NL-11-096, New York State (NYS) Pre-Filed Evidentiary Hearing Exhibit NYS000154, Entergy Clarification (NL-11-096) for Request for Additional Information (Rai), Aging Management Programs, Indian Point Nuclear Generating Unit Nos. 2 & 3, Docket Nos. 5

New York State (NYS) Pre-Filed Evidentiary Hearing Exhibit NYS000154, Entergy Clarification (NL-11-096) for Request for Additional Information (Rai), Aging Management Programs, Indian Point Nuclear Generating Unit Nos. 2 & 3, Docket Nos. 50

ML11349A108
Person / Time
Site:	Indian Point
Issue date:	08/09/2011
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-11-096
Download: ML11349A108 (24)

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-11-096 August 9, 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

4. Entergy letter (NL-11-090),"Clarification for Request for Additional Information (RAI) Aging Management Programs," dated July 27, 2011 Entergy Nuclear Operations, Inc is providing, in Attachment 1, clarifications of the responses in References 2, 3 and 4. Attachment 2 provides the latest list of regulatory commitments including revisions to commitments discussed in this letter.

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

NYS000154 Submitted: December 15, 2011

\\

Docket Nos. 50-247 & 50-286 NL-11-096 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on

~rr~) -lNlL Sincerely,

~~~ ~.

FRD/rw

Attachment:

1.

Attachment:

2.

Clarification for Request for Additional Information (RAI), Aging Management Programs IPEC List of Regulatory Commitments (Rev. 16) 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 J 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-11-096 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 NL-11-096 Page 1 of 3 This clarification amends the response in letters NL-11-032, dated March 28, 2011; NL-11-074, dated July 14, 2011; and NL-11-090, dated July 27,2011. These letters revised LRA Section A.2.1.22, A.3.1.22 and 8.1.23.

This letter revises LRA Sections A.2.1.22, A.3.1.22, and 8.1.23.

Clarification is provided on the performance of event-driven inspections for water in cable manholes. Letter NL-11-032 correctly identified event-driven inspections as part of the Non-EQ Inaccessible Medium-Voltage Cable Program. Minor clarifications are provided to the program description in LRA Section 8.1.23 provided in letter NL-11-032. In addition, LRA sections A.2.1.22 and A.3.1.22 are revised to clearly state that even-driven inspections are part of the program.

A.2.1.22 Non-EQ Inaccessible Medium-Voltage Cable Program The Non-EO Inaccessible Medium-Voltage Cable Program is a new program that entails periodic and event-driven 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 'Nith cable wetting or submergence in manholes (Le., the inspection is performed periodically based on 'Nater accumulation over time and event driven occurrences, such as heavy rain or flooding).

The frequency will be program includes periodic inspections for water accumulation in manholes at least once every year (annually). In addition to the periodic manhole inspections, manhole inspection for water after events, such as heaw rain or flooding will be performed. 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-1801,Section XI.E3, Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 Environmental Qualification Requirements.

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

• NL-11-096 Page 2 of 3 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 frequensy of inspestions for water assumulation in manholes is established based on plant spesifis operating experience v,'ith cable wetting or sUbmergense in manholes (i.e., the inspestion is performed periodisally based on water assumulation over time and event driven ossurronses, sush as heavy rain or flooding).

The frequensy will be program includes periodic inspections for water accumulation in manholes at least once every year (annually). In addition to the periodic manhole inspections. manhole inspection for water after events. such 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.

B.1.23 NON-EQ INACCESSIBLE MEDIUM-VOLTAGE CABLE Program Description The Non-EO Inaccessible Medium-Voltage Cable Program is a new program that entails periodic 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 will be adjusted based on test results and operating experience. The program includes inspections for water accumulation in manholes at least once every year (annually). In addition to the periodic manhole inspections, manhole inspection for water fef-after events driven ossurronses, such as heavy rain or flooding will be performed. Inspection frequency will be increased as necessary based on evaluation of inspection results.

This program will be implemented prior to the period of extended operation.

Operating Experience The Non-EQ Inaccessible Medium-Voltage Cable Program is a new program. Industry and plant-specific operating experience will be considered when implementing this program. Industry operating experience that forms the basis for the program is described in the operating experience element of the NUREG-1801 program description. IPEC plant-specific operating experience is not inconsistent with the operating experience in the NUREG-1801 program description.

The inspection frequency for manholes is based on plant-specific operating experience with cable wetting or submergence in manholes (i.e., the inspection is performed periodically based on water accumulation over time and following events such as heavy rain or flooding).

The IPEC program is based on the program description in NUREG-1801, which in turn is based on industry operating experience. As such, operating experience provides assurance that the Non-EO Inaccessible Medium-Voltage Cable Program will manage the effects of aging such that applicable components will

NL-11-096 Page 3 of 3 continue to perform their intended functions consistent with the current licensing basis through the period of extended operation.

Conclusion The Non-EO Inaccessible Medium-Voltage Cable Program will be effective for managing aging effects since it wi" incorporate proven monitoring techniques and industry and plant-specific operating experience. The Non-EO Inaccessible Medium-Voltage Cable Program assures that the effects of aging will be managed such that the applicable components wi" continue to perform their intended functions consistent with the current licensing basis through the period of extended operation.

Clarification for RAI3.1.2.2.16-1 band RAI3.1.2.2.16-1 Part 2 Commitment 42 was inadvertently changed due to an administrative error in the list of regulatory commitments attached to NL-11-07 4. The revision had not been identified as a change to the responses to RAls 3.1.2.2.16-1 band RAI 3.1.2.2.16-1 Part 2 as documented in NL-11-032. These RAI responses accurately describe the intended program and associated commitment. The list of regulatory commitments has been changed to be consistent with the RAI responses.

Commitment 42 IPEC wi" develop a plan for each unit to address the potential for cracking of the primary to secondary pressure boundary due to PWSCC of tube-to-tubesheet welds using one of the following two options.

Each plan 'Nill consist of two options.

Option 1 (Analysis)

IPEC wi" perform an analytical evaluation of the steam generator tube-to-tubesheet welds in order to establish a technical basis for either determining that the tubesheet cladding and welds are not susceptible to PWSCC, QLredefining 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 as a license amendment request.

Option 2 (Inspection)

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

a. The condition will be resolved through 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.

ATTACHMENT 2 TO NL-11-096 LICENSE RENEWAL APPLICATION IPEC LIST OF REGULATORY COMMITMENTS Rev. 16 ENTERGY NUCLEAR OPERATIONS, INC.

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

List of Regulatory Commitments Rev. 16 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 September 28, I P2 and I P3 to perform thickness measurements of

[2013 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 September 28, to clarify that actual yield strength is used in selecting 12013 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

[2015 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 of coating. Establish inspection priority and frequency for periodic inspections of the in-scope piping and tanks based on the results of the risk assessment. Perform inspections using direct visual inspection.

NL-11-096 Page 1 of 17 RELATED LRASECTION I AUDIT ITEM A.2.1.1 A.3.1.1 B.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 IP2 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 SBO/Appendix R diesel generator fuel oil day tank, IP2 security diesel fuel oil storage tank, IP2 security diesel fuel oil day tank, and IP3 Appendix R fuel oil storage tank. Particulates, water and sediment checks will be performed on the samples. Filterable solids acceptance criterion will be less than or equal to 10mg/l. Water and sediment acceptance criterion will be less than or equal to 0.05%.

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

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

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

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

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

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

IMPLEMENTATION SOURCE SCHEDULE IP2:

NL-07-039 September 28,

~013 NL-07-153 IP3:

December 12, 12015 NL"08-057 NL-11-096 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, 12013 IP3:

December 12, 12015 IP2:

NL-07-039 September 28,

~013 NL-07-153 IP3:

December 12, 12015 IP2:

NL-07-039 September 28,

~013 IP3:

December 12, 2015 NL-11-096 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 B.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, 12013 NL-07-153 IP3:

December 12, NL-08-014 12015 NL-11-096 Page 4 of 17 RELATED LRASECTION I AUDIT ITEM A.2.1.13 A.3.1.13 B.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 SOURCE SCHEDULE IP2:

NL-07-039 September 28,

~O13 IP3:

December 12,

~O15 NL-11-096 Page 5 of 17 RELATED LRASECTION 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

• HHR 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, 12015 NL-09-018 NL-09-056 NL-11-096 Page 6 of 17 RELATED LRA SECTION 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 IP2 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 IP2 and IP3 as described in LRA Section B.1.22.

IMPLEMENTATION SOURCE SCHEDULE IP2:

NL-07-039 September 28, 2013 IP3:

December 12, 2015 IP2:

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

December 12, NL-08-057 2015 IP2:

NL-07-039 September 28, 2013 IP3:

December 12,

~015 NL-11-096 Page 7 of 17 RELATED LRA SECTION I AUDIT ITEM A.2.1.18 A.3.1.18 B.1.19 A.2.1.19 A.3.1.19 B.1.20 Audit Items

124, 133,519 A.2.1.21 A.3.1.21 B.1.22

COMMITMENT 15 Implement the Non-EO 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 XI.E3, Inaccessible Medium Voltage Power Cables Not Subject To 10 CFR 50.49 Environmental Oualification 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 XI.E2, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits.

17 Implement the Non-EO 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 XI.E1, 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 I P2 and I P3 tosample and analyze generator seal oil and turbine hydraulic control oil.

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

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

IMPLEMENTATION SOURCE SCHEDULE IP2:

NL-07-039 September 28,

~013 NL-07-153 IP3:

December 12, NL-11-032

~015 NL-11-096 IP2:

NL-07-039 September 28,

~013 NL-07-153 IP3:

December 12, 12015 IP2:

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

December 12, 2015 IP2:

NL-07-039 September 28, 2013 IP3:

December 12, 2015 NL-11-096 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 B.1.25 Audit item 173 A.2.1.25 A.3.1.25 B.1.26

COMMITMENT 19 Implement the One-Time Inspection Program for IP2 and IP3 as described in LRA Section B.1.27.

This new program will be implemented consistent with the corresponding program described in NUREG-1801,Section XI.M32, One-Time Inspection.

20 Implement the One-Time Inspection - Small Bore Piping Program for IP2 and IP3 as described in LRA Section 8.1.28.

This new program will be implemented consistent with the corresponding program described in NUREG-1801,Section XI.M35, One-Time Inspection of ASME Code Class I Small-Bore Piping.

21 Enhance the Periodic Surveillance and Preventive Maintenance Program for IP2 and IP3 as necessary to assure that the effects of aging will be managed such that applicable components will continue to perform their intended functions consistent with the current licensing basis through the period of extended operation.

22 Enhance the Reactor Vessel Surveillance Program for IP2 and IP3 revising the specimen capsule withdrawal schedules to draw and test a standby capsule to cover the peak reactor vessel fluence expected through the end of the period of extended operation.

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

23 Implement the Selective Leaching Program for IP2 and IP3 as described in LRA Section B.1.33.

This new program will be implemented consistent with the corresponding program described in NUREG-1801,Section XI.M33 Selective Leaching of Materials.

24 Enhance the Steam Generator Integrity Program for IP2 and IP3 to require that the results of the condition monitoring assessment are compared to the operational assessment performed for the prior operating cycle with differences evaluated.

IMPLEMENTATION SOURCE SCHEDULE IP2:

NL-07-039 September 28,

~013 NL-07-153 IP3:

December 12,

~015 IP2:

NL-07-039 September 28,

~013 NL-07-153 IP3:

December 12, 12015 IP2:

NL-07-039 September 28,

~013 IP3:

December 12, 12015 IP2:

NL-07-039 September 28,

~013 IP3:

December 12,

~015 IP2:

NL-07-039 September 28,

~013 NL-07-153 IP3:

December 12, 12015 IP2:

NL-07-039 September 28, 12013 IP3:

December 12, 12015 NL-11-096 Page 9 of 17 RELATED LRASECTION I AUDIT ITEM A.2.1.26 A.3.1.26 8.1.27 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 B.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 (IP2I3)

• emergency lighting poles and foundations (IP2/3)

• fire pumphouse (IP2)

• fire protection pump house (IP3)

• fire water storage tank foundations (I P2/3)

• 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 (IP3)

• 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-11-096 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 I P3 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 IP3 to perform inspection of the degraded areas of the water control structure once per 3 years rather than the normal frequency of once per 5 years during the PE~.

IMPLEMENTATION SOURCE SCHEDULE NL-08-127 NL-11-096 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 EmbriUlement 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,

~015 IP2:

NL-07-039 September 28,

~013 NL-07-153 IP3:

December 12,

~015 IP2:

NL-07-039 September 28,

~013 NL-08-057 IP3:

December 12,

~015 IP2:

NL-07-039 September 28,

~013 IP2:

NL-07-039 September 28,

~011 IP3:

December 12, 12013 NL-11-096 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 8.1.41 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 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.

IMPLEMENTATION SOURCE SCHEDULE IP2:

NL-07-039 September 28, 12013 IP3:

December 12, 2015 IP3:

NL-07-039 December 12, 2015 NL-08-127 IP2:

NL-07-039 September 28, 2011 NL-07-153 IP3:

December 12, NL-08-021 2013 Complete NL-10-082 NL-11-096 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 IP2 SSO I 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 IP2 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 to 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 (Le., 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, 2015 NL-09-018 IP2:

NL-08-127 September 28, 2013 NL-09-056 NL-09-079 IP2:

NL-08-127 September 28, 2013 IP3:

December 12, 2015 NL-11-096 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 establishing 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 IPEC 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 generator divider 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 PEO.

IMPLEMENTATION SCHEDULE IP2:

September 28, 2013 IP3:

December 12, 2015 IP2:

September 28,

~013 IP3:

December 12, 12015 IP2:

IAfter the beginning of the PEO and prior to September 28, 2023 IP3:

Prior to the end of the first refueling outage if:ollowing the beginning of the PEO.

SOURCE NL-08-143 NL-09-079 NL-09-106 NL-11-032 NL-11-074 NL-11-090 NL-11-096 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 IPEC will develop a plan for each unit to address the potential for cracking of the primary to secondary pressure boundary due to PWSCC of tube-to-tubesheet welds using one of the following two options.

EaGh plan will Gonsist of two options.

Option 1 (Analysis)

IPEC will perform an analytical evaluation of the steam generator tube-to-tubesheet welds in order to establish a technical basis for either determining that the tubesheet cladding and welds are not susceptible to PWSCC, or 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 as a license amendment request.

Option 2 (Inspection)

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

a. The condition will be resolved through 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 I P3 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 2024 I P3: Prior to the end of the first refueling outage following the beginning of the PEO.

IP2:

Between March 2020 and March 2024 IP3: Prior to the end of the first refueling outage following the beginning of the PEO.

IP2:

Prior to September 28, 12013 I P3: Prior to December 12, 12015 SOURCE NL-11-032 NL-11-074 NL-11-090 NL-11-096 NL-11-032 NL-11-096 Page 16 of 17 RELATED LRASECTION I AUDIT ITEM N/A 4.3.3

COMMITMENT 44 IPEG 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 review 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 operating license.

Within 60 days of issuance of he renewed operating license.

IP2:

Prior to September 28, 12013 SOURCE NL-11-032 NL-11-032 NL-11-032 NL-11-074 NL-11-096 Page 17 of 17 RELATED LRA SECTION I AUDIT ITEM N/A N/A N/A