View source for RS-16-003, Responses to NRC Requests for Additional Information, Set 14, Dated December 14, 2015, and Two Additional Commitment Implementation Schedule Clarifications, Related to the License Renewal Application

{{Adams
| number = ML16007A130
| issue date = 01/07/2016
| title = Responses to NRC Requests for Additional Information, Set 14, Dated December 14, 2015, and Two Additional Commitment Implementation Schedule Clarifications, Related to the License Renewal Application
| author name = Gallagher M
| author affiliation = Exelon Generation Co, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRO
| docket = 05000373, 05000374
| license number = NPF-011, NPF-018
| contact person = 
| case reference number = RS-16-003, TAC MF5346, TAC MF5347
| document type = Letter type:RS, Response to Request for Additional Information (RAI)
| page count = 34
| project = TAC:MF5346, TAC:MF5347
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:Michael P. Gallagher Vice President, License Renewal Exelon Generation Exelon Nuclear 200 Exelon Way Kennett Square. PA 19348 610 765 5958 Office 610 765 5956 Fax www.exeloncorp.com michaelp.gallagher@exeloncorp.com 10 CFR 50 10 CFR 51 10 CFR 54 RS-16-003 January 7, 2016 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374

==Subject:==
Responses to NRC Requests for Additional Information, Set 14, dated December 14, 2015, and Two Additional Commitment Implementation Schedule Clarifications, related to the LaSalle County Station, Units 1 and 2, License Renewal Application (TAC Nos. MF5347 and MF5346)

==References:==
: 1. Letter from Michael P. Gallagher, Exelon Generation Company LLC (Exelon),
to NRC Document Control Desk, dated December 9, 2014, "Application for Renewed Operating Licenses"
: 2. Letter from Jeffrey S. Mitchell, US NRC to Michael P. Gallagher, Exelon, dated December 14, 2015, "Requests for Additional Information for the Review of the LaSalle County Station, Units 1 and 2 License Renewal Application - Set 14 (TAC Nos. MF5347 and MF5346)"
: 3. Letter from Michael P. Gallagher, Exelon Generation Company LLC (Exelon),
to NRC Document Control Desk, dated September 15, 2015, "Response to NRC Requests for Additional Information, Set 9, dated August 18, 2015 related to the LaSalle County Station, Units 1 and 2, License Renewal Application (TAC Nos.
MF5347 and MF5346)"
In Reference 1, Exelon Generation Company, LLC (Exelon) submitted the License Renewal Application (LRA) for the LaSalle County Station (LSCS), Units 1 and 2. In Reference 2, the NRC requested additional information to support staff review of the LRA.
Enclosure A contains the responses to these requests for additional information.

January 7, 2016 U.S. Nuclear Regulatory Commission Page 2 Enclosure B contains updates to sections of the LRA (except for the License Renewal Commitment List) affected by the responses.
Enclosure C provides an update to the License Renewal Commitment List (LRA Appendix A, Section A.5) resulting from these responses.
Note that two additional commitment implementation schedule clarifications, unrelated to RAI A.5-1, are provided in Enclosure C. The first one clarifies the information in the Implementation Schedule column of Commitment 47, making it consistent with the response to RAI 4.2.10-1, which was provided in Reference 3. The second one standardizes the language used for several of the commitments within LRA Appendix A, Section A.5, indicating that additional information regarding the commitment implementation schedule is provided within the Commitment column of the table. These changes are also summarized in Enclosure A and noted as bulleted items on page 1 of Enclosure C.
Other than these commitment implementation schedule clarifications, shown in Enclosure C, there are no new or revised regulatory commitments contained in this letter.
If you have any questions, please contact Mr. John Hufnagel, Licensing Lead, LaSalle License Renewal Project, at 610-765-5829.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on Respectfully, Vice President - License Renewal Projects Exelon Generation Company, LLC

==Enclosures:==
A: Responses to Set 14 Requests for Additional Information B: LSCS License Renewal Application Updates C: LSCS License Renewal Commitment List Updates cc:     Regional Administrator - NRC Region Ill NRC Project Manager (Safety Review), NRR-DLR NRC Project Manager (Environmental Review), NRR-DLR NRC Project Manager, NRR-DORL- LaSalle County Station NRC Senior Resident Inspector, LaSalle County Station Illinois Emergency Management Agency - Division of Nuclear Safety

RS-16-003 Enclosure A Page 1 of 4 Enclosure A Responses to Set 14 Requests for Additional Information related to the LaSalle County Station (LSCS) License Renewal Application (LRA)
RAI A.5-1 Note: Two additional commitment implementation schedule clarifications, unrelated to RAI A.5-1, are described in Enclosure A, following the response to RAI A.5-1.

RS-16-003 Enclosure A Page 2 of 4 RAI A.5-1

==Background:==

The LaSalle County Station (LSCS) license renewal application (LRA), submitted December 9, 2014, includes an Updated Final Safety Analysis Report (UFSAR) supplement, as required by 10 CFR 54.21(d). The LSCS UFSAR supplement includes a list of commitments related to aging management programs (AMPs), aging management reviews (AMRs), and time-limited aging analyses (TLAA), related to managing the aging effects of structures and components, which will be implemented prior to the period of extended operation (PEO). This list of commitments has been updated throughout the LRA review process to incorporate new information as needed.
The list of these commitments, as well as the implementation schedules and the sources for each commitment, will be included as a Table in Appendix A to the staffs safety evaluation report (SER). The staff expects to identify two proposed license conditions in the SER related to the implementation of new programs and enhancements to existing programs, and the completion of activities as listed in the SER Appendix A.
The first proposed license condition requires that the information in the UFSAR supplement, submitted pursuant to10 CFR 54.21(d), as revised during the LRA review process, and as listed in the SER Appendix A, be made a part of the updated final safety analysis report (UFSAR).
The second license condition states, in part, that the new programs and enhancements to existing programs that are incorporated into the UFSAR by the first license condition, be implemented no later than 6 months prior to the PEO. This license condition also states, in part, that activities in certain commitments that are incorporated into the UFSAR by the first license condition, shall be completed by 6 months prior to the PEO or the end of the last refueling outage prior to the PEO, whichever occurs later.
Proposed License Conditions:
: 1. The information in the UFSAR supplement, submitted pursuant to 10 CFR 54.21(d),
as revised during the license renewal application review process, and licensee commitments as listed in Appendix A of the Safety Evaluation Report Related to the License Renewal of LaSalle County Station, Unit 1 and 2, are collectively the License Renewal UFSAR Supplement. This Supplement is henceforth part of the UFSAR which will be updated in accordance with 10 CFR 50.71(e). As such, the licensee may make changes to the programs, activities, and commitments described in this Supplement, provided the licensee evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

RS-16-003 Enclosure A Page 3 of 4
: 2. The License Renewal UFSAR Supplement, as updated by license condition [1]
above, describes certain programs to be implemented and activities to be completed prior to the period of extended operation (PEO).
: a. The applicant shall implement those new programs and enhancements to existing programs no later than 6 months prior to the PEO.
: b. The applicant shall complete those activities by the 6-month date prior to PEO or the end of the last refueling outage prior to the PEO, whichever occurs later.
: c. The applicant shall notify the NRC in writing within 30 days after having accomplished item (a) above and include the status of those activities that have been or remain to be completed in item (b) above.
Issue:
As reflected in the LRA Appendix A program and TLAA descriptions, and the table of commitments in LRA Section A.5 which will be included in the staffs SER Appendix A, the implementation schedule for some commitments could conflict with the implementation schedule intended by the proposed license conditions. In addition, these licensing commitments need to be incorporated either into a license condition or into the applicants UFSAR in such a manner as discussed above.
Request:
: 1.      Identify those commitments to implement new programs and enhancements to existing programs, and indicate the expected date for completing the implementation of each of these programs and enhancements.
: 2.      Identify those commitments to complete inspection or testing activities prior to the PEO, and indicate the expected dates for the completion of each of these inspection and testing activities.
: 3.      For each commitment provided in the LRA Appendix A, identify where and how it will be incorporated, either into a license condition or into the LSCS UFSAR.
Exelon Response:
: 1.      Following is the list of commitments to implement new programs and enhancements to existing programs. This list uses the Item numbers from the LSCS License Renewal Commitment List, LRA Appendix A, Section A.5:
9, 11-25, 27-31, 33-35, 37-44, 47, 48 The Implementation Schedule column within LRA Section A.5, as updated with this submittal, indicates the specific completion timing requirements for each of these commitments. In summary, Exelon will complete implementation of new programs and enhancements to existing programs no later than six months prior to entry into the respective period of extended operation for each LSCS unit. The period of extended

RS-16-003 Enclosure A Page 4 of 4 operation (PEO) for LaSalle Unit 1 begins on April 17, 2022, and for LaSalle Unit 2, the PEO begins on December 16, 2023.
: 2.      Following is the list of commitments that involve completion of inspection or testing activities prior to the PEO. Unless a specific earlier completion date is specified in the LRA Appendix A, Section A.5 License Renewal Commitment List (i.e., Commitment 29, Enhancement 2), these activities will be completed either no later than six months prior to entry into the period of extended operation, or prior to completion of the last refueling outage prior to the PEO, whichever occurs later, for each LSCS unit. As noted above, the period of extended operation (PEO) for LaSalle Unit 1 begins on April 17, 2022, and for LaSalle Unit 2, the PEO begins on December 16, 2023. This list uses the Item numbers from the LSCS Station License Renewal Commitment List, which contains the specific completion timing requirements for each commitment:
17-19, 21-23, 28, 29, 37-39, 41-43, 48
: 3.      All of the commitments made by Exelon for license renewal are included in LRA Appendix A, Section A.5, License Renewal Commitment List, as revised during the LRA review process, and as shown in Enclosure C. Appendix A of the LRA is the UFSAR Supplement required by 10 CFR 54.21(d), and following receipt of the renewed operating licenses, this UFSAR Supplement will be part of the LSCS UFSAR, which will be updated in accordance with 10 CFR 50.71(e). Therefore, Exelon proposes that none of the commitments in SER Appendix A be incorporated into a license condition.
As a result of this request, LRA Appendix A, Section A.5, License Renewal Commitment List, is updated to reflect the schedule information summarized above for each commitment, as shown in Enclosure C.
References to the implementation of programs and activities made throughout other portions of LRA Appendix A, and LRA Appendix B do not describe actual schedule dates; rather, they indicate that the associated activities will be completed prior to the period of extended operation.
Meeting the implementation schedule provided within LRA Appendix A, Section A.5, License Renewal Commitment List, will ensure that the timing for implementation of the commitments is consistent with Proposed License Condition 2.
For clarity and consistency within the UFSAR Supplement (LRA Appendix A), Section A.1.0 of LRA Appendix A is updated as shown in Enclosure B.
Additional Commitment Implementation Schedule Clarifications:
Note that two additional commitment implementation schedule clarifications, unrelated to RAI A.5-1, are provided in Enclosure C. The first one clarifies the information in the Implementation Schedule column of Commitment 47, making it consistent with the response to RAI 4.2.10-1, provided in Exelon letter RS-15-232 dated September 15, 2015. The second one standardizes the language used for several of the commitments within LRA Appendix A, Section A.5, indicating that additional information regarding the commitment implementation schedule is provided within the Commitment column of the table. These changes are also summarized in bulleted items on page 1 of Enclosure C.

RS-16-003 Enclosure B Page 1 of 3 Enclosure B LSCS License Renewal Application (LRA) Updates Resulting from the Response to the following RAI:
RAI A.5-1 Note: To facilitate understanding, portions of the LRA have been repeated in this Enclosure, with revisions indicated. Previously submitted information is shown in normal font. Changes are highlighted with bolded italics for inserted text and strikethroughs for deleted text.

RS-16-003 Enclosure B Page 2 of 3 LRA Appendix A, Section A.1.0, Introduction, shown on page A-4 of the LRA, is revised to add subsection A.1.0.1 as shown below to better define the phrase prior to the period of extended operation as it is used throughout Appendix A, in relation to the license renewal commitment implementation schedule. The added subsection is shown in bolded italics.
A.1.0    Introduction The application for a renewed operating license is required by 10 CFR 54.21(d) to include a FSAR Supplement. This appendix, which includes the following sections, comprises the FSAR supplement:
Section A.1.1 contains a listing of the aging management programs that correspond to NUREG-1801 Chapter XI programs, including the status of the programs at the time the License Renewal Application was submitted.
Section A.1.2 contains a listing of the plant-specific aging management programs, including the status of the programs at the time the License Renewal Application was submitted.
Section A.1.3 contains a listing of aging management programs that correspond to NUREG-1801 Chapter X programs associated with Time-Limited Aging Analyses, including the status of the programs at the time the License Renewal Application was submitted.
Section A.1.4 contains a listing of the Time-Limited Aging Analyses summaries (TLAAs).
Section A.1.5 contains a discussion of the Quality Assurance Program and Administrative Controls.
Section A.1.6 contains a discussion of the Operating Experience.
Section A.2 contains a summarized description of the aging management programs.
Section A.2.1 contains a summarized description of the NUREG-1801 Chapter XI programs for managing the effects of aging.
Section A.2.2 contains a summarized description of the plant-specific programs for managing the effects of aging.
Section A.3 contains a summarized description of the NUREG-1801 Chapter X programs that support the TLAAs.
Section A.4 contains a summarized description of the TLAAs applicable to the period of extended operation.
Section A.5 contains the License Renewal Commitment List.

RS-16-003 Enclosure B Page 3 of 3 The integrated plant assessment for license renewal identified new and existing aging management programs necessary to provide reasonable assurance that systems, structures, and components within the scope of license renewal will continue to perform their intended functions consistent with the current licensing basis (CLB) for the period of extended operation. The period of extended operation is defined as 20 years from the units current operating license expiration date.
A.1.0.1 Commitment Implementation Schedule Information LRA Appendix A, Section A.5, License Renewal Commitment List contains the specific implementation schedule requirements for each commitment.
Consistent with the License Renewal Commitment list, when used throughout Appendix A, the phrase prior to the period of extended operation means that:
Implementation of new aging management programs and enhancements to existing aging management programs will be completed no later than six months prior to the respective period of extended operation (PEO) for each LaSalle County Station unit; and Inspection or testing activities identified for completion prior to the PEO will be completed either:
o  No later than six months prior to the respective PEO for each LaSalle County Station unit, or o  Prior to the end of the last refueling outage before the PEO for each respective unit, whichever occurs later.

RS-16-003 Enclosure C Page 1 of 25 Enclosure C LaSalle County Station, Units 1 and 2 License Renewal Commitment List Updates This Enclosure provides a complete update to the LaSalle County Station (LSCS) LRA Appendix A, Section A.5, License Renewal Commitment List, showing the updated commitment implementation schedule completion requirements resulting from the response to NRC RAI A.5-1.
This updated license renewal commitment list shows the integrated effects of all previous Exelon correspondence that has revised the license renewal commitments since submittal of the LRA on December 9, 2014.
Notes:
Information within the License Renewal Commitment List table that existed prior to this response to RAI A.5-1 is shown in normal font. Text inserted as part of this response package is shown in bolded italics, with deletions shown using strikethroughs.
With the exception of the changes described in the two notes below, the changes made to the License Renewal Commitment List are limited to commitment implementation schedule information that is being updated as a direct result of the Exelon Responses to Requests 1 and 2 of RAI A.5-1.
For Commitment Number 47, the implementation schedule information is updated to make clear that, as described in Exelon letter RS-15-232, the procedure used to track cumulative EFPY values will be enhanced no later than six months prior to the period of extended operation. This will ensure that corrective action is taken for the Unit 1 jet pump slip joint clamp in accordance with the schedule information contained in the Commitment column, for Commitment 47.
Minor changes have been made to standardize the language used in the Implementation Schedule column of several commitments (i.e., Commitments 9, 11, 12, 13, 17, 18, 19, 28, 29, 37, 38, 39, 40, and 47) to indicate that additional schedule information, beyond that requested in RAI A.5-1, is included within the Commitment column. The standard language used is Additional schedule information identified in commitment.

RS-16-003 Enclosure C Page 2 of 25 A.5      License Renewal Commitment List NO.      PROGRAM OR                                                                                                      IMPLEMENTATION COMMITMENT                                                                        SOURCE TOPIC                                                                                                          SCHEDULE*
1   ASME Section XI         Existing program is credited.                                                           Ongoing                   Section A.2.1.1 Inservice Inspection, Subsections IWB, IWC, and IWD 2   Water Chemistry         Existing program is credited.                                                           Ongoing                   Section A.2.1.2 3   Reactor Head            Existing program is credited.                                                           Ongoing                   Section A.2.1.3 Closure Stud Bolting 4   BWR Vessel ID           Existing program is credited.                                                           Ongoing                   Section A.2.1.4 Attachment Welds 5   BWR Feedwater           Existing program is credited.                                                           Ongoing                   Section A.2.1.5 Nozzle 6   BWR Control Rod         Existing program is credited.                                                           Ongoing                   Section A.2.1.6 Drive Return Line Nozzle 7   BWR Stress              Existing program is credited.                                                           Ongoing                   Section A.2.1.7 Corrosion Cracking 8   BWR Penetrations        Existing program is credited.                                                           Ongoing                   Section A.2.1.8 9   BWR Vessel              BWR Vessel Internals is an existing program that will be enhanced to:                   Program to be enhanced    Section A.2.1.9 Internals                                                                                                       no later than six
: 1. Perform an assessment of the susceptibility of reactor vessel internal            months prior to the components fabricated from CASS to loss of fracture toughness due to              period of extended thermal aging embrittlement. If material properties cannot be determined to       operation.
perform the screening, they will be assumed susceptible to thermal aging for the purposes of determining program examination requirements.                     Additional Inspection schedule information
: 2. Perform an assessment of the susceptibility of reactor vessel internal            identified in commitment.
components fabricated from CASS to loss of fracture toughness due to neutron irradiation embrittlement.
: 3. Specify the required periodic inspection of CASS components determined to be susceptible to loss of fracture toughness due to thermal aging and neutron irradiation embrittlement. The initial inspections will be performed either prior
* The dates for the start of the respective periods of extended operation for LaSalle County Station, Units 1 and 2 are:
LaSalle County Station, Unit 1: April 17, 2022         LaSalle County Station, Unit 2: December 16, 2023 Exelon Letter RS-16-003 resulted in refining commitment implementation timing requirements as shown throughout the above table, in order to provide time for NRC inspection of commitment implementation prior to the units entering their respective periods of extended operation.

RS-16-003 Enclosure C Page 3 of 25 NO.      PROGRAM OR                                                                                                     IMPLEMENTATION COMMITMENT                                                                       SOURCE TOPIC                                                                                                        SCHEDULE*
to or within five years after entering the period of extended operation.
10   Flow-Accelerated        Existing program is credited.                                                          Ongoing                   Section A.2.1.10 Corrosion 11   Bolting Integrity       Bolting Integrity is an existing program that will be enhanced to:                     Program to be enhanced    Section A.2.1.11 no later than six
: 1. Provide guidance to ensure proper specification of bolting material, lubricant   months prior to the and sealants, storage, and installation torque or tension to prevent or mitigate period of extended degradation and failure of closure bolting for pressure-retaining bolted joints. operation.
: 2. Prohibit the use of lubricants containing molybdenum disulfide on                                          Exelon Letter pressure-retaining bolted joints.                                                                          RS-15-194 Additional Inspection     08/06/2015
: 3. Minimize the use of high strength bolting (actual measured yield strength        schedule information equal to or greater than 150 ksi) for pressure-retaining bolted joints in        identified in commitment.
portions of systems within the scope of the Bolting Integrity program. High strength bolting (regardless of code classification) will be monitored for cracking in accordance with ASME Section XI, Table IWB-2500-1, Examination Category B-G-1.
: 4. Perform inspection of submerged bolting for the emergency core cooling systems (ECCS) and reactor core isolation cooling (RCIC) system suction strainers in the suppression pool for loss of material and loss of preload during each ISI inspection interval.
: 5. Perform inspection of submerged bolting for the service water diver safety barriers and diesel fire pump suction screens for loss of material and loss of preload each refuel interval.
: 6. Perform inspection of submerged bolting for the Lake Screen House travelling screens framework for loss of material and loss of preload each refueling interval.
* The dates for the start of the respective periods of extended operation for LaSalle County Station, Units 1 and 2 are:
LaSalle County Station, Unit 1: April 17, 2022          LaSalle County Station, Unit 2: December 16, 2023 Exelon Letter RS-16-003 resulted in refining commitment implementation timing requirements as shown throughout the above table, in order to provide time for NRC inspection of commitment implementation prior to the units entering their respective periods of extended operation.

RS-16-003 Enclosure C Page 4 of 25 NO.      PROGRAM OR                                                                                                     IMPLEMENTATION COMMITMENT                                                                       SOURCE TOPIC                                                                                                         SCHEDULE*
12   Open-Cycle Cooling      Open-Cycle Cooling Water System is an existing program that will be enhanced to:       Program to be enhanced    Section A.2.1.12 Water System                                                                                                   no later than six
: 1. Perform a minimum of 10 microbiologically influenced corrosion (MIC)              months prior to the degradation inspections for aboveground piping in the Essential Cooling           period of extended Water System every 24 months until the rate of MIC occurrences no longer          operation.
meets the criteria for recurring internal corrosion. The selected inspection locations will be periodically reviewed to validate their relevance and           Additional Inspection usefulness and adjusted as appropriate. Evaluation of the inspection results      schedule information will include; (1) a comparison to the nominal wall thickness or previous wall     identified in commitment.
thickness measurements to determine rate of corrosion degradation; (2) a comparison to the design minimum allowable wall thickness to determine the acceptability of the component for continued use; and (3) a determination of re-inspection interval. A portion of these inspection locations will be selected with process conditions similar (e. g. flow, temperature) to those in buried portions of the piping to provide sufficient understanding of the condition of the buried piping.
: 2. Perform a minimum of 10 MIC degradation inspections for in scope aboveground piping in the Nonessential Cooling Water System every 24 months until the rate of MIC occurrences no longer meets the criteria for recurring internal corrosion. The selected inspection locations will be periodically reviewed to validate their relevance and usefulness and adjusted as appropriate. Evaluation of the inspection results will include (1) a comparison to the nominal wall thickness or previous wall thickness measurements to determine rate of corrosion degradation; (2) a comparison to the design minimum allowable wall thickness to determine the acceptability of the component for continued use; and (3) a determination of re-inspection interval. A portion of these inspection locations will be selected with process conditions similar (e. g. flow, temperature) to those in buried portions of the piping to provide sufficient understanding of the condition of the buried piping.
: 3. Select an inspection method that will provide indication of suitable wall thickness to perform inspections on a representative sample of buried piping to supplement the aboveground piping inspection locations.
: 4. Perform visual inspections of the interior surface of buried portions of the Essential Cooling Water System and Nonessential Cooling Water System whenever the piping internal surface is made accessible due to maintenance and repair activities.
* The dates for the start of the respective periods of extended operation for LaSalle County Station, Units 1 and 2 are:
LaSalle County Station, Unit 1: April 17, 2022         LaSalle County Station, Unit 2: December 16, 2023 Exelon Letter RS-16-003 resulted in refining commitment implementation timing requirements as shown throughout the above table, in order to provide time for NRC inspection of commitment implementation prior to the units entering their respective periods of extended operation.

RS-16-003 Enclosure C Page 5 of 25 NO.      PROGRAM OR                                                                                                        IMPLEMENTATION COMMITMENT                                                                          SOURCE TOPIC                                                                                                            SCHEDULE*
13   Closed Treated          Closed Treated Water Systems is an existing program that will be enhanced to:             Program to be enhanced    Section A.2.1.13 Water Systems                                                                                                     no later than six
: 1. Perform condition monitoring, including periodic visual inspections and              months prior to the non-destructive examinations, to verify the effectiveness of water chemistry         period of extended        Exelon Letter control to mitigate aging effects. A representative sample of piping and             operation.                RS-15-193 components will be selected based on likelihood of corrosion, stress                                           08/06/2015 corrosion cracking, or fouling, and inspected at an interval not to exceed once      Additional Inspection in 10 years during the period of extended operation. The selection of                schedule information components to be inspected will focus on locations which are most                    identified in commitment.
susceptible to age-related degradation, where practical.
: 2. Monitor and trend drywell penetration cooling coil outlet temperatures monthly to ensure that adequate cooling is being provided to the concrete adjacent to the drywell penetrations.
14   Inspection of           Inspection of Overhead Heavy Load and Light Load (Related to Refueling)                   Program to be enhanced    Section A.2.1.14 Overhead Heavy          Handling Systems is an existing program that will be enhanced to:                         no later than six Load and Light Load                                                                                               months prior to the (Related to              1. Provide additional guidance to include inspection of structural components,          period of extended Refueling) Handling          rails, and bolting for loss of material due to corrosion; rails for loss of material operation.
Systems                      due to wear; and bolted connections for loss of preload.
15   Compressed Air          Compressed Air Monitoring is an existing program that will be enhanced to:                Program to be enhanced    Section A.2.1.15 Monitoring                                                                                                        no later than six
: 1. Inspect the internal surfaces of system filters, compressors, and after-coolers      months prior to the for signs of corrosion and corrosion products.                                       period of extended operation.
: 2. Perform analysis and trending of air quality monitoring results and visual inspection results.
: 3. Document deficiencies which are identified during visual inspections of the internal surfaces of system components in the corrective action program.
* The dates for the start of the respective periods of extended operation for LaSalle County Station, Units 1 and 2 are:
LaSalle County Station, Unit 1: April 17, 2022         LaSalle County Station, Unit 2: December 16, 2023 Exelon Letter RS-16-003 resulted in refining commitment implementation timing requirements as shown throughout the above table, in order to provide time for NRC inspection of commitment implementation prior to the units entering their respective periods of extended operation.

RS-16-003 Enclosure C Page 6 of 25 NO.      PROGRAM OR                                                                                                     IMPLEMENTATION COMMITMENT                                                                      SOURCE TOPIC                                                                                                         SCHEDULE*
16   Fire Protection         Fire Protection is an existing program that will be enhanced to:                       Program to be enhanced   Section A.2.1.16 no later than six
: 1. Perform periodic visual inspection of combustible liquid spill retaining curbs. months prior to the period of extended
: 2. Perform periodic visual inspection for identification of corrosion that may lead operation.
to loss of material on the external surfaces of the low pressure carbon dioxide fire suppression systems.
: 3. Provide additional inspection guidance to identify aging effects as follows:
: a. Fire barrier walls, ceilings, and floors degradation such as spalling, cracking, and loss of material for concrete.
: b. Elastomeric fire barrier material degradation such as loss of material, shrinkage, separation from walls and components, increased hardness and loss of strength.
: 4. Provide additional inspection guidance to identify degradation of fire barrier penetration seals for aging effects such as loss of material, cracking, increased hardness, shrinkage, and loss of strength.
17   Fire Water System       Fire Water System is an existing program that will be enhanced to:                     Program to be enhanced   Section A.2.1.17 no later than six
: 1. Perform volumetric examinations at five locations on the carbon steel            months prior to the aboveground fire water piping susceptible to microbiologically induced           period of extended       Exelon Letter corrosion (MIC) every year to identify loss of material. Additional locations    operation.               RS-15-171 will be examined if these volumetric examinations or plant operating                                      07/01/2015 experience identify significant degradation. For through-wall leaks and          Inspections described material loss greater than 50 percent of nominal wall, four additional locations in Enhancement 3.d.i will be examined. Where the identified material loss is 30 percent to 50         and 3.d.ii, if required, percent of nominal wall thickness and the calculated remaining life is less      will be completed than two years, two additional locations will be examined.                       either no later than six months prior to the
: 2. Perform visual inspections, for loss of material and flow obstructions, of the   PEO, or before the end accessible header piping and sparger external surfaces for the deluge            of the last refueling systems located within filter plenums on a once per refueling cycle frequency. outage prior to the The visual inspection will include verification that the piping and spargers are PEO, whichever occurs in their proper position and that there are no obstructions to the desired spray later.
* The dates for the start of the respective periods of extended operation for LaSalle County Station, Units 1 and 2 are:
LaSalle County Station, Unit 1: April 17, 2022          LaSalle County Station, Unit 2: December 16, 2023 Exelon Letter RS-16-003 resulted in refining commitment implementation timing requirements as shown throughout the above table, in order to provide time for NRC inspection of commitment implementation prior to the units entering their respective periods of extended operation.

RS-16-003 Enclosure C Page 7 of 25 NO.      PROGRAM OR                                                                                                       IMPLEMENTATION COMMITMENT                                                                       SOURCE TOPIC                                                                                                           SCHEDULE*
patterns.
Additional Inspection
: 3. Perform internal visual inspections of sprinkler and deluge system piping to        schedule information identify internal corrosion and obstructions to flow. If the presence of            identified in commitment.
sufficient foreign organic or inorganic material to obstruct pipe or sprinklers is detected during pipe inspections, the material is removed and its source is determined and corrected where possible. Followup volumetric examinations will be performed if internal visual inspections detect age-related degradation in excess of what would be expected accounting for design, previous inspection experience, and inspection interval.
The internal visual inspections will consist of the following:
: a. Wet pipe sprinkler systems - 50 percent of the wet pipe sprinkler systems in scope for license renewal will have visual internal inspections of piping performed every five years consistent with NFPA 25, 2011 Edition, Section 14.2.
: b. Dry pipe sprinkler systems - Dry pipe sprinkler systems in scope for license renewal will have visual internal inspections of piping performed every five years consistent with NFPA 25, 2011 Edition, Section 14.2.
: c. Deluge systems - Deluge systems in scope for license renewal, except for the charcoal filter deluge systems, will have visual internal inspections of piping performed every five years consistent with NFPA 25, 2011 Edition, Section 14.2.
: i. The in scope charcoal filter deluge systems will have visual internal inspections performed on one of the 11 systems every five years. If degraded conditions are identified, the inspections will be expanded to include all 11 charcoal filter systems every five years.
: d. Sprinkler and deluge systems that are normally dry but may be wetted as the result of testing or actuations will have additional tests and inspections on piping segments that cannot be drained or piping
* The dates for the start of the respective periods of extended operation for LaSalle County Station, Units 1 and 2 are:
LaSalle County Station, Unit 1: April 17, 2022         LaSalle County Station, Unit 2: December 16, 2023 Exelon Letter RS-16-003 resulted in refining commitment implementation timing requirements as shown throughout the above table, in order to provide time for NRC inspection of commitment implementation prior to the units entering their respective periods of extended operation.

RS-16-003 Enclosure C Page 8 of 25 NO.      PROGRAM OR                                                                                                    IMPLEMENTATION COMMITMENT                                                          SOURCE TOPIC                                                                                                       SCHEDULE*
segments that allow water to collect.
: i. These additional inspections, if required, will be performed in each five-year interval beginning five years prior to the period of extended operation.
ii. This additional inspection consists of either a flow test or flush sufficient to detect potential flow blockage or a visual inspection of 100 percent of the internal surface of piping segments that cannot be drained or piping segments that allow water to collect.
iii. In addition, in each five-year interval of the period of extended operation, 20 percent of the length of piping segments that cannot be drained or piping segments that allow water to collect is subject to volumetric wall thickness inspections.
: 4. Perform obstruction evaluations when degraded conditions are identified by visual inspections, flow testing, or volumetric examinations. The obstruction evaluations will include an extent of condition determination, need for increased inspections, and followup examinations if internal visual inspections detect age-related degradation in excess of what would be expected accounting for design, previous inspection experience, and inspection interval.
: 5. Perform flow tests for hose stations at the hydraulically most limiting locations for each zone of the system on a five-year frequency to demonstrate the capability to provide the design pressure at required flow.
: 6. Perform annual air tests on deluge systems supporting charcoal filter units excluding the A and B Auxiliary Electric Equipment Room Supply Air Filter units and the High Radiation Sampling System Filter unit. Perform visual internal inspections of the excluded filter units deluge systems in the event blockage was found on any deluge system that could be generic in nature.
: 7. Perform visual inspections of all charcoal filter unit deluge nozzles for proper
* The dates for the start of the respective periods of extended operation for LaSalle County Station, Units 1 and 2 are:
LaSalle County Station, Unit 1: April 17, 2022         LaSalle County Station, Unit 2: December 16, 2023 Exelon Letter RS-16-003 resulted in refining commitment implementation timing requirements as shown throughout the above table, in order to provide time for NRC inspection of commitment implementation prior to the units entering their respective periods of extended operation.

RS-16-003 Enclosure C Page 9 of 25 NO.      PROGRAM OR                                                                                                 IMPLEMENTATION COMMITMENT                                                          SOURCE TOPIC                                                                                                    SCHEDULE*
orientation and verification that the nozzles are not obstructed on a 24 month frequency.
: 8. Include inspection for water leakage and loss of fluid in the glass bulbs of sprinkler heads, when performing visual inspections of sprinkler systems.
: 9. Include in main drain test acceptance criteria, the monitoring of flowing pressures from test to test. If there is a ten percent reduction in full flow pressure when compared to previously performed tests, an issue report shall be generated in the corrective action program to determine the cause and correct if necessary.
: 10. Maintain yard loop flow testing at a two year frequency until such time that the restricted section of piping from the pump house to Node 515 is restored to normal flow conditions.
* The dates for the start of the respective periods of extended operation for LaSalle County Station, Units 1 and 2 are:
LaSalle County Station, Unit 1: April 17, 2022        LaSalle County Station, Unit 2: December 16, 2023 Exelon Letter RS-16-003 resulted in refining commitment implementation timing requirements as shown throughout the above table, in order to provide time for NRC inspection of commitment implementation prior to the units entering their respective periods of extended operation.

RS-16-003 Enclosure C Page 10 of 25 NO.      PROGRAM OR                                                                                                   IMPLEMENTATION COMMITMENT                                                                      SOURCE TOPIC                                                                                                      SCHEDULE*
18   Aboveground             Aboveground Metallic Tanks is an existing program that will be enhanced to:          Program to be enhanced     Section A.2.1.18 Metallic Tanks                                                                                               no later than six
: 1. Perform a visual inspection of the tank shell, roof, and bottom interior        months prior to the surfaces for signs of loss of material on one of the cycled condensate storage  period of extended tanks within five years prior to the period of extended operation. This         operation.                Exelon Letter inspection shall include both wetted and non-wetted surfaces and may be                                   RS-15-193 either direct visual inspection from inside the tanks or volumetric examination Inspections described     08/06/2015 from outside the tank. A volumetric examination from outside the tank will      in Enhancements 1 and include 25 percent of the tank surface area. Should the one-time inspection     3 will be completed identify degradation, periodic inspections with an inspection frequency based   either no later than six on the rate of degradation will be established for both tanks.                  months prior to the PEO, or before the end
: 2. Perform a visual inspection of the exterior surfaces of both cycled condensate  of the last refueling storage tanks for loss of material each refueling interval.                     outage prior to the PEO, whichever occurs
: 3. Perform a volumetric examination of the tank bottom for both cycled             later.
condensate storage tanks for signs of loss of material whenever the tanks are drained. At a minimum, an inspection shall be performed within 10 years prior to the period of extended operation and subsequent inspections shall be   Additional Inspection performed in each 10-year period during the period of extended operation.       schedule information The next inspection scope will include 100% of the accessible areas of each     identified in commitment.
of the tank bottoms that are within 30 inches of the shell. Included in this scope are the patch plates that are directly exposed to the sand bed below.
Additionally, 10 random locations of approximately one square foot each, outside of the 30 inch band, will be inspected. This inspection program will encompass approximately 20% of the tank bottom and will inspect all the susceptible areas which were found during the baseline inspections. Based on the results of this inspection, the scope will be reassessed for future tank bottom inspections, per the Corrective Action Program.
: 4. Perform an inspection of the caulking at the perimeter of the cycled condensate storage tank bases for signs of degradation each refueling interval (caulking inspections are supplemented with physical manipulation).
19   Fuel Oil Chemistry      Fuel Oil Chemistry is an existing program that will be enhanced to:                  Program to be enhanced    Section A.2.1.19 no later than six
: 1. Perform periodic (quarterly) sampling and analysis for water and sediment       months prior to the content, particulate concentration, and the levels of microbiological organisms period of extended
* The dates for the start of the respective periods of extended operation for LaSalle County Station, Units 1 and 2 are:
LaSalle County Station, Unit 1: April 17, 2022         LaSalle County Station, Unit 2: December 16, 2023 Exelon Letter RS-16-003 resulted in refining commitment implementation timing requirements as shown throughout the above table, in order to provide time for NRC inspection of commitment implementation prior to the units entering their respective periods of extended operation.

RS-16-003 Enclosure C Page 11 of 25 NO.      PROGRAM OR                                                                                                      IMPLEMENTATION COMMITMENT                                                                        SOURCE TOPIC                                                                                                          SCHEDULE*
for diesel fuel storage tanks 0DO01T, 1DO01T, and 2DO01T.                          operation.
: 2. Perform periodic (quarterly) sampling and analysis for water and sediment          Inspections described content, particulate concentration, and the levels of microbiological organisms    in Enhancements 6 and for HPCS diesel fuel storage tanks 1DO02T and 2DO02T.                              7 will be completed either no later than six
: 3. Perform periodic (quarterly) sampling and analysis for water and sediment          months prior to the content and the levels of microbiological organisms for diesel generator day       PEO, or before the end tanks 0DO02T, 1DO05T, and 2DO05T.                                                  of the last refueling outage prior to the PEO, whichever occurs
: 4. Perform periodic (quarterly) sampling and analysis for water and sediment later.
content and the levels of microbiological organisms for HPCS diesel day tanks 1DO04T and 2DO04T.
Additional Inspection schedule information
: 5. Perform periodic (quarterly) sampling and analysis for water and sediment          identified in commitment.
content, particulate concentration, and the levels of microbiological organisms for diesel fire pump day tanks 0FP01TA and 0FP01TB.
: 6. Perform periodic internal inspections of diesel fire pump day tanks 0FP01TA and 0FP01TB at least once during the 10-year period prior to the period of extended operation, and at least once every 10 years during the period of extended operation. Each diesel fuel tank will be drained and cleaned, the internal surfaces visually inspected (if physically possible), and, if evidence of degradation is observed during inspections, or if visual inspection is not possible, these diesel fuel tanks will be volumetrically inspected.
: 7. Perform volumetric inspection of diesel fuel storage tanks 0DO01T, 1DO01T, and 2DO01T; HPCS diesel fuel storage tanks 1DO02T and 2DO02T; diesel generator day tanks 0DO02T, 1DO05T, and 2DO05T; and HPCS diesel day tanks 1DO04T and 2DO04T if evidence of degradation is observed during visual inspection, or if visual inspection is not possible.
: 8. Perform periodic (quarterly) trending of water and sediment content, particulate concentration, and the levels of microbiological organisms for all fuel oil tanks within the scope of the program.
* The dates for the start of the respective periods of extended operation for LaSalle County Station, Units 1 and 2 are:
LaSalle County Station, Unit 1: April 17, 2022         LaSalle County Station, Unit 2: December 16, 2023 Exelon Letter RS-16-003 resulted in refining commitment implementation timing requirements as shown throughout the above table, in order to provide time for NRC inspection of commitment implementation prior to the units entering their respective periods of extended operation.

RS-16-003 Enclosure C Page 12 of 25 NO.      PROGRAM OR                                                                                                  IMPLEMENTATION COMMITMENT                                                                       SOURCE TOPIC                                                                                                      SCHEDULE*
20   Reactor Vessel          Reactor Vessel Surveillance is an existing program that will be enhanced to:        Enhancement 1 to be         Section A.2.1.20 Surveillance                                                                                                implemented no later
: 1. Establish a maximum fluence limit of 6.25E+17 n/cm2 (39.15 EFPY)               than six months prior to    Section A.4.2.5 for monitoring the limiting Unit 1 axial welds to ensure that the axial        the period of extended weld failure probability does not exceed 5.02E-06 per reactor year.            operation.                  Exelon Letter RS-15-223
: 2. Complete a probabilistic axial weld failure analysis for Unit 1 that           Enhancement 2 to be         08/26/2015 demonstrates the 60-year axial weld failure probability is no greater          completed at least three than 5.02E-06 per reactor year. Submit the analysis to the NRC for             years prior to the limiting Exelon Letter review and approval.                                                           Unit 1 axial welds          RS-15-281 reaching the fluence limit  10/29/2015 of 6.25E+17 n/cm2 (39.15 EFPY).
21   One-Time Inspection     One-Time Inspection is a new condition monitoring program that will be used to      Program to be               Section A.2.1.21 verify the system-wide effectiveness of the Water Chemistry (A.2.1.2) program,      implemented no later Fuel Oil Chemistry (A.2.1.19) program, and Lubricating Oil Analysis (A.2.1.26)      than six months prior to program which are designed to prevent or minimize aging to the extent that it will  the period of extended not cause a loss of intended function during the period of extended operation.      operation.
One-time inspections will be performed within the 10 years prior to the period of extended operation, and will be completed either no later than six months prior to the PEO, or before the end of the last refueling outage prior to the PEO, whichever occurs later.
22   Selective Leaching      Selective Leaching is a new condition monitoring program that will include one-time Program to be               Section A.2.1.22 inspections of a representative sample of susceptible components to determine if    implemented no later loss of material due to selective leaching is occurring.                            than six months prior to the period of extended operation.
* The dates for the start of the respective periods of extended operation for LaSalle County Station, Units 1 and 2 are:
LaSalle County Station, Unit 1: April 17, 2022         LaSalle County Station, Unit 2: December 16, 2023 Exelon Letter RS-16-003 resulted in refining commitment implementation timing requirements as shown throughout the above table, in order to provide time for NRC inspection of commitment implementation prior to the units entering their respective periods of extended operation.

RS-16-003 Enclosure C Page 13 of 25 NO.      PROGRAM OR                                                                                               IMPLEMENTATION COMMITMENT                                                                    SOURCE TOPIC                                                                                                  SCHEDULE*
One-time inspections will be performed within the five years prior to the period of extended operation, and will be completed either no later than six months prior to the PEO, or before the end of the last refueling outage prior to the PEO, whichever occurs later.
23   Unit 1 One-time         Unit 1 One-time Inspection of ASME Code Class 1 Small-Bore Piping is a new       Program to be             Section A.2.1.23 Inspection of ASME      condition monitoring program that will manage the aging effect of cracking in    implemented no later Code Class 1            ASME Code Class 1 small-bore piping that is less than nominal pipe size (NPS) 4- than six months prior to  Exelon Letter Small-Bore Piping       inches, and greater than or equal to NPS 1-inch.                                 the period of extended    RS-15-193 operation.                08/06/2015 One-time Inspections will be performed within the six years prior to the period of extended operation, and will be completed either no later than six months prior to the PEO, or before the end of the last refueling outage prior to the PEO, whichever occurs later.
24   External Surfaces       External Surfaces Monitoring of Mechanical Components is a new condition         Program to be             Section A.2.1.24 Monitoring of           monitoring program that directs visual inspections of external surfaces of       implemented no later Mechanical              components be performed during system inspections and walkdowns.                 than six months prior to Components                                                                                               the period of extended operation.
* The dates for the start of the respective periods of extended operation for LaSalle County Station, Units 1 and 2 are:
LaSalle County Station, Unit 1: April 17, 2022        LaSalle County Station, Unit 2: December 16, 2023 Exelon Letter RS-16-003 resulted in refining commitment implementation timing requirements as shown throughout the above table, in order to provide time for NRC inspection of commitment implementation prior to the units entering their respective periods of extended operation.

RS-16-003 Enclosure C Page 14 of 25 NO.      PROGRAM OR                                                                                                     IMPLEMENTATION COMMITMENT                                                                     SOURCE TOPIC                                                                                                         SCHEDULE*
25   Inspection of Internal  Internal Surfaces in Miscellaneous Piping and Ducting Components is new                Program to be            Section A.2.1.25 Surfaces in             condition monitoring program that will consist of inspections of the internal surfaces implemented no later Miscellaneous           of metallic and elastomeric components such as piping, piping components and           than six months prior to Piping and Ducting      piping elements, ducting components, tanks, heat exchanger components,                 the period of extended Components              elastomers, and other components that are exposed to environments of                   operation.
condensation, diesel exhaust, and waste water.
26   Lubricating Oil         Existing program is credited.                                                          Ongoing                  Section A.2.1.26 Analysis 27   Monitoring of           Monitoring of Neutron-Absorbing Materials Other than Boraflex is an existing           Program to be enhanced   Section A.2.1.27 Neutron-Absorbing       program that will be enhanced to:                                                      no later than six Materials Other than                                                                                           months prior to the Boraflex                 1. Maintain the test coupon exposure such that it is bounding for the               period of extended neutron-absorbing material in all spent fuel racks, by relocating the coupon     operation.
tree to a different spent fuel rack cell location each cycle and by surrounding the coupons with a greater number of freshly discharged fuel assemblies than that of any other cell location.
28   Buried and              Buried and Underground Piping is an existing program that will be enhanced to:         Program to be enhanced   Section A.2.1.28 Underground Piping                                                                                             no later than six
: 1. Manage cracking for stainless steel piping, utilizing a method that has been     months prior to the demonstrated to be capable of detecting cracking, whenever coatings are          period of extended removed and expose the base material.                                            operation.
: 2. Ensure all underground carbon steel Essential Cooling Water System and           Enhancement 2 and Nonessential Cooling Water System piping and components within the scope         inspections described of license renewal are coated in accordance with Table 1 of NACE                 in Enhancements 4 and SP0169-2007.                                                                     5 will be completed
: 3. Define acceptable coating conditions as coating exhibiting either no evidence    either no later than six of degradation, or, the type and extent of coating damage evaluated as           months prior to the insignificant by an individual possessing a NACE Coating Inspector Program       PEO, or before the end Level 2 or 3 operator qualification, or by an individual who has attended the    of the last refueling Electric Power Research Institute (EPRI) Comprehensive Coatings Course           outage prior to the and completed the EPRI Buried Pipe Condition Assessment and Repair               PEO, whichever occurs Training Computer Based Training Course.                                         later.
: 4. Perform inspection quantities of buried piping within the scope of license       Additional Inspection renewal in accordance with LR-ISG-2011-03, Element 4.b and Table 4a,             schedule information
* The dates for the start of the respective periods of extended operation for LaSalle County Station, Units 1 and 2 are:
LaSalle County Station, Unit 1: April 17, 2022          LaSalle County Station, Unit 2: December 16, 2023 Exelon Letter RS-16-003 resulted in refining commitment implementation timing requirements as shown throughout the above table, in order to provide time for NRC inspection of commitment implementation prior to the units entering their respective periods of extended operation.

RS-16-003 Enclosure C Page 15 of 25 NO.      PROGRAM OR                                                                                                  IMPLEMENTATION COMMITMENT                                                                   SOURCE TOPIC                                                                                                      SCHEDULE*
during each 10-year period, beginning 10 years prior to the period of          identified in commitment.
extended operation. The number of inspections of buried piping will be based upon the as-found results of cathodic protection system availability and effectiveness.
: 5. Perform direct visual inspections of underground Essential Cooling Water System and Nonessential Cooling Water System piping within the scope of license renewal during each 10-year period, beginning 10 years prior to the period of extended operation.
: 6. Double the inspection sample sizes within the affected piping categories if adverse indications are detected during inspection. If adverse indications are found in the expanded sample, an analysis will be conducted to determine the extent of condition and extent of cause. The size of the followup inspections will be determined based on the analysis. Timing of the additional inspections will be based on the severity of the identified degradation and the consequences of leakage. In all cases, the additional inspections will be performed within the same 10-year inspection interval in which the original adverse indication was identified. Expansion of sample size may be limited by the extent of piping subject to the observed degradation mechanism.
: 7. Use only the -850mV polarized potential criterion specified in NACE SP0169-2007 for acceptance criteria for steel piping and determination of cathodic protection system effectiveness in performing cathodic protection surveys. Alternatively, soil corrosion probes may also be used to demonstrate cathodic protection effectiveness during the annual surveys. An upper limit of -1200mV for pipe-to-soil potential measurements of coated pipes will also be established, so as to preclude potential damage to coatings.
: 8. Conduct an extent of condition evaluation if observed coating damage caused by non-conforming backfill has been evaluated as significant. The extent of condition evaluation will be conducted to ensure that the as-left condition of backfill in the vicinity of the observed damage will not lead to further degradation.
* The dates for the start of the respective periods of extended operation for LaSalle County Station, Units 1 and 2 are:
LaSalle County Station, Unit 1: April 17, 2022        LaSalle County Station, Unit 2: December 16, 2023 Exelon Letter RS-16-003 resulted in refining commitment implementation timing requirements as shown throughout the above table, in order to provide time for NRC inspection of commitment implementation prior to the units entering their respective periods of extended operation.

RS-16-003 Enclosure C Page 16 of 25 NO.      PROGRAM OR                                                                                                    IMPLEMENTATION COMMITMENT                                                                      SOURCE TOPIC                                                                                                        SCHEDULE*
29   ASME Section XI,        ASME Section XI, Subsection IWE is an existing program that will be enhanced to:      Program to be enhanced    Section A.2.1.29 Subsection IWE                                                                                                no later than six
: 1. Provide guidance for proper specification of bolting material, lubricant and     months prior to the sealants, and installation torque or tension to prevent or mitigate degradation  period of extended and failure of structural bolting.                                               operation.
: 2. If leakage from the reactor cavity pool drain line welds exists, then perform    Additional Inspection ultrasonic thickness measurements on the Unit 2 drywell liner at 0 and 180       schedule information degrees for several feet below elevation 813. The inspections will begin in      identified in commitment.
2015 and a periodic inspection frequency will be established based on the inspection results.
30   ASME Section XI,        ASME Section XI, Subsection IWL is an existing program that will be enhanced to:      Program to be enhanced    Section A.2.1.30 Subsection IWL                                                                                                no later than six
: 1. Explicitly require that areas of concrete deterioration and distress be recorded months prior to the in accordance with the guidance provided in ACI 349.3R.                          period of extended operation.
: 2. Include quantitative acceptance criteria, based on the "Evaluation Criteria" provided in Chapter 5 of ACI 349.3R, that will be used to augment the qualitative assessment of the Responsible Engineer.
* The dates for the start of the respective periods of extended operation for LaSalle County Station, Units 1 and 2 are:
LaSalle County Station, Unit 1: April 17, 2022         LaSalle County Station, Unit 2: December 16, 2023 Exelon Letter RS-16-003 resulted in refining commitment implementation timing requirements as shown throughout the above table, in order to provide time for NRC inspection of commitment implementation prior to the units entering their respective periods of extended operation.

RS-16-003 Enclosure C Page 17 of 25 NO.      PROGRAM OR                                                                                                    IMPLEMENTATION COMMITMENT                                                                     SOURCE TOPIC                                                                                                         SCHEDULE*
31   ASME Section XI,        ASME Section XI, Subsection IWF is an existing program that will be enhanced to:       Program to be enhanced Section A.2.1.31 Subsection IWF                                                                                                 no later than six
: 1. Provide guidance for proper specification of bolting material, storage,          months prior to the    Exelon Letter lubricant and sealants, and installation torque or tension to prevent or         period of extended     RS-15-180 mitigate degradation and failure of structural bolting. Requirements for high    operation.             7/15/2015 strength bolts shall include the preventive actions for storage, lubricants, and stress corrosion cracking potential discussed in Section 2 of RCSC (Research Council on Structural Connections) publication Specification for Structural Joints Using ASTM A325 or A490 Bolts. Lubricants that contain molybdenum disulfide (MoS2) shall not be applied to high strength bolts within the scope of license renewal. Bolting material with actual measured yield strength greater than or equal to 150 ksi or 1,034 MPa, in sizes greater than 1 inch nominal diameter shall not be used in supports for ASME Class 1, 2, and 3 piping and components or supports for MC components.
: 2. Provide guidance, regarding the selection of supports to be inspected on subsequent inspections, when a support is repaired in accordance with the corrective action program. The enhanced guidance will ensure that the supports inspected on subsequent inspections are representative of the general population.
32   10 CFR Part 50,         Existing program is credited.                                                          Ongoing                Section A.2.1.32 Appendix J 33   Masonry Walls           Masonry Walls is an existing program that will be enhanced to:                         Program to be enhanced Section A.2.1.33 no later than six
: 1. Provide guidance for inspection of masonry walls for separation and gaps         months prior to the    Exelon Letter between the supports and masonry walls.                                          period of extended     RS-15-180 operation.             7/15/2015
: 2. Require that personnel performing inspections and evaluations meet the qualifications described in ACI 349.3R.
34   Structures              Structures Monitoring is an existing program that will be enhanced to:                 Program to be enhanced Section A.2.1.34 Monitoring                                                                                                     no later than six
: 1. Add the following components and commodities:                                      months prior to the    Exelon Letter period of extended     RS-15-180
: a. Pipe, electrical, and equipment component support members                     operation.             7/15/2015
: b. Pipe whip restraints and jet impingement shields
* The dates for the start of the respective periods of extended operation for LaSalle County Station, Units 1 and 2 are:
LaSalle County Station, Unit 1: April 17, 2022         LaSalle County Station, Unit 2: December 16, 2023 Exelon Letter RS-16-003 resulted in refining commitment implementation timing requirements as shown throughout the above table, in order to provide time for NRC inspection of commitment implementation prior to the units entering their respective periods of extended operation.

RS-16-003 Enclosure C Page 18 of 25 NO.      PROGRAM OR                                                                                                  IMPLEMENTATION COMMITMENT                                                           SOURCE TOPIC                                                                                                     SCHEDULE*
: c. Panels, racks, cabinets, and other enclosures                                             Exelon Letter
: d. Sliding surfaces                                                                          RS-15-238
: e. Sumps                                                                                     09/17/2015
: f. Electrical cable trays and conduits
: g. Electrical duct banks
: h. Tube tracks
: i. Transmission tower (including takeoff towers) and foundation (including cycled condensate storage tank foundations)
: j. Penetration seals and sleeves
: k. Blowout panels
: l. Permanent drywell shielding
: m. Transformer foundation
: n. Bearing pads
: o. Compressible joints
: p. Hatches, plugs, handholes, and manholes
: q. Metal components (decking, vent stack, and miscellaneous steel)
: r. Building features - doors and seals, bird screens, louvers, windows, and siding
: s. Concrete curbs, and anchors
: t. Turbine Building smoke and heat vent housings
: 2. Provide guidance for proper specification of bolting material, lubricant and sealants, and installation torque or tension to prevent or mitigate degradation and failure of structural bolting.
: 3. Revise storage requirements for high strength bolts to include recommendations of Research Council on Structural Connections (RCSC)
Specification for Structural Joints Using High Strength Bolts, Section 2.0.
: 4. Require acceptance and evaluation of structural concrete using quantitative criteria based on Chapter 5 of ACI 349.3R.
: 5. Monitor raw water and ground water chemistry on a frequency not to exceed five years for pH, chlorides, and sulfates and verify that it remains non-aggressive, or evaluate results exceeding criteria to assess impact, if any, on below-grade concrete.
* The dates for the start of the respective periods of extended operation for LaSalle County Station, Units 1 and 2 are:
LaSalle County Station, Unit 1: April 17, 2022         LaSalle County Station, Unit 2: December 16, 2023 Exelon Letter RS-16-003 resulted in refining commitment implementation timing requirements as shown throughout the above table, in order to provide time for NRC inspection of commitment implementation prior to the units entering their respective periods of extended operation.

RS-16-003 Enclosure C Page 19 of 25 NO.      PROGRAM OR                                                                                                    IMPLEMENTATION COMMITMENT                                                                    SOURCE TOPIC                                                                                                        SCHEDULE*
: 6. Monitor concrete for increase in porosity and permeability, inspection of accessible sliding surfaces for indication of significant loss of material due to wear or corrosion, debris, or dirt.
: 7. Evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas, and examine representative samples of the exposed portions of the below grade concrete, when excavated for any reason.
: 8. Require that personnel performing inspections and evaluations meet the qualifications specified within ACI 349.3R with respect to knowledge of inservice inspection of concrete and visual acuity requirements.
: 9. Clarify that loose bolts and nuts and cracked high strength bolts are not acceptable unless accepted by engineering evaluations.
: 10. Inspect the fiberglass outer covering for the permanent drywell shielding for signs of rips and tears. If a rip or tear is found, repair or replace the permanent drywell shielding.
35   RG 1.127,               RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power         Program to be enhanced Section A.2.1.35 Inspection of           Plants is an existing program that will be enhanced to:                                no later than six Water-Control                                                                                                  months prior to the Structures               1. Include monitoring of the following:                                              period of extended Associated with                                                                                                operation.
Nuclear Power                a. Submerged Core Standby Cooling System Pond and Intake Flume Plants                             (includes earthen walls, south flume concrete retaining wall, and north flume sheet piling retaining wall)
: b. Core Standby Cooling System outfall structure
: c. Bar racks and miscellaneous steel
: d. Shad net anchors
: e. Lake Screen House (includes service water tunnel)
: 2. Monitor raw water and ground water chemistry at least once every five years for pH, chlorides, and sulfates and verify that it remains non-aggressive, or evaluate results exceeding criteria to assess impact, if any, on buried or
* The dates for the start of the respective periods of extended operation for LaSalle County Station, Units 1 and 2 are:
LaSalle County Station, Unit 1: April 17, 2022         LaSalle County Station, Unit 2: December 16, 2023 Exelon Letter RS-16-003 resulted in refining commitment implementation timing requirements as shown throughout the above table, in order to provide time for NRC inspection of commitment implementation prior to the units entering their respective periods of extended operation.

RS-16-003 Enclosure C Page 20 of 25 NO.      PROGRAM OR                                                                                                      IMPLEMENTATION COMMITMENT                                                                      SOURCE TOPIC                                                                                                         SCHEDULE*
submerged concrete.
: 3. Provide guidance for proper specification of bolting material, lubricant and sealants, and installation torque or tension to prevent or mitigate degradation and failure of structural bolting, and preventative actions for storage of materials to prevent stress corrosion cracking.
: 4. Require acceptance and evaluation of structural concrete using quantitative criteria based on Chapter 5 of ACI 349.3R.
: 5. Require inspection of accessible in scope portions of the Cooling Lake and Lake Screen House immediately following the occurrence of significant natural phenomena, which includes intense local rainfalls and large floods.
: 6. Require:
: a. The evaluation of the acceptability of inaccessible areas when conditions exist in the accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas.
: b. Examination of the exposed portions of the below grade concrete when excavated for any reason.
36   Protective Coating      Existing program is credited.                                                           Ongoing.                 Section A.2.1.36 Monitoring and Maintenance Program 37   Insulation Material     Insulation Material for Electrical Cables and Connections Not Subject to                Program and initial      Section A.2.1.37 for Electrical Cables   10 CFR 50.49 Environmental Qualification Requirements is a new program that will        inspections to be and Connections         be used to manage reduced insulation resistance of the insulation material for non-     implemented no later Not Subject to          EQ cables and connections. Accessible cables and connections located in                 than six months prior to 10 CFR 50.49            adverse localized environments will be visually inspected at least once every           the period of extended Environmental           10 years for indications of reduced insulation resistance, such as embrittlement,       operation.
Qualification           discoloration, cracking, melting, swelling, or surface contamination.
Requirements                                                                                                    Initial inspections will be completed either no later than six months prior to the PEO, or
* The dates for the start of the respective periods of extended operation for LaSalle County Station, Units 1 and 2 are:
LaSalle County Station, Unit 1: April 17, 2022          LaSalle County Station, Unit 2: December 16, 2023 Exelon Letter RS-16-003 resulted in refining commitment implementation timing requirements as shown throughout the above table, in order to provide time for NRC inspection of commitment implementation prior to the units entering their respective periods of extended operation.

RS-16-003 Enclosure C Page 21 of 25 NO.      PROGRAM OR                                                                                                  IMPLEMENTATION COMMITMENT                                                                   SOURCE TOPIC                                                                                                     SCHEDULE*
before the end of the last refueling outage prior to the PEO, whichever occurs later.
Additional Inspection schedule information identified in commitment.
38   Insulation Material     Insulation Material for Electrical Cables and Connections Not Subject to            Program and initial       Section A.2.1.38 for Electrical Cables   10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation       assessment of calibration and Connections         Circuits is a new program that will be used to manage the effects of reduced        and test results to be Not Subject to          insulation resistance of non-EQ cable and connection insulation of the in scope     implemented no later 10 CFR 50.49            portions of Neutron Monitoring, Process Radiation Monitoring and Area Radiation     than six months prior to Environmental           Monitoring Systems.                                                                 the period of extended Qualification                                                                                               operation.
Requirements Used       Calibration and cable tests will be performed and results will be assessed for in Instrumentation      reduced insulation resistance prior to the period of extended operation. Cable test Initial testing and Circuits                frequency is based on engineering evaluation and is performed at least once every   assessment of results 10 years. Calibration and assessment of results is performed at least once every    will be completed 10 years during the period of extended operation.                                   either no later than six months prior to the PEO, or before the end of the last refueling outage prior to the PEO, whichever occurs later.
Additional Assessment schedule information identified in commitment.
39   Inaccessible Power      Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental                 Program and initial tests Section A.2.1.39 Cables Not Subject      Qualification Requirements is a new program that will be used to manage the         and inspections to be to 10 CFR 50.49         effects of reduced insulation resistance of non-EQ, in scope, inaccessible power    implemented no later Environmental           cables.                                                                             than six months prior to Qualification                                                                                               the period of extended Requirements            Cables will be tested using one or more proven tests for detecting deterioration of operation.
* The dates for the start of the respective periods of extended operation for LaSalle County Station, Units 1 and 2 are:
LaSalle County Station, Unit 1: April 17, 2022         LaSalle County Station, Unit 2: December 16, 2023 Exelon Letter RS-16-003 resulted in refining commitment implementation timing requirements as shown throughout the above table, in order to provide time for NRC inspection of commitment implementation prior to the units entering their respective periods of extended operation.

RS-16-003 Enclosure C Page 22 of 25 NO.      PROGRAM OR                                                                                                     IMPLEMENTATION COMMITMENT                                                                       SOURCE TOPIC                                                                                                         SCHEDULE*
the insulation system. The cables will be tested at least once every six years.
More frequent testing may occur based on test results and operating experience.        Initial tests and Manholes associated with the cables included in this aging management program          inspections will be will be inspected for water collection with subsequent corrective actions (e.g., water completed either no removal), as necessary. Prior to the period of extended operation, the frequency of    later than six months inspections for accumulated water will be established and adjusted based on plant      prior to the PEO, or specific operating experience with cable wetting or submergence, including water       before the end of the accumulation over time and event driven occurrences such as heavy rain or              last refueling outage flooding. Operation of dewatering devices will be verified prior to any known or       prior to the PEO, predicted heavy rain or flooding event. During the period of extended operation,       whichever occurs later.
the inspections will occur at least annually.
Additional Test and Inspection schedule information identified in commitment.
40   Metal Enclosed Bus      Metal Enclosed Bus is an existing program that will be enhanced to:                    Program to be enhanced    Section A.2.1.40 no later than six
: 1. Specify internal inspections will be performed for accessible non-segregated     months prior to the bus duct sections that are in scope for license renewal.                         period of extended operation.
: 2. Clarify requirements for visual inspections of internal portions (bus enclosure assemblies); bus insulation; internal bus insulating supports; accessible        Additional Inspection gaskets, boots and sealants; and bus duct external surfaces.                     schedule information identified in commitment.
: 3. Specify a sample size of 20 percent of the accessible bolted connection population, with a maximum sample size of 25, will be inspected for increased resistance of connection by either thermography or measuring the connection resistance using a micro ohmmeter.
: 4. Specify an inspection frequency of at least every 10 years.
* The dates for the start of the respective periods of extended operation for LaSalle County Station, Units 1 and 2 are:
LaSalle County Station, Unit 1: April 17, 2022         LaSalle County Station, Unit 2: December 16, 2023 Exelon Letter RS-16-003 resulted in refining commitment implementation timing requirements as shown throughout the above table, in order to provide time for NRC inspection of commitment implementation prior to the units entering their respective periods of extended operation.

RS-16-003 Enclosure C Page 23 of 25 NO.      PROGRAM OR                                                                                                   IMPLEMENTATION COMMITMENT                                                                      SOURCE TOPIC                                                                                                      SCHEDULE*
41   Electrical Cable        Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental               Program and one-time       Section A.2.1.41 Connections Not         Qualification Requirements program is a new program that will implement one-time     tests to be implemented Subject to              testing of a representative sample (20 percent with a maximum sample size of 25)     no later than six 10 CFR 50.49            of non-EQ electrical cable connections to ensure that either increased resistance of months prior to the Environmental           connection is not occurring or that the existing preventive maintenance program is   period of extended Qualification           effective such that a periodic inspection program is not required.                   operation.
Requirements One-time tests will be completed either no later than six months prior to the PEO, or before the end of the last refueling outage prior to the PEO, whichever occurs later.
42   Service Level III and   Service Level III and Service Level III Augmented Coatings Monitoring and            Program to be              Section A.2.2.1 Service Level III       Maintenance Program is a new condition monitoring program that performs              implemented no later Augmented               periodic visual inspections to verify the integrity of internal coatings designed to than six months prior to Coatings Monitoring     adhere to and protect the base metal.                                                the period of extended and Maintenance                                                                                              operation.
Program Baseline inspections will occur in the 10-year period prior to the period of extended operation, and will be completed either no later than six months prior to the PEO, or before the end of the last refueling outage prior to the PEO, whichever occurs later.
* The dates for the start of the respective periods of extended operation for LaSalle County Station, Units 1 and 2 are:
LaSalle County Station, Unit 1: April 17, 2022         LaSalle County Station, Unit 2: December 16, 2023 Exelon Letter RS-16-003 resulted in refining commitment implementation timing requirements as shown throughout the above table, in order to provide time for NRC inspection of commitment implementation prior to the units entering their respective periods of extended operation.

RS-16-003 Enclosure C Page 24 of 25 NO.      PROGRAM OR                                                                                                IMPLEMENTATION COMMITMENT                                                                SOURCE TOPIC                                                                                                    SCHEDULE*
43   Fatigue Monitoring      Fatigue Monitoring is an existing program that will be enhanced to:                Program to be enhanced  Section A.3.1.1 no later than six
: 1. Impose administrative transient cycle limits corresponding to the limiting   months prior to the numbers of cycles used in the environmental fatigue calculations.            period of extended operation.
: 2. Evaluate the impact of the reactor coolant environment on Class 1 components including valves and pumps if they are more limiting than those considered in NUREG/CR-6260.                                                 Any additional environmental fatigue evaluations to be performed will be completed no later than six months prior to the period of extended operation.
44   Concrete                Concrete Containment Tendon Prestress is an existing condition monitoring          Program to be enhanced  Section A.3.1.2 Containment             program that will be enhanced to:                                                  no later than six Tendon Prestress                                                                                           months prior to the
: 1. For each surveillance interval, trending lines will be updated through the   period of extended period of extended operation as part of the regression analysis and compared operation.
to the predicted lower limit and minimum required values for each tendon group.
45   Environmental           Existing program is credited.                                                      Ongoing                 Section A.3.1.3 Qualification (EQ) of Electric Components 46   Operating               Existing program is credited.                                                      Ongoing                 Section A.1.6 Experience
* The dates for the start of the respective periods of extended operation for LaSalle County Station, Units 1 and 2 are:
LaSalle County Station, Unit 1: April 17, 2022         LaSalle County Station, Unit 2: December 16, 2023 Exelon Letter RS-16-003 resulted in refining commitment implementation timing requirements as shown throughout the above table, in order to provide time for NRC inspection of commitment implementation prior to the units entering their respective periods of extended operation.

RS-16-003 Enclosure C Page 25 of 25 NO.      PROGRAM OR                                                                                                 IMPLEMENTATION COMMITMENT                                                                  SOURCE TOPIC                                                                                                     SCHEDULE*
47   TLAA - Slip Joint       Prior to exceeding the limiting fluence value of 1.17E+20 n/cm2 at the Unit 1 jet  Procedure tracking the   Section A.4.2.10 Clamp                   pump slip joint clamp location, estimated to be at 50.7 EFPY, revise the analysis  cumulative EFPY for the slip joint clamps for a higher acceptable fluence value or take other      values to be enhanced    Exelon Letter corrective action such as repair or replacement of the clamps to ensure acceptable no later than six        RS-15-232 clamp preload.                                                                     months pPrior to the     09/15/2015 period of extended operation.               Exelon Letter RS-16-003 Additional schedule      01/07/2016 information identified in commitment.
48   Unit 2 Inspection of    Unit 2 Inspection of ASME Code Class 1 Small-Bore Piping Program is a new          Program to be            Section A.2.2.2 ASME Code Class 1       condition monitoring program that will manage the aging effect of cracking in      implemented no later Small-Bore Piping       ASME Code Class 1 small-bore piping that is less than nominal pipe size (NPS) 4-   than six months prior to Exelon Letter Program                 inches, and greater than or equal to NPS 1-inch.                                   the period of extended   RS-15-193 operation.               08/06/2015 The one-time inspections and the first set of periodic inspections will be performed within the six years prior to the period of extended operation, and will be completed either no later than six months prior to the PEO, or before the end of the last refueling outage prior to the PEO, whichever occurs later.
* The dates for the start of the respective periods of extended operation for LaSalle County Station, Units 1 and 2 are:
LaSalle County Station, Unit 1: April 17, 2022          LaSalle County Station, Unit 2: December 16, 2023 Exelon Letter RS-16-003 resulted in refining commitment implementation timing requirements as shown throughout the above table, in order to provide time for NRC inspection of commitment implementation prior to the units entering their respective periods of extended operation.}}