NL-13-077, License Renewal Application-Update to Electrical Meb and Structures Monitoring Program Scope, Aging Management Programs

License Renewal Application-Update to Electrical Meb and Structures Monitoring Program Scope, Aging Management Programs

ML13142A013
Person / Time
Site:	Indian Point
Issue date:	05/06/2013
From:	Dacimo F Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-13-077
Download: ML13142A013 (36)

Text

Enter-qy Nuclear Northeast Indian Point Energy Center Entergy 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 254-2055 Fred Dacimo Vice President Operations License Renewal NL-13-077 May 6, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

License Renewal Application-Update to Electrical MEB and Structures Monitoring Program Scope Aging Management Programs Indian Point Nuclear Generating Unit Nos. 2 & 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64 REFERENCE 1. Entergy Letter dated April 23, 2007, F. R. Dacimo to Document Control Desk, "License Renewal Application" (NL-07-039)

Dear Sir or Madam:

In the referenced letter, Entergy Nuclear Operations, Inc. applied for renewal of the operating licenses for Indian Point Nuclear Generating Units 2 and 3. This letter describes an update to the License Renewal Application (LRA) regarding the Metal-Enclosed Bus (MEB) Inspection and Structures Monitoring Programs and the associated regulatory commitments. provides the MEB Inspection Program changes to LRA Sections A.2.1.19 and B.1.20. Attachment 2 provides the Structures Monitoring Program changes to LRA Sections A.2.1.35, A.3.1.35, and B.1.36. Attachment 3 provides the listing of regulatory commitments for license renewal including the revision to the associated regulatory commitments.

Docket Nos. 50-247 & 50-286 NL-13-077 Page 2 of 2 If you have any questions, or require additional information, please contact Mr. Robert Walpole at 914-734-6710.

I declare under penalty of perjury that the foregoing is true and correct. Executed on May 6, 2013.

Sincerely, FRD/ai

Attachment:

1. License Renewal Application Updated Information for MEB Inspection Program

2. License Renewal Application Updated Information for Structures Monitoring Program

3. IPEC List of Regulatory Commitments (Rev. 20) cc: Mr. William Dean, Regional Administrator, NRC Region I Mr. David Wrona, NRC Branch Chief, Division of License Renewal Ms. Lois James, NRC Environmental Project Manager, IPEC License Renewal Mr. Nathaniel Ferrer, NRC Project Manager, Division of License Renewal Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel NRC Resident Inspectors Office, Indian Point Ms. Bridget Frymire, New York State Department of Public Service Mr. Francis J. Murray, Jr., President and CEO, NYSERDA

ATTACHMENT I TO NL-13-077 LICENSE RENEWAL APPLICATION UPDATED INFORMATION FOR MEB INSPECTION PROGRAM ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286

Docket Nos. 50-247 and 50-286 NL-13-077 Attachment 1 Page 1 of 5 INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION UPDATED INFORMATION FOR MEB INSPECTION PROGRAM

Background

The Metal-Enclosed Bus Inspection Program is described in the License Renewal Application (LRA) in Section B.1.20 and includes an enhancement to revise appropriate procedures to add the 480V bus associated with substation A to the scope of bus inspected. This was also reflected in the LRA UFSAR Section A.2.1.19. This bus was considered within the scope of license renewal for 10 CFR 54.4(a)(3), because it provides AC power to the IP2 Diesel Fire Pump (DFP). However, based on a recent evaluation, the 480V bus is not used for starting the DFP. The AC power is used to maintain the control system's dual batteries in a charged state, which in turn provide the DC power for starting the DFP and the power for instrumentation. Any loss of the 480V bus associated with Substation A would initiate an automatic start of the DFP via the batteries.

Therefore, the 480VAC bus associated with Substation A does not perform a license renewal intended function based on 10 CFR 54.4, so the enhancement to the Metal-Enclosed Bus Inspection Program to include the 480V bus associated with Substation A is no longer necessary. The following changes reflect this conclusion.

Identification of Changes Changes are shown as strikethroughs for deletions and underlines for additions.

LRA UFSAR Changes A.2.1.19 Metal-Enclosed Bus Inspection Program The Metal-Enclosed Bus Inspection Program is an existing program that performs inspections on the following non-segregated phase bus.

• 6.9kV bus between station aux transformers and switchgear buses 1/2/3/4/5/6

• 480V bus a..ociated with substatin A

• 480V bus between emergency diesel generators and switchgear buses 2A/3A/5A16A Inspections of the metal enclosed bus (MEB) include the bus and bus connections, the bus enclosure assemblies, and the bus insulation and insulators. A sample of the accessible bolted connections will be inspected for loose connections. The bus enclosure assemblies will be inspected for loss of material and elastomer degradation. This program will be used instead of the Structures Monitoring Program for external surfaces of the bus enclosure assemblies. The internal portions of the MEB will be inspected for foreign debris, excessive dust buildup, and evidence of moisture intrusion. The bus insulation or insulators are inspected for degradation leading to reduced insulation resistance (IR). The bus insulation will be inspected for signs of embrittlement, cracking, melting, swelling, or discoloration, which may indicate overheating or aging degradation. The internal bus supports or insulators will be inspected for structural integrity and signs of cracks and corrosion. These inspections include visual inspections, as well as quantitative measurements, such as thermography or connection resistance measurements, as required.

The Metal-Enclosed Bus Inspection Program will be enhanced to include the following.

Docket Nos. 50-247 and 50-286 NL-13-077 Attachment 1 Page 2 of 5

• Revise appropriate procedures to add 480V bus associated with substation A to the scoepe of bus-0nsperated.

" Revise appropriate procedures to visually inspect the external surface of MEB enclosure assemblies for no unacceptable loss of material at least once every ten years. The inspection will occur prior to the period of extended operation and the acceptance criterion will be no significant loss of material.

• Revise appropriate procedures to inspect bolted connections at least once every five years if only 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.

• Revise acceptance criteria of appropriate procedures for MEB internal visual inspections that will 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.

Enhancements will be implemented prior to the period of extended operation.

LRA Aging Management Program Changes B.1.20 METAL-ENCLOSED BUS INSPECTION Program Descriation The Metal-Enclosed Bus Inspection Program is an existing program that inspects the following non-segregated phase bus.

olP2/IP3 - 6.9kV bus between station aux transformers and switchgear buses 1/2/3/4/5/6

• 11P3 - 6.9kV bus associated with the gas turbine substation

'!122 4180V bus associa ted with substatfion olP2/IP3 - 480V bus between emergency diesel generators and switchgear buses 2A/3A/5A/6A Inspections of the metal enclosed bus (MEB) include the bus and bus connections, the bus enclosure assemblies, and the bus insulation and insulators. A sample of the accessible bolted connections will be inspected for loose connections. The bus enclosure assemblies will be inspected for loss of material and elastomer degradation. This program will be used instead of the Structures Monitoring Program for external surfaces of the bus enclosure assemblies. The internal portions of the MEB will be inspected for foreign debris, excessive dust buildup, and evidence of moisture intrusion. The bus insulation or insulators are inspected for degradation leading to reduced insulation resistance (IR). The bus insulation will be inspected for signs of embrittlement, cracking, melting, swelling, or discoloration, which may indicate overheating or aging degradation. The internal bus supports or insulators will be inspected for structural integrity and signs of cracks and corrosion. These inspections include visual inspections, as well as quantitative measurements, such as thermography or connection resistance measurements, as required.

NUREG-1801 Consistency The Metal-Enclosed Bus Inspection Program is consistent with the program attributes described in NUREG-1801,Section XI.E4, Metal-Enclosed Bus, with enhancements and exceptions.

Docket Nos. 50-247 and 50-286 NL-13-077 Attachment 1 Page 3 of 5 Exceptions to NUREG-1801 The Metal-Enclosed Bus (MEB) Inspection Program is consistent with the program described in NUREG-1801,Section XI.E4, Metal-Enclosed Bus Aging Management Program, with the following exceptions.

Attributes Affected Exception

3. Parameters Monitored or NUREG-1 801 specifies this program Inspected provides for the inspection of the internal portion of the MEBs. The IPEC program specifies visual inspection of the external surfaces of the MEB enclosure assemblies in addition to internal portions. 1

4. Detection of Aging Effects NUREG-1801 specifies this program provides for the inspection of the internal portion of the MEBs. IPEC inspects the MEB enclosure assemblies externally in addition to internal surfaces.1 Exception Notes Inspection of the external portion of MEB enclosure assemblies under the Metal-Enclosed Bus Inspection Program assures that effects of aging will be identified prior to loss of intended function. Visual inspections have been proven effective in detecting indications of loss of material.

Enhancements The following enhancements will be implemented prior to the period of extended operation.

Attributes Affected Enhancements 1.- Scope Of Programn Revise appropriate procedure6 to add 1P2 480V bus asoriated with subtation; A te the scope of bus inspected.

3. Parameters Monitored or Revise appropriate procedures to visually Inspected inspect the external surface of MEB

4. Detection of Aging Effects external enclosure assemblies for loss of

6. Acceptance Criteria material at least once every ten years. The first inspection will occur prior to the period of extended operation and the acceptance criterion will be no significant loss of material.

Docket Nos. 50-247 and 50-286 NL-13-077 Attachment 1 Page 4 of 5 Attributes Affected Enhancements

4. Detection of Aging Effects Revise appropriate procedures to inspect bolted connections at least once every five years if only 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.

6. Acceptance Criteria Revise the 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.

Oneratina Exoerience A comparison of techniques for the cleaning and inspection of metal-enclosed buses at IP2 and IP3 was performed to develop a site-wide program procedure. Input from a review of NRC Information Notice 2000-014 was also used for this procedure. Comparison of program techniques and use of industry findings in the development of site-wide procedures provide assurance that the program will remain effective for managing aging effects for passive components.

Conclusion The Metal-Enclosed Bus Inspection Program is effective at managing aging effects. The Metal-Enclosed Bus Inspection Program assures the effects of aging are managed such that the applicable components will continue to perform their intended functions consistent with the current licensing basis through the period of extended operation.

Revised Commitment 13 I I I N*A J AAI D I Ill A i Ii Ennhane the etal ERG'esecl Bus inspectin Progaram to add 1122 48UV bus acssolatcdl Wrth 6Wu9tatlon A tO thec cco-me of buh-; ctd Enhance the Metal-Enclosed Bus Inspection Program for IP2 and IP3 to visually inspect the external surface of MEB enclosure assemblies for loss of material at least once every 10 years. The first inspection will occur prior to the period of extended operation and the acceptance criterion will be no significant loss of material.

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.

Docket Nos. 50-247 and 50-286 NL-13-077 Attachment 1 Page 5 of 5 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.

ATTACHMENT 2 TO NL-13-077 LICENSE RENEWAL APPLICATION UPDATED INFORMATION FOR STRUCTURES MONITORING PROGRAM ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286

Docket Nos. 50-247 and 50-286 NL-13-077 Attachment 2 Page 1 of 6 INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION UPDATED INFORMATION FOR STRUCTURES MONITORING PROGRAM

Background

Amendment 5, which included the annual update to the license renewal application, revised the aging management review results for the sump screens, strainers and flow barriers in the structures monitoring program as a result of the change in material from carbon steel to stainless steel. For material made from stainless steel in an air-indoor uncontrolled environment, NUREG 1801 Item 11l.B1.3-7 (TP-5) indicates that no aging management program is necessary. Therefore, the annual update showed for "sump screens, strainers and flow barriers" that there were no aging effects requiring management and no aging management program was necessary. Amendment 5 updated tables in Sections 2 and 3 of the LRA, but did not update Appendix A, Appendix B or the NRC commitment list. Accordingly, the updates to these documents are provided below.

Identification of Changes Changes are shown with strikethroughs for deletions.

LRA UFSAR Changes A.2.1.35 Structures Monitoring Program The Structures Monitoring Program is an existing program that performs inspections in accordance with 10 CFR 50.65 (Maintenance Rule) as addressed in Regulatory Guide 1.160 and NUMARC 93-01. Periodic inspections are used to monitor the condition of structures and structural commodities to ensure there is no loss of intended function.

The Structures Monitoring Program will be enhanced to include the following.

Appropriate procedures will be revised to explicitly specify that the following structures are included in the program.

- city water storage tank foundation

- discharge canal

- emergency lighting poles and foundations

- fire pumphouse

- fire water storage tank foundation

- gas turbine 1 fuel storage tank foundation

- maintenance and outage building-elevated passageway

- new station security building

- nuclear service building (IP1)

- service water pipe chase

- superheater stack

- transformer/switchyard support structures

- waste holdup tank pit

Docket Nos. 50-247 and 50-286 NL-13-077 Attachment 2 Page 2 of 6 Appropriate procedures will be revised 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

- SUmDS. S"um .... cns. St.ain.., and flow ba.. ierc

Docket Nos. 50-247 and 50-286 NL-1 3-077 Attachment 2 Page 3 of 6 A.3.1.35 Structures Monitoring Program The Structures Monitoring Program is an existing program that performs inspections in accordance with 10 CFR 50.65 (Maintenance Rule) as addressed in Regulatory Guide 1.160 and NUMARC 93-01. Periodic inspections are used to monitor the condition of structures and structural commodities to ensure there is no loss of intended function.

The Structures Monitoring Program will be enhanced to include the following.

" Appropriate procedures will be revised to explicitly specify that the following structures are included in the program.

- Appendix R emergency diesel generator foundation

- Appendix R emergency diesel generator fuel oil tank vault

- Appendix R emergency diesel generator switchgear and enclosure

- city water storage tanks foundation

- condensate storage tank foundation

- containment access facility and annex

- discharge canal

- emergency lighting poles and foundations

- fire protection pumphouse

- fire water storage tank foundation

- gas turbine 1 fuel storage tank foundation

- primary water storage tank foundation

- refueling water storage tank foundation

- security access and office building

- service water pipe chase

- service water valve pit

- superheater stack

- waste holdup tank pit

• Appropriate procedures will be revised 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, sump Screens, strainers. and flow barrierS

Docket Nos. 50-247 and 50-286 NL-13-077 Attachment 2 Page 4 of 6 LRA Structures Monitoring Program Changes B.1.36 STRUCTURES MONITORING Proaram Description The Structures Monitoring Program is an existing program that performs inspections in accordance with 10 CFR 50.65 (Maintenance Rule) as addressed in Regulatory Guide 1.160 and NUMARC 93-01. Periodic inspections are used to monitor the condition of structures and structural components to ensure there is no loss of intended function.

Since protective coatings are not relied upon to manage the effects of aging for structures included in the Structures Monitoring Program, the program does not address protective coating monitoring and maintenance.

NUREG-1801 Consistency The Structures Monitoring Program is consistent with the program described in NUREG-1801,Section XI.S6, Structures Monitoring Program, with enhancements.

Exceptions to NUREG-1801 None Enhancements The following enhancements will be implemented prior to the period of extended operation.

Attributes Affected Enhancements

1. Scope of Program Appropriate procedures will be revised to explicitly specify that the following structures are included in the program.

" Appendix R emergency diesel generator foundation (IP3)

" Appendix R emergency diesel generator fuel oil tank vault (IP3)

" Appendix R emergency diesel generator switchgear and enclosure (IP3)

• city water storage tank foundation

" condensate storage tanks foundation (IP3)

" containment access facility and annex (IP3)

Docket Nos. 50-247 and 50-286 NL-13-077 Attachment 2 Page 5 of 6 Attributes Affected Enhancements

• discharge canal (IP2/3)

" emergency lighting poles and foundations (IP2/3)

" fire pumphouse (IP2)

• fire protection pumphouse (IP3)

• fire water storage tank foundation (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)

" 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 pit (IP2/3)

Docket Nos. 50-247 and 50-286 NL-13-077 Attachment 2 Page 6 of 6 Attributes Affected Enhancements

1. Scope of Program Appropriate procedures will be revised 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 S

sumps, Sump ..... ns, Straincro and floe ba&eS Revised Commitment 25 Commitment 25 is revised consistent with the above as shown in Attachment 3.

ATTACHMENT 3 TO NL-13-077 LICENSE RENEWAL APPLICATION IPEC LIST OF REGULATORY COMITMENTS Rev. 20 ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286

NL-13-077 Attachment 3 Page 1 of 20 List of Regulatory Commitments Rev. 20 The following table identifies those actions committed to by Entergy in this document.

Changes are shown as strikethroughs for deletioes and underlines for additions.

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I 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 eptember 28, A.3.1.1 the bottom surfaces of the condensate storage tanks, 013 B.1.1 city water tank, and fire water tanks once during the lP3:

first ten years of the period of extended operation. December 12, Enhance the Aboveground Steel Tanks Program for 2015 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 eptember 28, A.3.1.2 materials for low susceptibility to SCC and clarify the 013 B.1.2 prohibition on use of lubricants containing MoS 2 for iP3: NL-07-153 Audit Items bolting. December 12, 201,241, The Bolting Integrity Program manages loss of 2015 270 preload and loss of material for all external bolting. I I

NL-13-077 Attachment 3 Page 2 of 20 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I I I /IAUDIT ITEM IP2: NL-07-039 A.2.1.5 3 Implement the Buried Piping and Tanks Inspection September 28, A.3.1.5 Program for IP2 and IP3 as described in LRA Section 2013 B.1.6 B.1.6.

NL-07-153 Audit Item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- December 12, 1801 Section XI.M34, Buried Piping and Tanks 2015 Inspection.

NL-09-106 Include in the Buried Piping and Tanks Inspection Program described in LRA Section B.1.6 a risk NL-09-111 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 NL-1 1-101 demonstrated effectiveness.

NL-13-077 Attachment 3 Page 3 of 20 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION IIP2: I__

NL-07-039 I/AUDIT ITEM A.2.1.8 4 Enhance the Diesel Fuel Monitoring Program to September 28, A.3.1.8 include cleaning and inspection of the IP2 GT-1 gas 2013 B.1.9 turbine fuel oil storage tanks, IP2 and IP3 EDG fuel oil NL-07-153 Audit items day tanks, IP2 SBO/Appendix R diesel generator fuel lP3: 128, 129, oil day tank, and IP3 Appendix R fuel oil storage tank

)ecember 12, 132, and day tank once every ten years.

1015 NL-08-057 491,492, Enhance the Diesel Fuel Monitoring Program to 510 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/I. 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.

NL-13-077 Attachment 3 Page 4 of 20

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM 5 Enhance the External Surfaces Monitoring Program 1P2: NL-07-039 A.2.1.10 September 28, A.3.1.10 for IP2 and IP3 to include periodic inspections of 013 B.1.11 systems in scope and subject to aging management review for license renewal in accordance with 10 CFR IP&

54.4(a)(1) and (a)(3). Inspections shall include areas surrounding the subject systems to identify hazards to emr1 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).

Enhance the Fatigue Monitoring Program for IP2 to IP2: NL-07-039 A.2.1.11 6

eptember 28, A.3.1.11 monitor steady state cycles and feedwater cycles or 2013 B.1 .12, perform an evaluation to determine monitoring is not 2013 Ad Item required. Review the number of allowed events and 164 resolve discrepancies between reference documents and monitoring procedures.

Enhance the Fatigue Monitoring Program for IP3 to IP3:

include all the transients identified. Assure all fatigue December 12, analysis transients are included with the lowest 2015 limiting numbers. Update the number of design transients accumulated to date.

P2: NL-07-039 A.2.1.12 7 Enhance the Fire Protection Program to inspect Ip2ember728,9 A.2.1.12 external surfaces of the IP3 RCP oil collection eptember 28, A.3.1.12 013 B.1.13 systems for loss of material each refueling cycle.

Enhance the Fire Protection Program to explicitly P3:

state that the IP2 and IP3 diesel fire pump engine December 12, sub-systems (including the fuel supply line) shall be 2015 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 CO 2 fire suppression system for signs of degradation, such as corrosion and mechanical damage at least once every six months.

NL-13-077 Attachment 3 Page 5 of 20 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I_ I I / AUDIT ITEM IP2: NL-07-039 A.2.1.13 8 Enhance the Fire Water Program to include inspection September 28, A.3.1.13 of IP2 and IP3 hose reels for evidence of corrosion.

2013 B.1.14 Acceptance criteria will be revised to verify no NL-07-153 Audit Items unacceptable signs of degradation.

IP3: 105, 106 Enhance the Fire Water Program to replace all or test December 12, NL-08-014 a sample of IP2 and IP3 sprinkler heads required for 2015 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 the current 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 sianificant corrosion.

NL-13-077 Attachment 3 Page 6 of 20 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I I I /IAUDIT ITEM IP2: NL-07-039 A.2.1.15 9 Enhance the Flux Thimble Tube Inspection Program September 28, A.3.1.15 for IP2 and IP3 to implement comparisons to wear 2013 B.1.16 rates identified in WCAP-12866. Include provisions to compare data to the previous performances and IP3:

perform evaluations regarding change to test December 12, frequency and scope.

2015 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.

NL-13-077 Attachment 3 Page 7 of 20 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I_ I I I AUDIT ITEM IP2: NL-07-039 A.2.1.16 10 Enhance the Heat Exchanger Monitoring Program for September 28, A.3.1.16 IP2 and IP3 to include the following heat exchangers B.1.17, 2013 in the scope of the program. Audit Item NL-07-153

• Safety injection pump lube oil heat exchangers IP3: 52 December 12,

• RHR heat exchangers 2015

• 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 program. Establish acceptance criteria for heat exchangers visually inspected to include no indication of tube erosion, vibration wear, corrosion, pitting, NL-09-018 fouling, or scaling.

11 Deleted NL-09-056 NL-11-101

NL-1 3-077 Attachment 3 Page 8 of 20

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM P2: NL-07-039 A.2.1.18 12 Enhance the Masonry Wall Program for IP2 and IP3 A September 28, A.3.1.18 to specify that the IP1 intake structure is included in the program. 013 B.1.19 IP3:

ecember 12, 2015 13 Enhanc~e thc Metal Encalosed Bus Inspection Programn IP2: NL-07-039 A.2.1.19 to add 1122 480V bus associated with substation A to September 28, A.3.1.19 the Scopo of bus inspected. 2013 B.1.20 NL-07-153 Audit Items Enhance the Metal-Enclosed Bus Inspection Program IP3: 124, for IP2 and IP3 to visually inspect the external surface December 12, NL-08-057 133, 519 of MEB enclosure assemblies for loss of material at 2015 least once every 10 years. The first inspection will NL-13-077 occur prior to the period of extended operation and the acceptance criterion will be no significant loss of material.

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 IP2: NL-07-039 A.2.1.21 Program for IP2 and IP3 as described in LRA Section September 28, A.3.1.21 B.1.22. 2013 B.1.22 IP3:

December 12, 2015

NL-13-077 Attachment 3 Page 9 of 20

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM 15 Implement the Non-EQ Inaccessible Medium-Voltage IP2: NL-07-039 A.2.1.22 Cable Program for IP2 and IP3 as described in LRA eptember 28, A.3.1.22 Section B.1.23. 2013 B.1.23 NL-07-153 Audit item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- December 12, NL-1 1-032 1801 Section XI.E3, Inaccessible Medium-Voltage 2015 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 September 28, A.3.1.23 Section B.1.24. 2013 B. 1.24 NL-07-153 Audit item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- ecember 12, 1801 Section XI.E2, Electrical Cables and 2015 Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits.

17 Implement the Non-EQ Insulated Cables and 1P2: NL-07-039 A.2.1.24 Connections Program for IP2 and IP3 as described in September 28, A.3.1.24 LRA Section B.1.25. 2013 B.1.25 NL-07-153 Audit item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- ecember 12, 1801 Section XI.E1, Electrical Cables and 015 Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.

NL-13-077 Attachment 3 Page 10 of 20

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM P2: NL-07-039 A.2.1.25 18 Enhance the Oil Analysis Program for IP2 to sample ay2 oil used in the SBO/Appendix and analyze lubricating . . .

September 013 28, NL-11-101 A.3.1.25 B.1.26 for R diesel generator consistent with the oil analysis other site diesel generators. IP3:

Enhance the Oil Analysis Program for IP2 and IP3 to December 12, sample and analyze generator seal oil and turbine 2015 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.

P2: NL-07-039 A.2.1.26 19 Implement the One-Time Inspection Program for IP2 Ip2ember728,9 A.3.1.26 and IP3 as described in LRA Section B.1.27. eptember 28, A.3.1.26 2013 B.1.27 This new program will be implemented consistent with NL-07-153 Audit item the corresponding program described in NUREG- IP3: 173 1801,Section XI.M32, One-Time Inspection. December 12, 2015 IP2: NL-07-039 A.2.1.27 20 Implement the One-Time Inspection - Small Bore P NL-07-028 A.3.1.27 Piping Program for IP2 and IP3 as described in LRA eptember 28, 2013 B.1.28 Section B.1.28.

NL-07-153 Audit item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- December 12, 1801,Section XI.M35, One-Time Inspection of ASME 2015 1 Code Class I Small-Bore Piping.

21 Enhance the Periodic Surveillance and Preventive P2: NL-07-039 A.2.1.28 September 28, A.3.1.28 Maintenance Program for IP2 and IP3 as necessary to assure that the effects of aging will be managed 013 B.1.29 such that applicable components will continue to perform their intended functions consistent with the DP e1 current licensing basis through the period of extended emr1

___ operation. o015

_______

NL-13-077 Attachment 3 Page 11 of 20

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM IP2: NL-07-039 A.2.1.31 A.2.1.31 22 Enhance the Reactor Vessel Surveillance Program for A.3.1.31 IP2 and IP3 revising the specimen capsule withdrawal September 28, 013 schedules to draw and test a standby capsule to cover the peak reactor vessel fluence expected IP&

through the end of the period of extended operation. December 12, Enhance the Reactor Vessel Surveillance Program for 2015 IP2 and IP3 to require that tested and untested specimens from all capsules pulled from the reactor vessel are maintained in storage.

Implement the Selective Leaching Program for IP2 eP2: NL-07-039 A.2.1.32 23 in LRA Section B.1.33. eptember 28, A.3.1.32 and IP3 as described 2013 B.1.33 This new program will be implemented consistent with NL-07-153 Audit item the corresponding program described in NUREG- IP3: 173 1801,Section XI.M33 Selective Leaching of Materials. December 12, 2015 Enhance the Steam Generator Integrity Program for P2: NL-07-039 A.2.1.34 24 September 28, A.3.1.34 IP2 and IP3 to require that the results of the condition 013 8.1.35 monitoring assessment are compared to the operational assessment performed for the prior IP3:

operating cycle with differences evaluated. ecember 12, 2015 25 Enhance the Structures Monitoring Program to IP2: NL-07-039 A.2.1.35 explicitly specify that the following structures are September 28, A.3.1.35 included in the program. 2013 B.1.36

• Appendix R diesel generator foundation (IP3) NL-07-153

• Appendix R diesel generator fuel oil tank vault IP3: Audit items (IP3) December 12, 86, 87, 88,

• Appendix R diesel generator switchgear and 2015 417 enclosure (IP3)

" city water storage tank foundation

• condensate storage tanks foundation (IP3)

• containment access facility and annex (IP3)

• discharge canal (IP2/3)

" emergency lighting poles and foundations (1P2/3)

" fire pumphouse (IP2)

" 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)

" new station security building (IP2)

• nuclear service building (IP1)

NL-13-077 Attachment 3 Page 12 of 20 COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I____I /AUDIT ITEM 0 primary water storage tank foundation (IP3) 0 refueling water storage tank foundation (IP3) 0 security access and office building (IP3) 0 service water pipe chase (IP2/3) 0 service water valve pit (IP3) 0 superheater stack S transformer/switchyard support structures (IP2) 0 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 4

v 01 Im'e w , Ciurn.,

bump e.ý"r borvvriti,

-ae e-L.,I . ',

b rd rlvrb nr- f-nl-' , a dri WVW rrJare NL-13-077 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 Attachment 3 Page 13 of 20

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM Enhance the Structures Monitoring Program for IP2 NL-08-127 and IP3 to perform an engineering evaluation of Audit Item groundwater samples to assess aggressiveness of 360 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 spent fuel 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 Audit Item of the water control structure once per 3 years rather 358 than the normal frequency of once per 5 years during the PEO.

Enhance the Structures Monitoring Program to include more detailed quantitative acceptance criteria NL-1 1-032 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-1 1-101 l 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 September 28, A.3.1.36 2013 B.1.37 and IP3 as described in LRA Section B.1.37.

NL-07-153 Audit item This new program will be implemented consistent with IP3: 173 the corresponding program described in NUREG- December 12, 1801,Section XI.M12, Thermal Aging Embrittlement 2015 of Cast Austenitic Stainless Steel (CASS) Program.

NL-13-077 Attachment 3 Page 14 of 20

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM NL-07-039 A.2.1.37 27 Implement the Thermal Aging and Neutron Irradiation P2:

September 28, A.3.1.37 Embrittlement of Cast Austenitic Stainless Steel 2013 B.1.38 (CASS) Program for IP2 and IP3 as described in LRA 013 N.1Ait SecionB.138.NL-07-153 Audit item Section B. 1.38. P3: 173 This new program will be implemented consistent with December 12, the corresponding program described in NUREG- 2015 1801 Section XI.M13, Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program.

eP2: NL-07-039 A.2.1.39 28 Enhance the Water Chemistry Control - Closed to maintain water chemistry of September 28, A.3.1.39 Cooling Water Program the IP2 SBO/Appendix R diesel generator cooling NL-08-057 Audit item system per EPRI guidelines. NP3: 509 Enhance the Water Chemistry Control - Closed ecember 12, Cooling Water Program to maintain the IP2 and IP3 2015 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 September 28, B.1.41 2013 the RWST with a limit of <150 ppb. 2013 30IP2: NL-07-039 A.2. 1.41 30 For aging management of the reactor vessel internals, epteNb0703 A.2.1.41 IPEC will (1) participate in the industry programs for September 28, A.3.1.41 investigating and managing aging effects on reactor 011 internals; (2) evaluate and implement the results of IP3:

the industry programs as applicable to the reactor ecember 12, internals; and (3) upon completion of these programs, 2013 but not less than 24 months before entering the period of extended operation, submit an inspection plan for Complete NL-1 1-107 reactor internals to the NRC for review and approval. Complete NL-11-107 31 Additional P-T curves will be submitted as required P2: NL-07-039 A.2.2.1.2 per 10 CFR 50, Appendix G prior to the period of September 28, A.3.2.1.2 extended operation as part of the Reactor Vessel 013 4.2.3 Surveillance Program. IP3:

December 12, 2015 32 As required by 10 CFR 50.61 (b)(4), IP3 will submit a IP3: 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-13-077 Attachment 3 Page 15 of 20

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION IAUDIT ITEM IP2: NL-07-039 A.2.2.2.3 33 At least 2 years prior to entering the period of September 28, A.3.2.2.3 extended operation, for the locations identified in LRA 2011 4.3.3 Table 4.3-13 (IP2) and LRA Table 4.3-14 (IP3), under NL-07-153 Audit item the Fatigue Monitoring Program, IP2 and IP3 will P3: 146 implement one or more of the following: NL-08-021

ecember 12, (1) Consistent with the Fatigue Monitoring Program, 2013 Detection of Aging Effects, update the fatigue usage calculations using refined fatigue analyses to determine valid CUFs less than 1.0 when accounting Complete NL-10-082 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 LRA Table 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.

34 1P2 SBO /Appendix R diesel generator will be April 30, 2008 NL-07-078 2.1.1.3.5 installed and operational by April 30, 2008. This Complete NL-08-074 committed change to the facility meets the requirements of 10 CFR 50.59(c)(1) and, therefore, a NL-11-101 license amendment pursuant to 10 CFR 50.90 is not required.

NL-13-077 Attachment 3 Page 16 of 20

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I 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 eptember 28, 013 1973 event behind the insulation, prior to entering the period of extended operation, to assure liner degradation is not occurring in this area. NL- 11-101 Perform a one-time inspection of representative IP3:

sample area of the IP3 containment steel liner at the December 12, juncture with the concrete floor slab, prior to entering 2015 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.

36 Perform a one-time inspection and evaluation of a P2: NL-08-127 Audit Item sample of potentially affected IP2 refueling cavity September 28, NL-11-101 359 concrete prior to the period of extended operation.

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.

37 Enhance the Containment Inservice Inspection (CII- P2: NL-08-127 Audit Item IWL) Program to include inspections of the September 28, 361 containment using enhanced characterization of 013 degradation (i.e., quantifying the dimensions of noted indications through the use of optical aids) during the DPe1 period of extended operation. The enhancement emr1 2015 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-1 3-077 Attachment 3 Page 17 of 20

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I 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 September 28, 2013 values of RTpts or CvUSE, updated calculations will be provided to the NRC. lP3:

December 12, 2015 39 Deleted NL-09-079 Evaluate plant specific and appropriate industry 1P2: NL-09-106 B.1.6 40 incorporate lessons learned eptember 28, B.1.22 operating experience and and inspection 013 B.1.23 in establishing appropriate monitoring frequencies to assess aging effects for the new aging B.1.25 BP3:

management programs. Documentation of the c 12, B.1.27 operating experience evaluated for each new program December 12, B.1.27 will be available on site for NRC review prior to the 015 B.1.28 B.1.37 period of extended operation.

B.1. 38 IP2: the NL-11-032 N/A IPEC will inspect steam generators for both units to fter 41 assess the condition of the divider plate assembly.

The examination technique used will be capable of beginning of the detecting PWSCC in the steam generator divider plate PEO and prior to assembly. The IP2 steam generator divider plate September 28, 2023 NL-1 1-074 inspections will be completed within the first ten years of the period of extended operation (PEO). The IP3 lP3: NL-11-090 steam generator divider plate inspections will be nor to the end completed within the first refueling outage following 3f the first NL-1 1-101 the beginning of the PEO. refueling outage following the beginning of the PEO. II

NL-13-077 Attachment 3 Page 18 of 20

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM NL-1 1-032 N/A 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 the NL-1 1-074 steam generator tube-to-tubesheet welds in order to 1P2: to-11-07 establish a technical basis for either determining that 20ior to March the tubesheet cladding and welds are not susceptible -024 NL-11-090 to PWSCC, or redefining the pressure boundary in 1P3: Prior to the which the tube-to-tubesheet weld is no longer of the first ind NL-11-096 included and, therefore, is not required for reactor efueling outage coolant pressure boundary function. The redefinition following the of the reactor coolant pressure boundary must be beginning of the approved by the NRC as a license amendment PEO.

request.

Option 2 (Inspection) IP2:

Between March IPEC will perform a one-time inspection of a 2020 and March representative number of tube-to-tubesheet welds in 2024 each steam generator to determine if PWSCC cracking is present. If weld cracking is identified: 1P3: Prior to the

a. The condition will be resolved through repair Bnd of the first or engineering evaluation to justify continued refueling outage service, as appropriate, and ollowing the beginning of the

b. An ongoing monitoring program will be PEO.

established to perform routine tube-to-tubesheet weld inspections for the remaining life of the steam generators.

IPEC will review design basis ASME Code Class 1 1P2: NL-1 1-032 4.3.3 43 fatigue evaluations to determine whether the nor to NUREG/CR-6260 locations that have been evaluated 2013 September 28, for the effects of the reactor coolant environment on NL-1 1-101 fatigue usage are the limiting locations for the IP2 and I-P& Prior to IP3 configurations. If more limiting locations are ecember 12, identified, the most limiting location will be evaluated 015 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.

NL-13-077 Attachment 3 Page 19 of 20

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION

/ AUDIT ITEM IPEC will include written explanation and justification P2: NL-1r1-032 N/A 44 nPror to of any user intervention in future evaluations using the 2013 WESTEMS "Design CUF" module.

1P3: Prior to December 12, 2015 45 IPEC will not use the NB-3600 option of the IP2: NL-11-032 N/A WESTEMS program in future design calculations until nor to the issues identified during the NRC review of the September 28, NL-1 1-101 program have been resolved. 2013 IP3: Prior to December 12, 2015 Include in the IP2 ISI Program that IPEC will perform iP2: NL-11-032 N/A 46 twenty-five volumetric weld metal inspections of nPror to socket welds during each 10-year ISI interval eptember 28, NL-1 1-074 scheduled as specified by IWB-2412 of the ASME 013 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 perform and submit analyses that IP2: NL-12-089 N/A demonstrate that the lower support column bodies will nor to maintain their functionality during the period of September 28, extended operation considering the possible loss of 013 fracture toughness due to thermal and irradiation IP3: Prior to embrittlement. The analyses will be consistent with December 12, the IP2/IP3 licensing basis. 2015

NL-13-077 Attachment 3 Page 20 of 20

1. COMMITMENT IMPLEMENTATION SOURCE RELATED SCHEDULE LRA SECTION I AUDIT ITEM 48 Entergy will visually inspect IPEC underground piping IP2: NL-12-174 N/A within the scope of license renewal and subject to Prior to aging management review prior to the period of September 28, extended operation and then on a frequency of at 2013 least once every two years during the period of extended operation. This inspection frequency will be IP3: Prior to maintained unless the piping is subsequently coated December 12, in accordance with the preventive actions specified in 2015 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-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).