ML14330A324

Update to the PWR Vessel Internals Program

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

Text

NExTera EN ERGY Qý November 21, 2014 10 CFR 54 SBK-L- 14212 Docket No. 50-443 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Seabrook Station Update to the PWR Vessel Internals Program

References:

1. NextEra Energy Seabrook, LLC letter SBK-L- 10077, "Seabrook Station Application for Renewed Operating License," May 25, 2010. (Accession Number ML101590099)

2. NextEra Energy Seabrook, LLC letter SBK-L-14089, "Response to Request for Additional Information Related to the Review of The Seabrook Station License Renewal Application- Set 21 (Tag No. ME4028)," June 24, 2014 (Accession Number ML14177A502)

3. NextEra Energy Seabrook, LLC letter SBK-L-14173, " Fourth Annual Update to the NextEra Energy Seabrook License Renewal Application," October 2, 2014 (Accession Number ML14282A023)

In Reference 1, NextEra Energy Seabrook, LLC submitted an application for a renewed facility operating license for Seabrook Station Unit 1 in accordance with the Code of Federal Regulations, Title 10, Parts 50, 51, and 54.

In Reference 2, NextEra Energy Seabrook, LLC submitted a revised PWR Vessel Internals program in accordance with the guidance provided in LR-ISG-2011-04, "Updated Aging Management Criteria for Reactor Vessel Internal Components for Pressurized Water Reactors."

In Reference 3, NextEra Energy Seabrook, LLC provided a due date of November 30, 2014 for submitting a schedule related to the confirmation and acceptability of the implementation of MRP-227-A by addressing the plant-specific Applicant/Licensee Action Items outlined in section 4.2 of the NRC SER.

,Au4-

U.S. Nuclear Regulatory Commission SBK-L-14212/Page 2 provides the schedule for the completion of these Applicant/Licensee Action Items. provides the revised LRA Appendix A - Updated Final Safety Analysis Report Supplement Table A.3, License Renewal Commitment List. Commitment # 1 has been revised as a result of this Supplement.

Provided in this Supplement are changes to the LRA. To facilitate understanding, the changes are explained, and where appropriate, portions of the LRA are repeated with the change highlighted by strikethroughs for deleted text and bolded italics for inserted text.

If there are any questions or additional information is needed, please contact Mr. Edward J.

Carley, Engineering Supervisor - License Renewal, at (603) 773-7957.

If you have any questions regarding this correspondence, please contact Mr. Michael H. Ossing Licensing Manager, at (603) 773-7512.

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

Executed on November,__ 2014.

Sincerely, NextEra Energy Seabrook, LLC Dean Curtland Site Vice President

Enclosures:

- Update to the PWR Vessel Internals Program - LRA Appendix A - Final Safety Analysis Report Supplement Table A.3, License Renewal Commitment List Updated to Reflect Changes to Date cc: W. M. Dean NRC Region I Administrator J. G. Lamb NRC Project Manager P. C. Cataldo NRC Senior Resident Inspector R. A. Plasse NRC Project Manager, License Renewal L. M. James NRC Project Manager, License Renewal Mr. Perry Plummer Director Homeland Security and Emergency Management New Hampshire Department of Safety Division of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen Drive Concord, NH 03305 Mr. John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399

Enclosure 1 to SBK-L-14212 Update to the PWR Vessel Internals Program

U.S. Nuclear Regulatory Commission SBK-L-14212/Enclosure 1/Page 2 Update to the PWR Vessel Internals Program By letter SBK-L-14089 (Reference 2), NextEra Energy Seabrook submitted a revised PWR Vessel Internals program in accordance with the guidance provided in LR-ISG-2011-04, "Updated Aging Management Criteria for Reactor Vessel Internal Components for Pressurized Water Reactors."

By letter SBK-L-14173 (Reference 3), NextEra Energy provided a due date of November 30, 2014 for submitting a schedule related to the confirmation and acceptability of the implementation of MRP-227-A by addressing the plant-specific Applicant/Licensee Action Items outlined in section 4.2 of the NRC SER (Commitment #1).

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

PROGRAM or UFSAR No. COMMITMENT SCHEDULE TOPIC LOCATION the SeabrookE iel prgy i.e Provide confirmation and acceptability of schedule a zubmtwia PWR Vessel implementation of MRP-227-A by addressing ue Action A.2.1.7 a s ,t ....

Internals the plant-specific Applicant/Licensee Items outlined in section 4.2 of the NRC byNvm-4,.

SER.

May 31, 2015

Enclosure 2 to SBK-L-14212 LRA Appendix A - Final Safety Analysis Report Supplement Table A.3, License Renewal Commitment List Updated to Reflect Changes to Date

U.S. Nuclear Regulatory Commission SBK-L-14212/Enclosure 2/Page 2 A.3 LICENSE RENEWAL COMMITMENT LIST UFSAR PROGRAM or TOPIC COMMITMENT SCHEDULE LOCATION

,NextEra Energy Seabroek -will Provide confirmation and acceptability of the implementation of xa Enbmitt lseelk

..... biyl PWR Vessel Internals MRP-227-A by addressing the plant-specific Applicant/Licensee A.2.1.7 November 30, 201* .

Action Items outlined in section 4.2 of the NRC SER.

May 31, 2015 Closed-Cycle Cooling Enhance the program to include visual inspection for cracking, loss Prior to the period of extended Water of material and fouling when the in-scope systems are opened for A.2.1.12 operation.

maintenance.

Inspection of Overhead Heavy Load and Light Enhance the program to monitor general corrosion on the crane and Load (Related to trolley structural components and the effects of wear on the rails in A.2.1.13 prratote Refueling) Handling the rail system. operation.

Systems Inspection of Overhead Heavy Load and Light Prior to the period of extended Load (Related to Enhance the program to list additional cranes for monitoring. A.2.1.13 operation.

Refueling) Handling Systems Compressed Air Enhance the program to include an annual air quality test requirement A.2.1.14 Prior to the period of extended Monitoring for the Diesel Generator compressed air sub system. operation.

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

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

reaction with aggregates by qualified inspector.

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

Enhance the program to include NFPA 25 (2011 Edition) guidance for "where sprinklers have been in place for 50 years, they shall be Prior to the period of extended

9. Fire Water System replaced or representative samples from one or more sample areas A.2.1.16 operation.

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

Enhance the program to include the performance of periodic flow Prior to the period of extended

10. Fire Water System testing of the fire water system in accordance with the guidance of A.2.1.16 operation.

NFPA 25 (2011 Edition).

Enhance the program to include the performance of periodic visual or volumetric inspection of the internal surface of the fire protection system upon each entry to the system for routine or corrective maintenance to evaluate wall thickness and inner diameter of the fire protection piping ensuring that corrosion product buildup will not result in flow blockage due to fouling. Where surface irregularities II. Fire Water System are detected, follow-up volumetric examinations are performed. A.2116 Within ten years prior to the These inspections will be documented and trended to determine if a period of extended operation.

representative number of inspections have been performed prior to the period of extended operation. If a representative number of inspections have not been performed prior to the period of extended operation, focused inspections will be conducted. These inspections will be performed within ten years prior to the period of extended operation.

Enhance the program to include components and aging effects Aboveground Steel required by the Aboveground Steel Tanks and to perform visual, Within 10 years prior to the

12. Tanks surface, and volumetric examinations of the outside and inside A.2.1.17 period of extended operation.

surfaces for managing the aging effects of loss of material and cracking.

U.S. Nuclear Regulatory Commission SBK-L- 14212/Enclosure 2/Page 4 Enhance the program to perform exterior inspection of the fire water storage tanks annually for signs of degradation and include an Within ten years prior to the

13. Fire Water System ultrasonic inspection and evaluation of the internal bottom surface of A.2.1.16 period of extended operation.

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

Enhance program to add requirements to 1) sample and analyze new fuel deliveries for biodiesel prior to offloading to the Auxiliary Boiler Prior to the period of extended

14. Fuel Oil Chemistry fuel oil storage tank and 2) periodically sample stored fuel in the A.2.1.18 operation.

Auxiliary Boiler fuel oil storage tank.

Enhance the program to add requirements to check for the presence Prior to the period of extended

15. Fuel Oil Chemistry of water in the Auxiliary Boiler fuel oil storage tank at least once per A.2.1.18 operation.

quarter and to remove water as necessary.

Enhance the program to require draining, cleaning and inspection of Prior to the period of extended

16. Fuel Oil Chemistry the diesel fire pump fuel oil day tanks on a frequency of at least once A.2.1.18 operation.

every ten years.

Enhance the program to require ultrasonic thickness measurement of the tank bottom during the I0-year draining, cleaning and inspection Prior to the period of extended

17. Fuel Oil Chemistry of the Diesel Generator fuel oil storage tanks, Diesel Generator fuel A.2.1.18 operation.

oil day tanks, diesel fire pump fuel oil day tanks and auxiliary boiler fuel oil storage tank.

Reactor Vessel Enhance the program to specify that all pulled and tested capsules, A.2.1.19 Prior to the period of extended

18. Surveillance unless discarded before August 31, 2000, are placed in storage. operation.

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

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

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

U.S. Nuclear Regulatory Commission SBK-L-14212/Enclosure 2/Page 5 Enhance the program as necessary to ensure the appropriate withdrawal schedule for capsules remaining in the vessel such that one capsule will be withdrawn at an outage in which the capsule Reactor Vessel receives a neutron fluence that meets the schedule requirements of 10 A.2.1.19 Prior to the period of extended

20. Surveillance CFR 50 Appendix H and ASTM E185-82 and that bounds the operation.

60-year fluence, and the remaining capsule(s) will be removed from the vessel unless determined to provide meaningful metallurgical data.

Enhance the program to ensure that any capsule removed, without the Reactor Vessel intent to test it, is stored in a manner which maintains it in a condition A.2.1.19 Prior to the period of extended

21. Surveillance which would permit its future use, including during the period of operation.

extended operation.

Within ten years prior to the

22. One-Time Inspection Implement the One Time Inspection Program. A.2.1.20 period of extended operation.

Implement the Selective Leaching of Materials Program. The Selective Leachingy of program will include a one-time inspection of selected components Within five years prior to the

23. where selective leaching has not been identified and periodic A.2.1.21 period of extended operation.

inspections of selected components where selective leaching has been identified.

Within ten years prior to Buried Piping And Implement the Buried Piping And Tanks Inspection Program.

24. Tanks Inspection A.2. 1.22 entering the period of extended operation tion Implement the One-Time Inspection of ASME Code Class I Small Within ten years prior to the

25. of ASME Code Class 1 ipl nt teoneTme A.2.1.23 period of extended operation.

Small Bore-Piping Bore-Piping Program.p Enhance the program to specifically address the scope of the External Surfaces program, relevant degradation mechanisms and effects of interest, the Prior to the period of extended

26. Monitoring refueling outage inspection frequency, the training requirements for A.2.1.24 operation.

inspectors, and the required periodic reviews to determine program effectiveness.

U.S. Nuclear Regulatory Commission SBK-L- I 4212/Enclo sure 2/Page 6 Inspection of Internal Surfaces in Implement the Inspection of Internal Surfaces in Miscellaneous Prior to the period of extended

27. Miscellaneous Piping Piping and Ducting Components Program. A.2.1.25 operation.

and Ducting Components A.2.1.26 Prior to the period of extended

28. Lubricating Oil Enhance the program to add required equipment, lube oil analysis operation.

Analysis required, sampling frequency, and periodic oil changes.

pump A.2.1.26 Prior to the period of extended

29. Lubricating Oil Enhance the program to sample the oil for the Reactor Coolant operation.

Analysis oil collection tanks.

Enhance the program to require the performance of a one-time the Reactor A.2.1.26 Prior to the period of extended

30. Lubricating Oil ultrasonic thickness measurement of the lower portion ofextended operation.

Analysis Coolant pump oil collection tanks prior to the period of operation.

A.2.1.28 Prior to the period of extended

31. ASME Section XI, Enhance procedure to include the definition of "Responsible operation.

Subsection IWL Engineer".

A.2.1.31 Prior to the period of extended

32. Structures Monitoring Enhance procedure to add the aging effects, additional locations, operation.

Program inspection frequency and ultrasonic test requirements.

A.2.1.31 Prior to the period of extended

33. Structures Monitoring Enhance procedure to include inspection of opportunity when operation.

Program planning excavation work that would expose inaccessible concrete.

U.S. Nuclear Regulatory Commission SBK-L- 14212/Enclosure 2/Page 7 Electrical Cables and Connections Not Subject to 10 CFR Implement the Electrical Cables and Connections Not Subject to 10 Prior to the period of extended

34. 50.49 Environmental CFR 50.49 Environmental Qualification Requirements program. operation.

Qualification Requirements Electrical Cables and Connections Not Subject to 10 CFR Implement the Electrical Cables and Connections Not Subject to 10

35. 50.49 Environmental CFR 50.49 Environmental Qualification Requirements Used in Prior to the period of extended Requirements Used in Instrumentation Circuits program. operation.

Instrumentation Circuits Inaccessible Power Cables Not Subject to 10 CFR 50.49 Implement the Inaccessible Power Cables Not Subject to 10 CFR Prior to the period of extended

36. Environmental 50.49 Environmental Qualification Requirements program. operation.

Qualification Requirements

37. Metal Enclosed Bus Implement the Metal Enclosed Bus program. ,eration.

38. Fuse Holders Implement the Fuse Holders program. on.

U.S. Nuclear Regulatory Commission SBK-L- 14212/Enclosure 2/Page 8 Electrical Cable Connections Not Subject to 10 CFR Implement the Electrical Cable Connections Not Subject to 10 CFR Prior to the period of extended 50.49 Environmental 50.49 Environmental Qualification Requirements program. A.2.1.37 operation.

Qualification Requirements Prior to the period of extended

40. 345 KV SF6 Bus Implement the 345 KV SF6 Bus program. A.2.2.1 operation.

Metal Fatigue of Prior to the period of extended

41. Reactor Coolant Enhance the program to include additional transients beyond those A.2.3.1Poraton.

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

Pressure Boundary Metal Fatigue of Enhance the program to implement a software program, to count Prior to the period of extended

42. Reactor Coolant transients to monitor cumulative usage on selected components. A.2.3.1 operation.

Pressure Boundary Pressure -Temperature The updated analyses will be Limits, including Low Seabrook Station will submit updates to the P-T curves and LTOP submitted at the appropriate time

43. Temperature limits to the NRC at the appropriate time to comply with 10 CFR 50 A.2.4.1.4 to comply with 10 CFR 50 Overpressure Appendix G. Appendix G, Fracture Protection Limits Toughness Requirements.

U.S. Nuclear Regulatory Commission SBK-L- 14212/Enclosure 2/Page 9 NextEra Seabrook will perform a review of design basis ASME Class 1 component fatigue evaluations to determine whether the NUREG/CR-6260-based components that have been evaluated foi the effects of the reactor coolant environment on fatigue usage are the limiting components for the Seabrook plant configuration. If more limiting components are identified, the most limiting component will be evaluated for the effects of the reactor coolant environment on fatigue usage. If the limiting location identified consists of nickel alloy, the environmentally-assisted fatigue calculation for nickel alloy will be performed using the rules of NUREG/CR-6909.

(1) Consistent with the Metal Fatigue of Reactor Coolant Pressure Boundary Program Seabrook Station will update the fatigue usage calculations using refined fatigue analyses, if necessary, to determine acceptable CUFs (i.e., less than 1.0) when accounting for the effects Environmentally- of the reactor water environment. This includes applying the At least two years prior to

44. Assisted Fatigue appropriate Fen factors to valid CUFs determined from an existing A.2.4.2.3 entering the period of extended Analyses (TLAA) fatigue analysis valid for the period of extended operation or from an operation.

analysis using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case).

(2) If acceptable CUFs cannot be demonstrated for all the selected locations, then additional plant-specific locations will be evaluated.

For the additional plant-specific locations, if CUF, including environmental effects is greater than 1.0, then Corrective Actions will be initiated, in accordance with the Metal Fatigue of Reactor Coolant Pressure Boundary Program, B.2.3. 1. Corrective Actions will include inspection, repair, or replacement of the affected locations before exceeding a CUF of 1.0 or the effects of fatigue will be managed by an inspection program that has been reviewed and approved by the NRC (e.g., periodic non-destructive examination of the affected locations at inspection intervals to be determined by a method accepted by the NRC).

U.S. Nuclear Regulatory Commission SBK-L-14212/Enclosure 2/Page 10

45. Number Not Used Protective Coating Enhance the program by designating and qualifying an Inspector Prior to the period of extended

46. Monitoring and Coordinator and an Inspection Results Evaluator. operation.

Maintenance Enhance the program by including, "Instruments and Equipment Protective Coating needed for inspection may include, but not be limited to, flashlight, Prior to the period of extended

47. Monitoring and spotlights, marker pen, mirror, measuring tape, magnifier, binoculars, A.2.1.38 prratote Maintenance camera with or without wide angle lens, and self sealing polyethylene sample bags."

Protective Coating Enhance the program to include a review of the previous two Prior to the period of extended

48. Monitoring and monitoring reports. A.2.1.38 operation.

Maintenance be Protective Coating Enhance the program to require that the inspection report is to A.2.1.38 Prior to the period of extended

49. Monitoring and evaluated by the responsible evaluation personnel, who is to prepare operation.

Maintenance a summary of findings and recommendations for future surveillance or repair.

Baseline inspections were Perform UT of the accessible areas of the containment liner plate in completedoduring TOR16. Repeat ASME Section X efr To heacsil raso h otimetlnrpaei containment liner UT thickness

50. Subsection oIWE the vicinity of the moisture barrier for loss of material. Perform A.2.1.27 examinations at intervals of no opportunistic UT of inaccessible areas.

more than five (5) refueling outages.

51. Number Not Used ASME Section XI, Implement measures to maintain the exterior surface of the

52. AS section I, Containment Structure, from elevation -30 feet to +20 feet, in a A.2.1.28 Ongoing dewatered state.

Reactor Head Closure Replace the spare reactor head closure stud(s) manufactured from the Prior to the period of extended

53. Studs bar that has a yield strength > 150 ksi with ones that do not exceed A.2.1.3 operation.

150 ksi.

U.S. Nuclear Regulatory Commission SBK-L- 14212/Enclosure 2/Page 11 NextEra will 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:

1) Perform a one-time inspection of a representative sample of tube-to-tubesheet welds in all steam generators to determine if PWSCC cracking is present and, if cracking is identified, resolve the condition through engineering evaluation justifying continued operation or repair the condition, as appropriate, and establish an ongoing monitoring program to perform routine tube-to-tubesheet weld Steam Generator Tube Complete

54. inspections for the remaining life of the steam generators, or A.2.1.10 Integrity

2) Perform an analytical evaluation showing that the structural integrity of the steam generator tube-to-tubesheet interface is adequately maintaining the pressure boundary in the presence of tube-to-tubesheet weld cracking, 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 part of a license amendment request.

Within five years prior to Wetein the priod o Steam Generator Tube Seabrook will perform an inspection of each steam generator to

55. Integrity assess the condition of the divider plate assembly. operation.

Closed-Cycle Cooling Revise the station program documents to reflect the EPRI Guideline A.2.1.12 Prior to entering the period of

56. Water System operating ranges and Action Level values for hydrazine and sulfates. extended operation.

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

Cooling Water Jacket pH.

Update Technical Requirement Program 5.1, (Diesel Fuel Oil Testing Prior to the period of extended

58. Fuel Oil Chemistry Program) ASTM standards to ASTM D2709-96 and ASTM D4057- A.2.1.18 operation.

95 required by the GALL XI.M30 Rev I

U.S. Nuclear Regulatory Commission SBK-L-14212/Enclosure 2/Page 12 Nozzles The Nickel Alloy Aging Nozzles and Penetrations program will Prior to the period of extended anickenel Alloy Nickel

59. rations implement applicable Bulletins, Generic Letters, and staff accepted A.2.2.3 prratote and Penetrations

59. industry guidelines, operation.

Buried Piping and Implement the design change replacing the buried Auxiliary Boiler Prior to entering the period of

60. Tanks Inspection supply piping with a pipe-within-pipe configuration with leak A.2.1.22 extended operation.

detection capability.

Within ten years prior to Compressed Air Replace the flexible hoses associated with the Diesel Generator air

61. Monitoring Program compressors on a frequency of every 10 years. A.2.1.14 entering the period of extended operation.

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

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

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

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

Soil analysis shall be performed prior to entering the period of extended operation to determine the corrosivity of the soil in the vicinity of non-cathodically protected steel pipe within the scope of Prior to entering the period of

64. Buried Piping and this program. If the initial analysis shows the soil to be non- A.2.1.22 extended operation.

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

65. Flux Thimble Tube Implement measures to ensure that the movable incore detectors are Prior to entering the period of not returned to service during the period of extended operation. N/A extended operation.

66. Number Not Used

U.S. Nuclear Regulatory Commission SBK-L-14212/Enclosure 2/Page 13 Perform one shallow core bore in an area that was continuously wetted from borated water to be examined for concrete degradation Structures Monitoring and also expose rebar to detect any degradation such as loss of No later than December 31,

67. Program material. The removed core will also be subjected to petrographic A.2.1.31 2015.

examination for concrete degradation due to ASR per ASTM Standard Practice C856.

Quarterly Preventive Structures Monitoring Perform sampling at the leakoff collection points for chlorides,

68. Program sulfates, pH and iron once every three months. A.2.1.31 Maintenance Activity Implemented PVC lined 2 Arior-Open-Cycle Cooling Replace the Diesel Generator Heat Exchanger Plastisol ev .

Service Water piping with piping fabricated from AL6XN material. A.2.1.11

69. Water System Complete Inspect the piping downstream of CC-V-444 and CC-V-446 to Closed-Cycle Cooling determine whether the loss of material due to cavitation induced Within ten years prior to the

70. Water System erosion has been eliminated or whether this remains an issue in the A.2.1.12 period of extended operation.

primary component cooling water system.

Alkali-Silica Reaction Implement the Alkali-Silica Reaction (ASR) Monitoring Program.

71. (ASR) Monitoring Testing will be performed to confirm that parameters being A.2.1.31A Prior to entering the period of 7ro ntrg monitored and acceptance criteria used are appropriate to manage the extended operation.

Program effects of ASR.

Flow-Accelerated Enhance the program to include management of wall thinning caused Prior to entering the period of

72. Corrosion by mechanisms other than FAC. A.2.1.8 extended operation.

Inspection of Internal Enhance the program to include performance of focused Surfaces in examinations to provide a representative sample of 20%, or a

73. Miscellaneous Piping maximum of 25, of each identified material, environment, and aging A.2.1.25 Prior'to entering the period of and Ducting effect combinations during each 10 year period in the period of extended operation.

Components extended operation.

Is U.S. Nuclear Regulatory Commission SBK-L-14212/Enclosure 2/Page 14 Enhance the program to perform sprinkler inspections annually per the guidance provided in NFPA 25 (2011 Edition). Inspection will ensure that sprinklers are free of corrosion, foreign materials, paint,

74. Fire Water System and physical damage and installed in the proper orientation (e.g., A.2.1.16 Within ten years prior to the upright, pendant, or sidewall). Any sprinkler that is painted, corroded, period of extended operation.

damaged, loaded, or in the improper orientation, and any glass bulb sprinkler where the bulb has emptied, will be evaluated for replacement.

Enhance the program to conduct an inspection of piping and branch line conditions every 5 years by opening a flushing connection at the end of one main and by removing a sprinkler toward the end of one Within ten years prior to the

75. Fire Water System branch line for the purpose of inspecting for the presence of foreign A.2.1.16 period of extended operation.

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

Enhance the Program to conduct the following activities annually per the guidance provided in NFPA 25 (2011 Edition). Within ten years prior to the

76. Fire Water System

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

• deluge valve trip tests

• fire water storage tank exterior surface inspections The Fire Water System Program will be enhanced to include the following requirements related to the main drain testing per the guidance provided in NFPA 25 (2011 Edition).

77. Fire Water System

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

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

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

U.S. Nuclear Regulatory Commission SBK-L- 14212/Enclosure 2/Page 15

78. External Surfaces Enhance the program to include periodic inspections of in-scope A.2.1.8 Prior to the period of extended Monitoring insulated components for possible corrosion under insulation. operation.

Enhance the program to include visual inspection of Service Level III

79. Open-Cycle Cooling (augmented) internal coatings for loss of coating integrity. A.2.1.11 Within 10 years prior to the Water System (umne)period of extended operation.

Enhance the program to include visual inspection of Service Level III

80. Fire Water System (augmented) internal coatings for loss of coating integrity. A.2.1.16 Within 10 years prior to the period of extended operation.

Enhance the program to include visual inspection of Service Level III

81. Fuel Oil Chemistry (augmented) internal coatings for loss of coating integrity. A.2.1.18 Within 10 yearsdprioretotthe

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

Inspection of Internal Surfaces in Enhance the program to include visual inspection of Service Level III

82. 82iclan Miscellaneous Piping (augmented) internal coatings for loss of coating integrity. A.2.1.25 Within of10extended period yearsdprioretotthe operation.

eoDuscPipin and Ducting Components Install instrumentation in representative sample areas of structures to monitor expansion due to alkali-silica reaction in the out-of-plane direction. Evaluate instrument and pin expansion data under the Operating Experience Element of the Alkali-Silica Reaction

83. Alkali-Silica Reaction Monitoring Program to determine whether there is a need to enhance A.2.1.31A Prior to the period of extended Monitoring the program to monitor expansion in the out-of-plane direction. If the operation.

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

A ý I U.S. Nuclear Regulatory Commission SBK-L-14212/Enclosure 2/Page 16

84. ASME Section XI, Evaluate the acceptability of inaccessible areas for structures within A.2.1.28 Prior to the period of extended Subsection IWL the scope of ASME Section XI, Subsection IWL Program. operation.