NL-11-101, Clarification for Request for Additional Information (RAI) Aging Management Programs

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Clarification for Request for Additional Information (RAI) Aging Management Programs
ML11243A085
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 08/22/2011
From: Dacimo F
Entergy Nuclear Northeast
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-11-101
Download: ML11243A085 (28)
v • d • e


Text

Entergy Nuclear Northeast Indian Point Energy Center wEntergy 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 788-2055 Fred Dacimo Vice President Operations License Renewal NL-1 1-101 August 22, 2011 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

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

REFERENCE:

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
5. Entergy letter (NL-1 1-096),"Clarification for Request for Additional Information (RAI) Aging Management Programs," dated August 9, 2011
6. Entergy letter (NL-1 0-063),"Amendment 9 to License Renewal Application (LRA) - Reactor Vessel Internals Program," dated July 14, 2010

Dear Sir or Madam:

Entergy Nuclear Operations, Inc is providing, in Attachment 1, clarifications of the responses in References 2, 3, 4 and 5. Attachment 2 provides the latest list of regulatory commitments including revisions to commitments discussed in this letter. A1 2- 8

Docket Nos. 50-247 & 50-286 NL-1 1-101 Page 2 of 2 In Reference 6 Entergy submitted Amendment 9 to the License Renewal Application regarding the Reactor Vessel Internals Program. Attachment 3 provides errata to that Program.

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

I declare nd r penalty of perjury that the foregoing is true and correct. Executed on FRD/rw

Attachment:

1. Clarification of Responses to Requests for Additional Information (RAIs) and Commitment List

Attachment:

2. IPEC List of Regulatory Commitments (Rev. 17) . Amendment 9 to the License Renewal Application (LRA) - Reactor Vessel Inspection Program Errata 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. Robert Kuntz, 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-11-101 LICENSE RENEWAL APPLICATION CLARIFICATION OF RESPONSES TO REQUESTS FOR ADDITIONAL INFORMATION (RAIs) AND COMMITMENT LIST ENTERGY NUCLEAR OPERATIONS, INC.

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

NL-11-101 Attachment 1 Page 1 of 4 INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION CLARIFICATION OF RESPONSES TO REQUESTS FOR ADDITIONAL INFORMATION (RAIs) AND COMMITMENT LIST Introduction Entergy has made regulatory commitments relating to managing the effects of aging on certain structures and components during the period of extended operation. These commitments are included in a number of transmittal letters as identified in the commitment list contained in . The NRC Safety Evaluation Report (SER), issued as NUREG-1930, also contains the commitments made up to the time of its issue.

Entergy has reviewed the commitment transmittal letters and the SER. As a result of the review certain commitments made by Entergy require minor revision. A large majority of these revisions are editorial and do not alter the intent of the commitment. In addition, there are certain instances where the SER commitment list contains minor deviations from the Entergy commitment. The results of the review are documented below.

Changes to Enteray Commitments Commitment 3 In NL-1 1-074, Entergy inadvertently changed this commitment due to an administrative error.

The change was not identified as a change and NL-1 1-074 was not identified as a source document. This commitment is being restored to the version provided in NL-1 1-032.

NL-1 1-101 has been added as a source document in the list of regulatory commitments.

Commitment 11 A minor grammatical error is corrected here by replacing "Delete commitment." by "Deleted".

NL-11-101 has been added as a source document in the list of regulatory commitments.

Commitment 15 The correct title for NUREG-1801 Section XI.E3 is "Inaccessible Medium Voltage Cables Not Subject To 10 CFR 50.49 Environmental Qualification Requirements." This supersedes the title change identified in NL-1 1-032 and the NL-1 1-096 commitment list.

NL-1 1-101 has been added as a source document in the list of regulatory commitments.

Commitment 25 In NL-1 1-074, Entergy inadvertently changed this commitment due to an administrative error.

The change was not identified as a change and NL-1 1-074 was not identified as a source document. This commitment is being restored to the version provided in NL-1 1-032 by deleting

"(PEO)" at the end of the commitment.

Docket Nos. 50-247 & 50-286 NL-1 1-101 Page 2 of 4 NL-1 1-101 has been added as a source document in the list of regulatory commitments.

Commitment 34 In NL-1 1-032, Entergy introduced a typographical error by changing "50.59(c)(1 )" to "50.591(1)."

That error is corrected here.

NL-1 1-101 has been added as a source document in the list of regulatory commitments.

Commitments 35 and 36 There are minor editorial differences between the commitments and the SER. The commitments have been revised to match the SER by changing "extended period of operation" to "period of extended operation" in commitment 35 and changing "Inspection" to "inspection" in commitment 36.

NL-1 1-101 has been added as a source document in the list of regulatory commitments.

Commitment 41 In NL-1 1-074, Entergy discussed and made changes to Commitment 41. In addition to the changes discussed in the letter, Entergy inadvertently made editorial changes to portions of this commitment due to an administrative error. These changes were not identified as a change in the commitment list. This commitment is being revised to correct the inadvertent editorial changes.

NL-1 1-101 has been added as a source document in the list of regulatory commitments.

Commitment 43 In NL-1 1-074, Entergy inadvertently changed the implementation schedule to IP2: Prior to September 28, 2023 and IP3: Prior to December 12, 2025. This change was corrected in NL-1 1-090 but the change was neither identified as a change nor discussed. Therefore, changes to the commitment are not required.

In order to provide traceability NL-1 1-101 has been added as a source document in the list of regulatory commitments.

Commitments 44 and 45 For consistency with other similar commitments the implementation schedule has been revised from 'Within 60 days of issuance of the renewed operating license" to "IP2: Prior to September 28, 2013 IP3: Prior to December 12, 2015".

NL-1 1-101 has been added as a source document in the list of regulatory commitments.

Commitment 45 A minor grammatical error is corrected here by replacing "has" by "have".

Docket Nos. 50-247 & 50-286 NL-1 1-101 Page 3 of 4 NL-1 1-101 has been added as a source document in the list of regulatory commitments.

Minor differences between the SER and Enterqy commitments Commitment 1 The words "Above Ground" were used instead of "Aboveground".

Commitments 3, 15, 16 and 17 The word "program" is missing following "corresponding" in the second paragraph of each commitment. In addition, in Commitment 17 "50.39" should be "50.49".

Commitment 4 The word "surface" was added to the SER in the third paragraph following "bottom".

The next to last paragraph in the SER reads "Revise applicable procedures to direct sampling of the onsite portable fuel oil contents prior to transferring the contents prior to transferring the contents to storage" while the Entergy commitment reads "Revise applicable procedures to direct sampling of the onsite portable fuel oil contents prior to transferring the contents to the storage tanks".

In NL-08-057, Entergy revised the commitment by adding "EDG fuel oil storage tanks" without identifying the change as a change. In accordance with NL-08-057 the third paragraph in the SER should read ".....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."

Commitment 8 In NL-07-153, Entergy identified a change to the second paragraph of Commitment 8 that replaced "inspect" by "replace all or test".

In NL-08-014, Entergy identified a change to the fourth paragraph of Commitment 8 that deleted

'the 1P3". The statement is applicable to both IP2 and IP3.

Commitment 10 In NL-09-018, Entergy identified a change to the fourth paragraph of Commitment 10 that replaced "unacceptable signs of degradation" by "indication of tube erosion, vibration wear, corrosion, pitting, fouling, or scaling".

Commitments 11 and 39 The words "not applicable" were added in the SER under LRA section and implementation schedule columns.

Docket Nos. 50-247 & 50-286 NL-1 1-101 Page 4 of 4 Commitment 13 In NL-07-153, Entergy identified a change to the fourth paragraph of Commitment 13 that added the words "such as thermography or contact resistance measurements".

The words "metal-enclosed bus" in the second paragraph were added to the SER in place of "MEB".

Commitment 18 There is a minor editorial difference in the first paragraph. The SER says "the oil analysis" and the Entergy commitment says "oil analysis".

Commitment 21 The word "extended" is missing.

Commitment 30 The word "and" is missing prior to (3) and the Entergy commitment implementation schedule dates should be IP2: September 28, 2011 and IP3: December 12, 2013.

Commitment 32 "10 CFR 50.61 (b) 4)" should read "10 CFR 50.61 (b)(4)".

In addition to the commitment review Entergy provides below an update to the implementation of Commitment 30.

Inspection Plan for Reactor Internals This inspection plan that Entergy will submit by September 28, 2011 is responsive to RIS 2011-007 for Category C plants. This inspection plan will include the inspections specified in MRP-227, as modified by the conditions and limitations and applicant/licensee action items in the NRC SER on MRP-227, Revision 0. In accordance with guidance on the NRC website, EPRI is expected to publish an accepted version of MRP-227, designated MRP-227-A, which will incorporate the NRC SER. Following issuance of MRP-227-A, Entergy will review the inspection plan to determine the need for revision, and will modify the inspection plan to include the necessary revisions, if any.

ATTACHMENT 2 TO NL-11-101 LICENSE RENEWAL APPLICATION IPEC LIST OF REGULATORY COMMITMENTS Rev. 17 ENTERGY NUCLEAR OPERATIONS, INC.

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

NL-1 1-101 Attachment 2 Page 1 of 18 List of Regulatory Commitments Rev. 17 The following table identifies those actions committed to by Entergy in this document.

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

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM IP2: NL-07-039 A.2.1.1 1 Enhance the Aboveground Steel Tanks Program for September 28, A.3.1.1 IP2 and IP3 to perform thickness measurements of 013 B.1.1 the bottom surfaces of the condensate storage tanks, city water tank, and fire water tanks once during the IP3:

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

2 Enhance the Bolting Integrity Program for IP2 and IP3 IP2: NL-07-039 A.2.1.2 to clarify that actual yield strength is used in selecting September28, A.3.1.2 materials for low susceptibility to SCC and clarify the 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__ 1_preload and loss of material for all external bolting. I I I

NL-11-101 Attachment 2 Page 2 of 18 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

_ 1 _ _ 1/ AUDIT ITEM IP2: NL-07-039 A.2.1.5 3 Implement the Buried Piping and Tanks Inspection September 28, A.3.1.5 Program for IP2 and IP3 as described in LRA Section 2013 B.1.6 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.

NL-09-106 Include in the Buried Piping and Tanks Inspection Program described in LRA Section B.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 inspection techniques with demonstrated effectiveness diroct visual in.ecti. . NL-1 1-101

NL-11-101 Attachment 2 Page 3 of 18

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

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

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

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

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

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

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

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

NL-11-101 Attachment 2 Page 4 of 18

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM 5 Enhance the External Surfaces Monitoring Program 1P2: NL-07-039 A.2.1.10 for IP2 and IP3 to include periodic inspections of September 28, A.3.1.10 systems in scope and subject to aging management 013 B.1.11 review for license renewal in accordance with 10 CFR IP3:

54.4(a)(1) and (a)(3). Inspections shall include areas December 12, surrounding the subject systems to identify hazards to 015 those systems. Inspections of nearby systems that could impact the subject systems will include SSCs that are in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4(a)(2).

6 Enhance the Fatigue Monitoring Program for IP2 to IP2: NL-07-039 A.2.1.11 Septmber28,A.3.1.11 monitor steady state cycles and feedwater cycles or eptember 28, A.1 .12 perform an evaluation to determine monitoring is not 013 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 P2: 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 [P3:

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 1-101 Attachment 2 Page 5 of 18 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I I I 1/ AUDIT ITEM 8 Enhance the Fire Water Program to include inspection IP2: NL-07-039 A.2.1.13 September 28, A.3.1.13 of IP2 and IP3 hose reels for evidence of corrosion.

Acceptance criteria will be revised to verify no 2013 B.1.14 NL-07-153 Audit Items unacceptable signs of degradation.

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

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

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

Acceptance criteria will be enhanced to verify no significant corrosion.

NL-11-101 Attachment 2 Page 6 of 18

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I_ / AUDIT ITEM IP2: NL-07-039 A.2.1.15 9 Enhance the Flux Thimble Tube Inspection Program September 28, A.3.1.15 for IP2 and IP3 to implement comparisons to wear 2013 B.1.16 rates identified in WCAP-12866. Include provisions to compare data to the previous performances and IP3:

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

2015 Enhance the Flux Thimble Tube Inspection Program for IP2 and IP3 to specify the acceptance criteria as outlined in WCAP-1 2866 or other plant-specific values based on evaluation of previous test results.

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

NL-1 1-101 Attachment 2 Page 7 of 18 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I /.AUDIT ITEM P2: NL-07-039 A.2.1.16 10 Enhance the Heat Exchanger Monitoring Program for September 28, A.3.1.16 IP2 and IP3 to include the following heat exchangers 2013 B.1.17, in the scope of the program.

NL-07-153 Audit Item

  • Safety injection pump lube oil heat exchangers P3: 52 December 12,
  • RHR heat exchangers 2015
  • RHR pump seal coolers
  • Non-regenerative heat exchangers

" Charging pump seal water heat exchangers

  • Charging pump fluid drive coolers
  • Charging pump crankcase oil coolers
  • Spent fuel pit heat exchangers
  • 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, INL-09-018 foulina, or scalinc.

11 NL-09-056 De*te .....

11Q*. O.

mitmo"t. Deleted n . J I NL-1 1-101

NL-11-101 Attachment 2 Page 8 of 18

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

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

December 12, 2015 13 Enhance the Metal-Enclosed Bus Inspection Program IP2: NL-07-039 A.2.1.19 to add IP2 480V bus associated with substation A to September 28, A.3.1.19 the scope of bus inspected. 2013 B.1.20 NL-07-153 Audit Items Enhance the Metal-Enclosed Bus Inspection Program IP3: 124, for IP2 and IP3 to visually inspect the external surface December 12, NL-08-057 133, 519 of MEB enclosure assemblies for loss of material at 2015 least once every 10 years. The first inspection will occur prior to the period of extended operation and the acceptance criterion will be no significant loss of material.

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

Enhance the Metal-Enclosed Bus Inspection Program for IP2 and 1P3 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 P2: 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 IP3:

December 12,

_015

NL-11-101 Attachment 2 Page 9 of 18

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM 15 Implement the Non-EQ Inaccessible Medium-Voltage lP2: NL-07-039 A.2.1.22 Cable Program for IP2 and IP3 as described in LRA September 28, A.3.1.22 2013 B.1.23 Section B.1.23.

NL-07-153 Audit item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- December 12, NL-1 1-032 1801 Section XI.E3, Inaccessible Medium-Voltage 2015 PeweF Cables Not Subject To 10 CFR 50.49 NL-1 1-096 Environmental Qualification Requirements.

NL-1 1-101 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 SP2: NL-07-039 A.2.1.24 IP3 as described in September 28, Connections Program for IP2 and 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 015 Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.

18 Enhance the Oil Analysis Program for IP2 to sample 1P2: 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 the oil analysis for 013 NL-1 1-101 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-11-101 Attachment 2 Page 10 of 18 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM 19 Implement the One-Time Inspection Program for IP2 IP2: 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, 2_015 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*_013 IP2 and IP3 as necessary September 28, A.3.1.28 B.1 .29 to assure that the effects of aging will be managed such that applicable components will continue to 1P3:

perform their intended functions consistent with the IP3:

current licensing basis through the period of extended D b015 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 2013 B.1.32 cover the peak reactor vessel fluence expected IP3:

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

23 Implement the Selective Leaching Program for IP2 IP2: 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, 2015

NL-11-101 Attachment 2 Page 11 of 18 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION 1_ 1 1 1/ AUDIT ITEM Enhance the Structures Monitoring Program to IP2: NL-07-039 A.2.1.35 25 explicitly specify that the following structures are September 28, A.3.1.35 included in the program. 2013 B.1.36

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

  • Appendix R diesel generator fuel oil tank vault IP3: Audit items (IP3) December 12, 86, 87, 88,
  • Appendix R diesel generator switchgear and 2015 NL-08-057 417 enclosure (IP3)
  • city water storage tank foundation
  • condensate storage tanks foundation (IP3)

" containment access facility and annex (IP3)

  • discharge canal (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)
  • 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)
  • jib cranes
  • manholes and duct banks

" manways, hatches and hatch covers

  • monorails

NL-11-101 Attachment 2 Page 12 of 18 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION 1_ 1 1 / 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 NL-08-127 Audit Item groundwater samples to assess aggressiveness of 360 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 Audit Item of the water control structure once per 3 years rather 358 than the normal frequency of once per 5 years during the PEO.

NL-11-101 Attachment 2 Page 13 of 18 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 ACl 349.3R, "Evaluation of Existing Nuclear Safety-Related Concrete Structures" prior to the period of extended operation T-E-*. NL-1 1-101 26 Implement the Thermal Aging Embrittlement of Cast IP2: NL-07-039 A.2.1.36 Austenitic Stainless Steel (CASS) Program for IP2 September 28, A.3.1.36 and as described in LRA Section B.1.37. 013 2P3 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 P2: 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 B.1.38. IP3: 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 P2: NL-07-039 A.2.1.39 Cooling Water Program to maintain water chemistry of September 28, A.3.1.39 the IP2 SBO/Appendix R diesel generator cooling 013 B.1 .40 system per EPRI guidelines. NP3: 509 Enhance the Water Chemistry Control - Closed December 12, Cooling Water Program to maintain the IP2 and IP3 2015 security generator and fire protection diesel cooling water pH and glycol within limits specified by EPRI guidelines.

29 Enhance the Water Chemistry Control - Primary and IP2: NL-07-039 A.2.1.40 Secondary Program for IP2 to test sulfates monthly in September 28, B.1.41 the RWST with a limit of <150 ppb. 013 30 For aging management of the reactor vessel internals, P2: NL-07-039 A.2.1.41 IPEC will (1) participate in the industry programs for September 28, A.3.1.41 investigating and managing aging effects on reactor 011 internals; (2) evaluate and implement the results of lP3:

the industry programs as applicable to the reactor December 12, internals; and (3) upon completion of these programs, 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-11-101 Attachment 2 Page 14 of 18

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM 31 Additional P-T curves will be submitted as required P2: 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 2013 4.2.3 extended operation as part of the Reactor Vessel Surveillance Program. IP3:

December 12, 2015 32 As required by 10 CFR 50.61(b)(4), IP3 will submit a IP3: NL-07-039 A.3.2.1.4 plant-specific safety analysis for plate B2803-3 to the December 12, 4.2.5 NRC three years prior to reaching the RTpTs 2015 NL-08-127 screening criterion. Alternatively, the site may choose to implement the revised PTS rule when approved.

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

December 12, NL-08-021 (1) Consistent with the Fatigue Monitoring Program, 2013 Detection of Aging Effects, update the fatigue usage calculations using refined fatigue analyses to determine valid CUFs less than 1.0 when accounting Complete NL-10-082 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 CUE.

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

NL-11-101 Attachment 2 Page 15 of 18

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM 34 I P2 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 50.59tc_.(1) and, therefore, a NL-1 1 license amendment pursuant to 10 CFR 50.90 is not required.

IP2: IP2:NL-08-127 Audit Item 35 Perform a one-time inspection of representative 27 sample area of IP2 containment liner affected by the September 28, 1973 event behind the insulation, prior to entering the 013 period of extended peiied of operation, to assure liner degradation is not occurring in this area. NL-1 1-101 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 015 the period of extended peiied ef operation, to assure liner degradation is not occurring in this area.

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

iP2: NL-08-127 Audit 359Item 36 Perform a one-time inspection and evaluation of a Spt r NL-08-101 sample of potentially affected IP2 refueling cavity 2013 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 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 P2: NL-08-127 Audit 361Item 37 Enhance the Containment Inservice Inspection (CII- September 28, IWL) Program to include inspections of the 2013 containment using enhanced characterization of 013 degradation (i.e., quantifying the dimensions of noted lP3:

indications through the use of optical aids) during the December 12, period of extended operation. The enhancement 015 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.

NL-11-101 Attachment 2 Page 16 of 18

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ 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 P2: NL-09-106 B.1.6 operating experience and incorporate lessons learned September 28, B.1.22 in establishing appropriate monitoring and inspection 013 B.1.23 frequencies to assess aging effects for the new aging P3: B.1.25 management programs. Documentation of the operating experience evaluated for each new program December 12, B.1.27 will be available on site for NRC review prior to the 2015 .1.28 period of extended operation. B.1.37 B.1.38

___P2______NL-11-032 1 N/A 41 .P2: " of insect steam IPEC will poform an inspctin generators for both units to assess the condition of fter the the divider plate assembly. The examination beginning of the technique used will be capable of detecting PWSCC PEO and prior to in the steam generator divider plate assembly September 28, a6seimblie. The IP2 steam generator divider plate 023 NL-1 1-074 inspections will be completed within the first ten years IP3: NL-1 1-090 of the period of extended operation (PEO). The IP3 Prior to the end steam generator divider plate inspections will be f the first NL-1 1-101 completed within the first refueling outage following refueling outage the beginning of the PEO. following the beginning of the PEO.

NL-11-101 Attachment 2 Page 17 of 18 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION 1 1 1 4/ AUDIT ITEM NL-1 1-032 N/A 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.

Option 1 (Analysis)

IPEC will perform an analytical evaluation of the IP2: NL-1 1-074 steam generator tube-to-tubesheet welds in order to Prior to March establish a technical basis for either determining that 2024 NL-11-090 the tubesheet cladding and welds are not susceptible IP3: Prior to the to PWSCC, or redefining the pressure boundary in end of the first NL-1 1-096 which the tube-to-tubesheet weld is no longer refueling outage included and, therefore, is not required for reactor following the coolant pressure boundary function. The redefinition beginning of the of the reactor coolant pressure boundary must be PEO.

approved by the NRC as a license amendment request.

I P2:

Option 2 (Inspection)

Between March IPEC will perform a one-time inspection of a 2020 and March representative number of tube-to-tubesheet welds in 2024 each steam generator to determine if PWSCC cracking is present. If weld cracking is identified: 1P3: Prior to the

a. The condition will be resolved through repair end of the first or engineering evaluation to justify continued refueling outage service, as appropriate, and following the beginning of the
b. An ongoing monitoring program will be PEO.

established to perform routine tube-to-tubesheet weld inspections for the remaining life of the steam generators.

IP2: NL-1 1-032 4.3.3 43 IPEC will review design basis ASME Code Class 1 Prior to fatigue evaluations to determine whether the September 28, NUREG/CR-6260 locations that have been evaluated 2013 for the effects of the reactor coolant environment on NL-11-101 fatigue usage are the limiting locations for the IP2 and IP3: Prior to IP3 configurations. If more limiting locations are December 12, identified, the most limiting location will be evaluated 2015 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 allov, if anv.

NL-11-101 Attachment 2 Page 18 of 18 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM L~lh,n , ... NL-11-032 1 N/A 44 IPEC will include written explanation and justification W, ; .i

",, ' NL-1 1-101 of any user intervention in future evaluations using the W ESTEMS "Design CUF' module. t, .... ,;,1-0 IP2:

Prior to September 28, 2013 1P3: Prior to December 12, 2015 45 IPEC will not use the NB-3600 option of the .. N days.L-11-032 N/A WESTEMS program in future design calculations until ef NL-1 1-101 the issues identified during the NRC review of the program has have been resolved.

IP2:

Prior to September 28, 2013 IP3: Prior to December 12, 2015 IP2: 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 socket welds during each 10-year ISI interval September 28, NL-1 1-074 scheduled as specified by IWB-2412 of the ASME 013 Section Xl 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.

ATTACHMENT 3 TO NL-11-101 AMENDMENT 9 TO THE LICENSE RENEWAL APPLICATION (LRA)

REACTOR VESSEL INSPECTION PROGRAM ERRATA ENTERGY NUCLEAR OPERATIONS, INC.

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

NL-11-101 Attachment 3 Page 1 of 1 INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 AMMENMENT 9 TO LICENSE RENEWAL APPLICATION (LRA)

REACTOR VESSEL INSPECTION PROGRAM ERRATA The LRA is revised as described below. (underline - added, strikethrough - deleted)

NL-10-063 submitted Amendment 9 to the LRA - Reactor Vessel Internals Program, however, the update to Section 3.1.2.2.12 was inadvertently not included. The update is provided below.

3.1.2.2.12 Cracking due to Stress Corrosion Cracking and Irradiation-Assisted Stress Corrosion Cracking (IASCC)

Cracking due to SCC and IASCC '.uld occur in PWR stainless steel reactor internals exposed to reactor coolant will be managed by the Water Chemistry Control - Primary and Secondary and Reactor Vessel Internals (RVI) Programs. The RVI Program will implement the EPRI Pressurized Water Reactor Internals Inspection and Evaluation Guidelines, MRP- 227. The RVI Program will use nondestructive examinations (NDE) and other inspection methods to manage aging effects for reactor vessel internals. To mana..ge GFaGking in ...... intorntecalsmpononte, PEC. maintains the Watr Chemlitry Control Primsar'.and SGcondar;.

Programn and Will (1)participato inthe industry program~s for invostigating and m~anagingaigefco r.act.r intornals; (2) evaluate and implement the results of the industry programs.a. p lcbeo to the. .acto, aintornals; and (3)upon comRpletion of those programs, but net less than 24 moenths bcfore entering the period Of extended operation, submit an inspection plan for reactor internals to the NRC for review and approval. T-he IPEC com tmentt these RVI programns is inlue inFAR  ; Supplement, Appendix A, Sections A.2.1.41 adA-. 4r---

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