ML14330A324

Seabrook Station - Update to the PWR Vessel Internals Program

ML14330A324
Person / Time
Site:	Seabrook
Issue date:	11/21/2014
From:	Curtland D A NextEra Energy Seabrook
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML14330A324 (21)

Text

NExTeraEN E RGY QýNovember 21, 201410 CFR 54SBK-L- 14212Docket No. 50-443U. S. Nuclear Regulatory Commission Attn: Document Control DeskWashington, DC 20555-0001 Seabrook StationUpdate to the PWR Vessel Internals Program

References:

1. NextEra Energy Seabrook, LLC letter SBK-L- 10077, "Seabrook Station Application forRenewed Operating License,"

May 25, 2010. (Accession Number ML101590099)

2. NextEra Energy Seabrook, LLC letter SBK-L-14089, "Response to Request forAdditional Information Related to the Review of The Seabrook Station License RenewalApplication-Set 21 (Tag No. ME4028),"

June 24, 2014 (Accession NumberML14177A502)

3. NextEra Energy Seabrook, LLC letter SBK-L-14173,

" Fourth Annual Update to theNextEra Energy Seabrook License Renewal Application,"

October 2, 2014 (Accession Number ML14282A023)

In Reference 1, NextEra Energy Seabrook, LLC submitted an application for a renewed facilityoperating license for Seabrook Station Unit 1 in accordance with the Code of FederalRegulations, Title 10, Parts 50, 51, and 54.In Reference 2, NextEra Energy Seabrook, LLC submitted a revised PWR Vessel Internals program in accordance with the guidance provided in LR-ISG-2011-04, "Updated AgingManagement Criteria for Reactor Vessel Internal Components for Pressurized Water Reactors."

In Reference 3, NextEra Energy Seabrook, LLC provided a due date of November 30, 2014 forsubmitting a schedule related to the confirmation and acceptability of the implementation ofMRP-227-A by addressing the plant-specific Applicant/Licensee Action Items outlined insection 4.2 of the NRC SER.,Au4-U.S. Nuclear Regulatory Commission SBK-L-14212/Page 2Enclosure 1 provides the schedule for the completion of these Applicant/Licensee Action Items.Enclosure 2 provides the revised LRA Appendix A -Updated Final Safety Analysis ReportSupplement Table A.3, License Renewal Commitment List. Commitment

1. 1 has been revised asa result of this Supplement.

Provided in this Supplement are changes to the LRA. To facilitate understanding, the changes areexplained, and where appropriate, portions of the LRA are repeated with the change highlighted by strikethroughs for deleted text and bolded italics for inserted text.If there are any questions or additional information is needed, please contact Mr. Edward J.Carley, Engineering Supervisor

-License Renewal, at (603) 773-7957.

If you have any questions regarding this correspondence, please contact Mr. Michael H. OssingLicensing

Manager, at (603) 773-7512.

U.S. Nuclear Regulatory Commission SBK-L-14212/Page 3I declare under penalty of perjury that the foregoing is true and correct.Executed on November,__

2014.Sincerely, NextEra Energy Seabrook, LLCDean CurtlandSite Vice President

Enclosures:

Enclosure 1- Update to the PWR Vessel Internals ProgramEnclosure 2- LRA Appendix A -Final Safety Analysis Report Supplement Table A.3, LicenseRenewal Commitment List Updated to Reflect Changes to Datecc: W. M. Dean NRC Region I Administrator J. G. Lamb NRC Project ManagerP. C. Cataldo NRC Senior Resident Inspector R. A. Plasse NRC Project Manager, License RenewalL. M. James NRC Project Manager, License RenewalMr. Perry PlummerDirector Homeland Security and Emergency Management New Hampshire Department of SafetyDivision of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen DriveConcord, NH 03305Mr. John Giarrusso, Jr., Nuclear Preparedness ManagerThe Commonwealth of Massachusetts Emergency Management Agency400 Worcester RoadFramingham, MA 01702-5399 Enclosure 1 to SBK-L-14212 Update to the PWR Vessel Internals Program U.S. Nuclear Regulatory Commission SBK-L-14212/Enclosure 1/Page 2Update to the PWR Vessel Internals ProgramBy letter SBK-L-14089 (Reference 2), NextEra Energy Seabrook submitted a revised PWRVessel Internals program in accordance with the guidance provided in LR-ISG-2011-04, "Updated Aging Management Criteria for Reactor Vessel Internal Components for Pressurized Water Reactors."

By letter SBK-L-14173 (Reference 3), NextEra Energy provided a due date of November 30,2014 for submitting a schedule related to the confirmation and acceptability of theimplementation of MRP-227-A by addressing the plant-specific Applicant/Licensee ActionItems outlined in section 4.2 of the NRC SER (Commitment

1. 1).As previously stated in SBK-L-14173 (Reference 3), NextEra Energy Seabrook is currently participating in the PWR Owners Group to address these plant-specific Applicant/Licensee Action Items. The NSSS supplier has established a Project Team to support completion of theseitems. Project completion is currently scheduled for May 31, 2015. As a result, Commitment

1. 1has been revised as follows:PROGRAM or UFSARNo. COMMITMENT SCHEDULETOPIC LOCATIONProvide confirmation and acceptability of the Seabrook E iel prgy i.ePWR Vessel implementation of MRP-227-A by addressing a zubmtwia scheduleInternals the plant-specific Applicant/Licensee Action A.2.1.7 a s ,t .... u eItems outlined in section 4.2 of the NRC byNvm-4,.

SER.May 31, 2015 Enclosure 2 to SBK-L-14212 LRA Appendix A -Final Safety Analysis Report Supplement Table A.3,License Renewal Commitment List Updated to Reflect Changes to Date U.S. Nuclear Regulatory Commission SBK-L-14212/Enclosure 2/Page 2A.3 LICENSE RENEWAL COMMITMENT LISTUFSARPROGRAM or TOPIC COMMITMENT SCHEDULELOCATION,NextEra Energy Seabroek

-willProvide confirmation and acceptability of the implementation of ..... xa Enbmitt lseelk biylPWR Vessel Internals MRP-227-A by addressing the plant-specific Applicant/Licensee A.2.1.7 November 30, .Action Items outlined in section 4.2 of the NRC SER.May 31, 2015Closed-Cycle Cooling Enhance the program to include visual inspection for cracking, loss Prior to the period of extendedWater of material and fouling when the in-scope systems are opened for A.2.1.12 operation.

maintenance.

Inspection of OverheadHeavy Load and Light Enhance the program to monitor general corrosion on the crane andLoad (Related to trolley structural components and the effects of wear on the rails in A.2.1.13 prratoteRefueling)

Handling the rail system. operation.

SystemsInspection of OverheadHeavy Load and Light Prior to the period of extendedLoad (Related to Enhance the program to list additional cranes for monitoring.

A.2.1.13 operation.

Refueling)

HandlingSystemsCompressed Air Enhance the program to include an annual air quality test requirement A.2.1.14 Prior to the period of extendedMonitoring for the Diesel Generator compressed air sub system. operation.

Fire Protection Enhance the program to perform visual inspection of penetration A.2.1.15 Prior to the period of extendedseals by a fire protection qualified inspector.

operation.

Enhance the program to add inspection requirements such as spalling, Prior to the period of extendedFire Protection and loss of material caused by freeze-thaw, chemical attack, and A.2.1.15 operation.

reaction with aggregates by qualified inspector.

U.S. Nuclear Regulatory Commission SBK-L- 14212/Enclosure 2/Page 3Enhance the program to include the performance of visual inspection Prior to the period of extendedof fire-rated doors by a fire protection qualified inspector.

operation.

Enhance the program to include NFPA 25 (2011 Edition) guidancefor "where sprinklers have been in place for 50 years, they shall be Prior to the period of extended9. Fire Water System replaced or representative samples from one or more sample areas A.2.1.16 operation.

shall be submitted to a recognized testing laboratory for field servicetesting".

Enhance the program to include the performance of periodic flow Prior to the period of extended10. Fire Water System testing of the fire water system in accordance with the guidance of A.2.1.16 operation.

NFPA 25 (2011 Edition).

Enhance the program to include the performance of periodic visual orvolumetric inspection of the internal surface of the fire protection system upon each entry to the system for routine or corrective maintenance to evaluate wall thickness and inner diameter of the fireprotection piping ensuring that corrosion product buildup will notresult in flow blockage due to fouling.

Where surface irregularities II. Fire Water System are detected, follow-up volumetric examinations are performed.

A.2116 Within ten years prior to theThese inspections will be documented and trended to determine if a period of extended operation.

representative number of inspections have been performed prior tothe period of extended operation.

If a representative number ofinspections have not been performed prior to the period of extendedoperation, focused inspections will be conducted.

These inspections will be performed within ten years prior to the period of extendedoperation.

Enhance the program to include components and aging effectsAboveground Steel required by the Aboveground Steel Tanks and to perform visual, Within 10 years prior to the12. Tanks surface, and volumetric examinations of the outside and inside A.2.1.17 period of extended operation.

surfaces for managing the aging effects of loss of material andcracking.

U.S. Nuclear Regulatory Commission SBK-L- 14212/Enclosure 2/Page 4Enhance the program to perform exterior inspection of the fire waterstorage tanks annually for signs of degradation and include an Within ten years prior to the13. Fire Water System ultrasonic inspection and evaluation of the internal bottom surface of A.2.1.16 period of extended operation.

the two Fire Protection Water Storage Tanks per the guidanceprovided in NFPA 25 (2011 Edition).

Enhance program to add requirements to 1) sample and analyze newfuel deliveries for biodiesel prior to offloading to the Auxiliary Boiler Prior to the period of extended14. Fuel Oil Chemistry fuel oil storage tank and 2) periodically sample stored fuel in the A.2.1.18 operation.

Auxiliary Boiler fuel oil storage tank.Enhance the program to add requirements to check for the presence Prior to the period of extended15. Fuel Oil Chemistry of water in the Auxiliary Boiler fuel oil storage tank at least once per A.2.1.18 operation.

quarter and to remove water as necessary.

Enhance the program to require draining, cleaning and inspection of Prior to the period of extended16. Fuel Oil Chemistry the diesel fire pump fuel oil day tanks on a frequency of at least once A.2.1.18 operation.

every ten years.Enhance the program to require ultrasonic thickness measurement ofthe tank bottom during the I 0-year draining, cleaning and inspection Prior to the period of extended17. Fuel Oil Chemistry of the Diesel Generator fuel oil storage tanks, Diesel Generator fuel A.2.1.18 operation.

oil day tanks, diesel fire pump fuel oil day tanks and auxiliary boilerfuel oil storage tank.Reactor Vessel Enhance the program to specify that all pulled and tested capsules, A.2.1.19 Prior to the period of extended18. Surveillance unless discarded before August 31, 2000, are placed in storage.

operation.

Enhance the program to specify that if plant operations exceed thelimitations or bounds defined by the Reactor Vessel Surveillance Reactor Vessel Program, such as operating at a lower cold leg temperature or higher A.2.1.19 Prior to the period of extended19. Surveillance

fluence, the impact of plant operation changes on the extent of operation.

Reactor Vessel embrittlement will be evaluated and the NRC will benotified.

U.S. Nuclear Regulatory Commission SBK-L-14212/Enclosure 2/Page 5Enhance the program as necessary to ensure the appropriate withdrawal schedule for capsules remaining in the vessel such thatone capsule will be withdrawn at an outage in which the capsuleReactor Vessel receives a neutron fluence that meets the schedule requirements of 10 A.2.1.19 Prior to the period of extended20. Surveillance CFR 50 Appendix H and ASTM E185-82 and that bounds the operation.

60-year fluence, and the remaining capsule(s) will be removed fromthe vessel unless determined to provide meaningful metallurgical data.Enhance the program to ensure that any capsule removed, without theReactor Vessel intent to test it, is stored in a manner which maintains it in a condition A.2.1.19 Prior to the period of extended21. Surveillance which would permit its future use, including during the period of operation.

extended operation.

Within ten years prior to the22. One-Time Inspection Implement the One Time Inspection Program.

A.2.1.20 period of extended operation.

Implement the Selective Leaching of Materials Program.

TheSelective Leachingy of program will include a one-time inspection of selected components Within five years prior to the23. where selective leaching has not been identified and periodic A.2.1.21 period of extended operation.

inspections of selected components where selective leaching has beenidentified.

Buried Piping And Implement the Buried Piping And Tanks Inspection Program.

Within ten years prior to24. Tanks Inspection A.2. 1.22 entering the period of extendedoperation tion Implement the One-Time Inspection of ASME Code Class I Small Within ten years prior to the25. of ASME Code Class 1 ipl nt teoneTme A.2.1.23 period of extended operation.

Small Bore-Piping Bore-Piping Program.p Enhance the program to specifically address the scope of theExternal Surfaces

program, relevant degradation mechanisms and effects of interest, the Prior to the period of extended26. Monitoring refueling outage inspection frequency, the training requirements for A.2.1.24 operation.

inspectors, and the required periodic reviews to determine programeffectiveness.

U.S. Nuclear Regulatory Commission SBK-L- I 4212/Enclo sure 2/Page 6Inspection of InternalSurfaces in Implement the Inspection of Internal Surfaces in Miscellaneous Prior to the period of extended27. Miscellaneous Piping Piping and Ducting Components Program.

A.2.1.25 operation.

and DuctingComponents

28. Lubricating Oil Enhance the program to add required equipment, lube oil analysis A.2.1.26 Prior to the period of extendedAnalysis

required, sampling frequency, and periodic oil changes.

operation.

29. Lubricating Oil Enhance the program to sample the oil for the Reactor Coolant pump A.2.1.26 Prior to the period of extendedAnalysis oil collection tanks. operation.

Enhance the program to require the performance of a one-time30. Lubricating Oil ultrasonic thickness measurement of the lower portion of the Reactor A.2.1.26 Prior to the period of extendedAnalysis Coolant pump oil collection tanks prior to the period of extended operation.

operation.

31. ASME Section XI, Enhance procedure to include the definition of "Responsible A.2.1.28 Prior to the period of extendedSubsection IWL Engineer".

operation.

32. Structures Monitoring Enhance procedure to add the aging effects, additional locations, A.2.1.31 Prior to the period of extendedProgram inspection frequency and ultrasonic test requirements.

operation.

33. Structures Monitoring Enhance procedure to include inspection of opportunity when A.2.1.31 Prior to the period of extendedProgram planning excavation work that would expose inaccessible concrete.

operation.

U.S. Nuclear Regulatory Commission SBK-L- 14212/Enclosure 2/Page 7Electrical Cables andConnections NotSubject to 10 CFR Implement the Electrical Cables and Connections Not Subject to 1034. 50.49 Environmental CFR 50.49 Environmental Qualification Requirements program.Qualification Requirements Electrical Cables andConnections NotSubject to 10 CFR Implement the Electrical Cables and Connections Not Subject to 1035. 50.49 Environmental CFR 50.49 Environmental Qualification Requirements Used inRequirements Used in Instrumentation Circuits program.Instrumentation CircuitsInaccessible PowerCables Not Subject to10 CFR 50.49 Implement the Inaccessible Power Cables Not Subject to 10 CFR36. Environmental 50.49 Environmental Qualification Requirements program.Qualification Requirements

37. Metal Enclosed Bus Implement the Metal Enclosed Bus program.38. Fuse Holders Implement the Fuse Holders program.Prior to the period of extendedoperation.

Prior to the period of extendedoperation.

Prior to the period of extendedoperation.

,eration.

on.

U.S. Nuclear Regulatory Commission SBK-L- 14212/Enclosure 2/Page 8Electrical CableConnections NotSubject to 10 CFR Implement the Electrical Cable Connections Not Subject to 10 CFR Prior to the period of extended50.49 Environmental 50.49 Environmental Qualification Requirements program.

A.2.1.37 operation.

Qualification Requirements Prior to the period of extended40. 345 KV SF6 Bus Implement the 345 KV SF6 Bus program.

A.2.2.1 operation.

Metal Fatigue of Prior to the period of extended41. Reactor Coolant Enhance the program to include additional transients beyond those A.2.3.1Poraton.

PRessur Bound defined in the Technical Specifications and UFSAR. operation.

Pressure BoundaryMetal Fatigue of Enhance the program to implement a software

program, to count Prior to the period of extended42. Reactor Coolant transients to monitor cumulative usage on selected components.

A.2.3.1 operation.

Pressure BoundaryPressure

-Temperature The updated analyses will beLimits, including Low Seabrook Station will submit updates to the P-T curves and LTOP submitted at the appropriate time43. Temperature limits to the NRC at the appropriate time to comply with 10 CFR 50 A.2.4.1.4 to comply with 10 CFR 50Overpressure Appendix G. Appendix G, FractureProtection Limits Toughness Requirements.

U.S. Nuclear Regulatory Commission SBK-L- 14212/Enclosure 2/Page 944.Environmentally-Assisted FatigueAnalyses (TLAA)NextEra Seabrook will perform a review of design basis ASME Class1 component fatigue evaluations to determine whether theNUREG/CR-6260-based components that have been evaluated foithe effects of the reactor coolant environment on fatigue usage are thelimiting components for the Seabrook plant configuration.

If morelimiting components are identified, the most limiting component willbe evaluated for the effects of the reactor coolant environment onfatigue usage. If the limiting location identified consists of nickelalloy, the environmentally-assisted fatigue calculation for nickel alloywill be performed using the rules of NUREG/CR-6909.

(1) Consistent with the Metal Fatigue of Reactor Coolant PressureBoundary Program Seabrook Station will update the fatigue usagecalculations using refined fatigue analyses, if necessary, to determine acceptable CUFs (i.e., less than 1.0) when accounting for the effectsof the reactor water environment.

This includes applying theappropriate Fen factors to valid CUFs determined from an existingfatigue analysis valid for the period of extended operation or from ananalysis using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case).(2) If acceptable CUFs cannot be demonstrated for all the selectedlocations, then additional plant-specific locations will be evaluated.

For the additional plant-specific locations, if CUF, including environmental effects is greater than 1.0, then Corrective Actions willbe initiated, in accordance with the Metal Fatigue of Reactor CoolantPressure Boundary

Program, B.2.3. 1. Corrective Actions willinclude inspection, repair, or replacement of the affected locations before exceeding a CUF of 1.0 or the effects of fatigue will bemanaged by an inspection program that has been reviewed andapproved by the NRC (e.g., periodic non-destructive examination ofthe affected locations at inspection intervals to be determined by amethod accepted by the NRC).A.2.4.2.3 At least two years prior toentering the period of extendedoperation.

U.S. Nuclear Regulatory Commission SBK-L-14212/Enclosure 2/Page 1045. Number Not UsedProtective Coating Enhance the program by designating and qualifying an Inspector Prior to the period of extended46. Monitoring and Coordinator and an Inspection Results Evaluator.

operation.

Maintenance Enhance the program by including, "Instruments and Equipment Protective Coating needed for inspection may include, but not be limited to, flashlight, Prior to the period of extended47. Monitoring and spotlights, marker pen, mirror, measuring tape, magnifier, binoculars, A.2.1.38 prratoteMaintenance camera with or without wide angle lens, and self sealing polyethylene sample bags."Protective Coating Enhance the program to include a review of the previous two Prior to the period of extended48. Monitoring and monitoring reports.

A.2.1.38 operation.

Maintenance Protective Coating Enhance the program to require that the inspection report is to be49. Monitoring and evaluated by the responsible evaluation personnel, who is to prepare A.2.1.38 Prior to the period of extendedMaintenance a summary of findings and recommendations for future surveillance operation.

or repair.Baseline inspections werePerform UT of the accessible areas of the containment liner plate in completedo during TOR16. RepeatASME Section X efr To heacsil raso h otimetlnrpaei containment liner UT thickness

50. Subsection the vicinity of the moisture barrier for loss of material.

Perform A.2.1.27 examinations at intervals of nooIWE opportunistic UT of inaccessible areas.more than five (5) refueling outages.51. Number Not UsedASME Section XI, Implement measures to maintain the exterior surface of the52. AS section I, Containment Structure, from elevation

-30 feet to +20 feet, in a A.2.1.28 Ongoingdewatered state.Reactor Head Closure Replace the spare reactor head closure stud(s) manufactured from the Prior to the period of extended53. Studs bar that has a yield strength

> 150 ksi with ones that do not exceed A.2.1.3 operation.

150 ksi.

U.S. Nuclear Regulatory Commission SBK-L- 14212/Enclosure 2/Page 1154.Steam Generator TubeIntegrity NextEra will address the potential for cracking of the primary tosecondary pressure boundary due to PWSCC of tube-to-tubesheet welds using one of the following two options:1) Perform a one-time inspection of a representative sample of tube-to-tubesheet welds in all steam generators to determine if PWSCCcracking is present and, if cracking is identified, resolve the condition through engineering evaluation justifying continued operation orrepair the condition, as appropriate, and establish an ongoingmonitoring program to perform routine tube-to-tubesheet weldinspections for the remaining life of the steam generators, or2) Perform an analytical evaluation showing that the structural integrity of the steam generator tube-to-tubesheet interface isadequately maintaining the pressure boundary in the presence oftube-to-tubesheet weld cracking, or redefining the pressure boundaryin which the tube-to-tubesheet weld is no longer included and,therefore, is not required for reactor coolant pressure boundaryfunction.

The redefinition of the reactor coolant pressure boundarymust be approved by the NRC as part of a license amendment request.A.2.1.10CompleteWithin five years prior toSteam Generator Tube Seabrook will perform an inspection of each steam generator to Wetein the priod o55. Integrity assess the condition of the divider plate assembly.

operation.

Closed-Cycle Cooling Revise the station program documents to reflect the EPRI Guideline A.2.1.12 Prior to entering the period of56. Water System operating ranges and Action Level values for hydrazine and sulfates.

extended operation.

Closed-Cycle Cooling Revise the station program documents to reflect the EPRI Guideline Prior to entering the period ofWater System operating ranges and Action Level values for Diesel Generator A.2.1.12 extended operation.

Cooling Water Jacket pH.Update Technical Requirement Program 5.1, (Diesel Fuel Oil Testing Prior to the period of extended58. Fuel Oil Chemistry Program)

ASTM standards to ASTM D2709-96 and ASTM D4057- A.2.1.18 operation.

95 required by the GALL XI.M30 Rev I U.S. Nuclear Regulatory Commission SBK-L-14212/Enclosure 2/Page 12The Nickel Alloy Aging Nozzles and Penetrations program willNickel Alloy Nozzles Prior to the period of extended59. anickenel rations implement applicable Bulletins, Generic Letters, and staff accepted A.2.2.3 prratote59. and Penetrations industry guidelines, operation.

Buried Piping and Implement the design change replacing the buried Auxiliary Boiler Prior to entering the period of60. Tanks Inspection supply piping with a pipe-within-pipe configuration with leak A.2.1.22 extended operation.

detection capability.

Compressed Air Replace the flexible hoses associated with the Diesel Generator air Within ten years prior to61. Monitoring Program compressors on a frequency of every 10 years. A.2.1.14 entering the period of extendedoperation.

62. Water Chemistry Enhance the program to include a statement that sampling A.2.1.2 Prior to the period of extendedfrequencies are increased when chemistry action levels are exceeded.

operation.

Ensure that the quarterly CVCS Charging Pump testing is continued during the PEO. Additionally, add a precaution to the test procedure

63. Flow Induced Erosion to state that an increase in the CVCS Charging Pump mini flow N/A prratoteabove the acceptance criteria may be indicative of erosion of the mini operation.

flow orifice as described in LER 50-275/94-023.

Soil analysis shall be performed prior to entering the period ofextended operation to determine the corrosivity of the soil in thevicinity of non-cathodically protected steel pipe within the scope of Prior to entering the period of64. Buried Piping and this program.

If the initial analysis shows the soil to be non- A.2.1.22 extended operation.

Tanks Inspection corrosive, this analysis will be re-performed every ten yearsthereafter.

65. Flux Thimble Tube Implement measures to ensure that the movable incore detectors are Prior to entering the period ofnot returned to service during the period of extended operation.

N/A extended operation.

66. Number Not Used U.S. Nuclear Regulatory Commission SBK-L-14212/Enclosure 2/Page 13Perform one shallow core bore in an area that was continuously wetted from borated water to be examined for concrete degradation Structures Monitoring and also expose rebar to detect any degradation such as loss of No later than December 31,67. Program material.

The removed core will also be subjected to petrographic A.2.1.31 2015.examination for concrete degradation due to ASR per ASTMStandard Practice C856.Structures Monitoring Perform sampling at the leakoff collection points for chlorides, Quarterly Preventive

68. Program sulfates, pH and iron once every three months. A.2.1.31 Maintenance ActivityImplemented Open-Cycle Cooling Replace the Diesel Generator Heat Exchanger Plastisol PVC lined Arior- 269. Water System Service Water piping with piping fabricated from AL6XN material.

A.2.1.11 ev .CompleteInspect the piping downstream of CC-V-444 and CC-V-446 toClosed-Cycle Cooling determine whether the loss of material due to cavitation induced Within ten years prior to the70. Water System erosion has been eliminated or whether this remains an issue in the A.2.1.12 period of extended operation.

primary component cooling water system.Alkali-Silica Reaction Implement the Alkali-Silica Reaction (ASR) Monitoring Program.71. (ASR) Monitoring Testing will be performed to confirm that parameters being A.2.1.31A Prior to entering the period of7ro ntrg monitored and acceptance criteria used are appropriate to manage the extended operation.

Program effects of ASR.Flow-Accelerated Enhance the program to include management of wall thinning caused Prior to entering the period of72. Corrosion by mechanisms other than FAC. A.2.1.8 extended operation.

Inspection of Internal Enhance the program to include performance of focusedSurfaces in examinations to provide a representative sample of 20%, or a73. Miscellaneous Piping maximum of 25, of each identified

material, environment, and aging A.2.1.25 Prior'to entering the period ofand Ducting effect combinations during each 10 year period in the period of extended operation.

Components extended operation.

IsU.S. Nuclear Regulatory Commission SBK-L-14212/Enclosure 2/Page 14Enhance the program to perform sprinkler inspections annually perthe guidance provided in NFPA 25 (2011 Edition).

Inspection willensure that sprinklers are free of corrosion, foreign materials, paint,74. Fire Water System and physical damage and installed in the proper orientation (e.g., A.2.1.16 Within ten years prior to theupright,

pendant, or sidewall).

Any sprinkler that is painted,

corroded, period of extended operation.

damaged, loaded, or in the improper orientation, and any glass bulbsprinkler where the bulb has emptied, will be evaluated forreplacement.

Enhance the program to conduct an inspection of piping and branchline conditions every 5 years by opening a flushing connection at theend of one main and by removing a sprinkler toward the end of one Within ten years prior to the75. Fire Water System branch line for the purpose of inspecting for the presence of foreign A.2.1.16 period of extended operation.

organic and inorganic material per the guidance provided in NFPA 25(2011 Edition).

Enhance the Program to conduct the following activities annually perthe guidance provided in NFPA 25 (2011 Edition).

Within ten years prior to the76. Fire Water System

• main drain tests A.2.1.16 period of extended operation.

• deluge valve trip tests* fire water storage tank exterior surface inspections The Fire Water System Program will be enhanced to include thefollowing requirements related to the main drain testing per theguidance provided in NFPA 25 (2011 Edition).

77. Fire Water System

• The requirement that if there is a 10 percent reduction in full flow A.2.1.16 Within ten years prior to thepressure when compared to the original acceptance tests or period of extended operation.

previously performed tests, the cause of the reduction shall beidentified and corrected if necessary.

• Recording the time taken for the supply water pressure to returnto the original static (nonflowing) pressure.

U.S. Nuclear Regulatory Commission SBK-L- 14212/Enclosure 2/Page 1578. External Surfaces Enhance the program to include periodic inspections of in-scope A.2.1.8 Prior to the period of extendedMonitoring insulated components for possible corrosion under insulation.

operation.

Enhance the program to include visual inspection of Service Level III79. Open-Cycle Cooling (augmented) internal coatings for loss of coating integrity.

A.2.1.11 Within 10 years prior to theWater System (umne)period of extended operation.

Enhance the program to include visual inspection of Service Level III80. Fire Water System (augmented) internal coatings for loss of coating integrity.

A.2.1.16 Within 10 years prior to theperiod of extended operation.

Enhance the program to include visual inspection of Service Level III81. Fuel Oil Chemistry (augmented) internal coatings for loss of coating integrity.

A.2.1.18 Within 10 yearsdprioretotthe

81. uel il hemit~'period of extended operation.

Inspection of InternalSurfaces in Enhance the program to include visual inspection of Service Level III82. Miscellaneous Piping (augmented) internal coatings for loss of coating integrity.

A.2.1.25 Within 10 yearsdprioretotthe 82iclan eoDuscPipin period of extended operation.

and DuctingComponents Install instrumentation in representative sample areas of structures tomonitor expansion due to alkali-silica reaction in the out-of-plane direction.

Evaluate instrument and pin expansion data under theOperating Experience Element of the Alkali-Silica Reaction83. Alkali-Silica Reaction Monitoring Program to determine whether there is a need to enhance A.2.1.31A Prior to the period of extendedMonitoring the program to monitor expansion in the out-of-plane direction.

If the operation.

evaluation concludes that out-of-plane monitoring is necessary, establish acceptance criteria and monitoring frequencies forexpansion in the out-of-plane direction using the instrument and pinexpansion data.

A ý IU.S. Nuclear Regulatory Commission SBK-L-14212/Enclosure 2/Page 1684. ASME Section XI, Evaluate the acceptability of inaccessible areas for structures within A.2.1.28 Prior to the period of extendedSubsection IWL the scope of ASME Section XI, Subsection IWL Program.

operation.