View source for NL-16-122, Reply to Request for Additional Information for the Review of License Renewal Application, Set 2016-01 (CAC Nos. MD5407 and MD5408)

{{Adams
| number = ML16350A005
| issue date = 12/02/2016
| title = Reply to Request for Additional Information for the Review of License Renewal Application, Set 2016-01 (CAC Nos. MD5407 and MD5408)
| author name = Vitale A
| author affiliation = Entergy Nuclear Northeast
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000247, 05000286
| license number = DPR-026, DPR-064
| contact person = 
| case reference number = CAC MD5407, CAC MD5408, NL-16-122
| document type = Letter type:NL, Response to Request for Additional Information (RAI)
| page count = 61
| project = CAC:MD5407, CAC:MD5408
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:**=-=* Entergx                                                     Enterqv Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box249 Buchanan, NY 10511-0249 Tel (914) 254-6700 Anthony J Vitale Site Vice President NL-16-122 December 2, 2016 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 Nuclear Generating Unit Nos. 2 and 3, License Renewal Application, SET 2016-01 (CAC Nos. MD5407 and MD5408)
Docket Nos. 50-24 7 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 Nuclear Generating Unit Nos. 2 and 3, License Renewal Application, SET 2016-01 (CAC Nos. MD5407 and MD5408)," dated July 25, 2016(ML16208A277)
: 2) USNRC letter, "Service Water and Fire Water Systems Aging Management Programs Audit Report for Indian Point Nuclear Generating Unit Nos. 2 and 3 License Renewal Application (CAC Nos. MD5407 and MD5408)," dated June 15, 2016 (ML16133A459)
: 3) USNRC, "Public Meeting Summary with Entergy Regarding Proposed Changes to the Service Water Integrity Program for the Indian Point Nuclear Generating Unit Nos. 2 and 3 License Renewal Application," October 4, 2016(ML16285A179)

==Dear Sir or Madam:==

Entergy Nuclear Operations, Inc. (Entergy) is providing, in Attachment 1, the additional information requested by Reference 1 pertaining to the U.S. Nuclear Regulatory Commission (NRC) review of the License Renewal Application (LRA) for Indian Point Energy Center (IPEC) Unit Nos. 2 and 3. On February 23-25, 2016, the NRC staff conducted a supplemental regulatory audit to gain a better understanding of Entergy's

NL-16-122 Docket Nos. 50-247 and 50-286 Page 2 of 3 position with respect to LR-ISG-2012-02, "Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation (Reference 2).
On October 4, 2016, subsequent to the NRG staff's issuance of Reference--1, representatives from Entergy met with the NRG staff to discuss proposed enhancements to the Service Water Integrity Program (SWIP), the aging management program for the Service Water (SW) system at IPEC (Reference 3). Reference 1 identifies a due date of October 24, 2016 for this submittal. As a result of the discussions held between the NRG and Entergy at the October 4, 2016 public meeting, a request by Entergy to provide this information by December 1, 2016, was granted.
Changes to the LRA sections resulting from the responses in Attachment 1 are provided in Attachment 2. Changes to the List of Regulatory Commitments are provided in Attachment 3.
If you have any questions, or require additional information, please contact Mr. Robert Walpole at 914-254-6710.
I declare under penalty of perjury that the foregoing is true and correct. Executed on ffee~n~-"-< )-,, , 2016.
Sincerely, AJV/rl Attachments:
: 1. Reply to NRG Request for Additional Information Regarding the License Renewal Application
: 2. License Renewal Application Changes Due To Responses To, Requests For Information
: 3. License Renewal Application IPEC List of Regulatory Commitments Revision 29
* NL-16-122 Docket Nos. 50-247 and 50-286 Page 3 of 3 cc: Mr. Daniel H. Dorman, Regional Administrator, NRG Region I Mr. Sherwin E. Turk, NRG Office of General Counsel, Special Counsel Mr. William Burton, NRG Senior Project Manager, Division of License Renewal Mr. Douglas Pickett, NRR Senior Project Manager Ms. Bridget Frymire, New York State Department of Public Service Mr. John B. Rhodes, President and CEO NYSERDA NRG Resident Inspector's Office

ATTACHMENT 1 TO NL-16-122 REPLY TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE LICENSE RENEWAL APPLICATION ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286

NL-16-122 Attachment 1 Page 1 of 21 RAI 3.0.3-9

===Background===
By letter dated December 16, 2014 (ML14365A069), Entergy Nuclear Operations, Inc.
(Entergy), stated the following:
* The Fire Water System Program includes volumetric wall thickness measurements used to ensure that wall thickness is within required stru*ctural _
limits. Entergy also stated that wall thickness measurements conducted for IP2 prior to the end of its original operating term did not identify any unacceptable wall thinning. Entergy also stated that, "[l]ocalized corrosion has resulted in minor through-wall leaks that have no impact on system performance and do not threaten the structural integrity of the piping or the safety function of nearby equipment." Entergy did not propose any changes to' its Fire Water System Program to address recurring internal corrosion (RIC).
* Loss of material in the city water system is managed by the Periodic Surveillance and Preventive Maintenance Program. Entergy also stated that, "[h]owever, based on past operating experience, they [through-wall leaks] do not              ..
compromise the intended functions of these or any other system, and do not warrant aging management program activities beyond those provided by established aging management programs and the corrective action program." In its letter dated September 26, 2012(ML12285A084), Entergy.stated that visual inspection or other NOE techniques will be used to inspect a representative sample of the internals of city water piping, and piping components to manage loss of material. Entergy did not propose any changes to its Periodic Surveillance and Preventive Maintenance Program to address RIC.
* It appears that two events have impacted the performance of the fire water system.
    * . IP2 - NRC Integrated Inspection Report 050000247/2003011 (ML033140584) documents a September 10, 2003, 80 gallon per minute leak that resulted in the fire water header not being available to perform its intended function for approximately three hours. The apparent cause for this leak states, "[t]he apparent cause for the pin-hole leak is age related corrosion degradation of the piping, specifically, high-oxygenation pitting corrosion. The piping is original Unit 1 equipment, schedule 40 un-lined black steel pipe that is approximately 45 years old. The follow-up UT inspections indicated that the corrosion mechanism that resulted in the pinhole was not general pipe corros_ion but was localized in
* the pinhole. The periodic testing of the system introduces fresh oxygen to the system and such cyclic re-oxygenation results in pits caused by 'high-oxygenation corrosion.' These pits then grow to become thru wall pinhole leaks in the piping. Portions not subject to periodic flow are not subject to this corrosion mechanism."
* NL-16-122 Attachment 1 Page 2 of 21
* IP2 - NRC Integrated Inspection Report 05000247/2015001 and 05000286/2015001 (ML15133A264) documents a December 29, 2014, failure of a 10-inch piping spool piece in the IP1 high pressure fire protection header that resulted .in the fire water header to IP2 not being available to perform its intended function for about two hours. The failure was as a result of a crack opening up along the longitudinal seam weld along the bottom of the pipe. Three previously identified pinhole leaks were located along the length of the cracked region.
During the supplemental audit conducted on February 23-25, 2016, the U.S. Nuclear
. Regulatory Commission (NRC) staff reviewed a list of leaks in the fire water and city water systems p*rovided by Entergy. These leaks encompassed those occurring from 2007 through 2015. During this timeframe, there were approximately 42 leaks in the fire water system and 14 in the city water system. Sixteen of the fire water leaks were inspected using ultrasonic thickness techniques. Ultrasonic inspections were conducted on an additional 14 locations at IP2. Based on Entergy's evaluation of all of the thickness measurements, structural integrity requirements were met. The NRC staff reviewed Entergy's analytical techniques. Entergy has generated a preventive maintenance activity to perform ultrasonic inspections at the additional 14 locations by 2023; The NRC staff reviewed the ultrasonic thickness reports for two of the leaks associated with the December 29, 2014 failure. The NRC staff projected potential loss of material based on corrosion rates documented in Entergy's calculations. It would appear that structural integrity requirements would have been met on the day of the failure. Based on its review of documents during the audit, the NRC staff concluded that conducting ultrasonic wall thickness examinations will not provide sufficient information to result in prevention of potential future losses of intended function of the fire water and city water system.
The cause evaluation for the September 10, 2003, failure did not provide an explanation as to why the pinhole leak, unlike the numerous other pinhole leaks, resulted in a temporary loss of intended function of the fire water header. Entergy doe~ not have or did not provide an apparent cause report for the December 29, 2014 failure.
Lacking an apparent cause of the failure on December 29, 2014, and the limited causal analysis of the failure on September 10, 2003, the NRC staff lacks sufficient information to conclude that Entergy has implemented effective means to provide reasonable assurance that future losses of intended function of the fire water and city water system will not occur.
RAI 3.0.3-9 Request 1
: 1) State the cause of the failure on December 29, 2014. If possible, provide additional information related to the cause of the failure on September 10, 2003. In particular, if

                                                                                 *
* NL-16~122 Attachment 1
* Page 3 of 21 possible, provide information related to why the pinhole leak, unlike numerous other pinhole leaks, resulted in a temporary loss of intended function of the fire water header during the September *10, 2003, failure.

===Response===
Based upon photographic evidence and contemporaneous field observations of the failed fire protection pipe section, the December 29, 2014 piping leak appears to have been caused by selective seam corrosion attack on the longitudinal seam weld. That seam weld was located along the bottom (6 o'clock position) of the pipe, the same portion of the pipe from which the leakage was observed. Entergy personnel had observed previous leakage along the longitudinal seam weld on the bottom of the piping segment. The selective seam corrosion in the crevice formed by the seam may have
* been exacerbated by microbiologically influenced corrosion (MIC) or under-deposit corrosion. Entergy replaced the affected piping spool piece in the high-pressure fire protection water header.
The leak associated with the September 10, 2003 event began as a pinhole and grew to a nominal 3/8" hole, discharging approximately 80-90 gallons per minute (gpm). The rate of discharge and potential for runoff to adjacent safety-related equipment areas mandated that the fire water supply system be secured until a temporary clamp could be installed. For that reason, there was a temporary loss of intended function of the fire water header. However, during the clamp installation, the system could have been manually returned to service if necessary to combat fire.
RAI 3.0.3-9 Request 2
: 2) State how these causes of failure are related to age-related degradation.

===Response===
These two Indian Point Energy Center (IPEC) fire water sys~em piping leaks are attributed to an aging effect, specifically, loss of material due to corrosion mechanisms, such as pitting, crevice corrosion and MIC.
RAI 3.0.3-9 Request 3
: 3) Propose changes to aging management programs, as applicable, to address
* recurring internal corrosion in the fire water and city water systems or provide the basis as to why changes are not necessary.

===Response===
If loss of material due to corrosion meets the criteria for recurring internal corrosion (defined in LR-ISG-2012-02), then Entergy will conduct' wall thickness measurements
* NL-16-122 Attachment 1 Page 4 of 21 on a representative sample of 25 locations every five years during the period of
*extended operation (PEO) until recurring internal corrosion has subsided. Procedures shall require wall thickness measurements at selected locations to provide a representative sample of the type of pipirig and environment where recurring internal corrosion is identified. The procedures should allo.w for selected grid locations to change based on the relevance and usefulness of the wall thickness measurements.
Additional wall thickness inspections will be performed based on the results of the 25 inspections performed during the five year interval mentioned above.
* If > 1 and s5 degraded locations are found in the five year interval, then as a minimum, 10 additional volumetric examinations of system welds will be performed during the following refueling interval.                  .
* If >5 degraded locations are found, then a minimum of 15 additional volumetric examinations will be performed during the following refueling interval.
In addition to the above, for areas of piping that are found degraded and returned to service, the remaining service life will be calculated and the piping will be re-examined prior to the end of calculated life.
In addition, Entergy will revise the IPEC Fire Water System Program procedures to specify that when individual piping segments are found with multiple leaks or degraded areas that align to indicate selective seam corrosion, then corrective action will be taken .
to replace the affected piping segment.
For the city water system, Entergy's Periodic Surveillance and Preventive Maintenance Program will include periodic inspections, either internal visual or UT wall thickness measurements, of a representative sample of 25 components. The frequency of these inspections is once every five years. In the event that the frequency of internal corrosion meets the criteria for recurring internal corrosion, the frequency of the representative sample of 25 inspections will be increased as follows:
* If > 1 and :s5 degraded locations are found in the five year interval, then as a minimum, 10 additional volumetric examinations of system welds will be performed during the following refueling interval.
* If >5 degraded locations are found, then a minimum of 15 additional volumetric examinations will be performed during the.following refueling interval.
In addition to the above, for areas of piping that are found degraded and returned to service, the remaining service life will be calculated and the piping will be re-examined prior'to the end of calculated life.
The program documents will be revised to reflect these enhancements by .December 31, 2017.

                                                                                     *
* NL-16-122 Attachment 1 Page 5 of 21 RAI 3.0.3-10

===Background===
The NRC staff issued the Safety Evaluation Report (SER) for License Renewal of Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3) in August 2009. As documented in the SER, the NRG.staff concluded that the Service Water Integrity Program was shown to adequately manage the effects of aging. Since the completion of its initial reviews for the SER, as part of its efforts to evaluate information for interim staff guidance in LR-ISG-2012-02, "Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation," the NRC staff identified operating experience at IP2 and IP3 during the intervening years (i.e., after 2009) where, as a result of aging effects, licensing basis functions may have been impacted by certain service water system components or components supported by the service water system. In addition, during its reviews of the more recent events, the NRC staff identified another historical event in 2002 that was not previously described. Based on this recently identified operating experience, the NRC staff needs additional information to evaluate the adequacy of Entergy's Service Water Integrity Program in addressing recurring internal corrosion.
: 1) Licensee Event Report (LER) 286/2002-001 documents corrosion in an 18-inch service water pipe where the remaining wall thickness did not provide sufficient structural integrity. The cement-lined pipe configuration did not appear to be unique, the prior visual inspections did not reveal any missing cement liner or biological growth that are precursors to corrosion of the pipe; however, the existing NRC Generic Letter (GL) 89-13 program did not prevent a loss of pressure boundary due to a known degradation mechanism. It is unclear to the NRC staff that effective changes have been made to ensure that future, similar losses of pressure boundary will not occur in other cement-lined piping
: 2) LER 286/2011-003 documents corrosion in a 10-inch service water pipe involving a prior repair that *caused a safety system functional failure due to flooding.
Entergy's August 18, 2015, letter states that the through-wall failure of the piping was not considered to be due to the effects of aging because the loss of material occurred due to an inadequate repair of the concrete lining. It is unclear to the NRC staff that effective changes have been made to ensure that future, similar loss of intended function involving flooding or prior repairs will not occur in other cement-lined piping.
: 3) LER 247/2011-003 documents inoperable containment fan cooler units due to silt in the service water intake bay and notes that similar silt levels had caused similar issues in 2007. According to Entergy's August 2015 letter, the associated changes to the Service Water Integrity Program were not made to manage the

NL-16-1'22 Attachment I Page 6 of 21 effects of aging, but instead were made to manage the effects of weather-related events. In addition, as a separate action, Entergy changed its associated GL 89-13 program commitment, which potentially allows the service water intake bay silting inspections to be conducted less frequently than given in GL 89...:13. Given the distinction made between age-related silting and event-driven silting, and the change to GL 89-13 commitment, it is unclear to the NAC staff that effective changes have been made to ensure that the effects of aging associated with silting in the service water intake bay are adequately managed.
: 4) LEA 247/2013-004 documents inoperable service water piping that rendered radiation monitors A-49, A-46, and _A-53 non-functional, requiring compensatory action to be taken. The NAC staff identified four subsequent condition reports (CA-IP2-2013-5053, CA-IP2-201-4-1179, CA-IP2-2014-6504, and CA-IP2-2015.:.
3500) documenting additional leaks with the same consequence. The LEA states that full piping replacement was planned for the 2014 refueling outage, and
  . Entergy's August 2015 letter states that 200 feet of this piping was replaced in 2014. Given that leakage has occurred subsequent to the piping replacement, it is unclear to the NAC staff that effective changes have been made to the program to ensure that future, similar recurring leaks will not adversely impact the intended function(s) of the radiation monitors.
: 5) LEA 286/2014-002 documents a leak in a socket welded service water pipe that resulted in an essential service water header being declared inoperable because the leak location did not meet the ASME Code Case N-513-3 criteria. The LEA states that the service water piping and valve flush procedure, 3-PT-A1858, was specifically developed to address recurring leaks in stagnant vent and drain piping, and the procedure is the main barrier for preventing future leaks in carbon steel socket welded piping. In its August 2015 letter, Entergy states that a section was added to the Program governing procedure in July 2011, after Entergy
  *identified that IP2 did not have an equivalent flushing procedure as IP3. Entergy also states that the IP3 flushing procedure has been effective since being
* instituted in 2001. It is unclear to the NAC staff that effective changes have been made to the program because the procedure for preventing leaks apparently does not prevent recurring leaks. It is also unclear whether a comprehensive review has been performed to identify other missing unit-specific procedures for managing the effects of aging.
: 6) The August 2015 response to AAI 3.0.3-4 states more than 600 weld examinations have been performed since 1997 with more than 90 percent of the welds meeting acceptance criteria. The approximately 10 percent of welds that did not meet acceptance criteria can be viewed as the program having prevented about 60 leaks over the span of 18 years. In contrast, the listing for the number of leaks in the response indicates there have been over 90 leaks that the program did not prevent in 11 years. Although Entergy has made efforts to manage the effects of aging associated with recurring leaks, it is L,1nclear whether the

NL-16-122 Attachment 1 Page 7 of 21 significance (i.e., multiple instances of loss of intended function) of these leaks will be limited as ongoing corrosion occurs.
: 7) Entergy's December 2014 letter included an enhancement to the Service Water Integrity Program to evaluate through-wall leakage using the corrective action program. Although all conditions adverse to quality should be entered into the corrective action program and evaluated, given the need for this enhancement, it is unclear to the NRC staff whether previous leaks were evaluated under the corrective action program and, consequently, considered during previous operating experience reviews of corrective action documents. In addition, the basis for the December 31, 2019, completion date for this enhancement is unclear.
Request
: 1) Regarding the issues discussed above in LER 286/2002-001, provide information to show that changes made to the program (since that time) provide reasonable
     *assurance that recurrence of the loss of function in other cement-lined piping is unlikely.
: 2) For LER 286/2011-003:
: a. Provide the bases for reasonable assurance that the Service Water Integrity Program compensates for all past liner repairs such that this degradation mechanism will not result in a loss of intended function of the service water system. Also, provide the bases for reasonable assurance that all locations where flooding due to system leakage could cause loss of intended function have been identified and evaluated for probable leak rates.
: b. For the previous operating experience reviews for license renewal, identify past degradation involving through-wall leakage that was not considered to be due to the effects of aging, and provide the bases to demonstrate that the cause of through-wall leakage has been adequately addressed to prevent a recurrence of a loss of safety function.
: 3) For LER 247/2011-003, clarify whether silt monitoring of the intake bays is included as an aging management activity. Provide the basis to demonstrate that the Service Water Integrity program, as modified by the December 201 O commitment changes, provides reasonable assurance that silting cannot result in a loss of intended function of the service water system.
: 4) For LER 247/2013-004, and subsequently issued condition reports CR-IP2-2013-5053, CR-IP2-2014-1179, CR-IP2-2014-6504, and CR-IP2-2015-3500:

                         * ,, l *' -~ -:-~ - - -.
                                                                             " NL~t6-122 Attachment 1 Page 8 of 21
: a. Describe what aspects of the Service Water Integrity Program will provide reasonable assurance that the intended function of these in-scope components will not be lost during the period of extended operation.
: b. Provide an explanation for the continuing non-functionality of the radiation monitoring*system given that 200 feet of the associated piping was replaced in 2014.                                  *
: 5) As it pertains to LER 286/2014-002:
: a. State the basis for why the current Service Water Piping and Valve Flush procedure will provide reasonable assurance that the intended function of the service water system will be met. Address the effectiveness of the procedure in mitigating the leaks that it is intended to prevent, and discuss the basis for not needing to change the procedure to address recurring leaks in stagnant vent and drain piping.
: b. Provide the bases establishing reasonable assurance that there are no other missing unit-specific aging management procedures being credited in the Service Water Integrity Program.
: 6) For the specific recurring internal corrosion category of cement-lined piping, state the minimum number of augmented inspections that will be performed in response to any identified leakage associated with corrosion. If augmented inspections will not be performed, provide an assessment based on observed corrosion rate ranges to provide reasonable assurance that structural integrity of the service water piping will be maintained throughout the period of extended operation.
: 7) For components managed by the Service Water Integrity Program:
a) List the past degradation due to through-wall leakage issues that have not been evaluated under the corrective action program. VVithin the list provide the date, description of the issue, the basis for why it was not addressed in the corrective action program, and whether the issue was considered during the development of the program elements of the Service Water Integrity Program.
b) Provide the basis to justify the December 31, 2019 implementation date of this enhancement.                                                *

                                                                                  ***** NL-1ff-1'22 Attachment 1 Page 9 of 21
* RAI 3.0.3-10 Request 1 Regarding the issues discussed above in LER 286/2002-001, provide information to show that changes made to the program (since that time) provide reasonable assurance that recurrence of the Joss of function in other cement-lined piping is unlikely.

===Response===
Event Summary The event descr.ibed in LER 286/2002-001 wa~ the result of loss of material due to long-term crevice corrosion of the weld and piping base metal at a joint between tw_o piping segments . The piping is carbon steel cement-lined piping. At the *weld joints, there are small gaps between the ends of the cement liner on each side of the joint.. The gap allows river water to contact the bare metal of the weld inside diameter (ID), which can cause corrosion of the weld metal over time.. Furthermore, the gap can allow river water to seep under the cement liner causing corrosion of the base metal. Therefore, the program inspections specifically target weld locations .
Extent of Condition Review In response to the 2002 event, the piping of the service water header that remained in service was inspected to verify no leakage. Ultrasonic testing Was performed on a similar weld on the in-service header, which demonstrated that the weld had acceptable thickness. The extent of condition review also included review of prior inspections of this 18-inch diameter line (line number 409) that was examined by a boroscope . This previous inspection revealed no signs of missing cement liner or biological growth which can be a precursor to corrosion of the piping or weld metal. The GL 89-1 ~ corrosion monitoring program schedule was adjusted to include radiographic testing of four additional weld locations of similar pipe size and flow characteristics prior to the March 2003. refueling outage.
Program Changes since 2002 While no specific changes were made to the program directly as a result of the event reported in LER 286/2002-001, following the event reported in LER 286/2011-003, provisions were added to the program to ensure that nonsafety-related SW piping at locations where a leak can cause flooding, and where this flooding could prevent personnel from manually operating valves, is inspected on the same priority and frequency as safety-related SW piping. This program modification provides additional assurance that leakage from nonsafety-related cement-lined SW piping will not impact the ability of safety-related equipment to fulfill its intended functions .
Operating Experience Review

                                -**", 1-,-: . ,-, .*'* . *.                      *
* NL-=-16-122 Attachment :1 Page 10 of 21 A review of IPEC operating experience (OE) data, as documented in condition reports and Licensee Event Reports, for the period from January 2004 through August 2016, was performed. During this review, Entergy identified recurring internal corrosion (RIC) as defined in LR-ISG-2012-02. Some of the identified conditions in the SW system are similar to the condition described in LER 286/2002-001. Corrosion at the crevice of the cement lining on carbon steel system piping welds has occurred and, in some cases, has resulted in a loss of*
intended function.
Augmented Inspections The weld that leaked on 18-inch diameter line No. 408 (4/~/6 FCU supply header) described in LER 286/2002-001 had not been selected as an inspection sample prior to the leak. Following the 2002 leak, additional cement-lined piping welds on 18-inch diameter line No. 409 (1/2/3 FCU supply header) located in the primary auxiliary building SW pipe chase were inspected during the 2003 refueling outage. This ensured that all welds on the 1/2/3 FCU supply header had been inspected since the refueling outage in 1999. All welds in the 4/5/6 FCU header (18 inch - line No. 408) containing the leak described in LER 286/2002-001 were examined during the 2005 refueling outage.
A key element of the Service Water Integrity Program is the use of predictive ll)Onitoring. Entergy conducts an ongoing program of volumetric non-destructive examination (NOE) of SW system piping welds to obtain information on weld structural integrity. Since 2002, over 700 welds between both IPEC units have been inspected.
These inspections utilized volumetric techniques. An emphasis for inspection sampie selection is placed on system welds that could place the plant in a short-term (72 hour
* or less) TS limiting condition for operation (LCO) completion time, as was the case for the event discussed in LER 286/2002-001. In addition to LCO considerations, the inspection schedule takes into account the required minimum wall thickness and the available margin. Welds with a lower calculated remaining service life would be scheduled for re-inspection accordingly. Of the welds inspected, a number have been identified for repair/replacement and a number are also being tracked for periodic follow-up NOE under the program. This would ensure welds are repaired or re-inspected, thereby ensuring structural integrity is maintained and no loss of function occurs during the predicted remaining service life.
Additional Program Enhancements The*follQwing enhancements will be made to the Service Water Integrity Program.
: 1. A minimum number of volumetric weld examinations for safety-related 10 CFR 54.4(a)(1) cement-lined SW piping will be performed. The volumetric examinations will determine the extent of wall thinning. A degraded location, as defined in LR-ISG-2012-02, will be considered a location with a through-wall leak or a location with greater than 50 percent reduction of wall thickness from nominal thickness.

                                                                                * -- **
* Nl:16-122 Attachment 1 Page 11 of 21
* Program procedures will be revised to specify a minimum of 10 volumetric.weld examinations on each unit's SW system cement-lined piping during each refueling interval.            *
* If > 1 and .$.5 degraded locations are found in a specific refueling interval, then as a minimum, 10 additional volumetric examinations of system welds will be performed during the following refueling interval.
* If >5 degraded locations are found, then a minimum* of 15 additional volumetric examinations will be performed during the following refueling interval.
* For areas of piping that are found degraded and returned to service, the remaining service life will be calculated and the piping will be re-examined prior to the end of calculated life.
: 2. The program will be enhanced fo require a minimum of 5 additional volumetric weld examinations if a through-wall leak is discovered in non-safety related portions of the SW system that are within the scope of license renewal for the criterion of 10 CFR 54.4(a)(2).
: 3. The frequency of internal robotic inspections on the system headers at both units will be increased from once during the first 10 years of the period of extended operation to also include once during the second 10 years of 1he period of extended operation.
These program enhancements will include clarifying those activities that are required to satisfy licensing renewal requirements.
* These enhancements will be implemented by December 31, 2017.
RAI 3.0.3-10 Request 2a For LER 286/2011-003:
a) Provide the bases for reasonable assurance that the Service Water Integrity Program compensates for all past liner repairs such that this degradation mechanism will not result in a loss of intended function of the service water system. Also, provide the bases for reasonable assurance that all locations where flooding due to system leakage could cause loss of intended function have been identified and evaluated for probable.leak rates:

===Response===
The following activities provide the bases for reasonable assurance that loss of material, including loss of material resulting from improper liner repairs, will be adequately

                                                                                               -**NL-16~122 Attachment 1 Page 12 of 21 managed to preclude loss of intended function of the cement-lined service water piping during the period of extended operation 1 .
Operating Experience Review Entergy performed another review of site operating experience (OE) to determine whether there have been other instances of inadequate cement liner repairs that resulted in a loss of intended function of the SW system. Specifically, personnel reviewed OE for the SW systems at both IPEC units for the period from 2004 to the present to identify leaks similar to the leak described in LER 286/2011-003. The review identified no other instances of loss of safety function due to leakage resulting from improper repairs to internal linings. Because Entergy did not identify any other instances of loss of intended function due to an improperly repaired cement liner, and considering the program enhancements discussed in response to Request 1, there is a reasonable assurance that this condition will not result in loss of intended function in the future. The majority of the SW system leaks have been minor leaks that do not result in a leak rate large enough to result in a loss of the system's intended function.
External Inspections As documented in the condition report associated with LER 286/2011-003, visual inspections were performed on similar locations in the SW valve pits at both IPEC units where the potential for flooding is a concern. Those inspections did not identify any other leaking locations in the SW piping.
* In addition, IPEC system engineers perform quarterly inspections of accessible portions of the SW system and operations personnei conduct routine field observations during operator rounds.*
Internal Inspections As part of the Service Water Integrity Program, internal robotic inspections are performed of the main system headers and accessible piping in"the primary auxiliary Under 10 CFR &sect; 54.29(a), the NRC may issue a renewed license upon finding that actions have been identified, and have b~en or will be taken, to manage the effects of aging on structures and components that perform license renewal intended functions, such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the current licensing basis (CLB). The license renewal process "is not intended to demonstrate absolute assurance that structures or components will not fail, but rather that there is reasonable assurance that they will perform such that the intended functions, as delineated in &sect; 54.4, are maintained consistent with the CLB." Final Rule, Nuclear Power Plant License Renewal; Revisions, 60 Fed. Reg. 22,461, 22,479 (May 8, 1995). See also NUREG-1800, Rev. 2, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants," App. A at A.1-1 (Dec. 2010). Thus, in this context, Entergy is not required to provide absolute assurance that SW piping will not leak. Instead, it must show, through appropriate preventive actions and/or condition monitoring, that there is reasonable assurance that it will adequately manage the loss of material due to internal corrosion, such that that intended safety functions of IPEC SW piping are maintained consistent with the CLB for the period of extended operation.

                                                                                  - * ' NL-16"122 Attachment 1 Page 13 of 21 building for each IPEC unit. These inspections of the large-bore cement-lined piping headers assess the material condition of the internal cement lining and provide additional assurance that a leak due to degraded liner material is unlikely.
To reduce the probability of an event similar to that reported in LER 286/2011-003, several changes were made to the SWI Program. As part of routine SW system heat exchanger maintenance activities, whenever a heat exchanger is opened, IPEC engineering is contacted to perform a visual inspection. These safety-related heat exchangers include the containment fan cooler units, component coolingwater heat exchangers, emergency diesel generator jacket water and lube oil coolers. Accessible piping is examined as permitted by the opened component. Heat exchanger tubes and tubesheets are visually examined. These inspections include monitoring specifically for evidence of liner degradation, for example, loose cement pieces and damage to tube ends or tubesheets that may have been caused by impact from cement pieces. Similar visual inspections are performed whenever SW system components such as valves are removed.                                                        *
* Volumetric Inspections The following activities provide additional assuranc~ that a SW system leak is unlikely to cause a loss of safety function in an area subject to flooding.
* As a result of the LER, the Service Water Integrity Program was revised to specifically require. inspections of non-safety related SW piping in locations where a leak can cause flooding, with the same priority and at the same frequency as safety-related SW piping.
Piping Material Upgrades At a number of plant locations, SW piping has been replaced with a material having
. corrosion resistance characteristics that are superior to those of the original cement-lined carbon steel piping. Using a proven corrosion-resistant pipe material greatly reduces the potential risk of leakage in an area where flooding is a concern. The Unit3 switchgear room in the control building is an example of a location where flooding is a concern. Consequently, the service water piping to the instrument air compressor cooling water heat exchangers that passes through this room was replaced with more corrosion-resistant material.
Related Event In addition to the leak reported in LER 286/2011-003, a minor leak was identified in the same valve pit in 2013. The leak was not similar in nature (i.e., size or cause) to the leak reported in LER 286/2011-003. The leak rate was well within the capacity of sump pumps in the valve pit, such that flooding conditions sufficient to challenge the safety function of the SW system did not exist. The characteristics of the flaw were also

                               ' .. -., . .. ' ~ . , . '~...'                     * **** NL"16-t22 Attachment 1 Page 14 of 21 different. The leak cause was identified as localized crevice corrosion. In contrast,. the flaw discovered in 2011 was caused by extensive corrosion that resulted from the improper repair of the cement lining. Volumetric examination showed that the 2013 flaw did not impactthe structural integrity of the affected piping. The flaw was evaluated under the corrective action program and did not result in a loss of system intended function. Cement liner degradation was not identified as a cause in the repair work order.
Future Program Enhancements
: 1. Entergy will review the SW system to identify areas where leakage from nonsafety-related SW piping cOuld result in unacceptable flooding. The SWI Program will be reviewed to verify that this nonsafety-related piping in locations subject to flooding concerns is clearly identified in the program document. The SWI Program willbe revised to specify volumetric examination of at least 20 percent of (up to a maximum of 25) nonsafety-related welds located in areas subject to flooding of safety-related equipment within each 10-year period of the PEO. This enhancement will be completed by December 31, 2017.
: 2. The SWIP will be enhanced to specify a yearly OE review to look for any failure due to the effects of aging, specifically including any failures related to inadequate cement liner repairs which may have occurred in the prior year. This enhancement will be completed by December 31, 2017.
RAI 3.0.3'."'"10 Request 2b For LER 286/2011-003:
For the previous operating experience reviews for license renewal, identify past degradation involving through-wall leakage that was not considered to be due to the effects of aging, and provide the bases to demonstrate that the cause of through-wall leakage has been adequately addressed to prevent a recurrence of a loss of safety function.

===Response===
During the previous operating 13xperience (OE) reviews that were performed relative to LER 286/2011-003, Entergy looked for loss of material due to corrosion. The initial review, however, did not include OE related to this LER because the cause of the LER event was specifically identified as poor workmanship in performing the prior repair and, therefore, was not attributed to an aging effect. Upon further evaluation, it was determined that the LER 286/2011-003 leak was caused by loss of material due to .
corrosion. The poor workmanship during the previous repair .resulted in exposure of the weld to the raw water environment, thereby increasing the material's susceptibility to corrosion.

                               ' .<* l'' ' *\ I.* . ** ' * ' ~
                                                                                   ** "NL-16:122 .
Attachment 1 Page 15 of 21 As a result of this new insight, a more comprehensive understanding of the issue was*
developed. The original OE review would have excluded issues attributed to causes other than the effects of aging. A subsequent review of the same site OE data was performed with a broader consideration of aging effects. No additional occurrences of a loss of intended function were found that had been previously excluded based ori classifying the cause as unrelated to the effects of aging. Therefore, Entergy concludes that the causes of through-wall leakage observed in the OE review have been adequately ,considered in determining the appropriate actions to prevent loss of license renewal intended function.
RAI 3.0.3-10 Request 3 For LER 247/2011-003, clarify whether silt monitoring of the intake bays is included as an aging management activity. Provide the basis to demonstrate that the Service Water Integrity program, as modified by the December 2010 commitment changes, provides reasonable assurance that silting cannot result in a Joss of intended function of the service water system.

===Response===
Silt monitoring of the SW intake bays is included in the IPEC Service Water Integrity Program. The program descriptions in the IP2 and IP3 UFSAR supplements (Appendix A) for license renewal will be revis_ed to indicate that silt monitoring is a program activity*.
Silt accumulation can be the result of acute (short-term) events such as storms or chronic (long-term) effects over an extended period of time. The original monitoring for silt described in the IPEC GL 89-13 response was established strictly on a time basis. It did not consider the higher short-term rates of silting that could result from excessive rainfall or storms. Via the corrective action program, corrective actions from the 2007 silting event, LER 247/2011-003,. and SOER 07-2, "Intake Cooling Water Blockage",
were incorporated into the SWI Program. These changes were made to keep the SW system intakes clear of silt irrespective of the cause - i.e., short-term event or long-term chronic silt accumulation.
GL 89-13 Commitment Change In the original responses to GL 89-13, Required Action I, both Consolidated Edison and the New York Power Authority committed to implement a program to visually inspect the SW intake structure bays at a frequency of once per refueling outage at ln_dian Point Units 1, 2, and 3. The original tasks to visually inspect (via diver inspection) the intake bays at IP2 and IP3 were eliminated due to safety concerns related to entering the intake bays with any of the SW pumps running. In addition to the safety concerns, water turbidity and murkiness limited the efficacy of visual inspections in determining bay conditions. Consequently, in November 2010, the commitments to visually inspect

                                  .. ' * ~ ' '. : ! ..,
                                                                                  ***
* Nt~16-122 Attachment 1 Page 16 of 21 the SW intake bays at IP2 and IP3 were replaced with commitments to perform silt mapping using a sonar technique.
In accordance with IPEC procedures, Entergy performs the following activities to manage silt accumulat,ion in the intq,ke bays.
: 1. At 3-month intervals, IP2 and IP3 perform silt mapping of the SW bays using sonar.
: 2. Every 24 months, divers inspect the IP1 intake structure for structural integrity of the bay components, biofouling, and silt and debris.
: 3. Full desilting and debris removal from the SW bays is performed at the following frequencies:                                      *
: a. Unit 1: every 8 years with 25 percent grace
: b. Unit 2: every 4 years with no grace
: c. Unit 3: every 10 years with 25 percent grace Note: The different frequencies between Unit 2 and Unit 3 are due to differences in designs (i.e., the bottoms of the Un.it 3 SW pump columns are further above the bottom of the bays than are the bottoms of the Unit 2 SW pump columns).
These activities provide reasonable assurance that silting will not cause a loss of intended function of the SW system.
RAI 3.0.3-10 Request 4a For LER 24712013-004, and subsequently issued condition reports CR-IP2-2013-5053, CR-IP2-2014-1179, CR-IP2-2014-6504, and CR-IP2-2015-3500:-
a) Describe what aspects of the Service Water Integrity Program will provide reasonable assurance that the intended function of these in-scope components will not be lost during the period of extended operation.

===Response===
The causes of the loss of intended function of the components addressed in LER 247/2013-004, and subsequently issued condition reports CR-IP2-2013-50.53, CR-IP2-2014-1179, CR-IP2-2014-6504, and CR-IP2-2015-3500, were (1) loss of material due to pitting corrosion in service water piping and tubing, and (2) loosening of tubing fittings (Swagelok connections) due to freezing of the fluid in the tubing. During normal plant operations, the lines are in service. However, there are no provisions in place for proper lay-up of the system when the service water lines are secured. During the time the system was out of service following the event reported in LER 247/2013-004, stagnant conditions accelerated pitting corrosion in the 316 series stainless steel tubing.
Additionally, extreme cold weather conditions during this same time, in conjunction with
.failure of the heat trace system, led to freezing within the tubing. That freezing caused separation of Swagelok connections and thus additional leaks.

NL:.tff'-122 Attachment 1 Page 17 of 21 All welded piping within the IP2 primary auxiliary building (PAB) SW pipe chase (i.e., for leaks documented under CR-IP2-2013-03759 and CR-IP2-2013-05053) has been replaced with a corrosion-resistant 6 percent molybdenum stainless steel alloy (AL6XN).
IPEC operating experience has shown that this material exhibits excellent corrosion resistance in brackish Hudson River water. This piping material upgrade provides reasonable asstmmce that the intended function of the weldec;i piping will not be lost during the period of extended operation.
All leaks outside of the PAB within the guard pipe and radiation monitor house have been repaired by retightening the Swagelok tubing joints and replacing sections of tubing.
Plant procedures will be revised to include guidance for lay-up of the SW process radiation monitoring system to minimize exposure of susceptible tubing to stagnant conditions. This enhancement will be completed by December 31, 2017.
The enhancement, in conjunction with the SW piping material upgrades and repairs discussed above, provides reasonable assurance that the effects of aging will not cause a loss of intended function of susceptible tubing* during the period of extended
* operation.
RAI 3.0.3-10 Request 4b For LER 247/2013-004, and subsequently issued condition reports CR-IP2-2013-S053, CR-IP2-2014-1179, CR-IP2-2014-6504, and CR-IP2-2015-3500:
b) Provide an explanation for the continuing non-functionality of the radiation monitoring system given that 200 feet of the associated piping was replaced in 2014.
Response      .
The non-functionality of the SW process radiation monitoring system that occurred after the spring of 2014 was not related to the approximately 200 feet of piping that was replaced in 2014 (2R21). The piping that was replaced in 2014 included only the welded portion of the system that was located within the primary auxiliary building (PAB). Leaks occurring subsequent to that replacement were in the stainless steel tubing of the SW lines.
Leaks from the tubing outside of the PAB within the guard pipe and radiation monitor house have been repaired by retightening the Swagelok tubing joints and replacing sections of tubing. Some of these repair activities occurred as recently as the first quarter 'at 2016 during the IP2 refueling outage.

                               . * . * * * * "**!*+'.' ** ,,
                                                                                      .. NL-16~122 Attachment 1 Page 18 of 21 RAI 3.0.3-10 Request Sa As it pertains to LER 286/2014-002:
a) State the basis for why the current Service Water Piping and Valve Flush procedure will provide reasonable assurance that the intended function of the service water system will be met. Address the effectiveness of the procedure in mitigating the leaks that it is intended to prevent, and discuss the basis -ror not needing to change the procedure to address recurring leaks in stagnant vent and drain piping.

===Response===
 *The Hudson River is a natural water source thatcontains various minerals and silt.
These substances tend to'deposit and accum_ulate,in stagnant small-bore piping, such as vents and drains. This condition is seen more in carbon steel piping than in brass or stainless steel piping since brass and stainless steel piping have a smoother interior surface. However, all materials are susceptible to this condition.
After years of service, small bore piping with stagnant conditions (e.g., piping used for vents' and drains).can become clogged if not flushed or otherwise cleared. Clogged, dead-ended, stagnant pipe creates favorable conditions for corrosive anaerobic bacteria (the cause of microbiologically influenced corrosion (MIC)), which is naturally present in the river. Biocides (e.g., sodium hypochlorite) injected into the SW systems are ineffective in these areas because the biocide cannot penetrate the clogged area. Most MIC manifests as pits thaMorm underneath colonies of living organic matter, mineral,,
and bio-deposits. These deposits create an environment in which corrosion may be accelerated. To address this issue, piping vent and drain connections are periodically
* flushed to remove 'silt, organic matter, and other debris.
At IP3, these actions are accomplished utilizing a series of flushing procedures .. At IP2, similar procedures were developed in 2012 and were scheduled for performance once every two years. The flushing procedures were developed at both units by identifying susceptible piping lines, valves, and branch connections via review of system flow diagrams. The acceptance criteria in the flushing procedures are satisfied when all locations identified are satisfactorily flushed, the valves closed, and the piping.
caps/flanges/plugs restored. If any components fail to meet these criteria, then work requests must be initiated for component repairs. Failure to flush one or more piping connections does not necessarily impact SW system operability.
Thus, the strategy to manage MIC at IPEC includes: 1) flushing the lines, 2) inspecting for leaks, and 3) replacing sections of piping that are susceptible to corrosion with improved material types. Additionally, Operations and Engineering personnel perform periodic system inspections, during which leaks, if any, are identified. Although small leaks have occurred, these actions provide reasonable assurance that loss of material

NL~16.:122
                              .. r:. ***"'" ._,,,.,
Attachment 1 Page 19. of 21 in the small-bore SW system piping will be managed such that the system's intended functions are maintained consistent,with the current licensing basis (CLB) during the period of extended operation. Some leaks have occurred in sections of piping that cannot be evaluated as operable from a structural point of view because the configuration does not match acceptable code case evaluation configurations. For those cases where NOE techniques are not suitable to demonstrate structural integrity, the system is declared inoperable and repairs are undertaken.
Future Program Enhancements An enhancement will be made to the program to establish recurring internal corrosion goals for stagnant vent and drain connection piping. If these recurring internal corrosion
* goals are not met, Entergy will increase the frequency for flushing the affected stagnant vent and drain connection piping. The program document will be revised to reflect this enhancement by December 31, 2017.
RAI 3.0.3.:..10 Request Sb As itpertains to LER 28612014-002:
b) Provide the bases establishing reasonable assurance that there are no other missing unit-specific aging management procedures being credited in the Service Water Integrity Program.

===Response===
A condition report was generated in October 201 O upon discovery that there was no IP2
. procedure similar to IP3 procedure 3PT-R185 for flushing small bore vents and drains in the SW system. The issue at IP2 was identified shortly after Entergy cOmbined the IP2 and IP3 programs. In developing a combined program document for both units, Entergy_.
performed a side-by-side evaluation of each unit's programs. No other differences             .. ,.,.,
between units were identified related to implementing procedures for the program.
RAI 3.0.3-10 Request 6 For the specific recurring internal corrosion category of cement-lined piping, state the minimum number of augmented inspections that will be performed in response to any identified leakage associated with corrosion. If augmented inspections will not be performed, provide an assessment based on observed corrosion rate ranges to provide reasonable assurance that structural integrity of the service water piping will be maintained throughout the period of extended operation.

                            .' .. ''t* ,... '*. -~ " ... ' '
                                                                                 .. '* NL"16-122 Attachment 1 Page 20 of 21

===Response===
The additional program enhancements described in the response to Request 1 specify the numbers of inspections for cement-lined piping. The enhancements establish a minimum number of inspections per refueling *cycle interval and provide for augmented (additional) inspections depending on the number of degraded piping locations found during the pe(iod.
RAI .3.0.3-10 Request 7a For components managed by the Service Water Integrity Program:
a) List the past degradation due to through-wall leakage issues that have not been evaluated under the corrective action program. Within the list provide the date,
* description of the issue, the basis for why it was not addressed in the corrective action program, and whether the issue was considered during the development of the program elements of the Service Water Integrity Program.

===Response===
The Corrective Action Program procedure provides instructions for the prompt identification, reporting, evaluation, and correction of adverse conditions and conditions adverse to quality. The enhancement included in Entergy's December 2014 letter was intended to make explicit in the Service Water ln_tegrity Program procedures the requirement to identify and evaluate through-wall leakage in the SW system using the Corrective Action Prag-ram. Through-wall piping leakage, regardless of plant system, or nuclear safety or ISi classification, is a condition that is entered into the Corrective Action Program. Entergy has identified no past SW system through-wall leakage issues at either IP2 or IP3 that have not been evaluated under the Corrective Action Program.
RAI 3.0.3-10 Request 7b For components managed by the Service Water Integrity Program:
b) Provide the basis to justify the December 31, 2019 implementation date of this enhancement.

===Response===
The timing of program activities recommended in LR-ISG-2012-02 is tied to the date a unit will enter the period of extended operation (PEO). At the time Entergy filed its response to RAls associated with LR-ISG-2012-02 on December 16, 2014, IP2 had entered the PEO and IP3 was less than a year away from entering the PEO. Therefore, the date of entering the PEO was not a realistic date for implementing the program enhancements described in the response to the ISG-related RAls. Consequently, in the

NL~16"122 Attachment 1 Page 21 of 21 RAI respons:es submitted on December 16, 2014, Entergy identified December 31, 2019, as the implementation date, which it viewed as an appropriate surrogate to the date for entering the PEO. Thus;where the ISG specifies activities to be completed "prior to the period of extended operation," Entergy intends to complete those activities at IPEC for both units prior to December 31, 2019.
The ISG provided a ten-year window in which to perform the first inspections prior to the PEO. Since IPEC did not have ten years from the time the RAI was received, a five-year period was deemed reasonable. The five-year period (December 2014 through.
December 2019) allows two outages for each unit in which to perform the specified inspections, some of which can only be performed during an outage. The scope of an outage is established many months in advance to allow for adequate planning and coordination, including coordination with system and train outages that may only occur during alternate refueling outages. Given that the ISG provided a ten-year window for the first inspections, the five-year window for IPEC is reasonable to allow for adequate planning and scheduling around and within outage windows.
The implementation date of "prior to December 31, 2019," allows for the following activities to occur:
* Planning the activities specified in the ISG as ordinarily being performed prior to the PEO.
        * ' Revising procedures to include the enhancements described in the LRA.
* Ensuring availability of test equipment as needed.
* Scheduling and completing the activities specified in the ISG as ordinarily being performed prior t6 the PEO.       *         .
* Working with two units, each with two-year operating cycles affecting opportunities for inspections.
        *
* Assessing the results from the activities specified in the ISG as ordinarily being performed prior to the PEO.
* Determining corrective actions as needed.
* Establishing scope and frequency for future activities.
* Planning and scheduling the activities specified in the ISG to be performed during the PEO.
* Scheduling inspections for refueling outages.
* Scheduling 10-year inspections as specified.
                                                                                      ,.,

ATTACHMENT 2 TO NL-16-122 LICENSE RENEWAL APPLICATION CHANGES DUE TO RESPONSES TO REQUESTS FOR INFORMATION

NL"16-122 Attachment 2 Page 1 of 9 LRA Sections A.2.1.13, A.2.1.28, A.2.1.33, A.3.1.13, A.3.1.28, A.3.1.33, 8.1.14, 8.1.29, and 8.1.34 are revised as shown below. Additions are underlined.
A.2.1.13 Fire Water System Program
* Revise Fire Water System Program procedures by December 31, 2017 to address recurring internal corrosion at least once every five years during the PEO until recurring internal corrosion has subsided:
a) Require wall thickness measurements at selected locations to provide a representative sample of 25 locations.
b) Require additional wall thickness measurements based on the following:
* If > 1 and <5 degraded locations are found in the five-year intei"Vi!ti7then as a minimum, 1O additional volumetric examinations of system Welds will be performed during the following refueling interval.                  **
* If >5 degraded locations are found, then a minimum of 15 additional volumetric examinations will be performed during the following refueling interval.
c) For areas of piping that are found degraded and.returned to service. the remaining service life will be calculated and the piping will be re-examined prior to the end of calculated life.                                                 .
d) Allow for selected grid locations to change based on the relevance and usefulness of the wall thickness measurements.
e) Specify that when individual piping segments are found with multiple leaks or degraded areas that align to indicate selective seam corrosion, then corrective action will be taken    *-.;-.
to replace the affected piping segment.
A.2.1.28 Periodic Surveillance and Preventive Maintenance Program A representative sample of at least 25 inspections of city water piping will be performed at least every five years. In the event that the frequency of internal corrosion meets the criteria for .
recurring internal corrosion. the frequency of the representative sample of 25 inspections will be
. increased as follows:
* If > 1 and <5 degraded locations are found in the five year Interval. then 1O additional volumetric examinations of system welds will be performed during the following refueling interval.
* If >5 degraded locations are found, then 15 additional volumetric examinations will be performed during the following refueling interval.
In addition to the above. for areas of piping that are found degraded and returned to service, the remaining service life will be calculated and the piping will be re-examined prior fo the end of calculated life.
 *A.2.1.33 Service Water Integrity Program The Service Water Integrity Program is an existing program that relies on implementation of the recommendations of GL 89-13 to ensure that the effects of aging on the service water system are managed through the period of extended operation. The program includes component .

                                                                                           .. NL-16~122 Attachment 2 Page 2 of 9 inspections for erosion, corrosion, and biofouling to verify the heat transfer capability of safety-related heat exchangers cooled by service water and monitoring of the silt levels in the intake bays. Chemical treatment using biocides and sodium hypochlorite and periodic cleaning and flushing of infrequently used loops are methods used to control fouling within the heat exchangers and to manage loss of material in service water components. Scheduling of nonsafety-related piping examinations is determined by trending of examination results.
Selection of large bore service water pipe points for voltJmetric inspection is based on piping configuration, results from previous inspections, consideration of follow-ups to previous repairs, and condition assessments when components are opened during preventive maintenance activities. Scope expansion for indications found by program inspections of nonsafety-related piping is based on engineering analysis, judgment and program experience. The factors that are considered include'piping location, severity of use, piping materials, previous in~pection results, and repair history.                                                   ,            *,
* Revise Service Water Integrity Program procedures by December 31 2017 to address the I
following:
a) Perform a minimum number of volumetric weld examinations for safety-related cement-lined SW piping. The volumetric examinations will determine the extent of wall thinning.
A degraded location will be considered a location with a through-wall leak or with greater than 50 percent reduction of wall thickness from nominal thickness.,
         ~ Perform a minimum of 1O volumetric weld examinations for cement-lined piping on the IP2 SW system during each refueling interval.
         ~ If > 1 and <5 degraded locations are found in a specific refueling interval, then 1O additional volumetric examinations of system welds will be performed during the following refueling interval.
         ~* If >5 degraded locations are found, then 15 additional volumetric examinations will be performed during the following refueling interval.
b) For areas of piping that are found degraded and returned to service, the remaining service life will be calculated and the piping will be, re-examined prior to the end of calculated life; c) Require a minimum of 5 additional volumetric weld examinations if a through-wall leak is discovered in non-safety related portions of the SW system that are within the scope of license renewal for 10 CFR 54.4(a)(2).
d) Increase the frequency bf internal robotic inspections on the system headers at both units from once during the first 1O years of the period of extended operation to also.
include once during the second 1O years of the period of extended operation.
e) Review the SW system to identify areas where leakage from nonsafety-related SW piping could result in unacceptable flooding and ensure the nonsafety-related piping that can cause flooding concerns is clearly identified in the program documents. Specify volumetric examination of at least 20 percent of (up to a maximum of 25) non-safety related welds located in areas subject to flooding of safety-related equipment within each 10-year period of the PEO.
* NL-16-122 Attachment 2 Page 3 of 9 f)  Specify a yearly OE review to identify any effects of aging reported on the SW system.
specifically including any conditions that may have occurred in the prior year related to inadequate cement liner repairs.
g) Include guidance for lay-up of the SW process radiation monitoring system to minimize
.* 7, ..
* exposure of susceptible tubing to stagnant conditions.
h) Establish recurring internal corrosion goals for stagnant vent and drain connection piping. If these recurring internal goals are not met. the frequency for flushing stagnant vent and drain connection piping will be increased.
A.3.1.13 Fire Water       Sys~~m   Program
* Revise Fire Water System Program procedures by December 31, 2017 to address recurring internal corrosion at least once every five years during the PEO until recurring internal corrosion has subsided:
a) Require wall thickness measurements at selected locations to provide a representative sample of 25 locations.
b) Require additional wall thickness measurements based on the following:
* If >1 and <5 degraded locations are found in the five-year interval. then as a minimum, 1O additional volumetric examinations of system welds will be performed during the following refueling interval.
* If >5 degraded locations are found, then a minimum of 15 additional volumetric examinations will be performed during the following refueling interval.
c) For areas of piping that are found degraded and returned to service. the remaining service life will be calculated and the biping will be re~examined prior to the end of calculated life. " ,.
d) Allow for selected grid locations to change based on the relevance and usefulness of the wall thickness measurements.
e) Specify that when individual piping segments are found with multiple leaks or degraded areas that align to indicate selective seam corrosion. then corrective action will be taken to replace the affected piping segment.
A.3.1.28 Periodic Surveillance and Preventive Maintenance Program A represehtative sample of 'at least 25 inspections of city water piping will be performed at least every five years: In the event that the frequency of internal corrosion meets the criteria for recurring internal corrosion, the frequency of the representative sample of 25 inspections will be increased as follows:
* If > 1 and <5 degraded locations are found in the five year interval. then as a minimum, 1O additional volumetric examinations of system welds will be performed during the following refueling interval.
* If >5 degraded locations are found. then a minimum of 15 additional volumetric .
examinations will be performed during the following refueling interval.

NL-16-122 Attachment 2 Page 4 of 9 In addition to.the above, for areas of piping that are found degraded and returned to service, the remaining service life will be calculated and the piping will be re-examined prior to the end of calculated life.
A.3.1.33 Service Water Integrity Program The Service Water Integrity Program is an existing program that relies on implementation of the recommendations of GL 89-13 to ensure that the effects of aging on the service water system are managed through the period of extended.'operation. The program includes component inspections for erosion, corrosion, and biofouling to verify the heat transfer capability of safety-
. related heat exchangers cooled by service water and monitoring of the silt levels in the intake bays. Chemical treatment using biocides and chlorine and periodic cleaning and flushing of infrequently used loops are methods used to control fouling within the heat exchangers and to manage loss of material in service water components. Scheduling of nonsafety-related piping
 *examinations is determined by trending of examination results. Selection of large bore service water pipe points for volumetric inspection is based on piping configuration, results from previous inspections, consideration of follow-ups to previous repairs, and condition assessments when components are opened during preventive maintenance activities. Scope expansion for indications found by program inspections of nonsafety-related piping is based on engineering analysis, judgment and program experience. The factors that are considered include piping location, severity of use, piping materials, previous inspection results, and repair histo"ry.
* Revise Service Water Integrity Program procedures by December 31, 2017 to address the
* following:
a) Perform a minimum number of volumetric weld examinations for safety-related cement-lined SW piping. The volumetric examinations will determine the extent of wall thinning.
A degraded location will be considered a location with a through-wall leak or with greater than 50 percent reduction of wall thickness from nominal thickness.
            ~ Perform a minimum of 1O volumetric weld examinations for cement-lined piping on the IP3 SW system during each refueling interval.
            ~ If > 1 and .<5 degraded locations are found in a specific. refueling interval, then 10 additional volumetric examinations of system welds will be performed during the following refueling interval.
            ~ If >5 degraded locations are found, then a minimum of 15 additional volumetric examinations will be performed during the following refueling interval.
b) For areas of piping that are found degraded and returned to service, the remaining service life Will be calculated and the piping will be re-examined p1-ior to the end of calculated life:        *"'''"
c) Require a minimum of 5 additional volumetric weld examinations if a through-wall leak is discovered in non-safety related portions of the SW system that are within the scope of license renewal for 10 CFR 54.4(a)(2).

                                                                                           *
* NtctB-122 Attachment 2 Page 5 of 9 d) Increase the frequency of internal robotic inspections on the system headers at both units from once during the first 1O years of the period of extended operation to also include ohce during the second 1O years of the period of extended operation.
e) Review the SW system to identify areas where leakage from nonsafety-related SW piping could result in unacceptable flooding and ensure the nonsafety-related piping that can cause flooding concerns is clearly identified in the program documei:its. Specify
       *volumetric examination of at least 20 percent of (up to a maximum of 25) non-safety related welds located in areas subject to flooding of safety-related equipment within each 10-year period of the PEO.
f)- Specify a yearly OE review to identify any effects of aging reported on the SW system, specifically including any conditions that may have occurred in the prior year related to inadequate cement liner repairs.
g) Include gu!~nce for lay-up of the SW process radiation monitoring system to minimize exposure of susceptible tubing to stagnant conditions.
i)   Establish recurring internal corrosion goals for stagnant vent and drain connection piping. If these recurring internal goals are not met, the frequency for flushing stagnant vent and drain connection piping will be increased.
B.1.14 Fire Water System Attributes Affected                                Enhancement
: 4. Detection of Aging Effects                 Hevise IP2 and IP3 Fire Water Program procedures by December 31, 2017 to address recurring internal corrosion at least once every five years during the PEO until recurring internal corrosion has subsided:
a) Require wall thickness measurements at selected locations to provide a representative sample of 25 locations b) Require additional wall thickness
                                                  ~     measurements based on the following:
* If > 1 and <5 degraded locations are found in the five year interval,
                             '                              then as a minimum, 1O additional volumetric examinations of system welds will be performed during the following refueling interval.
* If >5 degraded locations are found, then a minimum of 15 additional volumetric examinations will be performed during the following
* NL-16-122 Attachment 2 Page 6 of 9 refueling interval.
c) For areas of piping that are found degraded and returned to service, the remaining service life will be calculated and the piping will be re-examined prfor to the end of calculated life.
d) Allow for selected grid locations to change based on thi3 relevance and usefulness of the wall thickness measurements e) Specify that when individual piping segments
    >
are found with multiple leaks or degraded areas that align to indicate selective seam corrosion. then corrective action will be taken to replace the affected piping segment

NL-16-122 Attachment 2 Page 7 of 9 B.1.29   Periodic Surveillance and Preventive Maintenance Program Description The Periodic Surveillance and Preventive Maintenance Program is an existing program that includes periodic inspections and tests that manage aging effects not managed by other aging management programs. In addition to specific activities in the plant's preventive maintenance program and surveillance program, the Periodic Surveillance and Preventive Maintenance Program includes enhancements to add new activities. The preventive maintenance and surveillance testing activities are generally implemented through repetitive tasks or routine monitoring of plant operations. Credit for program activities has been taken in the aging management review of the following systems and structures. All activities are new unless otherwise noted.
City water system                Use visual or other NOE techniques to inspect a representative samplei- of the internals of city water piping, strainer housing, valve bodies, piping elements, and components exposed to treated water (city water) to manage loss of material. A representative sample of at least 25 inspections of city water piping will be performed at least every five years. In the event that the frequency of internal corrosion meets the criteria for recurring internal corrosion; the frequency
                                          ..  . *.
of
                                                     .
the*
                                                        . .
representative
                                                                .
sample of 25 inspections
                                                                  .*..... '.* ''"*,.,."'-""" "
                                   *will be increased as follows: . *. ' *'*'*. "*'" *
* If > 1 and <5 degraded locations are found in the five year interval, then 1O additional volumetric examinations of system welds will be performed during the following refueling interval.
* If >5 degraded locations are found. then 15 additional volumetric examinations will be performed during the following refueling interval.
In addition to the above. for areas of piping that are found degraded and returned to service. the remaining service life will be calculated and the piping will be re-examined prior to the end of calculated life.
B.1.34 Service Water Integrity Program Description The Service Water Integrity Program is an existing program that relies on implementation of the recommendations of GL 89-13 to ensure that the effects of aging on the service water system are managed through the period of extended operation. The program includes component inspections for erosion, corrosion, and biofouling to verify the heat transfer capability of safety-related heat exchangers cooled by service water and monitoring of the silt level in the intake bays. Chemical treatment using biocides and sodium hypochlorite and periodic cleaning and flushing of infrequently used loops are methods used to control fouling within the heat

---------
                                                                                                  *
* NL-16"122 Attachment 2 Page 8 of 9 exchangers and to manage 'loss of material in service water components. Prioritization of internal examinations of SW piping is based on ~afety classification. Scheduling of nonsafety-related piping examination is determined by trending of examination results. Selection of large bore service water pipe points forvolumetric inspection is based on piping configuration, results from previous inspections, consideration of follow-ups to previous repairs, and condition assessments when components are opened during preventive maintenance activities. Scope expansion for indications found by program inspections of nonsafety:related piping is based on engineering analysis, judgment and program experience. The factors that are considered include piping location, severity of use, piping materials, previous inspection results, and repair history.
Attributes Affected                                  Enhancements
: 4. Detection of Aging Effects        Revised Service Water Integrity Program grocedures by December 31 1 2017 to address the following:
a) - Perform a minimum number of volumetric weld examinations for safety-related cement-lined SW QiQing. The volumetric examinations will determine the extent of wall thinning. A degraded location will be considered a location with a through-wall leak or with greater than 50 gercent reduction of wall thickness from nominal thickness.
                                                 >- Perform a minimum of 1O volumetric weld examinations for cement-lined QiQing on each unit's SW system during each refueling interval.
                                                >- If > 1 and <5 degraded locations are found in a sgecific refueling interval 1 then 10 additional volumetric examinations of system welds will be gerformed during the following refueling interval.
                                                 >- If >5 degraded locations are found 1 then 15 additional volumetric examinations will be gerformed during the following refueling interval.
b) For areas of giging that are found degraded and returned to service 1 the remaining service life will be calculated and the QiQing will be re-examined grior to the end of calculated life.
c) Reguire a minimum of 5 additional volumetric weld examinations if a through-wall leak is discovered in non-safety related gortions of the SW system that are within the scoge of license renewal for 1O.CFR
                                                                                                   . '\
54.4(a)(2).
                                                                                                                . .. ~"
                                                                                                                        ... _._

NL~16-122 Attachment 2 Page 9 of 9 d) Increase the frequency of internal robotic inspections on the system headers at both units from once during the first 1O years of the period of extended operation to also include once during the
* second 1O years of the period of extended operation.
e) Review the SW system to identify areas where leakage from nonsafety-related SW piping could result in unacceptable flooding and ensure the nonsafety-related piping that can cause flooding concerns is clearly identified in the program
~
I documents. Specify volumetric examination of at least 20 percent of (up to a maximum of 25) non-safety related welds located in areas subject to flooding of safety-related equipment within each 10-year period of the PEO.
f)  Specify a yearly OE review to identify any effects of aging reported on the SW system, specifically including any conditions that may have occurred in the prior year related to inadequate cement liner repairs.
g) Include guidance-for lay-up of the SW process radiation monitoring system to minimize exposure of susceptible tubing to staqnant conditions.
h) Establish recurring internal corrosion goals for stagnant vent and drain connection piping. If thes*e recurring internal goals are not met. the frequency for flushing stagnant vent and drain connection piping will be increased.

ATTACHMENT 3 TO NL-16-122 LICENSE RENEWAL APPLICATION
    . IPEC LIST OF REGULATORY COMMITMENTS Rev.29 ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 and 50-286

                                     .-- *i ,.,,,_
NL-16-122 Attachment 3 Page 1 of 25 List of Regulatory Commitments Rev.29 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                      LRA SECTION/
AUDIT ITEM IP2:            NL-07;.039     A.2.1.1 1   Enhance the Aboveground Steel Tanks Program for IP2 and IP3 to perform thickness          Complete                       A.3.1.1 measurements of the bottom surfaces of the                            NL-13-122       B.1.1 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.
Implement LRA Sections, A.2.1.1, A.3.1.1 and          IP2 & IP3:      NL-14-147      A.2.1.1 B.1.1, as shown in NL-14-147.                         December 31 ,                  A.3.1.1 2019                            B.1.1 Implement LRA Sections, A.2.1.1 and B.1.1, as IP2 & IP3:              NL-15-092      A.2.1.1 December 31 ,                   B.1.1 shown in NL-15-092 2019 2   Enhance the Bolting Integrity Program for IP2         IP2:            NL-07-039      A.2.1.2 and IP3 to clarify that actual yield strength is. Complete                       A.3.1.2 used in selecting materials for low susceptibility                                    B.1.2 to  sec  and clarify the prohibition on use of        IP3:
lubricants containing MoS2 for bolting.               Complete        NL-07-153 Audit Items 201, 241, The Bolting Integrity Program manages loss of                         NL-13-122        270 preload and loss of material for all external bolting.

                                   -~*.'' -_ . ,--. - ...
                                                   *'
                                                                                         * * *
* NL-"16~122 Attachment 3 Page 2 of 25
#                       COMMITMENT                         IMPLEMENTATION             SOURCE         RELATED SCHEDULE                            LRA SECTION/
AUDIT ITEM Implement the Buried Piping and Tanks                  IP2:                      NL-07-039        A.2.1.5 3
Inspection Program for IP2 and IP3 as                  Complete                                   A.3.1.5 described in LRA Section B.1.6.                                                  NL-13-122         B.1.6 IP3:                      NL-07-153 Audit Item This new program will be implemented                   n~---~1-~~
LJ""--
                                                                              -tri NL-15-121          173 consistent with the corresponding program
                                                                         ~
                                                                               -=*
:w+eComplete described in NUREG-1801 Section Xl.M34, Buried Piping and Tanks Inspection.
Include in the Buried Piping and Tanks                                           NL-09-106 Inspection Program described in LRA Section B.1 .6 a risk assessment of in-scope buried                                      NL-09-111 piping and tanks that includes consideration of the impacts of buried piping or tank leakage and of conditions affecting the risk for corrosion.
Classify pipe segments and tanks as having a high, medium or low impact of leakage based on the safety class, the hazard posed by fluid contained in the piping and the impact of leakage on reliable plant operation. Determine corrosion risk through consideration of piping or tank. material, soil resistivity, drainage, the presence of cathodic protection and the type of coating .. Establish inspection priority and frequency for periodic inspections of the in:..
scope piping and tanks based on the results of the risk assessment. Perform inspections using                                   NL-11-101 inspection techniques with demonstrated effectiveness.
IP2:                       NL-07-039        A.2.1.8 4   Enhance the Diesel Fuel Monitoring Program to Complete                                    A.3.1.8 include cleaning and inspection of the IP2 GT-1 NL-13-122         B.1.9 gas turbine fuel oil storage tanks, IP2 and IP3 IP3:                       NL-07-153      Audit items EOG fuel oil day tanks, IP2 SBC/Appendix R diesel generator fuel oil day fank, and IP3
                                                          *...,.
                                                          .-     ---
                                                          ~Complete
                                                                   - - - * ~~ -t,..,
                                                                        *-- ""'*     NL-15-121       128, 129, 132,
* Appendix R fuel oil storage tank and day tank NL-08-057       491, 492, once every ten years.
510 Enhance the Diesel Fuel Monitoring Program to include quarterly sampling and analysis of the IP2 SBC/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 storaQe tank.

                                                                       ,  ,-NL~16-122 Attachment 3 Page 3 of 25
#                     COMMITMENT                     IMPLEMENTATION SOURCE      RE.LATED SCHEDULE                  LRA SECTION/
AUDIT ITEM 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 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:
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 f.uel 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-rn.:122 Attachment 3 Page 4 of 25
#                     COMMITMENT                  IMPLEMENTATION          SOURCE      RELATED SCHEDULE                             LRA SECTION/
AUDIT ITEM IP2:                   NL-07-039    A.2.1.10 5 Enhance the External Surfaces Monitoring Complete                            A.3.1.10 Program for IP2 and IP3 to include periodic NL-13-122      B.1.11 inspections of 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 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).
IP2 & IP3:             NL-14-147    A.2.1.10 Implement LRA Sections A.2.1.1 O, A.3.1.1 o and December 31 ,                       A.3.1.10 B.1.11, as shown in NL-14-147.
                                                  ~019                                  B.1 ;11 IP2:                   NL-07-039 A.2.1.11 6 Enhance the Fatigue Monitoring Program for Complete                            A.3.1.11 IP2 to monitor steady state cycles and NL-13-122 B.1.12, feedwater cycles or perform an evaluation to NL-07-153 Audit Item determine monitoring is not required. Review 164 the number of allowed events and resolve NL-15-121 discrepancies between reference documents IP3:
and monitoring procedures.
                                                               ..... ,
                                                  '"'----'--~-in
                                                         -~~
Enhance the Fatigue Monitoring Program for      00-+eComplete 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.

                                                                                 .. *NL~rn~t22 Attachment 3 Page 5 of 25
#                      COMMITMENT                    IMPLEMENTATION         SOURCE       RELATED SCHEDULE                      LRA
* SECTION/
AUDIT ITEM Enhance the Fire Protection Program to inspect    IP2:                  NL-07-039     A.2.1.12 7
external surfaces of the IP3 RCP oil collection   8omplete                            A.3.1.12 systems for loss of material each refueling                             NL-13-122      B.1.13 cycle.                                            IP3:
                                                     ....,. ___
n,,.---r...- .. -t 'J
                                                                *--     -, NL-15-121 Enhance the Fire Protection Program to            2-0+SComglete explicitly 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 C02 fire suppression system for signs of degradation, such as corrosion and mechanical damage at least once every six months.

                              ' *. "'. ,, ; . ~ - ** .. ' : .                     * , ** NL~16-122 Attachment 3 Page 6 of 25
#                       COMMITMENT                            IMPLEMENTATION  SOURCE          RELATED SCHEDULE                       LRA SECTION/
AUDIT ITEM Enhance the Fire Water Program to include                 IP2:           NL-07-039        A.2.1.13 8
inspection of IP2 and IP3 hose reels for                  8omplete                        A.3.1.13 evidence of corrosion. Acceptance criteria will                          NL-13-122         B.1.14 be revised to verify no unacceptable signs of                            NL-07-153 Audit Items degradation.                                                                              105, 106 NL-08-014. *              -
Enhance the F:ire Water Program to replace all or test a sample of IP2 and IP3 sprinkler heads required for 10 CFR 50.48 using guidance. of NFPA 25 (2002 edition), Section 5.3.1.1.1 before the end of the 50-year sprinkler head service life and at 10-year intervals thereafter during the extended .period of operation to ensure that signs of degradation, such as corrosion, are detected in a timely manner.
Enhance the Fire Water Program to perform wall thickness evaluations of IP2 and IP3 fire protection piping on system components using non-intrusive techniques (e.g., volumetric testing) to identify evidence of loss of material due to corrosion. These inspections will be
* performed before the end of the current operating term and at intervals thereafter during the period of extended operation. Results of the initial evaluations will be used to determine                                       ;
the appropriate inspection interval to ensure aging effects are identified priO-r 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.
Implement LRA Sections, A.2.1.13, A.3.1.13                IP2 & IP3:     NL-14-147        A.2.1.13 and B.1.14, as shown in NL-14-147.                        December 31,                    A.3.1.13
                                                              ~019                             B.1.14 Implement LRA Sections A.2.1.13, A.3.1.13 and IP2 & IP3:                 NL-15-019        A.2.1.13 B.1.14, as shown in NL-15-019                             December 31                     A.3.1.13
                                                                          '
2019                             B.1.14

                                                                                    *NL~16~122 Attachment 3 Page 7 of 25
#                    COMMITMENT                       IMPLEMENTATION         SOURCE       RELATED SCHEDULE                          LRA SECTION/
AUDIT ITEM IP2 & IP3:            NL'-15-092    A.2.1.13 Implement LRA Sections A.2.1.13, A.3.1.13 and December 31,                        A.3.1.13 B.1.14, as shown in NL-15-092
                                                      ~019                                 B.1.14
                                                    . IP2 & IP3:            NL-16-122     A.2.1.13 lmglement LRA Sections A.2.1.13 1 A.3.1.13 1 December 31                         A.3.1.13 and B.1.14 1 as shown in NL-16-122
                                                      ~017                                 B.1.14 IP2:                  NL-07-039     A.2.1.15 9 Enhance the Flux Thimble Tube Inspection Complete                            A.3.1.15 Program for IP2 and IP3 to implement NL-13-122      B.1.16 comparisons to wear rates identified in WCAP-IP3:                  NL-15-121 12866. Include provisions to compare data to        r'\---..... L..-- ~I) the previous performances and perform               - --- *--          ~,
                                                      ~Comglete 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 thimbl~ 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~16-122 Attachment 3 Page 8 of 25
#                      COMMITMENT                   IMPLEMENTATION           SOURCE         RELATED SCHEDULE                            LRA SECTION/
AUDIT ITEM IP2:                    NL-07-039       A.2.1.16 10 Enhance the Heat Exchanger Monitoring Complete                                A.3.1.16 Program for IP2 and IP3 to include the following NL-13-122 B.1.17, heat exchangers in the scope of the program.
IP3:                    NL-07-153 Audit Item
       ** Safety injection pump lube oil heat       I n - - - - ' - -- -4n
                                                    *~    *~
                                                                        ,~,
NL-15-121          52 exchangers
                                                    ~Complete
* RHR heat exchangers
* RHR pump seal coolers
* Non-regenerative heat exchangers
* Charging pump seal water heat exchangers
* Charging   pump fluid drive coolers
* Charging pump crankcase oil coolers
* Spent fuel pit heat exchangers
* Secondary system steam generator sample coolers
* Waste   gas compressor heat exchangers
* SBC/Appendix R diesel jacket water heat exchanger (IP2 only)
Enhance the Heat Exchanger Monitoring .
Program for IP2 and IP3 to perform visual inspection on heat exchangers where non-destructive examination, such as eddy current inspection, is not possible due to heat exchanger design limitations.
Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to include consideration of material-environment combinations when determining sample population of heat exchangers.
Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to establish minimum tube wall thickness for the new heat exchangers identified in the scope of the program.
Establish acceptance criteria for heat exchangers visually inspected to include no indication of tube erosion, vibration wear, corrosion, pitting, fouling, or scaling.                                 NL-09-018

                                                                                        'NL-16~122 Attachment 3 Page 9 of 25
 #                        COMMITMENT                     IMPLEMENTATION          SOURCE      RELATED SCHEDULE                        LRA SECTION/
AUDIT ITEM NL-09-056.
11   Deleted*
NL-11-101 12   Enhance the Masonry Wall Program for IP2 and IP2:                          NL-07-039    A.2.1.18 Complete                            A.3.1.18 IP3 to specify that the IP1 intake structure is NL-13-122     B.1.19 included in the program.
IP3:
Complete IP2:                   NL-07-039    A.2.1.19 13   Enhance tffe Metal-Enclosed Bus Inspection Complete                            A.3.1.19 Program for IP2 and IP3 to visually inspect the NL-13-122     B.1.20 external surface of MEB enclosure assemblies IP3:                   NL-07-153   Audit Items for loss of material at least once every 10 years.
The first inspection will occur prior to the period of .extended operation and_the acceptance
                                                         -
I""\      i..~~
                                                              - -- *--
M+aComplete        -*
                                                                         '1 ' l NL-15-121 NL-08-057 124, 133,519 c-riterion will be no significant loss of material.
NL-13-077
                                                                                 *::
Enhance the Metal-Enclosed Bus Inspection
   . Program to add acceptance criteria for MEB int~rnal 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.

                                  . ~ .' *' .' ..                                        .. NL-16-122 Attachment 3 Page 10 of 25
#                      COMMITMENT                   IMPLEMENTATION                 SOURCE       RELATED SCHEDULE                             LRA SECTION/
AUDIT ITEM IP2:                          NL-07-039     A.2.1.21 14   Implement the Non-EQ Bolted Gabl~
Connections Program tor IP2 and IP3 as         Complete                                    A.3.1.21 described in LRA Section B.1.22.                                             NL-13-122      B.1.22 IP3:                          NL-15-121 n,..,.---L..-,.
            -                                       --              --     1 rJ
                                                                             ~,
                                                    ~ComQlete IP2:                          NL-07-039     A.2.1.22 15   Implement the Non-EQ Inaccessible Medium-Complete                                    A.3.1.22 Voltage Cable Program for IP2 and IP3 as NL-13-122      8.1.23 described in LRA Section 8.1.23.
IP3:                          NL-07-153 Audit item This new program will be implemented            ...... ___
n,..,.---h,..,. ..
                                                                    .~~
10~,   NL-15-121        173 consistent with the corresponding program      ~ComQlete                     NL-11-032 described in NUREG-1801 Section Xl.E3,                                     -
Inaccessible Medium-Voltage Cables Not                                       NL-11-096 Subject To 10 CFR 50.49 Environmental Qualification Requirements.                                                  NL-11-101 NL-07-039     A.2.1.23 16   Implement the Non-EQ Instrumentation Circuits IP2:
Test Review Program for IP2 and IP3 as          8omplete                                   A.3.1.23 NL-13-122      8.1.24 described in LRA Section 8.1 .24.
IP3:                          NL-07-153 Audit item This new program will be implemented           ....,   ___ *--- 1 I) n,..,.---L..-,.          ~,   NL-15-121        173 consistent with the corresponding program      ~ComQlete
   , 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:                          NL-07-039     A.2.1.24 17   Implement the Non-EQ Insulated Cables and 8omplete                                   A.3.1.24 Connections Program for IP2 and IP3 as NL-13-122      B.1.25 described in LRA Section 8.1.25.
IP3:                          NL-07-153 Audit item This new program will be implemented           n-
                                                    ----        *-  I -
                                                                   *---
                                                                        >" 11)
                                                                             ~,   NL-15-121        173 consistent with the corresponding program      ~ComQlete described in NUREG-1801 Section Xl.E1, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.

                               '' ~- *.. ... ...
* NL-16~122 Attachment 3 Page 11 of 25
#                     COMMITMENT                     IMPLEMENTATION             SOURCE      RELATED SCHEDULE                            LRA SECTION/
                                                                             '
AUDIT ITEM IP2:                      NL-07-039    A.2.1.25 18 Enhance the Oil Analysis Program for IP2 to Complete                               A.3.1.25 sample and analyze lubricating oil used in the NL-13-122     B.1.26 SBO/Appendix R diesel generator consistent IP3:.                     NL-11-101 with the oil analysis for other site diesel generators.                                     /
n,.,.---.h,.,. ..
                                                     --
                                                     ~Complete
                                                               *--       -*
                                                                       -tl'l 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.

                                                                                           .,.NL~rn.:122 Attachment 3 Page 12 of 25
 #                    COMMITMENT                      IMPLEMENTATION                 SOURCE       RELATED SCHEDULE                              LRA SECTION/
AUDIT ITEM 19 Implement the One-Time Inspection Program          IP2:                          NL-07-039     A.2.1.26 for IP2 and IP3 as described in LRA Section        Complete                                    A.3.1.26 B.1.27.                                                                          NL-13-122      B.1.27 IP3:                          NL-07-153 Audit item This new program will be implemented               --___
                                                      ......  - -   ,h-*-
                                                                                -*
                                                                     """'""" -lt"'I NL-15-121        173 consistent with the corresponding program          2Q-t.&sect;Complete described in NUREG-1801, Section Xl.M32, One-Time Inspection.
20 Implement the One-Time Inspection - Small          IP2:                          NL-07-039     A.2.1.27 Complet~                                    A.3.1.27 Bore Piping Program for IP2 and IP3 as described in LRA Section B.1.28.
* NL-13-122      B.1.28 IP3:                          NL-07-153 Audit item
                                                      "' -
This new program will be implemented consistent with the corresponding program
                                                      ----
oo+ecomplete
                                                                  . 1...---lri
                                                                    ,..,....,
                                                                                -*  NL-15-121        173 described in NUREG-1801, Section Xl.M35, One-Time Inspection of ASME Code Class I Small-Bore Pipinq.
21 Enhance the Periodic Surveillance and              IP2:                          NL-07-039     A.2.1.28 Preventive Maintenance Program for IP2 and         Complete                                    A.3.1.28 IP3 as necessary to assure that the effects of                                   NL-13-122      B.1.29 IP3:                          NL-15-121
* aging will be managed such that applicable components will continue to perform their intended functions consistent with the current
                                                      -- ...... ....,
n~---*--.- -in w+eComplete               -*
licensing basis through the period of extended operation.
Implement LRA Sections A.2.1.28 1 A.3.1.28 and IP2 & IP3:                        NL-16-122     A.2.1.28 B.1.29 1 as shown in NL-16-122                     December 31                                 A.3.1.28 2017                                         B.1.29 22 Enhance the Reactor Vessel Surveillance
* IP2:                          NL-07-039     A.2.1.31  !
I
                                                      ~omplete                                    A.3.1.31 Program for IP2 and IP3 revising the specimen capsule withdrawal schedules to draw and test                                    NL-13-122      B.1.32 a standby capsule to cover the peak reactor        IP3:                          NL-15-121 n----'- - - -I,...,
vessel fluence expected through the end of the            --- *--          . ~,
period of extended operation.                      w+aComplete 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
* storaqe.

                                                                                   .*. NL~16-122 Attachment 3 Page 13 of 25
 #                      COMMITMENT                    IMPLEMENTATION         SOURCE        RELATED SCHEDULE                            LRA SECTION/
AUDIT ITEM IP2:                   NL-07-039      A.2.1.32.
23  Implement the Selective Leaching Program for IP2 and IP3 as described in LRA Section          Complete                              A.3.1.32 B.1.33.                                                                 NL-13-122       8.1.33 IP3:                   NL-07-153 Audit item This new program will be implemented consistent with the corresponding program n-
                                                     -
                                                           *-  I
                                                        --- *---
                                                                 - ,.
                                                                       *-,
                                                                      -I I)
NL-15-121         173
                                                     ~ComQlete
 -  described in NUREG-1801, Section Xl.M33 Selective Leaching of Materials.
IP2:                   NL-07-039      A.2.1.34 24  Enhance the Steam Generator Integrity Complete                              A.3.1.34 Program for IP2 and IP3-to require that the NL-13-122       B.1.35 results of the condition monitoring assessment IP3:
are compared to the operational assessment
   *performed for the prior operating cycle with     Complete differences evaluated.
Enhance the Structures Monitoring Program to     IP2:                   NL-07-039      A.2.1,35 25 explicitly specify that the following structures Complete                              A.3.1.35 are included in the program: ***                                        NL-13-122       B.1.36
* Appendix R diesel generator foundation         IP3:                   NL-07-153 (IP3)
    * *Appendix R diesel generator fuel oil tank
                                                     - ---
                                                     '"'-        -~
                                                              -- -
                                                     *~comQlete.
                                                                         -*
                                                                      '11"1 NL-15-121 Audit items 86, 87, 88, vault (IP3)                                                         NL-08-057         417
* Appendix R diesel generator switchgear and enclosure (IP3)
NL-13-077
* city water storage tank foundation
* condensate.storage tanks foundation (IP3)
* containment access facility and annex (IP3)
* discharge canal (IP2/3)
* emergency lighting poles and foundations (IP2/3)
* fire pumphouse (IP2)
* fire protection pur:nphouse (IP3)
* fire water storage tank foundations (IP2/3)
* gas turbine 1 fuel storage tank foundation
* maintenance and outage building-elevated passageway (I P2)
* 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 buildinq (IP3)
* NL-16-122 Attachment 3 Page 14 of 25
#                       COMMITMENT                  IMPLEMENTATION       SOURCE      RELATED SCHEDULE                         LRA SECTION/
AUDIT ITEM
* service water pipe chase (IP2/3)
* service water valve pit (IP3)                                    NL-14-146
* superheater stack
* transformer/switchyard support structures (IP2)
* waste holdup tank pits (IP2/3)
Enhance the Structures Monitoring Program for IP2 and IP3 to clarify that in addition to structural steel and concrete, the following commodities (including their anchorages) are inspected for each structure as applicable.
* cable trays and supports                              .*'*.":"'
* concrete portion of reactor vessel supports
   ..
* conduits and supports cranes, rails and girders
  ..*   equipment pads and foundations
      . fire proofing (pyrocre~e)
* HVAC duct supports
* jib cranes
* manholes and duct banks
* manways, hatches. and hatch covers                              NL-13-077
* monorails
* new fuel storage racks
* sumps 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.
l;nhance 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

NL-16-122 Attachment 3 Page 15 of 25
#                     COMMITMENT                     IMPLEMENTATION  SOURCE      RELATED SCHEDULE                    LRA SECTION/
                                                     '                          AUDIT ITEM of aluminum vents and louvers to identify loss of material.
NL-08-127 Audit Item Enhance the Structures Monitoring Program for                                     360 IP2 and IP3 to perform an engineering evaluation of groundwater samples to assess aggressiveness of groundwater to concrete on a periodic basis (at least once every five years).
IPEC will obtain samples from at least 5 wells that are representative of the ground water surrounding below-grade site structures and perform an engineering evaluation of the results from those samples for sulfates, pH and chlorides. Additionally, to assess potential indications of spent fuel pool leakage, IPEC will sample for tritium in groundwater wells in close proximity to the IP2 spent fuel pool at least once every 3 months .
  .Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspection of normally submerged concrete portions of the intake structures at least once every-5 years. Inspect the baffling/grating partition and support                                    Audit Item platform of the IP3 intake structure at least once                                358 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                           NL-11-032 frequency of once per 5 years during the PEO.
Enhance the Structures Monitoring Program to include more detailed quantitative acceptance                     NL-11-101 criteria for inspections of concrete structures in accordance with.AC! 349.3R, "Evaluation of Existing Nuclear Safety-Related Concrete Structures" prior to the period of extended operation.

                                                                                   *
* NL~tB-122 Attachment 3 Page 16 of 25
 #                   COMMITMENT                       IMPLEMENTATION         SOURCE        RELATED SCHEDULE                            LRA SECTION/
AUDIT ITEM IP2:                  NL-07-039      A.2.1.36 26 Implement the Thermal Aging Embrittlement of Complete                             A.3.1.36 Cast Austenitic Stainless Steel (CASS)
NL-.13-122      B.1.37 Program for IP2 and IP3 as described in LRA Section B.1.37.                                    IP3:                  NL-07-153 Audit item This new program wiJI be. implemented
                                                      ~-*--   *-- ,
                                                     *n.---~i...-~
                                                      ~Complete
                                                                   -11"'1
                                                                      ..... NL-15-121         173 consistent with the corresponding program described in NUREG-1801, Section Xl.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) Proqram.
IP2:                  NL-07-039      A.2.1.37 27 Implement the Thermal Aging and Neutron Complete                             A.3.1.37 Irradiation Embrittlement of Cast Austenitic NL-13-122       B.1.38 Stainless Steel (CASS) Program for IP2 and IP3:                  NL-07-153 Audit item IP3 as described in LRA Section B.1.38.
Complete                                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)
Proqram.
IP2:                  NL-07-039      A.2.1.39 28 Enhance the Water Chemistry Control - Closed Complete                             A.3.1.39 Cooling Water Program to maintain water NL-13-122       B.1.40 chemistry of the IP2 SBO/Appendix R diesel IP3:                  NL-08-057 Audit item generator cooling system per EPRI guidelines ..
Complete                                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 ouidelines.
IP2:                  NL-07-039      A.2.1.40 29 Enhance the Water Chemistry Control -
Complete                              B.1.41 Primary and Secondary Program for IP2 to test sulfates monthly in the RWST with a limit of                             NL-13-122
   <150 ppb.
* NL-16-122 Attachment 3 Page 17 of 25
 #                    COMMITMENT                        IMPLEMENTATION      SOURCE      RELATED
     ..
SCHEDULE                       LRA SECTION/
AUDIT ITEM IP2:               NL-07-039    A.2.1.41 30 For aging management of the reactor vessel Complete                        A.3.1.41 internals, IPEC will (1) participate in the industry NL-13-122 programs for investigating and managing aging IP3:
effects on reactor internals; (2) evaluate and Complete implement the results of the industry program$
as applicable to the reactor internals; and (3) upon completion of these programs, but not less than 24 months before entering the period NL-11-107 of extended operation, submit an inspection plan for reactor internals to the NRC for review and approval.
IP2:               NL-07-039    A.2.2.1.2 31 Additional P-T curves will be submitted as Complete                        A.3.2.1.2 required per 10 CFR 50, Appendix G prior to NL-13-122      4.2.3 the period of extended operation as part of the IP3:               NL-15-121 Reactor Vessel Surveillance Program.                 r"\---~i...-~
                                                        ----    -~-   *-,
1 ')
                                                        ~Comglete As required by 10 CFR 50.61 (b)(4), IP3 will         IP3:               NL-07-039    A.3.2.1.4 32 submit a plant-specific safety analysis for plate Approximately 6       NL-07-140      4.2.5 82803-3 to the NRC three years prior to              years after        NL-08-014 reaching the RT PTS screening criterion.             entering the PEO   NL-08-127 Alternatively, the site may choose to implement the revised PTS rule when approved.

NL-16c122 Attachment 3 Page 18 of 25
 #                     COMMITMENT                      IMPLEMENTATION  SOURCE      RELATED SCHEDULE                    LRA SECTION/
AUDIT ITEM IP2:           NL-07-039    A.2.2.2.3 33 At least 2 years prior to entering the period of Complete                    A.3.2.2.3 extended operation; for the locations identified NL-13-122 . 4.3.3 in LRA Table 4.3-13 (IP2) and LRA Table 4.3-IP3:           NL-07-153 Audit item 14 (IP3), under the Fatigue Monitoring Program, Complete                        146 IP2 and IP3 will implement one or more of the                                         '
NL-08-021 following:
(1) Consistent with the Fatigue Monitoring Program, Detection of Aging Effects, update the fatigue usage calculations using refined fatigue                   NL-10-082 analyses to determine valid CUFs less than 1.0 when accounting for the effects of reactor water environment. This includes applying the appropriate Fen factors to valid CUFs determined in accordance with one of the following:
: 1. For locations in LRA Table 4.3-13 (IP2) and LRA Tab.le 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 NRC-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.

                                                                               *
* NL-16-122 Attachment 3 Page 19 of 25
 #                      COMMITMENT                      IMPLEMENTATION     SOURCE      RELATED SCHEDULE                       LRA SECTION/
AUDIT ITEM 34  IP2 SBO I Appendix R diesel generator will be       8omplete          NL-13-122    2.1.1.3.5 NL~07-078 installed and operational by April 30, 2008.
This committed change to the facility meets the requirements of 10 CFR 50.59(c)(1) and,                               NL-08-074 therefore, a license amendment pursuant to 1O
   .CFR 50.90 is not required.                                            NL-11-101 35  Perform a one-time inspection of representative IP2:                  NL-08-127 Audit Item sample area of IP2 containment liner affected       8omplete                           27 by the 1973 event behind the insulation, prior to                     NL-13-122 entering the period of extended operation, to assure liner degradation is not occurring in this area.                                               IP3:              NL-11-101
                                                        ----
n~---'--,.
                                                               --
Perform a one-time inspection of representative :w+eComglete       -*
                                                                     "llJ NL-15-121 sample area of the IP3 containment steel liner at the juncture with the concrete floor slab, prior to entering the period of extended operation, to assure liner degradation is not occurring in this                     NL-09-018 area.
Any degradation will be evaluated for updating of the containment liner analyses as needed.
36  Perform a one-time inspection and evaluation of IP2:                  NL-08-127 Audit Item a sample of potentially affected IP2 refueling      Complete          NL-11-101       359 cavity concrete prior to the period of extended                       NL-13-122 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 reinforcin-g steel.
Additional core bore samples will be taken, if                        NL-09-056 the leakage is not stopped, prior to the end of the first ten years of the period of extended operation.                                                            NL-09-079 A sample of leakage fluid will b_e analyzed to 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.

                                      . ... .  '
                                  -*~        ~   ' \
                                                                                              ** NL-16"122 Attachment 3 Page 20. of 25
 #                    COMMITMENT                         IMPLEMENTATION                  SOURCE      RELATED SCHEDULE                                 LRA SECTION/
AUDIT ITEM NL-08-127 Audit Item 37 Enhance the Containment lnservice Inspection IP2:
Complete                                       361 (Cll-IWL) Program to include inspections of the NL-13-122 containment using enhanced characterization of degradation (i.e., quantifying the dimensions of
* IP3:
Complete noted indications through the use of optical aids) during the period of extended operation.
The enhancement includes obtaining critical dimensional data of degradation where possibte through direct measurement or the use of scaling technologies for photographs, and the use of consistent vantage points for visual inspections.
IP2:                           NL-08-143      4.2.1 38 For Reactor Vessel Fluence, should future core Complete loading patterns invalidate the basis for the NL-13-122 projected values of RTpts or CvUSE, updated IP3:                           NL-15-121 calculations will be provided to the NRC.
                                                         ----
n- ---'-
                                                                              ..... ,
                                                                       -.~ -tl"'J
                                                                  ,, ___
                                                         ~Comolete NL-09-079 39 Deleted IP2:                           NL-09-106      B.1.6 40 Evaluate plant specific and appropriate industry Complete                                     B.1.22 operating experience and incorporate lessons NL-13-122     B.1.23 learned in establishing appropriate monitoring IP3:                           NL-15-121     B.1.24 and inspection frequencies to assess aging          . n...: ___ .._ ___ -4 l"'J B.1.25 effects for the new aging management              *
                                                                              ~,
LJ -  -- *-
OO-:t-5Comglete                              B.1.27 programs. Documentation of the operating B.1.28 experience evaluated for each new program will B.1.33 be available on site for NRC review prior to the B.1.37 period of extended operation.                                                      I B.1.38

NL-16-122 Attachment 3 Page 21 of 25
 #                   COMMl.TMENT                      IMPLEMENTATION    SOURCE      RELATED SCHEDULE                     LRA SECTION/
AUDIT ITEM 41 IPEC will inspect steam generators for both        IP2:             NL-11-032       N/A After the units to assess the condition of the divider plate beginning of the assembly. The examination technique used will PEO and prior to be capable of detecting PWSCC in the steam generator divider plate assembly. The IP2          September 28, 2023             NL-11-074 steam generator divider plate inspections will be completed within the first ten years of the period IP3:             NL-11-090 of extended operation (PEO). The IP3 steam Prior to the end generator divider plate inspections will be of the first     NL-11-101 completed within the first refueling outage refueling outage following the beginning of the PEO.
allowing the beginning of the PEO.

NL-16-122 Attachment 3 Page 22 of 25
 #                      COMMITMENT                       IMPLEMENTATION     SOURCE      RELATED SCHEDULE                      LRA SECTION/
AUDIT ITEM 42   IPEC will develop a plan for each unit to                             NL-11-032       N/A 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 steam g~nerator tube-to-tubesheet welds in          IP2:              NL-11-074 order to establish a technical basis for either     Prior to March determining that the tubesheet cladding and         ~024              NL-11-090 welds are not susceptible to PWSCC, or              IP3: Prior to the redefining the pressure boundary in which the       end of the first  NL-11-096 tube-to-tubesheet weld is no longer included        refueling outage
                                                         ~allowing the and, therefore; is not required for reactor coolant pressure boundary function. The             oeginning. of the redefinition of the reactor coolant pressure        PEO.
boundary must be approved by the NRC as* a license amendment request.
Option 2 (Inspection)                               IP2:
IPEC will perform a one-time inspection of a        Between March representative number of tube-to-tubesheet          2020 and March welds in each steam generator to determine if       2024
* PWSCC cracking is present. If weld cracking is identified:                                         IP3: Prior to the end of the first
: a. The condition will be resolved through       refueling outage repair or engineering evaluation to justify ~allowing the continued service, as appropriate, and      oeginning of the
: b. An ongoing monitoring program will be        PEO.
established to perform routine tube-to- .
tubesheet weld inspections for the remaininQ life of the steam generators.

                                 . . *t.,*, .** ,_
                                                                                                 *
* NL~t6~122 Attachment 3 Page 23 of 25
 #                        COMMITMENT                        IMPLEMENTATION                 SOURCE        RELATED SCHEDULE                                LRA r                  SECTION/
AUDIT ITEM IPEC will review design basis ASME Code               IP2:                          NL-11-032        4.3.3 43 Class 1 fatigue evaluations to determine              Complete.
whether'the NUREG/CR-6260 locations that have been evaluated for the effects of the           . IP3: Prior to                 NL-13-122
                                                            ---*- 1--
r'"\ _ _ _ _ , ____ .. ,..,
reactor coolant environment on fatigue usage                                        NL-11-101 w+eComglete
                                                                                        ' NL-15-121 are the limiting locations: for the IP2 and IP3 configurations. If more limiting locations are identified, the most limiting location will be evaluated for the effects of the reactor coolant environment on fatigue usage.
* IPEC will use the NUREG/CR-6909 methodology in the evaluation of the limiting locations consistinQ of nickel alloy, if any.
IP2:                          NL-11-032         N/A 44    IPEC will include written explanation and 8omplete justification of any user intervention in future NL-11-101 evaluations using the WESTEMS "Design CUF''
IP3: Prior to                 NL-13-122 module.                                               n,,.- ____ ,_ - ..
                                                            ---- *--
                                                            ~_Comglete             -*
                                                                                -1 ~
NL-15-121 IP2:                          NL-11-032-        N/A 45    IPEG will not use the NB-3600 option of the Complete WESTEMS program in future design NL-11-101 calculations until the issues identified during the IP3: Prior to                 NL-13-122 NRC review of the program have been resolved.
n,,.
                                                                 - *--
w+eComglete            -*
                                                                         ' ... -1 ,..,    NL-15-121 46*                                                         IP2:                          NL-11-032.        N/A Include in the IP2 ISi Program that IPEC will 8omplete
    . perform twenty-five volumetric weld metal NL-11-074 inspections of socket welds during each 10-year NL-13-122 ISi interval 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-r6"122 Attachment 3 Page 24 of 25
   #                      COMMITMENT                      IMPLEMENTATION              SOURCE          RELATED SCHEDULE                               LRA SECTION/
AUDIT ITEM IP2:                       NL-12-174          N/A 48   Entergy will visually inspect IPEC underground 8omplete piping within the scope of license renewal and subject to aging management review prior to IP3: Prior to              NL-13-122 the period of extended operation and then on a . l""\----1-..-~ 11) frequency of at least once every two years         ---- *---
:w-1-&sect;Complete
                                                                                 *-* NL-15-121      '
during the period of extended operation. This inspection frequency will be maintained unless the piping is subsequently coated in accordance with the pr:eventlve actions specified in NUREG-
      .1801 Section Xl.M41 as modified by LR-ISG-2011-03. Visual inspedions will be supplemented with surface or volumetric non-destructive testing if indications of significant loss of material are observed. Consistent with revised NUREG-1801 Section Xl.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).
                                 -
. 49                                                      IP2:                       NL-13-052         A.2.2.2
      *Recalculate each of the limiting CUFs provided 8omplete                                     A.3.2.2 in section 4.3 of the LRA for the reactor vessel internals to include the reactor coolant IP3: Prior to              NL-13-122 environment effects (Fen) as provided in the       l""\----1-..-.
IPEC Fatigue Monitoring Program using              ----          ---- . 11)-* NL-15-121
                                                          ~Complete NUREG/CR-5704 or NUREG/CR-6909. In accordance with the corrective actions specified                        I 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           IP2:                       NL-13-122        A.2.1.41 50 refueling outage (2R22).                                  ,_     --
D ...:-.,...1.-
8.1.42 i----*-.L*--
r--     *r -     -     -
_z.
NL-14-067
                                                          ~nr""'Complete IP3: N/A

                                                                               *
* NL-:16~122 Attachment 3 Page 25 of 25
 #                         COMMITMENT                      IMPLEMENTATION  SOURCE      RELATED SCHEDULE                    LRA SECTION/
AUDIT ITEM IP2 & IP3:     NL-14-147     A.2.1.33 51       En~ance   the ~ervice Water Integrity Program December 31,                 A.3.1.33 by implementing LRA Sections A.2.1.33; 2017                          8.1~34 A.3.1.33 and 8.1.34, as shown in NL-14-147.
IP2 & IP3:     NL-16-122     A.2.1.33 lm~lement    LRA Sections A.2.1.33 1 A.3.1.33 and December 31 .                A.3.1.33 8.1.34 1 as shown in NL-16-122 2017                          8.1.34 IP2 & IP3:     NL-15-019     A.2.1.42 52       Implement the Coating Integrity Program for IP2 December 31                  A.3.1.42
      . and IP3 as described in LRA Section 8.1.42, as                 '
                                                           ~024                          8.1.43 shown in NL-15-019.
   .. I}}