ML092250374: Difference between revisions

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#REDIRECT [[NL-09-111, Additional Information Regarding License Renewal Application - IPEC RAI 2.3A.3.11-1 and Buried Piping and Tanks Inspection Clarifications]]
| number = ML092250374
| issue date = 08/06/2009
| title = Additional Information Regarding License Renewal Application - IPEC RAI 2.3A.3.11-1 and Buried Piping and Tanks Inspection Clarifications
| author name = Dacimo F
| author affiliation = Entergy Nuclear Northeast, Entergy Nuclear Operations, Inc
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000247, 05000286
| license number = DPR-026, DPR-064
| contact person =
| case reference number = FOIA/PA-2010-0133, NL-09-111
| document type = Letter
| page count = 23
| project =
| stage = Other
}}
 
=Text=
{{#Wiki_filter:v "-%rEnteW 0 Enterqy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 788-2055 Fred Dacimo Vice President License Renewal NL-09-111 August 6, 2009 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
 
==SUBJECT:==
 
==REFERENCE:==
 
Additional Information Regarding License Renewal Application  
-IPEC RAI 2.3A.3.11-1 and Buried Piping and Tanks Inspection Clarifications Indian Point Nuclear Generating Unit Nos. 2 & 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64 1. Entergy Letter dated November 16, 2007, F. R. Dacimo to Document Control Desk, "Reply to Request for Additional Information Regarding License Renewal Application" (NL-07-138)
: 2. Entergy Letter dated July 27, 2009, F. R. Dacimo to Document Control.Desk, "Questions Regarding Buried Piping Inspections" (NL-09-106)3. Telephone Conference Call Held on August 4, 2009, Between the U.S. Nuclear Regulatory Commission and Entergy Nuclear Operations, Inc., Pertaining to the Indian Point Nuclear Generating Unit Nos. 2 and 3, License Renewal Application
-IPEC RAI 2.3A.3.1 1-1 Clarification
: 4. Telephone Conference Call Held on August 5, 2009, Between the U.S. Nuclear Regulatory Commission and Entergy Nuclear Operations, Inc., Pertaining to the Indian Point Nuclear Generating Unit Nos. 2 and 3, License Renewal Application
-Buried Piping and Tanks Inspection
 
==Dear Sir or Madam:==
On August 4 and August 5, 2009 Teleconferences were held between the U.S. Nuclear Regulatory Commission and Entergy Nuclear Operations, Inc. concerning our response to RAI 2.3A.3.1 1-1 in Reference 1 and Buried Piping and Tanks Inspection information in Reference 2.In response to staff questions, Entergy Nuclear Operations, Inc is providing, in Attachment 1, a IPEC RAI 2.3A.3.1 1-1 and Buried Piping and Tanks Inspection clarifications pertaining to the License Renewal Application for Indian Point 2 and Indian Point 3.-A NL-09-1 11 Page 2 of 2 If you have any questions, or require additional information, please contact Mr. Robert Walpole at 914-734-6710.
I declare under penalty of perjury that the foregoing is true and correct. Executed on Sincer FRD/dmt
 
==Attachment:==
: 1. Additional Information Regarding License Renewal Application
-IPEC RAI 2.3A.3.11-1 and Buried Piping and Tanks Inspection Clarifications
: 2. IPEC Commitment List, Revision 11 cc: Mr. Samuel J. Collins, Regional Administrator, NRC Region I Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel Ms. Kimberly Green, NRC Safety Project Manager Mr. John Boska, NRR Senior Project Manager Mr. Paul Eddy, New York State Department of Public Service NRC Resident Inspector's Office Mr. Francis J. Murray, President and CEO, NYSERDA ATTACHMENT 1 TO NL-09-1 11 Additional Information Regarding License Renewal Application
-IPEC RAI 2.3A.3.1 1-1 and Buried Pipinq and Tanks Inspection Clarifications ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286 Attachment 1 NL-09-111 Page 1 of 1 INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION IPEC RAI 2.3A.3.11-1 AND BURIED PIPING AND TANKS INSPECTION CLARIFICATIONS RAI 2.3A.3.11-1 Clarification The IP1 fire protection components that are referenced in the RAI 2.3A.3.1 1-1 response are specifically used only to support IP1 and do not have an intended function for IP2 or IP3. They are not required to demonstrate IP2 or IP3 compliance with 10 CFR 50.48 and therefore, are not in the scope of license renewal.The IP1 components are credited in the IP1 fire protection program which meets the requirements of 10 CFR 50.48(f).Buried Piping and Tanks Inspection Program -Clarification Program Improvements Resulting from Operating Experience Entergy will employ inspection methods with demonstrated effectiveness for detection of aging effects during the period of extended operation The Electric Power Research Institute is evaluating a number of techniques for application to the commercial nuclear power industry, e.g., guided wave ultrasonic technology.
Entergy will employ an inspection method that has been demonstrated effective by EPRI to address issues with degradation of buried components.
Commitment Include in the Buried Piping and Tanks Inspection Program described in LRA Section B.1.6 a risk assessment of in-scope buried piping and tanks that includes consideration of the impacts of buried piping or tank leakage and of conditions affecting the risk for corrosion.
Classify pipe segments and tanks as having a high, medium or low impact of leakage based on the safety class, the hazard posed by fluid contained in the piping and the impact of leakage on reliable plant operation.
Determine corrosion risk through consideration of piping or tank material, soil resistivity, drainage, the presence of cathodic protection and the type of coating. Establish inspection priority and frequency for periodic inspections of the in-scope piping and tanks based on the results of the risk assessment.
Perform inspections using inspection techniques with demonstrated effectiveness.
ATTACHMENT 2 TO NL-09-1 11 IPEC Commitment Letter, Revision 11 ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286 Attachment 2 NL-09-1 11 Page 1 of 18 List of Regulatory Commitments Revision 11 The following table identifies those actions committed to by Entergy in this document.Changes are shown as strikethroughs for deletiens and underlines for additions.
# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 1 Enhance the Aboveground Steel Tanks Program for IP2: NL-07-039 A.2.1.1 IP2 and IP3 to perform thickness measurements of September 28, A.3.1.1 the bottom surfaces of the condensate storage tanks, 013 B.1.1 city water tank, and fire water tanks once during the IP3: first ten years of the period of extended operation.
December 12, Enhance the Aboveground Steel Tanks Program for 2015 IP2 and IP3 to require trending of thickness I measurements when material loss is detected.2 Enhance the Bolting Integrity Program for IP2 and IP3 IP2: NL-07-039 A.2.1.2 to clarify that actual yield strength is used in selecting September 28, A.3.1.2 materials for low susceptibility to SCC and clarify the 2013 B.1.2 prohibition on use of lubricants containing MoS 2 for IP3: NL-07-153 Audit Items bolting. I3 L0 -5 ui tm December 12, 201,241, The Bolting Integrity Program manages loss of 2015 270 1 preload and loss of material for all external bolting. I I I Attachment 2 NL-09-1 11 Page 2 of 18# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I_ I / AUDIT ITEM 3 Implement the Buried Piping and Tanks Inspection Program for IP2 and IP3 as described in LRA Section B.1.6.This new program will be implemented consistent with the corresponding program described in NUREG-1801 Section XI.M34, Buried Piping and Tanks Inspection..
Include in the Buried Piping and-Tanks Inspection Program described-in LRA Section B13.6 a risk assessment of. in-scopeburied piping and tanks that includes consideration of. the impacts of buried piping or tank leakage and of conditions affecting the risk for corrosion.
Classify pipe segments and tanks as having a high, medium-or low impact of-leakage.
based on the safety class,.the hazard posed by fluid-contained in the piping and.the impact of leakage on reliable plant-operation.
-Determine-corrosion risk-through consideration of piping or tank material, soil resistivity, drainage, the presence of cathodic protection and the type of coating.-
Establish inspection priority and frequency for periodic.inspections of the in-scope piIping and tanks based on, the results of the risk assessment.
Perform inspections using qualified inspection techniques with demonstrated effectiveness.
I P2: September 28, 2013 I P3: December 12, 2015 NL-07-039 NL-07-153 NL-09-106 NL-09-1 11 A.2.1.5 A.3.1.5 B.1.6 Audit Item 173 I A. A. I Attachment 2 NL-09-111 Page 3 of 18 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION 1 11. 1 J/AUDIT ITEM 4 Enhance the Diesel Fuel Monitoring Program to include cleaning and inspection of the IP2 GT-1 gas turbine fuel oil storage tanks, IP2 and IP3 EDG fuel oil day tanks, !P2 SBO/Appendix R diesel generator fuel oil day tank, and IP3 Appendix R fuel oil storage tank and day tank once every ten years.Enhance the Diesel Fuel Monitoring Program to include quarterly sampling and analysis of the IP2 SBO/Appendix R diesel generator fuel oil day tank, IP2 security diesel fuel oil storage tank, IP2 security diesel fuel oil day tank, and IP3 Appendix'R fuel oil storage tank. -Particulates, water and sediment checks will be performed on the samples. Filterable solids acceptance criterion-will be'less than or equal to 10mg/l. Water and sediment acceptance criterion will be less than or equal to 0.05%.Enhance-the Diesel Fuel Monitoring Program to-include thickness measurement of the bottom-of the following tanks once every ten years. IP2: EDG fuel oil storage tanks,. EDG fuel oil day-tanks, SBO/Appendix R diesel generator fuel oil day tank, GT-1 gas turbine fuel oil storage tanks, and diesel fire pump fuel oil storage tank; IP3: EDG fuel oil day tanks, EDG fuel oil storage. tanks, Appendix R fuel oil storage tank, and-diesel fire pump fuel oil storage -tank.Enhance the Diesel Fuel Monitoring Program to change the analysis for water and particulates to a quarterly frequency for the following tanks. IP2: GT-1 gas turbine fuel oil storage tanks and diesel fire pump fuel oil storage tank; IP3: Appendix R fuel oil day tank and diesel fire pump fuel oil storage tank.Enhance the Diesel Fuel Monitoring Program to specify acceptance criteria for thickness measurements of the fuel oil storage tanks within the scope of the program.Enhance the Diesel Fuel Monitoring Program to direct samples be taken and include direction to remove water when detected.Revise applicable procedures to direct sampling of the onsite portable fuel oil contents prior to transferring the contents to the storage tanks.IP2: September 28, 2013 IP3: December 12, 2_015 NL-07-039 NL-07-153 NL-08-057 A.2.1.8 A.3.1.8 B.1.9 Audit items 128,129, 132, 491,492, 510 Attachment 2 NL-09-1 11 Page 4 of 18 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 4 Enhance the Diesel Fuel Monitoring Program to direct Cont the addition of chemicals including biocide when the presence of biological activity is confirmed.
5 Enhance the External Surfaces Monitoring Program IP2: NL-07-039 A.2.1.10 for IP2 and IP3 to include periodic inspections of September 28, A.3.1.10 systems in scope and subject to aging management 013 B.1.11 review for license:renewal in accordance with 10 CFR 54.4(a)(1) and (a)(3):- Inspections shall include areas IP3: surrounding the subject systems to identify hazards to De r1 those systems. Inspections of nearby systems that could impact the subject systems will include SSCs that are in scope and subject to aging management review for license renewal- in accordance.
with 10 CFR 54-.4(a)(2)-.---
----.: , , .-1 .I -_ _.._____a 7. IP2: NL-07-039 A.2.1.11 6 Enhance the Fatigue Monitoring Program for IP2 to eptember 28, A.3.1.11 monitor steady state cycles and feedwater cycles or perform an evaluation-to determine monitoring is not 2013 B.1.12, required:
Review the number of allowed events-and NL-07-153 Audit Item resolve discrepancies between reference documents 164 and monitoring procedures.
Enhance the Fatigue Monitoring Program for iP3 to IP3: include all the transients identified.
Assure all fatigue December 12, analysis transients are included with the lowest 2015 limiting numbers. Update the number of design transients accumulated to date.
Attachment 2 NL-09-1 11 Page 5 of 18# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I I I/ AUDIT ITEM 7 Enhance the Fire Protection Program to inspect external surfaces of the IP3 RCP oil collection systems for loss of material each refueling cycle.Enhance the Fire Protection Program to explicitly state that the IP2 and IP3 diesel fire pump engine sub-systems (including the fuel supply line) shall be observed while the pump is running. Acceptance criteria will be revised to verify that the diesel engine does not exhibit signs of degradation while running;such as fuel oil, lube-oil, coolant, or exhaust gas leakage.: Enhance the Fire Protection Program to specify that the IP2 and IP3 diesel fire pump engine carbon steel exhaust components are inspected for evidence of corrosion and cracking at least once each operating cycle..Enhance the Fire Protection Program for IP3 to visually inspect the cable spreading room, 480V switchgear room, and EDG room C02 fire suppression system for signs of degradation, such as corrosion and mechanical damage at least once every six months.I P2: September 28, 2013 I P3: December 12, 2015 NL-07-039 A.2.1.12 A.3.1.12 B.1.13 Attachment 2 NL-09-111 Page 6 of 18 COMMITMENT IMPLEMENTATION SOURCE -RELATED SCHEDULE LRA SECTION_ 1_ 1 1_ /AUDIT ITEM 8 Enhance the Fire Water Program to include inspection of IP2 and IP3 hose reels for evidence of corrosion.
Acceptance criteria will be revised to verify no unacceptable signs of degradation.
Enhance the Fire Water Program to replace all or test a sample of IP2 and IP3 sprinkler heads required for 10 CFR 50.48 using guidance of NFPA 25 (2002 edition), Section-5.3.1.1.1 before theend of the 50-year sprinkler head service life and at 10-year intervals thereafter during the extended period of operation to ensure that signs of degradation, such as corrosion, are detected in a timely manner.Enhance the Fire Water Program to perform wall thickness=
evaluations of IP2-and IP3 fire protection piping on system components using non-intrusive techniques (e.g., volumetric testing) to identify evidence of loss of material due to corrosion.
These inspections will be performed before the end of the current operating term and at intervals thereafter during the period of extended operation.
Results of the initial evaluations will be used to determine the appropriate inspection interval to ensure aging effects are identified prior to loss of intended function.Enhance the Fire Water Program to inspect the internal surface of foam based fire suppression tanks.Acceptance criteria will be enhanced to verify no sianificant corrosion.
P2: September 28, 2013 P3: December 12, 2015 NL-07-039 NL-07-153 NL-08-014 A.2.1.13 A.3.1.13 B.1.14 Audit Items 105,106____ I A. I Attachment 2 NL-09-111 Page 7 of 18# COMMITMENT IMPLEMENTATION
-SOURCE -RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 9 Enhance the Flux Thimble Tube Inspection Program IP2: NL-07-039 A.2.1.15 for IP2 and IP3 to implement comparisons to wear September 28, A.3.1.15 rates identified in WCAP-12866.
Include provisions to 013 B.1.16 compare data to the previous performances and IP3: perform evaluations regarding change to test December 12, frequency and scope. 015~2015 Enhance the Flux.Thimble Tube Inspection Program for IP2 and I P3 to specify the acceptance criteria as outlined in WCAP-12866 or other plant-specific values based on evaluation of previous test results.Enhance the Flux Thimble Tube Inspection Program for IP2 and IP3 to direct evaluation and performance of corrective-actions based on tubes that exceed or are-projected to exceed the acceptance criteria.
Also stipulate that flux-thimble tubes that cannot be inspected over the tube length and cannot be shown by analysis to besatisfactory for continued service, must be removed from service to ensure the integrity of the reactor coolant system pressure boundary.
Attachment 2 NL-09-1 11 Page 8 of 18 COMMITMENT IMPLEMENTATION SOURCE- RELATED SCHEDULE LRA SECTION I I / AUDIT ITEM 10 Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to include the following heat exchangers in the scope of the program.* Safety injection pump lube oil heat exchangers
* RHR heat exchangers
* RHR pump seal coolers* Non-regenerative heat exchangers
* Charging pump seal water heat exchangers Charging pump fluid drive coolers I P2: September 28, 2013 1 P3: December 12, 2015 0 0 Charging pump crankcase oil coolers Spent fuel pit heat exchangers
* Secondary system steam generator sample coolers* Waste gas compressor heat exchangers
* SBO/Appendix R diesel jacket water heat exchanger (IP2 only)Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to perform visual inspection on heat exchangers where non-destructive examination, such as eddy current inspection, is not possible due to heat exchanger design limitations.
Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to include consideration of material-environment combinations when determining sample population of heat exchangers.
Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to establish minimum tube wall thickness for the new heat exchangers identified in the scope of the program. Establish acceptance criteria for heat exchangers visually inspected to include no indication of tube erosion, vibration wear, corrosion, pitting, foulinci, or scalina.NL-07-039 NL-07-153 NL-09-018 A.2.1.16 A.3.1.16 B.1.17, Audit Item 52 11 Delete commitment.
NL-09-056 Attachment 2 NL-09-111 Page 9 of 18# COMMITMENT IMPLEMENTATION SOURCE- RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 12 Enhance the Masonry Wall Program for IP2 and IP3 P2: NL-07-039 A.2.1.18 to specify that the IP1 intake structure is included in September 28, A.3.1.18 the program.IP3: December 12, 2015 13 Enhance the Metal-Enclosed Bus Inspection Program to add IP2 480V bus associated with substation A to the scope of bus inspected.
Enhance the Metal-Enclosed Bus Inspection Program for IP2 and IP3 to visually inspect the external surface of MEB enclosure assemblies for loss of material at least once every 10 years. The first inspection will occur prior to the period of extended operation and the acceptance criterion will be no significant loss of material.Enhance the Metal-Enclosed Bus Inspection Program to add acceptance criteria for MEB internal visual inspections to include the absence of indications of dust accumulation on the bus bar, on the insulators, and in the duct, in addition to the absence of indications of moisture intrusion into the duct.Enhance the Metal-Enclosed Bus Inspection Program for IP2 and IP3 to inspect bolted connections at least once every five years if performed visually or at least once every ten years using quantitative measurements such as thermography or Contact resistance measurements.
The first inspection will occur prior to the period of extended operation.
The plant will process a change to applicable site procedure to remove the reference to "re-torquing" connections for phase bus maintenance and bolted connection maintenance.
I P2: September 28, 2013 1 P3: December 12, 2015 NL-07-039 NL-07-153 NL-08-057 A.2.1.19 A.3.1.19 B.1.20 Audit Items 124, 133, 519 14 Implement the Non-EQ Bolted Cable Connections P2: NL-07-039 A.2.1.21 Program for IP2 and IP3 as described in LRA Section September 28,.1.2 B. 1.22. 013 8.1.22 I P3: December 12, 12015 Attachment 2 NL-09-1 11 Page 10 of 18 COMMITMENT IMPLEMENTATION SOURCE -RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 15 Implement the Non-EQ Inaccessible Medium-Voltage
!P2: NL-07-039 A.2.1.22 September 28,. A.3.1 .22-Cable Program for IP2 and IP3 as described in LRA S e013 28B.1.23 Section 8.1.23.203B13 NL-07-153 Audit item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- December 12, 1801 Section XI.E3, Inaccessible Medium-Voltage 2015 Cables Not Subject To 10 CFR 50.49 Environmental.
Qualification Requirements.
.:__. -_.. ._._...-,-.__...
16 Implement the Non-EQ Instrumentation Circuits Test IP2: NL-07-039 A.2.1.23 Review Program for IP2 and IP3 as described in LRA September 28, A.3.1.23 Section B.1.24. 013 B.1.24.. 53-Audit item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- December 12, 1801 Section XI.E2, Electrical Cables and 2015 Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits.17 Implement the Non-EQ Insulated Cables and 1P2: NL-07-039-A.2.1.24 Connections Program for IP2 and IP3 as described in September 28, A.3.1.24 LRA Section B.1.25. 013 B.1.25 NL-07-153 Audit item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- December 12,: 1801 Section XI.E1, Electrical Cables and 2015 Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.
Attachment 2 NL-09-111 Page 11 of 18# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 18 Enhance the Oil Analysis Program for IP2 to sample IP2: NL-07-039 A.2.1.25 and analyze lubricating oil used in the SBO/Appendix September 28, A.3.1.25 R diesel generator consistent with oil analysis for 2013 B. 1.26 other site diesel generators..
-P3: Enhance the Oil Analysis Program for IP2 and IP3 to. December 12, sample and analyze generator seal oil and turbine 2015 hydraulic control oil.Enhance the Oil Analysis Program for IP2 and IP3 to--formalize preliminary oil screening for water and particulates and laboratory analyses including-defined
-acceptance criteria for all components included in the scope of this program. The program will specify corrective actions in the event acceptance criteria are not met.Enhance the Oil Analysis Program for IP2 and IP3 to formalize trending of preliminary oil screening results as well as data provided from independent laboratories.
IP2: " NL-07-039 19 Implement the One-Time Inspection Program:for IP2 .P_ : septemberA22,1.2 and IP3 as described in LRA Section B.1.27. September 28, A.3.1.26 2013 B.1.27 This new program will be implemented consistent with NL-07-153 Audit item the corresponding program described in NUREG- I P3:: 173 1801, Section XI.M32, One-Time Inspection.
December 12, 2015 20 Implement the One-Time Inspection
-Small Bore 1p2: NL-07-039 A.2.1.27 Piping Program for IP2 and IP3 as described in LRA September 28, A.3.1.27 Section B.1.28. 2013 B.1.28 NL-07-153 Audit item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- December 12, 1801, Section XI.M35, One-Time Inspection of ASME 2015 Code Class I Small-Bore Piping.21 Enhance the Periodic Surveillance and Preventive IP2: NL-07-039 A.2.1.28 Maintenance Program for IP2 and IP3 as necessary September 28, A.3.1.28 to assure that the effects of aging will be managed 013 B.1.29 such that applicable components will continue to perform their intended functions consistent with the D e r1 current licensing basis through the period of extended De r1 operation.
2015
.Attachment 2 NL-09-1 11 Page 12 of 18 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 22 Enhance the Reactor Vessel Surveillance Program for IP2: NL-07-039 A.2.1.31 IP2 and IP3 revising the specimen capsule withdrawal September 28, A.3.1.31 schedules to draw and test a standby capsule to 013 B.1.32 cover the peak reactor vessel fluence expected IP3: through the end of the period of extended operation.
December 12, Enhance the Reactor Vessel Surveillance Program for 2015 IP2 and IP3 to require that tested and untested specimens from all capsules pulled from the reactor vessel are maintained in storage.23 Implement the Selective, Leaching Program for]P2, IP2: NL-07-039 A.2.1.32 and IP3 as described in LRA Sectioný B,4:.33"..
September 28, A.3.1.32 2013 B.1,33 This new program will be implemented consistent with NL-07-153 Audit item the corresponding program described in NUREG- IP3. 173 1801, Section XI.M33 Selective Leaching of Materials.
December 12,__ __ __ __ __ _2 015" ;: " " IP2: -NL-07-039 A.2.1.34 24 Enhance the Steam Generator Integrity Program for Sp2 b 28, A.3.1.34 IP2 and IP3 to require that the results of the condition September 28, A.3.1.34 monitoring assessment are compared to the 03*15 operational assessment performed for the prior IP3.operating cycle with differences evaluated.
December 12, 2015 25 Enhance the Structures Monitoring Program to IP2: NL-07-039 A.2.1.35 explicitly specify that the following structures are September 28, A.3.1.35 included in the program., 013'.. B.1.36* Appendix R diesel generator foundation (IP3) NL-07-153* Appendix R diesel generator fuel oil tank vault IP3: Audit items (IP3) December 12, 86, 87, 88,* Appendix R diesel generator switchgear and 2015 NL-08-057 417 enclosure (IP3)" city water storage tank foundation
* condensate storage tanks foundation (IP3)* containment access facility and annex (IP3)* discharge canal (IP2/3)* emergency lighting poles and foundations (IP2/3)* fire pumphouse (IP2)* fire protection pumphouse (IP3)* fire water storage tank foundations (IP2/3)* gas turbine 1 fuel storage tank foundation
* maintenance and outage building-elevated passageway (I P2)
Attachment 2 NL-09-1 11 Page 13 of 18 COMMITMENT IMPLEMENTATION SOURCE-. RELATED SCHEDULE LRA SECTION I_ I/ AUDIT ITEM" new station security building (IP2)* nuclear service building (IP1)* primary water storage tank foundation (IP3)* refueling water storage tank foundation (IP3)" security access and office building (IP3)* service water pipe chase (IP2/3)* service water valve pit (IP3)* superheater stack* transformer/switchyard support structures (IP2)-" waste holdup tank pits (IP2/3)Enhance the Structures Monitoring Program for IP2 and IP3 to clarify that in addition to structural steel and concrete, the following-commodities (including,.
their anchorages) are inspected for each structure as.applicable.
* cable trays and supports',-
* concrete portion of reactor vessel supports* conduits and supports-* cranes, rails and girders" equipment pads and foundations
* fire proofing (pyrocrete)" HVAC duct supports* jib cranes* manholes and duct banks- :-.* manways, hatches and hatch covers-* monorails* new fuel storage racks* sumps, sump screens, strainers and flow barriers Enhance the Structures Monitoring Program for IP2 and IP3 to inspect inaccessible concrete areas that are exposed by excavation for any reason. IP2 and IP3 will also inspect inaccessible concrete areas in environments where observed conditions in accessible areas exposed to the same environment indicate that significant concrete degradation is occurring.
Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspections of elastomers (seals, gaskets, seismic joint filler, and roof elastomers) to I I .1.
Attachment 2 NL-09-1 11 Page 14 of 18# COMMITMENT IMPLEMENTATION
-SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM identify cracking and change in material properties and for inspection of aluminum vents and louvers to identify loss of material.Enhance the Structures Monitoring Program for IP2 NL-08-127 Audit Item and IP3 to perform an engineering evaluation of 360 groundwater samples to assess aggressiveness of groundwater to concrete on a periodic basis (at least, once every five years).. IPEC will obtain samples from at least 5 wells that are representative of the ground water surrounding below-grade site structures and perform an engineering evaluation of the results from those samples for sulfates, pH and chlorides.
Additionally, to assess potential indications of spent fuel pool leakage,'
IPEC will sample for tritium in groundwater wells in close proximity to the IP2 spent fuel pool at least once every 3 months.Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspection of normally submerged concrete portions of the intake structures at least once every 5 years. Inspect the baffling/grating partition and support platform of the IP3 intake structure at least once every 5 years.Enhance the Structures Monitoring Program for IP2 Audit Item and IP3 to perform inspection of the degraded areas 358 of the water control structure once per 3 years rather than the normal frequency of once per 5 years during the PEO .__._....__
_ _... .. ..IP2: NL-07-039 A.2.1.36 26 Implement the Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) Program for IP2 September 28, A.3.1.36 and IP3 as described in LRA Section B.1.37. 013 B.1.37 NL-07-153 Audit item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- December 12, 1801, Section XI.M12, Thermal Aging Embrittlement2 015 -of Cast Austenitic Stainless Steel (CASS) Program: ._ _ ______- .....
Attachment 2 NL-09-111 Page 15 of 18 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 27 Implement the Thermal Aging and Neutron Irradiation P2: NL-07-039 A.2.1.37 Embrittlement of Cast Austenitic Stainless Steel September 28, A.3.1.37 (CASS) Program for IP2 and IP3 as described in LRA 013 8.1.38 SecionB.138.NL-07-153 Audit item Section B.1.38. P3: 173 This new program will be implemented consistent with December 12, the corresponding program described in-NUREG-2015 1801 Section XI.M13, Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program. " _....P2: NL-07-039 A.2.1.39 28 Enhance the Water Chemistry Control -Closed September
: 28. Y A.3.1.39 Cooling Water Program to maintain Water chemistry of Setme 28 A. .3..2013 8 .1.40 the IP2 SBO/Appendix R diesel generator cooling NL-08-057 Audit item system per EPRI guidelines.
NP80 509.-:: ....I P3: ...509 Enhance the Water Chemistry Control -Closed: December 12, Cooling-Water Program to maintain the IP2 and IP3 2015 security generator and fire protection diesel cooling water pH and glycol within limits specified by EPRI guidelines.
29 Enhance the Water Chemistry Control -Primary and IP2: NL-07-039 A.2.1.40 Secondary Program forlP2 to test sulfates monthly in September 28, B.1.41 Seodr Porm2013 the RWST with a limit of <150 ppb.
* __30 For aging management of the reactor vessel internals, IP2: NL-07-039 A.2.1.41 IPEC will (1) participate in the industry programs for September 28, A.3.1.41 2011 investigating and managing aging effects on reactor 011 internals; (2) evaluate and implement the results of IP3: the industry programs as applicable to the reactor December 12, internals; and (3) upon completion of these programs;but not less than 24 months before entering the period 2013..of extended operation, submit an inspection plan for reactor internals to the NRC for review and approval.-IP2: NL-07-039 A.2.2.1.2 31 Additional P-T curves will be submitted as required per 10 CFR 50, Appendix G prior to the period of. S28, 2013 4.2.3 extended operation as part of the Reactor.Vessel Surveillance Program. I P3.-.-- --- ----, .December12, 2 .. -2015 32 As required by 10 CFR 50.61 (b)(4), IP3 will submit a IP3: NL-07-039 A.3.2.1.4 plant-specific safety analysis for plate B2803-3 to the December 12, 4.2.5 NRC three years prior toreaching the RTPTS 2015 NL-08-127 screening criterion.
Alternatively, the site may choose to implement the revised PTS rule when approved.
Attachment 2 NL-09-111 Page 16 of 18 COMMITMENT
-IMPLEMENTATION SOURCE. RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 33 At least 2 years prior to entering the period of extended operation, for the locations identified in LRA'Table 4.3-13 (1 P2) and LRA Table 4.3-14 (1 P3),- under the Fatigue Monitoring Program, IP2 and IP3 will implement one or more of the following:_
(1) Consistent with the Fatigue Monitoring Program, Detection of Aging Effects, update the fatigue usage.calculations using&#xfd; refined fatigue analyses to determine valid CUFs less than 1.0 when accounting.
for the effects of reactor water environment.
This-includes applying the appropriate Fen factors to valid,.-CUFs determined in accordance with one of the,-following:
: 1. For locations in LRA Table 4.3-13 (1P2) and LRA Table 4.3-14 (IP3), with existing fatigue analysis valid for the period of extended operation, use the existing CUF: _- -2. Additional plant-specific locations with a valid CUF may be evaluated.
In particular, the pressurizer lower shell Will be reviewed the surge nozzle remains the limiting component.
: 3. Representative CUF values from other plants, adjusted to or enveloping the IPEC plant specific--..
external loads may be used if demonstrated applicable to IPEC.: 4. An analysis using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case) may be-,,-performed to determine a valid CUF.(2) Consistent with the Fatigue Monitoring Program, Corrective Actions, repair or replace the affected locations before exceeding a CUF of 1.0.IP2:, September 28, 2011 I P3: December 12, 2013 NL-07-039 NL-07-153 NL-08-021 A.2.2.2.3 A.3.2.2.3 4.3.3 Audit item 146 34 1P2 SBO / Appendix R diesel generator will be April 30, 2008 NL-07-078 2.1.1.3.5 installed and operational by April 30, 2008. This committed change to the facility meets the- CmpleteNL-08--74 requirements of 10 CFR 50.59(c)(1) and, therefore, a license amendment pursuant to 10 CFR 50.90 is not required.
Attachment 2 NL-09-1 11 Page 17 of 18 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 35 Perform a one-time inspection of. representative.
I P2: NL-08-127 Audit Item sample area of IP2 containment liner affected by the September 28, 27 1973 event behind the insulation, prior to entering the 013 extended period of operation, to assure liner degradation is not occurring in this area.Perform a one-time inspection of representative
.lP3: sample area of the I P3 containment steel liner at the December 12, juncture with the concrete floor slab, prior to entering 015 the extended period-of operation, to assure liner,.degradation is not occurring-in this:area.
-Any degradation will be evaluated for updating of the NL-09-018 containment liner analyses as needed'.1P2: NL-08-127 Audit Item 36 Perform a one-time-Inspection and evaluation of a SPtembert28, 359 sample of-potentially affected IP2 refueling cavity September 2 concrete prior to the period of extended operation.
013 The sample will be obtained by core boring the-refueling cavity wall in an area that is susceptible to exposure to borated water leakage. The inspection will include an assessment of embedded reinforcing steel.Additional core bore samples will be taken,-if the NL-09-056 leakage is not stopped, prior to the end-of the first ten-years of the period of extended operation.L A sample of leakage fluid will be analyzed to NL-09-079 determine the composition of the fluid. If additional core samples are taken prior to the end of the first ten.-years of the period of extended operation,-
a sample- of leakage fluid will be analyzed.-;
_-_._-"P2: -NL-08-127 Audit Item 37 Enhance the Containment Inservice Inspection (Ci2- Ip2: 28, 361 IWL) Program to include inspections of the containment using enhanced characterization of 2 .013 degradation (i.e., quantifying the-dimensions of noted IP: indications through the use of optical aids)during the December 12, period of extended operation.
The enhancement 01 -.I-, .2 0 1 5 7- ... ... ..- -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.
_
Attachment 2 NL-09-111 Page 18 of 18 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM IP2: NL-08-143 4.2.1 38 For Reactor Vessel Fluence, should future core loading patterns invalidate-the basisfor the projected September 28, values of RTpts or CvUSE, updated calculations will 013 be provided to the NRC-. I P3: December 12,.-__....._ 2015 39 Deleted NL-09-079 40I P2: NL-09-106 B.1.6 40 Evaluate plant spcf-i and appropriate industry~
September 28, B.1.22 operating experience and incorporate lessons learned 013 B.1.22 2013 B.1.23 in establishing appropriate monitoring-and inspection B.1.24 frequencies to assess aging-effects for.the new aging.. P3 B.1.25 management programs.
Documentation of the D m 1 B.1.25 operating experience evaluatedofor each new program- Dcme 12, B.1.28 will be available on site for NRC review prior to thej 2015 B.1.28 period of extended operation.
B.1.37 B.1.38}}

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