ML15331A186

Official Exhibit - NYS000504-00-BD01 - Dacimo, Fred, Entergy, Letter to Document Control Desk, USNRC, Reply to Request for Additional Information Regarding the License Renewal Application, NL-14-067 (June 9, 2014) (ML14176A159)

ML15331A186
Person / Time
Site:	Indian Point
Issue date:	06/09/2014
From:	State of NY, Office of the Attorney General
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 27909, ASLBP 07-858-03-LR-BD01, 50-247-LR, 50-286-LR
Download: ML15331A186 (60)

Text

iE vw-EnterWy Enteray Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 254-2055 Fred Dacimo Vice President Operations License Renewal NL-14-067 June 9, 2014 U.S. Nuclear Regulatory Commission Document Control Desk 11545 Rockville Pike, TWFN-2 F1 Rockville, MD 20852-2738

REFERENCE:

Reply to Request for Additional Information Regarding the License Renewal Application Indian Point Nuclear Generating Unit Nos. 2 & 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64 NRC letter, "Request for Additional Information for the Review of the Indian Point Nuclear Generating Unit Nos. 2 and 3, License Renewal Application, SET 2014-02 (TAC Nos. MD5407 and MD5408)" dated April 9, 2014.

Dear Sir or Madam:

Entergy Nuclear Operations, Inc. is providing, in Attachment 1, the additional information requested in the referenced letter pertaining to NRC review of the License Renewal Application (LRA) for Indian Point 2 and Indian Point 3.The responses to RAI 11-C and RAI 16-B include the deletion of Commitment 47 and a revision to Commitment 50, respectively.

These commitment changes are included in the list of regulatory commitments provided in Attachment 2.If you have any questions, or require additional information, please contact Mr. Robert Walpole at 914-254-6710.

I declare d r penalty of perjury that the foregoing is true and correct. Executed on 6A , 2014.Sin rely, FRD/rw A(21ý-f 44 A-Docket Nos. 50-247 & 50-286 NL-14-067 Page 2 of 2

Attachment:

1. Reply to NRC Request for Additional Information Regarding the License Renewal Application

2. License Renewal Applicati,.° IPEC List of Regulatory CommitmentsRevision 23 cc: Mr. William Dean, Regional Administrator, NRC Region I Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel Mr. Dave Wrona, NRC Branch Chief, Engineering Review Branch I Ms. Kimberly Green, NRC Sr. Project Manager, Division of License Renewal Mr. Douglas Pickett, NRR Senior Project Manager Ms. Bridget Frymire, New York State Department of Public Service NRC Resident Inspector's Office Mr. John B. Rhodes, President and CEO NYSERDA ATTACHMENT 1 TO NL-14-067 REPLY TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE LICENSE RENEWAL APPLICATION ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286 NL-14-067 Attachment 1 Page 1 of 5 REQUEST FOR ADDITIONAL INFORMATION, SET 2014-02 RELATED TO INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION REACTOR VESSEL INTERNALS PROGRAM AND INSPECTION PLAN RAI 11-C Applicant/Licensee Action Item 7 from the staff's final safety evaluation (SE) of MRP-227 requires the applicants/licensees of Babcock & Wilcox (B&W), Combustion Engineering (CE), and Westinghouse reactors to develop plant-specific analyses to be applied for their facilities to demonstrate that B&W In-Core Monitoring Instrumentation (IMI) guide tube assembly spiders and control rod guide tube (CRGT) assembly spacer castings, CE lower support columns, and Westinghouse lower support column bodies will maintain their functionality during the period of extended operation, and states that these analyses should also consider the possible loss of fracture toughness in these components due to thermal embrittlement (TE) and irradiation embrittlement (IE). For Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3), the equivalent component to the lower support column bodies are the lower internals assembly -column caps (column caps).By letter dated January 28, 2014, Entergy provided plant specific information on the ferrite content and susceptibility to TE for the Indian Point Nuclear Generating Unit Nos. 2 and 3 lower internals assembly -column caps. Based on its evaluation of the plant-specific material information for the column caps, Entergy concluded that the IP2 and IP3 column caps are not susceptible to TE.Entergy's conclusion related to TE notwithstanding, the column caps remain susceptible to IE.The staff is concerned that the linked Primary component for the column caps, the CRGT assembly lower flange welds, is not a good predictor of IE for the column caps since the CRGT lower flange welds receive substantially lower neutron fluence than the column caps (based on the estimated neutron fluence tabulated in MRP-1 91 for the two components).

Irradiation assisted stress corrosion cracking (IASCC) is the only mechanism of cracking that screened in for the column caps. The CRGT lower flange welds are also not a good predictorfor IASCC of the column caps, because the lower flange welds are susceptible to stress corrosion cracking (SCC) and fatigue cracking, but not IASCC.The staff, therefore, requests that Entergy modify its Reactor Vessel Internals Inspection Plan (RVI Inspection Plan) to provide a link to a Primary component or components that is an appropriate predictor of IE and IASCC of the column caps.Response to RAI 11-C The following text will be incorporated into the reactor vessel internals (RVI) Inspection Plan for Indian Point Units 2 and 3 regarding a link to a component that is an appropriate predictor of irradiation embrittlement (IE) and irradiation-assisted stress corrosion cracking (IASCC) of the column caps.

NL-14-067 Attachment 1 Page 2 of 5"The lower core plate, which was screened in for IASCC in MRP-191 [1], is a leading indicator of cracking in the column caps of the lower support column bodies because it is subject to more severe service conditions.

Due to its proximity to the core, the lower core plate experiences both higher fluences and higher gamma heating than the column caps. Additionally, thermally induced tensile stresses are anticipated in the lower core plate while the stresses in the column caps are largely compressive.

These factors Pre expected to contribute to earlier IASCC initiation in the lower core plate, making it a suitable leading indicator of cracking in the column caps.The lower support column caps at Indian Point Units 2 and 3 have the same irradiation embrittlement mechanism as the wrought stainless steel lower core plate. The 60-year fluence in the top few inches of the lower support column body, which is where the column cap is located, is projected to exceed the threshold for irradiation embrittlement of austenitic stainless steel. Therefore, irradiation embritt!ement is considered a damage mechanism in the column caps.Considering both the cracking mechanism and the likely embrittlement mechanism, a leading indicator of degradation for the column caps is the lower core plate. Since the lower core plate is an Existing Programs component in MRP-227-A

[2] and must be inspected as part of the aging management program, it is an appropriate alternate component for predicting aging effects.

The lower core plate will continue to be an Existing Programs component, managed under the Indian Point program for ASME Section Xl inspections. The inspection requirement will remain a VT-3 inspection of the accessible upper surface on a ten-year interval.

In addition to the standard requirements for assessing extent of condition required under ASME Section XI, a trigger for the Expansion inspection of the lower support column bodies (column caps) for Indian Point Units 2 and 3 will be the confirmed discovery of a service induced flaw in the lower core plate." The intent of Commitment 47 was to demonstrate that the lower support column bodies willmaintain their functionality during the period of extended operation considering the possible loss of fracture toughness due to thermal and irradiation embrittlement.

As the staff noted in this RAI 11-C, Entergy has concluded that the IP2 and IP3 column caps (equivalent component to the lower support column bodies) are not susceptible to TE and will modify the Reactor Vessel Internals (RVI) Inspection Plan to credit inspection of the lower core plate as an appropriate predictor of IE and IASCC of the column caps. Therefore, the functionality of the lower support column bodies is assured during the period of extended operation without the need for a functionality analysis.

Therefore, Entergy is deleting Commitment 47 (additions are underlined, deletions lined out).Commitment 47 IPE. will and -ubmit analyses that domnStato that the lower support column bodioS Will maintain their functionality duFrig the period of extended operation concidoring the poccfiblo los6 of fracture toughness duo to thermal and irradiation eMbrittloMont.

The analyses will be consistent With the 1122/1123 licensing basis. Deleted.

NL-14-067 Attachment 1 Page 3 of 5 References

1. Materials Reliability Program: Screening, Categorization, and Ranking of Reactor Internals Components for Westinghouse and Combustion Engineering PWR Design (MRP-1 91).EPRI, Palo Alto, CA: 2006. 1013234.2. Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guidelines (MRP-227-A).

EPRI, Palo Alto, CA: 2011. 1022863.RAI 16-B In its September 27, 2013 response to RAI 16-A, Entergy proposed Commitment No. 50 stating that it would provide the NRC staff a detailed inspection plan for the IP2 split pins, including inspection methods, inspection coverage, and inspection frequency, by March 31, 2015, if the planned replacement of the IP2 split pins will not be accomplished in 2016. In order to resolve MRP-227-A Applicant/Licensee Action Item 3, the NRC staff requests Entergy submit the schedule for initial inspection, inspection methods, inspection coverage, and inspection frequency for the IP2 split pins in the event the IP2 split pins are not replaced by2016, and that Commitment No. 50 be modified accordingly.

Response to RAI 16-B Entergy commits to replacing the IP2 split pins during the 2016 refueling outage (2R22).Therefore, a schedule for initial inspection, inspection methods, inspection coverage, and inspection frequency for the IP2 split pins is not necessary.

Accordingly, Entergy is revising Commitment 50 and the identified LRA sections as follows (additions are underlined, deletions lined out).Commitment 50 If the plaRned rreplacement of the IP2 Split priS Will not be accomnplished in 2016, proVido tho NRC st-aff a adetailed inspection plan ifo the 1 P2 split pinS, inldn inspoction methods, inspection coverage, and ..inspection fequency, by March 31, 2016. Replace the IP2 split pins during the 2016 refueling outage (2R22).The following paragraph is revised in the Updated Final Safety Analysis Report LRA Section A.2.1.41.The IP2 guide tube support pins (split pins) will be replaced during the 2016 refueling outage (2R22) a.e-.hedue, , rp... e duing the-201- refe 'li;g outage. *" the planned replacemont of the 1P2 split pins will not be accomFplished in 2016, Entorgy wil provide the NRC staff a detailed inspection plan, including inspection methods, The following paragraph is revised in LRA Section B. 1.42, Reactor Vessel Internals Program, under "Evaluation/i.

Scope of Program," new last paragraph:

The IP2 guide tube support pins (split pins) are plant-specific components as discussed in MRP-227-A, Section 4.4.3, "Westinghouse Components." The split pins will be NL-14-067 Attachment 1 Page 4 of 5 replaced during the 2016 refueling outage (2R22) a .e-"Ghed,,ed to be r `placed during the 20146e .utagc. See letter NL-12-166, Entergy to NRC, response to RAI 16, dated November 20, 2012, and letter NL-14-067, Entergy to NRC. response to RAI 16B for further discussion.

if the planned of thc 11P2 split pins will not be accomplished in 2016, EnRtergy Will provfido the NRC staff a dctailcd inspoct'ion plan, 0l A iRGe:i9 llnethed.

ll lls, i..Gse ltSl, GEVelage, a .#equleql , nelaslthan March. 31, 2015.The revised commitment only affects IP2; therefore, LRA Section A.3.1.41 does not need revision.RAI 17-A In its September 27, 2013 response to RAI 17, Entergy provided a technical justification for the adequacy of the existing inspection requirements specified in MRP-227-A for the clevis insert bolts, which relies on its American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI Inservice Inspection (ISI) Program. Entergy's response included the statement, "[t]he video camera visual inspections at a ten-year interval by qualified personnel that are specified in the ASME Code Section Xl and MRP-227-A are capable of identifying wear or dislodged components of the clevis insert cap screws or dowel pins at any location, if they exist." To assure that the type of degradation documented in Westinghouse InfoGram IG-10-1 would be reliably detected at IP2 and IP3, the staff requests the following additional information:

1. Provide the ASME Code Section Xl, Table IWB-2500 Examination Category and Item Number under which the IP2 and IP3 clevis insert bolts are classified.

2. Verify that the ASME Code,Section XI examination of the clevis inserts directly views all the clevis insert bolt heads, dowel pins and locking devices for each clevis insert.3. If the ASME Code,Section XI examination does not directly view all the clevis insert bolts heads, locking devices, and dowel pins, propose a modification to Entergy's ASME Code, Section Xl ISI Program to do so.4. State when the most recent ASME Code, Section Xl inspection of the clevis insert bolts was conducted at IP2 and IP3. Summarize the findings of that inspection for the clevis insert bolts.Response to RAI 17-A 1. The clevis insert bolts at IP2 and IP3 are inspected as part of the Category B-N-2 Item Number B13.60 inspections.

2. At IPEC, the ASME Code, Section Xl examination of the clevis inserts directly views all the clevis insert bolt heads, dowel pins, and locking devices for each clevis insert.3. At IPEC, the ASME Code, Section Xl examination does directly view all the clevis insert bolts heads, locking devices, and dowel pins. The ASME Code requires a VT-3 of these NL-14-067 Attachment 1 Page 5 of 5 components and the VT-3 requirements include lighting and resolution requirements which will ensure that future inspections will continue to be performed in the same manner as they currently are being performed and, therefore, Entergy's ASME Code, Section Xl ISI program does not require modification.

4. The most recent ASME Code, Section Xl inspection of the clevis insert bolts was conducted at IP2 in 2006 with no recordable indications and at IP3 in 2009 with no recordable indications.

ATTACHMENT 2 TO NL-14-067 LICENSE RENEWAL APPLICATION IPEC LIST OF REGULATORY COMMITMENTS Rev. 23 ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286 NL-14-067 Attachment 2 Page 1 of 21List of Regulatory Commitments Rev. 23 The following table identifies those actions committed to by Entergy in this document.Changes are shown as strikethroughs for defte#GR, and underlines for additions.

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 1 Enhance the Aboveground Steel Tanks Program for oP2: NL-07-039 A.2.1.1 IP2 and IP3 to perform thickness measurements of omplete A.3.1.1 the bottom surfaces of the condensate storage tanks, lP3: city water tank, and fire water tanks once during the ecember 12, first ten years of the period of extended operation.

2015 Enhance the Aboveground Steel Tanks Program for IP2 and IP3 to require trending of thickness measurements when material loss is detected.2 Enhance the Bolting Integrity Program for IP2 and IP3 P2: NL-07-039 A.2.1.2 to clarify that actual yield strength is used in selecting Complete A.3.1.2 B.1.2 materials for low susceptibility to SCC and clarify the P3: prohibition on use of lubricants containing MoS 2 for omplete NL-07-153 Audit Items bolting. 201,241, The Bolting Integrity Program manages loss of NL-13-122 270 preload and loss of material for all external bolting. __ I I _ __ I NL-14-067 Attachment 2 Page 2 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I_ II/I AUDIT ITEM 3 Implement the Buried Piping and Tanks Inspection Program for IP2 and IP3 as described in LRA Section B.1.6.This new program will be implemented consistent with the corresponding program described in NUREG-1801 Section XI.M34, Buried Piping and Tanks Inspection.

Include in the Buried Piping and Tanks Inspection Program described in LRA Section B.1.6 a risk assessment of in-scope buried piping and tanks that includes consideration of the impacts of buried piping or tank leakage and of conditions affecting the risk forcorrosion. Classify pipe segments and tanks as having a high, medium or low impact of leakage based on the safety class, the hazard posed by fluid contained in the piping and the impact of leakage on reliable plant operation.

Determine corrosion risk through consideration of piping or tank material, soil resistivity, drainage, the presence of cathodic protection and the type of coating. Establish inspection priority and frequency for periodic inspections of the in-scope piping and tanks based on the results of the risk assessment.

Perform inspections using inspection techniques with demonstrated effectiveness.

IP2: Complete.P3: December 12, 2015 NL-07-039 NL-13-122 NL-07-153 NL-09-106 NL-09-111 A.2.1.5 A.3.1.5 B.1.6 Audit Item 173 NL-1 1-101 NL-14-067 Attachment 2 Page 3 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 4 Enhance the Diesel Fuel Monitoring Program to include cleaning and inspection of the IP2 GT-1 gas turbine fuel oil storage tanks, IF2 and TP3 EDG fuel oil day tanks, IP2 SBO/Appendix R diesel generator fuel oil day tank, and IP3 Appendix R fuel oil storage tank and day tank once every ten years.Enhance the Diesel Fuel Monitoring Program to include quarterly sampling and analysis of the IP2 SBO/Appendix R diesel generator fuel oil day tank, IP2 security diesel fuel oil storage tank, IP2 security diesel fuel oil day tank, and IP3 Appendix R fuel oil storage tank. Particulates, water and sediment checks will be performed on the samples. Filterable solids acceptance criterion will be less than or equal to 10mg/l. Water and sediment acceptance criterion will be less than or equal to 0.05%.Enhance the Diesel Fuel Monitoring Program to include thickness measurement of the bottom of the following tanks once every ten years. IP2: EDG fuel oil storage tanks, EDG fuel oil day tanks, SBO/Appendix R diesel generator fuel oil day tank, GT-1 gas turbine fuel oil storage tanks, and diesel fire pump fuel oil storage tank; IP3: EDG fuel oil day tanks, EDG fuel oil storage tanks, Appendix R fuel oil storage tank, and diesel fire pump fuel oil storage tank.Enhance the Diesel Fuel Monitoring Program to change the analysis for water and particulates to a quarterly frequency for the following tanks. IP2: GT-1 gas turbine fuel oil storage tanks and diesel fire pump fuel oil storage tank; IP3: Appendix R fuel oil day tank and diesel fire pump fuel oil storage tank.Enhance the Diesel Fuel Monitoring Program to specify acceptance criteria for thickness measurements of the fuel oil storage tanks within the scope of the program.Enhance the Diesel Fuel Monitoring Program to direct samples be taken and include direction to remove water when detected.Revise applicable procedures to direct sampling of the onsite portable fuel oil contents prior to transferring the contents to the storage tanks.

Enhance the Diesel Fuel Monitoring Program to direct the addition of chemicals including biocide when the presence of biological activity is confirmed.

I P2: Complete I P3: December 12, 2015 NL-07-039 NL-13-122 NL-07-153 NL-08-057 A.2.1.8 A.3.1.8 B.1.9Audit items 128, 129, 132, 491,492, 510 NL-14-067 Attachment 2 Page 4 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 5 Enhance the External Surfaces Monitoring Program P2: NL-07-039 A.2.1.10 for IP2 and IP3 to include periodic inspections of omplete A.3.1.10 systems in scope and subject to aging management PNL-13-122 B.1.11 review for license renewal in accordance with 10 CFR D3: 54.4(a)(1) and (a)(3). Inspections shall include areas err1 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).

IP2: NL-07-039 A.2. 1.11 6 Enhance the Fatigue Monitoring Program for IP2 to p2ete A.2.1.11 monitor steady state cycles and feedwater cycles or ornplete A.3.1.11 perform an evaluation to determine monitoring is not NL-13-122 Audt1te required.

Review the number of allowed events and NL-07-153 Audit Item resolve discrepancies between reference documents 164 and monitoring procedures.

P3: Enhance the Fatigue Monitoring Program for IP3 to December 12, include all the transients identified.

Assure all fatigue 2015 analysis transients are included with the lowest limiting numbers. Update the number of design transients accumulated to date.

NL-14-067 Attachment 2 Page 5 of 21 COMMITMENT IMPLEMENTATION SOURCE I RELATED SCHEDULE LRA SECTION I AUDIT ITEM 7 Enhance the Fire Protection Program to inspect external surfaces of the JP3 RCP oil collection systems for loss of material each refueling cycle.Enhance the Fire Protection Program to explicitly state that the IP2 and IP3 diesel fire pump engine sub-systems (including the fuel supply line) shall be observed while the pump is running. Acceptance criteria will be revised to verify that the diesel engine does not exhibit signs of degradation while running;such as fuel oil, lube oil, coolant, or exhaust gas leakage.Enhance the Fire Protection Program to specify that the IP2 and IP3 diesel fire pump engine carbon steel exhaust components are inspected for evidence of corrosion and cracking at least once each operating cycle.Enhance the Fire Protection Program for IP3 to visually inspect the cable spreading room, 480V switchgear room, and EDG room C02 fire suppression system for signs of degradation, such as corrosion and mechanical damage at least once every six months.P2: ,omplete NL-07-039 NL-13-122 A.2.1.12 A.3.1.12 B.1.13 P3: December 12, 2015 NL-14-067 Attachment 2 Page 6 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE [LRA SECTION j/ AUDIT ITEM 8 Enhance the Fire Water Program to include inspection of IP2 and IP3 hose reels for evidence of corrosion.

Acceptance criteria will be revised to verify no unacceptable signs of degradation.

Enhance the Fire Water Program to replace all or testa sample of IP2 and IP3 sprinkler heads required for 10 CFR 50.48 using guidance of NFPA 25 (2002 edition), Section 5.3.1.1.1 before the end of the 50-year sprinkler head service life and at 10-year intervals thereafter during the extended period of operation to ensure that signs of degradation, such as corrosion, are detected in a timely manner.Enhance the Fire Water Program to perform wall thickness evaluations of IP2 and IP3 fire protection piping on system components using non-intrusive techniques (e.g., volumetric testing) to identify evidence of loss of material due to corrosion.

These inspections will be performed before the end of thecurrent operating term and at intervals thereafter during the period of extended operation.

Results of the initial evaluations will be used to determine the appropriate inspection interval to ensure aging effects are identified prior to loss of intended function.Enhance the Fire Water Program to inspect the internal surface of foam based fire suppression tanks.Acceptance criteria will be enhanced to verify nosianificant corrosion.

P2: ,omplete NL-07-039 NL-13-122 NL-07-153 NL-08-014 A.2.1.13 A.3.1.13 B.1.14 Audit Items 105,106 P3: December 12, 2015 NL-14-067 Attachment 2 Page 7 of 21 COMMITMENT IMPLEMENTATION SCHEDULE SOURCE RELATED LRA SECTION/ AUDIT ITEM 9 Enhance the Flux Thimble Tube Inspection Program for IP2 and IP3 to implement comparisons to wear rates identified in WCAP-12866.

Include provisions to compare data to the previous performances and perform evaluations regarding change to testfrequency and scope.Enhance the Flux Thimble Tube Inspection Program for IP2 and IP3 to specify the acceptance criteria as outlined in WCAP-12866 or other plant-specific values based on evaluation of previous test results.Enhance the Flux Thimble Tube Inspection Program for IP2 and IP3 to direct evaluation and performance of corrective actions based on tubes that exceed or are projected to exceed the acceptance criteria.

Also stipulate that flux thimble tubes that cannot be inspected over the tube length and cannot be shown by analysis to be satisfactory for continued service, must be removed from service to ensure the integrity of the reactor coolant system pressure boundary.IP2: Complete I P3: December 12, 2015 NL-07-039 NL-13-122 A.2.1.15 A.3.1.15 B.1.16 NL-14-067 Attachment 2 Page 8 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I_ I / AUDIT ITEM 10 Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to include the following heat exchangers in the scope of the program.* Safety injection pump lube oil heat exchangers

• RHR heat exchangers

• RHR pump seal coolers* Non-regenerative heat exchangers

• Charging pump seal water heat exchangers

• Charging pump fluid drive coolers* Charging pump crankcase oil coolers* Spent fuel pit heat exchangers

• Secondary system steam generator sample coolers* Waste gas compressor heat exchangers

• SBO/Appendix R diesel jacket water heat exchanger (IP2 only)

Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to perform visual inspection on heat exchangers where non-destructive examination, such as eddy current inspection, is not possible due to heat exchanger design limitations.

Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to include consideration of material-environment combinations when determining sample population of heat exchangers.

Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to establish minimum tube wall thickness for the new heat exchangers identified in the scope of the prcgram. Establish acceptance criteria for heat exchangers visually inspected to include no indication of tube erosion, vibration wear, corrosion, pitting, fouling, or scaling.P2: complete P3: December 12, 2015 NL-07-039 NL-13-122 NL-07-153 NL-09-018 A.2.1.16 A.3.1.16 B.1.17, Audit Item 52 11 Deleted NL-09-056{ I NL-11-101 NL-14-067 Attachment 2 Page 9 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 12 Enhance the Masonry Wall Program for IP2 and IP3 1P2: NL-07-039 A.2.1.18 to specify that the IP1 intake structure is included in Complete A.3.1.18 the program. IP3:NL-13-122 B.1.19 Complete 13 Enhance the Metal-Enclosed Bus Inspection Program 1P2: NL-07-039 A.2.1.19 for IP2 and IP3 to visually inspect the external surface Complete A.3.1.19 NL-13-122 B.1.20 of MEB enclosure assemblies for loss of material at NL-13-122 Aui.tm least once every 10 years. The first inspection will occur prior to the period of extended operation and -ecember 12, 124, the acceptance criterion will be no significant loss of 015 NL-08-057 133,519 material.

NL-13-077 Enhance the Metal-Enclosed Bus Inspection Program to add acceptance criteria for MEB internal visual inspections to include the absence of indications of dust accumulation on the bus bar, on the insulators, and in the duct, in addition to the absence of indications of moisture intrusion into the duct.Enhance the Metal-Enclosed Bus Inspection Programfor IP2 and IP3 to inspect bolted connections at least once every five years if performed visually or at least once every ten years using quantitative measurements such as thermography or contactresistance measurements.

The first inspection will occur prior to the period of extended operation.

The plant will process a change to applicable site procedure to remove the reference to "re-torquing" connections for phase bus maintenance and bolted connection maintenance.

14 Implement the Non-EQ Bolted Cable Connections P2: NL-07-039 A.2.1.21 Program for IP2 and IP3 as described in LRA Section Nomplete A.3.1.21 B. .2.NL-13-122 B.1.22 B.1.22. IP3: lecember 12,__015 NL-14-067 Attachment 2 Page 10 of 21 COMMITMENT IMPLEMENTATION SCHEDULE SOURCE RELATED LRA SECTION/ AUDIT ITEM 15 Implement the Non-EQ Inaccessible Med'um-Voltage oP2: NL-07-039 A.2.1.22 Cable Program for IP2 and IP3 as described in LRA omplete NL-13-122

.1.2 Section B.1 .23. N1322 B.1.23 IP3: NL-07-153 Audit item This new program will be implemented consistent with December 12, 173 the corresponding program described in NUREG- 2015 NL-1 1-032 1801 Section Xl.E3, Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 Environmental NL-11-096 Qualification Requirements.

NL-1 1-101 IP2: NL-07-039 A.2.1.23 16 Implement the Non-EQ Instrumentation Circuits Test A.2.1.23 Review Program for IP2 and IP3 as described in LRA Complete A.3.1.23 SecionB.124.NL-13-122 B. 1.24 Section B.1.24. IP3: NL-07-153 Audit item This new program will be implemented consistent with December 12, 173 the corresponding program described in NUREG- ?015 1801 Section XI.E2, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits.IP2: NL-07-039 A.2.1.24 17 Implement the Non-EQ Insulated Cables and Connections Program for IP2 and IP3 as described in omplete A.3.1.24 LRA Section B.1.25. NL-13-122 B.1.25 P3: NL-07-153 Audit item This new program will be implemented consistent with December 12, 173 the corresponding program described in NUREG- 2015 1801 Section XI.E1, Electrical Cables and Connections Not Subject to 10 CFR 50.46 Environmental Qualification Requirements.

NL-14-067 Attachment 2 Page 11 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 18 Enhance the Oil Analysis Program for IP2 to sample 1P2: NL-07-039 A.2.1.25 and analyze lubricating oil used in the SBO/Appendix Complete A.3.1.25 NL-13-122 B.1.26 R diesel generator consistent with the oil analysis for P3: NL-11-101 other site diesel generators.

December 12, Enhance the Oil Analysis Program for IP2 and IP3 to 2015sample and analyze generator seal oil and turbine hydraulic control oil.Enhance the Oil Analysis Program for IP2 and IP3 to formalize preliminary oil screening for water and particulates and laboratory analyses including defined acceptance criteria for all components included in the scope of this program. The program will specify corrective actions in the event acceptance criteria are not met.Enhance the Oil Analysis Program for IP2 and IP3 to formalize trending of preliminary oil screening results as well as data provided from independent laboratories.

19 Implement the One-Time Inspection Program for IP2 P2: NL-07-039 A.2.1.26 and IP3 as described in LRA Section 1.1.27. Complete A.3.1.26 NL-13-122 B.1.27 This new program will be implemented consistent with P3: NL-07-153 Audit item the corresponding program described in NUREG- ecember 12, 173 1801,Section XI.M32, One-Time Inspection.

015 20 Implement the One-Time Inspection

-Small Bore P2: NL-07-039 A.2.1.27 Piping Program for IP2 and IP3 as described in LRA omplete A.3.1.27 Section 1.1.28. NL-13-122 6.1.28 1 P3: NL-07-153 Audit item This new program will be implemented consistent with December 12, 173 the corresponding program described in NUREG- 2015 1801,Section XI.M35, One-Time Inspection of ASME Code Class I Small-Bore Piping.21 Enhance the Periodic Surveillance and Preventive P2: NL-07-039 A.2.1.28 Maintenance Program for IP2 and IP3 as necessary omplete A.3.1.28 to assure that the effects of aging will be managed P3: NL-13-122 B.1.29 such that applicable components will continue to perform their intended functions consistent with the em 1 current licensing basis through the period of extended I operation.

NL-14-067 Attachment 2 Page 12 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 22 Enhance the Reactor Vessel Surveillance Program for P2: NL-07-039 A.2.1.31 IP2 and IP3 revising the specimen capsule withdrawal Complete A.3.1.31 NL-13-122 B.1.32 schedules to draw and test a standby capsule to P3: cover the peak reactor vessel fluence expected December 12, through the end of the period of extended operation.

2015 Enhance the Reactor Vessel Surveillance Program for IP2 and IP3 to require that tested and untested specimens from all capsules pulled from the reactor vessel are maintained in storage.IP2: NL-07-039 A.2.1.3223 Implement the Selective Leaching Program for IP2 Cpet LA.3.1.32 and IP3 as described in LRA Section B.1.33. omplete A.3.1.32NL-13-122 B.1.33 This new program will be implemented consistent with IP3: NL-07-153 Audit item the corresponding program described in NUREG- ecember 12, 173 1801,Section XI.M33 Selective Leaching of Materials.

015 24 Enhance the Steam Generator Integrity Program for P2- NL-07-039 A.2.1.34 IP2 and IP3 to require that the results of the condition omplete A.3.1.34 NL-13-122 B.1.35 monitoring assessment are compared to the PP3B operational assessment performed for the prior omplete operating cycle with differences evaluated.

f Enhance the Structures Monitoring Program to P2: NL-07-039 A.2.1.35 25 explicitly specify that the following structures are omplete A.3.1.35 included in the program. NL-13-122 B.1.36 G Appendix R diesel generator foundation (IP3) P3: NL-07-153 0 Appendix R diesel generator fuel oil tank vault December 12, Audit items (IP3) 2015 86, 87, 88, 6 Appendix R diesel generator switchgear and NL-08-057 417 enclosure (IP3)a city water storage tank foundation

• condensate storage tanks foundation (IP3) NL-13-077* containment access facility and annex (IP3)* discharge canal (IP2/3)0 emergency lighting poles and foundations (IP2/3)* fire pumphouse (IP2)0 fire protection pumphouse (IP3)* fire water storage tank foundations (IP2/3)* gas turbine 1 fuel storage tank foundation

• maintenance and outage building-elevated passageway (IP2)0 new station security building (IP2)

• nuclear service building (IP1)* primary water storage tank foundation (IP3)_ refueling water storage tank foundation (IP3)

NL-14-067 Attachment 2 Page 13 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I_____ /AUDIT ITEM 0 0 0 0 0 0 security access and office building (IP3)service water pipe chase (IP2/3)service water valve pit (IP3)superheater stack transformer/switchyard support structures (IP2)waste holdup tank pits (IP2/3)Enhance the Structures Monitoring Program for IP2 and IP3 to clarify that in addition to structural steel and concrete, the following commodities (including their anchorages) are inspected for each structure as applicable.

• cable trays and supports* concrete portion of reactor vessel supports* conduits and supports* cranes, rails and girders* equipment pads and foundations

• fire proofing (pyrocrete)" HVAC duct supports* jib cranes* manholes and duct banks* manways, hatches and hatch covers* monorails* new fuel storage racks* sumps Enhance the Structures Monitoring Program for IP2 and IP3 to inspect inaccessible concrete areas that are exposed by excavation for any reason. IP2 and IP3 will also inspect inaccessible concrete areas in environments where observed conditions in accessible areas exposed to the same environment indicate that significant concrete degradation is occurring.

Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspections of elastomers (seals, gaskets, seismic joint filler, and roof elastomers) to identify cracking and change in material properties and for inspection of aluminum vents and louvers to identify loss of material.NL-13-077 Enhance the Structures Monitoring Program for IP2 NL-14-067 Attachment 2 Page 14 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I I./ AUDIT ITEM and IP3 to perform an engineering evaluation of groundwater samples to assess aggressiveness of groundwater to concrete on a periodic basis (at least once every five years). IPEC will obtain samples from at least 5 wells that are representative of the ground water surrounding below-grade site structures and perform an engineering evaluation of the results from those samples for sulfates, pH and chlorides.

Additionally, to assess potential indications of spent fuel pool leakage, IPEC will sample for tritium in groundwater wells in close proximity to the IP2 spentfuel pool at least once every 3 months.Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspection of normally submerged concrete portions of the intake structures at least once every 5 years. Inspect the baffling/grating partition and support platform of the IP3 intake structure at least once every 5 years.Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspection of the degraded areas of the water control structure once per 3 years ratherthan the normal frequency of once per 5 years during the PEO.Enhance the Structures Monitoring Program to include more detailed quantitative acceptance criteria for inspections of concrete structures in accordance with ACI 349.3R, "Evaluation of Existing Nuclear Safety-Related Concrete Structures" prior to the period of extended operation.

NL-08-127 Audit Item 360 Audit Item 358 NL-1 1-032 NL-1 1-101 P2: NL-07-039 A.2.1.36 26 Implement the Thermal Aging Embrittlement of Cast A.2.1.36 Austenitic Stainless Steel (CASS) Program for IP2 omplete A.3.1.36 and IP3 as described in LRA Section B.1.37. NL-13-122 B.1.37 P3: NL-07-153 Audit item This new program will be implemented consistent with ecember 12, 173 the corresponding program described in NUREG- 015 1801,Section XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)

Program.

NL-14-067 Attachment 2 Page 15 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 27 Implement the Thermal Aging and Neutron Irradiation 1P2: NL-07-039 A.2.1.37 Embrittlement of Cast Austenitic Stainless Steel Complete A.3.1.37 NL-13-122 B.1.38 (CASS) Program for IP2 and IP3 as described in LRA IP3: NL-07-153 Audit item Section B.1.38.Complete 173 This new program will be implemented consistent with the corresponding program described in NUREG-1801 Section XI.M13, Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program.28 Enhance the Water Chemistry Control -Closed IP2: NL-07-039 A.2.1.39 Cooling Water Program to maintain water chemistry of Complete A.3.1.39 NL-13-122 B.1.40 the IP2 SBO/Appendix R diesel generator cooling IP3: NL-08-057 Audit item system per EPRI guidelines.

Complete 509Enhance the Water Chemistry Control -Closed Cooling Water Program to maintain the IP2 and IP3 security generator and fire protection diesel cooling water pH and glycol within limits specified by EPRI guidelines.

29 Enhance the Water Chemistry Control -Primary and P2: NL-07-039 A.2.1.40 Secondary Program for IP2 to test sulfates monthly in omplete B.1N.41 the RWST with a limit of <150 ppb. NL-13-122 30 For aging management of the reactor vessel internals, P2: NL-07-039 A.2.1.41 IPEC will (1) participate in the industry programs for omplete NL-13-122 A.3.1.41 investigating and managing aging effects on reactor N-31 internals; (2) evaluate and implement the results of Complete the industry programs as applicable to the reactor internals; and (3) upon completion of these programs, but not less than 24 months before entering the period of extended operation, submit an inspection plan for NL-1 1-107 reactor internals to the NRC for review and approval.P2: NL-07-039 A.2.2.1.2 31 Additional P-T curves will be submitted as required p2Nte A.3.2.1.2 per 10 CFR 50, Appendix G prior to the period of omplete A.3.2.1.2 extended operation as part of the Reactor Vessel PNL-13-122 4.2.3 Surveillance Program. ecember 12, 2015 32 As required by 10 CFR 50.61 (b)(4), IP3 will submit a P3: NL-07-039 A.3.2.1.4 plant-specific safety analysis for plate B2803-3 to the December 12, 4.2.5 NRC three years prior to reaching the RTPTS 015 NL-08-127 screening criterion.

Alternatively, the site may choose to implement the revised PTS rule when approved.

NL-14-067 Attachment 2 Page 16 of 21 COMMITMENT IMPLEMENTATION SOURCE I RELATED SCHEDULE LRA SECTION I_/ I I / AUDIT ITEM 33 At least 2 years prior to entering the period of extended operation, for the locations identified in LRA Table 4.3-13 (1P2) and LRA Table 4.3-14 (!P3), under the Fatigue Monitoring Program, IP2 and IP3 will implement one or more of the following:

(1) Consistent with the Fatigue Monitoring Program, Detection of Aging Effects, update the fatigue usage calculations using refined fatigue analyses to determine valid CUFs less than 1.0 when accounting for the effects of reactor water environment.

This includes applying the appropriate Fen factors to valid CUFs determined in accordance with one of the following:

1. For locations in LRA Table 4.3-13 (IP2) and LRATable 4.3-14 (IP3), with existing fatigue analysis valid for the period of extended operation, use the existing CUF.2. Additional plant-specific locations with a valid CUF may be evaluated.

In particular, the pressurizer lower shell will be reviewed to ensure the surge nozzleremains the limiting component.

3. Representative CUF values from other plants, adjusted to or enveloping the IPEC plant specific external loads may be used if demonstrated applicable to IPEC.4. An analysis using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case) may be performed to determine a valid CUF.(2) Consistent with the Fatigue Monitoring Program, Corrective Actions, repair or replace the affected locations before exceeding a CUF of 1.0.P2: Domplete P3: Domplete NL-07-039 NL-13-122 NL-07-153 NL-08-021 NL-10-082 A.2.2.2.3 A.3.2.2.3 4.3.3 Audit item 146 34 1P2 SBO / Appendix R diesel generator will be NL-13-122 2.1.1.3.5 installed and operationaesel gy erator wi bemplet NL-07-078 committed change to the facility meets the 0Complete requirements of 10 CFR 50.59(c)(1) and, therefore, a license amendment pursuant to 10 CFR 50.90 is not NL-1 1-101 required.

NL-11-101 NL- 14-067 Attachment 2 Page 17 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 35 Perform a one-time inspection of representative P2: NL-08-127 Audit Item sample area of IP2 containment liner affected by the ompleteNL-13-122 1973 event behind the insulation, prior to ente'ing the period of extended operation, to assure liner degradation is not occurring in this area. P3: NL-1 1-101 Perform a one-time inspection of representative December 12, sample area of the I P3 containment steel liner at the ?015 juncture with the concrete floor slab, prior to entering the period of extended operation, to assure liner degradation is not occurring in this area.Any degradation will be evaluated for updating of the NL-09-018 containment liner analyses as needed.IP2: NL-08-127 Audit Item 36 Perform a one-time inspection and evaluation of a sample of potentially affected IP2 refueling cavity omplete NL-11-101 359 concrete prior to the period of extended operation.

NL-13-122 The sample will be obtained by core boring the refueling cavity wall in an area that is susceptible to exposure to borated water leakage. The inspection will include an assessment of embedded reinforcing steel.Additional core bore samples will be taken, if the NL-09-056 leakage is not stopped, prior to the end of the first ten years of the period of extended operation.

A sample of leakage fluid will be analyzed to NL-09-079 determine the composition of the fluid. If additional core samples are taken prior to the end of the first ten years of the period of extended operation, a sample of leakage fluid will be analyzed.IP2: NL-08-127 Audit Item 37 Enhance the Containment Inservice Inspection (CII- P2: 361 IWL) Program to include inspections of the Complete NL-13-122 361 containment using enhanced characterization of IP3: degradation (i.e., quantifying the dimensions of noted Complete indications through the use of optical aids) during the period of extended operation.

The enhancement includes obtaining critical dimensional data of degradation where possible through direct measurement or the use of scaling technologies for photographs, and the use of consistent vantage points for visual inspections.

NL-14-067 Attachment 2 Page 18 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 1P2: NL-08-143 4.2.1 38 For Reactor Vessel Fluence, should future core loading patterns invalidate the basis for the projected Complete values of RTpts or CRUSE, updated calculations will N3: be provided to the NRC. P3:br 2]ecember 12,ý0115 39 Deleted NL-09-079 40 Evaluate plant specific and appropriate industry pNL-09-106 B.1.6 operating experience and incorporate lessons learned Complete B. 1.22 in establishing appropriate monitoring and inspection NL-13-122 B.1.23 frequencies to assess aging effects for the new aging ecember 12, B.1.25 management programs.

Documentation of the _e015 B.1.27 operating experience evaluated for each new program B.1.28 will be available on site for NRC review prior to the B.1.28 period of extended operation.

B.1.33 B. 1.37 B.1.38 41 IPEC will inspect steam generators for both units to NL-1 1-032 N/A assess the condition of the divider plate assembly.

egn t The examination technique used will be capable of Peginning of the detecting PWSCC in the steam generator divider plate EO and prior to assembly.

The IP2 steam generator divider plate eptember 28, inspections will be completed within the first ten years NL-1 1-074 of the period of extended operation (PEO). The IP3 NL-1 1-090 steam generator divider plate inspections will be completed within the first refueling outage following Prior to the end the beginning of the PEO. f the first NL-11-101 refueling outage Following the Deginning of the PEO.II NL-14-067 Attachment 2 Page 19 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION 1 1_ _ / AUDIT ITEM 42 IPEC will develop a plan for each unit to address the potential for cracking of the primary to secondary pressure boundary due to PWSCC of tubc -to-tubesheet welds using one of the following two options.Option 1 (Analysis)

IPEC will perform an analytical evaluation of the steam generator tube-to-tubesheet welds in order to establish a technical basis for either determining that the tubesheet cladding and welds are not susceptible to PWSCC, or redefining the pressure boundary in which the tube-to-tubesheet weld is no longer included and, therefore, is not required for reactor coolant pressure boundary function.

The redefinition of the reactor coolant pressure boundary must be approved by the NRC as a license amendment request.Option 2 (Inspection)

IPEC will perform a one-time inspection of a representative number of tube-to-tubesheet welds ineach steam generator to determine if PWSCC cracking is present. If weld cracking is identified:

a. The condition will be resolved through repair or engineering evaluation to justify continued service, as appropriate, and

b. An ongoing monitoring program will be established to perform routine tube-to-tubesheet weld inspections for the remaining life of the steam generators.

NL-1 1-032 NL-1 1-074 NL-1 1-090 NL-1 1-096 N/A I P2: Prior to March 2024 IP3: Prior to the end of the first refueling outage following the beginning of the PEO.IP2: Between March 2020 and March 2024 1P3: Prior to the end of the first refueling outage following the beginning of the PEO.43 IPEC will review design basis ASME Code Class 1 fatigue evaluations to determine whether the NUREG/CR-6260 locations that have been evaluated for the effects of the reactor coolant environment on fatigue usage are the limiting locations for the IP2 and IP3 configurations.

If more limiting locations are identified, the most limiting location will be evaluated for the effects of the reactor coolant environment on fatigue usage.IPEC will use the NUREG/CR-6909 methodology in the evaluation of the limiting locations consisting of nickel alloy, if any.P2:.complete P3: Prior to)ecember 12, 2015 NL-1 1-032 NL-13-122 NL-1 1-101 4.3.3 NL-14-067 Attachment 2 Page 20 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 44 IPEC will include written explanation and justification oP2: NL-11-032 N/A of any user intervention in future evaluations using the omplete NL-1 1-101 WESTEMS "Design CUF" module. IP3: Prior to NL-13-122 December 12, 2015 45 IPEC will not use the NB-3600 option of the P2: NL-1 1-032 N/A WESTEMS program in future design calculations until omplete NL11-101 the issues identified during the NRC review of the P3: Prior to NL-13-122 program have been resolved.

December 12, 2015 46 Include in the IP2 IS[ Program that IPEC will perform P2: NL-1 1-032 N/A twenty-five volumetric weld metal inspections of omplete NL-1 1-074 socket welds during each 10-year ISI interval NL-1122 scheduled as specified by IWB-2412 of the ASME NL-13-122 Section Xl Code during the period of extended operation.

In lieu of volumetric examinations, destructive examinations may be performed, where one destructive examination may be substituted for two volumetric examinations.

47 IPEC will and submit aRaly"es that W-- N12089 N/A demonzstrate that the lOWor cUPPGot GGlUF-bedee-wiGF maditain their f-nctionality g the p o .-,, 02f_____ 14-12-32a otd ,,de , pc.atiOn conidorig tho possible loss of 3 to fracture toughness duo to thormal and OFadiatiOR emb12 NL406 ombrittlomont.

The analyses will be .....is..t With NL-14-067 the IPWZ1P3 iOn ...ing baSis. Deleted.

NL-14-067 Attachment 2 Page 21 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 48 Entergy will visually inspect IPEC underground piping P2: NL-12-174 N/A within the scope of license renewal and subject to omplete aging management review prior to the period of lP3: Prior to NL-13-122 extended operation and then on a frequency of at December 12, least once every two years during the period of extended operation.

This inspection frequency will be maintained unless the piping is subsequently coated in accordance with the preventive actions specified in NUREG-1801 Section XI.M41 as modified by LR-ISG-2011-03. Visual inspections will be supplemented with surface or volumetric non-destructive testing if indications of significant loss of material areobserved. Consistent with revised NUREG-1 801 Section XI.M41, such adverse indications will be entered into the plant corrective action program for evaluation of extent of condition and for determination of appropriate corrective actions (e.g., increased inspection frequency, repair, replacement).

49 Recalculate each of the limiting CUFs provided in P2: NL-13-052 A.2.2.2 section 4.3 of the LRA for the reactor vessel internals omplete A.3.2.2to include the reactor coolant environment effects P3: Prior to NL-13-122 (Fen) as provided in the IPEC Fatigue Monitoring ecember 12, Program using NUREG/CR-5704 or NUREG/CR-2015 6909. In accordance with the corrective actions specified in the Fatigue Monitoring Program, corrective actions include further CUF re-analysis, and/or repair or replacement of the affected components prior to the CUFen reaching 1.0.50 f .the planned cplacemcnt of the 1122 split pine P2: NL-1 3-122 A.2.1.41 will not be in 2016, proVide the B.1.42 NRC staff a detailed in.pection plaR for the IP2 , 20!5 NL-14-067split pins, including ORSPectiOR methods, n.p.c.i ; coe"rage, and 5nRpctti0R fr.equency, rior to by March 31, 2015. Replace the IP2 split pins ;ompletion of during the 2016 refueling outa-ge (2R22). 2R22 P3: N/A

-Entergy Enterav Nuclear Northeast Indian Point Energy Center 450 Broadway, GS13 P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 254-2055 Fred Dacimno Vice President Operations License Renewal NL-14-067 June 9, 2014 U.S. Nuclear Regulatory Commission Document Control Desk 11545 Rockville Pike, TWFN-2 F1 Rockville, MD 20852-2738

REFERENCE:

Reply to Request for Additional Information Regarding the License Renewal Application Indian Point Nuclear Generating Unit Nos. 2 & 3Docket Nos.

50-247 and 50-286 License Nos. DPR-26 and DPR-64 NRC letter, "Request for Additional Information for the Review of the Indian Point Nuclear Generating Unit Nos. 2 and 3, License Renewal Application, SET 2014-02 (TAC Nos. MD5407 and MD5408)" dated April 9, 2014.

Dear Sir or Madam:

Entergy Nuclear Operations, Inc. is providing, in Attachment 1, the additional information requested in the referenced letter pertaining tcu NRC review of the License Renewal Application (LRA) for Indian Point 2 and Indian Point 3.The responses to RAI 11-C. and RAI 16-B include the deletion of Commitment 47 and a revision to Commitment 50, respectively.

These commitment changes are included in the list of regulatory commitments provided in Attachment 2.If you have any questions, or require additional information, please contact Mr. Robert Walpoleat 914-254-6710.

I declare d r penalty of perjury that the foregoing is true and correct. Executed on M 2014.Sin erely FRD/rw Docket Nos. 50-247 & 50-286 NL-14-067 Page 2 of 2

Attachment:

1. Reply to NRC Request for Additional Information Regarding the License Renewal Application

2. License Renewal Application IPEC List of Regulatory Commitments Revision 23 cc: Mr. William Dean, Regional Administrator, NRC Region I Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel Mr. Dave Wrona, NRC Branch Chief, Engineering Review Branch I Ms. Kimberly Green, NRC Sr. Project Manager, Division of License Renewal Mr. Douglas Pickett, NRR Senior Project Manager Ms. Bridget Frymire, New York State Department of Public Service NRC Resident Inspector's Office Mr. John B. Rhodes, President and CEO NYSERDA ATTACHMENT 1 TO NL-14-067 REPLY TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE LICENSE RENEWAL APPLICATION ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286 NL-14-067 Attachment 1 Page 1 of 5 REQUEST FOR ADDITIONAL.INFORMATION, SET 2014-02 RELATED TO INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION REACTOR VESSEL INTERNALS PROGRAM AND INSPECTION PLAN RA! 11-C Applicant/Licensee Action Item 7 from the staff's final safety evaluation (SE) of MRP-227 requires the applicants/licensees of Babcock & Wilcox (B&W), Combustion Engineering (CE), and Westinghouse reactors to develop plant-specific analyses to be applied for their facilities to demonstrate that B&W In-Core Monitoring Instrumentation (IMI) guide tube assembly spiders and control rod guide tube (CRGT) assembly spacer castings, CE lower support columns, and Westinghouse lower support column bodies will maintain their functionality during the period of extended operation, and states that these analyses should also consider the possible loss of fracture toughness in these components due to thermal embrittlement (TE) and irradiation embrittlement (IE). For Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3), the equivalent component to the lower support column bodies are the lower internals assembly -column caps (column caps).By letter dated January 28, 2014, Entergy provided plant specific information on the ferrite content and susceptibility to TE for the Indian Point Nuclear Generating Unit Nos. 2 and 3 lower internals assembly -column caps. Based on its evaluation of the plant-specific material information for the column caps, Entergy concluded that the IP2 and IP3 column caps are not susceptible to TE.Entergy's conclusion related to TE notwithstanding, the column caps remain susceptible to IE.The staff is concerned that the linked Primary component for the column caps, the CRGT assembly lower flange welds, is not a good predictor of IE for the column caps since the CRGT lower flange welds receive substantially lower neutron fluence than the column caps (based on the estimated neutron fluence tabulated in MRP-191 for the two components).

Irradiation assisted stress corrosion cracking (IASCC) is the only mechanism of cracking that screened in for the column caps. The CRGT lower flange welds are also not a good predictor for IASCC of the column caps, because the lower flange welds are susceptible to stress corrosion cracking (SCC) and fatigue cracking, but not IASCC.The staff, therefore, requests that Entergy modify its Reactor Vessel Internals Inspection Plan (RVI Inspection Plan) to provide a link to a Primary component or components that isan appropriate predictor of IE and IASCC of the column caps.Response to RAI 11-C The following text will be incorporated into the reactor vessel internals (RVI) Inspection Plan for Indian Point Units 2 and 3 regarding a link to a component that is an appropriate predictor of irradiation embrittlement (IE) and irradiation-assisted stress corrosion cracking (IASCC) of the column caps.

NL-14-067 Attachment 1 Page 2 of 5'The lower core plate, which was screened in for IASCC in MRP..191[1], is a leading indicator of cracking in the column caps of the lower support column bodies because it is subject to more severe service conditions. Due to its proximity to the core, the lower core plate experiences bothhigher fluences and higher gamma heating than the column caps. Additionally, thermally induced tensile stresses are anticipated in the lower core plate while the stresses in the column caps are largely compressive.

These factors are expected to contribute to earlier IASCC initiation in the lower core plate, making it a suitable leading indicator of cracking in the column caps.The lower support column caps at Indian Point Units 2 and 3 have the same irradiation embrittlement mechanism as the wrought stainless steel lower core plate. The 60-year fluence in the top few inches of the lower support column body, which is where the column cap is located, is projected to exceed the threshold for irradiation embrittlement of austenitic stainless steel. Therefore, irradiation embrittlement is considered a damage mechanism in the column caps.Considering both the cracking mechanism and the likely embrittlement mechanism, a leading indicator of degradation for the column caps is the lower core plate.

Since the lower core plate is an Existing Programs component in MRP-227-A

[21 and must be inspected as part of the aging management program, it is an appropriate alternate component for predicting aging effects.The lower core plate will continue to be an Existing Programs component, managed under the Indian Point program for ASME Section Xl inspections.

The inspection requirement will remain a VT-3 inspection of the accessible upper surface on a ten-year interval.

In addition to the standard requirements for assessing extent of condition required under ASME Section Xl, a trigger for the Expansion inspection of the lower support column bodies (column caps) for Indian Point Units 2 and 3 will be the confirmed discovery of a service induced flaw in the lower core plate." The intent of Commitment 47 was to demonstrate that the lower support column bodies will maintain their functionality during the period of extended operation considering the possible loss of fracture toughness due to thermal and irradiation embrittlement.

As the staff noted in this RAI 11-C, Entergy has concluded that the IP2 and IP3 column caps (equivalent component to the lower support column bodies) are not susceptible to TE and will modify the Reactor Vessel Internals (RVI) Inspection Plan to credit inspection of the lower core plate as an appropriate predictor of IE and IASCC of the column caps. Therefore, the functionality of the lower support column bodies is assured during the period of extended operation without the need for a functionality analysis.

Therefore, Entergy is deleting Commitment 47 (additions are underlined, deletions lined out).Commitment 47 IPEC will peorfm and submit analyses that tho loWor .uppe. t column bodio,, wil m1 aintain thoir hfunctienality during the poriod of oxtondod operation; concidoring the pocciblo9 lace of fracture toughnocc duo to therm;al and irradiation omnbrittlomnet.

The analycoc will be GGRG!6teRt KH tHe 11-atilde 11GeHG1HgLI.gIeIeU.

NL- 14-067 Attachment 1 Page 3 of 5 References

1. Materials Reliability Program: Screening, Categorization, and Ranking of Reactor Internals Components for Westinghouse and Combustion Engineering PWR Design (MRP-1 91).EPRI, Palo Alto, CA:

2006. 1013234.2. Materials Re~iability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guidelines (MRP-227-A). EPRI, Palo Alto, CA: 2011. 1022863.RAI 16-B In its September 27, 2013 response to RAI 16-A, Entergy proposed Commitment No. 50 stating that it would provide the NRC staff a detailed inspection plan for the IP2 split pins, including inspection methods, inspection coverage, and inspection frequency, by March 31, 2015, if the planned replacement of the IP2 split pins will not be accomplished in 2016. In order to resolve MRP-227-A Applicant/Licensee Action Item 3, the NRC staff requests Entergy submit the schedule for initial inspection, inspection methods, inspection coverage, and inspection frequency for the IP2 split pins in the event the IP2 split pins are not replaced by 2016, and that Commitment No. 50 be modified accordingly.

Response to RA! 16-BEntergy commits to replacing the IP2 split pins during the 2016 refueling outage (2R22).Therefore, a schedule for initial inspection, inspection methods, inspection coverage, and inspection frequency for the IP2 split pins is not necessary.

Accordingly, Entergy is revising Commitment 50 and the identified LRA sections as follows (additions are underlined, deletions lined out).Commitment 50 if tho plainnod roplacornot of the 1122 split pins will noet be accomplashod in 2016, provide the NAC staff a detailod inspoction plan !fo the 1122 split pins, including insepotionin..eption c...rag., and in.e..tiO.

fr.quoncy, by March 31, 2016. Replace the IP2 split pins durinq the 2016 refueling outage (2R22).The following paragraph is revised in the Updated Final Safety Analysis Report LRA Section A.2.1.41.The IP2 guide tube support pins (split pins) will be replaced during the 2016 refueling outage (2R22) arc ,hoduo, t- be roplacod dur.ing the 2016 Ofe 5 e u' ' ita"e. ' 4-the planned replaement of the 1122 split pins will i,,t bo a ,omplishd in 2016, E.torg ,wll prvide the NIRI staff a pn including in.p..ti;" mothods, inepoc~tion coverage, and inspoction; frquoncY, no lator than March 31 , 2015.The following paragraph is revised in LRA Section B.1.42, Reactor Vessel Internals Program, under "Evaluation/l.

Scope of Program," new last paragraph:

The IP2 guide tube support pins (split pins) are plant-specific components as discussed in MRP-227-A, Section 4.4.3, "Westinghouse Components." The split pins will be NL-14-067 Attachment 1 Page 4 of 5 replaced during the 2016 refueling outage (2R22) ar..,ch"duld to bo the 2016 rofuoling .utago. See letter NL-12-166, Entergy to NRC, response to RAI 16, dated November 20, 2012, and letter NL-14-067, Entergy to NRC. response to RAI 16B for further discussion.

If the plannod ..aont of the 1122 , ^ it pins ,la*i" net be aGGOmnp!*chod in 2016, Entorgy Will prOVido the NIRG 6taff a dtidiepconplan, g ineptieoR. in..... "covoragondn frqUncY, no later than March 31, 2015.The revised commitment only affects IP2; therefore, LRA Section A.3.1.41 does not need revision.RAI 17-A In its September 27, 2013 response to RAI 17, Entergy provided a technical justification for the adequacy of the existing inspection requirements specified in MRP-227-A for the clevis insert bolts, which relies on its American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section Xl Inservice Inspection (ISI) Program. Entergy's response included the statement, "[t]he video camera visual inspections at a ten-year interval by qualified personnel that are specified in the ASME Code Section Xl and MRP-227-A are capable of identifying wear or dislodged components of the clevis insert cap screws or dowel pins at any location, if they exist." To assure that ihe type of degradation documented in Westinghouse InfoGram IG-10-1 would be reliably detected at IP2 and IP3, the staff requests the following additional information:

1. Provide the ASME Code Section Xl, Table IWB-2500 Examination Category and Item Number under which the IP2 and IP3 clevis insert bolts are classified.

2. Verify that the ASME Code, Section Xl examination of the clevis inserts directly views all the clevis insert bolt heads, dowel pins and locking devices for each clevis insert.3. If the ASME Code, Section Xl examination does not directly view all the clevis insert bolts heads, locking devices, and dowel pins, propose a modification to Entergy's ASME Code, Section Xl ISI Program to do so.4. State when the most recent ASME Code, Section Xl inspection of the clevis insert bolts was conducted at IP2 and IP3. Summarize the findings of that inspection for the clevis insert bolts.Response to RAI 17-A 1. The clevis insert bolts at IP2 and IP3 are inspected as part of the Category B-N-2 Item Number B133.60 inspections.

2. At IPEC, the ASME Code, Section Xl examination of the clevis inserts directly views all the clevis insert bolt heads, dowel pins, and locking devices for each clevis insert.3. At IPEC, the ASME Code,Section XI examination does directly view all the clevis insert bolts heads, locking devices, and dowel pins. The ASME Code requires a VT-3 of these NL-14-067 Attachment 1 Page 5 of 5 components and the VT-3 requirements include lighting and resolution requirements which will ensure that future inspections will continue to be performed in the same manner as they currently are being performed and, therefore, Entergy's ASME" Code, Section Xl ISI program does not require modification.

4. The most recent ASME Code, Section X1 inspection of the clevis insert bolts was conducted at IP2 in 2006 with no recordable indications and at IP3 in 2009 with no recordable indications.

ATTACHMENT 2 TO NL-14-067 LICENSE RENEWAL APPLICATION IPEC LIST OF REGULATORY COMMITMENTS Rev. 23 ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286 NL-14-067 Attachment 2 Page 1 of 21List of Regulatory Commitments Rev. 23 The following table identifies those actions committed to by Entergy in this document.Changes are shown as strikethroughs for and underlines for additions.

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 1 Enhance the Aboveground Steel Tanks Program for IP2: NL-07-039 A.2.1.1 IP2 and IP3 to perform thickness measurements of .omplete A.3.1.1 NL-13-122 8.1.1 the bottom surfaces of the condensate storage tanks, P3: city water tank, and fire water tanks once during the ecember 12, first ten years of the period of extended operation.

2015Enhance the Aboveground Steel Tanks Program for IP2 and IP3 to require trending of thickness I measurements when material loss is detected.NL-07-039 A.2.1 .2 2 Enhance the Bolting Integrity Program for IP2 and IP3 .2 to clarify that actual yield strength is used in selecting "omplete A.3.1.2 materials for low susceptibility to SCC and clarify the P3B. 1.2 prohibition on use of lubricants containing MoS 2 for omplete NL-07-153 Audit Items bolting. 201,241, The Bolting Integrity Program manages loss of NL-13-122 270 1 preload and loss of material for all external bolting. I _ I NL-14-067 Attachment 2 Page 2 of 21 COMMITMENT IMPLEMENTATION SOURCE I RELATED SCHEDULE LRA SECTION I/ I / AUDIT ITEM 3 Implement the Buried Piping and Tanks Inspection Program for IP2 and IP3 as described in LRA Section B.1.6.This new program will be implemented consistent with the corresponding program described in NUREG-1801 Section XI.M34, Buried Piping and Tanks Inspection.

Include in the Buried Piping and Tanks Inspection Program described in LRA Section B.1.6 a risk assessment of in-scope buried piping and tanks that includes consideration of the impacts of buried piping or tank leakage and of conditions affecting the risk for corrosion.

Classify pipe segments and tanks as having a high, medium or low impact of leakage based on the safety class, the hazard posed by fluid contained in the piping and the impact of leakage on reliable plant operation.

Determine corrosion risk through consideration of piping or tank material, soil resistivity, drainage, the presence of cathodic protection and the type of coating. Establish inspection priority and frequency for periodic inspections of the in-scope piping and tanks based on the results of the risk assessment.

Perform inspections using inspection techniques with demonstrated effectiveness.

IP2: ,omplete IP3: December 12, 2015 NL-07-039 NL-13-122 NL-07-153 NL-09-106 NL-09-1 11 A.2.1.5 A.3.1.5 8.1.6 Audit Item 173 NL-1 1-101 I I~ I- I NL-14-067 Attachment 2 Page 3 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION_/ 1 1 / AUDIT ITEM 4 Enhance the Diesel Fuel Monitoring Program to include cleaning and inspection of the IP2 GT-1 gas turbine fuel oil storage tanks, IP2 and IP3 EDG fuel oil day tanks, IP2 SBO/Appendix R diesel generator fuel oil day tank, and IP3 Appendix R fuel oil storage tank and day tank once every ten years.Enhance the Diesel Fuel Monitoring Program to include quarterly sampling and analysis of the IP2 SBO/Appendix R diesel generator fuel oil day tank, IP2 security diesel fuel oil storage tank, IP2 security diesel fuel oil day tank, and IP3 Appendix R fuel oil storage tank. Particulates, water and sediment checks will be performed on the samples. Filterable solids acceptance criterion will be less than or equal to 10mg/l. Water and sediment acceptance criterion will be less than or equal to 0.05%.Enhance the Diesel Fuel Monitoring Program to include thickness measurement of the bottom of the following tanks once every ten years. IP2: EDG fuel oil storage tanks, EDG fuel oil day tanks, SBO/Appendix R diesel generator fuel oil day tank, GT-1 gas turbine fuel oil storage tanks, and diesel fire pump fuel oil storage tank; IP3: EDG fuel oil day tanks, EDG fuel oil storage tanks, Appendix R fuel oil storage tank, and diesel fire pump-fuel oil storage tank.Enhance the Diesel Fuel Monitoring Program to change the analysis for water and particulates to a quarterly frequency for the following tanks. IP2: GT-1 gas turbine fuel oil storage tanks and diesel fire pump fuel oil storage tank; IP3: Appendix R fuel oil day tank and diesel fire pump fuel oil storage tank.Enhance the Diesel Fuel Monitoring Program to specify acceptance criteria for thickness measurements of the fuel oil storage tanks within the scope of the program.Enhance the Diesel Fuel Monitoring Program to direct samples be taken and include direction to remove water when detected.Revise applicable procedures to direct sampling of the onsite portable fuel oil contents prior to transferring the contents to the storage tanks.Enhance the Diesel Fuel Monitoring Program to direct the addition of chemicals including biocide when the presence of biological activity is confirmed.

P2: ,omplete IP3: December 12, P_01 5 NL-07-039 NL-13-122 NL-07-153 NL-08-057 A.2.1.8 A.3.1.8 B.1.9 Audit items 128, 129, 132, 491,492, 510 NL-14-067 Attachment 2 Page 4 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 5 Enhance the External Surfaces Monitoring Program IP2: NL-07-039 A.2.1.10 for IP2 and IP3 to include periodic inspections of Complete A.3.1.10 systems in scope and subject to aging management NL-13-122 6.1.11 review for license renewal in accordance with 10 CFR bP3: 54.4(a)(1) and (a)(3). Inspections shall include areas e br 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).

6 Enhance the Fatigue Monitoring Program for IP2 to P2: NL-07-039 A.2.1.11 monitor steady state cycles and feedwater cycles or omplete A.3.1.11 perform an evaluation to determine monitcring is not NL-13-122 A.1.12, required.

Review the number of allowed events and NL-07-153 Audit Item resolve discrepancies between reference documents 164 and monitoring procedures.

P3: Enhance the Fatigue Monitoring Program for iP3 to December 12, include all the transients identified.

Assure all fatigue 2015 analysis transients are included with the lowest limiting numbers. Update the number of design transients accumulated to date.

NL-14-067 Attachment 2 Page 5 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE ILRA SECTION I__IIjI/ AUDIT ITEM 7 Enhance the Fire Protection Program to inspect external surfaces of the IP3 RCP oil collection systems for loss of material each refueling cycle.Enhance the Fire Protection Program to explicitly state that the IP2 and IP3 diesel fire pump engine sub-systems (including the fuel supply line) shall be observed while the pump is running. Acceptance criteria will be revised to verify that the diesel engine does not exhibit signs of degradation while running;such as fuel oil, lube oil, coolant, or exhaust gas leakage.Enhance the Fire Protection Program to specify that the IP2 and IP3 diesel fire pump engine carbon steel exhaust components are inspected for evidence of corrosion and cracking at least once each operating cycle.Enhance the Fire Protection Program for IP3 to visually inspect the cable spreading room, 480V switchgear room, and EDG room C02 fire suppression system for signs of degradation, such as corrosion and mechanical damage at least once every six months.IP2: Complete NL-07-039 NL-13-122 A.2.1.12 A.3.1.12 B.1.13 1P3: December 12, 2015 I ~ L NL-14-067 Attachment 2 Page 6 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I I_ I / AUDIT ITEM 8 Enhance the Fire Water Program to include inspection of IP2 and IP3 hose reels for evidence of corrosion.

Acceptance criteria will be revised to verify no unacceptable signs of degradation.

Enhance the Fire Water Program to replace all or test a sample of IP2 and IP3 sprinkler heads required for 10 CFR 50.48 using guidance of NFPA 25 (2002 edition), Section 5.3.1.1.1 before the end of the 50-year sprinkler head service life and at 10-year intervals thereafter during the extended period of operation to ensure that signs of degradation, such as corrosion, are detected in a timely manner.Enhance the Fire Water Program to perform wall thickness evaluations of IP2 and IP3 fire protection piping on system components using non-intrusive techniques (e.g., volumetric testing) to identify evidence of loss of material due to corrosion.

These inspections will be performed before the end of thecurrent operating term and at intervals thereafter during the period of extended operation.

Results of the initial evaluations will be used to determine the appropriate inspection interval to ensure aging effects are identified prior to loss of intended function.Enhance the Fire Water Program to inspect the internal surface of foam based fire suppression tanks.

Acceptance criteria will be enhanced to verify no siQnificant corrosion.

I1P2: Complete NL-07-039 NL-13-122 NL-07-153 NL-08-014 A.2.1.13 A.3.1.13 B.1.14 Audit Items 105,106 IP3: December 12, 2015 NL-14-067 Attachment 2 Page 7 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I I_ I / AUDIT ITEM 9 Enhance the Flux Thimble Tube Inspection Program for IP2 and IP3 to implement comparisons to wear rates identified in WCAP-12866.

Include provisions to compare data to the previous performances and perform evaluations regarding change to test frequency and scope.Enhance the Flux Thimble Tube Inspection Program for IP2 and IP3 to specify the acceptance criteria as outlined in WCAP-12866 or other plant-specific values based on evaluation of previous test results.Enhance the Flux Thimble Tube Inspection Program for IP2 and IP3 to direct evaluation and performance of corrective actions based on tubes that exceed or are projected to exceed the acceptance criteria.

Also stipulate that flux thimble tubes that cannot be inspected over the tube length and cannot be shown by analysis to be satisfactory for continued service, must be removed from service to ensure the integrity of the reactor coolant system pressure boundary.P2: ,omplete NL-07-039 NL-13-122 A.2.1.15 A.3.1.15 B.1.16 P3::)ecember 12, 2-0115 NL-14-067 Attachment 2 Page 8 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/I I / AUDIT ITEM 10 Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to include the following heat exchangers in the scope of the program." Safety injection pump lube oil heat exchangers" RHR heat exchangers

• RHR pump seal coolers" Non-regenerative heat exchangers

• Charging pump seal water heat exchangers

• Charging pump fluid drive coolers* Charging pump crankcase oil coolers* Spent fuel pit heat exchangers

• Secondary system steam generator sample coolers o Waste gas compressor heat exchangers

• SBO/Appendix R diesel jacket water heat exchanger (IP2 only)Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to perform visual inspection on heat exchangers where non-destructive examination, such as eddy current inspection, is not possible due to heat exchanger design limitations.

Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to include consideration of material-environment combinations when determining sample population of heat exchangers.

Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to establish minimum tube wall thickness for the new heat exchangers identified in the scope of the program. Establish acceptance criteria for heat exchangers visually inspected to include no indication of tube erosion, vibration wear, corrosion, pitting, foulina, or scalinq.IP2: complete IP3: December 12, 2015 NL-07-039 NL-1 3-122 NL-07-153 NL-09-018 A.2.1.16 A.3.1.16 B.1.17, Audit Item 52 11 Deleted NL-09-056 NL-1 1-101 NL-14-067 Attachment 2 Page 9 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEMI P2:N L-07-039 A.2. 1.18 12 Enhance the Masonry Wall Program for IP2 and IP3 P2: to specify that the IPI intake structure is included in Complete A.3.1.18 the program. NL-13-122 B.1.19 the rogrm, p3:___omplete

ýP2: NL-07-039 A.2.1.19 13 Enhance the Metal-Enclosed Bus Inspection Program Pomplete A.3.1.19 for IP2 and IP3 to visually inspect the external surface NL-13-122 B.1.20 of MEB enclosure assemblies for loss of material at NL-07-153 Bui.tm least once every 10 years. The first inspection will P3 b 12, AdIe occur prior to the period of extended operation and DeceNber 12, 124, the acceptance criterion will be no significant loss of 015 NL-08-057 133, 519 material.

NL- 13-077 Enhance the Metal-Enclosed Bus Inspection Program to add acceptance criteria for MEB internal visual inspections to include the absence of indications of dust accumulation on the bus bar, on the insulators, and in the duct, in addition to the absence of indications of moisture intrusion into the duct.Enhance the Metal-Enclosed Bus Inspection Program for IP2 and IP3 to inspect bolted connections at least once every five years if performed visually or at least once every ten years using quantitative measurements such as thermography or contact resistance measurements.

The first inspection will occur prior to the period of extended operation.

The plant will process a change to applicable site procedure to remove the reference to "re-torquing" connections for phase bus maintenance and bolted connection maintenance.

14 Implement the Non-EQ Bolted Cable Connections P2: NL-07-039 A.2.1.21 Program for IP2 and IP3 as described in LRA Section omplete A.3.1.21 B.1.22. P3: NL-13-122 B.1.22 Vecember 12,_015 NL-14-067 Attachment 2 Page 10 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM IP2: NL-07-039 A.2.1 .22 15 Implement the Non-EQ Inaccessible Medium-Voltage Cable Program for IP2 and IP3 as described in LRA Complete A.3.1.22 Section B.1.23. NL-13-122 B.1.23 P3: NL-07-153 Audit item This new program will be implemented consistent with December 12, 173 the corresponding program described in NUREG- 2015 NL-1 1-032 1801 Section XIE3, Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 Environmental NL-1 1-096 Qualification Requirements.

NL-11-101 IP2: NL-07-039 A.2.1 .23 16 Implement the Non-EQ Instrumentation Circuits Test A.2.1.23 Review Program for IP2 and IP3 as described in LRA Complete N3B.1.24 Section B.1.24. P3: NL-07-153 Audit item This new program will be implemented consistent with December 12, 173 the corresponding program described in NUREG- 2015 1801 Section XI.E2, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits.17 Implement the Non-EQ Insulated Cables and P2: NL-07-039 A.2.1.24..omleteA.3.1

.24 Connections Program for IP2 and IP3 as described in NL-13-122 B.1.25 LRA Section B.1.25. P3: NL-07-153 Audit item This new program will be implemented consistent with Decernber 12, 173 the corresponding program described in NUREG- 2015 1801 Section XI.E1, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.

NL-14-067 Attachment 2 Page 11 of 21 Y -I -COMMITMENT IMPLEMENTATION SCHEDULE SOURCE RELATED LRA SECTION/ AUDIT ITEM-t 18 Enhance the Oil Analysis Program for IP2 to sample and analyze lubricating oil used in the SBO/Appendix R diesel generator consistent with the oil ankc,lysis for other site diesel generators.Enhance the Oil Analysis Program for IP2 and IP3 to sample and analyze generator seal oil and turbine hydraulic control oil.Enhance the Oil Analysis Program for IP2 and IP3 toformalize preliminary oil screening for water and particulates and laboratory analyses including defined acceptance criteria for all components included in the scope of this program. The program will specify corrective actions in the event acceptance criteria are not met.Enhance the Oil Analysis Program for IP2 and IP3 to formalize trending of preliminary oil screening results as well as data provided from independent laboratories.

IP2: ,omplete IP3: December 12, 2015 NL-07-039 NL-13-122 NL-11-101 A.2.1.25 A.3.1.25 B.1.26 19 Implement the One-Time Inspection Program for IP2 P2:

NL-07-039 A.2.1.26 and IP3 as described in LRA Section 8.1.27. omplete A.3.1.26 NL-13-122 B.1.27 This new program will be implemented consistent with P3: NL-07-153 Audit item the corresponding program described in NUREG- Decernber 12, 173 1801,Section XI.M32, One-Time Inspection.

2015 20 Implement the One-Time Inspection

-Small Bore P2: NL-07-039 A.2.1.27 Piping Program for IP2 and IP3 as described in LRA Complete 8.31.28 Section B.1.28. P3: NL-07-153 Audit item This new program will be implemented consistent with December 12, 173 the corresponding program described in NUREG- 2015 1801,Section XI.M35, One-Time Inspection of ASME Code Class I Small-Bore Piping.IP2: NL-07-039 A.2.1.28 21 Enhance the Periodic Surveillance and Preventive P2N03 A.3.1.28Maintenance Program for IP2 and IP3 as necessary Complete A.3.1.28 to assure that the effects of aging will be managed 3P3: such that applicable components will continue to P31 perform their intended functions consistent with the em 1 current licensing basis through the period of extended 015 operation.

NL-14-067 Attachment 2 Page 12 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 22 Enhance the Reactor Vessel Surveillance Program for P2: NL-07-039 A.2.1.31 IP2 and IP3 revising the specimen capsule withdrawal omplete A.3.1.31 NL-13-122 B.1.32 schedules to draw and test a standby capsule to P3: cover the peak reactor vessel fluence expected December 12, through the end of the period of extended operation.

2015, Enhance the Reactor Vessel Surveillance Program for IP2 and IP3 to require that tested and untested specimens from all capsules pulled from the reactor I vessel are maintained in storage.23 Implement the Selective Leaching Program for IP2 -P2:

NL-07-039 A.2.1.32 and IP3 as described in LRA Section B.1.33. Oomplete A.3.1.32 NL-13-122 B.1.33 This new program will be implemented consistent with P3: NL-07-153 Audit item the corresponding program described in NUREG- ecember 12, 173 1801,Section XI.M33 Selective Leaching of Materials.

015 24 Enhance the Steam Generator Integrity Program for P2: NL-07-039 A.2.1.34 IP2 and IP3 to require that the results of the condition omplete A.3.1.34 monitoring assessment are compared to the P3: operational assessment performed for the prior omplete operating cycle with differences evaluated.

2 Enhance the Structures Monitoring Program to P2: NL-07-039 A.2.1.35 25 explicitly specify that the following structures are Domplete A.3.1.35 included in the program. NL-13-122 B.1.36* Appendix R diesel generator foundation (IP3) P3: NL-07-153* Appendix R diesel generator fuel oil tank vault December 12, Audit items (IP3) 2015 86, 87, 88,* Appendix R diesel generator switchgear and NL-08-057 417 enclosure (IP3)* city water storage tank foundation" condensate storage tanks foundation (IP3) NL-13-077* containment access facility and annex (IP3)* discharge canal (IP2/3)" emergency lighting poles and foundations (IP2/3)" fire pumphouse (IP2)* fire protection pumphouse (1P3)* fire water storage tank foundations (IP2/3)* gas turbine 1 fuel storage tank foundation" maintenance and outage building-elevated passageway (IP2)" new station security building (IP2)* nuclear service building (IP1)* primary water storage tank foundation (IP3)* refueling water storage tank foundation (IP3)

NL-14-067 Attachment 2 Page 13 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I_ I _I I/ AUDIT ITEM S 0 0 0 0 0 security access and office building (IP3)service water pipe chase (IP2/3)service water valve pit (IP3)superheater stack transformer/switchyard support structures (IP2)waste holdup tank pits (IP2/3)

Enhance the Structures Monitoring Program for IP2 and IP3 to clarify that in addition to structural steel and concrete, the following commodities (including their anchorages) are inspected for each structure as applicable." cable trays and supports* concrete portion of reactor vessel supports* conduits and supports" cranes, rails and girders* equipment pads and foundations

• fire proofing (pyrocrete)

• HVAC duct supports* jib cranes.* manholes and duct banks* manways, hatches and hatch covers" monorails* new fuel storage racks* sumps Enhance the Structures Monitoring Program for IP2 and IP3 to inspect inaccessible concrete areas that are exposed by excavation for any reason. IP2 and IP3 will also inspect inaccessible concrete areas in environments where observed conditions in accessible areas exposed to the same environment indicate that significant concrete degradation is occurring.Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspections of elastomers (seals, gaskets, seismic joint filler, and roof elastomers) to identify cracking and change in material properties and for inspection of aluminum vents and louvers to identify loss of material.NL-13-077 Enhance the Structures Monitorinq Proqram for IP2 NL-14-067 Attachment 2 Page 14 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I I _I / AUDIT ITEM and IP3 to perform an engineering evaluation of groundwater samples to assess aggressiveness of groundwater to concrete on a periodic basis (at least once every five years). IPEC will obtain samples from at least 5 wells that are representative of the ground water surrounding below-grade site structures and perform an engineering evaluation of the results from those samples for sulfates, pH and chlorides.

Additionally, to assess potential indications of spentfuel pool leakage, IPEC will sample for tritium in groundwater wells in close proximity to the IP2 spentfuel pool at least once every 3 months.Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspection of normally submerged concrete portions of the intake structures at least once every 5 years. Inspect the baffling/grating partition and support platform of the IP3 intake structure at least once every 5 years.Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspection of the degraded areas of the water control structure once per 3 years rather than the normal frequency of once per 5 years during the PEO.Enhance the 'Structures Monitoring Program to include more detailed quantitative acceptance criteria for inspections of concrete structures in accordance with ACl 349.3R, "Evaluation of Existing Nuclear Safety-Related Concrete Structures" prior to the period of extended operation.

NL-08-127 NL-1 1-032 NL-11-101 Audit Item 360 Audit Item 358 26 Implement the Thermal Aging Embrittlement of Cast P2: NL-07-039 A.2.1.36 Austenitic Stainless Steel (CASS) Program for IP2 omplete A.3.1.36 and IP3 as described in LRA Section B.1.37. NL-13-122 B.1.37 aP3: NL-07-153 Audit item This new program will be implemented consistent with ecember 12, 173 the corresponding program described in NUREG- 015 1801,Section XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) Program.

NL-14-067 Attachment 2 Page 15 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 27 Implement the Thermal Aging and Neutron Irradiation P2:

NL-07-039 A.2.1.37 Embrittlement of Cast Austenitic Stainless Steel Domplete A.3.1.37 (CASS) Program for IP2 and IP3 as described in LRA NL-13-122 B.1.38 Section B.1.38. IP3& NL-07-153 Audit item Complete 173 This new program will be implemented consistent with the corresponding program described in NUREG-1801 Section XI.M13, Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program.28 Enhance the Water Chemistry Control -Closed P2: NL-07-039 A.2.1.39 Cooling Water Program to maintain water chemistry of omplete A.3.1 .39 NL-13-122 B.1.40 the IP2 SBO/Appendix R diesel generator cooling -P3:

NL-08-057 Audit item system per EPRI guidelines.

Complete 509 Enhance the Water Chemistry Control -Closed Cooling Water Program to maintain the IP2 and IP3 security generator and fire protection diesel cooling water pH and glycol within limits specified by EPRI guidelines.

29 Enhance the Water Chemistry Control -Primary and P2: NL-07-039 A.2.1.40 Secondary Program for 1P2 to test sulfates monthly in omplete 3-122 1.41 the RWST with a limit of <150 ppb.30 For aging management of the reactor vessel internals, P2: NL-07-039 A.2.1.41 IPEC will (1) participate in the industry programs for omplete A.3.1.41 investigating and managing aging effects on reactor P3: internals; (2) evaluate and implement the results of 3 the industry programs as applicable to the reactor Domplete internals; and (3) upon completion of these programs, but not less than 24 months before entering the period of extended operation, submit an inspection plan for NL-1 1-107 reactor internals to the NRC for review and approval.31 Additional P-T curves will be submitted as required IP2: NL-07-039 A.2.2.1.2 per 10 CFR 50, Appendix G prior to the period of Complete A.3.2.1.2 extended operation as part of the Reactor Vessel PNL-13-122 4.2.3 Surveillance Program. ecember 12, 2015 32 As required by 10 CFR 50.61 (b)(4), IP3 will submit a P3: NL-07-039 A.3.2.1.4 plant-specific safety analysis for plate B2803-3 to the December 12, 4.2.5 NRC three years prior to reaching the RTPTS 2015 NL-08-127 screening criterion. Alternatively, the site may choose to implement the revised PTS rule when approved.

NL-14-067 Attachment 2 Page 16 of 21 COMMITMENT IMPLEMENTATION SOURCE I RELATED SCHEDULE LRA SECTION I/ I I / AUDIT ITEM 33 At least 2 years prior to entering the period of extended operation, for the locations identified in LRATable 4.3-13 (IP2) and LRA Table 4.3-14 (IP3), under the Fatigue Monitoring Program, IP2 and IP3 will implement one or more of the following:(1) Consistent with the Fatigue Monitoring Program, Detection of Aging Effects, update the fatigue usagecalculations using refined fatigue analyses to determine valid CUFs less than 1.0 when accounting for the effects of reactor water environment.

This includes applying the appropriate Fen factors to valid CUFs determined in accordance with one of the following:

1. For locations in LRA Table 4.3-13 (IP2) and LRATable 4.3-14 (IP3), with existing fatigue analysis valid for the period of extended operation, use the existing CUF.2. Additional plant-specific locations with a valid CUF may be evaluated.

In particular, the pressurizer lower shell will be reviewed to ensure the surge nozzle remains the limiting component.

3. Representative CUF values from other plants, adjusted to or enveloping the IPEC plant specific external loads may be used if demonstrated applicable to IPEC.4. An analysis using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case) may be performed to determine a valid CUF.(2) Consistent with the Fatigue Monitoring Program, Corrective Actions, repair or replace the affected locations before exceeding a CUF of 1.0.P2: ,omplete IP3: ,omplete NL-07-039 NL-13-122 NL-07-153 NL-08-021 NL-1 0-082 A.2.2.2.3 A.3.2.2.3 4.3.3Audit item 146 34 1IP2 SBO / Appendix R diesel generator will be NL-13-122 2.1.1.3.5 installed and operationaesel gy erator wi bemplet NL-07-078 committed change to theo facility meets the Complete requirements of 10 CFR 50.59(c)(1) and, therefore, a license amendment pursuant to 10 CFR 50.90 is not NL-1 1-101 1 required.

NL-11-101 NL-14-067 Attachment 2 Page 17 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM ,P2: NL-08-127 Audit Item35 Perform a one-time inspection of representative

]P2: 27 sample area of IP2 containment liner affected by the omplete 27 1973 event behind the insulaticn, prior to entering the period of extended operation, to assure liner degradation is not occurring in this area. P3: NL-1 1-101 Perform a one-time inspection of representative December 12, sample area of the IP3 containment steel liner at the 2015 juncture with the concrete floor slab, prior to entering the period of extended operation, to assure liner degradation is not occurring in this area.Any degradation will be evaluated for updating of the NL-09-018 I containment liner analyses as needed.36 Perform a one-time inspection and evaluation of a P2: NL-08-127 Audit Item sample of potentially affected IP2 refueling cavity omplete NL-11-101 359 concrete prior to the period of extended operation.

NL-13-122 The sample wi!l be obtained by core boring the refueling cavity wall in an area that is susceptible to exposure to borated water leakage. The inspection will include an assessment of embedded reinforcing steel.Additional core bore samples will be taken, if the NL-09-056 leakage is not stopped, prior to the end of the first ten years of the period of extended operation.

A sample of leakage fluid will be analyzed to NL-09-079determine the composition of the fluid. If additional core samples are taken prior to the end of the first ten years of the period of extended operation, a sample of leakage fluid will be analyzed.37 -.. P2: NL-08-127 Audit Item 37 Enhance the Containment Inservice Inspection (CII- mPee 36 IWL) Program to include inspections of the omplete 361 containment using enhanced characterization of NP3: degradation (i.e., quantifying the dimensions of noted P3: indications through the use of optical aids) during the omplete period of extended operation.

The enhancementincludes obtaining critical dimensional data of degradation where possible through direct measurement or the use of scaling technologies for photographs, and the use of consistent vantage points for visual inspections.

NL-14-067 Attachment 2 Page 18 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 38 For Reactor Vessel Fluence, should future core P2: NL-08-143 4.2.1 loading patterns invalidate the basis for the projected omplete NL-13-122 values of RTpts or CvUSE, updated calculations will P3-be provided to the NRC. ecember 12, 2015 39 Deleted NL-09-079 40 Evaluate plant specific and appropriate industry P2: NL-09-106 B.1.6 operating experience and incorporate lessons learned omplete B.1.22 opeatngNL-13-122 B.1.23 in establishing appropriate monitoring and inspection NP3: B.1.24 frequencies to assess aging effects for the new aging ecember 12, B.1.25 management programs.

Documentation of the 2015 B.1.25 operating experience evaluated for each new program 015 B.1.27 will be available on site for NRC review prior to the B.1.28 period of extended operation.

B.1.33 B.1.37 B.1.38 41 IPEC will inspect steam generators for both units to P2: NL-1 1-032 N/A assess the condition of the divider plate assembly.

fter the The examination technique used will be capable of )eginning of the detecting PWSCC in the steam generator divider plate PEO and prior to assembly.

The IP2 steam generator divider plate September 28, inspections will be completed within the first ten years 023 NL-1 1-074 of the period of extended operation (PEO). The IP3 P3 NL-1 1-090steam generator divider plate inspections will be completed within the first refueling outage following for to the end the beginning of the PEO. f the first NL-1 1-101 oefueling outage ollowing the Eginning of the NL- 14-067 Attachment 2 Page 19 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION_I _ _ I AUDIT ITEM 42 IPEC will develop a plan for each unit to address the potential for cracking of the primary to secondary pressure boundary due to PWSCC of tube-to-tubesheet welds using one of the following two options.Option 1 (Analysis)

IPEC will perform an analytical evaluation of thesteam generator tube-to-tubesheet welds in order to establish a technical basis for either determining that the tubesheet cladding and welds are not susceptible to PWSCC, or redefining the pressure boundary in which the tube-to-tubesheet weld is no longer included and, therefore, is not required for reactor coolant pressure boundary function.

The redefinition of the reactor coolant pressure boundary must be approved by the NRC as a license amendment request.Option 2 (Inspection)

IPEC will perform a one-time inspection of a representative number of tube-to-tubesheet welds in each steam generator to determine if PWSCC cracking is present. If weld cracking is identified:

a. The condition will be resolved through repair or engineering evaluation to justify continued service, as appropriate, andb. An ongoing monitoring program will be established to perform routine tube-to-tubesheet weld inspections for the remaining life of the steam generators.

1P2: Prior to March R024 IP3: Prior to the end of the first refueling outage following the beginning of the PEO.I P2: Between March 2020 and March 2024 IP3: Prior to the end of the first refueling outage following the beginning of the PEO.NL-1 1-032 NL-1 1-074 NL-1 1-090 NL-11-096 N/A 43 IPEC will review design basis ASME Code Class 1 fatigue evaluations to determine whether the NUREG/CR-6260 locations that have been evaluated for the effects of the reactor coolant environment on fatigue usage are the limiting locations ior the IP2 and IP3 configurations.

If more limiting locations are identified, the most limiting location will be evaluated for the effects of the reactor coolant environment on fatigue usage.IPEC will use the NUREG/CR-6909 methodology in the evaluation of the limiting locations consisting of nickel alloy, if any.I P2: ,ompleteP3: Prior to December 12, 2015 NL-1 1-032 NL-13-122 NL-1 1-101 4.3.3 NL-14-067 Attachment 2 Page 20 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 44 IPEC will include written explanation and justification P2: NL-11-032 N/A of any user intervention in future evaluations using the omplete NL-1 1-101 WESTEMS "Design CUP' module. P3: Prior to NL-13-122 December 12, R015 45 IPEC will not use the NB-3600 option of the P2: NL-1 1-032 N/A WESTEMS program in future design calculations until omplete NL-1 1-101 the issues identified during the NRC review of the P3: Prior to NL-13-122 program have been resolved.

ecember 12, 015 46 Include in the IP2 ISI Program that IPEC will perform P2: NL- 1-032 N/A twenty-five volumetric weld metal inspections of Complete socket welds during each 10-year ISI interval NL-11-074 scheduled as specified by IWB-2412 of the ASME NL-13-122 Section Xl Code during the period of extended operation.

In lieu of volumetric examinations, destructive examinations may be performed, where one destructive examination may be substituted for two volumetric examinations.

47 IPE- will and submit analysos that I O89 N/A domenontrato that the loWorF 61Appo0 column bedic il mnaintain thoir funcitionality during tho poriod Ugus 16' N=o)dended oporation concid8Fr@n tho pocciblo less of P.PmFW N=1 2 fracturo teughnocc duo to thormnal and fiReadat~e ee~e -L1-6 ombrittlmont.

Tho analycoc, will be concicton~t with 2L-4-06 the 1P2X'1P3 liconcing baic Deleted.

NL-14-067 Attachment 2 Page 21 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM 48 Entergy will visually inspect IPEC underground piping P2: NL-12-174 N/A within the scope of license renewal and subject to Complete aging management review prior to the period of P3: Prior to NL-13-122 extended operation and then on a frequency of at ecember 12, least once every two years during the period of extended operation.

This inspection frequency will be maintained unless the piping is subsequently coated in accordance with the preventive actions specified in NUREG-1801 Section XI.M41 as modified by LR-ISG-2011-03. Visual inspections will be supplemented with surface or volumetric non-destructive testing if indications of significant loss of material are observed.

Consistent with revised NUREG-1801 Section XI.M41, such adverse indications will be entered into the plant corrective action program for evaluation of extent of condition and for determination of appropriate corrective actions (e.g., increased inspection frequency, repair, replacement).

49 Recalculate each of the limiting CUFs provided in IP2: NL-13-052 A.2.2.2 section 4.3 of the LRA for the reactor vessel internals Complete A.3.2.2 to include the reactor coolant environment effects P3: Prior to NL-13-122 (Fen) as provided in the IPEC Fatigue Monitoring ecember 12, Program using NUREG/CR-5704 or NUREG/CR-2015 6909. In accordance with the corrective actions specified in the Fatigue Monitoring Program, corrective actions include further CUF re-analysis, and/or repair or replacement of the affected components prior to the CUFen reaching 1.0.50 if the planned , rop a...,nt of tho , 122 split pips P2: NL-13-122 A.2.1.41 will not be a,. ompli.ehd in 2016, provfido the oO" W MaF B.1.42 NRCG taff a

....; .p.tn plan for the. 22 1, 20:1 NL-14-067.pl...pine, including insepotion mothods, S..ep.tiGn c....ag, and in..p..tion-fr.quonc.y, norior to by MaF,,1-, ,2046- Replace the IP2 split pins Completion of during the 2016 refuelinq outaae (2R22). 2R22 P3: N/A iE vw-EnterWy Enteray Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 254-2055 Fred Dacimo Vice President Operations License Renewal NL-14-067 June 9, 2014 U.S. Nuclear Regulatory Commission Document Control Desk 11545 Rockville Pike, TWFN-2 F1 Rockville, MD 20852-2738

REFERENCE:

Reply to Request for Additional Information Regarding the License Renewal Application Indian Point Nuclear Generating Unit Nos. 2 & 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64 NRC letter, "Request for Additional Information for the Review of the Indian Point Nuclear Generating Unit Nos. 2 and 3, License Renewal Application, SET 2014-02 (TAC Nos. MD5407 and MD5408)" dated April 9, 2014.

Dear Sir or Madam:

Entergy Nuclear Operations, Inc. is providing, in Attachment 1, the additional information requested in the referenced letter pertaining to NRC review of the License Renewal Application (LRA) for Indian Point 2 and Indian Point 3.The responses to RAI 11-C and RAI 16-B include the deletion of Commitment 47 and a revision to Commitment 50, respectively.

These commitment changes are included in the list of regulatory commitments provided in Attachment 2.If you have any questions, or require additional information, please contact Mr. Robert Walpole at 914-254-6710.

I declare d r penalty of perjury that the foregoing is true and correct. Executed on 6A , 2014.Sin rely, FRD/rw A(21ý-f 44 A-Docket Nos. 50-247 & 50-286 NL-14-067 Page 2 of 2

Attachment:

1. Reply to NRC Request for Additional Information Regarding the License Renewal Application

2. License Renewal Applicati,.° IPEC List of Regulatory CommitmentsRevision 23 cc: Mr. William Dean, Regional Administrator, NRC Region I Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel Mr. Dave Wrona, NRC Branch Chief, Engineering Review Branch I Ms. Kimberly Green, NRC Sr. Project Manager, Division of License Renewal Mr. Douglas Pickett, NRR Senior Project Manager Ms. Bridget Frymire, New York State Department of Public Service NRC Resident Inspector's Office Mr. John B. Rhodes, President and CEO NYSERDA ATTACHMENT 1 TO NL-14-067 REPLY TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE LICENSE RENEWAL APPLICATION ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286 NL-14-067 Attachment 1 Page 1 of 5 REQUEST FOR ADDITIONAL INFORMATION, SET 2014-02 RELATED TO INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION REACTOR VESSEL INTERNALS PROGRAM AND INSPECTION PLAN RAI 11-C Applicant/Licensee Action Item 7 from the staff's final safety evaluation (SE) of MRP-227 requires the applicants/licensees of Babcock & Wilcox (B&W), Combustion Engineering (CE), and Westinghouse reactors to develop plant-specific analyses to be applied for their facilities to demonstrate that B&W In-Core Monitoring Instrumentation (IMI) guide tube assembly spiders and control rod guide tube (CRGT) assembly spacer castings, CE lower support columns, and Westinghouse lower support column bodies will maintain their functionality during the period of extended operation, and states that these analyses should also consider the possible loss of fracture toughness in these components due to thermal embrittlement (TE) and irradiation embrittlement (IE). For Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3), the equivalent component to the lower support column bodies are the lower internals assembly -column caps (column caps).By letter dated January 28, 2014, Entergy provided plant specific information on the ferrite content and susceptibility to TE for the Indian Point Nuclear Generating Unit Nos. 2 and 3 lower internals assembly -column caps. Based on its evaluation of the plant-specific material information for the column caps, Entergy concluded that the IP2 and IP3 column caps are not susceptible to TE.Entergy's conclusion related to TE notwithstanding, the column caps remain susceptible to IE.The staff is concerned that the linked Primary component for the column caps, the CRGT assembly lower flange welds, is not a good predictor of IE for the column caps since the CRGT lower flange welds receive substantially lower neutron fluence than the column caps (based on the estimated neutron fluence tabulated in MRP-1 91 for the two components).

Irradiation assisted stress corrosion cracking (IASCC) is the only mechanism of cracking that screened in for the column caps. The CRGT lower flange welds are also not a good predictorfor IASCC of the column caps, because the lower flange welds are susceptible to stress corrosion cracking (SCC) and fatigue cracking, but not IASCC.The staff, therefore, requests that Entergy modify its Reactor Vessel Internals Inspection Plan (RVI Inspection Plan) to provide a link to a Primary component or components that is an appropriate predictor of IE and IASCC of the column caps.Response to RAI 11-C The following text will be incorporated into the reactor vessel internals (RVI) Inspection Plan for Indian Point Units 2 and 3 regarding a link to a component that is an appropriate predictor of irradiation embrittlement (IE) and irradiation-assisted stress corrosion cracking (IASCC) of the column caps.

NL-14-067 Attachment 1 Page 2 of 5"The lower core plate, which was screened in for IASCC in MRP-191 [1], is a leading indicator of cracking in the column caps of the lower support column bodies because it is subject to more severe service conditions.

Due to its proximity to the core, the lower core plate experiences both higher fluences and higher gamma heating than the column caps. Additionally, thermally induced tensile stresses are anticipated in the lower core plate while the stresses in the column caps are largely compressive.

These factors Pre expected to contribute to earlier IASCC initiation in the lower core plate, making it a suitable leading indicator of cracking in the column caps.The lower support column caps at Indian Point Units 2 and 3 have the same irradiation embrittlement mechanism as the wrought stainless steel lower core plate. The 60-year fluence in the top few inches of the lower support column body, which is where the column cap is located, is projected to exceed the threshold for irradiation embrittlement of austenitic stainless steel. Therefore, irradiation embritt!ement is considered a damage mechanism in the column caps.Considering both the cracking mechanism and the likely embrittlement mechanism, a leading indicator of degradation for the column caps is the lower core plate. Since the lower core plate is an Existing Programs component in MRP-227-A

[2] and must be inspected as part of the aging management program, it is an appropriate alternate component for predicting aging effects.

The lower core plate will continue to be an Existing Programs component, managed under the Indian Point program for ASME Section Xl inspections. The inspection requirement will remain a VT-3 inspection of the accessible upper surface on a ten-year interval.

In addition to the standard requirements for assessing extent of condition required under ASME Section XI, a trigger for the Expansion inspection of the lower support column bodies (column caps) for Indian Point Units 2 and 3 will be the confirmed discovery of a service induced flaw in the lower core plate." The intent of Commitment 47 was to demonstrate that the lower support column bodies willmaintain their functionality during the period of extended operation considering the possible loss of fracture toughness due to thermal and irradiation embrittlement.

As the staff noted in this RAI 11-C, Entergy has concluded that the IP2 and IP3 column caps (equivalent component to the lower support column bodies) are not susceptible to TE and will modify the Reactor Vessel Internals (RVI) Inspection Plan to credit inspection of the lower core plate as an appropriate predictor of IE and IASCC of the column caps. Therefore, the functionality of the lower support column bodies is assured during the period of extended operation without the need for a functionality analysis.

Therefore, Entergy is deleting Commitment 47 (additions are underlined, deletions lined out).Commitment 47 IPE. will and -ubmit analyses that domnStato that the lower support column bodioS Will maintain their functionality duFrig the period of extended operation concidoring the poccfiblo los6 of fracture toughness duo to thermal and irradiation eMbrittloMont.

The analyses will be consistent With the 1122/1123 licensing basis. Deleted.

NL-14-067 Attachment 1 Page 3 of 5 References

1. Materials Reliability Program: Screening, Categorization, and Ranking of Reactor Internals Components for Westinghouse and Combustion Engineering PWR Design (MRP-1 91).EPRI, Palo Alto, CA: 2006. 1013234.2. Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guidelines (MRP-227-A).

EPRI, Palo Alto, CA: 2011. 1022863.RAI 16-B In its September 27, 2013 response to RAI 16-A, Entergy proposed Commitment No. 50 stating that it would provide the NRC staff a detailed inspection plan for the IP2 split pins, including inspection methods, inspection coverage, and inspection frequency, by March 31, 2015, if the planned replacement of the IP2 split pins will not be accomplished in 2016. In order to resolve MRP-227-A Applicant/Licensee Action Item 3, the NRC staff requests Entergy submit the schedule for initial inspection, inspection methods, inspection coverage, and inspection frequency for the IP2 split pins in the event the IP2 split pins are not replaced by2016, and that Commitment No. 50 be modified accordingly.

Response to RAI 16-B Entergy commits to replacing the IP2 split pins during the 2016 refueling outage (2R22).Therefore, a schedule for initial inspection, inspection methods, inspection coverage, and inspection frequency for the IP2 split pins is not necessary.

Accordingly, Entergy is revising Commitment 50 and the identified LRA sections as follows (additions are underlined, deletions lined out).Commitment 50 If the plaRned rreplacement of the IP2 Split priS Will not be accomnplished in 2016, proVido tho NRC st-aff a adetailed inspection plan ifo the 1 P2 split pinS, inldn inspoction methods, inspection coverage, and ..inspection fequency, by March 31, 2016. Replace the IP2 split pins during the 2016 refueling outage (2R22).The following paragraph is revised in the Updated Final Safety Analysis Report LRA Section A.2.1.41.The IP2 guide tube support pins (split pins) will be replaced during the 2016 refueling outage (2R22) a.e-.hedue, , rp... e duing the-201- refe 'li;g outage. *" the planned replacemont of the 1P2 split pins will not be accomFplished in 2016, Entorgy wil provide the NRC staff a detailed inspection plan, including inspection methods, The following paragraph is revised in LRA Section B. 1.42, Reactor Vessel Internals Program, under "Evaluation/i.

Scope of Program," new last paragraph:

The IP2 guide tube support pins (split pins) are plant-specific components as discussed in MRP-227-A, Section 4.4.3, "Westinghouse Components." The split pins will be NL-14-067 Attachment 1 Page 4 of 5 replaced during the 2016 refueling outage (2R22) a .e-"Ghed,,ed to be r `placed during the 20146e .utagc. See letter NL-12-166, Entergy to NRC, response to RAI 16, dated November 20, 2012, and letter NL-14-067, Entergy to NRC. response to RAI 16B for further discussion.

if the planned of thc 11P2 split pins will not be accomplished in 2016, EnRtergy Will provfido the NRC staff a dctailcd inspoct'ion plan, 0l A iRGe:i9 llnethed.

ll lls, i..Gse ltSl, GEVelage, a .#equleql , nelaslthan March. 31, 2015.The revised commitment only affects IP2; therefore, LRA Section A.3.1.41 does not need revision.RAI 17-A In its September 27, 2013 response to RAI 17, Entergy provided a technical justification for the adequacy of the existing inspection requirements specified in MRP-227-A for the clevis insert bolts, which relies on its American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI Inservice Inspection (ISI) Program. Entergy's response included the statement, "[t]he video camera visual inspections at a ten-year interval by qualified personnel that are specified in the ASME Code Section Xl and MRP-227-A are capable of identifying wear or dislodged components of the clevis insert cap screws or dowel pins at any location, if they exist." To assure that the type of degradation documented in Westinghouse InfoGram IG-10-1 would be reliably detected at IP2 and IP3, the staff requests the following additional information:

1. Provide the ASME Code Section Xl, Table IWB-2500 Examination Category and Item Number under which the IP2 and IP3 clevis insert bolts are classified.

2. Verify that the ASME Code,Section XI examination of the clevis inserts directly views all the clevis insert bolt heads, dowel pins and locking devices for each clevis insert.3. If the ASME Code,Section XI examination does not directly view all the clevis insert bolts heads, locking devices, and dowel pins, propose a modification to Entergy's ASME Code, Section Xl ISI Program to do so.4. State when the most recent ASME Code, Section Xl inspection of the clevis insert bolts was conducted at IP2 and IP3. Summarize the findings of that inspection for the clevis insert bolts.Response to RAI 17-A 1. The clevis insert bolts at IP2 and IP3 are inspected as part of the Category B-N-2 Item Number B13.60 inspections.

2. At IPEC, the ASME Code, Section Xl examination of the clevis inserts directly views all the clevis insert bolt heads, dowel pins, and locking devices for each clevis insert.3. At IPEC, the ASME Code, Section Xl examination does directly view all the clevis insert bolts heads, locking devices, and dowel pins. The ASME Code requires a VT-3 of these NL-14-067 Attachment 1 Page 5 of 5 components and the VT-3 requirements include lighting and resolution requirements which will ensure that future inspections will continue to be performed in the same manner as they currently are being performed and, therefore, Entergy's ASME Code, Section Xl ISI program does not require modification.

4. The most recent ASME Code, Section Xl inspection of the clevis insert bolts was conducted at IP2 in 2006 with no recordable indications and at IP3 in 2009 with no recordable indications.

ATTACHMENT 2 TO NL-14-067 LICENSE RENEWAL APPLICATION IPEC LIST OF REGULATORY COMMITMENTS Rev. 23 ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286 NL-14-067 Attachment 2 Page 1 of 21List of Regulatory Commitments Rev. 23 The following table identifies those actions committed to by Entergy in this document.Changes are shown as strikethroughs for defte#GR, and underlines for additions.

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 1 Enhance the Aboveground Steel Tanks Program for oP2: NL-07-039 A.2.1.1 IP2 and IP3 to perform thickness measurements of omplete A.3.1.1 the bottom surfaces of the condensate storage tanks, lP3: city water tank, and fire water tanks once during the ecember 12, first ten years of the period of extended operation.

2015 Enhance the Aboveground Steel Tanks Program for IP2 and IP3 to require trending of thickness measurements when material loss is detected.2 Enhance the Bolting Integrity Program for IP2 and IP3 P2: NL-07-039 A.2.1.2 to clarify that actual yield strength is used in selecting Complete A.3.1.2 B.1.2 materials for low susceptibility to SCC and clarify the P3: prohibition on use of lubricants containing MoS 2 for omplete NL-07-153 Audit Items bolting. 201,241, The Bolting Integrity Program manages loss of NL-13-122 270 preload and loss of material for all external bolting. __ I I _ __ I NL-14-067 Attachment 2 Page 2 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I_ II/I AUDIT ITEM 3 Implement the Buried Piping and Tanks Inspection Program for IP2 and IP3 as described in LRA Section B.1.6.This new program will be implemented consistent with the corresponding program described in NUREG-1801 Section XI.M34, Buried Piping and Tanks Inspection.

Include in the Buried Piping and Tanks Inspection Program described in LRA Section B.1.6 a risk assessment of in-scope buried piping and tanks that includes consideration of the impacts of buried piping or tank leakage and of conditions affecting the risk forcorrosion. Classify pipe segments and tanks as having a high, medium or low impact of leakage based on the safety class, the hazard posed by fluid contained in the piping and the impact of leakage on reliable plant operation.

Determine corrosion risk through consideration of piping or tank material, soil resistivity, drainage, the presence of cathodic protection and the type of coating. Establish inspection priority and frequency for periodic inspections of the in-scope piping and tanks based on the results of the risk assessment.

Perform inspections using inspection techniques with demonstrated effectiveness.

IP2: Complete.P3: December 12, 2015 NL-07-039 NL-13-122 NL-07-153 NL-09-106 NL-09-111 A.2.1.5 A.3.1.5 B.1.6 Audit Item 173 NL-1 1-101 NL-14-067 Attachment 2 Page 3 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 4 Enhance the Diesel Fuel Monitoring Program to include cleaning and inspection of the IP2 GT-1 gas turbine fuel oil storage tanks, IF2 and TP3 EDG fuel oil day tanks, IP2 SBO/Appendix R diesel generator fuel oil day tank, and IP3 Appendix R fuel oil storage tank and day tank once every ten years.Enhance the Diesel Fuel Monitoring Program to include quarterly sampling and analysis of the IP2 SBO/Appendix R diesel generator fuel oil day tank, IP2 security diesel fuel oil storage tank, IP2 security diesel fuel oil day tank, and IP3 Appendix R fuel oil storage tank. Particulates, water and sediment checks will be performed on the samples. Filterable solids acceptance criterion will be less than or equal to 10mg/l. Water and sediment acceptance criterion will be less than or equal to 0.05%.Enhance the Diesel Fuel Monitoring Program to include thickness measurement of the bottom of the following tanks once every ten years. IP2: EDG fuel oil storage tanks, EDG fuel oil day tanks, SBO/Appendix R diesel generator fuel oil day tank, GT-1 gas turbine fuel oil storage tanks, and diesel fire pump fuel oil storage tank; IP3: EDG fuel oil day tanks, EDG fuel oil storage tanks, Appendix R fuel oil storage tank, and diesel fire pump fuel oil storage tank.Enhance the Diesel Fuel Monitoring Program to change the analysis for water and particulates to a quarterly frequency for the following tanks. IP2: GT-1 gas turbine fuel oil storage tanks and diesel fire pump fuel oil storage tank; IP3: Appendix R fuel oil day tank and diesel fire pump fuel oil storage tank.Enhance the Diesel Fuel Monitoring Program to specify acceptance criteria for thickness measurements of the fuel oil storage tanks within the scope of the program.Enhance the Diesel Fuel Monitoring Program to direct samples be taken and include direction to remove water when detected.Revise applicable procedures to direct sampling of the onsite portable fuel oil contents prior to transferring the contents to the storage tanks.

Enhance the Diesel Fuel Monitoring Program to direct the addition of chemicals including biocide when the presence of biological activity is confirmed.

I P2: Complete I P3: December 12, 2015 NL-07-039 NL-13-122 NL-07-153 NL-08-057 A.2.1.8 A.3.1.8 B.1.9Audit items 128, 129, 132, 491,492, 510 NL-14-067 Attachment 2 Page 4 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 5 Enhance the External Surfaces Monitoring Program P2: NL-07-039 A.2.1.10 for IP2 and IP3 to include periodic inspections of omplete A.3.1.10 systems in scope and subject to aging management PNL-13-122 B.1.11 review for license renewal in accordance with 10 CFR D3: 54.4(a)(1) and (a)(3). Inspections shall include areas err1 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).

IP2: NL-07-039 A.2. 1.11 6 Enhance the Fatigue Monitoring Program for IP2 to p2ete A.2.1.11 monitor steady state cycles and feedwater cycles or ornplete A.3.1.11 perform an evaluation to determine monitoring is not NL-13-122 Audt1te required.

Review the number of allowed events and NL-07-153 Audit Item resolve discrepancies between reference documents 164 and monitoring procedures.

P3: Enhance the Fatigue Monitoring Program for IP3 to December 12, include all the transients identified.

Assure all fatigue 2015 analysis transients are included with the lowest limiting numbers. Update the number of design transients accumulated to date.

NL-14-067 Attachment 2 Page 5 of 21 COMMITMENT IMPLEMENTATION SOURCE I RELATED SCHEDULE LRA SECTION I AUDIT ITEM 7 Enhance the Fire Protection Program to inspect external surfaces of the JP3 RCP oil collection systems for loss of material each refueling cycle.Enhance the Fire Protection Program to explicitly state that the IP2 and IP3 diesel fire pump engine sub-systems (including the fuel supply line) shall be observed while the pump is running. Acceptance criteria will be revised to verify that the diesel engine does not exhibit signs of degradation while running;such as fuel oil, lube oil, coolant, or exhaust gas leakage.Enhance the Fire Protection Program to specify that the IP2 and IP3 diesel fire pump engine carbon steel exhaust components are inspected for evidence of corrosion and cracking at least once each operating cycle.Enhance the Fire Protection Program for IP3 to visually inspect the cable spreading room, 480V switchgear room, and EDG room C02 fire suppression system for signs of degradation, such as corrosion and mechanical damage at least once every six months.P2: ,omplete NL-07-039 NL-13-122 A.2.1.12 A.3.1.12 B.1.13 P3: December 12, 2015 NL-14-067 Attachment 2 Page 6 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE [LRA SECTION j/ AUDIT ITEM 8 Enhance the Fire Water Program to include inspection of IP2 and IP3 hose reels for evidence of corrosion.

Acceptance criteria will be revised to verify no unacceptable signs of degradation.

Enhance the Fire Water Program to replace all or testa sample of IP2 and IP3 sprinkler heads required for 10 CFR 50.48 using guidance of NFPA 25 (2002 edition), Section 5.3.1.1.1 before the end of the 50-year sprinkler head service life and at 10-year intervals thereafter during the extended period of operation to ensure that signs of degradation, such as corrosion, are detected in a timely manner.Enhance the Fire Water Program to perform wall thickness evaluations of IP2 and IP3 fire protection piping on system components using non-intrusive techniques (e.g., volumetric testing) to identify evidence of loss of material due to corrosion.

These inspections will be performed before the end of thecurrent operating term and at intervals thereafter during the period of extended operation.

Results of the initial evaluations will be used to determine the appropriate inspection interval to ensure aging effects are identified prior to loss of intended function.Enhance the Fire Water Program to inspect the internal surface of foam based fire suppression tanks.Acceptance criteria will be enhanced to verify nosianificant corrosion.

P2: ,omplete NL-07-039 NL-13-122 NL-07-153 NL-08-014 A.2.1.13 A.3.1.13 B.1.14 Audit Items 105,106 P3: December 12, 2015 NL-14-067 Attachment 2 Page 7 of 21 COMMITMENT IMPLEMENTATION SCHEDULE SOURCE RELATED LRA SECTION/ AUDIT ITEM 9 Enhance the Flux Thimble Tube Inspection Program for IP2 and IP3 to implement comparisons to wear rates identified in WCAP-12866.

Include provisions to compare data to the previous performances and perform evaluations regarding change to testfrequency and scope.Enhance the Flux Thimble Tube Inspection Program for IP2 and IP3 to specify the acceptance criteria as outlined in WCAP-12866 or other plant-specific values based on evaluation of previous test results.Enhance the Flux Thimble Tube Inspection Program for IP2 and IP3 to direct evaluation and performance of corrective actions based on tubes that exceed or are projected to exceed the acceptance criteria.

Also stipulate that flux thimble tubes that cannot be inspected over the tube length and cannot be shown by analysis to be satisfactory for continued service, must be removed from service to ensure the integrity of the reactor coolant system pressure boundary.IP2: Complete I P3: December 12, 2015 NL-07-039 NL-13-122 A.2.1.15 A.3.1.15 B.1.16 NL-14-067 Attachment 2 Page 8 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I_ I / AUDIT ITEM 10 Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to include the following heat exchangers in the scope of the program.* Safety injection pump lube oil heat exchangers

• RHR heat exchangers

• RHR pump seal coolers* Non-regenerative heat exchangers

• Charging pump seal water heat exchangers

• Charging pump fluid drive coolers* Charging pump crankcase oil coolers* Spent fuel pit heat exchangers

• Secondary system steam generator sample coolers* Waste gas compressor heat exchangers

• SBO/Appendix R diesel jacket water heat exchanger (IP2 only)

Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to perform visual inspection on heat exchangers where non-destructive examination, such as eddy current inspection, is not possible due to heat exchanger design limitations.

Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to include consideration of material-environment combinations when determining sample population of heat exchangers.

Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to establish minimum tube wall thickness for the new heat exchangers identified in the scope of the prcgram. Establish acceptance criteria for heat exchangers visually inspected to include no indication of tube erosion, vibration wear, corrosion, pitting, fouling, or scaling.P2: complete P3: December 12, 2015 NL-07-039 NL-13-122 NL-07-153 NL-09-018 A.2.1.16 A.3.1.16 B.1.17, Audit Item 52 11 Deleted NL-09-056{ I NL-11-101 NL-14-067 Attachment 2 Page 9 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 12 Enhance the Masonry Wall Program for IP2 and IP3 1P2: NL-07-039 A.2.1.18 to specify that the IP1 intake structure is included in Complete A.3.1.18 the program. IP3:NL-13-122 B.1.19 Complete 13 Enhance the Metal-Enclosed Bus Inspection Program 1P2: NL-07-039 A.2.1.19 for IP2 and IP3 to visually inspect the external surface Complete A.3.1.19 NL-13-122 B.1.20 of MEB enclosure assemblies for loss of material at NL-13-122 Aui.tm least once every 10 years. The first inspection will occur prior to the period of extended operation and -ecember 12, 124, the acceptance criterion will be no significant loss of 015 NL-08-057 133,519 material.

NL-13-077 Enhance the Metal-Enclosed Bus Inspection Program to add acceptance criteria for MEB internal visual inspections to include the absence of indications of dust accumulation on the bus bar, on the insulators, and in the duct, in addition to the absence of indications of moisture intrusion into the duct.Enhance the Metal-Enclosed Bus Inspection Programfor IP2 and IP3 to inspect bolted connections at least once every five years if performed visually or at least once every ten years using quantitative measurements such as thermography or contactresistance measurements.

The first inspection will occur prior to the period of extended operation.

The plant will process a change to applicable site procedure to remove the reference to "re-torquing" connections for phase bus maintenance and bolted connection maintenance.

14 Implement the Non-EQ Bolted Cable Connections P2: NL-07-039 A.2.1.21 Program for IP2 and IP3 as described in LRA Section Nomplete A.3.1.21 B. .2.NL-13-122 B.1.22 B.1.22. IP3: lecember 12,__015 NL-14-067 Attachment 2 Page 10 of 21 COMMITMENT IMPLEMENTATION SCHEDULE SOURCE RELATED LRA SECTION/ AUDIT ITEM 15 Implement the Non-EQ Inaccessible Med'um-Voltage oP2: NL-07-039 A.2.1.22 Cable Program for IP2 and IP3 as described in LRA omplete NL-13-122

.1.2 Section B.1 .23. N1322 B.1.23 IP3: NL-07-153 Audit item This new program will be implemented consistent with December 12, 173 the corresponding program described in NUREG- 2015 NL-1 1-032 1801 Section Xl.E3, Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 Environmental NL-11-096 Qualification Requirements.

NL-1 1-101 IP2: NL-07-039 A.2.1.23 16 Implement the Non-EQ Instrumentation Circuits Test A.2.1.23 Review Program for IP2 and IP3 as described in LRA Complete A.3.1.23 SecionB.124.NL-13-122 B. 1.24 Section B.1.24. IP3: NL-07-153 Audit item This new program will be implemented consistent with December 12, 173 the corresponding program described in NUREG- ?015 1801 Section XI.E2, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits.IP2: NL-07-039 A.2.1.24 17 Implement the Non-EQ Insulated Cables and Connections Program for IP2 and IP3 as described in omplete A.3.1.24 LRA Section B.1.25. NL-13-122 B.1.25 P3: NL-07-153 Audit item This new program will be implemented consistent with December 12, 173 the corresponding program described in NUREG- 2015 1801 Section XI.E1, Electrical Cables and Connections Not Subject to 10 CFR 50.46 Environmental Qualification Requirements.

NL-14-067 Attachment 2 Page 11 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 18 Enhance the Oil Analysis Program for IP2 to sample 1P2: NL-07-039 A.2.1.25 and analyze lubricating oil used in the SBO/Appendix Complete A.3.1.25 NL-13-122 B.1.26 R diesel generator consistent with the oil analysis for P3: NL-11-101 other site diesel generators.

December 12, Enhance the Oil Analysis Program for IP2 and IP3 to 2015sample and analyze generator seal oil and turbine hydraulic control oil.Enhance the Oil Analysis Program for IP2 and IP3 to formalize preliminary oil screening for water and particulates and laboratory analyses including defined acceptance criteria for all components included in the scope of this program. The program will specify corrective actions in the event acceptance criteria are not met.Enhance the Oil Analysis Program for IP2 and IP3 to formalize trending of preliminary oil screening results as well as data provided from independent laboratories.

19 Implement the One-Time Inspection Program for IP2 P2: NL-07-039 A.2.1.26 and IP3 as described in LRA Section 1.1.27. Complete A.3.1.26 NL-13-122 B.1.27 This new program will be implemented consistent with P3: NL-07-153 Audit item the corresponding program described in NUREG- ecember 12, 173 1801,Section XI.M32, One-Time Inspection.

015 20 Implement the One-Time Inspection

-Small Bore P2: NL-07-039 A.2.1.27 Piping Program for IP2 and IP3 as described in LRA omplete A.3.1.27 Section 1.1.28. NL-13-122 6.1.28 1 P3: NL-07-153 Audit item This new program will be implemented consistent with December 12, 173 the corresponding program described in NUREG- 2015 1801,Section XI.M35, One-Time Inspection of ASME Code Class I Small-Bore Piping.21 Enhance the Periodic Surveillance and Preventive P2: NL-07-039 A.2.1.28 Maintenance Program for IP2 and IP3 as necessary omplete A.3.1.28 to assure that the effects of aging will be managed P3: NL-13-122 B.1.29 such that applicable components will continue to perform their intended functions consistent with the em 1 current licensing basis through the period of extended I operation.

NL-14-067 Attachment 2 Page 12 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 22 Enhance the Reactor Vessel Surveillance Program for P2: NL-07-039 A.2.1.31 IP2 and IP3 revising the specimen capsule withdrawal Complete A.3.1.31 NL-13-122 B.1.32 schedules to draw and test a standby capsule to P3: cover the peak reactor vessel fluence expected December 12, through the end of the period of extended operation.

2015 Enhance the Reactor Vessel Surveillance Program for IP2 and IP3 to require that tested and untested specimens from all capsules pulled from the reactor vessel are maintained in storage.IP2: NL-07-039 A.2.1.3223 Implement the Selective Leaching Program for IP2 Cpet LA.3.1.32 and IP3 as described in LRA Section B.1.33. omplete A.3.1.32NL-13-122 B.1.33 This new program will be implemented consistent with IP3: NL-07-153 Audit item the corresponding program described in NUREG- ecember 12, 173 1801,Section XI.M33 Selective Leaching of Materials.

015 24 Enhance the Steam Generator Integrity Program for P2- NL-07-039 A.2.1.34 IP2 and IP3 to require that the results of the condition omplete A.3.1.34 NL-13-122 B.1.35 monitoring assessment are compared to the PP3B operational assessment performed for the prior omplete operating cycle with differences evaluated.

f Enhance the Structures Monitoring Program to P2: NL-07-039 A.2.1.35 25 explicitly specify that the following structures are omplete A.3.1.35 included in the program. NL-13-122 B.1.36 G Appendix R diesel generator foundation (IP3) P3: NL-07-153 0 Appendix R diesel generator fuel oil tank vault December 12, Audit items (IP3) 2015 86, 87, 88, 6 Appendix R diesel generator switchgear and NL-08-057 417 enclosure (IP3)a city water storage tank foundation

• condensate storage tanks foundation (IP3) NL-13-077* containment access facility and annex (IP3)* discharge canal (IP2/3)0 emergency lighting poles and foundations (IP2/3)* fire pumphouse (IP2)0 fire protection pumphouse (IP3)* fire water storage tank foundations (IP2/3)* gas turbine 1 fuel storage tank foundation

• maintenance and outage building-elevated passageway (IP2)0 new station security building (IP2)

• nuclear service building (IP1)* primary water storage tank foundation (IP3)_ refueling water storage tank foundation (IP3)

NL-14-067 Attachment 2 Page 13 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I_____ /AUDIT ITEM 0 0 0 0 0 0 security access and office building (IP3)service water pipe chase (IP2/3)service water valve pit (IP3)superheater stack transformer/switchyard support structures (IP2)waste holdup tank pits (IP2/3)Enhance the Structures Monitoring Program for IP2 and IP3 to clarify that in addition to structural steel and concrete, the following commodities (including their anchorages) are inspected for each structure as applicable.

• cable trays and supports* concrete portion of reactor vessel supports* conduits and supports* cranes, rails and girders* equipment pads and foundations

• fire proofing (pyrocrete)" HVAC duct supports* jib cranes* manholes and duct banks* manways, hatches and hatch covers* monorails* new fuel storage racks* sumps Enhance the Structures Monitoring Program for IP2 and IP3 to inspect inaccessible concrete areas that are exposed by excavation for any reason. IP2 and IP3 will also inspect inaccessible concrete areas in environments where observed conditions in accessible areas exposed to the same environment indicate that significant concrete degradation is occurring.

Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspections of elastomers (seals, gaskets, seismic joint filler, and roof elastomers) to identify cracking and change in material properties and for inspection of aluminum vents and louvers to identify loss of material.NL-13-077 Enhance the Structures Monitoring Program for IP2 NL-14-067 Attachment 2 Page 14 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I I./ AUDIT ITEM and IP3 to perform an engineering evaluation of groundwater samples to assess aggressiveness of groundwater to concrete on a periodic basis (at least once every five years). IPEC will obtain samples from at least 5 wells that are representative of the ground water surrounding below-grade site structures and perform an engineering evaluation of the results from those samples for sulfates, pH and chlorides.

Additionally, to assess potential indications of spent fuel pool leakage, IPEC will sample for tritium in groundwater wells in close proximity to the IP2 spentfuel pool at least once every 3 months.Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspection of normally submerged concrete portions of the intake structures at least once every 5 years. Inspect the baffling/grating partition and support platform of the IP3 intake structure at least once every 5 years.Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspection of the degraded areas of the water control structure once per 3 years ratherthan the normal frequency of once per 5 years during the PEO.Enhance the Structures Monitoring Program to include more detailed quantitative acceptance criteria for inspections of concrete structures in accordance with ACI 349.3R, "Evaluation of Existing Nuclear Safety-Related Concrete Structures" prior to the period of extended operation.

NL-08-127 Audit Item 360 Audit Item 358 NL-1 1-032 NL-1 1-101 P2: NL-07-039 A.2.1.36 26 Implement the Thermal Aging Embrittlement of Cast A.2.1.36 Austenitic Stainless Steel (CASS) Program for IP2 omplete A.3.1.36 and IP3 as described in LRA Section B.1.37. NL-13-122 B.1.37 P3: NL-07-153 Audit item This new program will be implemented consistent with ecember 12, 173 the corresponding program described in NUREG- 015 1801,Section XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)

Program.

NL-14-067 Attachment 2 Page 15 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 27 Implement the Thermal Aging and Neutron Irradiation 1P2: NL-07-039 A.2.1.37 Embrittlement of Cast Austenitic Stainless Steel Complete A.3.1.37 NL-13-122 B.1.38 (CASS) Program for IP2 and IP3 as described in LRA IP3: NL-07-153 Audit item Section B.1.38.Complete 173 This new program will be implemented consistent with the corresponding program described in NUREG-1801 Section XI.M13, Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program.28 Enhance the Water Chemistry Control -Closed IP2: NL-07-039 A.2.1.39 Cooling Water Program to maintain water chemistry of Complete A.3.1.39 NL-13-122 B.1.40 the IP2 SBO/Appendix R diesel generator cooling IP3: NL-08-057 Audit item system per EPRI guidelines.

Complete 509Enhance the Water Chemistry Control -Closed Cooling Water Program to maintain the IP2 and IP3 security generator and fire protection diesel cooling water pH and glycol within limits specified by EPRI guidelines.

29 Enhance the Water Chemistry Control -Primary and P2: NL-07-039 A.2.1.40 Secondary Program for IP2 to test sulfates monthly in omplete B.1N.41 the RWST with a limit of <150 ppb. NL-13-122 30 For aging management of the reactor vessel internals, P2: NL-07-039 A.2.1.41 IPEC will (1) participate in the industry programs for omplete NL-13-122 A.3.1.41 investigating and managing aging effects on reactor N-31 internals; (2) evaluate and implement the results of Complete the industry programs as applicable to the reactor internals; and (3) upon completion of these programs, but not less than 24 months before entering the period of extended operation, submit an inspection plan for NL-1 1-107 reactor internals to the NRC for review and approval.P2: NL-07-039 A.2.2.1.2 31 Additional P-T curves will be submitted as required p2Nte A.3.2.1.2 per 10 CFR 50, Appendix G prior to the period of omplete A.3.2.1.2 extended operation as part of the Reactor Vessel PNL-13-122 4.2.3 Surveillance Program. ecember 12, 2015 32 As required by 10 CFR 50.61 (b)(4), IP3 will submit a P3: NL-07-039 A.3.2.1.4 plant-specific safety analysis for plate B2803-3 to the December 12, 4.2.5 NRC three years prior to reaching the RTPTS 015 NL-08-127 screening criterion.

Alternatively, the site may choose to implement the revised PTS rule when approved.

NL-14-067 Attachment 2 Page 16 of 21 COMMITMENT IMPLEMENTATION SOURCE I RELATED SCHEDULE LRA SECTION I_/ I I / AUDIT ITEM 33 At least 2 years prior to entering the period of extended operation, for the locations identified in LRA Table 4.3-13 (1P2) and LRA Table 4.3-14 (!P3), under the Fatigue Monitoring Program, IP2 and IP3 will implement one or more of the following:

(1) Consistent with the Fatigue Monitoring Program, Detection of Aging Effects, update the fatigue usage calculations using refined fatigue analyses to determine valid CUFs less than 1.0 when accounting for the effects of reactor water environment.

This includes applying the appropriate Fen factors to valid CUFs determined in accordance with one of the following:

1. For locations in LRA Table 4.3-13 (IP2) and LRATable 4.3-14 (IP3), with existing fatigue analysis valid for the period of extended operation, use the existing CUF.2. Additional plant-specific locations with a valid CUF may be evaluated.

In particular, the pressurizer lower shell will be reviewed to ensure the surge nozzleremains the limiting component.

3. Representative CUF values from other plants, adjusted to or enveloping the IPEC plant specific external loads may be used if demonstrated applicable to IPEC.4. An analysis using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case) may be performed to determine a valid CUF.(2) Consistent with the Fatigue Monitoring Program, Corrective Actions, repair or replace the affected locations before exceeding a CUF of 1.0.P2: Domplete P3: Domplete NL-07-039 NL-13-122 NL-07-153 NL-08-021 NL-10-082 A.2.2.2.3 A.3.2.2.3 4.3.3 Audit item 146 34 1P2 SBO / Appendix R diesel generator will be NL-13-122 2.1.1.3.5 installed and operationaesel gy erator wi bemplet NL-07-078 committed change to the facility meets the 0Complete requirements of 10 CFR 50.59(c)(1) and, therefore, a license amendment pursuant to 10 CFR 50.90 is not NL-1 1-101 required.

NL-11-101 NL- 14-067 Attachment 2 Page 17 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 35 Perform a one-time inspection of representative P2: NL-08-127 Audit Item sample area of IP2 containment liner affected by the ompleteNL-13-122 1973 event behind the insulation, prior to ente'ing the period of extended operation, to assure liner degradation is not occurring in this area. P3: NL-1 1-101 Perform a one-time inspection of representative December 12, sample area of the I P3 containment steel liner at the ?015 juncture with the concrete floor slab, prior to entering the period of extended operation, to assure liner degradation is not occurring in this area.Any degradation will be evaluated for updating of the NL-09-018 containment liner analyses as needed.IP2: NL-08-127 Audit Item 36 Perform a one-time inspection and evaluation of a sample of potentially affected IP2 refueling cavity omplete NL-11-101 359 concrete prior to the period of extended operation.

NL-13-122 The sample will be obtained by core boring the refueling cavity wall in an area that is susceptible to exposure to borated water leakage. The inspection will include an assessment of embedded reinforcing steel.Additional core bore samples will be taken, if the NL-09-056 leakage is not stopped, prior to the end of the first ten years of the period of extended operation.

A sample of leakage fluid will be analyzed to NL-09-079 determine the composition of the fluid. If additional core samples are taken prior to the end of the first ten years of the period of extended operation, a sample of leakage fluid will be analyzed.IP2: NL-08-127 Audit Item 37 Enhance the Containment Inservice Inspection (CII- P2: 361 IWL) Program to include inspections of the Complete NL-13-122 361 containment using enhanced characterization of IP3: degradation (i.e., quantifying the dimensions of noted Complete indications through the use of optical aids) during the period of extended operation.

The enhancement includes obtaining critical dimensional data of degradation where possible through direct measurement or the use of scaling technologies for photographs, and the use of consistent vantage points for visual inspections.

NL-14-067 Attachment 2 Page 18 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 1P2: NL-08-143 4.2.1 38 For Reactor Vessel Fluence, should future core loading patterns invalidate the basis for the projected Complete values of RTpts or CRUSE, updated calculations will N3: be provided to the NRC. P3:br 2]ecember 12,ý0115 39 Deleted NL-09-079 40 Evaluate plant specific and appropriate industry pNL-09-106 B.1.6 operating experience and incorporate lessons learned Complete B. 1.22 in establishing appropriate monitoring and inspection NL-13-122 B.1.23 frequencies to assess aging effects for the new aging ecember 12, B.1.25 management programs.

Documentation of the _e015 B.1.27 operating experience evaluated for each new program B.1.28 will be available on site for NRC review prior to the B.1.28 period of extended operation.

B.1.33 B. 1.37 B.1.38 41 IPEC will inspect steam generators for both units to NL-1 1-032 N/A assess the condition of the divider plate assembly.

egn t The examination technique used will be capable of Peginning of the detecting PWSCC in the steam generator divider plate EO and prior to assembly.

The IP2 steam generator divider plate eptember 28, inspections will be completed within the first ten years NL-1 1-074 of the period of extended operation (PEO). The IP3 NL-1 1-090 steam generator divider plate inspections will be completed within the first refueling outage following Prior to the end the beginning of the PEO. f the first NL-11-101 refueling outage Following the Deginning of the PEO.II NL-14-067 Attachment 2 Page 19 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION 1 1_ _ / AUDIT ITEM 42 IPEC will develop a plan for each unit to address the potential for cracking of the primary to secondary pressure boundary due to PWSCC of tubc -to-tubesheet welds using one of the following two options.Option 1 (Analysis)

IPEC will perform an analytical evaluation of the steam generator tube-to-tubesheet welds in order to establish a technical basis for either determining that the tubesheet cladding and welds are not susceptible to PWSCC, or redefining the pressure boundary in which the tube-to-tubesheet weld is no longer included and, therefore, is not required for reactor coolant pressure boundary function.

The redefinition of the reactor coolant pressure boundary must be approved by the NRC as a license amendment request.Option 2 (Inspection)

IPEC will perform a one-time inspection of a representative number of tube-to-tubesheet welds ineach steam generator to determine if PWSCC cracking is present. If weld cracking is identified:

a. The condition will be resolved through repair or engineering evaluation to justify continued service, as appropriate, and

b. An ongoing monitoring program will be established to perform routine tube-to-tubesheet weld inspections for the remaining life of the steam generators.

NL-1 1-032 NL-1 1-074 NL-1 1-090 NL-1 1-096 N/A I P2: Prior to March 2024 IP3: Prior to the end of the first refueling outage following the beginning of the PEO.IP2: Between March 2020 and March 2024 1P3: Prior to the end of the first refueling outage following the beginning of the PEO.43 IPEC will review design basis ASME Code Class 1 fatigue evaluations to determine whether the NUREG/CR-6260 locations that have been evaluated for the effects of the reactor coolant environment on fatigue usage are the limiting locations for the IP2 and IP3 configurations.

If more limiting locations are identified, the most limiting location will be evaluated for the effects of the reactor coolant environment on fatigue usage.IPEC will use the NUREG/CR-6909 methodology in the evaluation of the limiting locations consisting of nickel alloy, if any.P2:.complete P3: Prior to)ecember 12, 2015 NL-1 1-032 NL-13-122 NL-1 1-101 4.3.3 NL-14-067 Attachment 2 Page 20 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 44 IPEC will include written explanation and justification oP2: NL-11-032 N/A of any user intervention in future evaluations using the omplete NL-1 1-101 WESTEMS "Design CUF" module. IP3: Prior to NL-13-122 December 12, 2015 45 IPEC will not use the NB-3600 option of the P2: NL-1 1-032 N/A WESTEMS program in future design calculations until omplete NL11-101 the issues identified during the NRC review of the P3: Prior to NL-13-122 program have been resolved.

December 12, 2015 46 Include in the IP2 IS[ Program that IPEC will perform P2: NL-1 1-032 N/A twenty-five volumetric weld metal inspections of omplete NL-1 1-074 socket welds during each 10-year ISI interval NL-1122 scheduled as specified by IWB-2412 of the ASME NL-13-122 Section Xl Code during the period of extended operation.

In lieu of volumetric examinations, destructive examinations may be performed, where one destructive examination may be substituted for two volumetric examinations.

47 IPEC will and submit aRaly"es that W-- N12089 N/A demonzstrate that the lOWor cUPPGot GGlUF-bedee-wiGF maditain their f-nctionality g the p o .-,, 02f_____ 14-12-32a otd ,,de , pc.atiOn conidorig tho possible loss of 3 to fracture toughness duo to thormal and OFadiatiOR emb12 NL406 ombrittlomont.

The analyses will be .....is..t With NL-14-067 the IPWZ1P3 iOn ...ing baSis. Deleted.

NL-14-067 Attachment 2 Page 21 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 48 Entergy will visually inspect IPEC underground piping P2: NL-12-174 N/A within the scope of license renewal and subject to omplete aging management review prior to the period of lP3: Prior to NL-13-122 extended operation and then on a frequency of at December 12, least once every two years during the period of extended operation.

This inspection frequency will be maintained unless the piping is subsequently coated in accordance with the preventive actions specified in NUREG-1801 Section XI.M41 as modified by LR-ISG-2011-03. Visual inspections will be supplemented with surface or volumetric non-destructive testing if indications of significant loss of material areobserved. Consistent with revised NUREG-1 801 Section XI.M41, such adverse indications will be entered into the plant corrective action program for evaluation of extent of condition and for determination of appropriate corrective actions (e.g., increased inspection frequency, repair, replacement).

49 Recalculate each of the limiting CUFs provided in P2: NL-13-052 A.2.2.2 section 4.3 of the LRA for the reactor vessel internals omplete A.3.2.2to include the reactor coolant environment effects P3: Prior to NL-13-122 (Fen) as provided in the IPEC Fatigue Monitoring ecember 12, Program using NUREG/CR-5704 or NUREG/CR-2015 6909. In accordance with the corrective actions specified in the Fatigue Monitoring Program, corrective actions include further CUF re-analysis, and/or repair or replacement of the affected components prior to the CUFen reaching 1.0.50 f .the planned cplacemcnt of the 1122 split pine P2: NL-1 3-122 A.2.1.41 will not be in 2016, proVide the B.1.42 NRC staff a detailed in.pection plaR for the IP2 , 20!5 NL-14-067split pins, including ORSPectiOR methods, n.p.c.i ; coe"rage, and 5nRpctti0R fr.equency, rior to by March 31, 2015. Replace the IP2 split pins ;ompletion of during the 2016 refueling outa-ge (2R22). 2R22 P3: N/A

-Entergy Enterav Nuclear Northeast Indian Point Energy Center 450 Broadway, GS13 P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 254-2055 Fred Dacimno Vice President Operations License Renewal NL-14-067 June 9, 2014 U.S. Nuclear Regulatory Commission Document Control Desk 11545 Rockville Pike, TWFN-2 F1 Rockville, MD 20852-2738

REFERENCE:

Reply to Request for Additional Information Regarding the License Renewal Application Indian Point Nuclear Generating Unit Nos. 2 & 3Docket Nos.

50-247 and 50-286 License Nos. DPR-26 and DPR-64 NRC letter, "Request for Additional Information for the Review of the Indian Point Nuclear Generating Unit Nos. 2 and 3, License Renewal Application, SET 2014-02 (TAC Nos. MD5407 and MD5408)" dated April 9, 2014.

Dear Sir or Madam:

Entergy Nuclear Operations, Inc. is providing, in Attachment 1, the additional information requested in the referenced letter pertaining tcu NRC review of the License Renewal Application (LRA) for Indian Point 2 and Indian Point 3.The responses to RAI 11-C. and RAI 16-B include the deletion of Commitment 47 and a revision to Commitment 50, respectively.

These commitment changes are included in the list of regulatory commitments provided in Attachment 2.If you have any questions, or require additional information, please contact Mr. Robert Walpoleat 914-254-6710.

I declare d r penalty of perjury that the foregoing is true and correct. Executed on M 2014.Sin erely FRD/rw Docket Nos. 50-247 & 50-286 NL-14-067 Page 2 of 2

Attachment:

1. Reply to NRC Request for Additional Information Regarding the License Renewal Application

2. License Renewal Application IPEC List of Regulatory Commitments Revision 23 cc: Mr. William Dean, Regional Administrator, NRC Region I Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel Mr. Dave Wrona, NRC Branch Chief, Engineering Review Branch I Ms. Kimberly Green, NRC Sr. Project Manager, Division of License Renewal Mr. Douglas Pickett, NRR Senior Project Manager Ms. Bridget Frymire, New York State Department of Public Service NRC Resident Inspector's Office Mr. John B. Rhodes, President and CEO NYSERDA ATTACHMENT 1 TO NL-14-067 REPLY TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE LICENSE RENEWAL APPLICATION ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286 NL-14-067 Attachment 1 Page 1 of 5 REQUEST FOR ADDITIONAL.INFORMATION, SET 2014-02 RELATED TO INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION REACTOR VESSEL INTERNALS PROGRAM AND INSPECTION PLAN RA! 11-C Applicant/Licensee Action Item 7 from the staff's final safety evaluation (SE) of MRP-227 requires the applicants/licensees of Babcock & Wilcox (B&W), Combustion Engineering (CE), and Westinghouse reactors to develop plant-specific analyses to be applied for their facilities to demonstrate that B&W In-Core Monitoring Instrumentation (IMI) guide tube assembly spiders and control rod guide tube (CRGT) assembly spacer castings, CE lower support columns, and Westinghouse lower support column bodies will maintain their functionality during the period of extended operation, and states that these analyses should also consider the possible loss of fracture toughness in these components due to thermal embrittlement (TE) and irradiation embrittlement (IE). For Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3), the equivalent component to the lower support column bodies are the lower internals assembly -column caps (column caps).By letter dated January 28, 2014, Entergy provided plant specific information on the ferrite content and susceptibility to TE for the Indian Point Nuclear Generating Unit Nos. 2 and 3 lower internals assembly -column caps. Based on its evaluation of the plant-specific material information for the column caps, Entergy concluded that the IP2 and IP3 column caps are not susceptible to TE.Entergy's conclusion related to TE notwithstanding, the column caps remain susceptible to IE.The staff is concerned that the linked Primary component for the column caps, the CRGT assembly lower flange welds, is not a good predictor of IE for the column caps since the CRGT lower flange welds receive substantially lower neutron fluence than the column caps (based on the estimated neutron fluence tabulated in MRP-191 for the two components).

Irradiation assisted stress corrosion cracking (IASCC) is the only mechanism of cracking that screened in for the column caps. The CRGT lower flange welds are also not a good predictor for IASCC of the column caps, because the lower flange welds are susceptible to stress corrosion cracking (SCC) and fatigue cracking, but not IASCC.The staff, therefore, requests that Entergy modify its Reactor Vessel Internals Inspection Plan (RVI Inspection Plan) to provide a link to a Primary component or components that isan appropriate predictor of IE and IASCC of the column caps.Response to RAI 11-C The following text will be incorporated into the reactor vessel internals (RVI) Inspection Plan for Indian Point Units 2 and 3 regarding a link to a component that is an appropriate predictor of irradiation embrittlement (IE) and irradiation-assisted stress corrosion cracking (IASCC) of the column caps.

NL-14-067 Attachment 1 Page 2 of 5'The lower core plate, which was screened in for IASCC in MRP..191[1], is a leading indicator of cracking in the column caps of the lower support column bodies because it is subject to more severe service conditions. Due to its proximity to the core, the lower core plate experiences bothhigher fluences and higher gamma heating than the column caps. Additionally, thermally induced tensile stresses are anticipated in the lower core plate while the stresses in the column caps are largely compressive.

These factors are expected to contribute to earlier IASCC initiation in the lower core plate, making it a suitable leading indicator of cracking in the column caps.The lower support column caps at Indian Point Units 2 and 3 have the same irradiation embrittlement mechanism as the wrought stainless steel lower core plate. The 60-year fluence in the top few inches of the lower support column body, which is where the column cap is located, is projected to exceed the threshold for irradiation embrittlement of austenitic stainless steel. Therefore, irradiation embrittlement is considered a damage mechanism in the column caps.Considering both the cracking mechanism and the likely embrittlement mechanism, a leading indicator of degradation for the column caps is the lower core plate.

Since the lower core plate is an Existing Programs component in MRP-227-A

[21 and must be inspected as part of the aging management program, it is an appropriate alternate component for predicting aging effects.The lower core plate will continue to be an Existing Programs component, managed under the Indian Point program for ASME Section Xl inspections.

The inspection requirement will remain a VT-3 inspection of the accessible upper surface on a ten-year interval.

In addition to the standard requirements for assessing extent of condition required under ASME Section Xl, a trigger for the Expansion inspection of the lower support column bodies (column caps) for Indian Point Units 2 and 3 will be the confirmed discovery of a service induced flaw in the lower core plate." The intent of Commitment 47 was to demonstrate that the lower support column bodies will maintain their functionality during the period of extended operation considering the possible loss of fracture toughness due to thermal and irradiation embrittlement.

As the staff noted in this RAI 11-C, Entergy has concluded that the IP2 and IP3 column caps (equivalent component to the lower support column bodies) are not susceptible to TE and will modify the Reactor Vessel Internals (RVI) Inspection Plan to credit inspection of the lower core plate as an appropriate predictor of IE and IASCC of the column caps. Therefore, the functionality of the lower support column bodies is assured during the period of extended operation without the need for a functionality analysis.

Therefore, Entergy is deleting Commitment 47 (additions are underlined, deletions lined out).Commitment 47 IPEC will peorfm and submit analyses that tho loWor .uppe. t column bodio,, wil m1 aintain thoir hfunctienality during the poriod of oxtondod operation; concidoring the pocciblo9 lace of fracture toughnocc duo to therm;al and irradiation omnbrittlomnet.

The analycoc will be GGRG!6teRt KH tHe 11-atilde 11GeHG1HgLI.gIeIeU.

NL- 14-067 Attachment 1 Page 3 of 5 References

1. Materials Reliability Program: Screening, Categorization, and Ranking of Reactor Internals Components for Westinghouse and Combustion Engineering PWR Design (MRP-1 91).EPRI, Palo Alto, CA:

2006. 1013234.2. Materials Re~iability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guidelines (MRP-227-A). EPRI, Palo Alto, CA: 2011. 1022863.RAI 16-B In its September 27, 2013 response to RAI 16-A, Entergy proposed Commitment No. 50 stating that it would provide the NRC staff a detailed inspection plan for the IP2 split pins, including inspection methods, inspection coverage, and inspection frequency, by March 31, 2015, if the planned replacement of the IP2 split pins will not be accomplished in 2016. In order to resolve MRP-227-A Applicant/Licensee Action Item 3, the NRC staff requests Entergy submit the schedule for initial inspection, inspection methods, inspection coverage, and inspection frequency for the IP2 split pins in the event the IP2 split pins are not replaced by 2016, and that Commitment No. 50 be modified accordingly.

Response to RA! 16-BEntergy commits to replacing the IP2 split pins during the 2016 refueling outage (2R22).Therefore, a schedule for initial inspection, inspection methods, inspection coverage, and inspection frequency for the IP2 split pins is not necessary.

Accordingly, Entergy is revising Commitment 50 and the identified LRA sections as follows (additions are underlined, deletions lined out).Commitment 50 if tho plainnod roplacornot of the 1122 split pins will noet be accomplashod in 2016, provide the NAC staff a detailod inspoction plan !fo the 1122 split pins, including insepotionin..eption c...rag., and in.e..tiO.

fr.quoncy, by March 31, 2016. Replace the IP2 split pins durinq the 2016 refueling outage (2R22).The following paragraph is revised in the Updated Final Safety Analysis Report LRA Section A.2.1.41.The IP2 guide tube support pins (split pins) will be replaced during the 2016 refueling outage (2R22) arc ,hoduo, t- be roplacod dur.ing the 2016 Ofe 5 e u' ' ita"e. ' 4-the planned replaement of the 1122 split pins will i,,t bo a ,omplishd in 2016, E.torg ,wll prvide the NIRI staff a pn including in.p..ti;" mothods, inepoc~tion coverage, and inspoction; frquoncY, no lator than March 31 , 2015.The following paragraph is revised in LRA Section B.1.42, Reactor Vessel Internals Program, under "Evaluation/l.

Scope of Program," new last paragraph:

The IP2 guide tube support pins (split pins) are plant-specific components as discussed in MRP-227-A, Section 4.4.3, "Westinghouse Components." The split pins will be NL-14-067 Attachment 1 Page 4 of 5 replaced during the 2016 refueling outage (2R22) ar..,ch"duld to bo the 2016 rofuoling .utago. See letter NL-12-166, Entergy to NRC, response to RAI 16, dated November 20, 2012, and letter NL-14-067, Entergy to NRC. response to RAI 16B for further discussion.

If the plannod ..aont of the 1122 , ^ it pins ,la*i" net be aGGOmnp!*chod in 2016, Entorgy Will prOVido the NIRG 6taff a dtidiepconplan, g ineptieoR. in..... "covoragondn frqUncY, no later than March 31, 2015.The revised commitment only affects IP2; therefore, LRA Section A.3.1.41 does not need revision.RAI 17-A In its September 27, 2013 response to RAI 17, Entergy provided a technical justification for the adequacy of the existing inspection requirements specified in MRP-227-A for the clevis insert bolts, which relies on its American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section Xl Inservice Inspection (ISI) Program. Entergy's response included the statement, "[t]he video camera visual inspections at a ten-year interval by qualified personnel that are specified in the ASME Code Section Xl and MRP-227-A are capable of identifying wear or dislodged components of the clevis insert cap screws or dowel pins at any location, if they exist." To assure that ihe type of degradation documented in Westinghouse InfoGram IG-10-1 would be reliably detected at IP2 and IP3, the staff requests the following additional information:

1. Provide the ASME Code Section Xl, Table IWB-2500 Examination Category and Item Number under which the IP2 and IP3 clevis insert bolts are classified.

2. Verify that the ASME Code, Section Xl examination of the clevis inserts directly views all the clevis insert bolt heads, dowel pins and locking devices for each clevis insert.3. If the ASME Code, Section Xl examination does not directly view all the clevis insert bolts heads, locking devices, and dowel pins, propose a modification to Entergy's ASME Code, Section Xl ISI Program to do so.4. State when the most recent ASME Code, Section Xl inspection of the clevis insert bolts was conducted at IP2 and IP3. Summarize the findings of that inspection for the clevis insert bolts.Response to RAI 17-A 1. The clevis insert bolts at IP2 and IP3 are inspected as part of the Category B-N-2 Item Number B133.60 inspections.

2. At IPEC, the ASME Code, Section Xl examination of the clevis inserts directly views all the clevis insert bolt heads, dowel pins, and locking devices for each clevis insert.3. At IPEC, the ASME Code,Section XI examination does directly view all the clevis insert bolts heads, locking devices, and dowel pins. The ASME Code requires a VT-3 of these NL-14-067 Attachment 1 Page 5 of 5 components and the VT-3 requirements include lighting and resolution requirements which will ensure that future inspections will continue to be performed in the same manner as they currently are being performed and, therefore, Entergy's ASME" Code, Section Xl ISI program does not require modification.

4. The most recent ASME Code, Section X1 inspection of the clevis insert bolts was conducted at IP2 in 2006 with no recordable indications and at IP3 in 2009 with no recordable indications.

ATTACHMENT 2 TO NL-14-067 LICENSE RENEWAL APPLICATION IPEC LIST OF REGULATORY COMMITMENTS Rev. 23 ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286 NL-14-067 Attachment 2 Page 1 of 21List of Regulatory Commitments Rev. 23 The following table identifies those actions committed to by Entergy in this document.Changes are shown as strikethroughs for and underlines for additions.

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 1 Enhance the Aboveground Steel Tanks Program for IP2: NL-07-039 A.2.1.1 IP2 and IP3 to perform thickness measurements of .omplete A.3.1.1 NL-13-122 8.1.1 the bottom surfaces of the condensate storage tanks, P3: city water tank, and fire water tanks once during the ecember 12, first ten years of the period of extended operation.

2015Enhance the Aboveground Steel Tanks Program for IP2 and IP3 to require trending of thickness I measurements when material loss is detected.NL-07-039 A.2.1 .2 2 Enhance the Bolting Integrity Program for IP2 and IP3 .2 to clarify that actual yield strength is used in selecting "omplete A.3.1.2 materials for low susceptibility to SCC and clarify the P3B. 1.2 prohibition on use of lubricants containing MoS 2 for omplete NL-07-153 Audit Items bolting. 201,241, The Bolting Integrity Program manages loss of NL-13-122 270 1 preload and loss of material for all external bolting. I _ I NL-14-067 Attachment 2 Page 2 of 21 COMMITMENT IMPLEMENTATION SOURCE I RELATED SCHEDULE LRA SECTION I/ I / AUDIT ITEM 3 Implement the Buried Piping and Tanks Inspection Program for IP2 and IP3 as described in LRA Section B.1.6.This new program will be implemented consistent with the corresponding program described in NUREG-1801 Section XI.M34, Buried Piping and Tanks Inspection.

Include in the Buried Piping and Tanks Inspection Program described in LRA Section B.1.6 a risk assessment of in-scope buried piping and tanks that includes consideration of the impacts of buried piping or tank leakage and of conditions affecting the risk for corrosion.

Classify pipe segments and tanks as having a high, medium or low impact of leakage based on the safety class, the hazard posed by fluid contained in the piping and the impact of leakage on reliable plant operation.

Determine corrosion risk through consideration of piping or tank material, soil resistivity, drainage, the presence of cathodic protection and the type of coating. Establish inspection priority and frequency for periodic inspections of the in-scope piping and tanks based on the results of the risk assessment.

Perform inspections using inspection techniques with demonstrated effectiveness.

IP2: ,omplete IP3: December 12, 2015 NL-07-039 NL-13-122 NL-07-153 NL-09-106 NL-09-1 11 A.2.1.5 A.3.1.5 8.1.6 Audit Item 173 NL-1 1-101 I I~ I- I NL-14-067 Attachment 2 Page 3 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION_/ 1 1 / AUDIT ITEM 4 Enhance the Diesel Fuel Monitoring Program to include cleaning and inspection of the IP2 GT-1 gas turbine fuel oil storage tanks, IP2 and IP3 EDG fuel oil day tanks, IP2 SBO/Appendix R diesel generator fuel oil day tank, and IP3 Appendix R fuel oil storage tank and day tank once every ten years.Enhance the Diesel Fuel Monitoring Program to include quarterly sampling and analysis of the IP2 SBO/Appendix R diesel generator fuel oil day tank, IP2 security diesel fuel oil storage tank, IP2 security diesel fuel oil day tank, and IP3 Appendix R fuel oil storage tank. Particulates, water and sediment checks will be performed on the samples. Filterable solids acceptance criterion will be less than or equal to 10mg/l. Water and sediment acceptance criterion will be less than or equal to 0.05%.Enhance the Diesel Fuel Monitoring Program to include thickness measurement of the bottom of the following tanks once every ten years. IP2: EDG fuel oil storage tanks, EDG fuel oil day tanks, SBO/Appendix R diesel generator fuel oil day tank, GT-1 gas turbine fuel oil storage tanks, and diesel fire pump fuel oil storage tank; IP3: EDG fuel oil day tanks, EDG fuel oil storage tanks, Appendix R fuel oil storage tank, and diesel fire pump-fuel oil storage tank.Enhance the Diesel Fuel Monitoring Program to change the analysis for water and particulates to a quarterly frequency for the following tanks. IP2: GT-1 gas turbine fuel oil storage tanks and diesel fire pump fuel oil storage tank; IP3: Appendix R fuel oil day tank and diesel fire pump fuel oil storage tank.Enhance the Diesel Fuel Monitoring Program to specify acceptance criteria for thickness measurements of the fuel oil storage tanks within the scope of the program.Enhance the Diesel Fuel Monitoring Program to direct samples be taken and include direction to remove water when detected.Revise applicable procedures to direct sampling of the onsite portable fuel oil contents prior to transferring the contents to the storage tanks.Enhance the Diesel Fuel Monitoring Program to direct the addition of chemicals including biocide when the presence of biological activity is confirmed.

P2: ,omplete IP3: December 12, P_01 5 NL-07-039 NL-13-122 NL-07-153 NL-08-057 A.2.1.8 A.3.1.8 B.1.9 Audit items 128, 129, 132, 491,492, 510 NL-14-067 Attachment 2 Page 4 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 5 Enhance the External Surfaces Monitoring Program IP2: NL-07-039 A.2.1.10 for IP2 and IP3 to include periodic inspections of Complete A.3.1.10 systems in scope and subject to aging management NL-13-122 6.1.11 review for license renewal in accordance with 10 CFR bP3: 54.4(a)(1) and (a)(3). Inspections shall include areas e br 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).

6 Enhance the Fatigue Monitoring Program for IP2 to P2: NL-07-039 A.2.1.11 monitor steady state cycles and feedwater cycles or omplete A.3.1.11 perform an evaluation to determine monitcring is not NL-13-122 A.1.12, required.

Review the number of allowed events and NL-07-153 Audit Item resolve discrepancies between reference documents 164 and monitoring procedures.

P3: Enhance the Fatigue Monitoring Program for iP3 to December 12, include all the transients identified.

Assure all fatigue 2015 analysis transients are included with the lowest limiting numbers. Update the number of design transients accumulated to date.

NL-14-067 Attachment 2 Page 5 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE ILRA SECTION I__IIjI/ AUDIT ITEM 7 Enhance the Fire Protection Program to inspect external surfaces of the IP3 RCP oil collection systems for loss of material each refueling cycle.Enhance the Fire Protection Program to explicitly state that the IP2 and IP3 diesel fire pump engine sub-systems (including the fuel supply line) shall be observed while the pump is running. Acceptance criteria will be revised to verify that the diesel engine does not exhibit signs of degradation while running;such as fuel oil, lube oil, coolant, or exhaust gas leakage.Enhance the Fire Protection Program to specify that the IP2 and IP3 diesel fire pump engine carbon steel exhaust components are inspected for evidence of corrosion and cracking at least once each operating cycle.Enhance the Fire Protection Program for IP3 to visually inspect the cable spreading room, 480V switchgear room, and EDG room C02 fire suppression system for signs of degradation, such as corrosion and mechanical damage at least once every six months.IP2: Complete NL-07-039 NL-13-122 A.2.1.12 A.3.1.12 B.1.13 1P3: December 12, 2015 I ~ L NL-14-067 Attachment 2 Page 6 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I I_ I / AUDIT ITEM 8 Enhance the Fire Water Program to include inspection of IP2 and IP3 hose reels for evidence of corrosion.

Acceptance criteria will be revised to verify no unacceptable signs of degradation.

Enhance the Fire Water Program to replace all or test a sample of IP2 and IP3 sprinkler heads required for 10 CFR 50.48 using guidance of NFPA 25 (2002 edition), Section 5.3.1.1.1 before the end of the 50-year sprinkler head service life and at 10-year intervals thereafter during the extended period of operation to ensure that signs of degradation, such as corrosion, are detected in a timely manner.Enhance the Fire Water Program to perform wall thickness evaluations of IP2 and IP3 fire protection piping on system components using non-intrusive techniques (e.g., volumetric testing) to identify evidence of loss of material due to corrosion.

These inspections will be performed before the end of thecurrent operating term and at intervals thereafter during the period of extended operation.

Results of the initial evaluations will be used to determine the appropriate inspection interval to ensure aging effects are identified prior to loss of intended function.Enhance the Fire Water Program to inspect the internal surface of foam based fire suppression tanks.

Acceptance criteria will be enhanced to verify no siQnificant corrosion.

I1P2: Complete NL-07-039 NL-13-122 NL-07-153 NL-08-014 A.2.1.13 A.3.1.13 B.1.14 Audit Items 105,106 IP3: December 12, 2015 NL-14-067 Attachment 2 Page 7 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I I_ I / AUDIT ITEM 9 Enhance the Flux Thimble Tube Inspection Program for IP2 and IP3 to implement comparisons to wear rates identified in WCAP-12866.

Include provisions to compare data to the previous performances and perform evaluations regarding change to test frequency and scope.Enhance the Flux Thimble Tube Inspection Program for IP2 and IP3 to specify the acceptance criteria as outlined in WCAP-12866 or other plant-specific values based on evaluation of previous test results.Enhance the Flux Thimble Tube Inspection Program for IP2 and IP3 to direct evaluation and performance of corrective actions based on tubes that exceed or are projected to exceed the acceptance criteria.

Also stipulate that flux thimble tubes that cannot be inspected over the tube length and cannot be shown by analysis to be satisfactory for continued service, must be removed from service to ensure the integrity of the reactor coolant system pressure boundary.P2: ,omplete NL-07-039 NL-13-122 A.2.1.15 A.3.1.15 B.1.16 P3::)ecember 12, 2-0115 NL-14-067 Attachment 2 Page 8 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/I I / AUDIT ITEM 10 Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to include the following heat exchangers in the scope of the program." Safety injection pump lube oil heat exchangers" RHR heat exchangers

• RHR pump seal coolers" Non-regenerative heat exchangers

• Charging pump seal water heat exchangers

• Charging pump fluid drive coolers* Charging pump crankcase oil coolers* Spent fuel pit heat exchangers

• Secondary system steam generator sample coolers o Waste gas compressor heat exchangers

• SBO/Appendix R diesel jacket water heat exchanger (IP2 only)Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to perform visual inspection on heat exchangers where non-destructive examination, such as eddy current inspection, is not possible due to heat exchanger design limitations.

Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to include consideration of material-environment combinations when determining sample population of heat exchangers.

Enhance the Heat Exchanger Monitoring Program for IP2 and IP3 to establish minimum tube wall thickness for the new heat exchangers identified in the scope of the program. Establish acceptance criteria for heat exchangers visually inspected to include no indication of tube erosion, vibration wear, corrosion, pitting, foulina, or scalinq.IP2: complete IP3: December 12, 2015 NL-07-039 NL-1 3-122 NL-07-153 NL-09-018 A.2.1.16 A.3.1.16 B.1.17, Audit Item 52 11 Deleted NL-09-056 NL-1 1-101 NL-14-067 Attachment 2 Page 9 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEMI P2:N L-07-039 A.2. 1.18 12 Enhance the Masonry Wall Program for IP2 and IP3 P2: to specify that the IPI intake structure is included in Complete A.3.1.18 the program. NL-13-122 B.1.19 the rogrm, p3:___omplete

ýP2: NL-07-039 A.2.1.19 13 Enhance the Metal-Enclosed Bus Inspection Program Pomplete A.3.1.19 for IP2 and IP3 to visually inspect the external surface NL-13-122 B.1.20 of MEB enclosure assemblies for loss of material at NL-07-153 Bui.tm least once every 10 years. The first inspection will P3 b 12, AdIe occur prior to the period of extended operation and DeceNber 12, 124, the acceptance criterion will be no significant loss of 015 NL-08-057 133, 519 material.

NL- 13-077 Enhance the Metal-Enclosed Bus Inspection Program to add acceptance criteria for MEB internal visual inspections to include the absence of indications of dust accumulation on the bus bar, on the insulators, and in the duct, in addition to the absence of indications of moisture intrusion into the duct.Enhance the Metal-Enclosed Bus Inspection Program for IP2 and IP3 to inspect bolted connections at least once every five years if performed visually or at least once every ten years using quantitative measurements such as thermography or contact resistance measurements.

The first inspection will occur prior to the period of extended operation.

The plant will process a change to applicable site procedure to remove the reference to "re-torquing" connections for phase bus maintenance and bolted connection maintenance.

14 Implement the Non-EQ Bolted Cable Connections P2: NL-07-039 A.2.1.21 Program for IP2 and IP3 as described in LRA Section omplete A.3.1.21 B.1.22. P3: NL-13-122 B.1.22 Vecember 12,_015 NL-14-067 Attachment 2 Page 10 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM IP2: NL-07-039 A.2.1 .22 15 Implement the Non-EQ Inaccessible Medium-Voltage Cable Program for IP2 and IP3 as described in LRA Complete A.3.1.22 Section B.1.23. NL-13-122 B.1.23 P3: NL-07-153 Audit item This new program will be implemented consistent with December 12, 173 the corresponding program described in NUREG- 2015 NL-1 1-032 1801 Section XIE3, Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 Environmental NL-1 1-096 Qualification Requirements.

NL-11-101 IP2: NL-07-039 A.2.1 .23 16 Implement the Non-EQ Instrumentation Circuits Test A.2.1.23 Review Program for IP2 and IP3 as described in LRA Complete N3B.1.24 Section B.1.24. P3: NL-07-153 Audit item This new program will be implemented consistent with December 12, 173 the corresponding program described in NUREG- 2015 1801 Section XI.E2, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits.17 Implement the Non-EQ Insulated Cables and P2: NL-07-039 A.2.1.24..omleteA.3.1

.24 Connections Program for IP2 and IP3 as described in NL-13-122 B.1.25 LRA Section B.1.25. P3: NL-07-153 Audit item This new program will be implemented consistent with Decernber 12, 173 the corresponding program described in NUREG- 2015 1801 Section XI.E1, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.

NL-14-067 Attachment 2 Page 11 of 21 Y -I -COMMITMENT IMPLEMENTATION SCHEDULE SOURCE RELATED LRA SECTION/ AUDIT ITEM-t 18 Enhance the Oil Analysis Program for IP2 to sample and analyze lubricating oil used in the SBO/Appendix R diesel generator consistent with the oil ankc,lysis for other site diesel generators.Enhance the Oil Analysis Program for IP2 and IP3 to sample and analyze generator seal oil and turbine hydraulic control oil.Enhance the Oil Analysis Program for IP2 and IP3 toformalize preliminary oil screening for water and particulates and laboratory analyses including defined acceptance criteria for all components included in the scope of this program. The program will specify corrective actions in the event acceptance criteria are not met.Enhance the Oil Analysis Program for IP2 and IP3 to formalize trending of preliminary oil screening results as well as data provided from independent laboratories.

IP2: ,omplete IP3: December 12, 2015 NL-07-039 NL-13-122 NL-11-101 A.2.1.25 A.3.1.25 B.1.26 19 Implement the One-Time Inspection Program for IP2 P2:

NL-07-039 A.2.1.26 and IP3 as described in LRA Section 8.1.27. omplete A.3.1.26 NL-13-122 B.1.27 This new program will be implemented consistent with P3: NL-07-153 Audit item the corresponding program described in NUREG- Decernber 12, 173 1801,Section XI.M32, One-Time Inspection.

2015 20 Implement the One-Time Inspection

-Small Bore P2: NL-07-039 A.2.1.27 Piping Program for IP2 and IP3 as described in LRA Complete 8.31.28 Section B.1.28. P3: NL-07-153 Audit item This new program will be implemented consistent with December 12, 173 the corresponding program described in NUREG- 2015 1801,Section XI.M35, One-Time Inspection of ASME Code Class I Small-Bore Piping.IP2: NL-07-039 A.2.1.28 21 Enhance the Periodic Surveillance and Preventive P2N03 A.3.1.28Maintenance Program for IP2 and IP3 as necessary Complete A.3.1.28 to assure that the effects of aging will be managed 3P3: such that applicable components will continue to P31 perform their intended functions consistent with the em 1 current licensing basis through the period of extended 015 operation.

NL-14-067 Attachment 2 Page 12 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 22 Enhance the Reactor Vessel Surveillance Program for P2: NL-07-039 A.2.1.31 IP2 and IP3 revising the specimen capsule withdrawal omplete A.3.1.31 NL-13-122 B.1.32 schedules to draw and test a standby capsule to P3: cover the peak reactor vessel fluence expected December 12, through the end of the period of extended operation.

2015, Enhance the Reactor Vessel Surveillance Program for IP2 and IP3 to require that tested and untested specimens from all capsules pulled from the reactor I vessel are maintained in storage.23 Implement the Selective Leaching Program for IP2 -P2:

NL-07-039 A.2.1.32 and IP3 as described in LRA Section B.1.33. Oomplete A.3.1.32 NL-13-122 B.1.33 This new program will be implemented consistent with P3: NL-07-153 Audit item the corresponding program described in NUREG- ecember 12, 173 1801,Section XI.M33 Selective Leaching of Materials.

015 24 Enhance the Steam Generator Integrity Program for P2: NL-07-039 A.2.1.34 IP2 and IP3 to require that the results of the condition omplete A.3.1.34 monitoring assessment are compared to the P3: operational assessment performed for the prior omplete operating cycle with differences evaluated.

2 Enhance the Structures Monitoring Program to P2: NL-07-039 A.2.1.35 25 explicitly specify that the following structures are Domplete A.3.1.35 included in the program. NL-13-122 B.1.36* Appendix R diesel generator foundation (IP3) P3: NL-07-153* Appendix R diesel generator fuel oil tank vault December 12, Audit items (IP3) 2015 86, 87, 88,* Appendix R diesel generator switchgear and NL-08-057 417 enclosure (IP3)* city water storage tank foundation" condensate storage tanks foundation (IP3) NL-13-077* containment access facility and annex (IP3)* discharge canal (IP2/3)" emergency lighting poles and foundations (IP2/3)" fire pumphouse (IP2)* fire protection pumphouse (1P3)* fire water storage tank foundations (IP2/3)* gas turbine 1 fuel storage tank foundation" maintenance and outage building-elevated passageway (IP2)" new station security building (IP2)* nuclear service building (IP1)* primary water storage tank foundation (IP3)* refueling water storage tank foundation (IP3)

NL-14-067 Attachment 2 Page 13 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I_ I _I I/ AUDIT ITEM S 0 0 0 0 0 security access and office building (IP3)service water pipe chase (IP2/3)service water valve pit (IP3)superheater stack transformer/switchyard support structures (IP2)waste holdup tank pits (IP2/3)

Enhance the Structures Monitoring Program for IP2 and IP3 to clarify that in addition to structural steel and concrete, the following commodities (including their anchorages) are inspected for each structure as applicable." cable trays and supports* concrete portion of reactor vessel supports* conduits and supports" cranes, rails and girders* equipment pads and foundations

• fire proofing (pyrocrete)

• HVAC duct supports* jib cranes.* manholes and duct banks* manways, hatches and hatch covers" monorails* new fuel storage racks* sumps Enhance the Structures Monitoring Program for IP2 and IP3 to inspect inaccessible concrete areas that are exposed by excavation for any reason. IP2 and IP3 will also inspect inaccessible concrete areas in environments where observed conditions in accessible areas exposed to the same environment indicate that significant concrete degradation is occurring.Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspections of elastomers (seals, gaskets, seismic joint filler, and roof elastomers) to identify cracking and change in material properties and for inspection of aluminum vents and louvers to identify loss of material.NL-13-077 Enhance the Structures Monitorinq Proqram for IP2 NL-14-067 Attachment 2 Page 14 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I I _I / AUDIT ITEM and IP3 to perform an engineering evaluation of groundwater samples to assess aggressiveness of groundwater to concrete on a periodic basis (at least once every five years). IPEC will obtain samples from at least 5 wells that are representative of the ground water surrounding below-grade site structures and perform an engineering evaluation of the results from those samples for sulfates, pH and chlorides.

Additionally, to assess potential indications of spentfuel pool leakage, IPEC will sample for tritium in groundwater wells in close proximity to the IP2 spentfuel pool at least once every 3 months.Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspection of normally submerged concrete portions of the intake structures at least once every 5 years. Inspect the baffling/grating partition and support platform of the IP3 intake structure at least once every 5 years.Enhance the Structures Monitoring Program for IP2 and IP3 to perform inspection of the degraded areas of the water control structure once per 3 years rather than the normal frequency of once per 5 years during the PEO.Enhance the 'Structures Monitoring Program to include more detailed quantitative acceptance criteria for inspections of concrete structures in accordance with ACl 349.3R, "Evaluation of Existing Nuclear Safety-Related Concrete Structures" prior to the period of extended operation.

NL-08-127 NL-1 1-032 NL-11-101 Audit Item 360 Audit Item 358 26 Implement the Thermal Aging Embrittlement of Cast P2: NL-07-039 A.2.1.36 Austenitic Stainless Steel (CASS) Program for IP2 omplete A.3.1.36 and IP3 as described in LRA Section B.1.37. NL-13-122 B.1.37 aP3: NL-07-153 Audit item This new program will be implemented consistent with ecember 12, 173 the corresponding program described in NUREG- 015 1801,Section XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) Program.

NL-14-067 Attachment 2 Page 15 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 27 Implement the Thermal Aging and Neutron Irradiation P2:

NL-07-039 A.2.1.37 Embrittlement of Cast Austenitic Stainless Steel Domplete A.3.1.37 (CASS) Program for IP2 and IP3 as described in LRA NL-13-122 B.1.38 Section B.1.38. IP3& NL-07-153 Audit item Complete 173 This new program will be implemented consistent with the corresponding program described in NUREG-1801 Section XI.M13, Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program.28 Enhance the Water Chemistry Control -Closed P2: NL-07-039 A.2.1.39 Cooling Water Program to maintain water chemistry of omplete A.3.1 .39 NL-13-122 B.1.40 the IP2 SBO/Appendix R diesel generator cooling -P3:

NL-08-057 Audit item system per EPRI guidelines.

Complete 509 Enhance the Water Chemistry Control -Closed Cooling Water Program to maintain the IP2 and IP3 security generator and fire protection diesel cooling water pH and glycol within limits specified by EPRI guidelines.

29 Enhance the Water Chemistry Control -Primary and P2: NL-07-039 A.2.1.40 Secondary Program for 1P2 to test sulfates monthly in omplete 3-122 1.41 the RWST with a limit of <150 ppb.30 For aging management of the reactor vessel internals, P2: NL-07-039 A.2.1.41 IPEC will (1) participate in the industry programs for omplete A.3.1.41 investigating and managing aging effects on reactor P3: internals; (2) evaluate and implement the results of 3 the industry programs as applicable to the reactor Domplete internals; and (3) upon completion of these programs, but not less than 24 months before entering the period of extended operation, submit an inspection plan for NL-1 1-107 reactor internals to the NRC for review and approval.31 Additional P-T curves will be submitted as required IP2: NL-07-039 A.2.2.1.2 per 10 CFR 50, Appendix G prior to the period of Complete A.3.2.1.2 extended operation as part of the Reactor Vessel PNL-13-122 4.2.3 Surveillance Program. ecember 12, 2015 32 As required by 10 CFR 50.61 (b)(4), IP3 will submit a P3: NL-07-039 A.3.2.1.4 plant-specific safety analysis for plate B2803-3 to the December 12, 4.2.5 NRC three years prior to reaching the RTPTS 2015 NL-08-127 screening criterion. Alternatively, the site may choose to implement the revised PTS rule when approved.

NL-14-067 Attachment 2 Page 16 of 21 COMMITMENT IMPLEMENTATION SOURCE I RELATED SCHEDULE LRA SECTION I/ I I / AUDIT ITEM 33 At least 2 years prior to entering the period of extended operation, for the locations identified in LRATable 4.3-13 (IP2) and LRA Table 4.3-14 (IP3), under the Fatigue Monitoring Program, IP2 and IP3 will implement one or more of the following:(1) Consistent with the Fatigue Monitoring Program, Detection of Aging Effects, update the fatigue usagecalculations using refined fatigue analyses to determine valid CUFs less than 1.0 when accounting for the effects of reactor water environment.

This includes applying the appropriate Fen factors to valid CUFs determined in accordance with one of the following:

1. For locations in LRA Table 4.3-13 (IP2) and LRATable 4.3-14 (IP3), with existing fatigue analysis valid for the period of extended operation, use the existing CUF.2. Additional plant-specific locations with a valid CUF may be evaluated.

In particular, the pressurizer lower shell will be reviewed to ensure the surge nozzle remains the limiting component.

3. Representative CUF values from other plants, adjusted to or enveloping the IPEC plant specific external loads may be used if demonstrated applicable to IPEC.4. An analysis using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case) may be performed to determine a valid CUF.(2) Consistent with the Fatigue Monitoring Program, Corrective Actions, repair or replace the affected locations before exceeding a CUF of 1.0.P2: ,omplete IP3: ,omplete NL-07-039 NL-13-122 NL-07-153 NL-08-021 NL-1 0-082 A.2.2.2.3 A.3.2.2.3 4.3.3Audit item 146 34 1IP2 SBO / Appendix R diesel generator will be NL-13-122 2.1.1.3.5 installed and operationaesel gy erator wi bemplet NL-07-078 committed change to theo facility meets the Complete requirements of 10 CFR 50.59(c)(1) and, therefore, a license amendment pursuant to 10 CFR 50.90 is not NL-1 1-101 1 required.

NL-11-101 NL-14-067 Attachment 2 Page 17 of 21 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM ,P2: NL-08-127 Audit Item35 Perform a one-time inspection of representative

]P2: 27 sample area of IP2 containment liner affected by the omplete 27 1973 event behind the insulaticn, prior to entering the period of extended operation, to assure liner degradation is not occurring in this area. P3: NL-1 1-101 Perform a one-time inspection of representative December 12, sample area of the IP3 containment steel liner at the 2015 juncture with the concrete floor slab, prior to entering the period of extended operation, to assure liner degradation is not occurring in this area.Any degradation will be evaluated for updating of the NL-09-018 I containment liner analyses as needed.36 Perform a one-time inspection and evaluation of a P2: NL-08-127 Audit Item sample of potentially affected IP2 refueling cavity omplete NL-11-101 359 concrete prior to the period of extended operation.

NL-13-122 The sample wi!l be obtained by core boring the refueling cavity wall in an area that is susceptible to exposure to borated water leakage. The inspection will include an assessment of embedded reinforcing steel.Additional core bore samples will be taken, if the NL-09-056 leakage is not stopped, prior to the end of the first ten years of the period of extended operation.

A sample of leakage fluid will be analyzed to NL-09-079determine the composition of the fluid. If additional core samples are taken prior to the end of the first ten years of the period of extended operation, a sample of leakage fluid will be analyzed.37 -.. P2: NL-08-127 Audit Item 37 Enhance the Containment Inservice Inspection (CII- mPee 36 IWL) Program to include inspections of the omplete 361 containment using enhanced characterization of NP3: degradation (i.e., quantifying the dimensions of noted P3: indications through the use of optical aids) during the omplete period of extended operation.

The enhancementincludes obtaining critical dimensional data of degradation where possible through direct measurement or the use of scaling technologies for photographs, and the use of consistent vantage points for visual inspections.

NL-14-067 Attachment 2 Page 18 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 38 For Reactor Vessel Fluence, should future core P2: NL-08-143 4.2.1 loading patterns invalidate the basis for the projected omplete NL-13-122 values of RTpts or CvUSE, updated calculations will P3-be provided to the NRC. ecember 12, 2015 39 Deleted NL-09-079 40 Evaluate plant specific and appropriate industry P2: NL-09-106 B.1.6 operating experience and incorporate lessons learned omplete B.1.22 opeatngNL-13-122 B.1.23 in establishing appropriate monitoring and inspection NP3: B.1.24 frequencies to assess aging effects for the new aging ecember 12, B.1.25 management programs.

Documentation of the 2015 B.1.25 operating experience evaluated for each new program 015 B.1.27 will be available on site for NRC review prior to the B.1.28 period of extended operation.

B.1.33 B.1.37 B.1.38 41 IPEC will inspect steam generators for both units to P2: NL-1 1-032 N/A assess the condition of the divider plate assembly.

fter the The examination technique used will be capable of )eginning of the detecting PWSCC in the steam generator divider plate PEO and prior to assembly.

The IP2 steam generator divider plate September 28, inspections will be completed within the first ten years 023 NL-1 1-074 of the period of extended operation (PEO). The IP3 P3 NL-1 1-090steam generator divider plate inspections will be completed within the first refueling outage following for to the end the beginning of the PEO. f the first NL-1 1-101 oefueling outage ollowing the Eginning of the NL- 14-067 Attachment 2 Page 19 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION_I _ _ I AUDIT ITEM 42 IPEC will develop a plan for each unit to address the potential for cracking of the primary to secondary pressure boundary due to PWSCC of tube-to-tubesheet welds using one of the following two options.Option 1 (Analysis)

IPEC will perform an analytical evaluation of thesteam generator tube-to-tubesheet welds in order to establish a technical basis for either determining that the tubesheet cladding and welds are not susceptible to PWSCC, or redefining the pressure boundary in which the tube-to-tubesheet weld is no longer included and, therefore, is not required for reactor coolant pressure boundary function.

The redefinition of the reactor coolant pressure boundary must be approved by the NRC as a license amendment request.Option 2 (Inspection)

IPEC will perform a one-time inspection of a representative number of tube-to-tubesheet welds in each steam generator to determine if PWSCC cracking is present. If weld cracking is identified:

a. The condition will be resolved through repair or engineering evaluation to justify continued service, as appropriate, andb. An ongoing monitoring program will be established to perform routine tube-to-tubesheet weld inspections for the remaining life of the steam generators.

1P2: Prior to March R024 IP3: Prior to the end of the first refueling outage following the beginning of the PEO.I P2: Between March 2020 and March 2024 IP3: Prior to the end of the first refueling outage following the beginning of the PEO.NL-1 1-032 NL-1 1-074 NL-1 1-090 NL-11-096 N/A 43 IPEC will review design basis ASME Code Class 1 fatigue evaluations to determine whether the NUREG/CR-6260 locations that have been evaluated for the effects of the reactor coolant environment on fatigue usage are the limiting locations ior the IP2 and IP3 configurations.

If more limiting locations are identified, the most limiting location will be evaluated for the effects of the reactor coolant environment on fatigue usage.IPEC will use the NUREG/CR-6909 methodology in the evaluation of the limiting locations consisting of nickel alloy, if any.I P2: ,ompleteP3: Prior to December 12, 2015 NL-1 1-032 NL-13-122 NL-1 1-101 4.3.3 NL-14-067 Attachment 2 Page 20 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION/ AUDIT ITEM 44 IPEC will include written explanation and justification P2: NL-11-032 N/A of any user intervention in future evaluations using the omplete NL-1 1-101 WESTEMS "Design CUP' module. P3: Prior to NL-13-122 December 12, R015 45 IPEC will not use the NB-3600 option of the P2: NL-1 1-032 N/A WESTEMS program in future design calculations until omplete NL-1 1-101 the issues identified during the NRC review of the P3: Prior to NL-13-122 program have been resolved.

ecember 12, 015 46 Include in the IP2 ISI Program that IPEC will perform P2: NL- 1-032 N/A twenty-five volumetric weld metal inspections of Complete socket welds during each 10-year ISI interval NL-11-074 scheduled as specified by IWB-2412 of the ASME NL-13-122 Section Xl Code during the period of extended operation.

In lieu of volumetric examinations, destructive examinations may be performed, where one destructive examination may be substituted for two volumetric examinations.

47 IPE- will and submit analysos that I O89 N/A domenontrato that the loWorF 61Appo0 column bedic il mnaintain thoir funcitionality during tho poriod Ugus 16' N=o)dended oporation concid8Fr@n tho pocciblo less of P.PmFW N=1 2 fracturo teughnocc duo to thormnal and fiReadat~e ee~e -L1-6 ombrittlmont.

Tho analycoc, will be concicton~t with 2L-4-06 the 1P2X'1P3 liconcing baic Deleted.

NL-14-067 Attachment 2 Page 21 of 21# COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM 48 Entergy will visually inspect IPEC underground piping P2: NL-12-174 N/A within the scope of license renewal and subject to Complete aging management review prior to the period of P3: Prior to NL-13-122 extended operation and then on a frequency of at ecember 12, least once every two years during the period of extended operation.

This inspection frequency will be maintained unless the piping is subsequently coated in accordance with the preventive actions specified in NUREG-1801 Section XI.M41 as modified by LR-ISG-2011-03. Visual inspections will be supplemented with surface or volumetric non-destructive testing if indications of significant loss of material are observed.

Consistent with revised NUREG-1801 Section XI.M41, such adverse indications will be entered into the plant corrective action program for evaluation of extent of condition and for determination of appropriate corrective actions (e.g., increased inspection frequency, repair, replacement).

49 Recalculate each of the limiting CUFs provided in IP2: NL-13-052 A.2.2.2 section 4.3 of the LRA for the reactor vessel internals Complete A.3.2.2 to include the reactor coolant environment effects P3: Prior to NL-13-122 (Fen) as provided in the IPEC Fatigue Monitoring ecember 12, Program using NUREG/CR-5704 or NUREG/CR-2015 6909. In accordance with the corrective actions specified in the Fatigue Monitoring Program, corrective actions include further CUF re-analysis, and/or repair or replacement of the affected components prior to the CUFen reaching 1.0.50 if the planned , rop a...,nt of tho , 122 split pips P2: NL-13-122 A.2.1.41 will not be a,. ompli.ehd in 2016, provfido the oO" W MaF B.1.42 NRCG taff a

....; .p.tn plan for the. 22 1, 20:1 NL-14-067.pl...pine, including insepotion mothods, S..ep.tiGn c....ag, and in..p..tion-fr.quonc.y, norior to by MaF,,1-, ,2046- Replace the IP2 split pins Completion of during the 2016 refuelinq outaae (2R22). 2R22 P3: N/A