View source for NL-17-060, Reply to Requests for Additional Information for the Review of the Indian Point License Renewal Application RAI Set 2017-02 (CAC Nos. MD5407 and MD5408)

{{Adams
| number = ML17145A288
| issue date = 05/19/2017
| title = Reply to Requests for Additional Information for the Review of the Indian Point License Renewal Application RAI Set 2017-02 (CAC Nos. MD5407 and MD5408)
| author name = Vitale A
| author affiliation = Entergy Nuclear Northeast, Entergy Nuclear Operations, Inc
| 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-17-060
| document type = Letter type:NL, Response to Request for Additional Information (RAI)
| page count = 36
| project = CAC:MD5407, CAC:MD5408
| stage = Response to RAI
}}

=Text=
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Entergy 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-17-060 c*
May 19, 2017 U.S. Nuclear Regulatory Commission Document Control Desk 11545 Rockville Pike, TWFN-2 F1 Rockville, MD 20852-2738

==SUBJECT:==
Reply to Requests for Additional Information for the Review of the Indian Point License Renewal Application RAI SET 2017-02 (CAC Nos. MD5407 and MD5408)
Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64

==REFERENCES:==
: 1) USN RC letter, "Requests for Additional Information for the Review of the Indian Point License Renewal Application RAI SET 2017-02 (CAC Nos. MD5407 and MD5408)," dated April 19, 2017(ML170~8A327)

==Dear Sir or Madam:==
* Entergy Nuclear Operations, Inc. (Entergy) is providing in Attachment 1 the additional information requested by the U.S. Nuclear Regulatory Commission (NRC) pertaining to the review of the License Renewal Application (LRA) for Indian Point Energy Center (IPEC) Unit Nos. 2 and 3 (Reference 1).
Changes to the 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 declc;lre under penalty of perjury that the foregoing is true and correct. Executed on
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NL-17-060 Docket Nos. 50-24 7 and 50-286 Page 2 of 2 Attachments:
: 1. Reply to NRC Request for Additional Information Regarding the License Renewal Application
: 2. License Renewal Application Changes Due To Responses To Requests For Information
: 3. License Renewal Application IPEC List of Regulatory Commitments   Revi~ion 33 cc:  Mr. Daniel H. Dorman, Regional Administrator, NRC Region I Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel Mr. William Burton, NRC Senior Project Manager, Division of License Renewal Mr. Richard V. Guzman, NRR Senior Project Manager Ms. Bridget Frymire, New York State Department of Public Service Mr. John B. Rhodes, President and CEO NYSERDA NRC Resident Inspector's Office

ATTACHMENT 1 to NL-17-060
. 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-17-060 Attachment 1 Page 1 of 5 RAI B.1.35-1

===Background===
By letter dated January 17, 2017, the applicant submitted the changed status of Commitments 41 and 42 for Indian Point Unit 2 and Unit 3 (IP2 and IP3 respectively). Previously, the applicant identified these license renewal commitments to manage cracking due to primary water stress corrosion cracking (PWSCC) for steam generator divider plates and tube-to-tubesheet welds. The January 17, 2017, letter indicates that the applicant eliminated Commitment 41 (regarding divider plates) and closed Commitment 42 (regarding tube-to-tubesheet welds) based on License Renewal Interim Staff Guidance (LR-ISG) 2016-01, "Changes to Aging Management Guidance for Various Steam Generator Components."
In the letter, the applicant also provided proprietary information to demonstrate that the industry analyses in EPRI Report 3002002850 are applicable and bounding for the applicant's units (as discussed in LR-ISG-2016-01). EPRI Report 3002002850 describes industry analyses of potential crack initiation and propagation in steam generator head components (e.g., divider plate cracking into the steam generator head). The EPRI report also addresses the implication of the potential cracking for the integrity of reactor coolant pressure boundary, taking into account material's resistance to PWSCC (e.g., resistance of Alloy 690) and steam generator loading conditions.
In addition, Tables 4-2 and 4-3 of EPRI Report 3002002850 identify the turbine roll test as one of the bounding thermal transients for the industry analyses. LRA Tables 4.3-1 and 4.3-2 describe design transients for ASME Class 1 fatigue analysis for IP2 and IP3, respectively.
LRA Table 4.3-1 indicates that the number of turbine-roll-test cycles analyzed for IP2 is 20 cycles. LRA Table 4.3-2 indicates that the turbine-roll-test transient is not a design transient for IP3.
In its review of the applicant's information, the staff noted the following concerns:
* The number of turbine-roll-test cycles analyzed in EPRI Report 3002002850 is less than that analyzed for IP2 in LRA Table 4.3-1 (i.e., 20 cycles). This indicates that the loading conditions analyzed in the EPRI report for this transient may not bound the IP2 loading conditions.
* Given that the LRA Table 4.3-2 does not identify the turbine roll test as an IP3 design transient for ASME Class 1 fatigue analysis, it is not clear how the applicant ensures the loading conditions at IP3 are bounded by those analyzed in EPRI Report 3002002850 in terms of the turbine-roll-test transient.

NL~17-060 Attachment 1 Page 2 of 5 RAI B.1.35-1. Request 1 Explain why the IP2 steam generator loading conditions are bounded by those analyzed in EPRI Report 3002002850 even though the number of turbine-roll-test cycles analyzed in the EPRI report is less than that analyzed for IP2 in LRA Table 4.3-1.

===Response===
A turbine roll test is a test performed during initial hot functional testing prior to commercial plant operation. The IP2 cycle counting program conservatively assumes that one turbine roll test was performed at IP2. IP2 has no plans to perform any additional turbine roll tests during its remaining operating life. IP2 has revised the cycle counting program to reduce the number of allowable turbine roll tests from 20 to 10 to be consistent with the EPRI analysis.
The steam generators at IP2 were replaced in 2000. The turbine roll test transient only occurs during plant hot functional testing; therefore, the IP2 replacement steam generators have not experienced and will not experience a turbine roll test transient. Because the IP2 replacement steam generators were installed after any turbine roll tests would have been performed, the loading conditions at IP2 are bounded by the loading conditions analyzed in EPRI Report 3002002850.
RAI B.1.35-1. Request 2 Discuss how the applicant ensures that the loading conditions at IP3 are bounded by those analyzed in EPRI Report 3002002850 in terms of the turbine-roll-test transient.

===Response===
A turbine roll test is a test performed during initial hot functional testing prior to commercial plant operation. The turbine roll test transient was not tracked prior to submittal of the license renewal application and therefore, was not included in LRA Table 4.3-2. Turbine roll test transients have since been added to the IP3 cycle counting program.
The IP3 cycle counting program conservatively assumes that five turbine roll tests were performed at IP3. IP3 has no plans to perform any additional turbine roll tests during its remaining operating life. The IPEC cycle counting procedure has a limit of 5 turbine roll test transient cycles for IP3, so IP3 is bounded by the EPRI analysis.
The steam generators at IP3 were replaced in 1989. The turbine roll test transient only occurs during plant hot functional testing; therefore, the IP3 replacement steam generators have not experienced and will not experience a turbine roll test transient. Because the IP3 replacement steam generators were installed after any turbine roll tests would have been performed, the loading conditions at IP3 are bounded by the ,loading conditions analyzed in EPRI Report 3002002850.

NL-17-060 Attachment 1 Page 3 of 5 RAI 8.1.35-2
~ Background By letter dated January 17, 2017, the applicant submitted information on the changed status of Commitments 41 and 42 for Indian Point Unit 2 and Unit 3. As the applicant's letter notes, the staff recently issued License Renewal Interim Staff Guidance (LR-ISG) 2016-01, "Changes to Aging Management Guidance for Various Steam Generator Components". LR-ISG-2016-01 includes the following guidance on aging management for steam generator components.
* Visual inspections: steam generator head internal areas (head interior surfaces, divider plate assemblies, tubesheets (primary side) and tube-to-tubesheet welds) are inspected to identify signs of cracking or loss of material (e.g., rust stains and distortion of divider plates). GALL Report AMP Xl.M19, "Steam Generators,." which includes these visual inspections, is used to manage (a) loss of material due to boric acid corrosion for channel heads and tubesheets and (b) cracking due to primary water stress corrosion cracking (PWSCC) for divider plate assembles and tube-to-tubesheet welds.
* Frequency of the visual inspections: at least every 72 effective full power months or every third refueling outage, whichever results in more frequent inspections.
* Implementation of the EPRI steam generator guidelines, including: (a) EPRI Report 1022832 (primary-to-secondary leak guidelines); (b) EPRI Report 1025132 (in-situ pressure test guidelines); (c) EPRI Report 3002007571 (integrity assessment guidelines); and (d) EPRI Report 3002007572 (examination guidelines).
The staff needs to confirm whether the applicant's Steam Generator Integrity Program is consistent with the guidance in LR-ISG-2016-01.
RAI B.1.35-2. Request 1 Clarify whether the Steam Generator Integrity Program is consistent with the guidance discussed above (i.e., conduct of visual inspections to manage loss of material and cracking due to PWSCC; visual inspection frequency; and implementation of or plans for implementation of the EPRI steam generator guidelines by the industry-provided implementation dates). If the program is not consistent with the guidance, provide justification for why the applicant's program is adequate for aging management.

===Response===
The IPEC Steam Generator Integrity Program will be updated to require general visual inspections of the steam generator channel head. These visual inspections provide an opportunity to identify cracking if it were to grow into pressure boundary components

NL-17-060 Attachment 1 Page 4 of 5 through identification of rust stains and gross cracking or distortion of the divider plate assembly.
Visual inspections will be performed whenever the steam generator primary side is opened for eddy current inspections. At IP2, the frequency is at least once every 48 effective full p'ower months per Technical Specification 5.5.7.d.2. At IP3, the frequency is at least once every 72 effective full power months (which is every third refueling outage) per Technical Specification 5.5.8.d.2.
I' IPEC implements the EPRI steam generator guidelines, including: (a) EPRI Report 1022832 (primary-to-secondary leak guidelines); (b) EPRI Report 1025132 (in-situ pressure test guidelines); (c) EPRI Report 1019038 (integrity assessment guidelines); and (d) EPRI Report 1013706 (examination guidelines). The IPEC Steam Generator Integrity Program is being revised to implement (c) EPRI Report 3002007571 (integrity assessment guidelines);
and (d) EPRI Report 3002007572 (examination guidelines) within the timeframes required by the EPRI Steam Generator Management Program (~GMP) in accordance with NEI 97-06 Rev 3 and NEI 03-08 Rev 2 and 3.
* RAI B.1.35-2. Request 2 Discuss whether the Steam Generator Integrity Program is used to manage cracking due to PWSCC for divider plate assemblies (LRA item 3.1.1-81) and tube-to-tubesheet welds (LRA item 3.1.1-35).

===Response===
As indicated in LRA item 3.1.1-81, the Water Chemistry Control - Primary and Secondary Program manages cracking of the nickel-alloy steam generator divider plate exposed to reactor coolant. Aging management review results do not credit the Steam Generator Integrity Program to manage cracking of the divider plate due to PWSCC because the program does not include VT-1 or volumetric examinations that are qualified for detection of small cracks resulting from PWSCC. However, consistent with LR-ISG-2016-01 recommendations, the IPEC Steam Generator Integrity Program will be enhanced to specify a general visual inspection of the steam generator channel head.
For the steam generator tubesheets, which are steel with nickel alloy cladding, cracking is managed by the Water Chemistry Control - Primary and Secondary, and the Steam Generator Integrity Programs. This position is documented in LRA item 3.1.1-35.
In the IP3 spring 2017 refueling outage, a general visual inspection was performed on the steam generator channel head, divider plate assembly, and tube-to-tubesheet welds in all 4 steam generators looking for evidence of cracking. The inspection was specifically performed to satisfy the recommendations of LR-ISG-2016-01. The purpose of the visual
        ,inspection was to identify rust stains or other abnormal conditions which could indicate the presence of cracking. The visual inspection was satisfactory with no evidence of rust stains I
L

NL-17-060 Attachment 1 Page 5 of 5 or other abnormal conditions which would indicate the presence of cracking. The general visual inspection identified no cracking or distortion of the divider plate.
A similar inspection is planned for IP2 in the spring 2018 refueling outage.
RAI B.1.35-2. Request 3 Provide updated description of UFSAR supplement for the Steam Generator Integrity Program as necessary. As part of the response, clarify whether the program is consistent with Revision 3 of NEI 97-06 "Steam Generator Program Guidelines."

===Response===
The IPEC Steam Generator Integrity Program is consistent with Revision 3 of NEI 97-06 "Steam Generator Program Guidelines."
The License Renewal Application requires changes due to the responses to this Request for Information. These changes are contained in Attachment 2. The IP3 UFSAR will be revised in the biennial update due in September 2017, and the IP2 UFSAR will be revised in the biennial update due in September 2018.

ATTAGHMENT 2 to NL-17-060 LICENSE RENEWAL APPLICATION CHANGES DUE TO RESPONSES TO REQUESTS FOR INFORMATION Changes are shown as strikethroughs for deletions and underlines for additions ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286

NL-17-060 Attachment 2 Page 1of4 Indian Point Unit No. 2 A.2.1.34    Steam Generator Integrity Program The Steam Generator Integrity Program is an existing program that uses nondestructive examination (NOE) techniques to identify tubes that are defective and need to be removed from service or repaired in accordance with the guidelines of the plant technical specifications. The program also includes processes for monitoring and maintaining primary and secondary side component integrity. The program defines when inspections and maintenance are performed, the scope of work, and the methods used, in accordance with the EPRI steam generator guidelines. including revisions to EPRI Steam Generator Management Program (SGMP) documents. any interim guidance provided by the SGMP.
and SGMP administrative procedures. The results of the condition monitoring assessment are compared to the operational assessment performed for the prior operating cycle with differences evaluated.
The Steam Generator Integrity Program will be enhanced to include the following.
* Revise appropriate procedures to require that the results of the condition monitoring assessment are compared to the operational assessment performed for the prior operating cycle *.vith differences evaluated.
Enhancements will be implemented prior to the period of extended operation.
* Revise applicable procedures to specify a general visual inspection of the steam generator channel head.
This enhancement will be implemented prior to December 31, 2017.
Indian Point Unit No. 3 A.3.1.34    Steam Generator Integrity Program The Steam Generator Integrity Program is an existing program that performs uses nondestructive examination (NOE) techniques to identify tubes that are defective and need to be removed from service or repaired in accordance with the guidelines of the plant technical specifications. The* program also includes processes for monitoring and maintaining primarY and secondary side component integrity. The program defines when inspections and maintenance are performed, the scope of work, and the methods used, in accordance with the EPRI steam generator guidelines. including revisions to EPRI Steam Generator Management Program (SGMP) documents. any interim guidance provided by the SGMP. and SGMP administrative procedures. The results of the condition monitoring assessment are compared to the operational assessment performed for the prior operating cyCle with differences evaluated.
The Steam Generator Integrity Program will be enhanced to include the following.

NL-17-060
                                                                               -, Attachment 2 Page 2 of 4
* Revise appropriate procedures to require that the results of the condition monitoring assessment are compared to the operational assessment performed for the prior operating cycle with differences evaluated.
Enhancements *11ill be implemented prior to the period of extended operation.
* Revise applicable procedures to specify a general visual inspection of the steam generator channel head~
This enhancement will be implemented prior to December 31. 2017.

NL-17-060 Attachment 2 Page 3 of4 8.1.35 STEAM GENERATOR INTEGRITY .
Program Description The Steam Generator Integrity Program is an existing program. In the industry, steam generator (SG) tubes have experienced tube degradation related to corrosion phenomena, such as primary water stress corrosion cracking (PWSCC), outside diameter stress corrosion cracking (ODSCC), intergranular attack (IGA), pitting, and wastage, along with other mechanically induced phenomena, such as denting, wear, impingement damage, and fatigue.
Nondestructive examination (NOE) techniques are used to identify tubes that are defective and need to.be removed frorri service or repaired in accordance with the guidelines of the plant technical specifications.
The Steam Generator Integrity Program includes processes for monitoring and maintaining primary and secondary side component integrity. The program defines when inspections and maintenance are performed, the scope of work, and the methods used. The Steam Generator Integrity Program is implemented in accordance with NEI 97-06, "Steam Generator Program Guidelines."
NUREG-1801 Consistency The Steam Generator Integrity Program is consistent with the program described in NUREG-1801, Section Xl.M19, Steam Generator Tube Integrity with enhancement.
Exceptjons to NUREG-1801 None Enhancements The following enhancement will be implemented prior to the period of extended operation.
Attributes Affected                         Enhancements
: 5. Monitoring and Trending          Revise appropriate procedures to require that the results of the condition monitoring assessment are compared to the operational assessment performed for the prior operating cycle with differences evaluated.
The following enhancement will be implemented prior to December 31. 2017.

NL-17-060 Attachment 2 Page 4 of 4 Attributes Affected                  Enhancements
: 4. Detection of Aging Effects Revise am2licable grocedures to sgecif~ a general visual insgection of the steam i                            generator channel head.

ATTACHMENT 3 to NL-17-060 LICENSE RENEWAL APPLICATION IPEC LIST OF REGULATORY COMMITMENTS Rev.33 ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286

NL-17-060 Attachment 3 Page 1 of 22 List of Regulatory Commitments Rev. 33 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 I AUDIT ITEM IP2: Complete        NL-07-039      A.2.1.1 1 Enhance the Aboveground Steel Tanks Program for A.3.1.1 IP2 and IP3 to perform thickness measurements of NL-13-122       8.1.1 the bottom surfaces qf the condensate storage tanks, city water tank, and fire water tanks once during the first ten years of the period of extended operation.
Enhance the Aboveground Steel Tanks Program for IP2 and IP3 to require trending of thickness measurements when material loss is detected.
IP2 & IP3:           NL-14-147      A.2.1.1 Implement LRA Sections, A.2.1.1, A.3.1.1 and 8.1.1, December 31, 2019                   A.3.1.1 as shown in NL-14-147.
8.1.1 IP2 & IP3:           NL-:-15-092    A.2.1.1 Implement LRA Sections, A.2.1.1 and 8.1~1, as December 31, 2019                    8.1.1 shown in NL-15:::092 IP2: Complete        NL-07-039      A.2.1.2 2 Enhance the Bolting Integrity Program for IP2 and A.3.1.2 IP3 to clarify that actual yield strength is used in IP3: Complete                        B.1.2 selecting materials for low susceptibility to sec and clarify the prohibition on use of lubricants containing NL-07-153 Audit Items MoS2 for bolting.
201, 241, The Bolting Integrity Program manages loss of                                  NL-13-122         270 preload and loss of material for all external bolting.

NL-17-060 Attachment 3 Page 2 of 22
#                       COMMITMENT                          IMPLEMENTATION SOURCE      RELATED SCHEDULE                   LRA SECTION I AUDIT ITEM IP2: Complete   NL-07-039     A.2.1.5 3  Implement the Buried Piping and Tanks Inspection A.3.1.5 Program for IP2 and IP3 as described in LRA IP3: Complete   NL-13-122      B.1.6 Section B.1.6.
NL-07-153   Audit Item This new program will be implemented consistent                         NL-15-121       173 with the corresponding program described in NUREG-1801 Section Xl.M34, Buried Piping and Tanks Inspection.
Include in the Buried Piping and Tanks Inspection                       NL-09-106 Program described in LRA Section B.1.6 a risk assessment of in-scope buried piping and tanks that                     NL-09-111 includes consideration of the impacts of buried piping or tank leakage and of conditions affecting the risk for corrosion. Classify pipe segments and tanks as having a high, medium or low impact of leakage based on the safety class, the hazard posed by fluid contained in the piping and the impact of leakage on reliable plant operation. Determine corrosion risk through consideration of piping or tank material, soil resistivity, drainage, the presence of cathodic protection and the type of coating. Establish inspection priority and frequency for periodic inspections of the in-scope piping and tanks based on the results of the risk assessment. Perform inspections using inspection techniques with demonstrated effectiveness.                                             NL-11-101 IP2: Complete   NL-07-039     A.2.1.8 4  Enhance the Diesel Fuel Monitoring Program to A.3.1.8 include cleaning and inspection of the IP2 GT-1 gas IP3: Complete   NL-13-122      B.1.9 turbine fuel oil storage tanks, IP2 and IP3 EDG fuel NL-07-153   Audit items oil day tanks, IP2 SBO/Appendix R diesel generator NL-15-121    128, 129, fuel oil day tank, and IP3 Appendix R fuel oil storage 132, tank and day tank once every ten years.
NL-08-057    491, 492, Enhance the Diesel Fuel Monitoring Program to                                           510 include quarterly sampling and analysis of the IP2 SBO/Appendix R diesel generator fuel oil day tank, IP2 security diesel fuel oil storage tank, IP2 security
  'diesel fuel oil day tank, and IP3 Appendix R fuel oil storage tank. Particulates, water and sediment checks will be performed on the samples. Filterable solids acceptance criterion will be less than or equal to 1Omg/I. Water and sediment acceptance criterion will be less than or eaual to 0.05%.

NL-17-060 Attachment 3 Page 3 of 22
#                      COMMITMENT                        IMPLEMENTATION SOURCE     RELATED SCHEDULE                  LRA SECTION I AUDIT ITEM Enhance the Diesel Fuel Monitoring Program to include thickness measurement of the bottom of the following tanks once every ten years. IP2: EDG fuel oil storage tanks, EDG fuel oil day tanks, SBO/Appendix R diesel generator fuel oil day tank,                  (
GT-1 gas turbine fuel oil storage tanks, and diesel fire pump fuel oil storage tank; IP3: EDG fuel oil day tanks, EDG fuel oil storage tanks, Appendix R fuel oil storage tank, and diesel fire pump fuel oil storage ,
tank.
Enhance the Diesel Fuel Monitoring Program to change the analysis for water and particulates to a quarterly frequency for the following tanks. IP2: GT-1 gas turbine fuel oil storage tanks and diesel fire pump fuel oil storage tank; IP3: Appendix R fuel oil day tank and diesel fire pump fuel oil sforage 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 presenceof bioloQical activity is confirmed.
5                                                        IP2: Complete  NL-07-039   A.2.1.10 Enhance the External Surfaces Monitoring Program for IP2 and IP3 to include periodic inspections of                                A.3.1.10 systems in scope and subject to aging management                      NL-13-122     8.1.11 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).

NL-17-060 Attachment 3 Page 4 of 22
#                       COMMITMENT                          IMPLEMENTATION SOURCE         RELATED SCHEDULE                      LRA SECTION I AUDIT ITEM IP2 & IP3:        NL-14-147    A.2.1.10 Implement LRA Sections A.2.1.10, A.3.1.10 and December 31, 2019              A.3.1.10 B.1.11, as shown in NL-14-147.
B.1.11 IP2: Complete     NL-07-039    A.2.1.11 6 Enhance the Fatigue Monitoring Program for IP2 to A.3.1.11 monitor steady state cycles and feedwater cycles or NL-13-122     B.1.12, perform an evaluation to determine monitoring is not NL-07-153   Audit Item required. Review the number of allowed events and 164 resolve discrepancies between reference documents IP3: Complete     NL-15-121 and monitoring procedures.
Enhance the Fatigue Monitoring Program for IP3 to include all the transients identified. Assure all fatigue analysis transients are included with the lowest limiting numbers. Update the number of design transients accumulated to date.
IP2: Complete     NL-07-039    A.2.1.12 7 Enhance the Fire Protection Program to inspect A.3.1.12 external surfaces of the IP3 RCP oil collection IP3: Complete     NL-13-122      B.1.13 systems for loss of material each refueling cycle.
Enhance the Fire Protection Program to explicitly                           NL-15-121 state that the IP2 and IP3 diesel fire pump engine sub-systems (including the fuel supply line) shall be                       "
observed while the pump is running. Acceptance criteria will be revised to verify that the diesel engine does not exhibit signs of degradation while running; such as fuel oil, lube oil, coolant, or exhaust gas leakage.
Enhance the Fire Protection Program to specify that the IP2 and IP3 diesel fire pump engine carbon steel exhaust components are inspected for evidence of corrosion and cracking at least once each operating cycle.
Enhance the Fire Protection Program for IP3 to visually inspect the cable spreading room, 480V switchgear room, and EOG room C0 2 fire suppression system for signs of degradation, such as corrosion and mechanical damage at least once every six months.

NL-17-060 Attachment 3 Page 5 of 22
#                      COMMITMENT                        . IMPLEMENTATION SOURCE        RELATED SCHEDULE                    LRA SECTION I AUDIT ITEM IP2: Complete     NL-07-039 A.2.1.13 8 Enhance the Fire Water Program to include A.3.1.13 inspection of IP2 and IP3 hose reels for evidence of NL-13-122     B.1.14
* corrosion. Acceptance criteria will be revised to NL-07-153 Audit Items verify no unacceptable signs of degradation.
105, 106 Enhance the Fire Water Program to replace all or                           NL-08-014 test a sample of IP2 and IP3 sprinkler heads required for 10 CFR 50.48 using guidance of NFPA                    "
25 (2002 edition), Section 5.3.1.1.1 before the end of the 50-year sprinkler head service life and at 10-year intervals thereafter during the extended period of operation to ensure that signs of degradation, such as corrosion, are detected in a timely manner.
Enhance the Fire Water Program to perform wall thickness evaluations of IP2 and IP3,fire protection piping on system components using non-intrusive techniques (e.g., volumetric testing) to identify evidence of loss of material due to corrosion. These inspections will be performed before the end of the current operating term and at intervals thereafter during the period of extended operation. Results of the initial evaluations will be used to determine the appropriate inspection interval to ensure aging effects are identified prior to loss of intended function.
Enhance the Fire Water Program to inspect the               J internal surface of foam based fire suppression tanks. Acceptance criteria will be enhanced to verify no siQnificant corrosion.
IP2 & IP3:        NL-14-147   A.2.1.13 Implement LRA Sections, A.2.1.13, A.3.1.13 and December 31, 2019             A.3.1.13 B.1.14, as shown in NL-14-147.
B.1.14 IP2 & IP3:        NL-15-019    A.2.1.13 Implement LRA Sections A.2.1.13, A.3.1.13 and December 31, 2019              A.3.1.13 B.1.14, as shown in NL-15-019 B.1.14 IP2 & IP3:        NL-15-092    A.2.1.13 Implement LRA Sections A.2.1.13, A.3.1.13 and December 31, 2019              A.3.1.13 B.1.14, as shown in NL-15-092 B.1.14

NL-17-060 Attachment 3 Page 6 of 22
#                      COMMITMENT                       IMPLEMENTATION SOURCE         RELATED SCHEDULE                      LRA SECTION I AUDIT ITEM IP2 & IP3:        NL-17-052 A.2.1.13 Implement LRA Sections A.2.1.13, A.3.1.13, and December 31, 2017              A.3.1.13 B.1.14, as shown in NL-17-052 B.1.14 IP2: Complete     NL-07-039    A.2.1.15 9 Enhance the Flux Thimble Tube Inspection Program A.3.1.15 for IP2 and IP3 to 'implement comparisons to wear IP3: Complete     NL-13-122     B.1.16 rates identified in WCAP-12866. Include provisions NL-15-121 to compare data to the previous performances and perform evaluations regarding change to test frequency and scope.
Enhance the Flux Thimble Tube Inspection Program for IP2 and IP3 to specify the acceptance criteria as outlined in WCAP-12866 or other plant-specific 1 values based on evaluation of previous test results.
' Enhance the Flux Thimble Tube Inspection Program for IP2 and IP3 to direct evaluation and performance of corrective actions based on tubes that exceed or are projected to exceed the acceptance criteria. Also stipulate that flux thimble tubes that cannot be inspected over the tube length and cannot be shown by analysis to be satisfactory for continued service, must be removed from service to ensure the integrity of the reactor coolant system pressure boundary.

NL-17-060 Attachment 3 Page 7 of 22
#                       COMMITMENT                         IMPLEMENTATION SOURCE      RELATED SCHEDULE                   LRA SECTION I AUDIT ITEM IP2: Complete   NL-07-039    A.2.1.16 10 Enhance the Heat Exchanger Monitoring Program A.3.1.16 for IP2 and IP3 to include the following heat IP3: Complete   NL-13-122     8.1.17, exchangers in the scope of the program.
NL-07-153   Audit Item
* Safety injection pump lube oil heat                             NL-15-121        52 exchangers
* 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
* S80/Appendix R diesel jacket water heat exchanger (IP2 only)
Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to perform visual inspection on heat exchangers where non-destructive examination, such as eddy current inspection, is not possible due to ~eat exchanger design limitations.
Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to include consideration of material-environment combinations when determining sample population of heat exchangers.
Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to establish minimum tube wall thickness for the new heat exchangers identified in the scope of the program. Establish acceptance criteria for heat exchangers visually inspected to include no indication of tube erosion, vibration wear, corrosion, pitting, fouling, or scaling.
NL-09-018
                                          '

NL-17-060 Attachment 3 Page 8 of 22
#                        COMMITMENT                        IMPLEMENTATION SOURCE      RELATED SCHEDULE                   LRA SECTION I AUDIT ITEM NL-09-056 11 Deleted NL-11-101 IP2: Complete  NL-07-039    A.2.1.18 12 Enhance the Masonry Wall Program for IP2 and IP3 A.3.1.18 to specify that the IP1 intake structure is included in IP3: Complete  NL-13-122      B.1.19 the program.
IP2: Complete  NL-07-039    A.2.1.19 13 Enhance the Metal-Enclosed Bus Inspection A.3.1.19 Program for IP2 and IP3 to visually inspect the IP3: Complete  NL-13-122      B.1.20 external surface of MEB enclosure assemblies for NL-07-153   Audit Items loss of material at least once every 10 years. The NL-15-121       124, first inspection will occur prior to the period of NL-08-057    133, 519 extended operation and the acceptance criterion will
                                 \
be no significant loss of material.
NL-13-077 .
Enhance the Metal-Enclosed Bus Inspection Program to add acceptance criteria for MEB internal visual inspections to include the absence of indications of dust accumulation on the bus bar, on the insulators, and in the duct, in addition to the absence of indications of moisture intrusion into the duct.                                                          ,
Enhance the Metal-Enclosed Bus Inspection Program for IP2 and IP3 to inspect bolted connections at least once every five years if performed visually or at least once every ten years using quantitative measurements such as thermography or contact resistance measurements.
The first inspection will occur prior to the period of extended operation.
The plant will process a change to applicable site procedure to remove the reference to "re-torquing" connections for phase bus maintenance and bolted connection maintenance.
IP2: Complete  NL-07-039    A.2.1.21 14  Implement the Non-EQ Bolted Cable Connections A.3.1.21 Program for IP2 and IP3 as described in LRA IP3: Complete  NL-13-122      B.1.22 Section B. 1.22.
NL-15-121

NL-17-060 Attachment 3 Page 9 of 22
#                     COMMITMENT                       IMPLEMENTATION SOURCE       RELATED SCHEDULE                    LRA SECTION I AUDIT ITEM IP2: Complete   NL-07-039     A.2.1.22 15 Implement the Non-EQ Inaccessible Medium-A.3.1.22 Voltage Cable Program for IP2 and IP3 as described.
IP3: Complete   NL-13-122      8.1.23 in LRA Section 8.1.23.
NL-07-153    Audit item This new program will be implemented consistent                     NL-15-121       173 with the corresponding program described in                         NL-11-032 NUREG-1801 Section Xl.E3, Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49                          NL-11-096 Environmental Qualification Requirements.
NL-11-101 IP2: Complete   NL-07-039     A.2.1.23 16 Implement the Non-EQ Instrumentation Circuits Test A.3.1.23 Review Program for IP2 and IP3 as described in IP3: Complete   NL-13-122      8.1.24 LRA Section 8.1.24.
NL-07-153 Audit item This new program will be implemented consistent                     NL-15-121       173 with the. corresponding program described in NUREG-1801 Section Xl.E2, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits.
IP2: Complete   NL-07-039     A.2.1.24 17 Implement the Non-EQ Insulated Cables and A.3.1.24 Connections Program for IP2 and IP3 as described.
IP3: Complete   NL-13-122      8.1.25 in LRA Section 8.1.25.
NL-07-153 Audit item This new program will be implemented consistent                     NL-15-121       173 with the corresponding program described in NUREG-1801 Secti.on Xl.E1, Electrical Cables and                  ~
Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.

NL-17-060 Attachment 3 Page 10 of 22
#                       COMMITMENT                         IMPLEMENTATION SOURCE      RELATED SCHEDULE                  LRA SECTION I AUDIT ITEM IP2: Complete  NL-07-039 A.2.1.25 18 Enhance the Oil Analysis Program for IP2 to sample A.3.1.25 and analyze lubricating oil used in the SBC/Appendix IP3: Complete  NL-13-122     B.1.26 R diesel generator consistent with the oil analysis for NL-11-101 other site diesel generators.
NL-15-121 Enhance the Oil Analysis Program for IP2 and IP3 to sample and analyze generator seal oil and turbine hydraulic control oil.
Enhance the Oil Analysis Program for IP2 and IP3 to formalize preliminary oil screening forwater and particulates and laboratory analyses including defined acceptance criteria for all components included in the scope of this program. The program will specify corrective actions in the event acceptance criteria are not met.
Enhance the Oil Analysis Program for IP2 and IP3 to formalize trending of preliminary oil screening results as well as data provided from independent laboratories.                          -,,
IP2: Complete  NL-07-039    A.2.1.26 19 Implement the One-Time Inspection Program for IP2 A.3.1.26 and IP3 as described in LRA Section B.1.27.
IP3: Complete  NL-13-122     B.1.27 This new program will be implemented consistent                        NL-07-153 Audit item with the corresponding program described in                            NL-15-121       173 NUREG-1801, Section Xl.M32, One-Time Inspection.
IP2: Complete  NL-07-039    A.2.1.27 20 Implement the One-Time Inspection - Small Bore A.3.1.27 Piping Program for IP2 and IP3 as described in LRA IP3: Complete  NL-13-122     B.1.28 Section B.1.28.
NL-07-153 Audit item This new program will be implemented consistent                        NL-15-121       173 with the corresponding program described in NUREG-1801, .section Xl.M35, One-Time Inspection of ASME Code Class I Small-Bore Piping.
21                                                         IP2: Complete  NL-07-039    A.2.1.28 Enhance the Periodic Surveillance and Preventive Maintenance Program for IP2 and IP3 as necessary                                    A.3.1.28 IP3: Complete  NL-13-122     B.1.29 to assure that the effects of aging wjll be managed such that applicable components will continue to                       NL-15-121 perform their intended functions consistent with the current licensing basis through the period of           )
extended operation.

NL-17-060 Attachment 3 Page 11 of 22
#                       COMMITMENT                           IMPLEMENTA~ION SOURCE        RELATED
                                                                 ~CH EDU LE                   LRA
                                      *'                                                  SECTION I AUDIT ITEM IP2 & IP3:        NL-17-052 A.2.1.28 Implement LRA Sections A.2.1.28, A.3.1.28 and December 31, 2017              A.3.1.28 8.1.29, as-shown in NL-17-052 8.1.29 I
IP2: Complete     NL-07-039 A.2.1.31 22 Enhance the Reactor Vessel Surveillance Program A.3.1.31 for IP2 and IP3 revising the specimen capsule 1IP3: Complete     NL-13-122     8.1.32 withdrawal schedules to draw and test a standby NL-15-121 capsule to cover the peak reactor vessel fluence expected through the end of the period of extended operation.
Enhance the Reactor Vessel Surveillance Program for IP2 and IP3 to require that tested and untested specimens from all capsules pulled from the reactor vessel are maintained in storage.
IP2: Complete     NL-07-039    A.2.1.32 23 Implement the Selective Leaching Program for IP2 A.3.1.32 and IP3 as described in LRA Section 8.1.33.
IP3: Complete     NL-13-122     8.1.33 This new program will be implemented consistent -                          NL-07-153   Audit item with the corresponding program described in                                NL-15-121       173 NUREG-1801, Section Xl.M33 Selective Leaching of Materials.                                                      ,
24                                                          IP2: Complete     NL-07-039    A.2.1.34 Enhance the Steam Generator Integrity Program for A.3.1.34 IP2 and IP3 to require that the results of the IP3: Complete     NL-13-122     8.1.35 condition monitoring assessment are compared to*
the operational assessment performed for the prior ooerating cycle with differences evaluated.
Enhance the Structures Monitoring Program to             IP2: Complete*    NL-07-039    A.2.1.35 25 explicitly specify that the following structures are                                    A.3.1.35.
included in the program.                                 IP3: Complete     NL-13-122     8.1.36
* Appendix   R  diesel  generator   foundation (I P3)                    NL-07-153
* Appendix R diesel generator fuel oil tank vault                          NL-15-121 Audit items
{IP3)                                                                             86, 87, 88,
* Appendix   R diesel generator switchgear and                           NL-08-057       417 enclosure (IP3)
* city water storage tank foundation NL-13-077
* 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 pumphouse (IP3)
* fire water storage tank foundations (IP2/3)
* gas turbine 1 fuel storage tank foundation

NL-17-060 Attachment 3 Page 12 of 22
  #                      COMMITMENT                         IMPLEMENTATION SOURCE     RELATED SCHEDULE                   LRA SECTION I AUDIT ITEM
* maintenance and outage building-elevated passageway (IP2)
* new station security building (IP2)
* nuclear service building (IP1)       .,
* primary water storage tank foundation (IP3)
* refueling water storage tank foundation (I P3)
* security access and office building (IP3)
* service water pipe chase (IP2/3)
* service water valve pit (IP3)
* transformer/switchyard support structures (IP2)
NL-14-146
* waste holdup tank pits (IP2/3)
Enhance the Structures Monitoring Program for IP2 and IP3 to clarify that in addition to structural steel and concrete, the following commodities (including their anchorages) are inspected for each structure as applicable.
* cable trays and supports
* concrete.portion of reactor vessel supports
* conduits and supports
* cranes, rails and girders
* equipment pads and foundations
* fire proofing (pyrocrete)
* HVAC duct supports
* jib cranes
* manholes and duct banks
* manways, hatches and hatch covers
* monorails
* new fuel storage racks
* sumps NL-13-077 Enhance the Structures Monitoring Program for IP2 and IP3 to inspect inaccessible concrete areas that are exposed by excavation for any reason. IP2 and IP3 will also inspect inaccessible concrete areas in environments where observed conditions in accessible areas exposed to the same environment indicate that significant concrete degradation is occurring.
Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspections of elastomers (seals, L

NL-17-060 Attachment 3 Page 13 of 22
#                      COMMITMENT                        IMPLEMENTATION SOURCE      RELATED SCHEDULE                    LRA SECTION I AUDIT ITEM gaskets, seismic joint filler, and roof elastomers) to identify cracking and change in material properties and for inspection of aluminum vents and louvers to identify loss of material.
Enhance the Structures Monitoring Program for IP2 and IP3 to perform an engineering evaluation of groundwater samples to assess aggressiveness of groundwater to concrete on a periodic basis (at least once every five years). IPEC will obtain samples                      NL-08-127 Audit Item from at least 5 wells that are representative of the                                  360 ground water surrounding below-grade site structures and perform an engineering evaluation of the results from those samples for sulfates, pH and chlorides.
Additionally, to assess potential indications of spent fuel pool leakage, IPEC will sample for tritium in groundwater wells in close proximity to the IP2 spent fuel pool at least once every 3 months.
Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspection of normally submerged concrete portions of the intake structures at least once every 5 years. Inspect the baffling/grating partition and support platform of the IP3 intake structure at least once every 5 years.
Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspection of the degraded areas of the water control structure once per 3 years rather than the normal frequency of once per 5 years during the PEO.                                                                           Audit Item 358 Enhance the Structures Monitoring Program to include more detailed quantitative acceptance criteria for inspections of concrete structures in accordance with ACI 349.3R, "Evaluation of Existing Nuclear Safety-Related Concrete Structures" prior to the period of extended operation.                                         NL-11-032 NL-11-101

NL-17-060 Attachment 3 Page 14 of 22
#                      COMMITMENT                         IMPLEMENTATION SOURCE      RELATED SCHEDULE                  LRA SECTION I AUDIT ITEM IP2: Complete  NL-07-039     A.2.1.36 26 Implement the Thermal Aging Embrittlement of Cast A.3.1.36 Austenitic Stainless Steel (CASS) Program for IP2 IP3: Complete  NL-13-122      B.1.37 and IP3 as described in LRA Section B.1.37.
NL-07-153    Audit item This new program will be implemented consistent                       NL-15-121       173 with the corresponding program described in NUREG-1801, Section Xl.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) Proaram.
IP2: Complete  NL-07-039     A.2.1.37 27 Implement the Thermal Aging and Neutron A.3.1.37 Irradiation Embrittlement of Cast Austenitic Stainless IP3: Complete  NL-13-122      B.1.38 Steel (CASS) Program for IP2 and IP3 as described NL-07-153 Audit item in LRA Section B.1.38.
173 This new program will be implemented consistent with the corresponding program described in NUREG-1801 Section Xl.M13, Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Proaram.
                                                                                                 -
IP2: Complete  NL-07-039     A.2.1.39 28 Enhance the Water Chemistry Control - Closed A.3.1.39 Cooling Water Program to maintain water chemistry IP3: Complete  NL-13-122      B.1.40 of the IP2 SBC/Appendix R diesel generator cooling NL-08-057 Audit item system per EPRI guidelines.
509 Enhance the Water Chemistry Control - Closed Cooling Water Program to maintain the IP2 and IP3 security generator and fire protection diesel cooling water pH and glycol within limits specified by EPRI Quidelines.
IP2: Complete  NL-07-039     A.2.1.40 29 Enhance the Water Chemistry Control - Primary and B.1.41
   ~econdary Program for IP2 to test sulfates monthly
                                                                    -    NL-13-122 m the RWST with a limit of <150 ppb.
IP2: Complete  NL-07-039     A.2.1.41 30 For aging management of the reactor vessel A.3.1.41 internals, IPEC will (1) participate in the industry IP3: Complete  NL-13-122 programs for investigating and managing aging effects on reactor internals; (2) evaluate and implement the results of the industry programs as applicable to the reactor internals; and (3) upon completion of these programs, but not less than 24 months before entering the period of extended NL-11-107 operation, submit an inspection plan for reactor internals to the NRC for review and approval.

NL-17-060 Attachment 3 Page 15of22
#'                      COMMITMENT                         IMPLEMENTATION SOURCE             RELATED SCHEDULE                         LRA SECTION I AUDIT ITEM IP2: Complete         NL-07-039 A.2.2.1.2 31 Additional P-T curves will be submitted as required A.3.2.1.2 per 10 CFR 50, Appendix G prior to the period of IP3: Complete         NL-13-122      4.2.3 extended operation as part of the Reactor Vessel
:              NL-15-121 Surveillance Program.
As required by 10 CFR 50.61(b)(4), IP3 will submit a    IP3:                  NL-07-039    A.3.2.1.4 32 plant-specific safety analysis for plate 82803-3 to the ~pproximately 6       NL-07-140      4.2.5 NRC three years prior to reaching the RT PTs            !fears after entering NL-08-014 screening criterio,n. Alternatively, the site may        he PEO               NL-08-127 choose to implement the revised PTS rule when approved.
                                                      '

NL-17-060 Attachment 3 Page 16 of 22
#                        COMMITMENT                            IMPLEMENTATION SOURCE      RELATED SCHEDULE                  LRA SECTION I AUDIT ITEM IP2: Complete  NL-07-039 A.2.2.2.3 33 At least 2 years prior to entering the period of A.3.2.2.3 extended operation, for the locations identified in
                                                             . IP3: Complete  NL-13-122      4.3.3 LRA Table 4.3-13 (IP2) and LRA Table 4.3-14 (IP3),
NL-07-153 Audit item under the Fatigue Monitoring Program, IP2 and IP3 146 will implement one or more of the following:
NL-08-021 (1) Consistent with the Fatigue Monitoring Program, Detection of Aging Effects, update the fatigue usage calculations using refined fatigue analyses to determine valid .CUFs less than 1.0 when accounting                        NL-10-082 for the effects of reactor water environment. This includes applying the appropriate Fen factors to 'valid CUFs determined in accordance with one of the following:*
: 1. For locations in LRA Table 4.3-13 (IP2) and LRA Table 4.3-14 (IP3), with existing fatigue
(
analysis valid for the period of extended operation, use the existing CUF.
: 2. Additional plant-specific locations with a valid CUF may be evaluated. In particular, the pressurizer lower shell will be reviewed to ensure the surge nozzle remains the limiting component.
: 3. Representative CUF values from other plants, adjusted to or enveloping the IPEC plant specific external loads may be used if demonstrated applicable to IPEC.
: 4. An analysis using an NRG-approved 'version of the ASME code or NRG-approved alternative (e.g., NRG-approved code case) may be performed to determine a valid CUF.
(2) Consistent with the Fatigue Monitoring Program, Corrective Actions, repair or replace the affected locations before exceeding a CUF of 1.0.
                                       '
Complete       NL-13-122    2.1.1.3.5 34 IP2 SBO I Appendix R diesel generator will be NL-07-078 installed and operational by April 30, 2008. This committed change to the facility meets the NL-08-074 requirements of 10 CFR 50.59(c)(1) and, therefore, a license amendment pursuant to 10 CFR 50.90 is not NL-11-101 required.

NL-17-060 Attachment 3 Page 17 of 22
#                       COMMITMENT                          IMPLEMENTATION SOURCE          RELATED SCHEDULE.                     LRA
                ?                                                                          SECTION I AUDIT ITEM IP2: Complete      NL-08-127 Audit Item 35 Perform a one-time inspection of representative 27 sample area of IP2 containment liner affected by the NL-13-122 1973 event behind the insulation, prior to entering the period of extended operation, to assure liner IP3: Complete degradation is not occurring in this area.
NL-11-101
                                                                                                   )
Perform a one-time inspection of representative                             NL-15-121 sample area of the IP3 containment steel liner at the juncture with the concrete floor slab, prior to entering the period of extended operation, to assure liner degradation is not occurring in this area.
NL-09-018 Any degradation will be evaluated for updating of the containment liner analvses as needed.
IP2: Complete      NL-08-127 Audit Item 36 Perform a one-time inspection and evaluation of a NL-11-101       359 sample of potentially affected IP2 refueling cavity NL-13-122 concrete prior to the period of extended operation.
The sample will be obtained by core boring the refueling cavity wall in an area that is susceptible to exposure to borated water leakage. The inspection will include an assessment of embedded reinforcing steel.
Additional core bore samples will be taken, if the                          NL-09-056 leakage is not stopped, prior to the end of the first ten years of the period of extended operation.
A sample of leakage fluid will be analyzed to                               NL-09-079 determine the composition of the fluid. If additional core samples are taken prior to the end of the first                    j '
ten years of the period of extended operation, a                  ____,
sample of leakaoe fluid will be analvzed.
IP2: Complete      NL-08-127 Audit Item 37  Enhance the Containment lnservice Inspection (Cll-361 IWL) Program to include inspections of the IP3: Complete      NL-13-122 containment using enhanced characterization of degradation (i.e., quantifying the dimensions of noted indications through the use of optical aids) during the period of extended operation. The enhancement includes obtaining critical dimensional data of degradation where possible through direct measurement or the use of scaling technologies for photographs, and the use of consistent vantage points for visual inspections.

NL-17-060 Attachment 3 Page 18 of 22
                                         -
 #                      COMMITMENT                            IMPLEMENTATION SOURCE      RELATED
                    '                                             SCHEDULE                   LRA SECTION I AUDIT ITEM IP2: Complete   NL-08-143      4.2.1 38 For Reactor Vessel Fluence, should future core loading patterns invalidate the basis for the projected IP3: Complete   NL-13-122 values of RTpts or CvUSE, updated calculations will NL-15-121 be orovided to the NRC.
NL-09-079 39 Deleted IP2: Complete   NL-09-106      8.1.6 40 Evalu~te   plant ~pecific and appropriate industry 8.1.22 operating experience and incorporate lessons IP3: Complete   NL-13-122     8.1.23
   ~earned_ in establishing appropriate monitoring and
* NL-15-121     8.1.24 inspect~on frequencies to assess aging effects for the 8.1.25 new aging management programs. Documentation 8.1.27 of the operating experience evaluated for each new 8.1.28 program will be available on site for NRC review 8.1.33 prior to the period of extended operation.
8.1.37 8.1.38 NL-17-005       N/A 41 Deleted

NL-17-060 Attachment 3 Page 19 of 22
#                         COMMITMENT                       IMPLEMENTATION SOURCE          RELATED SCHEDULE                      LRA SECTION I AUDIT ITEM NL-11-032       N/A 42  IPEC will develop a plan for each unit to address the potential for cracking of the primary to secondary pressure boundary due to PWSCC of tube-to-tubesheet welds using one of the following two options.
Option 1 (Analysis)
JPEC will perform an analytical evaluation of the steam generator tube-to-tubesheet welds in order to     IP2: Complete       NL-11-074 establish a technical basis for either determining that the tubesheet cladding and welds are not susceptible    IP3: Complete       NL-11-090 to PWSCC, or redefining the pressure boundary in which the tube-to-tubesheet weld is no longer                               NL-11-096 included and, therefore, is not required for reactor coolant pressure boundary function. The redefinition   IP2:                NL-17-005 of the reactor coolant pressure boundary must be       Not Applicable approved by the NRC as a license amendment request.                                               IP3: Not Applicable Option 2 (Inspection)                      I I
IPEC will perform a one-time inspection of a representative number of tube-to-tubesheet welds in each steam generator to determine if PWSCC cracking is present. If weld cracking is identified:
: a. The condition will be resolved through repair or engineering evaluation to justify continued service, as appropriate, and
: b. An ongoing monitoring program will be established to perform routine tube-to-tubesheet weld inspections for the remaining life of the steam aenerators.

NL-17-060 Attachment 3 Page 20 of 22
#                         COMMITMENT                        IMPLEMENTATION SOURCE      RELATED SCHEDULE                   LRA SECTION I AUDIT ITEM IP2: Complete  NL-11-032      4.3.3 43  IPEC will review design basis ASME Code Class 1 fatigue evaluations to determine whether the IP3: Complete NUREG/CR-6260 locations that have been NL-13-122 evaluated for the effects of the reactor coolant NL-11-101 environment on fatigue usage are the limiting NL-15-121 locations for the IP2 and IP3 configurations. If more limiting locations are identified, the most limiting location will be evaluated for the effects of the reactor coolant environment on fatigue usage.
IPEC will use the NUREG/CR-6909 methodology in the evaluation of the limiting locations consisting of nickel allov, if anv.
IP2: Complete  NL-11-032       N/A 44  IPEC will include written explanation and justification of any user intervention in future evaluations using IP3: Complete  NL-11-101 the WESTEMS "Design CUF" module.
                                                 /',                       NL-13-122 NL-15-121 IP2:Complete   NL-11-032       N/A 45  IPEC will not use the NB-3600 option of the WESTEMS program in future design calculations IP3: Complete  NL-11-101 until the issues identified during the NRC review of NL-13-122 the program have been resolved.
NL-15-121 IP2: Complete  NL-11-032       N/A 46  Include in the IP2 ISi Program that IPEC will perform twenty-five volumetric weld metal inspections of NL-11-074 socket welds during each 10-year ISi interval NL-13-122 scheduled as specified by IWB-2412 of the ASME Section XI Code during the period of extended operation.
In lieu of volumetric examinations, destructive examinations may be performed, where one
  \
destructive examination may be substituted for two volumetric examinations.
47  Deleted.                                                               NL-14-093        N/A

NL-17-060 Attachment 3 Page 21 of 22
  #                       COMMITMENT                          IMPLEMENTATION SOURCE         RELATED SCHEDULE                      LRA SECTION I AUDIT ITEM IP2: Complete     NL-12-174       N/A 48  Entergy will visually inspect IPEC underground piping within the scope of license renewal and IP3: Complete subject to aging management review prior to the NL-13-122 period of extended operation and then on a NL-15-121 frequency of at least once every two years during the period of extended operation. This inspection frequency will be maintained unless the piping is subsequently coated in accordance with the preventive actions specified in NUREG-1801 Section Xl.M41 as modified by LR-ISG-2011-03. Visual inspections will be supplemented with surface or volumetric non-destructive testing if indications of significant loss of material are observed. Consistent with revised NUREG-1801 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).
IP2: Complete     NL-13-052     A.2.2.2 49  Recalculate each of the limiting CUFs provided in A.3.2.2 section 4.3 of the LRA for the reactor vessel internals IP3: Complete to include the reactor coolant environment effects NL-13-122 (Fen) as provided in the IPEC Fatigue Monitoring NL-15-121 Program using NUREG/CR-5704 or NUREG/CR-6909. In accordance with the corrective actions specified in the Fatigue Monitoring Program, corrective actions include further CUF re-analysis, and/or repair or replacement of the affected components prior to the CUFen reaching 1.0.
~
Replace the IP2 split pins during the 2016               IP2: Complete     NL-13-122    A.2.1.41 50 refueling outage (2R22).                                                                  B.1.42 IP3: N/A          NL-14-067 IP2 & IP3:        NL-14-147     A.2.1.33 51  Enhance the Service Water Integrity Program by December 31, 2017               A.3.1.33 implementing LRA Sections A.2.1.33, A.3.1.33 and B.1.34 B.1.34, as shown in NL-14-147.
IP2 & IP3:        NL-17-052    A.2.1.33 Implement LRA Sections A.2.1.33, A.3.1.33 and December 31, 2017               A.3.1.33 B.1.34, as shown in NL-17-052 B.1.34

NL-17-060
* Attachment 3 Page 22 of 22
#                      COMMITMENT                             IMPLEMENTATION SOURCE           RELATED SCHEDULE                        LRA SECTION I AUDIT
                                               ,                                                 ITEM IP2 & IP3:          NL-15-019 A.2.1.42 52 Implement the Coating Integrity Program for IP2 and December 31, 2024                A.3.1.42 IP3 as described in LRA Section B.1.42, as shown in B.1.43 NL-15-019.
May 31, 2018        NL-17-053     A.2.1.2 53 Revise Bolting Integrity Program to include visual A.3.1.2 inspection of a representative sample of closure B.1.2 bolting (bolt heads, nuts, and threads) from components with an internal environment of a clear gas, such as air or nitrogen. A representative sample                     .
will be 20 percent of the population (for each bolting material and environment combination) up to a maximum of 25 fasteners during each 10-year period of the period of extended operation. The inspections will be performed when the bolting is removed to the extent that the bolting threads and bolt heads are accessible for inspections that cannot be performed during visual inspection with the threaded fastener installed.
Enhance the Steam Generator Integrity Program         December 31 2017    NL-17-060    A.2.1.34 54 as follows.                                                                            A.3.1.34 B.1.35
* Revise a1212licable 12rocedures to s12ecify a general visual ins12ection of the steam generator channel head.                                         )
(
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