ML13163A442

Sequoyah, Units 1 and 2 - Response to NRC Request for Additional Information Regarding the Scoping and Screening Methodology Review of the License Renewal Application, Set 3

ML13163A442
Person / Time
Site:	Sequoyah
Issue date:	06/07/2013
From:	Shea J W Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MF0481, TAC MF0482
Download: ML13163A442 (30)

Text

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 June 7, 2013 10 CFR Part 54 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Sequoyah Nuclear Plant, Units 1 and 2 Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327 and 50-328

References:

Response to NRC Request for Additional Information Regarding the Scoping and Screening Methodology Review of the Sequoyah Nuclear Plant, Units I and 2, License Renewal Application, Set 3 (TAC Nos. MF0481 and MF0482)1. TVA Letter to NRC, "Sequoyah Nuclear Plant, Units 1 and 2 License Renewal," dated January 7, 2013 (ADAMS Accession No. ML13024A004)

2. NRC Letter to TVA, "Requests for Additional Information for the Review of the Sequoyah Nuclear Plant, Units 1 and 2, License Renewal Application," dated May 8, 2013 (ADAMS Accession No. ML13122A340)

By letter dated January 7, 2013 (Reference 1), the Tennessee Valley Authority (TVA) submitted an application to the Nuclear Regulatory Commission (NRC) to renew the operating license for the Sequoyah Nuclear Plant, Units 1 and 2. The request would extend the license for an additional 20 years beyond the current expiration date. By letter dated May 8, 2013 (Reference 2), the NRC forwarded a request for additional information (RAI). The required date for the response is within 30 days of the date stated in the RAI, i.e., no later than June 7, 2013.Enclosure 1 to this letter provides TVA's response to the Reference 2 RAI.Enclosure 2 is an updated listing of the regulatory commitments for license renewal. The sole change is to Commitment 31.A, wherein the SQN service building was added as an in-scope structure in the Structures Monitoring Program.Printed on recycled paper U.S. Nuclear Regulatory Commission Page 2 June 7, 2013 Consistent with the standards set forth in 10 CFR 50.92(c), TVA has determined that the additional information, as provided in this letter, does not affect the no significant hazards considerations associated with the proposed application previously provided in Reference 1.Please address any questions regarding this submittal to Henry Lee at (423) 843-4104.I declare under penalty of perjury that the foregoing is true and correct.Executed on this 7 th day of June, 2013.Respe ully, J.. hea V* e lresident, Nuclear Licensing

Enclosures:

1. TVA Responses to NRC Request for Additional Information

2. Regulatory Commitment List, Revision 1 cc (Enclosures):

NRC Regional Administrator-Region II NRC Senior Resident Inspector

-Sequoyah Nuclear Plant ENCLOSURE1 Tennessee Valley Authority Sequoyah Nuclear Plant, Units I and 2 License Renewal TVA Responses to NRC Request for Additional Information NRC RAI 2.1-1

Background:

Title 10 of the Code of Federal Regulations (CFR) 54.4, "Scope," states, in part: (a) Plant systems, structures and components

[SSCs] within the scope of this part are -(1) Safety-related systems, structures, and components which are those relied upon to remain functional during and following design-basis events (as defined in 10 CFR 50.49 (b)(1)) to ensure the following functions

-(i) The integrity of the reactor coolant pressure boundary;(ii) The capability to shut down the reactor and maintain it in a safe shutdown condition; or (iii) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to those referred to in 10 CFR 50.34(a)(1), 10 CFR 50.67(b) (2), or 10 CFR 100.11, as applicable.

Issue: During the on-site scoping and screening methodology audit, the staff determined that the applicant had used a plant equipment database, which provides the component quality classification, as an information source used in identifying SSCs within the scope of license renewal. The plant equipment database uses the terms "safety-related" or "SR" to identify safety-related SSCs. However, during the audit the staff determined that not all components identified as safety-related in the plant equipment database were included within the scope of license renewal in accordance with 10 CFR 54.4(a)(1).

Request: The staff requests that the applicant perform a review of this issue and provide a description of the process used to evaluate components identified as safety-related in the plant equipment database and the basis for not including components identified as safety-related within the scope of license renewal in accordance with 10 CFR 54.4(a)(1).

Indicate if the review concludes that use of the scoping methodology precluded the identification of SSCs that should have included within the scope of license renewal in accordance with 10 CFR 54.4(a)(1).

Describe any additional scoping evaluations performed to address the 10 CFR 54.4(a)(1) criteria.

List any additional SSCs included within the scope of license renewal as a result of the review, and any structures and components (SCs) for which aging management reviews were performed.

E1-1 of 11 TVA Response to RAI 2.1-1 As described in the License Renewal Application (LRA) Sections 2.1.1 and 2.1.2, mechanical components identified as safety-related in the plant equipment database are included within the scope of license renewal in accordance with 10 CFR 54.4(a)(1).

These components are subject to aging management review if they are not subject to replacement based on a qualified life or specified time period, and they perform an intended function, as described in § 54.4, without moving parts or without a change in configuration or properties.

Although some structural components and many electrical components are identified in the plant equipment database as safety-related, neither structural nor electrical scoping and screening use the plant equipment database.

See LRA Sections 2.1.1, 2.1.2.2 and 2.1.2.3 for descriptions of structural and electrical scoping and screening.

In response to the NRC request, mechanical components classified as safety-related in the plant equipment database but determined not to be subject to an aging management review were re-evaluated.

The process used in this re-evaluation was to confirm that these mechanical components are either: (1) Subject to replacement based on a qualified life or specified time period, (2) Perform their intended function with moving parts or a change in configuration or properties, or (3) Do not perform a safety function as defined in 10 CFR 54.4(a)(1).

The review, following the process described above, confirmed that the mechanical components classified as safety-related in the plant equipment database and determined not to be subject to aging management review are either being replaced based on a qualified life or specified time period, perform their intended function with moving parts or a change in configuration or properties.

These components are conservatively classified as safety-related based on management decision but have no safety function as defined in 10 CFR 54.4(a)(1)..

The review concluded that the use of the scoping methodology did not preclude the identification of systems, structures, or components (SSCs) that should have been included within the scope of license renewal in accordance with 10 CFR 54.4(a)(1).

No additional scoping evaluations were necessary to address the 10 CFR 54.4(a)(1) criteria, no additional SSCs were included within the scope of license renewal as a result of this review and no additional aging management reviews were necessary.

E1-2 of 11 NRC RAI 2.1-2

Background:

10 CFR 54.4, "Scope," states, in part: (a) Plant systems, structures and components

[SSCs] within the scope of this part are -(1) Safety-related systems, structures, and components which are those relied upon to remain functional during and following design-basis events (as defined in 10 CFR 50.49 (b)(1)) to ensure the following functions

-(i) The integrity of the reactor coolant pressureboundary;(ii) The capability to shut down the reactor and maintain it in a safe shutdown condition; or (iii) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to those referred to in 10 CFR 50.34(a)(1), 10 CFR 50.67(b)(2), or 10 CFR 100.11, as applicable.

License renewal application (LRA) Section 2.1.1.1, "Application of Safety-Related Scoping Criteria," states, in part: A [Tennessee Valley Authority (TVA)] procedure provides the criteria and methodology for determining and evaluating the safety and quality classification of systems, structures and components.

The procedure defines safety-related or quality assurance category SR as: Those structures systems and components which are important to safety because they perform a function necessary to ensure either:* The integrity of the reactor coolant pressure boundary* The capability to shutdown the reactor and maintain it in a safe condition* The capability to prevent or mitigate the consequences of an incident which could result in potential offsite exposures comparable to those specified in 10 CFR Part 100.Update final safety analysis report (UFSAR) Section 3.2.1, "Seismic Qualifications," states, in part: The Sequoyah Nuclear Plant structures, systems, and components important to safety have been designed to remain functional in the event of a Safe Shutdown Earthquake (SSE). These structures, systems, and components, designated as Category I, are those necessary to assure: 1. The integrity of the reactor coolant pressure boundary.2. The capability to shut down the reactor and maintain it in a safe shutdown condition 3. The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to the guideline exposures of 10 CFR Part 100.Issue: During the on-site scoping and screening methodology audit, the staff reviewed the definitions of the term safety-related contained in the fleet procedures, the UFSAR and the LRA, used to identify SSCs within the scope of license renewal. The staff determined that the LRA Section 2.1.1.1 definition of safety-related is equivalent to the criteria in 10 CFR 54.4(a)(1) and the UFSAR definition of the function of SSCs designated as Category /. However, during its audit, the staff determined that there were structures designated as Category I that were not included within the scope of license renewal in accordance with 10 CFR 54.4(a)(1).

EI-3 of 11 Request: The staff requests that the applicant perform a review of this issue and provide a description of the process used to evaluate structures identified as Category I and the basis for not including the structures within the scope of license renewal in accordance with 10 CFR 54.4(a)(1).

Indicate if the review concludes that use of the scoping methodology precluded the identification of SSCs that should have included within the scope of license renewal in accordance with 10 CFR 54.4(a)(1).

Describe any additional scoping evaluations performed to address the 10 CFR 54.4(a)(1) criteria.

List any additional SSCs included within the scope of license renewal as a result of the review, and any SCs for which aging management reviews were performed.

TVA Response to RAI 2.1-2 In response to the NRC request, a review of UFSAR Section 3.8.4 and Table 3.2.1-1 was performed.

UFSAR Section 3.8.4 and Table 3.2.1-1 lists Sequoyah Nuclear Station (SQN) Category I structures.

The process used in this review was a comparison of the structures in the UFSAR section and table to the structures included within the scope of license renewal in accordance with 10 CFR 54.4(a)(1) as shown in LRA Section 2.4. Differences were then reviewed to determine if the basis for not including structures within the scope of license renewal in accordance with 10 CFR 54.4(a)(1) was appropriate.

The review identified the waste packaging area as a Category I structure that was not included in the scope of license renewal for 10 CFR 54.4(a)(1).

The waste packaging area is listed as Category I in the UFSAR but is not identified in the scope of license renewal for 10 CFR 54.4(a)(1);

however, it is included for 10 CFR 54.4(a)(2) as indicated in LRA Section 2.4.3. The waste packaging area is an area for receiving and sorting dry active waste.There are no systems or components that are in the scope of license renewal for 10 CFR 54.4(a)(1) located within the waste packaging area structure.

The structure's only license renewal intended function is to maintain structural integrity such that its failure could not impact the auxiliary building and condensate demineralizer waste evaporator building in a manner that could prevent satisfactory accomplishment of any of the functions identified in paragraphs (a)(1)(i), (ii), or (iii) of 10 CFR 54. This review confirmed the acceptability of the basis for not including the waste packaging area within the scope of license renewal in accordance with 10 CFR 54.4(a)(1).

This review also identified that the Condenser Cooling Water (CCW) pumping station intake channel forebay side slopes were not included in the scope of license renewal in accordance with 10 CFR 54.4 (a)(1) in the Sequoyah LRA. As discussed in LRA Section 2.4.2, the CCW pumping station intake channel was designed with Category I side slopes in the forebay area.As discussed in UFSAR Section 2.4A.2.2 the forebay area of the CCW pumping station intake channel is relied upon to retain a source of water to supply two steam generators in each unit for decay heat removal and provide spent fuel pit with evaporation makeup flow during design basis flood events. Therefore, the forebay area of the CCW pumping station intake channel has a 10 CFR 54.4(a)(1) function that should have been indicated, in addition to 10 CFR 54.4(a)(3), as the basis for its inclusion in the scope of license renewal.A review of this issue concluded that use of the scoping methodology described in LRA Section 2.1.1 provided the proper identification of SSCs within the scope of license renewal in accordance with 10 CFR 54.4(a)(1) with the single exception of the CCW pumping station intake channel forebay discussed above.E1-4 of 11 The review evaluated the entire Category I structures listed in UFSAR Section 3.8.4 and Table 3.2.1-1. Therefore, no additional scoping evaluations are necessary to address the 10 CFR 54.4(a)(1) criteria for SQN structures.

No non-safety-related SSCs were identified whose failure could affect the CCW pumping station intake channel forebay in a manner that could prevent satisfactory accomplishment of any of the safety functions identified in 10 CFR 54.4(a)(1).

No additional SSCs were included within the scope of license renewal as a result of the review.The LRA sections are revised as shown below. Additions are underlined and deletions are shown with strikethrough.

E1-5 of 11 LRA SECTION 2.4.2 CHANGES 2.4.2 Water Control Structures CCW Pumping Station Intake Channel The purpose of the CCW pumping station intake channel is to provide a source of water required for the Commission's regulated event fire protection (10 CFR 50.48), provide a source of water for two steam generators in each unit for decay heat removal and provide a source of make-up water for the spent fuel pits if spent fuel pit water is lost during a design basis event.The CCW pumping station intake channel is located on the north side of the main plant area.The CCW pumping station intake channel is an excavated channel that consists of an approach channel and the forebay for water retention that extends from the CCW pumping station and provides a conveyance path of raw water from the ultimate heat sink, the Tennessee River (also known as the Chickamauga Reservoir).

Parts of the side slope for the approach channel and the entire forebay area were constructed with sloped embankments.

The slopes are protected from wind-wave activity with riprap. Sloped rock walls form the side slopes of the excavated forebay area approach projecting in front of the CCW pumping station. The rock walls side slopes of the forebay area approach channel are covered with a 12-inch-minimum thickness of concrete to prevent possible erosion of material from joints in the rock due to wave action of water in the intake channel. The intake channel provides cooling water for the condensers, raw cooling water system and the fire/flood mode pumps of the HPFP system.The slopes of the approach channel prior to entering the forebay area of the CCW pumping station intake channel approach channel slope' are not designed as Category I slopes. The side slopes in the forebay area are Category I slopes and are constructed to remain stable for the most critical design conditions.

The intake channel is relied upon to provide a source of water supply for equipment credited in the Appendix R safe shutdown analysis and for fire protection (10 CFR 50.48) equipment which is housed in the CCW pumping station. The forebay area of the CCW pumping station intake channel is relied upon to supply a source of water for two steam generators in each unit for decay heat removal and make-up water for the spent fuel Dits which is a 10 CFR 54.4(a)(1) function.The CCW pumping sta;tinin chanRel har no intend f f 10 R -M(M()The CCW pumping station intake channel has the following intended functions for 10 CFR 54.4(a)M1kay(2}

and (a)(3).Provide physical support, shelter, and protection for systems, structures, and components relied upon to remain functional during and following a design basis event (forebay area of the CCW pumping station intake channel only). 10 CFR 54.4(a)(1)

Pra'.ide physical su1pport, shelter, and protection forF nonsafoty related systems, structur~es, and1 components Whose failure cou1ld preVent satisfactory accomAplishment of function(s) identifiedfo 10 CFR 64.41(a)(1).

10 CER 54.4(a)(2)

Provide physical support, shelter, and protection for systems, structures, and components relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commission's regulation for fire protection 10 CFR 50.48, and 10 CFR 54.4(a)(3).

The CCW pumping station intake channel has no intended functions for 10 CFR 54.4(a)(2).

E1-6 of 11 NRC RAI 2.1-3 Backqround 10 CFR 54.4, "Scope," states, in part: (a) Plant systems, structures and components

[SSCs] within the scope of this part are -(1) Safety-related systems, structures, and components which are those relied upon to remain functional during and following design basis events (as defined in 10 CFR 50.49 (b)(1)) to ensure the following functions

-(i) The integrity of the reactor coolant pressure boundary;(ii) The capability to shut down the reactor and maintain it in a safe shutdown condition; or (iii) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to those referred to in 10 CFR 50.34(a)(1), 10 CFR 50.67(b)(2), or 10 CFR 100.11, as applicable.

(2) All nonsafety-related systems, structures and components whose failure could prevent satisfactory accomplishment of any of the functions identified in (a)(1)(i), (ii), or (iii) of this section.Issue During the on-site scoping and screening methodology audit the staff reviewed the license renewal application, license renewal implementing documents, as-built drawings, and current licensing basis documentation.

The staff determined that the service building that is immediately adjacent to the control building (within the scope of license renewal in accordance with 10 CFR 54.4(a)(1)), is not included within the scope of license renewal in accordance with 10 CFR 54.4(a)(2).

During the audit the applicant indicated that the determination to not include the service building within the scope of license renewal in accordance with 10 CFR 54.4(a)(2) was based on an analysis that demonstrated that the service building would not impact the control building during or following design bases events. However, the applicant did not provide information that demonstrated that the service building would not be subject to the effects of aging similar to other buildings of the same construction that the applicant had included within the scope of license renewal and made subject to an aging management program.Request: The staff requests that the applicant provide a technical basis for not including the service building, which is located adjacent to the control building (within the scope of license renewal in accordance with 10 CFR 54.4(a)(1)), within the scope of license renewal in accordance with 10 CFR 54.4(a)(2).

If an analysis is cited as the technical basis for not including the service building within the scope of license renewal, demonstrate how the analysis considers the effects of aging relative to other buildings of similar construction that are included within the scope of license renewal. The staff requests that the applicant perform a review of this issue and indicate if the review concludes that use of the scoping methodology precluded the identification of SSCs that should have included within the scope of license renewal in accordance with 10 CFR 54.4(a)(2).

Describe any additional scoping evaluations performed to address the 10 CFR 54.4(a)(2) criteria.

List any additional SSCs included within the scope of license renewal as a result of the review, SCs for which aging management reviews were performed.

E1-7 of 11 TVA Response to RAI 2.1-3 The SQN service building is a non-Category I structure located adjacent to but separate from the SQN Unit 1 turbine, auxiliary and control buildings.

The service building is constructed of reinforced concrete and structural steel framing with a built- up roofing membrane on metal roof decking. The interior walls are constructed of reinforced concrete or concrete masonry block.The building was designed in accordance with SQN design criteria and uniform building code.To ensure that the effects of aging do not affect its structural integrity, the LRA will be revised to include the service building within the scope of License Renewal for 10 CFR 54.4(a)(2) and subject to aging management review (AMR). No analysis is credited as the technical basis for not including the service building within the scope of license renewal.In response to the NRC request, a confirmatory review of SQN structures was performed with respect to this issue. This review identified no other structures that were omitted from the scope of license renewal that should have been included in accordance with 10 CFR 54.4(a)(2).

As a result of this review, no additional scoping evaluations were necessary to address the 10 CFR 54.4(a)(2) criteria and no additional SSCs were included within the scope of license renewal for which aging management reviews were performed.

The LRA sections are revised as shown below. Additions are underlined and deletions are shown with strikethrough.

LRA TABLE 2.2-3 CHANGES Table 2.2-3 Structures within the Scope of License Renewal Structure Name LRA Section Refueling water storage tank Section 2.4.3, Turbine Building, Aux/Control Building foundation and pipe tunnel, and Other Structures Unit 2 Service buildinq Section 2.4.3, Turbine Building, Aux/Control Buildinq and Other Structures Skimmer wall, skimmer wall dike Section 2.4.2, Water Control Structures A and underwater dam E1-8 of 11 LRA TABLE 2.2-4 CHANGES Table 2.2-4 Structures Not within the Scope of License Renewal Structure Name Structure Function or UFSAR Reference Septic tank and pump Provide support for the site's waste water and sewage foundation system.SepviGe buiIiPrdo offie spa"G....

for ma6ntenanco, .p..ations, and planning personnel and janitorial offices and maintenance shops for site peFORsonel Sewage analysis house Provide space for support of the site sewage system and equipment.

LRA SECTION 2.4.3 CHANGES 2.4.3 Turbine Building, Aux/Control Building and Other Structures The following structures are included in this review.* Turbine Building" Auxiliary Control Building* Auxiliary Building* Control Bay (or Control Building)* Additional Equipment Buildings, Unit 1 and Unit 2* Condensate Demineralizer Waste Evaporator Building* Waste Packaging Area* Additional Diesel Generator Building" Carbon Dioxide Storage Building* Condensate Storage Tanks' Foundations and Pipe Trench* Diesel Generator Building* East Steam Valve Room, Unit 1* East Steam Valve Room, Unit 2* High Pressure Fire Protection Pump House and Water Storage Tanks' Foundations

• Manhole, Handhole and Duct Banks* Radiation Monitoring Station, Unit 1* Radiation Monitoring Station, Unit 2* Refueling Water Storage Tank Foundation and Pipe Tunnel, Unit 1* Refueling Water Storage Tank Foundation and Pipe Tunnel, Unit 2* Service buildinq* Transformer and Switchyard Support Structures and Foundation E1-9 of 11 Service Buildinq The purpose of the service building is to provide office space for maintenance, operations and planning personnel, and janitorial offices and maintenance shops for site personnel.

The service building, located adjacent to but separate from the Unit 1 auxiliary, control and turbine buildings, is a multi-level structure constructed of reinforced concrete and structural steel framing with a built up roofing membrane on a metal roof decking. The service building is comprised of basement, grade floor and superstructure floor above the grade floor. The basement contains column footings, a floor slab and substructure retaining walls. The grade floor consists of slabs on structure steel framing, grade beams and slabs on grade. The superstructure slabs are support on structural steel framing. The interior walls are constructed of reinforced concrete or concrete masonry block. The various structural components of the building are founded on structural backfill.

The service building has no safety function, however to ensure that its structural integrity is maintained and that it will not affect 10 CFR 54.4(a)(1) structures or components, the service building reinforced concrete, structural steel framing and roofing membrane have been included in the scope of license renewal for 10 CFR 54.4(a)(2).

This structure has no intended functions for 10 CFR 54.4(a)(1) or (a)(3).This structure has the following intended function for 10 CFR 54.4(a)(2).

• Maintain integrity of non-safety-related structural components such that safety functions are not affected.

10 CFR 54.4(a)(2)

UFSAR

References:

Refueling Water Storage Tank Foundation and Pipe Tunnel, Units 1 and 2 Section 3.8.4.1.4 Figure 3.8.4-3 Section 3.8.5.1.2 Figure 3.8.4-4 Service Buildinq Section 3.7.2.2.5 Transformer and Switchyard Support Structures and Foundations Section 8.2.1 El-10 of 11 LRA APPENDIX A CHANGES A.1.40 Structures Monitoring Program The Structures Monitoring Program will be enhanced as follows.* Revise Structures Monitoring Program procedures to include the following in-scope structures and structural components." Carbon dioxide building* Condensate storage tanks' (CSTs) foundations and pipe trench.East steam valve room Units 1 & 2* Essential raw cooling water (ERCW) pumping station.. High pressure fire protection (HPFP) pump house and water storage tanks'foundations

• Radiation monitoring station (or particulate iodine and noble gas station) Units 1 & 2* Service buildinq* Skimmer wall (Cell No. 12)*. Transformer and Switchyard Support Structures and Foundations LRA APPENDIX B CHANGES B.1.40 Structures Monitoring Enhancements The following enhancements will be implemented prior to the period of extended operation.

Elements Affected Enhancements

1. Scope of Program Revise Structures Monitoring Program procedures to include the following in-scope structures" Carbon dioxide building" Condensate storage tanks' (CSTs)foundations and pipe trench* East steam valve room Units 1 & 2* Essential raw cooling water (ERCW)pumping station* High pressure fire protection (HPFP)pump house and water storage tanks'foundations

• . Radiation monitoring station (or particulate iodine and noble gas station) Units 1 & 2* Service building* Skimmer wall (Cell No. 12)*. Transformer and switchyard support structures and foundations El-11 of 11 ENCLOSURE2 Tennessee Valley Authority Sequoyah Nuclear Plant, Units I and 2 License Renewal Regulatory Commitment List, Revision 1 (Only commitment 31 .A is revised. See page E2-1 1, "Service Building" is bold-faced)

RELATED IMPLMENTTIONLRA No. COMMITMENT IMPLEMENTATION SOURCE SECTION /SCHEDULESETOI AUDIT ITEM 1 Implement the Aboveground Metallic Tanks SQN1: Prior to 09/17/20 B.1.1 Program as described in LRA Section B.1.1 SQN2: Prior to 09/15/21 2 A. Revise Bolting Integrity Program procedures SQN1: Prior to 09/17/20 B.1.2 to ensure the actual yield strength of replacement or SQN2: Prior to 09/15/21 newly procured bolts will be less than 150 ksi B. Revise Bolting Integrity Program procedures to include the additional guidance and recommendations of EPRI NP-5769 for replacement of ASME pressure-retaining bolts and the guidance provided in EPRI TR-104213 for the replacement of other pressure-retaining bolts.Implement the Buried and Underground Piping QN1: Prior to 09/17/20 B.1.4 and Tanks Inspection Program as described in QN2: Prior to 09/15/21 LRA Section B.1.4. I E2-1 of 17 RELATED No OMTETIMPLEMENTATION SORE LRA No. COMITMENTSCHEDULE SORESECTION I AUDIT ITEM.4 A. Revise Compressed Air Monitoring Program SQN1: Prior to 09/17/20 B.1.5 procedures to include the standby diesel generator SQN2: Prior to 09/15/21 (DG) starting air subsystem.

B. Revise Compressed Air Monitoring Program procedures to include maintaining moisture and other contaminants below specified limits in the standby DG starting air subsystem C. Revise Compressed Air Monitoring Program procedures to apply a consideration of the guidance of ASME OM-S/G-1998, Part 17; EPRI NP-7079;and EPRI TR-1 08147 to the limits specified for the air system contaminants D. Revise Compressed Air Monitoring Program procedures to maintain moisture, particulate size, and particulate quantity below acceptable limits in the standby DG starting air subsystem to mitigate loss of material.E. Revise Compressed Air Monitoring Program procedures to include periodic and opportunistic visual inspections of surface conditions consistent with frequencies described in ASME O/M-SG-1998, Part 17 of accessible internal surfaces such as compressors, dryers, after-coolers, and filter boxes of the following compressed air systems:* Diesel starting air subsystem* Auxiliary controlled air subsystem* Nonsafety-related controlled air subsystem F. Revise Compressed Air Monitoring Program procedures to monitor and trend moisture content in the standby DG starting air subsystem.

G. Revise Compressed Air Monitoring Program procedures to include consideration of the guidance for acceptance criteria in ASME OM-S/G-1 998, Part 17. EPRI NP-7079: and EPRI TR-108147.

E2-2 of 17 RELATED IMPLMENTTIONLRA No. COMMITMENT IMPLEMENTATION SOURCE SECTION /SCHEDULESETO AUDIT ITEM 5 A. Revise Diesel Fuel Monitoring Program SQN1: Prior to 09/17/20 B.1.8 procedures to monitor and trend sediment and SQN2: Prior to 09/15/21 particulates in the standby DG day tanks.B. Revise Diesel Fuel Monitoring Program procedures to monitor and trend levels of microbiological organisms in the seven-day storage tanks.C. Revise Diesel Fuel Monitoring Program procedures to include a ten-year periodic cleaning and internal visual'inspection of the standby DG diesel fuel oil day tanks and high pressure fire protection (HPFP) diesel fuel oil storage tank. These cleanings and internal inspections will be performed at least once during the ten-year period prior to the period of extended operation and at succeeding ten-year intervals.

If visual inspection is not possible, a volumetric inspection will be performed.

D. Revise Diesel Fuel Monitoring Program procedures to include a volumetric examination of affected areas of the diesel fuel oil tanks, if evidence of degradation is observed during visual inspection.

The scope of this enhancement includes the standby DG seven-day fuel oil storage tanks, standby DG fuel oil day tanks, and HPFP diesel fuel oil storage tank and is applicable to the inspections performed during the ten-year period prior to the period of extended operation and succeeding ten-year intervals.

6 A. Revise External Surfaces Monitoring Program SQN1: Prior to 09/17/20 B.1.10 procedures to clarify that periodic inspections of SQN2: Prior to 09/15/21 systems in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4(a)(1) and (a)(3) will be performed.

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 SSCs that are in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4(a)(2).

B. Revise External Surfaces Monitoring Program procedures to include instructions to look for the following related to metallic components:

• Corrosion and material wastage (loss of material)." Leakage from or onto external surfaces loss of material).

E2-3 of 17 RELATED IMLMNA ION LRA No. COMMITMENT IMPLEMENTATION SOURCE SECTION /AUDIT ITEM 6 0 Worn, flaking, or oxide-coated surfaces (cont.) (loss of material).

• Corrosion stains on thermal insulation (loss of material).

• Protective coating degradation (cracking, flaking, and blistering).

• Leakage for detection of cracks on the external surfaces of stainless steel components exposed to an air environment containing halides.C. Revise External Surfaces Monitoring Program procedures to include instructions for monitoring aging effects for flexible polymeric components, including manual or physical manipulations of the material, with a sample size for manipulation of at least ten percent of the available surface area.The inspection parameters for polymers shall include the following:

• Surface cracking, crazing, scuffing, dimensional changes (e.g., ballooning and necking) -).* Discoloration.

• Exposure of internal reinforcement for reinforced elastomers (loss of material).

• Hardening as evidenced by loss of suppleness during manipulation where the component and material can be manipulated.

D. Revise External Surfaces Monitoring Program procedures to ensure surfaces that are insulated will be inspected when the external surface is exposed (i.e., during maintenance) at such intervals that would ensure that the components' intended function is maintained.

E. Revise External Surfaces Monitoring Program procedures to include acceptance criteria.

Examples include the following: " Stainless steel should have a clean shiny surface with no discoloration." Other metals should not have any abnormal surface indications.

• Flexible polymers should have a uniform surface texture and color with no cracks and no unanticipated dimensional change, no abnormal surface with the material in an as-new condition with respect to hardness, flexibility, physical dimensions, and color.* Rigid polymers should have no erosion, cracking, checking or chalks.E2-4 of 17 RELATED IMPLMENTTIONLRA No. COMMITMENT IMPLEMENTATION SOURCE SECTION /SCHEDULESETOI AUDIT ITEM 7 A. Revise Fatigue Monitoring Program SQN1: Prior to 09/17/20 B.1.11 procedures to monitor and track critical thermal and SQN2: Prior to 09/15/21 pressure transients for components that have been identified to have a fatigue Time Limited Aging Analysis.B. Fatigue usage calculations that consider the effects of the reactor water environment will be developed for a set of sample reactor coolant system components.

This sample set will include the locations identified in NUREG/CR-6260 and additional plant-specific component locations in the reactor coolant pressure boundary if they are found to be more limiting than those considered in NUREG/CR-6260.

Fen factors will be determined as described in Section 4.3.3.C. Fatigue usage factors for the reactor coolant system limiting components will be determined to address the Cold Overpressure Mitigation System (COMS) event (i.e., low temperature overpressurization event) and the effects of the structural weld overlays.D. Revise Fatigue Monitoring Program procedures to provide updates of the fatigue usage calculations on an as-needed basis if an allowable cycle limit is approached, or in a case where a transient definition has been changed, unanticipated new thermal events are discovered, or the geometry of components have been modified.8 A. Revise Fire Protection Program procedures to SQN1: Prior to 09/17/20 B.1.12 include an inspection of fire barrier walls, ceilings, SQN2: Prior to 09/15/21 and floors for any signs of degradation such as cracking, spalling, or loss of material caused by freeze thaw, chemical attack, or reaction with aggregates.

B. Revise Fire Protection Program procedures to provide acceptance criteria of no significant indications of concrete cracking, spalling, and loss of material of fire barrier walls, ceilings, and floors and in other fire barrier materials.

9 A. Revise Fire Water System Program procedures SQNI: Prior to 09/17/20 B.1.13 to include periodic visual inspection of fire water SQN2: Prior to 09/15/21 system internals for evidence of corrosion and loss of wall thickness.

E2-5 of 17 RELATED No. COMMITMENT IMPLEMENTATION SOURCE LRA__. _OMMI_ _SCHEDULE SECTIONT AUDIT ITEM B. Revise Fire Water System Program procedures 9 to include one of the following options: (cont.)

• Wall thickness evaluations of fire protection piping using non-intrusive techniques (e.g., volumetric testing) to identify evidence of loss of material will be performed prior to the period of extended operation and periodically thereafter.

Results of the initial evaluations will be used to determine the appropriate inspection interval to ensure aging effects are identified prior to loss of intended function.* A visual inspection of the internal surface of fire protection piping will be performed upon each entry into the system for routine or corrective maintenance.

These inspections will be capable of evaluating (1) wall thickness to ensure against catastrophic failure and (2) the inner diameter of the piping as it applies to the design flow of the fire protection system. Maintenance history shall be used to demonstrate that such inspections have been performed on a representative number of locations prior to the period of extended operation.

A representative number is 20% of the population (defined as locations having the same material, environment, and aging effect combination) with a maximum of 25 locations.

Additional inspections will be performed as needed to obtain this representative sample prior to the period of extended operation and periodically during the period of extended operation based on the findings from the inspections performed prior to the period of extended operation.

C. Revise Fire Water System Program procedures to ensure a representative sample of sprinkler heads will be tested or replaced before the end of the 50-year sprinkler head service life and at ten-year intervals thereafter during the extended period of operation.

NFPA-25 defines a representative sample of sprinklers to consist of a minimum of not less than four sprinklers or one percent of the number of sprinklers per individual sprinkler sample, whichever is greater. If the option to replace the sprinklers is chosen, all sprinkler heads that have been in service for 50 years will be replaced.E2-6 of 17 RELATED IMLMNA IO ILRA COMMITMENT IMPLEMENTATION SOURCE SECTION I ASCHEDULE SDI ON 4 1 4AUDIT ITEM D. Revise Fire Water System Program procedures to consider implementing the flow testing requirements of NFPA 25 or justify why the flow testing requirements of NFPA should not be implemented.

E. Revise Fire Water System Program procedures to include acceptance criteria for periodic visual inspection of fire water system internals for corrosion, minimum wall thickness, and the absence of biofouling in the sprinkler system that could cause corrosion in the sprinklers.

10 Revise Flow Accelerated Corrosion Program SQN1: Prior to 09/17/20 B.1.14 procedures to implement NSAC-202L guidance for SQN2: Prior to 09/15/21 examination of components upstream of piping surfaces where significant wear is detected.11 Revise Flux Thimble Tube Inspection Program SQN1: Prior to 09/17/20 B. 1.15 procedures to include a requirement to address if the predictive trending projects that a tube will SQN2: Prior to 09/15/21 exceed 80% wall wear prior to the next planned inspection, then initiate a Service Request (SR) to define actions (i.e., plugging, repositioning, replacement, evaluations, etc.) required to ensure that the projected wall wear does not exceed 80%.If any tube is found to be >80% through wall wear, then initiate a Service Request (SR) to evaluate the predictive methodology used and modify as required to define corrective actions (i.e., plugging, repositioning, replacement, etc).12 Revise Inservice Inspection-IWF Program SQN1: Prior to 09/17/20 B. 1.17 procedures to clarify that detection of aging effects SQN2: Prior to 09/15/21 will include monitoring anchor bolts for loss of material, loose or missing nuts, and cracking of concrete around the anchor bolts.13 Inspection of Overhead Heavy Load and Light SQN1: Prior to 09/17/20 B. 1.18 Load (Related to Refueling)

Handling Systems: SQN2: Prior to 09/15/21 A. Revise program procedures to specify the inspection scope will include monitoring of rails in the rail system for wear; monitoring structural components of the bridge, trolley and hoists for the aging effect of deformation, cracking, and loss of material due to corrosion; and monitoring structural connections/bolting for loose or missing bolts, nuts, pins or rivets and any other conditions indicative of loss of bolting integrity.

B. Revise program procedures to include the inspection and inspection frequency requirements of ASME B30.2. I E2-7 of 17 RELATED IMPLMENTTIONLRA No. COMMITMENT IMPLEMENTATION SOURCE SECTION I SCHEDULESETO AUDIT ITEM C. Revise program procedures to clarify that the 13 acceptance criteria will include requirements for (cont.) evaluation in accordance with ASME B30.2 of significant loss of material for structural components and structural bolts and significant wear of rail in the rail system.D. Revise program procedures to clarify that the acceptance criteria and maintenance and repair activities use the guidance provided in ASME B30.2 14 Implement the Internal Surfaces in Miscellaneous SQN1: Prior to 09/17/20 B.1.19 Piping and Ducting Components Program as SQN2: Prior to 09/15/21 described in LRA Section B.1.19.15 Implement the Metal Enclosed Bus Inspection QN1: Prior to 09/17/20 B.1.21 Program as described in LRA Section B.1.21. QN2: Prior to 09/15/21 16 A. Revise Neutron Absorbing Material QN1: Prior to 09/17/20 B. 1.22 Monitoring Program procedures to perform QN2: Prior to 09/15/21 blackness testing of the Boral coupons within the ten years prior to the period of extended operation and at least every ten years thereafter based on initial testing to determine possible changes in boron-10 areal density.B. Revise Neutron Absorbing Material Monitoring Program procedures to relate physical measurements of Boral coupons to the need to perform additional testing.C. Revise Neutron Absorbing Material Monitoring Program procedures to perform trending of coupon testing results to determine the rate of degradation and to take action as needed to maintain the intended function of the Boral.17 Implement the Non-EQ Cable Connections SQN1: Prior to 09/17/20 B. 1.24 Program as described in LRA Section B.1.24 SQN2: Prior to 09/15/21 18 Implement the Non-EQ Inaccessible Power Cable SQN1: Prior to 09/17/20 B.1.25 (400 V to 35 kV) Program as described in LRA SQN2: Prior to 09/15/21 Section B.1.25 19 Implement the Non-EQ Instrumentation Circuits SQN1: Prior to 09/17/20 B.1.26 Test Review Program as described in LRA Section SQN2: Prior to 09/15/21 B. 1.26.20 Implement the Non-EQ Insulated Cables and SQN1: Prior to 09/17/20 B.1.27 Connections Program as described in LRA SQN2: Prior to 09/15/21 Section B.1.27 E2-8 of 17 RELATED IMPLEMENTATION SOURCE LRA COMMITMENTSCHEDULE SOURCE SECTIONTE AUDIT ITEM 21 A. Revise Oil Analysis Program procedures to monitor and maintain contaminants in the 161-kV oil filled cable system within acceptable limits through periodic sampling in accordance with industry standards, manufacturer's recommendations and plant-specific operating experience.

B. Revise Oil Analysis Program procedures to trend oil contaminant levels and initiate a problem evaluation report if contaminants exceed alert levels or limits in the 161-kV on-filled cable system.3QN1: Prior to 09/17/20 3QN2: Prior to 09/15/21 B.1.28 22 Implement the One-Time Inspection Program as QNI: Prior to 09/17/20 B.1.29 described in LRA Section B.1.29. QN2: Prior to 09/15/21 23 Implement the One-Time Inspection

-Small Bore QNI: Prior to 09/17/20 B.1.30 Piping Program as described in LRA Section SQN2: Prior to 09/15/21 B.1.30 24 Revise Periodic Surveillance and Preventive SQNI: Prior to 09/17/20 B.1.31 Maintenance Program procedures as necessary to SQN2: Prior to 09/15/21 include all activities described in the table provided in the LRA Section B.1.31 program description.

25 A. Revise Protective Coating Program SQNI: Prior to 09/17/20 B.1.32 procedures to clarify that detection of aging effects SQN2: Prior to 09/15/21 will include inspection of coatings near sumps or screens associated with the emergency core cooling system.B. Revise Protective Coating Program procedures to clarify that instruments and equipment needed for inspection may include, but not be limited to, flashlights, spotlights, marker pen, mirror, measuring tape, magnifier, binoculars, camera with or without wide-angle lens, and self-sealing polyethylene sample bags.C. Revise Protective Coating Program procedures to clarify that the last two performance monitoring reports pertaining to the coating systems will be reviewed prior to the inspection or monitoring process.E2-9 of 17 RELATED IMPLMENTTIONLRA No. COMMITMENT IMPLEMENTATION SOURCE SECTION I SCHEDULESETO AUDIT ITEM 26 A. Revise Reactor Head Closure Studs Program SQN1: Prior to 09/17/20 B.1.33 procedures to ensure that replacement studs are SQN2: Prior to 09/15/21 fabricated from bolting material with actual measured yield strength less than 150 ksi.B. Revise Reactor Head Closure Studs Program procedures to exclude the use of molybdenum disulfide (MoS 2) on the reactor vessel closure studs and to refer to Reg. Guide 1.65, Revi.27 A. Revise Reactor Vessel Internals Program SQN1: Prior to 09/17/20 B.1.34 procedures to take physical measurements of the Type 304 stainless steel hold-down springs in Unit 1 SQN2: Not Applicable at each refueling outage to ensure preload is adequate for continued operation.

B. Revise Reactor Vessel Internals Program procedures to include preload acceptance criteria for the Type 304 stainless steel hold-down springs in Unit 1.28 A. Revise Reactor Vessel Surveillance Program QNI: Prior to 09/17/20 B.1.35 procedures to consider the area outside the beltline SQN2: Prior to 09/15/21 such as nozzles, penetrations and discontinuities to determine if more restrictive pressure-temperature limits are required than would be determined by just considering the reactor vessel beltline materials.

B. Revise Reactor Vessel Surveillance Program procedures to develop an NRC-approved schedule for capsule withdrawals to meet ASTM-E1 85-82 requirements, including the possibility of operation beyond 60 years.C. Revise Reactor Vessel Surveillance Program procedures to withdraw and test a standby capsule to cover the peak fluence expected at the end of the period of extended operation.

29 Implement the Selective Leaching Program as SQN1: Prior to 09/17/20 B.1.37 described in LRA Section B.1.37. SQN2: Prior to 09/15/21 30 Revise Steam Generator Integrity Program SQN1: Prior to 09/17/20 B.1.39 procedures to ensure that corrosion resistant SQN2: Prior to 09/15/21 materials are used for replacement steam generator tube plugs.31 A. Revise Structures Monitoring Program SQNI: Prior to 09/17/20 B.1.40 procedures to include the following in-scope SQN2: Prior to 09/15/21 structures:

_ Carbon dioxide building E2-10 of 17 RELATED No. COMMITMENT IMPLEMENTATION SOURCE LRA NMSCHEDULE SECTION AUDIT ITEM" Condensate storage tanks' (CSTs)31 foundations and pipe trench (cont.) 9 East steam valve room Units 1 & 2* Essential raw cooling water (ERCW)pumping station* High pressure fire protection (HPFP) pump house and water storage tanks' foundations

• Radiation monitoring station (or particulate iodine and noble gas station) Units 1 & 2* Service building* Skimmer wall (Cell No. 12)* Transformer and switchyard support structures and foundations B. Revise Structures Monitoring Program procedures to specify the following list of in-scope structures are included in the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program (Section B.1.36):* Condenser cooling water (CCW) pumping station (also known as intake pumping station) and retaining walls* CCW pumping station intake channel* ERCW discharge box* ERCW protective dike* ERCW pumping station and access cells* Skimmer wall, skimmer wall Dike A and underwater dam C. Revise Structures Monitoring Program procedures to include the following in-scope structural components and commodities:

• Anchor bolts* Anchorage/embedments (e.g., plates, channels, unistrut, angles, other structural shapes)* Beams, columns and base plates (steel)* Beams, columns, floor slabs and interior walls (concrete)

• Beams, columns, floor slabs and interior walls (reactor cavity and primary shield walls; pressurizer and reactor coolant pump compartments; refueling canal, steam generator compartments; crane wall and missile shield slabs and barriers)" Building concrete at locations of expansion and grouted anchors; grout pads for support base plates* Cable tray* Cable tunnel E2-11 of 17 RELATED IMPLEMENTATION LRA No. COMMITMENT ISCHEDULE SOURCE SECTION I AUDIT ITEM* Canal gate bulkhead 31 0 Compressible joints and seals (cont.)

• Concrete cover for the rock walls of approach channel* Concrete shield blocks* Conduit* Control rod drive missile shield* Control room ceiling support system* Curbs* Discharge box and foundation

• Doors (including air locks and bulkhead doors)* Duct banks* Earthen embankment

• Equipment pads/foundations

• Explosion bolts (E. G. Smith aluminum bolts)* Exterior above and below grade;foundation (concrete)

• Exterior concrete slabs (missile barrier)and concrete caps* Exterior walls: above and below grade (concrete)

• Foundations:

building, electrical components, switchyard, transformers, circuit breakers, tanks, etc.* Ice baskets* Ice baskets lattice support frames* Ice condenser support floor (concrete)

• Intermediate deck and top deck of ice condenser* Kick plates and curbs (steel -inside steel containment vessel)* Lower inlet doors (inside steel containment vessel)* Lower support structure structural steel: beams, columns, plates (inside steel containment vessel)* Manholes and handholes* Manways, hatches, manhole covers, and hatch covers (concrete)

• Manways, hatches, manhole covers, and hatch covers (steel)* Masonry walls* Metal siding* Miscellaneous steel (decking, grating, handrails, ladders, platforms, enclosure plates, stairs, vents and louvers, framing steel, etc.)* Missile barriers/shields (concrete)

E2-12 of 17 RELATED IMPLMENTTIONLIRA No. COMMITMENT IMPLEMENTATION SOURCE SECTION I SCHEDULESTI

______________AUDIT ITEM 0 Missile barriers/shields (steel)31 0 Monorails (cont.) 0 Penetration seals* Penetration seals (steel end caps)* Penetration sleeves (mechanical and electrical not penetrating primary containment boundary)* Personnel access doors, equipment access floor hatch and escape hatches* Piles* Pipe tunnel* Precast bulkheads* Pressure relief or blowout panels* Racks, panels, cabinets and enclosures for electrical equipment and instrumentation

• Riprap* Rock embankment

• Roof or floor decking* Roof membranes* Roof slabs* RWST rainwater diversion skirt* RWST storage basin* Seals and gaskets (doors, manways and hatches)* Seismic/expansion joint* Shield building concrete foundation, wall, tension ring beam and dome: interior, exterior above and below grade* Steel liner plate* Steel sheet piles* Structural bolting* Sumps (concrete)

• Sumps (steel)* Sump liners (steel)* Sump screens* Support members; welds; bolted connections; support anchorages to building structure (e.g., non-ASME piping and components supports, conduit supports, cable tray supports, HVAC duct supports, instrument tubing supports, tube track supports, pipe whip restraints, jet impingement shields, masonry walls, racks, panels, cabinets and enclosures for electrical equipment and instrumentation)

• Support pedestals (concrete)

• Transmission, angle and pull-off towers* Trash racks* Trash racks associated structural support E2-13 of 17 RELATED No OMTETIMPLEMENTATION SORE LRA No. COMITMENTSCHEDULE SORE SECTION/AUDIT ITEM framing 31 Traveling screen casing and associated (cont.) structural support framing* Trenches (concrete)

• Tube track* Turning vanes* Vibration isolators D. Revise Structures Monitoring Program procedures to include periodic sampling and chemical analysis of ground water chemistry for pH, chlorides, and sulfates on a frequency of at least every five years.E. Revise Masonry Wall Program procedures to specify masonry walls located in the following in-scope structures are in the scope of the 'Masonry Wall Program:* Auxiliary building* Reactor building Units 1 & 2* Control bay* ERCW pumping station* HPFP pump house* Turbine building F. Revise Structures Monitoring Program procedures to include the following parameters to be monitored or inspected:

• Requirements for concrete structures based on ACI 349-3R and ASCE 11 and include monitoring the surface condition for loss of material, loss of bond, increase in porosity and permeability, loss of strength, and reduction in concrete anchor capacity due to local concrete degradation.

• Loose or missing.nuts for structural bolting.* Monitoring gaps between the structural steel supports and masonry walls that could potentially affect wall qualification.

G. Revise Structures Monitoring Program procedures to include the following components to be monitored for the associated parameters: " Anchors/fasteners (nuts and bolts) will be monitored for loose or missing nuts and/or bolts, and cracking of concrete around the anchor bolts.* Elastomeric vibration isolators and structural sealants will be monitored for cracking, loss of material, loss of sealing, and change in material properties (e.g., E2-14 of 17 RELATED No. COMMITMENT IMPLEMENTATION SOURCE LIRA NMSCHEDULE SECTION AUDIT ITEM 31 (cont.)hardening).

H. Revise Structures Monitoring Program procedures to include the following for detection of aging effects:* Inspection of structural bolting for loose or missing nuts." Inspection of anchor bolts for loose or missing nuts and/or bolts, and cracking of concrete around the anchor bolts." Inspection of elastomeric material for cracking, loss of material, loss of sealing, and change in material properties (e.g., hardening), and supplement inspection by feel or touch to detect hardening if the intended function of the elastomeric material is suspect. Include instructions to augment the visual examination of elastomeric material with physical manipulation of at least ten percent of available surface area." Opportunistic inspections when normally inaccessible areas (e.g., high radiation areas, below grade concrete walls or foundations, buried or submerged structures) become accessible due to required plant activities.

Additionally, inspections will be performed of inaccessible areas in environments where observed conditions in accessible areas exposed to the same environment indicate that significant degradation is occurring.

• Inspection of submerged structures at least once every five years.Inspections of water control structures should be conducted under the direction of qualified personnel experienced in the investigation, design, construction, and operation of these types of facilities.

• Inspections of water control structures shall be performed on an interval not to exceed five years.* Perform special inspections of water control structures immediately (within 30 days) following the occurrence of significant natural phenomena, such as large floods, earthquakes, hurricanes, tornadoes, and intense local rainfalls.

I. Verify acceptance criteria in Structures Monitoring Program procedures is based on information provided in industry codes, standards, and E2-15 of 17 RELATED IMPLMENTTIONLRA No. COMMITMENT IMPLEMENTATION SOURCE SECTION /SCHEDULESETO AUDIT ITEM guidelines including NEI 96-03, ACI 201.1 R-92, 31 ANSI/ASCE 11-99 and ACI 349.3R-02.

Industry (cont.) and plant-specific operating experience will also be considered in the development of the acceptance criteria.32 Implement the Thermal Aging Embrittlement of SQN1: Prior to 09/17/20 B. 1.41 Cast Austenitic Stainless Steel (CASS) as SQN2: Prior to 09/15/21 described in LRA Section B.1.41 33 A. Revise Water Chemistry Control -Closed Treated Water Systems Program procedures to provide a corrosion inhibitor for the following chilled water subsystems in accordance with industry guidelines and vendor recommendations:

• Auxiliary building cooling* Incore Chiller 1A, 1B, 2A, & 2B* 6.9 kV Shutdown Board Room A & B B. Revise Water Chemistry Control -Closed Treated Water Systems Program procedures to conduct inspections whenever a boundary is opened for the following systems:* Standby diesel generator jacket water subsystem* Component cooling system* Glycol cooling loop system* High pressure fire protection diesel jacket water system* Chilled water portion of miscellaneous HVAC systems (i.e., auxiliary building, Incore Chiller 1A, 1B, 2A, & 2B, and 6.9 kV Shutdown Board Room A & B)C. Revise Water Chemistry Control-Closed Treated Water Systems Program procedures to state these inspections will be conducted in accordance with applicable ASME Code requirements, industry standards, or other plant-specific inspection and personnel qualification procedures that are capable of detecting corrosion or cracking.D. Revise Water Chemistry Control -Closed Treated Water Systems Program procedures to perform sampling and analysis of the glycol cooling system per industry standards and in no case greater than quarterly unless justified with an additional analysis.E. Revise Water Chemistry Control -Closed Treated Water Systems Proaram mrocedures to SQN1: Prior to 09/17/20 SQN2: Prior to 09/15/21 B.1.42 E2-16 of 17 RELATED IMPLMENTTIONLRA No. COMMITMENT IMPLEMENTATION SOURCE SECTION I SCHEDULESETO AUDIT ITEM inspect a representative sample of piping and components at a frequency of once every ten 33 years for the following systems: (cont.)

• Standby diesel generator jacket water subsystem* Component cooling system* Glycol cooling loop system* High pressure fire protection diesel jacket water system* Chilled water portion of miscellaneous HVAC systems (i.e., auxiliary building, Incore Chiller 1A, 1B, 2A, & 2B, and 6.9 kV Shutdown Board Room A & B)F. Components inspected will be those with the highest likelihood of corrosion or cracking.

A representative sample is 20% of the population (defined as components having the same material, environment, and aging effect combination) with a maximum of 25 components.

These inspections will be in accordance with applicable ASME Code requirements, industry standards, or other plant-specific inspection and personnel qualification procedures that ensure the capability of detecting corrosion or cracking.The above table identifies the 33 SQN NRC LR commitments.

Any other statements in this letter are provided for information purposes and are not considered to be regulatory commitments.

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