ML13186A179: Difference between revisions

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{{Adams
#REDIRECT [[IR 05000247/2013009]]
| number = ML13186A179
| issue date = 07/05/2013
| title = IR 05000247-13-009; 05/6/2013 to 05/23/2013; Indian Point Nuclear Generating Unit 2; License Renewal Team Inspection
| author name = Trapp J M
| author affiliation = NRC/RGN-I/DRS/EB1
| addressee name = Ventosa J A
| addressee affiliation = Entergy Nuclear Operations, Inc
| docket = 05000247
| license number = DPR-026
| contact person =
| document report number = IR-13-009
| document type = Inspection Report, Letter
| page count = 43
}}
See also: [[followed by::IR 05000247/2013009]]
 
=Text=
{{#Wiki_filter:UNITED STATES                          NUCLEAR REGULATORY COMMISSION                                                            REGION I                            2100 RENAISSANCE BOULEVARD, SUITE 100
                        KING OF PRUSSIA, PENNSYLVANIA 19406-2713
July 5, 2013
Mr. John Ventosa Site Vice President
Entergy Nuclear Operations, Inc.
Indian Point Energy Center
 
450 Broadway, GSB
Buchanan, NY 10511-0249
SUBJECT:  INDIAN POINT NUCLEAR GENERATING UNIT 2 - NRC LICENSE RENEWAL 
  TEAM INSPECTION REPORT 05000247/2013009
 
Dear Mr. Ventosa:
On May 23, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a team
inspection at your Indian Point Nuclear Generating Unit 2.  The enclosed inspection report
documents the inspection results, which were discussed on May 23, 2013 with Mr. Donald
Mayer and other members of your staff.
The inspectors examined activities conducted by your staff to complete commitments Entergy made as part of your application for a renewed facility operating license.  The inspectors also
reviewed selected procedures and records, observed activities, and interviewed personnel. 
 
No findings were identified during this inspection.  The team concluded that Entergy had made sufficient progress to complete our review of 30 commitments during this inspection.  Eleven of
the commitments reviewed during this inspection were determined to merit additional
assessment during our planned follow-up license renewal inspection scheduled for September
2013.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records (PARS) component of  NRC's Agencywide Document Access and Managem
ent System (ADAMS).  ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
      Sincerely,
        /RA/        James M. Trapp, Chief
      Engineering Branch 1
      Division of Reactor Safety
 
Docket No. 50-247 License No.  DPR-26 
 
  ML13186A179
  SUNSI Review
  Non-Sensitive  Sensitive
  Publicly Available  Non-Publicly Available OFFICE RI/DRS RI/DRP RI/DRS  NAME GMeyer/MM SRutenkroger JTrapp  DATE 7/3/13 7/3/13 7/5/13 
J. Ventosa 2
  Enclosure: Inspection Report 05000247/2013009 w/Attachment:  Supplementary Information
 
cc w/encl:  Distribution via ListServ 
J. Ventosa 3
Distribution w/encl: (via E-mail)
W. Dean, RA D. Lew, DRA
 
D. Roberts, DRP
 
A. Burritt, DRP
C. Miller, DRS 
 
J. Rogge, DRS
S. Rutenkroger, DRP
T. Setzer, DRP
S. McCarver, DRP
L. McKown, DRP
S. Stewart, DRP, SRI K. Dunham, DRP, RI
A. Patel, DRP, RI
D. Hochmuth, DRP, AA
V. Campbell, RI OEDO
RidsNrrPMIndianPoint Resource
RidsNrrDorlLpl1-1 Resource
ROPreport Resource
 
   
  i Enclosure U.S. NUCLEAR REGULATORY COMMISSION
REGION I  Docket No.:  50-247
License No.:  DPR-26
 
Report No.:  05000247/2013009
 
Applicant:  Entergy Nuclear Northeast (Entergy)
Facility:  Indian Point Energy Center Unit 2
 
  Location:  450 Broadway 
  Buchanan, NY 10511-0249
 
Dates:  May 6-10 and 20-23, 2013 
 
Inspectors:  G. W. Meyer, Senior Reactor Inspector, Team Leader
  E. H. Gray, Senior Reactor Inspector
  W. C. Holston, Senior Mechanical Engineer    M. C. Modes, Senior Reactor Inspector    J. E. Richmond, Senior Reactor Inspector
  M. P. Patel, Operations Engineer
  S. K. Chaudhary, Reactor Inspector
  E. M. Keighley, Project Engineer
  C. H. Ng, Mechanical Engineer
 
Approved By:  James M. Trapp, Chief
  Engineering Branch 1
  Division of Reactor Safety 
  ii  Enclosure              SUMMARY OF FINDINGS
IR 05000247/2013009; 05/6/2013 - 05/23/2013; Indian Point Nuclear Generating Unit 2; License
Renewal Team Inspection.
 
This report covers an announced two week inspec
tion, using the guidance provided in NRC inspection procedure Temporary Instruction 2516/001, "Review of License Renewal Activities,"
of activities conducted by Entergy to complete commitments made to the NRC as a part of the Indian Point Energy Center, Unit 2, application for a renewed operating license.  The commitments reviewed during this inspection are recorded in Supplement 1 to NUREG-1930,
"Safety Evaluation Report Related to the License Renewal of Indian Point Generating Units
Numbers 2 and 3," Attachment 1, dated August 2011, and in other related correspondence. 
The inspection also reviewed enhancements made to selected aging programs. 
Cornerstones:  Initiating Events, Mitigating Systems, and Barrier Integrity
No findings were identified.  On a sampling basis, the team concluded that Entergy had made
sufficient progress to complete our review of 30 commitments during this inspection.  Eleven of the commitments reviewed during this inspection were determined to merit additional assessment during our planned follow-up license renewal inspection scheduled for September
2013. 
Enclosure REPORT DETAILS
4. OTHER ACTIVITIES
  4OA5 Review of License Renewal Activities (TI 2516/001)
.1 Background
  The expiration date of the operating license for Indian Point Unit 2 is midnight on September 28, 2013.  Indian Point Unit 2 meets the criteria in Title 10 of the
Code of Federal Regulations (10 CFR) 2.109(b), "Effect of timely renewal application," and will likely operate beyond the current operating license expiration date.  Due to the
Commission's decision to revise the Waste Confidence Decision and Rule and because of the ongoing Atomic Safety and Licensing Board hearings, the Commission is not expected to issue a renewed license for Indian Point Unit 2 before the expiration date of
the original license.  Therefore, Indian Point is expected to continue operations under the
timely renewal provisions of 10 CFR 2.109(b).
  On May 1, 2013, Entergy sent a letter to the Nuclear Regulatory Commission (NRC) (ML13142A203) describing two actions Entergy plans to complete prior to entering the
period of extended operation (PEO).  The first action is that Entergy will submit a letter to
the NRC confirming implementation of the Unit 2 license renewal commitments.  The
second Entergy action is to submit a letter to the NRC confirming that the Unit 2 Updated
Final Safety Analysis Report has been updated to include the Unit 2 aging management
programs making them part of the licensing basis by September 28, 2013.
The team used NRC Inspection Manual Temporary Instruction 2516/001 to conduct this inspection.  The Temporary Instruction was written specifically for plants like Indian Point
Unit 2, where the holders of an operating license meet the criteria of 10 CFR 2.109, for timely renewal, but a final decision by the NRC on the license renewal application is not expected prior to the period of extended operation.  The inspection objectives and
requirements of the Temporary Instruction are to report the status of license renewal
commitment implementation, the status of aging management program implementation, and to verify the description of programs and activities for managing the effects of aging
are consistent with the Updated Final Safety Analysis Report. 
  The NRC planned to conduct this two week announced team inspection to assess the resolution of commitments made by the applicant as part of the license renewal process. 
Additionally, the NRC had planned to conduct an additional limited scope one week
inspection in September to address issues meriting additional follow-up based on the results of this inspection and to review any new issues or commitments. 
On a sampling basis, the team concluded that Entergy had made sufficient progress to
complete our review of 30 commitments during this inspection.  Eleven of the
commitments reviewed during this inspection were determined to merit additional
assessment during our planned follow-up inspection scheduled for September 2013.   
2  Enclosure The NRC review of four commitments (28, 29, 34 and 36) is documented in NRC Inspection Report 05000247/2012008 (ML12110A315).  Three commitments (11, 32, and 39), listed in the Safety Evaluation Report, were determined not to be applicable to
Unit 2 and were not reviewed during this inspection.
 
Sample Selection Process
  Temporary Instruction 2516/001 requires that the inspectors select a sample of completed commitments, license conditions, and aging management programs for
review during the inspection.  The reviewed commitments and enhanced aging
management programs were selected based on
several attributes including:  risk significance; the results of previous license renewal audits and inspections of aging management programs; the complexity in implementing a commitment; and the extent to which the baseline inspection programs will inspect attributes of the commitment or
 
aging management program. 
The commitments reviewed during this inspection are recorded in Supplement 1 to NUREG-1930, "Safety Evaluation Report Related to the License Renewal of Indian Point Generating Units Numbers 2 and 3," Attachment 1, dated August 2011, Entergy letter to
 
the NRC (NL-12-174), dated November 29, 2012 (ML12341A180) and in other related
correspondence.  For each commitment selected for review, the inspectors reviewed
supporting documents including completed surveillances, conducted interviews,
performed visual inspection of structures and components, and observed selected activities described below to verify the licensee completed the necessary actions to comply with the commitments.
The inspectors selectively verified the licensee implemented the aging management
programs, included in the staff's license renewal safety evaluation report, in accordance with 10 CFR Part 54, "Requirements for the Renewal of Operating Licenses for Nuclear Power Plants."  The inspectors verified a selected sample of licensee corrective actions
that were the result of license renewal activities.   
The following commitments and enhanced programs were reviewed:
.2 Commitment Reviews
 
.2.1 Commitment 1:  Enhance the Aboveground Steel Tanks Program to perform thickness measurements of the bottom surfaces of the condensate storage tanks, city water tank,
and fire water tanks once during the first 10 years of the period of extended operation.  Enhance the Aboveground Steel Tanks Program for Indian Point Unit 2 (IP2) and Indian Point Unit 3 (IP3) to require trending of thickness measurements when material loss is
detected.
 
a. Inspection Scope
  The inspectors observed the external conditions of each of the aboveground tanks in the license renewal scope during a plant walk down.  Entergy had scheduled procedures
and activities to measure the tank bottom thickness and trend thickness changes 
3  Enclosure indicative of degradation.  The inspectors reviewed the planned, periodic visual examinations under EN-DC-178, System Walkdowns, and 2-PI-SA002, Atmospheric Tanks, External Inspection, for the aboveground water storage tanks.  The inspectors
noted that documentation of the condition of coating integrity of external storage tank
walls was specified in EN-DC- 178, but was not addressed in 2-PI-SA002.  Condition
Report (CR) CR-IP2-2013-01989 was issued to update procedure 2-PI-SA002 regarding
the condition of coatings.
Findings and Observations
  No findings were identified. 
 
.2.2 Commitment 2:  Enhance the Bolting Integrity Program to clarify that actual yield strength is used in selecting materials for low susceptibility to stress crack corrosion
(SCC) and clarify the prohibition on use of lubricants containing MoS2 for bolting.  The
Bolting Integrity Program manages loss of preload and loss of material for all external
bolting.  a. Inspection Scope
 
In NRC Inspection Report 05000247/2012008, the inspectors reviewed the
implementation of the Bolting Integrity Program, but noted that a general statement on
loss of preload and loss of material for external bolting in the commitment had not been included in the site procedure.  The inspectors reviewed the Entergy corporate procedure for torqueing applications that had superseded the site procedure previously
reviewed.  The corporate procedure included statements which addressed the general
statement on external bolting.
 
Findings and Observations
 
No findings were identified. 
 
.2.3 Commitment 3:  Implement the Buried Piping and Tanks Inspection Program as described in License Renewal Application (LRA) Section B.1.6.  Risk assess buried in-scope pipe segments and tanks based on the impact of leakage and conditions affecting the risk for corrosion; classify the pipe segments and tanks as having a high, medium, or
low impact of leakage; establish inspection priority and frequency based on the results of
the risk assessment; and perform inspections using inspection techniques with
demonstrated effectiveness.
a. Inspection Scope
 
The inspectors conducted a walk down of an excavation which exposed three in-scope
segments of buried piping.  Piping coatings were generally in good condition.  The
inspectors confirmed that the corporate procedures included criteria for assessing buried in-scope piping segments and tanks based on the impact of leakage and conditions
affecting risk for corrosion.  The inspectors also confirmed that the site procedure, SEP-UIP-IPEC, Underground Components Inspection Plan, Appendix A, Piping 
4  Enclosure Inspection Information, and Appendix B, Tank Inspection Information, contained a listing of in-scope piping segments and tanks, each classified as high, medium, or low based on the impact of leakage.  Further, the inspectors reviewed 20 inspection reports, which
Entergy had stated would be completed prior to the period of extended operation.  The
inspection technique was excavated direct visual examinations with subsequent
ultrasonic thickness measurements w
here coating degradation was noted.  The inspections consisted of an acceptable mix of opportunistic and planned inspections with the majority conducted on piping segments classified as high risk.  All of the inspections provided valued insights into the condition of coatings and backfill quality.  Ultrasonic
thickness measurements in locations of coating degradation demonstrated that minimal
or no corrosion of the base metal had occurred. 
 
Findings and Observations
 
No findings were identified. 
.2.4 Commitment 4:  Enhance the Diesel Fuel Monitoring Program to include cleaning and inspection of additional fuel oil tanks, include quarterly sampling and analysis of additional tanks, include periodic thickness measurements with acceptance criteria of
the bottom surfaces of in-scope fuel oil tanks, change the analysis for water and
particulates to a quarterly frequency for some tanks, and address water removal and
biocide treatment. 
a. Inspection Scope
 
The inspectors reviewed the commitment implementation plan, and program and
implementing procedures, and discussed this commitment with applicable plant staff. 
The Diesel Fuel Monitoring Program is an existing program that was enhanced to meet the commitments.  The inspectors reviewed revised diesel fuel handling procedures, diesel fuel sampling procedures, and chemical addition procedures.  Also, the inspectors
reviewed inspection records for the No. 2 fuel oil storage tank, and work orders for
cleaning and inspecting additional tanks.
 
Findings and Observations
  No findings were identified. 
 
.2.5 Commitment 5:  Enhance the External Surfaces Monitoring Program to include periodic inspections of systems in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4(a)(1) and (a)(3).  Inspections shall include areas surrounding the subject systems to identify hazards to those systems.  Inspections
of nearby systems that could impact the subject systems will include structure, systems, and components (SSC) that are in scope and subject to aging management review for
license renewal in accordance with 10 CFR 54.4(a)(2).
   
5  Enclosure a. Inspection Scope
  The inspectors reviewed the commitment implementation plan and program procedures,
and discussed this commitment with applicable plant staff and license renewal
personnel.  The inspector noted that EN-DC-178, System Walkdowns, Revision 5
addressed the enhanced inspection scope during walkdowns to include attention
 
extended to nearby systems that could present a hazard or affect the walked down system.  The inspectors reviewed the site Engineering Standard ENN-MS-S-004-IPEC, which documented the system categories and their corresponding level of inspection,
including direction to accomplish the enhanced scope of system walkdown and the
surrounding areas.  The inspectors noted that the city water tank category classification
in Attachment 7.1 of ENN-MS-S-004-IPEC was not consistent between Unit 2 and Unit 3.  Entergy issued Condition Report CR-IP2-2013-01756 to correct this and improved the classification in Revision 2 of ENN-MS-S-004-IPEC.     
Findings and Observations
  No findings were identified. 
.2.6 Commitment 6:  Enhance the Fatigue Monitoring Program to monitor steady state cycles and feedwater cycles or perform an evaluation to determine monitoring is not required. 
Review the number of allowed events and resolve discrepancies between reference
documents and monitoring procedures.
a. Inspection Scope
 
The inspectors reviewed the commitment implementation plan and discussed this
commitment with applicable plant staff and license renewal personnel.  The inspectors noted that Entergy had awarded contracts to perform the calculations that will determine whether monitoring of steady state cycles and feedwater cycles is required.  Entergy
expected that the calculations would be completed prior to the period of extended
operation.  The inspectors also noted that Entergy planned to revise procedure
2-PT-2Y015, Thermal Cycle Monitoring Program, if the calculations demonstrate that a
change in the number of allowable steady state cycles and feedwater cycles is identified.
Findings and Observations
 
No findings were identified; however, the inspectors determined that additional
inspection was merited, including review of the results of the calculations and any changes to the Thermal Cycle Monitoring Program procedure.
.2.7 Commitment 7:  Enhance the Fire Protection Program to explicitly state that the diesel fire pump engine sub-systems (including the fuel supply line) shall be observed while the
pump is running.  Acceptance criteria will be revised to verify that the diesel engine does
not exhibit signs of degradation while running; such as fuel oil, lube oil, coolant, or exhaust gas leakage.  Enhance the Fire Protection Program to specify that the diesel fire pump engine carbon steel exhaust components are inspected for evidence of corrosion and cracking at least once each operating cycle. 
6  Enclosure a. Inspection Scope
  The inspectors reviewed the diesel fire pump testing and maintenance procedures to
verify that the surveillance and maintenance procedures had been revised to include the
enhanced visual inspections, and had appropriate acceptance criteria for those
inspections.  The inspectors walked down the diesel fire pump to independently assess
material conditions of the fire pump and diesel engine, and the feasibility of the revised procedures.
Findings and Observations
 
No findings were identified. 
.2.8 Commitment 8:  Enhance the Fire Water Program to include inspection of hose reels for evidence of corrosion, replace all or test a sample of sprinkler heads, to perform wall
thickness evaluations of fire protection piping, and inspect the internal surfaces of
foam-based fire suppression tanks. 
a. Inspection Scope
  The inspectors reviewed the fire hose reel inspection procedures to verify that the
procedures had been revised to include the enhanced visual inspections, and had
appropriate acceptance criteria for those inspections.  The inspectors walked down a sample of hose reels in safety-related areas to evaluate the material condition of the hose reels.
 
The inspectors reviewed work orders to replace all of the fire water system sprinkler
heads required for 10 CFR 50.48 prior to 50 years in service.  The inspectors walked down a sample of sprinkler heads in safety-related areas to independently assess the material condition of the sprinkler heads.
 
The inspectors reviewed IP-RPT-12-LRD02, Fire Water Piping Wall Thickness
Evaluation, the ultrasonic test (UT) examination data records, and the associated
structural assessments of minimum wall thickness and corrosion rate determinations.  The inspectors compared the UT data results to the established minimum wall thickness criteria for the selected piping locations to verify adequate pressure boundary and
structural integrity of the fire water piping system.  The inspectors also evaluated
Entergy's determination that all UT test locations would be greater than the minimum
required wall thickness values at the end of the period of extended operation, based upon worst case test results and conservative estimates of corrosion rates.
In addition, the inspectors evaluated the locations Entergy selected for UT examination
of fire water piping to verify the locations were sufficiently diverse and represented an
adequate sample population to ensure the test results were indicative of the piping
system as a whole.  The inspectors walked down all UT test locations and other portions of the fire water system to independently assess the material condition of the fire water piping.
 
7  Enclosure The inspectors reviewed work orders to visually inspect the internal surfaces of foam based fire suppression tanks for signs of significant corrosion.  The inspectors walked down the four foam tanks to independently assess the material condition of the tanks.  In
addition, the inspectors reviewed the visual inspection results for opportunistic internal
inspections of two of the four tanks which had been performed in 2001 and 2008.
Findings and Observations
  No findings were identified. 
 
.2.9 Commitment 9:  Enhance the Flux Thimble Tube Inspection Program to implement comparisons to wear rates identified in WCAP-12866, perform evaluations regarding changes to test frequency and scope, specify the acceptance criteria as outlined in WCAP-12866 or other plant-specific values based on evaluation of previous test results,
and perform corrective actions based on tubes that exceed or are projected to exceed
the acceptance criteria.
a. Inspection Scope
  The inspectors reviewed the commitment implementation plan, revised inspection
procedures, and discussed this commitment with applicable plant staff and license
renewal personnel.  An inspection procedure had been developed using the inspection
results and methodology provided in WCAP-12866 and included wear rate comparisons, appropriate acceptance criteria, and corrective actions for exceeding the acceptance criteria.  The inspectors reviewed the eddy current test (ECT) reports for the flux thimble
tube inspections conducted at Unit 2 in March 2012 and completed at Unit 3 during the
2009 and 2011 outages.  The ECT reports indicated insignificant flux thimble tube
degradation.  The ECT reinspections were planned in 8 years and had been included in the plant scheduling process.
Findings and Observations
 
No findings were identified. 
 
.2.10 Commitment 10
:  Enhance the Heat Exchanger Monitoring Program to include 22 specific heat exchangers within the program scope and provide program inspections, including non-destructive inspection methods, considerations for sampling, and
acceptance criteria.
a. Inspection Scope
  The inspectors reviewed corporate and site procedures, heat exchanger program
database, and work order planning documents that addressed inspection, sampling, and
acceptance criteria.  The inspectors verified that the additional heat exchangers had
been added to the program and the inspection methods, sampling and acceptance criteria were reasonable and in accordance with the commitment.
   
8  Enclosure Findings and Observations
  No findings were identified.   
 
.2.11 Commitment 12:  Enhance the Masonry Wall Program to specify that the IP1 intake structure is included in the program.
a. Inspection Scope
  The inspectors reviewed the commitment implementation plan and revised procedures,
and discussed this commitment with applicable plant staff and license renewal
personnel.  The inspectors verified that Entergy had revised EN-DC-150, Structural Monitoring Program, Attachment 9.15, in Revision 4 to explicitly include the masonry walls/structures in the intake structure of Unit 1. 
 
Findings and Observations
  No findings were identified.   
.2.12 Commitment 13:  Enhance the Metal-Enclosed Bus (MEB) Inspection Program to add a 480V bus, visually inspect the external surface of MEB enclosure assemblies, include
acceptance criteria, inspect bolted connections, and remove reference to "re-torquing"
connections from the applicable site procedure.
a. Inspection Scope
  The inspectors reviewed the licensee implementation plan and the associated completed
work orders.  The inspectors discussed this commitment with applicable plant staff and license renewal personnel.  The inspectors reviewed the procedures associated with the MEB Inspection Program to manage the aging effects on electrical bus and bus
connections, bus enclosure assemblies, and the bus insulation and insulators with
non-segregated phase bus.  The inspectors reviewed procedures to verify that the bus
enclosure assemblies are inspected for cracks, corrosion, foreign debris, excessive dust
buildup, and evidence of water intrusion.  The inspectors reviewed drawings, reviewed completed work orders, and performed walkdown inspections to evaluate the capability of the program to manage aging effects. 
 
The inspectors identified that Entergy had not included all accessible portions of the
MEB within the scope of the maintenance inspection program, in that the sections of the emergency diesel generator (EDG) 480 volt MEB in the electrical tunnel had not been visually inspected and was not included in the scope of the maintenance procedure
which performed the MEB inspections and tests.  The inspectors noted that quantitative
measures, such as insulation resistance and connection resistance tests, had been
performed for the associated bus duct sections.  Entergy initiated CR-IP2-2013-01786 to
revise site procedures and conduct visual inspections of those additional sections of the bus ducts prior to the PEO. 
 
9  Enclosure Findings and Observations
  No findings were identified; however, the inspectors determined that additional
inspection was merited regarding the revised visual inspection procedures and results of
the inspection.
.2.13 Commitment 14:  Implement the Non Environmentally Qualified (EQ) Bolted Cable Connections Program as described in LRA Section B.1.22.
a. Inspection Scope
  The inspectors reviewed the commitment implementation plan and the associated completed work orders.  The Non-EQ Bolted Cable Connections Program is a new program credited with managing the aging effects in bolted cable connections by a one-time inspection of a representative sample of in-scope connections.  The inspectors
reviewed the results of the sample of in-scope connections along with visual inspection
and testing methods to assess the program and its capability to manage aging effects.  The inspectors noted that there was no evidence of visual degradation, loosening, discoloration, cracking or corrosion for any of the connections in the sample population
and all as-found connection resistance values were within the acceptance criteria.  The
results indicated that there was no loosening of bolted electrical cable connections due
 
to thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, or oxidation.  Inspectors noted that thermography was
performed periodically through the preventive and predictive maintenance programs.  Though loosening of bolted connection was not ex
pected, this practice along with the condition reporting system was expected to identify any adverse trends that could
 
develop.
Findings and Observations
 
No findings were identified. 
 
.2.14 Commitment 15
:  Implement Non-EQ Inaccessible Medium-Voltage Cable Program as described in LRA Section B.1.23.  This new program will be implemented consistent with the corresponding program described in NUREG-1801, Section XI.E3, Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification
Requirements.
 
a. Inspection Scope
  The inspectors reviewed the commitment implementation plan, program procedures, and
cable testing procedures.  The inspectors reviewed the test results associated with
in-scope medium-voltage cables and low-voltage power cables to provide an indication
of the condition of the conductor insulation, and associated corrective action documents. 
The inspectors also sampled twelve completed work orders from the inspection program that includes inspections for water accumulation in manholes at least once every year. 
 
10  Enclosure Findings and Observations
  No findings were identified. 
.2.15 Commitment 16:  Implement the Non-EQ Instrumentation Circuits Test Review Program as described in LRA Section B.1.24.  This new program will be implemented consistent
with the corresponding program described in NUREG-1801, Section XI.E2, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.
 
a. Inspection Scope
  The inspectors reviewed the test results of neutron flux monitoring instrumentation cables, interviewed plant personnel, and reviewed program documentation to assess the
capability of the program to manage aging effects.  The inspectors noted that the initial
reviews of calibration test results for high range-radiation monitoring cables were not yet
performed.  However, the reviews were ongoing and were planned to be completed prior the period of extended operation.  The inspectors reviewed the preventive maintenance task performing the periodic review of the cable system testing and the calibration
surveillance results of neutron flux and radiation monitoring cables.  The inspectors also
reviewed the test methodology and procedures to determine appropriate acceptance
criteria were included. 
 
Findings and Observations
 
No findings were identified. 
 
.2.16 Commitment 17:  Implement the Non-EQ Insulated Cables and Connections Program as described in LRA Section B.1.25.  This new program will be implemented consistent with the corresponding program described in NUREG-1801, Section XI.E1, Electrical Cables and Connections not Subject to 10 CFR 50.49 Environmental Qualification
Requirements.
 
a. Inspection Scope
  The program manages the aging effects of cables and connections exposed to adverse
localized environments by visually inspecting accessible insulated cables and connections.  The inspectors reviewed Entergy's inspection results, documented in
IP-RPT-10-LRD15, Cable and Connection Inspection Summary Report, a representative sample of walkdown data sheets (e.g., field observation notes), and selected CRs which had been initiated as a result of the walkdowns to evaluate and correct potential
deficiencies.  In addition, the inspectors walked down cables and connections in the
electrical cable tunnel to independently assess the material conditions and to validate
Entergy's observations.
 
Findings and Observations
 
No findings were identified.   
11  Enclosure .2.17 Commitment 18:  Enhance the Oil Analysis Program to include the IP2 SBO/Appendix R, diesel generator, generator seal oil and turbine hydraulic control oil, formalize preliminary oil screening for water and particulates and laboratory analyses, and
formalize trending of preliminary oil screening results.
 
  a. Inspection Scope
  The inspectors reviewed Entergy's corporate and Indian Point site specific procedures for the oil analysis program.  The oil analysis program is an existing program that
maintains oil systems free of contaminants to preserve an environment that is not
conducive to loss of material, cracking, or fouling.  As part of the license renewal
application this process was formalized through the new procedures and a trending program, which was planned to be fully implemented by the period of extended operation.  Also, the inspectors reviewed
the corrective action documents from the past 5 years associated with oil analysis sampling. 
 
The inspectors noted that SEP-LUB-IPC-002, IPEC Oil Analysis Program, Revision 0 addressed the equipment included in the preliminary oil screening for water and particulates, but was not clear regarding the boiler feed pump being scoped into the
program.  Based on this observation, Entergy revised the procedure to address the
inspectors' concern.  The inspectors reviewed Revision 1 of the procedure which
included clear, specific guidance, and resolved the concern.
 
Findings and Observations
 
No findings were identified. 
 
.2.18 Commitment 19:  Implement the One-Time Inspection Program as described in LRA Section B.1.27.  This new program will be implemented consistent with the corresponding program described in NUREG-1801, Section XIM32, One-Time
Inspection.
 
a. Inspection Scope
  The inspectors reviewed Entergy's corporate procedure for one-time inspections and discussed this commitment with applicable plant staff and license renewal personnel.
The intent of the One-Time Inspection Program is to confirm that other existing aging
management programs have been effective.
The program also performs one-time inspections of other specific components.  The inspectors reviewed the Entergy letter submitting Amendment 13 to the LRA, which revised the sampling plan to the sampling specified in NUREG 1801, Generic Aging Lessons Learned (GALL), Revision 2, and the
inspection tracking matrix, which implemented the revised sampling plan.  The
inspectors noted that the program involved over 400 inspections, approximately 300 inspections to cover the existing aging management programs for water chemistry,
fuel oil, and lubrication oil, and an additional 120 inspections on components specified in the LRA.  Entergy had completed slightly over half of the planned inspections.  The inspectors selected 20 inspections and reviewed the inspection records. 
 
12  Enclosure Findings and Observations
  No findings were identified; however, t
he inspectors determined that additional NRC inspection was merited to review the inspections remaining; any further actions needed,
and program conclusions.
.2.19 Commitment 20
:  Enhance the One Time Inspection Program - Small Bore Piping Program as described in LRA Section B.1.28.  This new program will be implemented consistent with the corresponding program described in NUREG-1801, Section XI.M35, One-Time Inspection of American Society of Mechanical Engineers (ASME) Code
 
Class I Small Bore Piping.
a. Inspection Scope
 
The program includes butt-welded piping less than 4-inch nominal pipe size that are
susceptible to cracking.  Samples are selected based on susceptibility to thermal
stratification or turbulent penetration as provided in Electric Power Research Institute (EPRI) Report 1000701, "Interim Thermal Fatigue Management Guideline (MRP-24)," January 2001.  The program is intended to determine if the aging effect of
stress induced corrosion cracking is occurring in small bore piping when the license
renewal applicant has not found this aging affect in larger diameter piping.
 
Entergy had previously implemented a risk-informed inservice inspection program that included 195 risk-significant small bore butt welds in addition to the larger diameter butt welds chosen in the context of ASME Section XI.  In order to strictly meet the
commitment requirement to implement a program consistent with NUREG-1801,
Section XI.M35, One-Time Inspection of ASME Code Class 1 Small Bore Piping,
Entergy selected six small bore butt welds, or approximately 3 percent, from the risk-significant population of 195 which conformed with the guidance in EPRI Report 1000701, Interim Thermal Fatigue Management Guideline (MRP-24).
 
Findings and Observations
 
No findings were identified. 
.2.20 Commitment 21:  Enhance the Periodic Surveillance and Preventive Maintenance Program as necessary to assure that the effects of aging will be managed such that
applicable components will continue to perform their intended functions consistent with
the current licensing basis through the period of extended operation.
a. Inspection Scope
 
The inspectors reviewed the commitment implementation plan, work orders, and
program procedures, and discussed this commitment with applicable plant staff.  The
program involves repetitive tasks and routine monitoring of plant operations through visual and other non-destructive examination (NDE) inspection techniques.  The inspectors reviewed sampled work orders for preventive maintenance work performed
on five systems. 
13  Enclosure Findings and Observations
  No findings were identified. 
 
.2.21 Commitment 22:  Enhance the Reactor Vessel Surveillance Program revising the specimen capsule withdrawal schedules to draw and test a standby capsule to cover the
peak reactor vessel fluence expected through the end of the period of extended operation.  Enhance the Reactor Vessel Surveillance Program to require that tested and untested specimens from all capsules pulled from the reactor vessel are maintained in
storage. 
a. Inspection Scope
  Entergy determined the peak reactor vessel fluence expected through the end of the
period of extended operation.  The inspectors reviewed the revised pressure-thermal
curves generated to account for the peak reactor vessel fluence.  The inspectors
reviewed the supporting analysis reported in Westinghouse WCAP-16752-NP, Revision 0, Indian Point Heatup and Cooldown Limit Curves for Normal Operation, January 2008.  The inspectors noted the reactor vessel beltline materials included by
Entergy in the original application did not include all the components meeting the
threshold of greater than 1x10
17 n/cm2.  This was corrected in subsequent correspondence with the NRC.  Entergy took action to document the specific
components included in the beltline analysis.  Entergy had issued LO-LAR-2011-0174 CA 15 to identify capsule withdrawal schedules, and require tested and untested specimens from all capsules pulled from the reactor vessel are maintained in storage.
 
Findings and Observations
  No findings were identified. 
.2.22 Commitment 23:  Implement the Selective Leachi
ng Program as described in LRA Section B.1.33.  This new program will be implemented consistent with the
 
corresponding program described in NUREG-1801, Section XIM33 Selective Leaching of Materials.
a. Inspection Scope
 
The inspectors reviewed the commitment implementation plan and Entergy corporate
procedure for selective leaching inspections, and discussed this commitment with license renewal personnel.  The program is intended to confirm whether selective leaching, the removal of constituents from susceptible materials, is occurring.  The
inspectors reviewed Entergy's letter submitting Amendment 13 to the LRA, which
revised the sampling plan to the sampling specified in GALL, Revision 2, and the
inspection tracking matrix, which implemented the revised sampling plan.  The
inspectors noted that the program involved over 60 inspections, which Entergy was in progress of completing.  The inspectors observed the in-plant inspections and material conditions associated with fire protection valves 698 and 699.  The inspectors selected 
14  Enclosure 10 inspections of copper alloy materials and 12 inspections of gray cast iron materials, and reviewed the inspection records. 
Findings and Observations
 
No findings were identified; however, t
he inspectors determined that additional NRC inspection was merited to review the inspections remaining, any further actions needed, and program conclusions.
.2.23 Commitment 24:  Enhance the Steam Generator Integrity Program to require that the results of the condition monitoring assessment are compared to the operational
assessment performed for the prior operating cycle with differences evaluated.
a. Inspection Scope
 
The inspectors reviewed the commitment implementation plan and program procedures,
and discussed this commitment with applicable plant staff.  The inspectors noted that the IP2 Steam Generator Program, SEP-SG-IP2/3-001, Revision 0, in paragraph 5.3, provided for a comparison of the current condition monitoring assessment to the
operational assessment performed for the prior operating cycle with an evaluation of the
differences.  The inspectors reviewed Entergy's corporate procedure EN-DC-317, Steam
Generator Program, Revision 7, noting its inclusion of the appropriate Nuclear Energy
Institute (NEI), EPRI, ASME and NRC references.
  Findings and Observations
 
No findings were identified. 
 
.2.24 Commitment 25:  Enhance the Structural Monitoring Program by including additional structures, inspection of structural commodities and anchors, inspection of inaccessible
concrete areas, inspection of elastomers, engineering evaluation of groundwater
chemistry including tritium, inspection of submerged concrete and components of intake
structure, increased inspection frequency of degraded areas of water control structures,
and more detailed acceptance criteria.
a. Inspection Scope
  The inspectors reviewed the commitment implementation plan and revised procedures,
and discussed this commitment with applicable plant staff and license renewal personnel.  The inspectors reviewed the IPEC-specific attachments to the corporate procedure EN-DC-150, Structural Monitoring Program, documenting the enhancements. 
The inspectors verified that Entergy had revised applicable corporate and plant
procedures to include the additional structures, commodities, materials, and components
within the Structural Monitoring Program.  Additionally, the procedure had increased the
frequency of inspection of degraded areas of submerged concrete structures to every
3 years.   
15  Enclosure Findings and Observations
  No findings were identified. 
 
.2.25 Commitment 26:  Implement the Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) Program as described in LRA Section B.1.37.  This new program
will be implemented consistent with the corresponding program described in NUREG 1801, Section XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel Program.
 
a. Inspection Scope
  The Thermal Aging Embrittlement of the CASS Program is a new program that manages the aging effects of loss of fracture toughness due to thermal aging of cast austenitic
stainless steel components for the reactor coolant system (excluding the reactor vessel
internals).  Prior to the period of extended operation the program will screen all cast
austenitic stainless steel components to determine which are potentially susceptible to a loss of fracture toughness.  These components will be further evaluated, using a refined analytical technique, to determine the components susceptibility to reduction in fracture
toughness.  Entergy maintains the option of performing a volumetric examination that
conforms to ASME Section XI, Appendix VIII, Supplement 10.  This supplement has
been in the course of preparation since Appendix VIII was first added to Section XI
because extensive research has not resulted in a meaningful volumetric examination technique to date.  The inspectors verified that Entergy was gathering information about component temperature and loads in order to determine the component susceptibility.
 
In the LRA Entergy stated that this new program will be implemented consistent with the
corresponding program described in NUREG-1801, Section XI.M12, Thermal Aging Embrittlement of CASS Program.  Entergy has chosen to perform a unique fracture mechanics analysis of these components, which was in progress.  The inspector noted
that there may be a question regarding the submittal of the analysis under ASME
requirements, as stipulated in 10 CFR 50.55a.
Findings and Observations
  No findings were identified; however, the inspectors determined that additional
inspection was merited regarding the analysis results and the compliance approach
implemented.
 
.2.26 Commitment 27:  Implement the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program as described in LRA Section B.1.38. 
This new program will be implemented consistent with the corresponding program described in NUREG-1801, Section XI.M13, Thermal Aging and Neutron Embrittlement
of Cast Austenitic Stainless Steel program.
 
16  Enclosure a. Inspection Scope
  The inspectors reviewed the plans for implementation of this commitment.  The
programs supporting the identified actions were in the early stage of implementation. 
For example, the screening criteria of EPRI Technical Report 1013234, Materials
Reliability Program: Screening Categorization, and Ranking of Reactor Internals
Components for Westinghouse and Combustion Engineering PWR Design, (MRP-191), listed in Table 3-5, were applied to the Indian Point components listed in Table 5-1 of EPRI Report 1022863, Materials Reliability Program:  Pressurized Water Reactor
Internals Inspection and Evaluation Guidelines (MRP-227-A).  However, a site document had yet to be developed that defined and implemented this program.
 
Findings and Observations
 
No findings were identified; however, the inspectors determined that additional
inspection was merited regarding analysis conclusions and program direction.
 
.2.27 Commitment 30:  For aging management of the reactor vessel internals, IPEC will (1) participate in the industry programs for investigating and managing aging effect on
reactor internals, (2) evaluate and implement the results of the industry programs as
applicable to the reactor internals; and (3) upon completion of these programs, but less
than 24 months before entering the period of extended operation, submit an inspection
plan for reactor internals to the NRC for review and approval.
a. Inspection Scope
 
The inspectors reviewed Amendment 9 to the license renewal application, transmitted by Entergy letter NL-10-063 on July 14, 2010, which modified the application to include an aging management program for reactor vessels internals based on industry group generated guidance.  This amendment included an aging management review of the
reactor vessel internals within the scope of the renewal rule.  The aging management
program was included in the reactor vessel internals program already being
implemented at Indian Point Unit 2.
 
Findings and Observations
 
No findings were identified. 
 
.2.28 Commitment 31:  Additional P-T Curves will be submitted as required per 10 CFR Part 50, Appendix G, prior to the period of extended operation as part of the Reactor Vessel Surveillance Program.
a. Inspection Scope
 
Entergy submitted changes to the Indian Point 2 Technical Specifications proposing changes to the IP2 vessel heat-up and cool-down curves (P-T Curves) and low temperature over pressure requirements in letter NL-13-001, dated February 6, 2013.
 
17  Enclosure Findings and Observations
  No findings were identified. 
 
.2.29 Commitment 33:  For the locations identified in LRA Table 4.3-13 (IP2), update the fatigue usage calculations using refined fatigue analyses to determine if Cumulative
Usage Factors (CUF) remain less than 1.0 when accounting for the effects of reactor water environment, using valid Fen factors.
a. Inspection Scope
 
The inspectors reviewed the calculations and discussed this commitment with applicable plant staff.  The inspectors noted that the implementation schedule for completing the calculations was September 28, 2011.  By letter dated August 9, 2010, Entergy issued
 
Letter NL-10-082 (ML102300504) informing the NRC staff that the calculations had been
completed.  These calculations are documented as WCAP 17149-P, Evaluation of
Pressurizer Insurge/Outsurge Transients for Indian Point Unit 2, and WCAP 17199-P, Environmental Fatigue Evaluation for Indian Point Unit 2.  The inspectors reviewed these calculations and noted that both concluded that cumulative fatigue usage factors
including reactor water environment effects were below the ASME Code allowable value
of 1.0 for transients postulated for 60 years of operation.  The inspectors noted that
Entergy's action plan included revising the Thermal Cycle Monitoring Program procedure
to reflect changes in the number of projected cycles used in WCAP 17199-P.
Findings and Observations
 
No findings were identified; however, the inspectors determined that additional
inspection was merited regarding any changes to the Thermal Cycle Monitoring Program procedure warranted to ensure that it appropriately reflects the input values used by WCAP 17199-P.
 
.2.30 Commitment 35:  Perform a one-time inspection of representative sample area of IP2 containment liner affected by the 1973 event behind the insulation, prior to entering the
period of extended period of operation, to assure liner degradation is not occurring in this area.  Any degradation will be evaluated for updating of the containment liner analyses as needed.
a. Inspection Scope
  The inspectors reviewed the Unit 2 one time inspection report, including visual and ultrasonic examinations, which was completed on March 22, 2012 (Work Order
00282078-01).  These examinations were at the 68 foot elevation location between
columns 10 and 9.  The report showed that there had not been liner degradation.
 
Findings and Observations
  No findings were identified. 
 
18  Enclosure .2.31 Commitment 37:  Enhance the Containment Inservice Inspection (CIIIWL) Program to include inspections of the containment using enhanced characterization of degradation (i.e., quantifying the dimensions of noted indications through the use of optical aids)
during the period of extended operation.  The enhancement includes obtaining critical
dimensional data of degradation where possible through direct measurement or the use of scaling technologies for photographs, and the use of consistent vantage points for
visual inspections.
    a. Inspection Scope
  The inspectors reviewed the commitment implementation plan and discussed this
commitment with applicable plant staff and license renewal personnel.  Reactor containment is a seismic Class I, reinforced structure, with a welded steel liner attached to the inside surface of the concrete shell.  For IP2 the steel liner is covered by polyvinyl
chloride insulation in a stainless steel jacket.  The liner is anchored to the concrete shell
by stud anchors.  In accordance with applicable guidance in ASTM C33-90, Figure 1,
IP2 is located in a severe weathering region and the containment concrete exterior surface should be monitored for degradation based on freeze-thaw aging.  Entergy inspections have reported spalling on the containment vertical exterior wall; Entergy
attributes this degradation to Cadweld concrete coverage and not to freeze-thaw aging. 
This spalling was the subject of an Open Item (3.0.3.3.2-1) in Safety Evaluation Report
NUREG 1930, Volume 2, "Safety Evaluation Report Related to the License Renewal of
Indian Point Nuclear Generating Station Unit Nos. 2 and 3" (ADAMS ML093170671).  The staff position in the Safety Evaluation is that ASME IWL inspections performed in 2005 and 2009 using enhanced visual aids showed little additional degradation since the
original detection of spalling in 2000.  Because Entergy demonstrated the concrete is
above the 3000 psi design minimum, and Entergy is committed to implementing
ASME IWL for the duration of the extended period of operation, the staff concluded the spalling is not the consequence of freeze-thaw and if it were to occur it would be captured under the provisions of an inspection program in compliance with ASME IWL.
By letter dated August 14, 2008, Entergy added Commitment 37 to enhance the
Containment Inservice Inspection Program to include inspection using enhanced
characterization of degradation during the period of extended operation.  The enhancement includes obtaining critical dimensional data of degradation where possible through direct measurement or the use of scaling technologies for photography. 
 
To verify that enhancements had been incorporated in the structural monitoring program,
the inspectors reviewed revised program procedure EN-DC-1 that included obtaining critical dimensional data of degradation where possible through direct measurement of the use of scaling technologies for photography. 
 
The inspectors determined that the concrete inspection of structural members was
covered by the comprehensive structural monitoring program.  Also, other documents,
(i.e. the IWL ISI inspection packages for inspection years 2005 and 2009) were reviewed and compared to verify inclusion of enhanced examination requirements.
 
19  Enclosure Additionally, inspectors performed a walk-through inspection of accessible and exposed outer surfaces of the containment structure to assess the surface condition and any evidence of concrete distress or deterioration, such as defoliation, spalling, structurally
significant cracks, and any indication of chemical reaction or attack (e.g., alkali-silica
 
reaction). 
 
The inspectors noted that the acceptance criteria for visual indications of concrete were included in the procedure only by reference to the American Concrete Institute (ACI) standard.  This approach could introduce error and uncertainty into the inspection
process compared to acceptance criteria being readily available in the procedure. 
Entergy issued CR-IP2-2013-02005 to enhance the procedure.
 
Findings and Observations
 
No findings were identified. 
.2.32 Commitment 38:  For Reactor Vessel Fluence, should future core loading patterns, invalidate the basis for the projected values of RTpts or CvUSE, updated calculations will be provided to the NRC.
a. Inspection Scope
 
Entergy has calculated the charpy upper-shelf energy (CvUSE) threshold of
1 x 10 17 n/cm2 will be exceeded for a number of reactor vessel components at IP2.  The inspectors reviewed a list of these components in Table 4 in Attachment 1 to Entergy
letter NL-08-143, dated September 24, 2008.  As stated in the LRA, Section 4.2.1, the
48 effective full power year, end-of-life, peak fluence for IP2 was calculated to be
 
1.906 x 10
19 n/cm2.  As a consequence of this analysis Entergy has implemented flux reduction measures.  In corrective action LO-LAR-2011-0174 CA 29, Entergy initiated development of a site specific program document to maintain the flux mitigation program during the extended period of operation.
 
Findings and Observations
  No findings were identified. 
.2.33 Commitment 40:  Evaluate plant specific and appropriate industry operating experience and incorporate lessons learned in establishing appropriate monitoring and inspection
frequencies to assess aging effects for the new aging management programs.  Documentation of the operating experi
ence evaluated for each new program will be available on site for NRC review prior to the period of extended operation.
 
a. Inspection Scope
 
Entergy stated that the evaluations to implement this commitment would be performed following the implementation of the new programs.  As such there was insufficient
material to review during the inspection.
 
20  Enclosure Findings and Observations
  No findings were identified; however, the inspectors determined that additional
inspection was merited regarding review of the evaluations.
 
.2.34 Commitment 41:  IPEC will inspect steam generators for both units to assess the condition of the divider plate assembly.  The examination technique used will be capable of detecting primary water stress crack corrosion (PWSCC) in the steam generator divider plate assembly.  The IP2 steam generator divider plate inspections will be
completed within the first ten years of the period of extended operation.  The IP3 steam
generator divider plate inspections will be completed within the first refueling outage
(RFO) following the beginning of the period of extended operation.
a. Inspection Scope
 
The inspectors reviewed the commitment implementation plan and discussed this
commitment with informed plant staff.  Entergy personnel stated that preparations for these steam generator inspections are in-progress (the earliest inspection would occur in 2016).  As evidence of preparations for this inspection, Entergy provided an EPRI
report on divider plate cracking presented in June 5-7, 2012, and EPRI Technical Report
3002000411, dated April 2013 on the Flaw Tolerance Evaluation of the Steam Generator
Channel Head, which related to the inspections.
 
Findings and Observations
 
No findings were identified. 
 
.2.35 Commitment 42:  IPEC will develop a plan for each unit to address the potential for cracking of the primary to secondary pressure boundary due to PWSCC of tube-to-tubesheet welds using one of two options, analysis or inspection.
a. Inspection Scope
 
The inspectors reviewed the commitment implementation plan and discussed this commitment with applicable plant staff.  While a final inspection plan had not been established, the preparations were underway.  The inspectors reviewed
CR-IP2-2013-01440, Revision 2, which described the ongoing work.  The inspectors
noted the commitment schedule for the plan on Unit 3 would be sooner (prior to the end
of the first refueling outage after December 12, 2015) than the plan on Unit 2 (prior to March 2024).  This schedule was based on the replacement of Unit 2 steam generators in 2000 while the Unit 3 steam generators were replaced in 1989, with steam generator
service years of about 13 and 24 years, respectively, for each unit.
 
Findings and Observations
  No findings were identified.
 
21  Enclosure .2.36 Commitment 43:  IPEC will review design basis ASME Code Class 1 fatigue evaluations to determine whether the NUREG/CR-6260 locations that have been evaluated for the effects of the reactor coolant environment on fatigue usage are the limiting locations for
the IP2 and IP3 configurations.  If more limiting locations are identified, the most limiting
location will be evaluated for the effects of the reactor coolant environment on fatigue
usage.  IPEC will use the NUREG/CR-6909 met
hodology in the evaluation of the limiting locations consisting of nickel alloy, if any.
a. Inspection Scope
 
The inspectors noted that Entergy has awarded contracts to perform the calculations
that will support closure of this commitment.  The inspectors also noted that Entergy and its vendor have completed initial screening calculations to determine the locations that may require further analysis. 
 
   
Findings and Observations
  No findings were identified; however, the inspectors determined that additional inspection was merited regarding review of the results of the calculations and any
changes to the Thermal Cycle Monitoring Program procedure.
 
.2.37 Commitment 44:  Entergy will include written explanation and justification of any user intervention in future evaluations using the WESTEMSŽ Design CUF module.
.2.38 Commitment 45:  Entergy will not use the ASME Code Section III, NB-3600 option of the WESTEMSŽ program in future design calculations until the issues identified during the NRC review of the program have been resolved.
 
a. Inspection Scope
 
The inspectors noted that Entergy has revised procedure 2-PT-2Y015, Thermal Cycle
Monitoring Program, to incorporate the two restrictions described in Commitments 44 and 45.  The inspectors also noted that this procedure would be referenced whenever
fatigue calculations would be developed or modified.  The inspectors further noted that if an engineer were to inadvertently not use 2-PT-2Y015, procedures EN-LI-100, Process Applicability Determination, and EN-AD-101, Procedure Process, the procedures which
control changes, tests and experiments, and procedure changes include a required
review of all NRC commitments.  These two procedures (i.e., EN-LI-100, EN-AD-101)
would act as a backup to the thermal cycling monitoring procedure.
Findings and Observations
 
No findings were identified. 
 
.2.39 Commitment 46:  Include in the IP2 ISI Program that IPEC will perform 25 volumetric weld inspections of socket welds during each 10 year interval scheduled as specified by IWB-2412 of the ASME Section XI Code during the period of extended operation.  In lieu 
22  Enclosure of volumetric examinations, destructive examinations may be performed, where one destructive examination may be substituted for two volumetric examinations. a. Inspection Scope
 
The inspectors reviewed SEP-ISI-IP2-001, Revision 1, IP2 Fourth Ten-Year Interval
Inservice Inspection (ISI)/ Containment Inservice Inspection (CII) Program Plan, dated
June 20, 2012, Section 2.1.27 Examination Category R-A, Risk Informed Piping Welds, wherein Entergy states:  "Per ASME B&PV Code Case N-578-1, the only examination that is required on a socket weld is a VT-2 visual examination each refueling outage. 
However per License Renewal Commitment #46 (LO-LAR-2011-0174 CA 65), twenty-
five volumetric weld metal inspections of socket welds should be performed periodically
during each 10 year ISI interval scheduled as specified by IWB-2412 of the ASME Section XI Code during the period of extended operation.  In lieu of volumetric examinations, destructive examinations may be performed, where one destructive
examination may be substituted for two volumetric examinations."
 
The IP2 Inservice Inspection Program was revised to include the provision to perform 25 volumetric weld inspections of socket welds during each 10 year interval scheduled as specified by IWB-2412 of the ASME Section XI Code during the period of extended
operation.  The IP2 Inservice Inspection Program was revised to include the option of
substituting one destructive examination for two volumetric examinations.
 
Findings and Observations
  No findings were identified. 
 
.2.40 Commitment 47:  IPEC will perform and submit analyses that demonstrate that the lower support column bodies will maintain their functionality during the period of extended operation considering the possible loss of fracture toughness due to thermal irradiation embrittlement.  The analyses will be consistent with the IP2/IP3 licensing basis.
a. Inspection Scope
 
The inspectors reviewed the plans for implementation of these commitments.  The programs supporting the identified actions were in the early stage of implementation and awaiting analysis results.  For example the screening criteria of Electric Power Research
Institute Technical Report 1013234, Materials Reliability Program:  Screening
Categorization, and Ranking of Reactor Internals Components for Westinghouse and
Combustion Engineering PWR Design, (MRP-191), listed in Table 3-5, were applied to the Indian Point components listed in Table 5-1 of Electric Power Research Institute Report 1022863, Materials Reliability Program: Pressurized Water Reactor Internals
Inspection and Evaluation Guidelines (MRP-227-A).  A site document had not been
developed that defined and implemented this program.  In Entergy letter NL-13-052,
dated May 7, 2013, Entergy requested an extension in the scheduled completion date
for this commitment until March 1, 2015. 
23  Enclosure Findings and Observations
  No findings were identified; however, the inspectors determined that additional
inspection was merited regarding the results of the ongoing analysis and implementation
 
of the program, pending NRC action on the schedule extension.
 
.2.41 Commitment 48:  Entergy will visually inspect in-scope underground piping prior to the period of extended operation and then on a frequency of at least once every 2 years during the period of extended operation.  Visual inspections will be supplemented with
surface or volumetric non-destructive testing if indications of significant loss of material
are observed.  Adverse indications will be entered into the plant corrective action
program for evaluation of extent of condition and for determination of appropriate corrective actions (e.g., increased inspection frequency, repair, replacement).
a. Inspection Scope
 
The inspectors reviewed preventive maintenance requests for inspection of three in-scope underground piping locations.  These preventive maintenance requests specified a 2 year interval and stated that visual inspections will be supplemented with surface or
volumetric non-destructive testing if indications of significant loss of material are
observed.  The requests also designate the activities as a commitment for license
renewal.  The inspectors noted that if adverse conditions are detected, the corrective
action program is expected to direct the appropriate extent of condition review and corrective actions.  The inspectors also noted that work orders have been issued to perform the inspections to be conducted prior to the period of extended operation. 
 
Findings and Observations
  No findings were identified.  The inspectors determined that additional inspection was merited regarding review of the results of the underground piping inspections.
 
Program Review
 
Boric Acid Corrosion Control, Existing Aging Management Program (AMP)
  a. Inspection Scope
 
The Boric Acid Corrosion Prevention Program is an existing program that relies on
implementation of recommendations of NRC Generic Letter 88-05 to monitor the condition of components on which borated reactor water may leak.  The program detects boric acid leakage by periodic visual inspection of systems containing borated water for
deposits of boric acid crystals and the presence of moisture; and by inspection of
adjacent structures, components, and supports for evidence of leakage.  During plant
operation accessible portions of the plant are monitored for boric acid leakage and
during plant refuel outages the inspections for boric acid leakage are extended to areas of the plant usually inaccessible during plant operation.  The program includes provisions for evaluation when leakage is discovered by other activities.  Program improvements have been made as suggested in NRC Regulatory Issue 
24  Enclosure Summary 2003-013.  The Boric Acid Corrosion Prevention Program was enhanced to include recommendations of the Westinghouse Owner's Group WCAP-15988-NP "Generic Guidance to Best Practice 88-05 Boric Acid Inspection Program," EPRI
Technical Report 1000975 "Boric Acid Corrosion Guidebook," and NRC Bulletin 2003-02
"Leakage from Reactor Coolant Pressure Vessel Lower Head Penetrations and Reactor
Coolant Pressure Boundary Integrity."  The Boric Acid Corrosion Prevention Program is
consistent with the program described in NUREG-1801, Section XI.M10, Boric Acid
Corrosion. 
Findings and Observations
 
No findings were identified. 
Time Limited Aging Analysis Review
  a. Inspection Scope
  Time-limited aging analyses (TLAA) are plant-specific safety analyses that are based on
an explicitly assumed 40-year plant life as defined in 10 CFR 54.3.  Time-limited aging analyses are dispositioned in pursuant to 10 CFR 54.21(c)(1).  Entergy must
demonstrate that either: (1) the TLAAs will remain valid for the period of extended
operation, as required by 10 CFR 54.21(c)(1)(i); or (2) the TLAAs have been projected to
the end of the period of extended operation, as required by 10 CFR 54.21(c)(1)(ii); or (3) that the effects of aging on intended functions will be adequately managed for the period of extended operation, as required by 10 CFR 54.21(c)(1)(iii).  The inspectors
identified one neutron fluence TLAA as well as evaluations associated with
environmentally-assisted fatigue that Entergy had dispositioned in accordance with
10 CFR 54.21(c)(1)(iii) and had associated with license renewal commitments.
The inspectors determined that Entergy had committed (Commitment 38) to update the
neutron fluence TLAA calculations should there be changes in the fuel loadings that are
not bounded by current analytical assumptions.  The inspectors' evaluation of the status
of Commitment 38 is documented above.
 
The inspectors determined that Entergy had made four commitments related to the evaluations of environmentally-assisted fatigue.  Entergy committed (Commitment 33) to
 
update the fatigue usage calculations for those locations identified in NUREG/CR-6260 using refined fatigue analyses to determine valid cumulative usage factors (CUF) less
than 1.0 when accounting for the effects of reactor water environment.  Entergy also committed (Commitment 43) to review design basis ASME Code Class 1 fatigue evaluations to determine whether the NUREG/CR-6260 locations that have been
evaluated for the effects of the reactor coolant environment on fatigue usage are the
limiting locations for the IP2 and IP3 configurations.  Entergy committed (Commitment
44) to include written explanation and justification of any user intervention in future
evaluations using the WESTEMS "Design
CUF" module.  Entergy also committed (Commitment 45) that it will not use the NB-3600 option of the WESTEMS program in future design calculations until the issues identified during the NRC review of the 
25  Enclosure program have been resolved.  The inspectors' evaluations of the status of Commitments 33, 43, 44, and 45 are documented above.
Findings and Observations
 
No findings were identified. 
4OA6 Meetings, Including Exit
  On May 23, 2013, the inspectors presented the inspection results to Mr. Donald Mayer,
acting Site Vice President, and other members of the Entergy staff.  The inspectors
verified that no proprietary information was retained by the inspectors or documented in this report.  The exit meeting was attended by James Trapp, Chief, Engineering
Branch 1.
 
  ATTACHMENT:  SUPPLEMENTARY INFORMATION
 
A-1  Attachment SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
  Entergy Personnel
 
J. Ventosa, Site Vice President N. Azevedo, Code Programs Supervisor C. Caputo, License Renewal Team
T. Chan, Mechanical Systems Supervisor
P. Conroy, Nuclear Safety Assurance Director
 
J. Curry, License Renewal Project Manager
G. Dahl, Licensing Engineer
R. Dolanksy, ISI Program Manager
R. Drake, Civil Design Engineering Supervisor
J. Flagg, Selective Leaching Inspector
P. Guglielmino, Implementation Team Manager S. Manzione, Components Engineering Supervisor D. Mayer, Unit 1 Director
T. McCaffrey, Design Engineering Manager
T. Orlando, License Renewal Team
 
D. Pennino, Senior Program Engineer
 
J. Quirk, Selective Leaching Coordinator M. Tesoriero, Programs and Components Manager M. Troy, Plant Programs Supervisor
R. Walpole, Licensing Manager
M. Woodby, Engineering Director
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
  Open 
The inspectors determined that the following 11 commitments merited further inspection:
 
  6 Fatigue cycles analysis 13 Metal enclosed bus inspection
19 One-time inspection
23  Selective leaching inspection
26 Embrittlement of CASS analysis 27 Embrittlement of CASS analysis 33 Fatigue monitoring 
40 Operating experience for new programs
43 Fatigue monitoring analysis
47 Reactor vessel lower support analysis
48 Underground piping inspection
   
A-2  Attachment
Closed  The remaining 30 commitments reviewed were being or had been appropriately implemented.
 
  LIST OF ACRONYMS
 
ACI American Concrete Institute ADAMS Agencywide Documents Access Management System AMP Aging Management Program
ASME American Society of Mechanical Engineers
BACC Boric Acid Corrosion Control CAP Corrective Action Program CASS Cast Austenitic Stainless Steel
CFR Code of Federal Regulations
CIIIWL Containment Isolation Inspection
CR Condition Report
CRDM Control Rod Drive Mechanism EC Engineering Change
ECT Eddy Current Examination
EDG Emergency Diesel Generator
ENTERGY Entergy Nuclear Northeast
EPRI Electric Power Research Institute EQ Environmentally Qualified FSAR Final Safety Analysis Report
GALL Generic Aging Lessons Learned
IMC Inspection Manual Chapter
IP Inspection Procedure IPEC Indian Point Energy Center IR Inspection Report
ISI Inservice Inspection
LER Licensee Event Report
LRA License Renewal Application
MEB Metal-Enclosed Bus NCV Non-Cited Violation NDE Nondestructive Examination
NEI Nuclear Energy Institute
NRC Nuclear Regulatory Commission
PEO Period of Extended Operation PM Preventive Maintenance PWSCC Primary Water Stress Crack Corrosion
RCS Reactor Coolant System
RFO Refueling Outage
 
 
A-3  Attachment SCC Stress Crack Corrosion SG Steam Generator SSC Structure, System, and Component
TLAA Time-Limited Aging Analyses
UFSAR Updated Final Safety Evaluation Report
UT Ultrasonic Test
VT Visual Examination WO Work Order
  LIST OF DOCUMENTS REVIEWED
 
Commitment 1
 
LO-LAR-2011-0174 CA 43
CR IP2-2013-01989 
327152-Revision 2, Building and Structures Identification Plan
A216386-Revision 2, Fire Water Storage Tank AA-88, Revision 0, City Water Storage Tank, Graver
EN-DC-178, Revision 5, System Walkdowns
2-PI-SA002, Revision 7 Atmospheric Tanks, External Inspection
 
Commitment 2
  IP-RPT-11-LRD03, Review of the Bolting Integrity AMP for License Renewal Implementation,
Revision 0
EN-MA-145, Revision 0, Maintenance Standard for Torquing Applications
LO-LAR-2011-00174, CA-68
Commitment 3
 
EN-DC-343, Underground Piping and Tanks Inspection and Monitoring Program, Revision 8 SEP-UIP-IPEC, Underground Components Inspection Plan, Revision 1
CEP-UPT-0100, Underground Piping and Tanks Inspection and Monitoring, Revision 2 Buried Piping and Tanks General Visual Inspection Report, 11/12/2008, Condensate Storage  Tank to Auxiliary Feedwater Pump Suction Line 1505 and Condensate Storage Tank
Recirculation Line 1509 - Upper and Lower Excavations
CR-IP2-2008-04754, Coating Degradation Condensate Storage Tank Lines
Buried Piping and Tanks General Visual Inspection Report, 4/21/2009, Condensate Storage  Tank Recirculation Line 1509 -Outside of Auxiliary Feedwater Pump Room Buried Piping and Tanks General Visual Inspection Report, 11/28/2011, Circulating Water
Line - 26 Circulating Water Pump Discharge to 23 Main Condenser
Buried Piping and Tanks General Visual Inspection Report, 10/21/2009, City Water Line
Inspections - 16-Inch line from City Water Storage Tank
CR-IP2-2013-00131, Coating Degradation City Water Line from City Water Storage Tank Buried Piping and Tanks General Visual Inspection Report, 9/14/12, City Water Line 1502 to  Auxiliary Feedwater Pumps 
A-4  Attachment Buried Piping and Tanks General Visual Inspection Report, 12/13/12, City Water Line 1502 to  Auxiliary Feedwater Pumps Buried Piping and Tanks General Visual Inspection Report, 9/14/12, 8-Inch High Pressure Fire
Protection Line in 22 Moat Area at Electrical Tunnel Penetration and in 22 Moat Area at
North Wall
CR-IP2-2013-05324, Coating Degradation 8-Inch High Pressure Fire Protection Line in 22 Moat
Area at North Wall Buried Piping and Tanks General Visual Inspection Report, 12/13/12, 6-Inch High Pressure Fire  Protection Line to Hydrant 26
Buried Piping and Tanks General Visual Inspection Report, 8/29/12, 8-Inch Service Water Line
463 SE Return Line from the EDGs in 22 Moat Area at North Wall
CR-IP2-2013-05324, Coating Degradation Service Water Line 463 SE Return Line from the  EDGs in 22 Moat Area at North Wall Buried Piping and Tanks General Visual Inspection Report, 11/22/11, 24-Inch Main Service
Water Line 408 and Line 409 at Existing Access Port on West Side of Turbine Building
CR-IP2-2012-06248, Coating Degradation 24-Inch Main Service Water Line 408 at Existing
Access Port on West Side of Turbine Building - Intradose of Elbow on Line 408 Buried Piping and Tanks General Visual Inspection Report, 12/13/12, 24-Inch Main Service  Water Line 405 Return to Discharge Canal at 22 Moat Area and Line 408 and Line 409
Supply Header at 22 Moat Area
CR-IP2-2013-00131, Coating Degradation 24-Inch Main Service Water Line 405 Return to
Discharge Canal at 22 Moat Area, Line 408 Supply Header at 22 Moat Area, and 
1.5-Inch Weld Channel Piping to Penetration Buried Piping and Tanks General Visual Inspection Report, 12/13/12, 1.5-Inch Weld Channel  Piping to Penetration
Buried Piping and Tanks General Visual Inspection Report, 10/10/12, 8-Inch HP Fire Protection
Line and 8-Inch City Water Line 1502 in the IP2 Transformer Yard
 
  Commitment 4
 
LO-LAR-2011-00174
 
A.2.1.8 Diesel Fuel Monitoring Program
 
B.1.9 Diesel Fuel Monitoring Program 3-SOP-EL-009, Filling the Diesel Fuel Oil Storage Tanks, Revision 22 0-CY-1500, Chemistry Sampling Locations, Revision 23
0-CY-1560, Sampling and Adding Chemicals to Diesel Fuel Oil Storage Tanks, Revision 5
0-CY-1810, Diesel Fuel Oil Monitoring, Revision 14
0-CY-1810, Diesel Fuel Oil Monitoring, Revision 15 0-CY-3318, Water and Sediment in Fuel Oil, Revision 4 3-CY-2615, Adding Chemicals to Auxiliary Systems, Revision 1
0-GNR-402-ELC, Emergency Diesel Generator Main Fuel Oil Tank 10-Year 
Maintenance, Revision 3 2-SOP-29.20, Fuel Oil Transfer Using the Trailer, Revision 8
IP-RPT-11-LRD10, Review of the Diesel Fuel Monitoring Aging Management Program  For License Renewal Implementation, Revision 0 Report on the 2012 Inspection of the Entergy Nuclear Operations Indian Point Station 
No. 2 Fuel Oil Storage Tank GT2/3 FOT, November 27, 2012 
A-5  Attachment
00347381, Fuel Oil Storage Tank Bottom Thickness UT 00349623, Fuel Oil Storage Tank Open, Clean & Inspect
Commitment 5
 
Condition Report CR-IP2-2013-01756 Revision 2 of ENN-MS-S-004
EN-DC-178, Revision 5, System Walkdowns ENN-MS-S-004-IPEC, Rev 2 that documents the system categories EN-DC-159, Revision 6, System Monitoring Program
 
Commitment 6, 33, 43, 44, and 45
  2-PT-2Y015, Revision 3, Thermal Cycle Monitoring Program IP-RPT-11-LRD13, Revision 0, Review of the Fatigue Monitoring Aging Management Program  for License Renewal Implementation
EN-LI-100, Revision 13, Process Applicability Determination
EN-AD-101, Revision 16, Procedure Process WCAP-17199-P, July 2010, Environmental Fatigue Evaluation for Indian Point Unit 2 WCAP-17149-P, July 2010, Evaluation of Pressurizer Insurge/Outsurge Transients for Indian
Point Unit 2
Entergy Letter dated August 9, 2010 (NL-10-82), License Renewal Application - Completion of
Commitment #33 Regarding the Fatigue Monitoring Program Indian Point Nuclear
Generating Unit Nos. 2 and 3 [ML102300504]
Commitment 7
2-ENG-003-FIR, Detroit Diesel V-71, Emer
gency Fire Pump Diesel PM, Revision 5 2-PT-M040, Diesel Fire Pump, Revision 30
IP-RPT-11-LRD14, Review of the Fire Protection Aging Management Program for License
Renewal Implementation, Revision 2 SAO-703, Fire Protection Impairment Criteria and Surveillance, Revision 32
 
Commitment 8
 
2-PT-A017QA, Fire Hose Stations Inspections, Revision 8 A138057, City Water Supply Pipeline, Revision 18 CR-IP2-2004-01864, pin hole leak in fire water pipe
CR-IP2-2011-05889, Three pin hole leaks in fire water piping
IP2-UT-11-051/52/53, IP2-UT-12-016 thru 24, IP2-UT-12-026, and IP2-UT-12-028, Ultrasonic Test Reports for Fire Protection Piping, performed between 12/11 and 7/12 IP-RPT-11-LRD15, Review of the Fire Water System Aging Management Program for License
Renewal Implementation, Revision 0 IP-RPT-12-LRD02, Fire Water Piping Wall Thickness Evaluation for License Renewal,
Revision 0
SAO-703, Fire Protection Impairment Criteria and Surveillance, Revision 32
SE-86-59, Specification for Fire Standpipe Systems and City Water Piping, Revision 0 Work Order 134345, Main Turbine Lube Oil Fire Protection Foam Tank Refill, performed 6/12/08 Work Order 339750, 10-year Fire Water Piping UT Inspections 
A-6  Attachment Work Order NP-01-22451, Main Feed Pump Lube Oil Fire Protection Foam Tank Drain & Refill, performed 8/01/01 Work Orders 334193, 334196, 334198, and 334200, 4-year Visual Inspection of Foam Tank Internal Surfaces for Significant Corrosion Work Orders 335678, 335680, 335684, and 335686, 50-year Replacement of Sprinkler Heads
 
Commitment 9
  Corrective Action document LO-LAR-2011-00174, CA 06
A206913-1, Reactor Vessel Inspection Identification DWG, for U2
 
A209564-1, Reactor Vessel bottom mounted instrumentation, for U2
Mistras Procedure 583-ET-008, Revision 1 for Eddy Current Inspection of Incore Thimble Tubes IP-Calc-07-00038 dated 2/15/2007 on Reinspection frequency for IP3 Thimble Tubes Mistras Eddy Current test results for Unit 2 and Unit 3 Thimble tubes dated 3/16/09, 3/18/10,
and 3/9/12 (U2)
 
Commitment 10
  IP-RPT-11-LRD18, Revision 0, Review of the Heat Exchanger Performance and Condition
Monitoring Program
EN-DC-316, Revision 5, Heat Exchanger Performance and Condition Monitoring
SEP-HX-IP-001, Revision 1, IPEC Heat Exchanger/Eddy Current Program
Commitment 10 Implementation Matrix, May 4, 2013 IPEC Heat Exchanger and Eddy Current Inspection Program Data MWO 332520-01
MWO 349349-01
PMRQ 30855-01
PMRQ 31465-02
Commitment 12, 25, and 37
 
EN-DC-150, Rev. 4, Structural monitoring Program
Specific IPEC inspection requirements, Atta
chment to EN-DC-150, Structural Monitoring  Program Entergy Letter dated August 14, 2008, Commitment 37
Safety Evaluation Report Nureg 1930, Volume 2,
ASME Code, Section XI, Sub Sec. IWL
ASME IWL inspections performed in 2005 and 2009 using enhanced visual aids
ASTM C33-90, Guidance for Freeze-Thaw Monitoring
ER No. IP-RPT-11-00002, Revision 0, January 10, 2011, Assessment of Concrete Aging from Selected Indian Point Structures
 
Commitment 13
 
2-ELC-016-BUS, Inspection, Cleaning and Testing of 480V Buses, Revision 2 CR-IP2-2009-03029, Inspect electrical supports affected by water dripping at the bend in the  electric tunnel. Initiate corrective actions where required.
CR-IP2-2012-01903, Bus 5A surface rust noted on the interior divider panel 
A-7  Attachment Work Order 52293872, Inspection of Bus 5A Switchgear and Station Service Transformer  Work Order 52294517, Inspection of Bus 5A (480 V Switchgear to EDG)
Commitment 14
 
IP-RPT-11-LRD23, Revision 0, Review of the Non-EQ Bolted Cable Connections Aging
Management  Program for License Renewal Implementation. IP-RPT-13-LRD01, Non-EQ Bolted Cable Connection Evaluation, Revision 0
Work Orders related to Bolted Cable Connection Inspection Samples:
52249670, 52249670, 52339357, 52293872
Commitment 15
  CR-IP2-2012-01307, The 'C' phase Tan Delta values obtained were noticeably higher than the  remaining 2 phases for 24 CWP.
CR-IP2-2013-01480, During License Renewal walkdowns, deficiencies were noted with cables  that were not part of the program. EN-DC-346, Cable Reliability Program, Revision 5
EN-MA-138, VLF Tan Delta and Withstand Testing of Electrical Power Cables, Revision 1
Work Orders related to periodic preventive maintenance inspection and dewatering of various
manholes:  52477039, 52459080, 52471206, 52449618, 52449619, 52449801,
52431438, 52431439, 52450288, 52431268, 52454018, 52454019
Commitment 16
 
IP-RPT-11-LRD25, Review of the Non-EQ Instrumentation Circuits Test Review Aging
Management Program for License Renewal Implementation Report on ECAD Testing at Indian Point Unit 2, Dated November 2004 System Health Report for NI System (1
st QT 2013) Work Order 32099001, 4Y PEO Test Integrity of NI Cables N-31, N-32
Work Order 32099701, 4Y PEO Test Integrity of NI Cables N-35, N-36
Work Order 32100101, 4Y PEO Test Integrity of NI Cables N-41A/B through N-44A/B
Work Order 34926901, 8Y PEO Review of NI Calibration & Test Results Work Order 51800948, High Range Containment Area Radiation Monitor R26 Calibration Test  (3/11/10)
Work Order 51800949, High Range Containment Area Radiation Monitor R25 Calibration Test
(3/11/10)
Work Order 52246190, High Range Containment Area Radiation Monitor R25 Calibration Test  (3/15/12) Work Order 52246191, High Range Containment Area Radiation Monitor R26 Calibration Test
(3/11/12)
 
 
A-8  Attachment Commitment 17
  CR-IP2-2013-01480 and -01607, Cable walkdown deficiencies identified
Data Walkdown Sheets (e.g., field observation notes) for 21 RHR Pump Room, Primary Auxiliary Bldg (PAB) 15 foot elevation Piping and Valve Room, PAB Chemical Drain
Tank Room, PAB Filter Room, PAB Large Gas Decay Tank Room, Electrical Cable
Tunnel, Turbine Bldg (TB) Ground Floor - West, and TB Ground Floor - North West, walkdowns performed between 7/22/10 and 8/03/10  EN-DC-348, Non-EQ Insulated Cables and Connections Inspection, Revision4
IP-RPT-10-LRD15, Cable and Connection Inspection Summary Report, Revision 0
IP-RPT-11-LRD26, Review of the Non-EQ Insulated Cables and Connections Aging Management Program for License Renewal Implementation, Revision 0 Work Order 348737 and 348751, 8-year Cable & Connection Inspection
Commitment 18
 
LO-LAR-2011-00174
A.2.1.25 Oil Analysis Program
B.1.26 Oil Analysis Program
 
EN-DC-335, Nuclear Management Manual, Revision 4
EN-DC-149, Entergy Nuclear Management Manual, Rev. 6
SEP-LUB-IPC-001, IPEC Lubrication Program, Revision 0
SEP-LUB-IPC-002, IPEC Oil Analysis Program, Revision 0 SEP-LUB-IPC-002, IPEC Oil Analysis Program, Revision 1 PM Basis Template, EN - Pump - Horizontal with Couplings, Revision 4
 
Commitment 19
  IP-RPT-11-LRD28, Revision 0, Review of the One-Time Inspection Program EN-FAP-LR-024, Revision 1, One-Time Inspection
NL-13-046, Amendment 13 to LRA for One-Time Inspection and Selective Leaching Programs,
March 18, 2013
IPEC Unit 2 One-Time Inspection Tracking Matrix, May 3, 2013 and May 21, 2013
20 Inspection reports for one-time inspections
Commitment 20
 
UT Calibration Examination and Report Sheets:
 
206723-969A CVC CW Elbow-to-Pipe Component 96 9A 206723-969B CVC Circ-Weld Component 96 9B
206723-963.RI  CVC Circ-Weld Component 96 3
206723-964.RI  CVC Circ-Weld Component 96 4
206723-962.RI CVC Circ-Weld Component 96 2
206713-793.RI CVC Circ-Weld Component 79 3
Corrective Action LO-LAR-2011-00174 NRC Commitment #20
Commitment Closure Verification Form IP2 A-3230/ LO-LAR-2011-00174 -12 
A-9  Attachment Entergy Letter NL-07-153, "Amendment 1 to License Renewal Application (LRA)," 12/18/2007 Entergy Letter NL-10-076, "Amendment 10 to License Renewal Application (LRA)," 7/26/2010 Entergy Letter NL-11-032, "Response to Request for Additional Information," 3/28/2011
Entergy Letter NL-11-074, "Response to Request for Additional Information," 7/14/2011
 
LR Request #173
IP-RPT-11-LRD29, Revision 0, "Review of the One-Time Inspection - Small Bore Piping
Program for License Renewal Implementation," 1/16/2013
Commitment  21
 
IP-RPT-11-LRD30, Review of the Periodic Surveillance and Preventive Maintenance 
Aging Management Program for License Renewal Implementation, Revision 0 0-PT-M002, Alternate Safe Shutdown Equipment Inventory and Inspection, Revision 8 2-PT-Q033A, 21 Charging Pump, Revision 17
LO-LAR-2011-00174
A.2.1.28 Periodic Surveillance and Preventive Maintenance Program
B.1.29 Periodic Surveillance and Preventive Maintenance WO 00307819, U2 offsite power feeder 138 kV underground transmission cable WO 00332413, Unit 2 SBO/Appendix R Diesel Generator
WO 00334380, Station Air System
 
WO 00324716, Circulation Water System
WO 00334184, Emergency Diesel Generator System
 
Commitment 22
 
Corrective Action LO-LAR-2011- 00174, "Enhance the Reactor Vessel Surveillance Program,"  8/20/2011
Entergy Letter NL-07-140, "Reply to Request for Additional Information Regarding License  Renewal Application," November 28, 2007 Entergy Nuclear Management Manual, EN-DC-149 Revision 6, Vendor Document Review
Status, "Review of the Reactor Vessel
Surveillance Aging Management Program for  License Renewal Implementation, EC38922," 1/2/2013
Westinghouse WCAP-16752-NP, Revision 0, "Indian Point Heatup and Cooldown Limit Curves
for Normal Operation," January 2008.
Commitment 23
 
IP-RPT-11-LRD34, Revision 0, Review of the Selective Leaching Program
EN-FAP-LR-02, Revision 3, Selective Leaching Inspection NL-13-046, Amendment 13 to LRA for One-Time Inspection and Selective Leaching Programs,  March 18, 2013
IPEC Unit 2 Selective Leaching Inspection Tracking Matrix, May 20, 2013
10 Inspection reports for copper-alloy selective leaching inspections
12 Inspection reports for gray cast iron selective leaching inspections
 
WO 00326036-01
WO 00326216-01
 
A-10  Attachment Commitment 24
  Corrective Action document LO-LAR-2011-0174 CA 17
SEP-SG-IP2-001, Revision 0, IP2 Steam Generator Program
SEP-SG-IP3-001, Revision 0, IP3 Steam Generator Program
EN-DC-317, Revision 7, Steam Generator Program
IP-RPT-11-LRD36, Revision 0, Review of the Steam Generator Integrity Aging Management  Program for License Renewal Implementation
Commitment 26
 
Entergy Letter, NL-09-018, "Reply to Request for Additional Information - Miscellaneous Items,"  January 27, 2009 Entergy Letter NL-11-101, "Clarification for
Additional Information (RAI) Aging Management  Programs," August 22, 2011
 
LR# 173, LR Request, Confirm each AMP will be implemented with ten elements IP-RPT-11-LRD38, "Review the Thermal Aging Embrittlement of CASS Aging Management  Program for License Renewal Implementation," 1/2/2013 NRC Letter, "License Renewal Issue No. 98-0030, "Thermal Aging Embrittlement of Cast
Austenitic Stainless Steel Components," May 19, 2000
WCAP-10977, Supplement 1, "Additional Information in Support of the Technical Justification for
Eliminating Large Primary LOOP Pipe Rupture as the Structural Design Basis for Indian
Point Unit 2," January 1989
Commitments 27, 47
 
IP-RPT-11-LRD39, Revision), "Review of the Thermal Aging & Neutron Embrittlement of CASS
Aging Management Program for License Renewal Implementation," ED41109,  1/23/2013 EPRI 1013234 "Materials Reliability Program: Screening, Categorization, and Ranking of  Reactor Internals Components for Westinghouse and Combustion Engineering PWR
Design (MRP-191)," November 2006
EPRI 1022863 "Materials Reliability Program: Pressurized Water Reactor Internals Inspection  and Evaluation Guidelines (MRP-227-A)," December 2011 NRC Letter "Request for Additional Information for the Review of the Indian Point Nuclear  Generating Unit Nos. 2 and 3, License Renewal Application," May 15, 2012
Entergy Letter, NL-11-101, "Clarification for Request for Additional Information (RAI) Aging
Management Programs," 8/22/2011
Entergy Letter NL-13-052, "Reply to Request for Additional Information Regarding the License  Renewal Application," 5/7/2011 LR Request #173 Confirm new programs will be implemented consistent with 10 elements of
NUREG-1801.
IP-RPT-11-LRD39 "Review of the Thermal Aging & Neutron Irradiation Embrittlement of CASS
Aging Management Program for License Renewal Implementation," EC41109, 1/2/13
 
   
A-11  Attachment Commitment 30
  Entergy Letter NL-10-063, "Amendment 9 to License Renewal Application (LRA) - Reactor
Vessel Internals Program," dated 7/14/2010
Entergy Letter NL-11-101, "Clarification for Request for Additional Information (RAI), Aging
Management Programs," 08/22/2011
Entergy Letter NL-11-107, "License Renewal Application - Completion of Commitment #30  Regarding the Reactor Vessel Internals Inspection Plan," 09/28/2011 Entergy Letter NL-12-037, "License Renewal Application - Revised Reactor Vessel Internals
Program and Inspection Plan Compliant with MRP-227-A," 02/17/2012
Entergy Letter NL-12-089, "Reply to Request for Additional Information Regarding the License
Renewal Application," 06/14/2012 Entergy Letter NL-12-134, "Reply to Request for Additional Information Regarding the License  Renewal Application," 09/28/2012
Entergy Letter NL-12-140, "Reply to Request for Additional Information Regarding the License
Renewal Application," 10/17/2012
IP-RPT-11-LRD43, "Review of the Reactor
Vessel Internals Aging Management Program for  License Renewal Implementation," EC40997, Revision 0, 4/10/2013
Commitment 31
 
Entergy Letter NL-13-001, Proposed Changes to Indian Point 2 Technical Specifications
Regarding reactor Vessel Heatup and Cooldown Curves and Low Temperature Over  Pressure Requirements. 2/6/2013 Entergy Letter NL-07-140, NRC letter dated October 28, 2007; "Requests for Additional
Information for the Review of the Indian Point Nuclear Generating Unit Nos. 2 and 3,
License Renewal Application"
 
Commitment 35
 
Work order No. 00282078-01 for inspection of representative sample area of the IP2
containment liner affected by the 1973 event behind the insulation
Work order No. 00316062-01 for the Unit 3 one time inspection containment steel liner at the
juncture with the concrete floor slab.  Drawing A202453, Revision 28, Containment building, Elv 68', South Half
Commitment 38
 
Entergy Letter NL-08-143, "Additional Information Regarding License Renewal Application -  Reactor Vessel Fluence Clarification," 9/24/2008 Entergy Letter NL-11-101, "Clarification for Request for Additional Information (RAI) Aging
Management Programs," 8/22/2011
IP-RPT-11-LRD33, "Review of Reactor Vessel Surveillance Aging Management Program for  License Renewal Implementation," 1/2/2013
 
   
A-12  Attachment Commitment 41
  Corrective Action document LO-LAR-2011-0174 CA 58, 59, for commitment closure
IP-RPT-11-LRD36, Revision 0.  Review of the Steam Generator Integrity Aging Management
Program for License Renewal Implementation
EPRI report on Divider Plate cracking presented at the SGMP Meeting in June 2012
EPRI Technical Report # 3002000411, dated April 2013 on the Flaw Tolerance Evaluation of  the Steam Generator Channel Head
Commitment 42
 
LO-LAR-2011-0174 CA 60, 61 Corrective Action document LO-LAR-2011-0174 CA 60, 61, for commitment closure
Condition Report CR-IP2-2013-01440, Revision 2 
IP-RPT-11-LRD36, Revision 0.  Review of the Steam Generator Integrity Aging Management
Program for License Renewal Implementation
Aging Management SER section 3.1.2.2.17, Cracking due to SCC and PWSCC
Commitment 46
 
As referenced in the report.
 
Commitment 48
  Work Order PMRQ 00349816-01, 23 Fuel Oil Storage Tank Underground Piping Inspections
Work Order PMRQ 00349802-01, 21 Fuel Oil Storage Tank Underground Piping Inspections
Work Order PMRQ 00349814-01, 22 Fuel Oil Storage Tank Underground Piping Inspections
Work Order 00342492-01, Inspect Underground Piping by the IP2 EDG Building DF-2 Area Work Order 00342493-01, Inspect Underground Piping by the IP2 EDG Building DF-2-1 Area Work Order 00342494-01, Inspect Underground Piping by the IP2 EDG Building DF-2-2 Area
 
2.B.1.5  Boric Acid Corrosion Control, Existing Aging Management Program (AMP)
 
Corrective Action document LO-LAR-2011-00174, CA 30 SEP-BAC-IPC-001, Revision 0, IP2, IP3 Site Boric Acid Corrosion Control Program CEP-BAC-IPC-001, Revision 1, Corporate Boric Acid Corrosion Control Program Plan
EN-DC -319, Revision 9, Boric Acid Corrosion Control Program (BACCP)
2-PT-R156, Revision 4, RCS Boric Acid Leakage and Corrosion Inspection (during outages).
2-PT-Q092, Revision 7, Containment Building Inspection (during operation) EN-DC-178, Revision 5, System Walkdowns Engineering Report No. IP-RPT-11-LRD06, Revision 0, Review of the Boric Acid Corrosion
Prevention Aging Management Program for License Renewal Implementation
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