENTATION SOURCE SCHEDULE April 30, 2008 NL-07-078 Complete NL-08-074 IP2:

NL-08-127 September 28, 2013 IP3:

December 12, 12015 NL-09-018 IP2:

NL-08-127 September 28, 12013 NL-09-056 NL-09-079 IP2:

NL-08-127 September 28,

~013 IP3:

December 12,

~015 NL-11-090 Page 14 of 17 RELATED LRASECTION I AUDIT ITEM 2.1.1.3.5 Audit Item 27 Audit Item 359 Audit Item 361

COMMITMENT 38 For Reactor Vessel Fluence, should future core loading patterns invalidate the basis for the projected values of RTpts or CvUSE, updated calculations will be provided to the NRC.

39 Deleted 40 Evaluate plant specific and appropriate industry operating experience and incorporate lessons learned in establi~hing appropriate monitoring and inspection frequencies to assess aging effects for the new aging management programs. Documentation of the o~erating ~xperienc~ evaluated for each new program will be available on site for NRC review prior to the period of extended operation.

41 IPEG will perform an inspection of steam generators for both units to assess the condition of the divider plate assembly. The examination technique used will be capable of detecting PWSCC in the steam generator divider plate assemblies. The IP2 steam g~n~rator ~ivider plate inspections will be completed Within the first ten years of the period of extended operation (PEO). The IP3.steam generator divider plate inspections will be completed within the first refueling outage following the beginning of the PE~.

IMPLEMENTATION SCHEDULE IP2:

September 28, 2013 IP3:

December 12, 2015 IP2:

September 28, 2013 IP3:

December 12, 2015 IP2:

After the beqinnina of the PEO and.J2Qrior o September

>8,2023 IP3:

Prior to the end of the first refueling outage ollowing the beginning of the PE~.

SOURCE NL-08-143 NL-09-079 NL-09-106 NL-11-032 NL-11-074 NL-11-090 NL-11-090 Page 15 of 17 RELATED LRASECTION I AUDIT ITEM 4.2.1 B.1.6 B.1.22 B.1.23 B.1.24 B.1.25 B.1.27 B.1.28 B.1.33 B.1.37 B.1.38 N/A

COMMITMENT 42" I PEC will develop a plan for each unit to address the potential for cracking of the primary to secondary pressure boundary due to PWSCC of tube-to-tubesheet welds.

Each plan will consist of two options.

Option 1 (Analysis)

I PEC will perform an analytical evaluation redefining the pressure boundary in which the tube-to-tubesheet weld is no longer included and, therefore, is not required for reactor coolant pressure boundary function. The redefinition of the reactor coolant pressure boundary must _be approved by the NRC sl:IbmitteEi as part of a license amendment request reql:liring approval from tho NRC.

Option 2 (Inspection)

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

a. The condition will be resolved through repair or engineering evaluation to justify continued service, as appropriate, and

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

43 IPEC will review design basis ASME Code Class 1 fatigue evaluations to determine whether the '

NUREG/CR-6260 locations that have been evaluated for the effects of the reactor coolant environment on fatigue usage are the limiting locations for the IP2 and IP3 configurations. If more limiting locations are identified, the most limiting location will be evaluated for the effects of the reactor coolant environment on fatigue usage.

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

IMPLEMENTATION SCHEDULE IP2:

Prior to March

~8eptomber 100 I)(V)'l IP3: Prior to the end of the first refuelinQ outane oliowinQ the beQinninQ of the PEa. gesember 111) I){'\\I)!::

IP2:

Betweon March 12020 and March 12024.

I P3: Prior to the end of the first refueling outage following the beginning of the PEa.

IP2:

Prior to September 28, 2013 IP3: Prior to December 12,

~015 SOURCE NL-11-032 NL-11-074 NL-11-090 NL-11-032 NL-11-090 Page 16 of 17 RELATED LRASECTION I AUDIT ITEM N/A 4.3.3

COMMITMENT 44 IPEC will include written explanation and justification of any user intervention in future evaluations using the WESTEMS "Design CUF" module.

45 IPEC will not use the NB-3600 option 'of the WESTEMS program in future design calculations until the issues identified during the NRC revieVli of the program has been resolved.

46 Include in the IP2 lSI Program that IPEC will perform twenty-five volumetric weld metal inspections of socket welds during each 10-year lSI interval scheduled as specified by IWB-2412 of the ASME Section XI Code during the period of extended operation.

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

IMPLEMENTATION SCHEDULE Within 60 days of issuance of he renewed pperating license.

Within 60 days of issuance of he renewed operating license.

IP2:

Prior.to September 28,

~O13 SOURCE NL-11-032 NL-11-032 NL-11-032 NL-11-074 NL-11-090 Page 17 of 17 RELATED LRASECTION I AUDIT ITEM N/A N/A N/A