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| issue date = 07/05/2013
| 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
| 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 name = Trapp J
| author affiliation = NRC/RGN-I/DRS/EB1
| author affiliation = NRC/RGN-I/DRS/EB1
| addressee name = Ventosa J A
| addressee name = Ventosa J
| addressee affiliation = Entergy Nuclear Operations, Inc
| addressee affiliation = Entergy Nuclear Operations, Inc
| docket = 05000247
| docket = 05000247
Line 14: Line 14:
| page count = 43
| page count = 43
}}
}}
See also: [[followed by::IR 05000247/2013009]]
See also: [[see also::IR 05000247/2013009]]


=Text=
=Text=
{{#Wiki_filter:                                                 UNITED STATES                         NUCLEAR REGULATORY COMMISSION                                                           REGION I                           2100 RENAISSANCE BOULEVARD, SUITE 100  
{{#Wiki_filter:UNITED STATES
                        KING OF PRUSSIA, PENNSYLVANIA 19406-2713 July 5, 2013 Mr. John Ventosa Site Vice President  
                              NUCLEAR REGULATORY COMMISSION
Entergy Nuclear Operations, Inc.  
                                                REGION I
Indian Point Energy Center  
                              2100 RENAISSANCE BOULEVARD, SUITE 100
450 Broadway, GSB Buchanan, NY 10511-0249
                            KING OF PRUSSIA, PENNSYLVANIA 19406-2713
SUBJECT: INDIAN POINT NUCLEAR GENERATING UNIT 2 - NRC LICENSE RENEWAL
                                            July 5, 2013
  TEAM INSPECTION REPORT 05000247/2013009  
Mr. John Ventosa
Dear Mr. Ventosa:
Site Vice President
On May 23, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a team  
Entergy Nuclear Operations, Inc.
inspection at your Indian Point Nuclear Generating Unit 2. The enclosed inspection report  
Indian Point Energy Center
documents the inspection results, which were discussed on May 23, 2013 with Mr. Donald  
450 Broadway, GSB
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  
Buchanan, NY 10511-0249
reviewed selected procedures and records, observed activities, and interviewed personnel.  
SUBJECT:       INDIAN POINT NUCLEAR GENERATING UNIT 2 - NRC LICENSE RENEWAL
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  
                TEAM INSPECTION REPORT 05000247/2013009
the commitments reviewed during this inspection were determined to merit additional  
Dear Mr. Ventosa:
assessment during our planned follow-up license renewal inspection scheduled for September 2013.  
On May 23, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a team
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  
inspection at your Indian Point Nuclear Generating Unit 2. The enclosed inspection report
NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
documents the inspection results, which were discussed on May 23, 2013 with Mr. Donald
      Sincerely,  
Mayer and other members of your staff.
The inspectors examined activities conducted by your staff to complete commitments Entergy
        /RA/         James M. Trapp, Chief  
made as part of your application for a renewed facility operating license. The inspectors also
      Engineering Branch 1  
reviewed selected procedures and records, observed activities, and interviewed personnel.
      Division of Reactor Safety  
No findings were identified during this inspection. The team concluded that Entergy had made
Docket No. 50-247 License No.   DPR-26
sufficient progress to complete our review of 30 commitments during this inspection. Eleven of
Mr. John Ventosa Site Vice President
the commitments reviewed during this inspection were determined to merit additional
Entergy Nuclear Operations, Inc. Indian Point Energy Center 450 Broadway, GSB
assessment during our planned follow-up license renewal inspection scheduled for September
Buchanan, NY 10511-0249
2013.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its
SUBJECT:  INDIAN POINT NUCLEAR GENERATING UNIT 2 - NRC LICENSE RENEWAL 
enclosure, and your response (if any) will be available electronically for public inspection in the
  TEAM INSPECTION REPORT 05000247/2013009  Dear Mr. Ventosa:
NRC Public Document Room or from the Publicly Available Records (PARS) component of
NRCs Agencywide Document Access and Management System (ADAMS). ADAMS is
On May 23, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a team
accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public
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.
Electronic Reading Room).
                                                      Sincerely,
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.   
                                                      /RA/
No findings were identified during this inspection.  The team concluded that Entergy had made
                                                      James M. Trapp, Chief
sufficient progress to complete our review of 30 commitments during this inspection.  Eleven of
                                                      Engineering Branch 1
the commitments reviewed during this inspection were determined to merit additional
                                                      Division of Reactor Safety
assessment during our planned follow-up license renewal inspection scheduled for September 2013. 
Docket No.     50-247
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
License No.     DPR-26
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 Management 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 Distribution:  See Next Page DOCUMENT NAME:  \\nrc.gov\nrc\R1\Office\DRS\Engineering Branch 1\-- Meyer\Indian Pt TI 2516 001\Inspection Report\20130701 05000247 IPEC TI 2516-001 Inpsection Report.docx ADAMS ACCESSION NUMBER:  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  OFFICIAL RECORD COPY 
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 inspection, 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 where 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 expected, 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, the 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 1x1017 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 Leaching 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, the 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 1017 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 1019 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 experience 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 methodology 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, Emergency 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, Attachment 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 (1st 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 


ML13186A179
                                              Non-Sensitive                            Publicly Available
        SUNSI Review
                                              Sensitive                                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
              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
                                  i                            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 inspection, 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.
                                            ii                                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
    Commissions 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.
                                                                                      Enclosure
                                                  2
      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 staffs 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
                                                                                        Enclosure
                                                3
    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
                                                                                        Enclosure
                                                4
    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 where 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).
                                                                                        Enclosure
                                              5
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.
                                                                                        Enclosure
                                                6
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.
                                                                                        Enclosure
                                              7
      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.
                                                                                        Enclosure
                                                8
      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.
                                                                                      Enclosure
                                                9
      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 expected, 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.
                                                                                      Enclosure
                                                10
      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.
                                                                                      Enclosure
                                                  11
.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 Entergys 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 Entergys 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.
                                                                                        Enclosure
                                                12
      Findings and Observations
      No findings were identified; however, the 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.
                                                                                        Enclosure
                                              13
      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 1x1017 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 Leaching 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 Entergys 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
                                                                                      Enclosure
                                              14
      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, the 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 Entergys 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.
                                                                                      Enclosure
                                                15
      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.
                                                                                      Enclosure
                                                16
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.
                                                                                      Enclosure
                                                17
      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
      Entergys 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.
                                                                                      Enclosure
                                                  18
.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.
                                                                                          Enclosure
                                                19
      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 1017 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 1019 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 experience 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.
                                                                                          Enclosure
                                                20
      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.
                                                                                        Enclosure
                                                21
.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 methodology 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 WESTEMS' Design CUF module.
.2.38 Commitment 45: Entergy will not use the ASME Code Section III, NB-3600 option of the
      WESTEMS' 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
                                                                                        Enclosure
                                              22
      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.
                                                                                      Enclosure
                                                23
      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
                                                                                          Enclosure
                                            24
  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
                                                                                      Enclosure
                                              25
    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
                                                                                    Enclosure
                                              A-1
                              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
                                                                                  Attachment
                                            A-2
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
                                                                              Attachment
                                              A-3
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
                                                                                  Attachment
                                              A-4
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
                                                                                    Attachment
                                              A-5
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, Emergency 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
                                                                                  Attachment
                                                  A-6
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, Attachment 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
                                                                                      Attachment
                                            A-7
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 (1st 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)
                                                                                  Attachment
                                              A-8
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
                                                                                Attachment
                                                A-9
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
                                                                                    Attachment
                                              A-10
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
                                                                                      Attachment
                                              A-11
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
                                                                                      Attachment
                                              A-12
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
                                                                                Attachment
}}
}}

Latest revision as of 17:18, 4 November 2019

IR 05000247-13-009; 05/6/2013 to 05/23/2013; Indian Point Nuclear Generating Unit 2; License Renewal Team Inspection
ML13186A179
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 07/05/2013
From: James Trapp
Engineering Region 1 Branch 1
To: Ventosa J
Entergy Nuclear Operations
References
IR-13-009
Download: ML13186A179 (43)
v • d • e


See also: IR 05000247/2013009

Text

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 NRCs 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

NRCs Agencywide Document Access and Management 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

Non-Sensitive Publicly Available

SUNSI Review

Sensitive 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

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

i 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 inspection, 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.

ii 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

Commissions 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.

Enclosure

2

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 staffs 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

Enclosure

3

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

Enclosure

4

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 where 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).

Enclosure

5

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.

Enclosure

6

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.

Enclosure

7

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.

Enclosure

8

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.

Enclosure

9

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 expected, 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.

Enclosure

10

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.

Enclosure

11

.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 Entergys 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 Entergys 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.

Enclosure

12

Findings and Observations

No findings were identified; however, the 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.

Enclosure

13

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 1x1017 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 Leaching 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 Entergys 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

Enclosure

14

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, the 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 Entergys 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.

Enclosure

15

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.

Enclosure

16

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.

Enclosure

17

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

Entergys 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.

Enclosure

18

.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.

Enclosure

19

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 1017 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 1019 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 experience 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.

Enclosure

20

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.

Enclosure

21

.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 methodology 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 WESTEMS' Design CUF module.

.2.38 Commitment 45: Entergy will not use the ASME Code Section III, NB-3600 option of the

WESTEMS' 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

Enclosure

22

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.

Enclosure

23

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

Enclosure

24

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

Enclosure

25

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

Enclosure

A-1

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

Attachment

A-2

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

Attachment

A-3

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

Attachment

A-4

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

Attachment

A-5

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, Emergency 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

Attachment

A-6

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, Attachment 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

Attachment

A-7

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 (1st 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)

Attachment

A-8

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

Attachment

A-9

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

Attachment

A-10

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

Attachment

A-11

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

Attachment

A-12

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

Attachment

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