NL-17-053, Reply to Request for Additional Information for the Review of the Indian Point License Renewal Application RAI Set 2017-03 (CAC Nos. MD5407 and MD5408)

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Reply to Request for Additional Information for the Review of the Indian Point License Renewal Application RAI Set 2017-03 (CAC Nos. MD5407 and MD5408)
ML17143A234
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 05/18/2017
From: Vitale A
Entergy Nuclear Northeast, Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MD5407, CAC MD5408, NL-17-053
Download: ML17143A234 (32)
v • d • e


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Entergy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 254-6700 Anthony J Vitale Site Vice President NL-17-053 May 18, 2017 U.S. Nuclear Regulatory Commission Document Control Desk 11545 Rockville Pike, TWFN-2 F1 Rockville, MD 20852-2738

SUBJECT:

Reply to Request for Additional Information for the Review of the Indian Point License Renewal Application RAI SET 2017-03 (CAC Nos. MD5407 and MD5408) ,

Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64

REFERENCES:

1) USN RC letter, "Request for Additional Information for the Review of the Indian Point License Renewal Application SET 2017-03 (CAC Nos.

MD5407 and MD5408)," dated April 20, 2017

Dear Sir or Madam:

Entergy Nuclear Operations, Inc. (Entergy) is providing in Attachment 1, the additional information requested by the U.S. Nuclear Regulatory Commission (NRC) pertaining to the review of the License Renewal Application (LRA) for Indian Point Energy Center (IPEC) Unit Nos. 2 and 3. (Reference 1)

Changes to the List of Regulatory Commitments are provided in Attachment 2.

If you have any questions, or require additional information, please contact Mr. Robert Walpole at 914-254-6710.

~r ~ \

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

.2017.

NL-17-053 Docket Nos. 50-247 and 50-286 Page 2 of 2 Attachments: 1. Reply to NRC Request for Additional Information Regarding the License Renewal Application

2. License Renewal Application IPEC List of Regulatory Commitments Revision 32 cc: Mr. Daniel H. Dorman, Regional Administrator, NRC Region I Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel Mr. William Burton, NRC Senior Project Manager, Division of License Renewal Mr. Richard Guzman, NRR Senior Project Manager Ms. Bridget Frymire, New York State Department of Public Service Mr. John B. Rhodes, President and CEO NYSERDA NRC Resident Inspector's Office

ATTACHMENT 1 TO NL-17-053 1

RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE INDIAN POINT LICENSE RENEWAL APPLICATION RAI SET 2017-03 (CAC NOS. MD5407 AND MD5408)

ENTERGY NUCLEAR OPERATIONS, INC.

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

NL-17-053 Docket Nos. 50-247 and 50-286 Attachment 1 Page 1 of 6 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE INDIAN POINT LICENSE RENEWAL APPLICATION RAI SET 2017-03 (CAC NOS. MD5407 AND MD5408)

RAI B.1.2-1

Background

Section 54.21 (a)(3) of 10 CFR requires the applicant to demonstrate that the effects of aging for structures and components will be adequ?tely managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation. As described in SRP-LR, an applicant may demonstrate compliance with 10 CFR 54.21 (a)(3) by referencing the GALL Report and when evaluation of the matter in the GALL Report applies to the plant.

GALL Report AMP Xl.M18 states: \

Degradation of pressure boundary closure bolting due to crack initiation, loss of preload, or loss of material may result in leakage from the mating surfaces or joint connections of pressure boundary components. Periodic inspection of pressure boundary components for signs of leakage ensures that age-related degradation of closure bolting is detected and corrected before component leakage becomes excessive. Accordingly, pressure retaining bolted connections should be inspected at least once per refueling ~ycle.

LRA Section B.1.2 states that the Bolting Integrity Program includes "periodic inspection of closure bolting for signs of leakage that may be due to ... loss of preload." However, from its review of the program implementing document during the onsite audit, the staff determined that the program did not appear to manage loss of preload. The staff identified this concern in Audit Items 241 and 270. In response to Audit Items 241 and 270, by letter dated December 18, 2007, the applicant stated that the program will manage loss of preload. The applicant revised LRA Table 3.4.1, Item 3.4.1-22, Table 3.3.1, Item 3.3.1-45, and Table 3.2.1, Item 3.2.1-24, to state "the Bolting Integrity Program manages loss of preload for all bolting" in the respective systems. In addition, the applicant revised'Commitment #2 to state "[t]he Bolting Integrity Program manages loss of preload and loss of material for all external bolting."

It is not clear what methods will be used to detect leakage that would indicate loss of preload of Closure bolting. If visual inspections will be used, the staff notes that while visual inspections would be capable of detecting leakage of liquid-filled systems, visual inspection may not be sufficient to detect leakage for air- or gas-filled systems.

NL-17-053 Docket Nos. 50-247 and 50-286 Attachment 1 Page 2 of 6 LRA Table 3.3.2-4-IP2 (and IP3), "Compressed Air System," is an example of a system that cites the Bolting Integrity Program to manage aging effects associated with closure bolting that could be or are air-filled or gas-filled. Based on a review of LRA Section B.1.2 and SER Section 3.0.3.2.2, "Bolting Integrity," it is not clear how aging effects for closure bolting installed in air-filled or gas-filled systems will be effectively managed because in these systems there is typically limited or no visual signs of leakage.

Request

1. List theJn-scope systems that have portions that are air-filled and gas-filled for which aging effects associated with closure bolting are being managed by the

- Bolting Integrity Program.

Response

The systems listed below credit the Bolting Integrity Program and have components that contain a clear gas, such as air or nitrogen.

  • Containment Isolation
  • Safety Injection
  • Plant Drains
  • Compressed Air
  • Heating, Ventilation, and Air Conditioning
  • Fire Protection - Water

"

  • Security Generators
  • Fire Protection
  • Indian Point 2 Station Blackout and Appendix R Diesel Generator
  • Fuel Oil
  • Indian Point 3 Appendix R Diesel Generator
  • MainSteam
  • Containment Cooling and Filtration
  • Control Room HVAC Many systems are in the scope of license renewal and subject to aging management review only for 10 CFR 54.4(a)(2), that is, for the potential of nonsafety-related components to adversely impact the ability of safety-related equipment to perform its safety functions. Leakage from gas-containing portions of these systems would not be a threat to safety-related systems or compone1nts. Those portions of systems would be subject to aging management review because they have a license renewal intended function of structural support.

NL-17-053 Docket Nos. 50-247 and 50-286 Attachment 1 Page 3 of 6 Request

2. State how the aging effects will be managed.

Response

To manage the effects of aging, the Bolting Integrity Program includes preventive measures, which include material selection (e.g., use of materials with an actual yield strength of less than 150 kilo-pounds per square inch [ksi]), lubricant selection (e.g., restricting the use of molybdenum disulfide), applying the appropriate preload (torque), and checking for uniformity of gasket compression. Application of these preventive measures in accordance with industry standards is expected to preclude loss of preload, loss of material, and cracking. If these preventive measures were ineffective, system leakage would be noted. Corrective actions addressing preventive measures would then apply to bolted closures, in general including those serving in systems containing gases.

The review of IPEC operating experience did not identify events where components became unable to perform license renewal intended functions due to loss of pressure boundary bolting preload in clear gas, such as air or nitrogen environments.

In addition to preventive measures to preclude leakage, the Bolting Integrity Program provides for identification of leakage from bolted closures during periodic inspections conducted during system walkdowns. Other plant personnel may also identify leakage during routine maintenance and operational activities. During these inspections and other activities, personnel can identify leakage from bolted closures througb_yisual and audible indications. Visual indications can include residue on nearby components and, in the case of steam systems, a visible plume or condensation in the area of the leak. Audible indications that could indicate a leak are the sounds of leaking gaseous contents escaping from the system. In addition, system engineers review operations logs, deficiency lists, and system parameters such as pressure, flow, and temperature which could indicate a system leak.

Based on these activities and considerations, signs of leakage of clear gaseous fluids are detected from bolted closures included in the Bolting Integrity Program, and ensure that the

' detection of loss of material and loss of preload occur before there is a loss of intended function.

Request

3. State any enhancements to plant-specific procedures and/or to the Bolting Integrity Program necessary to incorporate how these aging effects are managed.

Response

To provide additional assurance of the adequate management of the effects of aging on bolting, the Bolting Integrity Program will be revised to include visual inspection of a representative sample of closure bolting (bolt heads, nuts, and threads) from components with an internal environment of a clear gas, such as air or nitrogen. A representative sample will be 20 percent of the population up to a maximum of 25 fasteners (for each bolting material and environment combination) during each 10-year period of the period of extended operation. The inspections

NL-17-053 Docket Nos. 50-247 and 50-286 Attachment 1 Page 4 of 6 will be performed when the bolting is removed to the extent that the bolting threads and bolt heads are accessible for inspections that cannot be performed during visual inspection with the threaded fastener installed.

The LRA is revised as follows. Additions are underlined and deletions are lined through.

A.2.1.2 Bolting Integrity Program The Bolting Integrity Program is an existing program that relies on recommendations for a comprehensive bolting integrity program, as delineated in NUREG-1339, industry recommendations, and Electric Power Research Institute (EPRI) NP-5769, with the exceptions noted in NUREG-1339 for safety-related bolting. The program relies on industry recommendations for compreh.ensive bolting maintenance, as delineated in EPRI TR-104213 for pressure retaining bolting ahd structural bolting.

The program applies to bolting and torquing practices of safety- and nonsafety-related bolting for pressure retaining components, NSSS component supports, and structural joints. The program addresses all bolting regardless of size except reactor head closure studs, which are addressed by the Reactor Head Closure Studs Program. The program includes periodic inspection of closure bolting for signs of leakage that may be due to crack initiation, loss of preload, or loss of material due to corrosion. The program also includ~s preventive measures to preclude or minimize loss of preload and cracking, which include use of actual yield strength in selecting materials for low susceptibility to sec and a prohibition on the use of lubricants containing MoS2 for bolting.

The Bolting Integrity Program will be enhanced to include the following.

  • Revise applisable prosedures to slarify that astual yield strength is used in selesting materials for low susseptibility to sec and to slarify the prohibition on use of lubrisants sontaining Mos~ for bolting.

Enhansements will be implemented prior to the period of extended operation.

  • Revise Bolting Integrity Program documents to specify visual inspection of a representative sample of closure bolting (bolt heads. nuts. and threads) from components with an internal environment of a clear gas. such as air or nitrogen. A representative sample will be 20 percent of the population up to a maximum of 25 fasteners (for each bolting material and environment combination) during each 10-year period of the period of extended operation.

The inspections will be performed when the bolting is removed to the extent that the bolting threads and bolt heads are accessible for inspections that cannot be performed during visual inspection with the threaded fastener installed.

A.3.1.2 Bolting Integrity Program The Bolting Integrity Program is an existing program that relies on recommendations for a comprehensive bolting integrity program, as delineated in NUREG-1339, industry recommendations, and Electric Power Research Institute (EPRI) NP-5769, with the exceptions noted in NUREG-1339 for safety-related bolting. The program relies on industry

NL-17-053 Docket Nos. 50-24 7 and 50-286 Attachment 1 Page 5 of 6 recommendations for comprehensive bolting maintenance, as delineated in EPRI TR-104213 for pressure retaining bolting and structural bolting.

The program applies to bolting and torquing practices of safety- and non-safety-related bolting for pressure retaining components, NSSS component supports, and structural joints. The program addresses all bolting regardless of size except reactor head closure studs, which are addressed by the Reactor Head Closure Studs Program. The program includes periodic inspection of closure bolting for signs of leakage that may be due to crack initiation, loss of prelo-ad, or loss of material due to corrosion. The program also includes preventive measures to preclude or minimize loss of preload and cracking. which include use of actual yield strength in selecting materials for low susceptibility to SCC and a prohibition on the use of lubricants containing Mos, for bolting.

The Bolting Integrity Program will be enhanced to include the following.

  • Revise applicable procedures to clarify that actual yield strength is used in selecting materials for 101.v susceptibility to sec and to clarify the prohibition on use of lubricants containing MoS2 for bolting.

Enhancements 1.vill be implemented prior to the period of extended operation.

  • Revise Bolting Integrity Program documents to specify visual inspection of a representative sample of closure bolting (bolt heads. nuts. and threads) from components with an internal environment of a clear gas. such as air or nitrogen. A representative sample will be 20 percent of the population up to a maximum of 25 fasteners (for each bolting material and environment combination) during each 10-year period of the period of extended operation.

The inspections will be performed when the bolting is removed to the extent that the bolting threads and bolt heads are accessible for inspections that cannot be performed during visual inspection with the threaded fastener installed.

B.1.2 BOLTING INTEGRITY Enhancements The following enhancement will be implemented prior to May 31. 2018.

NL-17-053 Docket Nos. 50-247 and 50-286 Attachment 1 Page 6 of 6 Attributes Affected Enhancements

4. Detection of Aging Effects Revise Bolting Integrity Program documents to sgecify visual insgection of a regresentative samgle of closure bolting (bolt heads, nuts, and threads) from comgonents with an internal environment of a clear gas, such as air or nitrogen. A regresentative samgle will be 20 12ercent of ,

the 12012ulation u12 to a maximum of 25 fasteners (for each bolting material and environment combination) during each 10-year geriod of the geriod of extended ogeration. The insgections will be gerformed when the bolting is removed to the extent that the bolting threads and bolt heads are accessible for insgections that

,

cannot be gerformed during visual insgection with the threaded fastener installed.

\

ATTACHMENT 2 TO NL-17-053 LICENSE RENEWAL APPLICATION IPEC LIST OF REGULATORY COMMITMENTS Rev.32 ENTERGY NUCLEAR OPERATIONS, INC.

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

NL-17-053' Attachment 2 Page 1 of 22 List of Regulatory Commitments Rev. 32 The following table identifies those actions committed to by Entergy in this document.

Changes are s.hoVl(n as strikethroughs for deletions and underlines for additions.

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM IP2: Complete NL-07-039 A.2.1.1 1 Enhance the Aboveground Steel Tanks Program for A.3.1.1 IP2 and IP3 to perform thickness measurements of NL-13-122 B.1.1 the bottom surfaces of the condensate storage tanks, city water tank, and fire water tanks once during the first ten years of the period of extended operation.

Enhance the Aboveground Steel Tanks Program for IP2 and IP3 to require trending of thickness measurements when material loss is detected.

IP2 & IP3: NL-14-147 A.2.1.1 Implement LRA Sections, A.2.1.1, A.3.1.1 and B.1.1, December 31, 2019 A.3.1.1 as shown in NL-14-147.

B.1.1 IP2 & IP3: NL-15-092 A.2.1.1 Implement LRA Sections, A.2.1.1 and B.1.1, as December 31, 2019 B.1.1 shown in NL-15-092 )

'

IP2: Complete NL-07-039 A.2.1.2 2 Enhance the Bolting Integrity Program for IP2 and A.3.1.2 IP3 to clarify that actual yield strength is used in IP3: Complete B.1.2 selecting materials for low susceptibility to sec and clarify the prohibition on use of lubricants containing NL-07-153 Audit Items MoS 2 for bolting.

201, 241, The Bolting Integrity Program manages loss of NL-13-122 270 preload and loss of material for all external bolting.

NL-17-053 Attachment 2 Page 2 of 22

  1. !

COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM IP2: Complete NL-07-039 A.2.1.5 3 Implement the Buried Piping and Tanks Inspection A.3.1.5 Program for IP2 and IP3 as described in LRA IP3: Complete NL-13-122 B.1.6 Section B.1.6.

NL-07-153 Audit Item This new program will be implemented consistent NL-15-121 173 with the corresponding program described in NUREG-1801 Section Xl.M34, Buried Piping and Tanks 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 inspection technique~ with demonstrated effectiveness. NL-11-101 4 Enhance the Diesel Fuel Monitoring Program to IP2:. Complete NL-07-039 A.2.1.8 include cleaning and inspection of the IP2 GT-1 gas A.3.1.8 IP3: Complete NL-13-122 B.1.9 turbine fuel oil storage tanks, IP2 and IP3 EOG fuel NL-07-153 Audit items oil day tanks, IP2 SBC/Appendix R diesel generator NL-15-121 128, 129, fuel oil day tank, and IP3 Appendix R fuel oil storage tank and day tank once every ten years. 132, 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 1Omg/I. Water and sediment acceptance criterion will be less than or eaual to 0.05%.

NL-17-053 Attachment 2 Page 3 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA

'

. SECTION I AUDIT ITEM Enhance the Diesel Fuel Monitoring Program to include thickness measurement of the bottom of the following tanks once every ten years. IP2: EOG fuel oil storage tanks, EOG fuel oil day tanks, SBC/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: EOG fuel oil day tanks, EOG 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 bioloqical activity is confirmed.

IP2: Complete NL-07-039 A.2.1.10 5 Enhance the External Surfaces Monitoring Program A.3.1.10 for IP2 and IP3 to include periodic inspections of NL-13-122 8.1.11 systems in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4(a)(1) and (a)(3). Inspections shall include areas surrounding the subject systems to identify '1 hazards to those systems. Inspections of nearby systems that could impact the subject systems will include SSCs that are in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4(a)(2).

)

'l NL-17-053 Attachment 2 Page 4 of 22

  1. COMMITMENT *IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM IP2 & IP3: NL-14-147 A.2.1.10 Implement LRA Se~tions A.2.1.10, A.3.1.1 O and December 31, 2019 A.3.1.10 8.1.11, as shown in NL-14-147.

8.1.11 IP2: Complete NL-07-039 A.2.1.11 6 Enhance the Fatigue Monitoring Program for IP2 to A.3.1.11 monitor steady state cycles and feedwater cycles or NL-13-122 8.1.12, perform an evaluation to determine monitoring is not NL-07-153 Audit Item required. Review the number of allowed events and 164 resolve discrepancies between reference documents IP3: Complete NL-15-121 and monitoring procedures.

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

IP2: Complete NL-07-039 A.2.1.12 7 Enhance the Fire Protection Program to inspect A.3.1.12 external surfaces of the IP3 RCP oil collection IP3: Complete NL-13-122 8.1.1.3 systems for loss of material each refueling cycle.

Enhance the Fire Protection Program to explicitly NL-15-121 state that the IP2 and IP3 diesel fire pump engine sub-systems (including the fuel supply line) shall be observed while the pump is running. Acceptance criteria will be revised to verify that the diesel engine does not exhibit signs of degradation while running; such as fuel oil, lube oil, coolant, or exhaust gas leakage.

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

Enhance the Fire Protection Program for IP3 to

.,visually inspect the cable spreading room, 480V switchgear room, and EOG room C0 2 fire suppression system for signs of degradation, such as corrosion and mechanical damage at least once everv six months.

NL-17-053 Attachment 2 Page 5 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM IP2: Complete NL-07-039 A.2.1.13 8 Enhance the Fire Water Program to include A.3.1.13 inspection of IP2 and IP3 hose reels for evidence of NL-13-122 B.1.14 corrosion. Acceptance criteria will be revised to NL-07-153 Audit Items verify no unacceptable signs of degradation.

\

105, 106 Enhance the Fire Water Program to replace all or NL-08-014 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 th.e 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 sianificant corrosion.

IP2 & IP3: NL-14-147 A.2.1.13 Implement LRA Sections, A.2.1.13, A.3.1.13 and B.1.14, as shown in NL-14-147. December 31, 2019 A.3.1.13 B.1.14 IP2 & IP3: NL-15-019 A.2.1.13 Implement LRA Sections A.2.1.13, A.3.1.13 and B.1.14, as shown in NL-15-019 December 31, 2019 A.3.1.13 B.1.14 IP2 & IP3: NL-15-092 A.2.1.13 Implement LRA Sections A.2.1.13, A.3.1.13 and B.1.14, as shown in NL-15-092 December 31, 2019 A.3.1.13 B.1.14

~

NL-17-053 Attachment 2 Page 6 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM IP2 & IP3: NL-17-052 A.2.1.13 Implement LRA Sections A.2.1.13, A.3.1.13, and December 31, 2017 A.3.1.13 B.1.14, as shown in NL-17-052 B.1.14 IP2: Complete NL-07-039 A.2.1.15 9 Enhance the Flux Thimble Tube Inspection Program A.3.1.15 for IP2 and IP3 to implement comparisons to wear IP3: Complete NL-13-122 B.1.16 rates identified in WCAP-12866. Include provisions NL-15-121 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.

NL-17-053 Attachment 2 Page 7 of 22 '

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT

/

ITEM IP2: Complete NL-07-039 A.2.1.16 10 Enhance the Heat Exchanger Monitoring Program A.3.1.16 for IP2 and IP3 to include the following heat IP3: Complete NL-13-122 8.1.17, exchangers in the scope of the program.

NL-07-153 Audit Item

  • RHR heat exchangers
  • RHR pump seal coolers
  • Non-regenerative heat exchangers
  • Charging pump seal water heat exchangers
  • Cha_rging pump fluid drive coolers
  • Charging pump crankcase oil coolers
  • Spent fuel pit heat exchangers
  • Waste gas compressor heat exchangers
  • SBC/Appendix R diesel jacket water heat J 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.

NL-09-018

--- - -- ----- - - - - -

NL-17-053 Attachment 2 Page 8 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM NL-09-056 11 Deleted NL-11-101 IP2: Complete NL-07-039 A.2.1.18 12 Enhance the Masonry Wall Program for IP2 and IP3 A.3.1.18 to specify that the IP1 intake structure is included in the program. IP3: Complete NL-13-122 B.1.19 IP2: Complete NL-07-039 A.2.1.19 13 Enhance the Metal-Enclosed Bus Inspection A.3.1.19 Program for IP2 and IP3 to visually inspect the IP3: Complete NL-13-122 B.1.20 external surface of MEB enclosure assemblies for NL-07-153 Audit Items loss of material at least once every 10 years. The first inspection will occur prior to the period of NL-15-121 124,
  • NL-08-057 133, 519 extended operation and the acceptance criterion will be no significant loss of material.

NL-13-077 Enhance the Metal-Enclosed Bus Inspection Program to add acceptance criteria for MEB internal visual inspections to include the absence of indications of dust accumulation on the bus bar, on -

the insulators, and in the duct, in addition to the absence of indications of moisture intrusion into the duct.

Enhance the Metal-Enclosed Bus Inspection Program for IP2 and IP3 to inspect bolted connections at least once every five years if performed visually or at least once every ten years using quantitative measurements such as thermography or contact resistance measurements.

The first inspection will occur prior to the period of extended operation.

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

14 IP2: Complete NL-07-039 A.2.1.21 Implement the Non-EQ Bolted Cable Connections Program for IP2 and IP3 as described in LRA A.3.1.21 Section B.1.22. IP3: Complete NL-13-122 B.1.22 NL-15-121

NL-17-053 Attachment 2

Page 9 of 22
  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM IP2: Complete NL-07-039 A.2.1.22 15 Implement the Non-EQ Inaccessible Medium-A.3.1.22 Voltage Cable Program for IP2 and IP3 as described IP3: Complete NL-13-122 8.1.23 in LRA Section 8.1.23.

NL-07-153 Audit item This new program will be implemented consistent NL-15-121 173 with the corresponding program described in NL-11-032 NUREG-1801 Section Xl.E3, Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 NL-11-096 Environmental Qualification Requirements.

NL-11-101 IP2: Complete NL-07-039 A.2.1.23 16 Implement the Non-EQ Instrumentation Circuits Test A.3.1.23 Review Program for IP2 and IP3 as described in IP3: Complete NL-13-122 8.1.24 LRA Section 8.1.24.

NL-07-153 Audit item This new program will be implemented cdnsistent NL-15-121 173 with the corresponding program described in NUREG-1801 Section Xl.E2, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits.

IP2: Complete NL-07-039 A.2.1.24 17 Implement the Non-EQ Insulated Cables and A.3.1.24 Connections Program for IP2 and IP3 as described IP3: Complete NL-13-122 8.1.25 in LRA Section 8.1.25.

NL-07-153 Audit item This new program will be implemented consistent NL-15-121 173 with the corresponding program described in NUREG-1801 Section Xl.E1, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.

NL-17-053 Attachment 2 Page 10 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM IP2: Complete NL-07-039 A.2.1.25 18 Enhance the Oil Analysis Program for IP2 to sample A.3.1.25 and analyze lubricating oil used in the SBO/Appendix IP3: Complete NL-13-122 B.1.26 R diesel generator consistent with the oil analysis for NL-11-101 other site diesel generators.

NL-15-121 Enhance the Oil Analysis Program for IP2 and IP3 to sample and analyze generator seal oil and turbine hydraulic control oil.

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

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

IP2: Complete NL-07-039 A.2.1.26 19 Implement the One-Time Inspection Program for IP2 A.3.1.26 and IP3 as described in LRA Section\B.1.__27.

IP3: Complete NL-13-122 B.1.27 This new program will be implemented consistent NL-07-153 Audit item with the corresponding program described in NL-15-121 173 NUREG-1801, Section Xl.M32, One-Time Inspection.

IP2: Complete NL-07-039 A.2.1.27 20 Implement the One-Time Inspection - Small Bore A.3.1.27 Piping Program for IP2 and IP3 as described in LRA IP3: Complete NL-13-122 B.1.28 Section B.1.28.

NL-07-153 Audit item This new program will be implemented consistent NL-15-121 173 with the corresponding program described in NUREG-1801, Section Xl.M35, One-Time Inspection of ASME Code Class I Small-Bore Piping.

IP2: Complete NL-07-039 A.2.1.28 21 Enhance the Periodic Surveillance and Preventive A.3.1.28 Maintenance Program for IP2 and IP3 as necessary IP3: Complete NL-13-122 B.1.29 to assure that the effects of aging will be managed NL-15-121 such that applicable components will continue to perform their intended functions consistent with the current licensing basis through the period of extended operation.

NL-17-053 Attachment 2 Page 11 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA

,

SECTION I AUDIT ITEM IP2 & IP3: ,NL-17-052 A.2.1.28 Implement LRA Sections A.2.1.28, A.3.1.28 and I

December 31, 2017 A.3.1.28 B.1.29, as shown in NL-17-052 B.1.29 IP2: Complete NL-07-039 A.2.1.31 22 Enhance the Reactor Vessel Surveillance Program

- for IP2 and IP3 revising the specimen capsule 1

A.3.1.31 IP3: Complete NL-13-122 B.1.32 withdrawal schedules to draw and test a standby NL-15-121 capsule to cover the peak reactor vessel fluence expected through the end of the period of extended I operation.

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

IP2: Complete NL-07-039 A.2.1.32 23 Implement the Selective leaching Program for IP2 A.3.1.32 and IP3 as described in LRA Section B.1.33.

IP3: Complete NL-13-122 B.1.33 This new program will be implemented consistent NL-07-153 Audit item with the corresponding program described in NL-15-121 173 NUREG-1801, Section Xl.M33 Selective Leaching of Materials.

IP2: Complete NL-07-039 A.2.1.34 24 Enhance the Steam Generator Integrity Program for A.3.1.34 IP2 and IP3 to require that the results of the IP3: Complete NL-13-122 B.1.35 condition monitoring assessment are compared to the operational assessm_ent performed for the prior operatina cvcle with differences evaluated.

Enhance the Structures Monitoring Program to IP2: Complete NL-07-039 A.2.1.35 25 explicitly specify that the following structures are A.3.1.35 included in the program. IP3: Complete NL-13-122 B.1.36

  • Appendix R diesel generator foundation (IP3) NL-07-153
  • Appendix R diesel generator fuel oil tank vault NL-15-121 Audit items (IP3) 86, 87, 88,
  • Appendix R diesel generator switchgear and NL-08-057 417 enclosure (IP3)
  • 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 '

)

NL-17-053 Attachment 2 Page 12 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ,

ITEM

  • maintenance and outage building-elevated passageway (I P2)
  • new station security building (IP2)
  • nuclear service building (IP1)
  • primary water storage tank foundation (IP3) e\ refueling water storage tank foundation (IP3)
  • security access and office building (IP3)
  • transformer/switchyard support structures (IP2)

NL-14-146

  • 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 I
  • cranes, rails and girders
  • equipment pads and foundations
  • fire proofing (pyrocrete)
  • jib cranes
  • manholes and duct banks
  • manways, hatches and hatch covers
  • monorails
  • new fuel storage racks
  • sumps NL-13-077 Enhance the Structures Monitoring Program for IP2 and IP3 to inspect inaccessible concrete areas that are exposed by excavation I 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,

NL-17-053 Attachment 2 Page 13 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM 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.

I 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 NL-08-127 Audit Item from at least 5 wells that are representative of the 360 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. Audit Item 358 Enhance the Structures Monitoring Program to include more detailed quantitative acceptance criteria for inspections of concrete structures in accordance with ACI 349.3R, "Evaluation of Existing Nuclear Safety-Related Concrete Structures" prior to the period of extended operation. NL-11-032

'NL-11-101

NL-17-053 Attachment 2 Page 14 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM IP2: Complete NL-07-039 A.2.1.36 26 Implement the Thermal Aging Embrittlement of Cast A.3.1.36 Austenitic Stainless Steel (CASS) Program for IP2 IP3: Complete NL-13-122 B.1.37 and IP3 as described in LRA Section B.1.37.

NL-07-153 Audit item This new program will be implemented consistent NL-15-121 173 with the corresponding program described in NUR~G-1801, Section Xl.M12, Thermal Aging Embnttlement of Cast Austenitic Stainless Steel (CASS) Program.

IP2: Complete NL-07-039 A.2.1.37 27 Implement the Thermal Aging and Neutron A.3.1.37 Irradiation Embrittlement of Cast Austenitic Stainless IP3: Complete NL-13-122 B.1.38 Steel (CASS) Program for IP2 and IP3 as described NL-07-153 Audit item in LRA Section B.1.38.

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

IP2: Complete NL-07-039 A.2.1.39 28 Enhance the Water Chemistry Control - Closed A.3.1.39 Cooling Water Program to maintain water chemistry IP3: Complete NL-13-122 8.1.40 of the IP2 SBC/Appendix R diesel generator cooling NL-08-057 Audit item system per EPRI guidelines.

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

" Control - Primary and IP2: Complete NL-07-039 A.2.1.40 29 Enhance the Water Chemistry 8.1.41

~econdary Program for IP2 to test sulfates monthly NL-13-122 in the RWST with a limit of <150 opb.

IP2: Complete NL-07-039 A.2.1.41 30 For aging management of the reactor vessel A.3.1.41 internals, IPEC will (1) participate in the industry IP3: Complete NL-13-122 programs for investigating and managing aging effects on reactor internals; (2) evaluate and impl~ment the results of the industry programs as applicable to the reactor internals; and (3) upon completion of these programs, but not less than 24 months before entering the period of extended NL-11-107 operation, submit an inspection plan for reactor internals to the NRC for review and approval.

'

NL-17-053 Attachment 2 Page 15 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA I

SECTION I AUDIT ITEM IP2: Complete NL-07-039 A.2.2.1.2 31 Additional P-T curves will be submitted as required A.3.2.1.2 per 10 CFR 50, Appendix G prior to the period of IP3: Complete NL-13-122 4.2.3 extended operation as part of the Reactor Vessel NL-15-121 Surveillance Program.

As required by 10 CFR 50.61 (b)(4), IP3 will submit a IP3: NL-07-039 A.3.2.1.4 32 plant-specific safety analysis for plate 82803-3 to the ~pproximately 6 NL-07-140 4.2.5 NRC three years prior to reaching the RT PTs ~ears after entering NL-08-014 screening criterion. Alternatively, the site may he PEO NL-08-127 choose to implement the revised PTS rule when approved.

,.

I

NL-17-053 Attachment 2 Page 16 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM 33 IP2: Complete NL-07-039 A.2.2.2.3 At least 2 years prior to entering the period of extended operation, for the locations identified in A.3.2.2.3 IP3: Complete NL-13-122 4.3.3 LRA Table 4.3-13 (IP2) and LRA Table 4.3-14 (IP3),

under the Fatigue Monitoring Program, IP2 and IP3 NL-07-153 Audit item will implement one or more of the following: 146 NL-08-021 (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 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 NRG-approved version of the ASME code or NRG-approved alternative (e.g., NRG-approved code case) may be performed to determine a valid CUF.

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

34 Complete NL-13-122 2.1.1.3.5 IP2 SBO I Appendix R diesel generator will be installed and operational by April 30, 2008. This NL-07-078 committed change to the facility meets the requirements of 10 CFR 50.59(c)(1) and, therefore, a NL-08-074 license amendment pursuant to 10 CFR 50.90 is not reauired. NL-11-101

NL-17-053 Attachment 2 Page 17 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT l

ITEM IP2: Complete NL-08-127 Audit Item 35 Perform a one-time inspection of representative 27 sample area of IP2 containment liner affecte'd by the NL-13-122 1973 event behind the insulation, prior to entering the period of extended operation, to assure liner IP3: Complete degradation is not occurring in this area.

NL-11-101 Perform a one-time inspection of representative NL-15-121 sample area of the IP3 containment steel liner at the juncture with the concrete floor slab, pripr to entering the period of extended 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: Complete NL-08-127 Audit Item 36 Perform a one-time inspection and evaluation of a NL-11-101 359 sample of potentially affected IP2 refueling cavity NL-13-122 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 leakaoe fluid will be analyzed.

IP2: Complete NL-08-127 Audit Item 37 Enhance the Containment lnservice Inspection (Cll-IWL) Program to include inspections of the 361 IP3: Complete NL-13-122 containme,nt using enhanced characterization of degradation (i.e., quantifying the dimensions of noted indications through the use of optical aids) during the period of extended operation. The enhancement includes obtaining critical dimensional data of degradation where possible through direct measurement or the use of scaling technologies for photographs, and the use of consistent vantage points for visual inspections.

NL-17-053 Attachment 2 Page 18 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA

' SECTION I AUDIT ITEM IP2: Complete NL-08-143 4.2.1 38 For Reactor Vessel Fluence, should future core loading patterns invalidate the basis for the projected IP3: Complete NL-13-122 values of RTpts or CvUSE, updated calculations will NL-15-121 be provided to the NRC.

NL-09-079 39 Deleted

. 40 IP2: Complete NL-09-106 B.1.6 Evaluate plant specific and appropriate industry B.1.22

  • I< operating experience and incorporate lessons IP3: Complete NL-13-122 B.1.23

~earne~ in establishing appropriate monitoring and NL-15-121 B.1.24 inspect~on frequencies to assess aging effects for the B.1.25 new aging management programs. Documentation B.1.27 of the operating experience evaluated for each new B.1.28 program will be available on site for NRC review B.1.33 prior to the period of extended operation.

B.1.37 B.1.38 NL-17-005 N/A 41 Deleted

NL-17-053 Attachment 2 Page 19 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA I,

SECTION I

'AUDIT ITEM NL-11-032 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: Complete NL-11-074 steam generator tube-to-tubesheet welds in order to establish a technical basis for either determining that the tubesheet cladding and welds are not susceptible IP3: Complete NL-11-090 to PWSCC, or redefining the pressure boundary in which the tube-to-tubesheet weld is no longer NL-11-096 included and, therefore, is not required for reactor coolant pressure boundary function. The redefinition IP2: NL-17-005 of the reactor coolant pressure boundary must be Not Applicable approved by the NRC as a license amendment request. IP3: Not Applicable Option 2 (Inspection)

IPEC will perform a one-time inspection of a

\

representative number of tube-to-tubesheet welds in each steam generate~ 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.

NL-17-053 Attachment 2 Page 20 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA I

SECTION I AUDIT ITEM IP2: Complete NL-11-032 4.3.3 43 IPEC will review design basis ASME Code Class 1 fatigue evaluations to determine whether the co IP3: Complete NUREG/CR-6260 locations that have been NL~13-122 evaluated for the effects of the reactor coolant NL-11-101 environment on fatigue usage are the limiting NL-15-121 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 reactpr 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: Complete NL-11-032 N/A 44 IPEC will include written explanation and justification of any user intervention in future evaluations using IP3: Complete NL-11-101 the WESTEMS "Design CUF" module.

NL-13-122 NL-15-121 IP2:Complete NL-11-032 N/A 45 IPEC will not use the NB-3600 option of the WESTEMS program in future design calculations IP3: Complete NL-11-101 until the issues identified during the NRC review of NL-13-122 the program have been resolved.

NL-15-121 IP2: Complete NL-11-032 N/A 46 Include in the IP2 ISi Program that IPEC will perform twenty-five volumetric weld metal inspections of NL-11-074 socket welds during each 10-year ISi interval NL-13-122 scheduled as specified by IWB-2412 of the ASME Section XI Code during the period of extended operation.

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

47 Deleted. NL-14-093 N/A

NL-17-053 Attachment 2 Page 21of22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM IP2: Complete NL-12-174 N/A 48 Entergy will visually inspect IPEC underground piping within the scope of license renewal and IP3: Complete subject to aging management review prior to the NL-13-122 period of extended operation and then on a NL-15-121 frequency of at least once every two years during the period of extended operation. This inspection frequency will be maintained unless the piping is subsequently coated in accordance with the preventive actions specified in NUREG-1801 Section Xl.M41 as modified by LR-ISG-2011-03. Visual inspections will be supplemented with surface or volumetric non-destructive testing if indications of significant loss of material are observed. Consistent with revised NUREG-1801 SectionXl.M41, such adverse indications will be entered into the plant corrective action program for evaluation of extent of condition and for determination of appropriate corrective actions (e.g., increased inspection frequency, repair, replacement).

IP2t Complete NL-13-052 A.2.2.2 49 Recalculate each of the limiting CUFs provided in A.3.2.2 section 4.3 of the LRA for the reactor vessel internals IP3l Complete to include the reactor coolant environment effects NL-13-122 (Fen) as provided in the IPEC Fatigue Monitoring NL-15-121 Program using NUREG/CR-5704 or NUREG/CR-6909. In accordance with the corrective actions specified in the Fatigue Monitoring Program, corrective actions include further CUF re-analysis, and/or repair or replacement of the affected components prior to the CUFen reaching 1.0.

Replace the IP2 split pins during the 2016 IP2r Complete NL-13-122 A.2.1.41 50 refueling outage (2R22). 8.1.42 IP3l N/A NL-14-067 r

IP21& IP3: NL-14-147 A.2.1.33 51 Enhance the Service Water Integrity Program by DeGember 31, 2017 A.3.1.33 implementing LRA Sections A.2.1.33, A.3.1.33 and 8.1.34 8.1.34, as shown in NL-14-147.

I IP2j& IP3: NL-17-052 A.2.1.33 Implement LRA Sections A.2.1.33, A.3.1.33 and DeGember 31, 2017 A.3.1.33 8.1.34, as shown in NL-17-052 8.1.34

NL-17-053 Attachment 2 Page 22 of 22

  1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM IP2 & IP3: NL-15-019 A.2.1.42 52 Implement the Coating Integrity Program for IP2 and December 31, 2024 A.3.1.42 IP3 as described in LRA Section 8.1.42, as shown in 8.1.43 NL-15-019.

Mav 31 2018 NL-17-053 A.2.1.2 53 Revise Bolting Integrity Program to include visual A.3.1.2 insgection of a regresentative samgle of closure (

8.1.2 bolting {bolt heads, nuts, and threads} from comgonents with an internal environment of a clear gas, such as air or nitrogen. A regresentative samgle will be 20 gercent of the gogulation {for each bolting material and environment combination} ug to a maximum of 25 fasteners during each 10-year geriod of the geriod of extended ogeration. The insgections will be gerformed when the bolting is removed to the extent that the bolting threads and bolt heads are accessible for insgections that cannot be gerformed during visual insgection with the threaded fastener installed.

I*

I I

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