NL-11-096, Indian Point, Units 2 & 3, Clarification to Request for Additional Information (RAI) on Aging Management Programs

Indian Point, Units 2 & 3, Clarification to Request for Additional Information (RAI) on Aging Management Programs

ML11229A803
Person / Time
Site:	Indian Point
Issue date:	08/09/2011
From:	Dacimo F Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-11-096
Download: ML11229A803 (24)

Text

AEntergy Enteroy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 788-2055 Fred Dacimo Vice President Operations License Renewal NL-1 1-096 August 9, 2011 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

REFERENCE:

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-1 1-032),"Response to Request for Additional Information (RAI) Aging Management Programs," dated March 28, 2011 3. Entergy letter (NL-1 1-074),"Response to Request for Additional Information (RAI) Aging Management Programs," dated July 14, 2011 4. Entergy letter (NL-1 1-090),"Clarification for Request for Additional Information (RAI) Aging Management Programs," dated July 27, 2011

Dear Sir or Madam:

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.

Docket Nos. 50-247 & 50-286 NL-1 1-096 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on Sincerely, FRD/rw

Attachment:

1. Clarification for Request for Additional Information (RAI), Aging Management Programs

Attachment:

2. 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 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-11-096 LICENSE RENEWAL APPLICATION CLARIFICATION FOR REQUEST FOR ADDITIONAL INFORMATION (RAI)AGING MANAGEMENT PROGRAMS ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286 NL-1 1-096 Attachment 1 Page 1 of 3 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 deletiens and underlines for additions.

Clarification for RAI 3.0.3.1.6-1 Part 1 This clarification amends the response in letters NL-1 1-032, dated March 28, 2011; NL-1 1-074, 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 B.1.23.This letter revises LRA Sections A.2.1.22, A.3.1.22, and B.1.23.Clarification is provided on the performance of event-driven inspections for water in cable manholes.

Letter NL-1 1-032 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 B.1.23 provided in letter NL-1 1-032. 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-EQ 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.

Tiho, fGrouenY Of for water in ma,,nhlo i6 ostablishd baod on plant epecific operating

.p....ne With cablo wetting Or .ubm..g.nc. manholeS (i.e., the inspection is performed periodical bae)n water accum~ulation over time and event driven occurr~ences, SUch as heavy rain; or The yi.,-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-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-EQ 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-1 1-096 Attachment 1 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; frequncGy Of O1inspetions for wate r cumltinin anholes !i6 e-sta-blirmhed based On plant specific operating with cAbl Wetting Or in m.an:hol (i.e., the inspeciRo is pr.fermed periodial baegn water: accumu16lationR ever time and eVent driven occuF9rrence, such as heavy rain or fl99diR)-The fFe ....W..,-be progqram 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-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.

B.1.23 NON-EQ INACCESSIBLE MEDIUM-VOLTAGE CABLE Program Description The Non-EQ 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 fer--after events-driven occurrences, 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-EQ Inaccessible Medium-Voltage Cable Program will manage the effects of aging such that applicable components will NL-1 1-096 Attachment 1 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-EQ Inaccessible Medium-Voltage Cable Program will be effective for managing aging effects since it will incorporate proven monitoring techniques and industry and plant-specific operating experience.

The Non-EQ Inaccessible Medium-Voltage Cable Program assures that the effects of aging will be managed such that the applicable components will continue to perform their intended functions consistent with the current licensing basis through the period of extended operation.

Clarification for RAI 3.1.2.2.16-1 b and RAI 3.1.2.2.16-1 Part 2 Commitment 42 was inadvertently changed due to an administrative error in the list of regulatory commitments attached to NL-1 1-074. The revision had not been identified as a change to the responses to RAIs 3.1.2.2.16-1 b and 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 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.Each plan Will cOncict Of two OptiOnc.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 determininq 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.

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 NL-1 1-096 Attachment 2 Page 1 of 17 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 deletiens and underlines for additions.

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 1 Enhance the Aboveground Steel Tanks Program for IP2: NL-07-039 A.2.1.1 IP2 and IP3 to perform thickness measurements of September 28, A.3.1.1 the bottom surfaces of the condensate storage tanks, 013 B.1.1 city water tank, and fire water tanks once during the lP3: first ten years of the period of extended operation.

December 12, Enhance the Aboveground Steel Tanks Program for 2015 IP2 and IP3 to require trending of thickness measurements when material loss is detected.2 Enhance the Bolting Integrity Program for IP2 and IP3 IP2: NL-07-039 A.2.1.2 to clarify that actual yield strength is used in selecting September 28, A.3.1.2 materials for low susceptibility to SCC and clarify the 013 B.1.2 prohibition on use of lubricants containing MoS 2 for IP3: NL-07-153 Audit Items bolting. December 12, 201,241, The Bolting Integrity Program manages loss of 2015 270 1 preload and loss of material for all external bolting.3 Implement the Buried Piping and Tanks Inspection IP2: NL-07-039 A.2.1.5 Program for IP2 and IP3 as described in LRA Section September 28, A.3.1.5 B.1.6. 2013 B.1.6 NL-07-153 Audit Item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- December 12, 1801 Section XI.M34, Buried Piping and Tanks 2015 Inspection.

Include in the Buried Piping and Tanks Inspection NL-09-106 Program described in LRA Section B.1.6 a risk assessment of in-scope buried piping and tanks that NL-09-111 includes consideration of the impacts of buried piping or tank leakage and of conditions affecting the risk for corrosion.

Classify pipe segments and tanks as having a high, medium or low impact of leakage based on the safety class, the hazard posed by fluid contained in the piping and the impact of leakage on reliable plant operation.

Determine corrosion risk through consideration of piping or tank material, soil resistivity, drainage, the presence of cathodic protection and the type of coating. Establish inspection priority and frequency for periodic inspections of the in-scope piping and tanks based on the results of the risk assessment.

Perform inspections using direct visual inspection.

NL-1 1-096 Attachment 2 Page 2 of 17 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I I/ AUDIT ITEM 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/I. 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.

I P2: September 28,_013 I P3: December 12, 2015 NL-07-039 NL-07-153 NL-08-057 A.2.1.8 A.3.1.8 B.1.9 Audit items 128, 129, 132, 491,492, 510 NL-1 1-096 Attachment 2 Page 3 of 17# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 5 Enhance the External Surfaces Monitoring Program IP2: NL-07-039 A.2.1.10 for IP2 and IP3 to include periodic inspections of September 28, A.3.1.10 systems in scope and subject to aging management 013 B.1.11 review for license renewal in accordance with 10 CFR lP3: 54.4(a)(1) and (a)(3). Inspections shall include areas December 12, surrounding the subject systems to identify hazards to 015 those systems. Inspections of nearby systems that could impact the subject systems will include SSCs that are in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4 (a) (2).6 Enhance the Fatigue Monitoring Program for IP2 to IP2: NL-07-039 A.2.1.11 monitor steady state cycles and feedwater cycles or September 28, A.3.1.11 perform an evaluation to determine monitoring is not 013 B.1.12, required.

Review the number of allowed events and NL-07-153 Audit Item resolve discrepancies between reference documents 164 and monitoring procedures.

Enhance the Fatigue Monitoring Program for IP3 to IP3: include all the transients identified.

Assure all fatigue December 12, analysis transients are included with the lowest 2015 limiting numbers. Update the number of design transients accumulated to date.7 Enhance the Fire Protection Program to inspect IP2: NL-07-039 A.2.1.12 external surfaces of the IP3 RCP oil collection September 28, A.3.1.12 systems for loss of material each refueling cycle. 013 B.1.13 Enhance the Fire Protection Program to explicitly IP3: state that the IP2 and IP3 diesel fire pump engine December 12, sub-systems (including the fuel supply line) shall be 2015 observed while the pump is running. Acceptance criteria will be revised to verify that the diesel engine does not exhibit signs of degradation while running;such as fuel oil, lube oil, coolant, or exhaust gas leakage.Enhance the Fire Protection Program to specify that the IP2 and IP3 diesel fire pump engine carbon steel exhaust components are inspected for evidence of corrosion and cracking at least once each operating cycle.Enhance the Fire Protection Program for IP3 to visually inspect the cable spreading room, 480V switchgear room, and EDG room C02 fire suppression system for signs of degradation, such as corrosion and mechanical damage at least once every six months.

NL-1 1-096 Attachment 2 Page 4 of 17# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I I IAUDIT ITEM 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 siqnificant corrosion.

IP2: September 28, 2013 1 P3: December 12, 2015 NL-07-039 NL-07-153 NL-08-014 A.2.1.13 A.3.1.13 B.1.14 Audit Items 105,106 NL- 11-096 Attachment 2 Page 5 of 17 COMMITMENT 1IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION* I/ _I I/AUDIT ITEM 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 IP2 and IP3 to specify the acceptance criteria as outlined in WCAP-12866 or other plant-specific values based on evaluation of previous test results.Enhance the Flux Thimble Tube Inspection Program for IP2 and IP3 to direct evaluation and performance of corrective actions based on tubes that exceed or are projected to exceed the acceptance criteria.

Also stipulate that flux thimble tubes that cannot be inspected over the tube length and cannot be shown by analysis to be satisfactory for continued service, must be removed from service to ensure the integrity of the reactor coolant system pressure boundary.I P2: September 28, 2013 1P3: December 12, 2015 NL-07-039 A.2.1.15 A.3.1.15 B.1.1 6 NL-1 1-096 Attachment 2 Page 6 of 17 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I_ I_ I / AUDIT ITEM 10 Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 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

• SBO/Appendix R diesel jacket water heat exchanger (IP2 only)Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to perform visual inspection on heat exchangers where non-destructive examination, such as eddy current inspection, is not possible due to heat exchanger design limitations.

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

Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to establish minimum tube wall thickness for the new heat exchangers identified in the scope of the program. Establish acceptance criteria for heat exchangers visually inspected to include no indication of tube erosion, vibration wear, corrosion, pitting, fouling, or scaling.I P2: September 28, 2013 IP3: December 12, 2015 NL-07-039 NL-07-153 NL-09-018 A.2.1.16 A.3.1.16 B.1.17, Audit Item 52 11 Delete commitment.

NL-09-056J NL-1 1-096 Attachment 2 Page 7 of 17 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 12 Enhance the Masonry Wall Program for IP2 and IP3 1P2: NL-07-039 A.2.1.18 to specify that the IP1 intake structure is included in September 28, A.3.1.18 the program. 2013 B.1.19 IP3: December 12, 12015 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.

I P2: September 28, 2013 I P3: December 12, 2015 NL-07-039 NL-07-153 NL-08-057 A.2.1.19 A.3.1.19 B.1.20 Audit Items 124, 133, 519 14 Implement the Non-EQ Bolted Cable Connections IP2: NL-07-039 A.2.1.21 Program for IP2 and IP3 as described in LRA Section September 28, A.3.1.21 B.1.22. 2013 B.1.22 I P3: December 12, 1____ 1_2015 1 1 NL-1 1-096 Attachment 2 Page 8 of 17# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 15 Implement the Non-EQ Inaccessible Medium-Voltage IP2: NL-07-039 A.2.1.22 Cable Program for IP2 and IP3 as described in LRA September 28, A.3.1.22 Section B.1.23. 2013 B.1.23 NL-07-153 Audit item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- December 12, NL-1 1-032 1801 Section XI.E3, Inaccessible Med',m-Veltago 2015 Power Cables Not Subject To 10 CFR 50.49 NL-1 1-096 Environmental Qualification Requirements.

16 Implement the Non-EQ Instrumentation Circuits Test IP2: NL-07-039 A.2.1.23 Review Program for IP2 and IP3 as described in LRA September 28, A.3.1.23 Section B.1.24. 2013 B. 1.24 NL-07-153 Audit item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- December 12, 1801 Section XI.E2, Electrical Cables and 2015 Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits.17 Implement the Non-EQ Insulated Cables and IP2: NL-07-039 A.2.1.24 Connections Program for IP2 and IP3 as described in September 28, A.3.1.24 LRA Section B.1.25. 2013 B.1.25 NL-07-153 Audit item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- December 12, 1801 Section XI.E1, Electrical Cables and 2015 Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.

18 Enhance the Oil Analysis Program for IP2 to sample IP2: NL-07-039 A.2.1.25 and analyze lubricating oil used in the SBO/Appendix September 28, A.3.1.25 R diesel generator consistent with oil analysis for 013 B.1.26 other site diesel generators.

IP3: Enhance the Oil Analysis Program for IP2 and IP3 to December 12, sample and analyze generator seal oil and turbine 2015 hydraulic control oil.Enhance the Oil Analysis Program for IP2 and IP3 to formalize preliminary oil screening for water and particulates and laboratory analyses including defined acceptance criteria for all components included in the scope of this program. The program will specify corrective actions in the event acceptance criteria are not met.Enhance the Oil Analysis Program for IP2 and IP3 to formalize trending of preliminary oil screening results as well as data provided from independent laboratories.

NL-1 1-096 Attachment 2 Page 9 of 17# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 19 Implement the One-Time Inspection Program for IP2 1P2: NL-07-039 A.2.1.26 and IP3 as described in LRA Section B.1.27. September 28, A.3.1.26 2013 B.1.27 This new program will be implemented consistent with NL-07-153 Audit item the corresponding program described in NUREG- IP3: 173 1801,Section XI.M32, One-Time Inspection.

December 12, 2015 20 Implement the One-Time Inspection

-Small Bore IP2: NL-07-039 A.2.1.27 Piping Program for IP2 and IP3 as described in LRA September 28, A.3.1.27 Section B. 1.28. 2013 B.1.28 NL-07-153 Audit item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- December 12, 1801,Section XI.M35, One-Time Inspection of ASME 2015 Code Class I Small-Bore Piping.21 Enhance the Periodic Surveillance and Preventive IP2: NL-07-039 A.2.1.28 Maintenance Program for IP2 and IP3 as necessary September 28, A.3.1.28 to assure that the effects of aging will be managed 013 B.1.29 such that applicable components will continue to IP3: perform their intended functions consistent with the current licensing basis through the period of extended 2015 operation.

22 Enhance the Reactor Vessel Surveillance Program for IP2: NL-07-039 A.2.1.31 IP2 and IP3 revising the specimen capsule withdrawal September 28, A.3.1.31 schedules to draw and test a standby capsule to 013 B. 1.32 cover the peak reactor vessel fluence expected through the end of the period of extended operation.

DP3: 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: NL-07-039 A.2.1.32 and IP3 as described in LRA Section B.1.33. September 28, A.3.1.32 2013 B. 1.33 This new program will be implemented consistent with NL-07-153 Audit item the corresponding program described in NUREG- IP3: 173 1801,Section XI.M33 Selective Leaching of Materials.

December 12, 2015 24 Enhance the Steam Generator Integrity Program for IP2: NL-07-039 A.2.1.34 IP2 and IP3 to require that the results of the condition September 28, A.3.1.34 monitoring assessment are compared to the 2013 B.1.35 operational assessment performed for the prior IP3: operating cycle with differences evaluated.

December 12, 015 NL-1 1-096 Attachment 2 Page 10 of 17# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I _I / AUDIT ITEM 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 (IP3)" 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 (IP3)" service water pipe chase (IP2/3)" service water valve pit (IP3)" superheater stack* transformer/switchyard support structures (IP2)" waste holdup tank pits (IP2/3)Enhance the Structures Monitoring Program for IP2 and IP3 to clarify that in addition to structural steel and concrete, the following commodities (including their anchorages) are inspected for each structure as applicable.

• cable trays and supports* concrete portion of reactor vessel supports* conduits and supports* cranes, rails and girders" equipment pads and foundations

• fire proofing (pyrocrete)

• HVAC duct supports* jib cranes" manholes and duct banks* manways, hatches and hatch covers* monorails IP2: September 28, 2013 I P3: December 12, 2015 NL-07-039 NL-07-153 NL-08-057 A.2.1.35 A.3.1.35 B.1.36 Audit items 86, 87, 88, 417 NL-1 1-096 Attachment 2 Page 11 of 17# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION::I I _I / AUDIT ITEM* 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). IPEC will obtain samples from at least 5 wells that are representative of the ground water surrounding below-grade site structures and perform an engineering evaluation of the results from those samples for sulfates, pH and chlorides.

Additionally, to assess potential indications of spent fuel pool leakage, IPEC will sample for tritium in groundwater wells in close proximity to the IP2 spent fuel pool at least once every 3 months.Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspection of normally submerged concrete portions of the intake structures at least once every 5 years. Inspect the baffling/grating partition and support platform of the IP3 intake structure at least once every 5 years.Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspection of the degraded areas of the water control structure once per 3 years rather than the normal frequency of once per 5 years during the PEO.NL-08-127 Audit Item 360 Audit Item 358 NL-1 1-096 Attachment 2 Page 12 of 17# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM Enhance the Structures Monitoring Program to include more detailed quantitative acceptance criteria NL-1 1-032 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 IP2: NL-07-039 A.2.1.36 Austenitic Stainless Steel (CASS) Program for IP2 September 28, A.3.1.36 and IP3 as described in LRA Section B.1.37. 2013 B. 1.37 NL-07-153 Audit item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- December 12, 1801,Section XI.M12, Thermal Aging Embrittlement 2015 of Cast Austenitic Stainless Steel (CASS) Program.27 Implement the Thermal Aging and Neutron Irradiation NL-07-039 A.2.1.37 Embrittlement of Cast Austenitic Stainless Steel September 28, A.3.1.37 (CASS) Program for IP2 and IP3 as described in LRA 013 B.1.38 NL-07-153 Audit item Section .1.38.P 173 This new program will be implemented consistent with December 12, the corresponding program described in NUREG- 2015 1801 Section XI.M13, Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program.28 Enhance the Water Chemistry Control -Closed IP2: NL-07-039 A.2.1.39 Cooling Water Program to maintain water chemistry of September 28, A.3.1.39 2013 B. 1.40 the IP2 SBO/Appendix R diesel generator cooling NL-08-057 Audit item system per EPRI guidelines.

IP3: 509 Enhance the Water Chemistry Control -Closed December 12, Cooling Water Program to maintain the IP2 and IP3 2015 security generator and fire protection diesel cooling water pH and glycol within limits specified by EPRI guidelines.

29 Enhance the Water Chemistry Control -Primary and NL-07-039 A.2.1.40 Secondary Program for IP2 to test sulfates monthly in September 28, B.1.41 the RWST with a limit of <150 ppb. 2013 30 For aging management of the reactor vessel internals, Spt e NL-07-039 A.2.1.41 IPEC will (1) participate in the industry programs for September 28, A.3.1.41 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, 2013 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.

NL-1 1-096 Attachment 2 Page 13 of 17# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 31 Additional P-T curves will be submitted as required 1P2: NL-07-039 A.2.2.1.2 per 10 CFR 50, Appendix G prior to the period of September 28, A.3.2.1.2 extended operation as part of the Reactor Vessel 013 4.2.3 Surveillance Program. I P3: December 12, 2_015 32 As required by 10 CFR 50.61 (b)(4), IP3 will submit a IP3: NL-07-039 A.3.2.1.4 plant-specific safety analysis for plate B2803-3 to the December 12, 4.2.5 NRC three years prior to reaching the RTPTS 2015 NL-08-127 screening criterion.

Alternatively, the site may choose to implement the revised PTS rule when approved.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 CUF.2. Additional plant-specific locations with a valid CUF may be evaluated.

In particular, the pressurizer lower shell will be reviewed to ensure the surge nozzle remains the limiting component.

3. Representative CUF values from other plants, adjusted to or enveloping the IPEC plant specific external loads may be used if demonstrated applicable to IPEC.4. An analysis using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case) may be performed to determine a valid CUF.(2) Consistent with the Fatigue Monitoring Program, Corrective Actions, repair or replace the affected locations before exceeding a CUF of 1.0.I P2: September 28, 2011 IP3: December 12, 2013 Complete NL-07-039 NL-07-153 NL-08-021 NL-10-082 A.2.2.2.3 A.3.2.2.3 4.3.3 Audit item 146 NL-1 1-096 Attachment 2 Page 14 of 17# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 34 IP2 SBO / Appendix R diesel generator will be April 30, 2008 NL-07-078 2.1.1.3.5 installed and operational by April 30, 2008. This Complete NL-08-074 committed change to the facility meets the requirements of 10 CFR 50.591(1) and, therefore, a license amendment pursuant to 10 CFR 50.90 is not required.35 Perform a one-time inspection of representative 1P2: NL-08-127 Audit Item sample area of IP2 containment liner affected by the September 28, 27 1973 event behind the insulation, prior to entering the 013 extended period of operation, to assure liner degradation is not occurring in this area.Perform a one-time inspection of representative IP3: sample area of the IP3 containment steel liner at the December 12, juncture with the concrete floor slab, prior to entering 2015 the extended period of operation, to assure liner degradation is not occurring in this area.Any degradation will be evaluated for updating of the NL-09-018 containment liner analyses as needed.IP2: NL-08-127 Audit Item 36 Perform a one-time Inspection and evaluation of a Sptb 28, 359 sample of potentially affected IP2 refueling cavity September 28, 359 concrete prior to the period of extended operation.

013 The sample will be obtained by core boring the refueling cavity wall in an area that is susceptible to exposure to borated water leakage. The inspection will include an assessment of embedded reinforcing steel.Additional core bore samples will be taken, if the NL-09-056 leakage is not stopped, prior to the end of the first ten years of the period of extended operation.

A sample of leakage fluid will be analyzed to NL-09-079 determine the composition of the fluid. If additional core samples are taken prior to the end of the first ten years of the period of extended operation, a sample of leakage fluid will be analyzed.37 Enhance the Containment Inservice Inspection (CII- IP2: NL-08-127 Audit Item IWL) Program to include inspections of the September 28, 361 containment using enhanced characterization of 013 degradation (i.e., quantifying the dimensions of noted P&indications through the use of optical aids) during the December 12, period of extended operation.

The enhancement includes obtaining critical dimensional data of 2015 degradation where possible through direct measurement or the use of scaling technologies for photographs, and the use of consistent vantage points for visual inspections.

NL-1 1-096 Attachment 2 Page 15 of 17 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM IP2: NL-08-143 4.2.1 38 For Reactor Vessel Fluence, should future core loading patterns invalidate the basis for the projected September 28, values of RTpts or CvUSE, updated calculations will 013 be provided to the NRC. IP3: December 12, 2015 39 Deleted NL-09-079 40 Evaluate plant specific and appropriate industry 1P2: NL-09-106 B.1.6 operating experience and incorporate lessons learned September 28, B. 1.22 in establishing appropriate monitoring and inspection 2013 B.1.23 B.1.24 frequencies to assess aging effects for the new aging lP3: B.1.25 management programs.

Documentation of the De r1 B.1.25 operating experience evaluated for each new program December 12, B.1.27 will be available on site for NRC review prior to the B.1.28 period of extended operation.

B. 1.33 B.1.37 B.1.38 41 IPEC will perform an inspection of steam generators NL-1 1-032 N/A for both units to assess the condition of the divider Afeth plate assembly.

The examination technique used will beginning of the be capable of detecting PWSCC in the steam PEG and prior to generator divider plate assemblies.

The IP2 steam September 28, generator divider plate inspections will be completed NL-1 1-074 within the first ten years of the period of extended NL-1 1-090 operation (PEO). The IP3 steam generator divider Prior to the end plate inspections will be completed within the first of the end refueling outage following the beginning of the PEO. refueling outage ollowing the beginning of the PEO.

NL-1 1-096 Attachment 2 Page 16 of 17 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I_ I I / AUDIT ITEM 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.Each plan Will consict 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 determinina that NL-1 1-032 NL-1 1-074 NL-1 1-090 NL-1 1-096 N/A 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.

I P2: Prior to March 2024 1P3: Prior to the end of the first refueling outage following the beginning of the PEO.I P2: Between March 2020 and March 2024 IP3: Prior to the end of the first refueling outage following the beginning of the PEO.t 1- $ I.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.IP2: Prior to September 28, 2013 IP3: Prior to December 12, 2-015 NL-1 1-032 4.3.3 NL-1 1-096 Attachment 2 Page 17 of 17 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 44ithin 60 days NL-1 1-032 N/A 44 IPEC will include written explanation and justification of issuance of of any user intervention in future evaluations using the ohe renewed WESTEMS "Design CUF" module. operang operating license.45ithin 60 days NL-1 1-032 N/A 45 IPEC will not use the NB-3600 option of the oftin of WESTEMS program in future design calculations until he renewed the issues identified during the NRC review of the operang program has been resolved, operating license.1P2: NL-11-032 N/A 46 Include in the IP2 ISI Program that IPEC will perform Prior to twenty-five volumetric weld metal inspections of Ptebr 21 socket welds during each 10-year ISI interval September 28, NL-11-074 scheduled as specified by IWB-2412 of the ASME 2013 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 I volumetric examinations.