RS-24-118, Enclosure B, License Renewal Commitment List Update
| ML24332A053 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 11/27/2024 |
| From: | Constellation Energy Generation |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML24332A050 | List: |
| References | |
| RS-24-118 | |
| Download: ML24332A053 (1) | |
Text
November 27, 2024 Enclosure B Page 1 of 13 Enclosure B Clinton License Renewal Commitment List Update Introduction This enclosure identifies commitments made in this document and is an update to the Clinton LRA Appendix A, Section A.5, License Renewal Commitment List. Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRCs information and are not regulatory commitments.
Changes to the Clinton LRA Appendix A, Section A.5, License Renewal Commitment List, are as a result of this LRA Supplement.
These Enclosure B pages are the same as the corresponding Clinton LRA Appendix A, Section A.5 pages included in Enclosure A.
To facilitate understanding, relevant portions of the previously submitted License Renewal Commitment List have been repeated in this Enclosure, with revisions indicated. Previously submitted information is shown in normal font. Additions due to this submittal are highlighted with bolded italics for inserted text, and strikethroughs for deleted text.
November 27, 2024 Enclosure B Page 2 of 13 LRA Appendix A, Section A.5, License Renewal Commitment List, Commitment 10, Flow-Accelerated Corrosion, page A-71 is revised to add Enhancement 1 as shown below:
A.5 License Renewal Commitment List NO.
PROGRAM OR TOPIC COMMITMENT IMPLEMENTATION SCHEDULE SOURCE 10 Flow-Accelerated Corrosion Existing program is credited. Flow-Accelerated Corrosion is an existing program that will be enhanced to:
- 1.
Provide guidance for the determination of wall thinning due to erosion predicted wear rate safety factors consistent with the direction outlined in Section 6.10 of EPRI Technical Report 3002023786, Revision 1, Recommendations for an Effective Program Against Erosive Attack.
Ongoing Program will be enhanced no later than six months prior to the period of extended operation.
Section A.2.1.10 CEG Letter CPS LRA Supplement No. 1, dated November 27, 2024
November 27, 2024 Enclosure B Page 3 of 13 LRA Appendix A, Section A.5, License Renewal Commitment List, Commitment 11, Bolting Integrity, page A-71, Enhancement 1 is revised as shown below:
A.5 License Renewal Commitment List NO.
PROGRAM OR TOPIC COMMITMENT IMPLEMENTATION SCHEDULE SOURCE 11 Bolting Integrity Bolting Integrity is an existing program that will be enhanced to:
- 1.
Perform shutdown service water (SX) pump and fire pump inspections with specific instructions to inspect the condition of all closure bolting for evidence of cracking, loss of material, or loss of preload.
Program will be enhanced no later than six months prior to the period of extended operation.
Section A.2.1.11 CEG Letter CPS LRA Supplement No. 1, dated November 27, 2024
November 27, 2024 Enclosure B Page 4 of 13 LRA Appendix A, Section A.5, License Renewal Commitment List, Commitment 16, Fire Protection, page A-73, Enhancement 3.d. is revised as shown below:
A.5 License Renewal Commitment List NO.
PROGRAM OR TOPIC COMMITMENT IMPLEMENTATION SCHEDULE SOURCE 16 Fire Protection Fire Protection is an existing program that will be enhanced to:
- 3.
Provide additional inspection guidance to identify aging effects as follows:
- a.
Fire barrier walls, ceilings, and floors degradation from spalling and loss of material that may be caused by freeze-thaw, chemical attack, and reaction with aggregates.
- b.
Elastomeric fire barrier material degradation such as increased hardness, shrinkage, and loss of strength.
- c.
Grout fire barrier material degradation such as concrete cracking and spalling.
- d.
Silicates, and subliming compounds, cementitious, and gypsum fire barrier degradation such as change in material properties, cracking and delamination, loss of material, and separation.
Program will be enhanced no later than six months prior to the period of extended operation.
Section A.2.1.16 CEG Letter CPS LRA Supplement No. 1, dated November 27, 2024
November 27, 2024 Enclosure B Page 5 of 13 LRA Appendix A, Section A.5, License Renewal Commitment List, Commitment 17, Fire Water System, page A-74, Enhancement 3.c is revised as shown below.
NO.
PROGRAM OR TOPIC COMMITMENT IMPLEMENTATION SCHEDULE SOURCE 17 Fire Water System Fire Water System is an existing program that will be enhanced to:
- 3.
Perform internal visual inspections of sprinkler and deluge system piping to identify internal corrosion, foreign material, and obstructions to flow. Follow-up volumetric wall thickness examinations will be performed if internal visual inspections detect an unexpected level of degradation due to corrosion and corrosion product deposition. If organic material, foreign material, or internal flow blockage that could result in failure of system function is identified, then an obstruction investigation will be performed within the corrective action program. The obstruction investigation includes the removal of the material, an extent of condition determination, a review for increased inspection frequencies, follow-up examinations, and a flush consistent with the guidance provided in NFPA 25 Annex D.5, Flushing Procedures.
The internal visual inspections will consist of the following:
- a.
Wet pipe sprinkler systems - 50 percent of the wet pipe sprinkler systems in scope for license renewal will have internal visual inspections of piping by removing a hydraulically remote sprinkler, performed every five years, consistent with NFPA 25, 2011 Edition, Section 14.2. During the next five-year inspection period, the alternate systems previously not inspected shall be inspected.
- b.
Preaction sprinkler systems - preaction sprinkler systems in scope for license renewal will have internal visual inspections of piping by removing a hydraulically remote nozzle, performed every five years, consistent with NFPA 25, 2011 Edition, Section 14.2.
- c.
Deluge systems - perform external visual inspections of accessible piping and spray spargers inside the filter plenums to assure they are in their proper position and spray patterns are not obstructed. In addition, perform internal visual inspections of piping on either side of the flanged spool piece that is removed in order to perform the air flow tests. Perform Program will be enhanced no later than six months prior to the period of extended operation.
Inspection schedule identified in the commitment.
Section A.2.1.17 CEG Letter CPS LRA Supplement No. 1, dated November 27, 2024
November 27, 2024 Enclosure B Page 6 of 13 NO.
PROGRAM OR TOPIC COMMITMENT IMPLEMENTATION SCHEDULE SOURCE these inspections during air flow testing of the charcoal bed deluge systems. perform an external visual inspection on a refueling outage frequency of the accessible piping and spray spargers inside the filter plenums to assure they are in their proper position and spray patterns are not obstructed. This will be in addition to the air flow tests that are currently performed to ensure there is no flow blockage. In addition, the program will be enhanced to include internal visual inspections of piping around the flanged spool piece during air flow testing.
November 27, 2024 Enclosure B Page 7 of 13 LRA Appendix A, Section A.5, License Renewal Commitment List, Commitment 17, Fire Water System, page A-75, Enhancement 9 is revised, and Enhancement 10 is added as shown below:
NO.
PROGRAM OR TOPIC COMMITMENT IMPLEMENTATION SCHEDULE SOURCE 17 Fire Water System Fire Water System is an existing program that will be enhanced to:
- 9.
Prior to 50 years of service, sprinklers shall be replaced or a representative sample of sprinklers will be removed and submitted for testing to a recognized laboratory. If sprinklers are not replaced, the testing shall be repeated every 10 years. This enhancement is in accordance with the requirements of NFPA 25 (2011), Section 5.3.1. and every 10 years after, remove a representative sample of sprinklers and submit for testing to a recognized laboratory.
- 10. Perform air flow testing of in scope charcoal bed deluge systems on a refuel outage (2-year) frequency.
Program will be enhanced no later than six months prior to the period of extended operation.
Inspection schedule identified in the commitment.
Section A.2.1.17 CEG Letter CPS LRA Supplement No. 1, dated November 27, 2024
November 27, 2024 Enclosure B Page 8 of 13 LRA Appendix A, Section A.5, License Renewal Commitment List, Commitment 27, Monitoring of Neutron-Absorbing Materials Other than Boraflex, page A-78, Enhancement 1 is revised, and Enhancement 2 is added as shown below:
NO.
PROGRAM OR TOPIC COMMITMENT IMPLEMENTATION SCHEDULE SOURCE 27 Monitoring of Neutron-Absorbing Materials Other than Boraflex Monitoring of Neutron-Absorbing Materials Other than Boraflex is an existing program that will be enhanced to:
- 1.
Perform NES spent fuel pool rack (Boral material) inspections and in-situ attenuation testing per NEI 16-03-A, Revision 1 guidance at a frequency not to exceed 10 years during the period of extended operation to assure proper neutron attenuation is maintained identify whether loss of B10 is occurring. The first in-situ attenuation test of Boral material will be performed within three years of entering the period of extended operation. In-situ test results found outside the established criteria will be entered into the corrective action program for engineering evaluation.
- 2.
Remove a Metamic coupon from the spent fuel pool for inspection and neutron attenuation testing in years 2035 and 2043.
Program will be enhanced no later than six months prior to the period of extended operation.
Section A.2.1.27 CEG Letter CPS LRA Supplement No. 1, dated November 27, 2024
November 27, 2024 Enclosure B Page 9 of 13 LRA Appendix A, Section A.5, License Renewal Commitment List, Commitment 28, Buried and Underground Piping and Tanks, page A-79, Enhancement 1 is revised as shown below:
NO.
PROGRAM OR TOPIC COMMITMENT IMPLEMENTATION SCHEDULE SOURCE 28 Buried and Underground Piping and Tanks Buried and Underground Piping and Tanks is an existing program that will be enhanced to:
- 1.
Perform extent of condition inspections as follows: When measured pipe wall thickness, projected to the end of the period of extended operation, does not meet the minimum pipe wall thickness requirements due to external environments, the number of inspections within the affected piping categories will be doubled or increased by five, whichever is smaller. If adverse indications are found in the expanded sample, an analysis will be conducted to determine the extent of condition and extent of cause. The size of the follow-up inspections will be determined based on the analysis. Timing of any additional inspections will be based on the severity of the identified degradation and the consequences of leakage or loss of function. Any additional inspections will be performed within the same 10-year inspection interval in which the original degradation was identified, or within four years after the end of the 10-year interval if the degradation was identified in the latter half of the 10-year interval.
Expansion of sample size may be limited by the extent of piping subject to the observed degradation mechanism or if the piping system or portion of the system is replaced or otherwise mitigated within the same 10-year inspection interval in which the original degradation was identified or within four years after the end of the 10-year interval, if the degradation was identified in the latter half of the 10-year interval.
Program will be enhanced no later than six months prior to the period of extended operation.
Inspection schedule identified in the commitment.
Inspections that are to be completed prior to the period of extended operation will be completed no later than six months prior to the period of extended operation.
Section A.2.1.28 CEG Letter CPS LRA Supplement No. 1, dated November 27, 2024
November 27, 2024 Enclosure B Page 10 of 13 LRA Appendix A, Section A.5, License Renewal Commitment List, Commitment 31, ASME Section XI, Subsection IWF, page A-80, Enhancement 2 is revised as shown below:
NO.
PROGRAM OR TOPIC COMMITMENT IMPLEMENTATION SCHEDULE SOURCE 31 ASME Section XI, Subsection IWF ASME Section XI, Subsection IWF is an existing program that will be enhanced to:
- 1.
Add the MC component support examinations for the fuel transfer tube and for containment penetrations spanning from the containment wall to the drywell wall for: reactor water cleanup, feedwater, residual heat removal, reactor core isolation cooling, and main steam drain to the scope of the program.
- 2.
Provide guidance, regarding the selection of supports to be examined in subsequent inspection intervals, when a support that is acceptable for continued service as defined in IWF-3400, is restored in accordance with the corrective action program. The enhanced guidance will ensure that future inspection populations are the sample is increased or modified to include another support, of the same type and function, that has not been restored to correct the observed condition. The purpose of increasing or modifying the sample size is to assure that the support population continues to be representative of the remaining population of supports that were not corrected.
Program will be enhanced no later than six months prior to the period of extended operation.
Section A.2.1.31 CEG Letter CPS LRA Supplement No. 1, dated November 27, 2024
November 27, 2024 Enclosure B Page 11 of 13 LRA Appendix A, Section A.5, License Renewal Commitment List, Commitment 34, Structures Monitoring, page A-81, Enhancements 6, 7, and 8 are revised as shown below:
NO.
PROGRAM OR TOPIC COMMITMENT IMPLEMENTATION SCHEDULE SOURCE 34 Structures Monitoring Structures Monitoring is an existing program that will be enhanced to:
- 6. Include inspection of accessible sliding surfaces for indication of significant loss of material due to wear or corrosion and that debris or dirt will not restrict or prevent sliding. Establish acceptance criteria for sliding surfaces as no indications of excessive loss of material due to corrosion or wear, and no debris or dirt that could restrict or prevent sliding of the surfaces, as required by design.
- 7. Monitor elastomeric vibration isolators and structural sealants for indication of loss of material, cracking or hardening resulting in loss of sealing or function.
Establish acceptance criteria for vibration isolation elements as being acceptable if there is no loss of material, cracking, or hardening that could lead to the reduction or loss of isolation function. Establish acceptance criteria for structural sealants as being acceptable if the observed loss of material, cracking, and hardening will not result in loss of sealing.
- 8. Clarify that loose bolts and nuts and cracked high strength bolts, not subject to stress corrosion cracking, are not acceptable unless accepted by engineering evaluations.
Program will be enhanced no later than six months prior to the period of extended operation.
Section A.2.1.34 CEG Letter CPS LRA Supplement No. 1, dated November 27, 2024
November 27, 2024 Enclosure B Page 12 of 13 LRA Appendix A, Section A.5, License Renewal Commitment List, Commitment 35, RG 1.127 Inspection of Water-Control Structures Associated with Nuclear Power Plants, page A-82, Enhancement 3 is revised, and Enhancement 4 is added as shown below:
NO.
PROGRAM OR TOPIC COMMITMENT IMPLEMENTATION SCHEDULE SOURCE 35 RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants is an existing program that will be enhanced to:
- 1.
Monitor raw water and ground water chemistry, for pH, chlorides, and sulfates, on a frequency not to exceed five years that accounts for seasonal variations (e.g., quarterly monitoring every fifth year), from locations that are representative of the groundwater in contact with structures within the scope of license renewal.
- 2.
Require inspection of accessible in-scope portions of the cooling lake and screen house immediately following the occurrence of significant natural phenomena, which includes hurricanes, tornadoes, large floods, and intense local rainfalls.
- 3.
Document current practices in implementing procedure for inspection of the cooling lake baffle dike. Monitor the baffle dike profile, specifically the baffle dike crest, for degradation that would lead to a loss of the baffle dikes intended function which is to provide longer cooling time for circulating water during a low water event. Use appropriate industry inspection methods such as sonar or divers. Monitor the baffle dike profile, including the crest of the baffle dike, and compare it to previous inspections including the original survey. If the crest is below the minimum height requirements which are based on the original survey, enter into the corrective action program for evaluation.
- 4.
Clarify that loose bolts and nuts and cracked high strength bolts are not acceptable unless accepted by engineering evaluations.
Program will be enhanced no later than six months prior to the period of extended operation.
Section A.2.1.35 CEG Letter CPS LRA Supplement No. 1, dated November 27, 2024
November 27, 2024 Enclosure B Page 13 of 13 LRA Appendix A, Section A.5, License Renewal Commitment List, Commitment 39, Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, page A-83 is revised as shown below:
NO.
PROGRAM OR TOPIC COMMITMENT IMPLEMENTATION SCHEDULE SOURCE 39 Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements is a new program that will be used to manage the effects of reduced insulation resistance of non-EQ, in scope, inaccessible power cables.
Cables will be tested using one or more proven tests for detecting reduced insulation resistance of the cables insulation system due to wetting or submergence. Cable testing will be performed at least once every six years. More frequent testing may occur based on test results and operating experience. Cable vaults associated with the cables included in this program will be inspected for water collection with subsequent corrective actions (e.g., water removal), as necessary. The frequency of inspections for accumulated water will be established at least six months prior to the period of extended operation and adjusted based on plant specific operating experience with cable wetting or submergence, including water accumulation over time and event driven occurrences such as heavy rain or flooding. During the period of extended operation, the inspections will occur periodically based on water accumulation over time. The manholes / cable vaults equipped with solar powered monitoring and alarms will be inspected at least once annually. The manholes / cable vaults equipped with 120 VAC powered level monitoring and alarms that result in consistent, subsequent pump out of accumulated water prior to wetting or submergence of cables will be inspected at least once every five years. Operation of dewatering devices will be verified prior to any known or predicted heavy rain or flooding event.
During the period extended operation, the inspections will occur periodically based on water accumulation over time. The manholes / cable vaults equipped with solar powered monitoring and alarms will be inspected following event driven occurrences, such as heavy rain or flooding. The manholes/ cable vaults equipped with 120 VAC powered level monitoring and alarms, will be inspected following event driven occurrences, such as heavy rain or flooding, when level monitoring indicates water is accumulating. The cable vaults will be inspected at least annually.
Program will be implemented no later than six months prior to the period of extended operation. Tests and inspections that are required to be performed prior to the period of extended operation will be completed no later than six months prior to the period of extended operation.
Test and inspection schedule identified in the commitment.
Section A.2.1.39 CEG Letter CPS LRA Supplement No. 1, dated November 27, 2024