View source for NL-11-096, Official Exhibit - NYS000154-00-BD01 - Entergy Clarification (NL-11-096) for Request for Additional Information, Aging Management Programs, Indian Point Nuclear Generating Unit Nos. 2 & 3, Docket Nos. 50-247 and 50-286, License Nos. DPR- 2

{{Adams
| number = ML12334A668
| issue date = 08/09/2011
| title = Official Exhibit - NYS000154-00-BD01 - Entergy Clarification (NL-11-096) for Request for Additional Information, Aging Management Programs, Indian Point Nuclear Generating Unit Nos. 2 & 3, Docket Nos. 50-247 and 50-286, License Nos. DPR- 26
| author name = Dacimo F
| author affiliation = Entergy Nuclear Northeast, Entergy Nuclear Operations, Inc
| addressee name = 
| addressee affiliation = NRC/ASLBP, NRC/Document Control Desk, NRC/NRR
| docket = 05000247, 05000286
| license number = DPR-026, DPR-064
| contact person = SECY RAS
| case reference number = RAS 21546, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01, NL-11-096
| document type = Legal-Exhibit
| page count = 24
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:United States Nuclear Regulatory Commission Official Hearing Exhibit Entergy Nuclear Operations, Inc.
In the Matter of:
(Indian Point Nuclear Generating Units 2 and 3)
ASLBP #: 07-858-03-LR-BD01 Docket #: 05000247 l 05000286                                                              NYS000154 Exhibit #: NYS000154-00-BD01                  Identified: 10/15/2012                       Submitted: December 15, 2011 Admitted: 10/15/2012                         Withdrawn:
Rejected:                                       Stricken:
Other:
Entergy Nuclear Northeast Indian Point Energy Center Entergx                                                                 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 788-2055 Fred Dacimo Vice President Operations License Renewal NL-11-096 August 9, 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-11-032),"Response to Request for Additional Information (RAI) Aging Management Programs," dated March 28, 2011
: 3. Entergy letter (NL-11-074),"Response to Request for Additional Information (RAI) Aging Management Programs," dated July 14, 2011
: 4. Entergy letter (NL-11-090),"Clarification for Request for Additional Information (RAI) Aging Management Programs," dated July 27, 2011

==Dear Sir or Madam:==

Entergy Nuclear Operations, Inc is providing, in Attachment 1, clarifications of the responses in References 2, 3 and 4. Attachment 2 provides the latest list of regulatory commitments including revisions to commitments discussed in this letter.
If you have any questions, or require additional information, please contact Mr. Robert Walpole at 914-734-6710.

Docket Nos. 50-247 & 50-286
  \                                                                                     NL-11-096
* Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on
      ~rr~) -lNlL FRD/rw

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

==Attachment:==
: 2. IPEC List of Regulatory Commitments (Rev. 16) cc:   Mr. William Dean, Regional Administrator, NRC Region I Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel Mr. Dave Wrona, NRC Branch Chief, Engineering Review Branch J Mr. John Boska, NRR Senior Project Manager Mr. Paul Eddy, New York State Department of Public Service NRC Resident Inspector's Office Mr. Francis J. Murray, Jr., President and CEO NYSERDA

ATTACHMENT 1 TO NL-11-096 LICENSE RENEWAL APPLICATION CLARIFICATION FOR REQUEST FOR ADDITIONAL INFORMATION (RAil AGING MANAGEMENT PROGRAMS ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286

NL-11-096 Attachment 1 Page 1 of 3 INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION CLARIFICATION FOR REQUEST FOR ADDITIONAL INFORMATION (RAI)
AGING MANAGEMENT PROGRAMS Changes are shown as strikethroughs for deletions and underlines for additions.
Clarification for RAI 3.0.3.1.6-1 Part 1 This clarification amends the response in letters NL-11-032, dated March 28, 2011; NL-11-074, dated July 14, 2011; and NL-11-090, dated July 27,2011. These letters revised LRA Section A.2.1.22, A.3.1.22 and 8.1.23.
This letter revises LRA Sections A.2.1.22, A.3.1.22, and 8.1.23.
Clarification is provided on the performance of event-driven inspections for water in cable manholes. Letter NL-11-032 correctly identified event-driven inspections as part of the Non-EQ Inaccessible Medium-Voltage Cable Program. Minor clarifications are provided to the program description in LRA Section 8.1.23 provided in letter NL-11-032. In addition, LRA sections A.2.1.22 and A.3.1.22 are revised to clearly state that even-driven inspections are part of the program.
A.2.1.22 Non-EQ Inaccessible Medium-Voltage Cable Program The Non-EO Inaccessible Medium-Voltage Cable Program is a new program that entails periodic and event-driven inspections for water collection in cable manholes, and periodic testing of cables. In scope medium-voltage cables (cables with operating voltage from 2kV to 35kV) and low-voltage power cables (400 V to 2 kV) exposed to significant moisture will be tested at least once every six years to provide an indication of the condition of the conductor insulation. Test frequencies are adjusted based on test results and operating experience.
The frequency of inspections for water accumulation in manholes is established based on plant specific operating experience '''lith cable wetting or submergence in manholes (Le., the inspection is performed periodically based on water accumulation over time and event driven occurrences, such as heavy rain or flooding).
The frequency will be program includes periodic inspections for water accumulation in manholes at least once every year (annually). In addition to the periodic manhole inspections, manhole inspection for water after events, such as heaw rain or flooding will be performed. Inspection frequency will be increased as necessary based on evaluation of inspection results.
The Non-EQ Inaccessible Medium-Voltage Cable Program will be implemented prior to the period of extended operation. This new program will be implemented consistent with the corresponding program described in NUREG-1801, Section XI.E3, Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 Environmental Qualification Requirements.
A.3.1.22 Non-EQ Inaccessible Medium-Voltage Cable Program The Non-EO Inaccessible Medium-Voltage Cable Program is a new program that entails periodic and event-driven inspections for water collection in cable manholes, and periodiC testing of cables. In scope medium-
* NL-11-096 Attachment 1 Page 2 of 3 voltage cables (cables with operating voltage from 2kV to 35kV) and low-voltage power cables (400 V to 2 kV) exposed to significant moisture will be tested at least once every six years to provide an indication of the condition of the conductor insulation. Test frequencies are adjusted based on test results and operating experience.
The frequensy of inspestions for water assumulation in manholes is established based on plant spesifis operating experience v,'ith cable wetting or sUbmergense in manholes (i.e., the inspestion is performed periodisally based on water assumulation over time and event driven ossurronses, sush as heavy rain or flooding).
The frequensy will be program includes periodic inspections for water accumulation in manholes at least once every year (annually). In addition to the periodic manhole inspections. manhole inspection for water after events. such as heavy rain or flooding will be performed. Inspection frequency will be increased as necessary based on evaluation of inspection results.
The Non-EO Inaccessible Medium-Voltage Cable Program will be implemented prior to the period of extended operation. This new program will be implemented consistent with the corresponding program described in NUREG-1 8001, Section XI.E3, Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 Environmental Oualification Requirements.
B.1.23          NON-EQ INACCESSIBLE MEDIUM-VOLTAGE CABLE Program Description The Non-EO Inaccessible Medium-Voltage Cable Program is a new program that entails periodic inspections for water collection in cable manholes and periodic testing of cables. In scope medium-voltage cables (cables with operating voltage from 2kV to 35kV) and low-voltage power cables (400 V to 2 kV) exposed to significant moisture will be tested at least once every six years to provide an indication of the condition of the conductor insulation. Test frequencies will be adjusted based on test results and operating experience. The program includes inspections for water accumulation in manholes at least once every year (annually). In addition to the periodic manhole inspections, manhole inspection for water fef-after events driven ossurronses, such as heavy rain or flooding will be performed. Inspection frequency will be increased as necessary based on evaluation of inspection results.
This program will be implemented prior to the period of extended operation.
Operating Experience The Non-EQ Inaccessible Medium-Voltage Cable Program is a new program. Industry and plant-specific operating experience will be considered when implementing this program. Industry operating experience that forms the basis for the program is described in the operating experience element of the NUREG-1801 program description. IPEC plant-specific operating experience is not inconsistent with the operating experience in the NUREG-1801 program description.
The inspection frequency for manholes is based on plant-specific operating experience with cable wetting or submergence in manholes (i.e., the inspection is performed periodically based on water accumulation over time and following events such as heavy rain or flooding).
The IPEC program is based on the program description in NUREG-1801, which in turn is based on industry operating experience. As such, operating experience provides assurance that the Non-EO Inaccessible Medium-Voltage Cable Program will manage the effects of aging such that applicable components will

NL-11-096 Attachment 1 Page 3 of 3 continue to perform their intended functions consistent with the current licensing basis through the period of extended operation.
Conclusion The Non-EO Inaccessible Medium-Voltage Cable Program will be effective for managing aging effects since it wi" incorporate proven monitoring techniques and industry and plant-specific operating experience. The Non-EO Inaccessible Medium-Voltage Cable Program assures that the effects of aging will be managed such that the applicable components wi" continue to perform their intended functions consistent with the current licensing basis through the period of extended operation.
Clarification for RAI3.1.2.2.16-1 band RAI3.1.2.2.16-1 Part 2 Commitment 42 was inadvertently changed due to an administrative error in the list of regulatory commitments attached to NL-11-07 4. The revision had not been identified as a change to the responses to RAls 3.1.2.2.16-1 band RAI 3.1.2.2.16-1 Part 2 as documented in NL-11-032. These RAI responses accurately describe the intended program and associated commitment. The list of regulatory commitments has been changed to be consistent with the RAI responses.
Commitment 42 IPEC wi" develop a plan for each unit to address the potential for cracking of the primary to secondary pressure boundary due to PWSCC of tube-to-tubesheet welds using one of the following two options.
Each plan 'Nill consist of two options.
Option 1 (Analysis)
IPEC wi" perform an analytical evaluation of the steam generator tube-to-tubesheet welds in order to establish a technical basis for either determining that the tubesheet cladding and welds are not susceptible to PWSCC, QLredefining the pressure boundary in which the tube-to-tubesheet weld is no longer included and, therefore, is not required for reactor coolant pressure boundary function. The redefinition of the reactor coolant pressure boundary must be approved by the NRC as a license amendment request.
Option 2 (Inspection)
IPEC will perform a one-time inspection of a representative number of tube-to-tubesheet welds in each steam generator to determine if PWSCC cracking is present. If weld cracking is identified:
: a. The condition will be resolved through repair or engineering evaluation to justify continued service, as appropriate, and
: b. An ongoing monitoring program will be established to perform routine tube-to-tubesheet weld inspections for the remaining life of the steam generators.

ATTACHMENT 2 TO NL-11-096 LICENSE RENEWAL APPLICATION IPEC LIST OF REGULATORY COMMITMENTS Rev. 16 ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286

NL-11-096 Attachment 2 Page 1 of 17 List of Regulatory Commitments Rev. 16 The following table identifies those actions committed to by Entergy in this document.
Changes are shown as strikethroughs for deletions and underlines for additions.
     #                            COMMITMENT                         IMPLEMENTATION    SOURCE     RELATED SCHEDULE               LRASECTION I AUDIT ITEM IP2:            NL-07-039     A.2.1.1 1    Enhance the Aboveground Steel Tanks Program for September 28,                 A.3.1.1 I P2 and IP3 to perform thickness measurements of 12013                          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            12015 IP2 and IP3 to require trending of thickness measurements when material loss is detected.
IP2:            NL-07-039     A.2.1.2 2    Enhance the Bolting Integrity Program for IP2 and IP3 September 28,                 A.3.1.2 to clarify that actual yield strength is used in selecting 12013                          B.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 preload and loss of material for all external bolting.
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               12015 Inspection.
Include in the Buried Piping and Tanks Inspection                          NL-09-106 Program described in LRA Section 8.1.6 a risk assessment of in-scope buried piping and tanks that                        NL-09-111 includes consideration of the impacts of buried piping or tank leakage and of conditions affecting the risk for corrosion. Classify pipe segments and tanks as having a high, medium or low impact of leakage based on the safety class, the hazard posed by fluid contained in the piping and the impact of leakage on reliable plant operation. Determine corrosion risk through consideration of piping or tank material, soil resistivity, drainage, the presence of cathodic protection and the type of coating. Establish inspection priority and frequency for periodic inspections of the in-scope piping and tanks based on the results of the risk assessment. Perform inspections using direct visual inspection.

NL-11-096 Attachment 2 Page 2 of 17
#                        COMMITMENT                        IMPLEMENTATION  SOURCE     RELATED SCHEDULE             LRASECTION I AUDIT ITEM IP2:           NL-07-039    A.2.1.8 4 Enhance the Diesel Fuel Monitoring Program to September 28,               A.3.1.8 include cleaning and inspection of the IP2 GT-1 gas
                                                           ~013                         B.1.9 turbine fuel oil storage tanks, IP2 and IP3 EDG fuel oil NL-07-153  Audit items day tanks, IP2 SBO/Appendix R diesel generator fuel IP3:                       128, 129, oil day tank, and IP3 Appendix R fuel oil storage tank December 12,                 132, and day tank once every ten years.
12015          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-11-096 Attachment 2 Page 3 of 17
#                         COMMITMENT                         IMPLEMENTATION  SOURCE     RELATED SCHEDULE              LRASECTION I AUDIT ITEM IP2:            NL-07-039   A.2.1.10 5 Enhance the External Surfaces Monitoring Program September 28,               A.3.1.10 for IP2 and IP3 to include periodic inspections of 12013                        B.1.11 systems in scope and subject to aging management 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 those systems. Inspections of nearby systems that         12015 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).
IP2:            NL-07-039   A.2.1.11 6 Enhance the Fatigue Monitoring Program for IP2 to September 28,               A.3.1.11 monitor steady state cycles and feedwater cycles or perform an evaluation to determine monitoring is not      ~013                         B.1.12, NL-07-153  Audit Item required. Review the number of allowed events and 164 resolve discrepancies between reference documents 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          12015 limiting numbers. Update the number of design transients accumulated to date.
IP2:            NL-07-039   A.2.1.12 7 Enhance the Fire Protection Program to inspect September 28,               A.3.1.12 external surfaces of the IP3 RCP oil collection
                                                            ~013                         B.1.13 systems for loss of material each refueling cycle.
Enhance the Fire Protection Program to explicitly         IP3:
state that the IP2 and IP3 diesel fire pump engine        December 12, sub-systems (including the fuel supply line) shall be     2015 observed while the pump is running. Acceptance criteria will be revised to verify that the diesel engine does not exhibit signs of degradation while running; such as fuel oil, lube oil, coolant, or exhaust gas leakage.
Enhance the Fire Protection Program to specify that the IP2 and IP3 diesel fire pump engine carbon steel exhaust components are inspected for evidence of corrosion and cracking at least once each operating cycle.
Enhance the Fire Protection Program for IP3 to visually inspect the cable spreading room, 480V switchgear room, and EDG room CO 2 fire suppression system for signs of degradation, such as corrosion and mechanical damage at least once every six months.

NL-11-096 Attachment 2 Page 4 of 17
#                        COMMITMENT                       IMPLEMENTATION  SOURCE     RELATED SCHEDULE             LRASECTION I AUDIT ITEM IP2:           NL-07-039   A.2.1.13 8 Enhance the Fire Water Program to include inspection September 28,              A.3.1.13 of IP2 and IP3 hose reels for evidence of corrosion.
12013                       B.1.14 Acceptance criteria will be revised to verify no 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 12015 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-11-096 Attachment 2 Page 5 of 17
#                        COMMITMENT                     IMPLEMENTATION  SOURCE     RELATED SCHEDULE              LRASECTION 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
                                                        ~O13                        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.
                                                        ~O15 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-11-096 Attachment 2 Page 6 of 17
 #                         COMMITMENT                      IMPLEMENTATION  SOURCE     RELATED SCHEDULE             LRA SECTION I AUDIT ITEM IP2:           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                        8;1.17, in the scope of the program.
NL-07-153   Audit Item
* Safety injection pump lube oil heat exchangers IP3:                           52 December 12,
* RHR heat exchangers 12015
* HHR pump seal coolers
* Non-regenerative heat exchangers
* Charging pump seal water heat exchangers
* Charging pump fluid drive coolers
* Charging pump crankcase oil coolers
* Spent fuel pit heat exchangers
* Secondary system steam generator sample coolers
* Waste gas compressor heat exchangers
* S80/Appendix R diesel jacket water heat exchanger (IP2 only)
Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to perform visual inspection on heat exchangers where non-destructive examination, such as eddy current inspection, is not possible due to heat exchanger design limitations.
Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to include consideration of material-environment combinations when determining sample population of heat exchangers.
Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to establish minimum tube wall thickness for the new heat exchangers identified in the scope of the program. Establish acceptance criteria for heat exchangers visually inspected to include no indication of tube erosion, vibration wear, corrosion, pitting,                   NL-09-018 fouling, or scaling.
NL-09-056 11 Delete commitment.

NL-11-096 Attachment 2 Page 7 of 17
 #                        COMMITMENT                        IMPLEMENTATION  SOURCE     RELATED SCHEDULE              LRA SECTION I AUDIT ITEM IP2:           NL-07-039   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 2013                        B.1.19 the program.
IP3:
December 12, 2015 Enhance the Metal-Enclosed Bus Inspection Program IP2:                  NL-07-039   A.2.1.19 13 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 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.
IP2:           NL-07-039   A.2.1.21 14 Implement the Non-EQ Bolted Cable Connections September 28,              A.3.1.21 Program for IP2 and IP3 as described in LRA Section 2013                        B.1.22 B.1.22.
IP3:
December 12,
                                                            ~015

NL-11-096 Attachment 2 Page 8 of 17
#                         COMMITMENT                       IMPLEMENTATION  SOURCE     RELATED SCHEDULE             LRASECTION I AUDIT ITEM IP2:           NL-07-039    A.2.1.22 15 Implement the Non-EO Inaccessible Medium-Voltage September 28,               A.3.1.22 Cable Program for IP2 and IP3 as described in LRA
                                                           ~013                         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-11-032 1801 Section XI.E3, Inaccessible Medium Voltage         ~015 Power Cables Not Subject To 10 CFR 50.49                               NL-11-096 Environmental Oualification Requirements.
IP2:           NL-07-039    A.2.1.23 16 Implement the Non-EQ Instrumentation Circuits Test September 28,               A.3.1.23 Review Program for IP2 and IP3 as described in LRA Section B.1.24.                                         ~013                         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               12015 Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits.
IP2:           NL-07-039    A.2.1.24 17 Implement the Non-EO Insulated Cables and September 28,               A.3.1.24 Connections Program for IP2 and IP3 as described in 2013                         B.1.25 LRA Section B.1.25.
NL-07-153   Audit item This new program will be implemented consistent with IP3:                             173 the corresponding program described in NUREG-           December 12, 1801 Section XI.E1, Electrical Cables and               2015 Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.
IP2:           NL-07-039    A.2.1.25 18 Enhance the Oil Analysis Program for IP2 to sample September 28,               A.3.1.25 and analyze lubricating oil used in the SBO/Appendix 2013                         B.1.26 R diesel generator consistent with oil analysis for 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-11-096 Attachment 2 Page 9 of 17
 #                       COMMITMENT                          IMPLEMENTATION  SOURCE     RELATED SCHEDULE              LRASECTION I AUDIT ITEM IP2:            NL-07-039    A.2.1.26 19 Implement the One-Time Inspection Program for IP2 September 28,                A.3.1.26 and IP3 as described in LRA Section B.1.27.
12013                         8.1.27 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, 12015 IP2:            NL-07-039    A.2.1.27 20 Implement the One-Time Inspection - Small Bore September 28,                A.3.1.27 Piping Program for IP2 and IP3 as described in LRA 12013                         B.1.28 Section 8.1.28.
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 12015 Code Class I Small-Bore Piping.
IP2:            NL-07-039    A.2.1.28 21 Enhance the Periodic Surveillance and Preventive September 28,                A.3.1.28 Maintenance Program for IP2 and IP3 as necessary 12013                         B.1.29 to assure that the effects of aging will be managed such that applicable components will continue to IP3:
perform their intended functions consistent with the December 12, current licensing basis through the period of extended 2015 operation.
IP2:            NL-07-039    A.2.1.31 22 Enhance the Reactor Vessel Surveillance Program for September 28,                A.3.1.31 IP2 and IP3 revising the specimen capsule withdrawal 12013                         B.1.32 schedules to draw and test a standby capsule to 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 ~015 IP2 and IP3 to require that tested and untested specimens from all capsules pulled from the reactor vessel are maintained in storage.
IP2:            NL-07-039    A.2.1.32 23 Implement the Selective Leaching Program for IP2 September 28,                A.3.1.32 and IP3 as described in LRA Section B.1.33.
12013                         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, 12015 IP2:            NL-07-039    A.2.1.34 24 Enhance the Steam Generator Integrity Program for September 28,                A.3.1.34 IP2 and IP3 to require that the results of the condition 12013                         B.1.35 monitoring assessment are compared to the operational assessment performed for the prior IP3:
operating cycle with differences evaluated.
December 12, 12015

NL-11-096 Attachment 2 Page 10 of 17
 #                        COMMITMENT                       IMPLEMENTATION  SOURCE     RELATED SCHEDULE             LRA SECTION I 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.                                12013                       8.1.36
* 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       12015          NL-08-057     417 enclosure (IP3)
* city water storage tank foundation
* condensate storage tanks foundation (IP3)
* containment access facility and annex (IP3)
* discharge canal (IP2I3)
* emergency lighting poles and foundations (IP2/3)
* fire pumphouse (IP2)
* fire protection pump house (IP3)
* fire water storage tank foundations (I P2/3)
* gas turbine 1 fuel storage tank foundation
* maintenance and outage building-elevated passageway (IP2)
* new station security building (IP2)
* nuclear service building (IP1)
* primary water storage tank foundation (IP3)
* refueling water storage tank foundation (IP3)
* security access and office building (IP3)
* service water pipe chase (IP2/3)
* service water valve pit (IP3)
* superheater stack
* transformerlswitchyard support structures (IP2)
* waste holdup tank pits (IP2/3)
Enhance the Structures Monitoring Program for IP2 and IP3 to clarify that in addition to structural steel and concrete, the following commodities (including their anchorages) are inspected for each structure as applicable.
* cable trays and supports
* concrete portion of reactor vessel supports
* conduits and supports
* cranes, rails and girders
* equipment pads and foundations
* fire proofing (pyrocrete)
* HVAC duct supports
* jib cranes
* manholes and duct banks
* manways, hatches and hatch covers
* monorails

NL-11-096 Attachment 2 Page 11 of 17
#                         COMMITMENT                        IMPLEMENTATION  SOURCE     RELATED SCHEDULE              LRA SECTION I AUDIT ITEM
* new fuel storage racks
* sumps, sump screens, strainers and flow barriers Enhance the Structures Monitoring Program for IP2 and IP3 to inspect inaccessible concrete areas that are exposed by excavation for any reason. IP2 and IP3 will also inspect inaccessible concrete areas in environments where observed conditions in accessible areas exposed to the same environment indicate that significant concrete degradation is occurring.
Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspections of elastomers (seals, gaskets, seismic joint filler, and roof elastomers) to identify cracking and change in material properties and for inspection of aluminum vents and louvers to identify loss of material.
Enhance the Structures Monitoring Program for IP2 and IP3 to perform an engineering evaluation of                          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). IPEG will obtain samples from at least 5 wells that are representative of the ground water surrounding below-grade site structures and perform an engineering evaluation of the results from those samples for sulfates, pH and chlorides.
Additionally, to assess potential indications of spent fuel pool leakage, IPEG will sample for tritium in groundwater wells in close proximity to the IP2 spent fuel pool at least once every 3 months.
Enhance the Structures Monitoring Program for IP2 and 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 PE~.

NL-11-096 Attachment 2 Page 12 of 17
 #                         COMMITMENT                      IMPLEMENTATION  SOURCE     RELATED SCHEDULE              LRASECTION I AUDIT ITEM Enhance the Structures Monitoring Program to include more detailed quantitative acceptance criteria                 NL-11-032 for inspections of concrete structures in accordance with ACI 349.3R, "Evaluation of EXisting Nuclear Safety-Related Concrete Structures" prior to the .
period of extended operation (PEO).
IP2:           NL-07-039    A.2.1.36 26  Implement the Thermal Aging Embrittlement of Cast September 28,               A.3.1.36 Austenitic Stainless Steel (CASS) Program for IP2 2013                         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 with IP3:                            173 the corresponding program described in NUREG-          December 12, 1801, Section XI.M12, Thermal Aging EmbriUlement       ~015 of Cast Austenitic Stainless Steel (CASS) Program.
IP2:           NL-07-039    A.2.1.37 27  Implement the Thermal Aging and Neutron Irradiation September 28,               A.3.1.37 Embrittlement of Cast Austenitic Stainless Steel (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-          ~015 1801 Section XI.M13, Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program.
IP2:           NL-07-039    A.2.1.39 28  Enhance the Water Chemistry Control- Closed September 28,               A.3.1.39 Cooling Water Program to maintain water chemistry of
                                                           ~013                         B.1.40 the IP2 SBO/Appendix R diesel generator cooling NL-08-057   Audit item system per EPRI guidelines.
IP3:                          509 Enhance the Water Chemistry Control- Closed            December 12, Cooling Water Program to maintain the IP2 and IP3      ~015 security generator and fire protection diesel cooling water pH and glycol within limits specified by EPRI guidelines.
IP2:           NL-07-039    A.2.1.40 29  Enhance the Water Chemistry Control- Primary and September 28,                8.1.41 Secondary Program for IP2 to test sulfates monthly in
                                                           ~013 the RWST with a limit of <150 ppb.
IP2:           NL-07-039    A.2.1.41 30  For aging management of the reactor vessel internals, September 28,               A.3.1.41 IPEC will (1) participate in the industry programs for
                                                           ~011 investigating and managing aging effects on reactor internals; (2) evaluate and implement the results of IP3:
the industry programs as applicable to the reactor December 12, internals; and (3) upon completion of these programs, but not less than 24 months before entering the period 12013 of extended operation, submit an inspection plan for reactor internals to the NRC for review and approval.

NL-11-096 Attachment 2 Page 13 of 17
 #                          COMMITMENT                            IMPLEMENTATION  SOURCE     RELATED SCHEDULE             LRA SECTION I AUDIT ITEM IP2:           NL-07-039   A.2.2.1.2 31 Additional P-T curves will be submitted as required September 28,              A.3.2.1.2 per 10 CFR 50, Appendix G prior to the period of 12013                        4.2.3 extended operation as part of the Reactor Vessel Surveillance Program.
IP3:
December 12, 2015 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 B2803-3 to the        December 12,                 4.2.5 NRC three years prior to reaching the RT PTS                   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 September 28,              A.3.2.2.3 extended operation, for the locations identified in LRA 2011                         4.3.3 Table 4.3-13 (IP2) and LRA Table 4.3-14 (IP3), under 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 GUF.
: 2. Additional plant-specific locations with a valid GUF may be evaluated. In particular, the pressurizer lower shell will be reviewed to ensure the surge nozzle remains the limiting component.
: 3. Representative GUF values from other plants, adjusted to or enveloping the IPEG plant specific external loads may be used if demonstrated applicable to IPEG.
: 4. An analysis using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case) may be performed to determine a valid CUF.
(2) Consistent with the Fatigue Monitoring Program, Corrective Actions, repair or replace the affected locations before exceeding a CUF of 1.0.

NL-11-096 Attachment 2 Page 14 of 17
 #                        COMMITMENT                         IMPLEMENTATION    SOURCE     RELATED SCHEDULE                LRASECTION I AUDIT ITEM April 30, 2008 NL-07-078   2.1.1.3.5 34 IP2 SSO I Appendix R diesel generator will be installed and operational by April 30, 2008. This Complete     NL-08-074 committed change to the facility meets the requirements of 10 CFR 50.591(1) and, therefore, a license amendment pursuant to 10 CFR 50.90 is not required.
IP2:             NL-08-127   Audit Item 35 Perform a one-time inspection of representative September 28,                    27 sample area of IP2 containment liner affected by the 2013 1973 event behind the insulation, prior to entering the extended period of operation, to assure liner degradation is not occurring in this area.
Perform a one-time inspection of representative           IP3:
sample area of the IP3 containment steel liner at the     December 12, juncture with the concrete floor slab, prior to entering  2015 the extended period of operation, to assure liner degradation is not occurring in this area.
Any degradation will be evaluated for updating of the                      NL-09-018 containment liner analyses as needed.
IP2:             NL-08-127   Audit Item 36 Perform a one-time Inspection and evaluation of a September 28,                   359 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.
IP2:             NL-08-127   Audit Item 37 Enhance the Containment Inservice Inspection (CII-September 28,                   361 IWL) Program to include inspections of the 2013 containment using enhanced characterization of degradation (Le., quantifying the dimensions of noted IP3:
indications through the use of optical aids) during the December 12, period of extended operation. The enhancement 2015 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-11-096 Attachment 2 Page 15 of 17
 #                        COMMITMENT                       IMPLEMENTATION    SOURCE     RELATED SCHEDULE               LRASECTION I AUDIT ITEM IP2:             NL-08-143     4.2.1 38 For Reactor Vessel Fluence, should future core September 28, loading patterns invalidate the basis for the projected values of RTpts or CvUSE, updated calculations will     ~013 be provided to the NRC.
IP3:
December 12, 12015 NL-09-079 39 Deleted IP2:             NL-09-106     B.1.6 40 Evaluate plant specific and appropriate industry September 28,                 B.1.22 operating experience and incorporate lessons learned
                                                           ~013                          B.1.23 in establishing appropriate monitoring and inspection B.1.24 frequencies to assess aging effects for the new aging IP3:                          B.1.25 management programs. Documentation of the December 12,                  B.1.27 o~erating ~xperienc~ evaluated for each new program will be available on site for NRC review prior to the
                                                           ~015                          B.1.28 B.1.33 period of extended operation.
B.1.37 B.1.38 IP2:             NL-11-032      N/A 41 IPEC will perform an inspection of steam generators After the for both units to assess the condition of the divider beginning of the plate assembly. The examination technique used will PEO and prior to be capable of detecting PWSCC in the steam September 28, generator divider plate assemblies. The IP2 steam 2023             NL-11-074 generator divider plate inspections will be completed within the first ten years of the period of extended IP3:             NL-11-090 operation (PEO). The IP3 steam generator divider Prior to the end plate inspections will be completed within the first pf the first refueling outage following the beginning of the PEO.
refueling outage ollowing the beginning of the PEO.

NL-11-096 Attachment 2 Page 16 of 17
 #                         COMMITMENT                       IMPLEMENTATION     SOURCE     RELATED SCHEDULE                LRASECTION 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.
EaGh plan will Gonsist of two options.
Option 1 (Analysis)
IP2:              NL-11-074 IPEC will perform an analytical evaluation of the        Prior to March steam generator tube-to-tubesheet welds in order to      ~024              NL-11-090 establish a technical basis for either determining that  IP3: Prior to the the tubesheet cladding and welds are not susceptible     end of the first  NL-11-096 to PWSCC, or redefining the pressure boundary in         refueling outage which the tube-to-tubesheet weld is no longer             ollowing the included and, therefore, is not required for reactor     beginning of the coolant pressure boundary function. The redefinition     PEO.
of the reactor coolant pressure boundary must be approved by the NRC as a license amendment request.
IP2:
Between March Option 2 (Inspection)                                    ~020 and March IPEC will perform a one-time inspection of a             ~024 representative number of tube-to-tubesheet welds in each steam generator to determine if PWSCC               IP3: Prior to the cracking is present. If weld cracking is identified:     end of the first refueling outage
: a. The condition will be resolved through repair     ollowing the or engineering evaluation to justify continued  beginning of the service, as appropriate, and                    PEO.
: b. An ongoing monitoring program will be established to perform routine tube-to-tubesheet weld inspections for the remaining life of the steam generators.
IP2:              NL-11-032     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 12013 for the effects of the reactor coolant environment on 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 12015 for the effects of the reactor coolant environment on fatigue usage.
IPEC will use the NUREG/CR-6909 methodology in the evaluation of the limiting locations consisting of nickel alloy, if any.

NL-11-096 Attachment 2 Page 17 of 17
 #                        COMMITMENT                         IMPLEMENTATION  SOURCE     RELATED SCHEDULE             LRA SECTION I AUDIT ITEM Within 60 days  NL-11-032     N/A 44 IPEG will include written explanation and justification of issuance of of any user intervention in future evaluations using the he renewed WESTEMS "Design CUF" module.
operating license.
Within 60 days  NL-11-032     N/A 45 IPEC will not use the NB-3600 option of the of issuance of WESTEMS program in future design calculations until he renewed the issues identified during the NRC review of the operating program has been resolved.
license.
IP2:            NL-11-032     N/A 46 Include in the IP2 lSI Program that IPEC will perform Prior to twenty-five volumetric weld metal inspections of September 28,   NL-11-074 socket welds during each 10-year lSI interval scheduled as specified by IWB-2412 of the ASME           12013 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.}}