ML11235A497

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2011/08/22 Indian Point Lr Hearing - IPEC License Renewal - Commitment Reconciliation - NL-11-101
ML11235A497
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 08/22/2011
From:
- No Known Affiliation
To:
Division of License Renewal
References
Download: ML11235A497 (30)
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1 IPRenewal NPEmails From: Waters, Roger M. [rwater1@entergy.com]

Sent: Monday, August 22, 2011 2:59 PM To: Kuntz, Robert; Boska, John Cc: Kerrigan, James A

Subject:

IPEC License Renewal - Commi tment Reconciliation - NL-11-101 Attachments:

NL-11-101 master file.pdfRob and John, Attached is a pdf version of the subject letter

- a hardcopy will be in the mail tonight to the Document Control Center and distribution.

In addition to commitment reconciliation Entergy has, as requested:

1) provided an update to Section 3.1.2.2.12 of the LRA, 2) provided a discussion on the approach to MRP-227-A, and
3) revised commitment 44 and 45 implementation schedule.

Roger Waters IPEC Licensing 914-827-7714

<<NL-11-101 master file.pdf>>

Hearing Identifier: IndianPointUnits2and3NonPublic_EX Email Number: 2840 Mail Envelope Properties (B512737293B8D64C83ECF28F37E85D06103A9994)

Subject:

IPEC License Renewal - Commitment Reconciliation - NL-11-101 Sent Date: 8/22/2011 2:59:04 PM Received Date: 8/22/2011 2:59:10 PM From: Waters, Roger M.

Created By: rwater1@entergy.com Recipients: "Kerrigan, James A" <jkerrig@entergy.com>

Tracking Status: None "Kuntz, Robert" <Robert.Kuntz@nrc.gov>

Tracking Status: None "Boska, John" <John.Boska@nrc.gov> Tracking Status: None

Post Office: IPCEXETSP001.etrsouth.corp.entergy.com Files Size Date & Time MESSAGE 509 8/22/2011 2:59:10 PM NL-11-101 master file.pdf 123141

Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:

Fred DacimoVice PresidentOperations License RenewalEntergy Nuclear NortheastIndian Point Energy Center 450 Broadway, GSB P.O. Box 249Buchanan, NY 10511-0249Tel (914) 788-2055NL-11-101August 22, 2011U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001

SUBJECT:

Clarification for Request for Additional Information (RAI)Aging Management Programs Indian Point Nuclear Generating Unit Nos. 2 & 3Docket Nos. 50-247 and 50-286License Nos. DPR-26 and DPR-64

REFERENCE:

1. NRC Letter, "Request for Additional Information for the Review of theIndian Point Nuclear Generating Unit Numbers 2 and 3, License Renewal Application," dated June 15, 20112. Entergy letter (NL-11-032),"Response to Request for AdditionalInformation (RAI) Aging Management Programs," dated March 28, 20113. Entergy letter (NL-11-074),"Response to Request for AdditionalInformation (RAI) Aging Management Programs," dated July 14, 20114. Entergy letter (NL-11-090),"Clarification for Request for AdditionalInformation (RAI) Aging Management Programs," dated July 27, 20115. Entergy letter (NL-11-096),"Clarification for Request for AdditionalInformation (RAI) Aging Management Programs," dated August 9,20116. Entergy letter (NL-10-063),"Amendment 9 to License RenewalApplication (LRA) - Reactor Vessel Internals Program," dated July14, 2010

Dear Sir or Madam:

Entergy Nuclear Operations, Inc is providing, in Attachment 1, clarifications of the responses inReferences 2, 3, 4 and 5. Attachment 2 provides the latest list of regulatory commitmentsincluding revisions to commitments discussed in this letter.

ATTACHMENT 1 TO NL-11-101LICENSE RENEWAL APPLICATIONCLARIFICATION OF RESPONSES TO REQUESTS FOR ADDITIONALINFORMATION (RAIs) AND COMMITMENT LISTENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3DOCKET NOS. 50-247 AND 50-286 NL-11-101Attachment 1Page 1 of 4INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3LICENSE RENEWAL APPLICATIONCLARIFICATION OF RESPONSES TO REQUESTS FOR ADDITIONALINFORMATION (RAIs) AND COMMITMENT LISTIntroductionEntergy has made regulatory commitments relating to managing the effects of aging on certainstructures and components during the period of extended operation. These commitments areincluded in a number of transmittal letters as identified in the commitment list contained inAttachment 2. The NRC Safety Evaluation Report (SER), issued as NUREG-1930, also contains the commitments made up to the time of its issue.Entergy has reviewed the commitment transmittal letters and the SER. As a result of the reviewcertain commitments made by Entergy require minor revision. A large majority of these revisions are editorial and do not alter the intent of the commitment. In addition, there are certaininstances where the SER commitment list contains minor deviations from the Entergycommitment. The results of the review are documented below.Changes to Entergy CommitmentsCommitment 3In NL-11-074, Entergy inadvertently changed this commitment due to an administrative error.The change was not identified as a change and NL-11-074 was not identified as a source document. This commitment is being restored to the version provided in NL-11-032.NL-11-101 has been added as a source document in the list of regulatory commitments.

Commitment 11A minor grammatical error is corrected here by replacing "Delete commitment." by "Deleted".

NL-11-101 has been added as a source document in the list of regulatory commitments.Commitment 15The correct title for NUREG-1801 Section XI.E3 is "Inaccessible Medium Voltage Cables NotSubject To 10 CFR 50.49 Environmental Qualification Requirements." This supersedes the title change identified in NL-11-032 and the NL-11-096 commitment list.NL-11-101 has been added as a source document in the list of regulatory commitments.

Commitment 25In NL-11-074, Entergy inadvertently changed this commitment due to an administrative error.The change was not identified as a change and NL-11-074 was not identified as a sourcedocument. This commitment is being restored to the version provided in NL-11-032 by deleting

"(PEO)" at the end of the commitment.

Docket Nos. 50-247 & 50-286 NL-11-101 Page 2 of 4NL-11-101 has been added as a source document in the list of regulatory commitments.Commitment 34In NL-11-032, Entergy introduced a typographical error by changing "50.59(c)(1)" to "50.59l(1)."That error is corrected here.NL-11-101 has been added as a source document in the list of regulatory commitments.Commitments 35 and 36There are minor editorial differences between the commitments and the SER. The commitmentshave been revised to match the SER by changing "extended period of operation" to "period of extended operation" in commitment 35 and changing "Inspection" to "inspection" in commitment 36.NL-11-101 has been added as a source document in the list of regulatory commitments.Commitment 41In NL-11-074, Entergy discussed and made changes to Commitment 41. In addition to thechanges discussed in the letter, Entergy inadvertently made editorial changes to portions of thiscommitment due to an administrative error. These changes were not identified as a change in the commitment list. This commitment is being revised to correct the inadvertent editorialchanges.NL-11-101 has been added as a source document in the list of regulatory commitments.Commitment 43In NL-11-074, Entergy inadvertently changed the implementation schedule to IP2: Prior toSeptember 28, 2023 and IP3: Prior to December 12, 2025. This change was corrected in NL-11-090 but the change was neither identified as a change nor discussed. Therefore, changes to the commitment are not required.In order to provide traceability NL-11-101 has been added as a source document in the list ofregulatory commitments.Commitments 44 and 45For consistency with other similar commitments the implementation schedule has been revisedfrom "Within 60 days of issuance of the renewed operating license" to "IP2: Prior to September28, 2013 IP3: Prior to December 12, 2015".NL-11-101 has been added as a source document in the list of regulatory commitments.Commitment 45A minor grammatical error is corrected here by replacing "has" by "have".

Docket Nos. 50-247 & 50-286 NL-11-101 Page 3 of 4NL-11-101 has been added as a source document in the list of regulatory commitments.Minor differences between the SER and Entergy commitmentsCommitment 1The words "Above Ground" were used instead of "Aboveground".Commitments 3, 15, 16 and 17The word "program" is missing following "corresponding" in the second paragraph of eachcommitment. In addition, in Commitment 17 "50.39" should be "50.49".Commitment 4The word "surface" was added to the SER in the third paragraph following "bottom".

The next to last paragraph in the SER reads "Revise applicable procedures to direct sampling ofthe onsite portable fuel oil contents prior to transferring the contents prior to transferring thecontents to storage" while the Entergy commitment reads "Revise applicable procedures to direct sampling of the onsite portable fuel oil contents prior to transferring the contents to thestorage tanks".In NL-08-057, Entergy revised the commitment by adding "EDG fuel oil storage tanks" withoutidentifying the change as a change. In accordance with NL-08-057 the third paragraph in theSER should read "-..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."Commitment 8In NL-07-153, Entergy identified a change to the second paragraph of Commitment 8 thatreplaced "inspect" by "replace all or test".In NL-08-014, Entergy identified a change to the fourth paragraph of Commitment 8 that deleted"the IP3". The statement is applicable to both IP2 and IP3.Commitment 10In NL-09-018, Entergy identified a change to the fourth paragraph of Commitment 10 thatreplaced "unacceptable signs of degradation" by "indication of tube erosion, vibration wear, corrosion, pitting, fouling, or scaling".Commitments 11 and 39The words "not applicable" were added in the SER under LRA section and implementationschedule columns.

Docket Nos. 50-247 & 50-286 NL-11-101 Page 4 of 4Commitment 13In NL-07-153, Entergy identified a change to the fourth paragraph of Commitment 13 that addedthe words "such as thermography or contact resistance measurements".The words "metal-enclosed bus" in the second paragraph were added to the SER in place of"MEB".Commitment 18There is a minor editorial difference in the first paragraph. The SER says "the oil analysis" andthe Entergy commitment says "oil analysis".Commitment 21The word "extended" is missing.

Commitment 30The word "and" is missing prior to (3) and the Entergy commitment implementation scheduledates should be IP2: September 28, 2011 and IP3: December 12, 2013.Commitment 32"10 CFR 50.61(b) 4)" should read "10 CFR 50.61(b)(4)".In addition to the commitment review Entergy provides below an update to the implementationof Commitment 30.Inspection Plan for Reactor InternalsThis inspection plan that Entergy will submit by September 28, 2011 is responsive to RIS 2011-007 for Category C plants. This inspection plan will include the inspections specified in MRP-227, as modified by the conditions and limitations and applicant/licensee action items in the NRC SER on MRP-227, Revision 0. In accordance with guidance on the NRC website, EPRI isexpected to publish an accepted version of MRP-227, designated MRP-227-A, which willincorporate the NRC SER. Following issuance of MRP-227-A, Entergy will review the inspection plan to determine the need for revision, and will modify the inspection plan to include the necessary revisions, if any.

ATTACHMENT 2 TO NL-11-101LICENSE RENEWAL APPLICATIONIPEC LIST OF REGULATORY COMMITMENTSRev. 17ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3DOCKET NOS. 50-247 AND 50-286 NL-11-101Attachment 2Page 1 of 18List of Regulatory CommitmentsRev. 17The following table identifies those actions committed to by Entergy in this document.

Changes are shown as strikethroughs for deletions and underlines for additions

.#COMMITMENTIMPLEMENTATION SCHEDULESOURCERELATEDLRA SECTION/ AUDIT ITEM1 Enhance the Aboveground Steel Tanks Program forIP2 and IP3 to perform thickness measurements ofthe bottom surfaces of the condensate storage tanks,city water tank, and fire water tanks once during the first ten years of the period of extended operation.Enhance the Aboveground Steel Tanks Program forIP2 and IP3 to require trending of thickness measurements when material loss is detected.IP2:September 28,2013IP3:December 12,2015NL-07-039A.2.1.1A.3.1.1B.1.12 Enhance the Bolting Integrity Program for IP2 and IP3to clarify that actual yield strength is used in selectingmaterials for low susceptibility to SCC and clarify the prohibition on use of lubricants containing MoS 2 forbolting.The Bolting Integrity Program manages loss ofpreload and loss of material for all external bolting.IP2:September 28,2013IP3:December 12,2015NL-07-039NL-07-153A.2.1.2A.3.1.2B.1.2Audit Items201, 241,270 NL-11-101Attachment 2Page 2 of 18

  1. COMMITMENTIMPLEMENTATION SCHEDULESOURCERELATEDLRA SECTION/ AUDIT ITEM3 Implement the Buried Piping and Tanks InspectionProgram for IP2 and IP3 as described in LRA Section B.1.6.This new program will be implemented consistent withthe corresponding program described in NUREG-1801 Section XI.M34, Buried Piping and TanksInspection.Include in the Buried Piping and Tanks InspectionProgram described in LRA Section B.1.6 a riskassessment of in-scope buried piping and tanks thatincludes consideration of the impacts of buried piping or tank leakage and of conditions affecting the risk for corrosion. Classify pipe segments and tanks ashaving a high, medium or low impact of leakagebased on the safety class, the hazard posed by fluid contained in the piping and the impact of leakage onreliable plant operation. Determine corrosion riskthrough consideration of piping or tank material, soil resistivity, drainage, the presence of cathodicprotection and the type of coating. Establishinspection priority and frequency for periodic inspections of the in-scope piping and tanks based on the results of the risk assessment. Performinspections using inspection techniques withdemonstrated effectivenessdirect visual inspection

.IP2:September 28, 2013IP3:December 12,2015NL-07-039NL-07-153NL-09-106NL-09-111NL-11-101A.2.1.5A.3.1.5B.1.6Audit Item173 NL-11-101Attachment 2Page 3 of 18

  1. COMMITMENTIMPLEMENTATION SCHEDULESOURCERELATEDLRA SECTION/ AUDIT ITEM4 Enhance the Diesel Fuel Monitoring Program toinclude cleaning and inspection of the IP2 GT-1 gas turbine fuel oil storage tanks, IP2 and IP3 EDG fuel oilday tanks, IP2 SBO/Appendix R diesel generator fueloil day tank, and IP3 Appendix R fuel oil storage tank and day tank once every ten years.Enhance the Diesel Fuel Monitoring Program toinclude quarterly sampling and analysis of the IP2 SBO/Appendix R diesel generator fuel oil day tank,IP2 security diesel fuel oil storage tank, IP2 securitydiesel fuel oil day tank, and IP3 Appendix R fuel oil storage tank. Particulates, water and sediment checks will be performed on the samples. Filterablesolids acceptance criterion will be less than or equalto 10mg/l. Water and sediment acceptance criterion will be less than or equal to 0.05%.Enhance the Diesel Fuel Monitoring Program toinclude thickness measurement of the bottom of the following tanks once every ten years. IP2: EDG fueloil 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 daytanks, EDG fuel oil storage tanks, Appendix R fuel oilstorage tank, and diesel fire pump fuel oil storage tank.Enhance the Diesel Fuel Monitoring Program tochange 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 pumpfuel oil storage tank; IP3: Appendix R fuel oil day tankand diesel fire pump fuel oil storage tank.Enhance the Diesel Fuel Monitoring Program tospecify acceptance criteria for thicknessmeasurements of the fuel oil storage tanks within the scope of the program.Enhance the Diesel Fuel Monitoring Program to directsamples be taken and include direction to remove water when detected.Revise applicable procedures to direct sampling of theonsite portable fuel oil contents prior to transferringthe contents to the storage tanks.Enhance the Diesel Fuel Monitoring Program to directthe addition of chemicals including biocide when thepresence of biological activity is confirmed.IP2:September 28, 2013IP3:December 12,2015NL-07-039NL-07-153 NL-08-057A.2.1.8A.3.1.8B.1.9Audit items128, 129,132,491, 492,510 NL-11-101Attachment 2Page 4 of 18
  1. COMMITMENTIMPLEMENTATION SCHEDULESOURCERELATEDLRA SECTION/ AUDIT ITEM5 Enhance the External Surfaces Monitoring Programfor IP2 and IP3 to include periodic inspections of systems in scope and subject to aging managementreview for license renewal in accordance with 10 CFR54.4(a)(1) and (a)(3). Inspections shall include areas surrounding the subject systems to identify hazards tothose systems. Inspections of nearby systems thatcould impact the subject systems will include SSCs that are in scope and subject to aging managementreview for license renewal in accordance with 10 CFR54.4(a)(2).IP2:September 28, 2013IP3:December 12,2015NL-07-039A.2.1.10A.3.1.10B.1.116 Enhance the Fatigue Monitoring Program for IP2 tomonitor steady state cycles and feedwater cycles orperform an evaluation to determine monitoring is notrequired. Review the number of allowed events and resolve discrepancies between reference documents and monitoring procedures.Enhance the Fatigue Monitoring Program for IP3 toinclude all the transients identified. Assure all fatigue analysis transients are included with the lowestlimiting numbers. Update the number of designtransients accumulated to date.IP2:September 28,2013IP3:December 12,2015NL-07-039NL-07-153A.2.1.11A.3.1.11B.1.12,Audit Item1647 Enhance the Fire Protection Program to inspectexternal surfaces of the IP3 RCP oil collectionsystems for loss of material each refueling cycle.Enhance the Fire Protection Program to explicitlystate that the IP2 and IP3 diesel fire pump enginesub-systems (including the fuel supply line) shall beobserved 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 gasleakage.Enhance the Fire Protection Program to specify thatthe IP2 and IP3 diesel fire pump engine carbon steelexhaust components are inspected for evidence of corrosion and cracking at least once each operating cycle.Enhance the Fire Protection Program for IP3 tovisually inspect the cable spreading room, 480V switchgear room, and EDG room CO 2 fire suppressionsystem for signs of degradation, such as corrosionand mechanical damage at least once every six months.IP2:September 28,2013IP3:December 12,2015NL-07-039A.2.1.12A.3.1.12B.1.13 NL-11-101Attachment 2Page 5 of 18
  1. COMMITMENTIMPLEMENTATION SCHEDULESOURCERELATEDLRA SECTION/ AUDIT ITEM8 Enhance the Fire Water Program to include inspectionof IP2 and IP3 hose reels for evidence of corrosion.

Acceptance criteria will be revised to verify nounacceptable signs of degradation.Enhance the Fire Water Program to replace all or testa sample of IP2 and IP3 sprinkler heads required for10 CFR 50.48 using guidance of NFPA 25 (2002edition), Section 5.3.1.1.1 before the end of the 50-year sprinkler head service life and at 10-yearintervals thereafter during the extended period ofoperation to ensure that signs of degradation, such as corrosion, are detected in a timely manner.Enhance the Fire Water Program to perform wallthickness evaluations of IP2 and IP3 fire protectionpiping on system components using non-intrusive techniques (e.g., volumetric testing) to identifyevidence of loss of material due to corrosion. Theseinspections will be performed before the end of the current operating term and at intervals thereafterduring the period of extended operation. Results ofthe 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 theinternal surface of foam based fire suppression tanks.

Acceptance criteria will be enhanced to verify nosignificant corrosion.IP2:September 28, 2013IP3:December 12,2015NL-07-039NL-07-153NL-08-014A.2.1.13A.3.1.13B.1.14Audit Items105, 106 NL-11-101Attachment 2Page 6 of 18

  1. COMMITMENTIMPLEMENTATION SCHEDULESOURCERELATEDLRA SECTION/ AUDIT ITEM9 Enhance the Flux Thimble Tube Inspection Programfor IP2 and IP3 to implement comparisons to wear rates identified in WCAP-12866. Include provisions tocompare data to the previous performances andperform evaluations regarding change to test frequency and scope.Enhance the Flux Thimble Tube Inspection Programfor IP2 and IP3 to specify the acceptance criteria as outlined in WCAP-12866 or other plant-specific valuesbased on evaluation of previous test results.Enhance the Flux Thimble Tube Inspection Programfor IP2 and IP3 to direct evaluation and performance of corrective actions based on tubes that exceed orare projected to exceed the acceptance criteria. Alsostipulate that flux thimble tubes that cannot be inspected over the tube length and cannot be shownby analysis to be satisfactory for continued service,must be removed from service to ensure the integrity of the reactor coolant system pressure boundary.IP2:September 28, 2013IP3:December 12,2015NL-07-039A.2.1.15A.3.1.15B.1.16 NL-11-101Attachment 2Page 7 of 18
  1. COMMITMENTIMPLEMENTATION SCHEDULESOURCERELATEDLRA SECTION/ AUDIT ITEM10 Enhance the Heat Exchanger Monitoring Program forIP2 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 samplecoolers Waste gas compressor heat exchangers SBO/Appendix R diesel jacket water heatexchanger (IP2 only)Enhance the Heat Exchanger Monitoring Program forIP2 and IP3 to perform visual inspection on heatexchangers where non-destructive examination, suchas eddy current inspection, is not possible due to heat exchanger design limitations.Enhance the Heat Exchanger Monitoring Program forIP2 and IP3 to include consideration of material-environment combinations when determining sample population of heat exchangers.Enhance the Heat Exchanger Monitoring Program forIP2 and IP3 to establish minimum tube wall thickness for the new heat exchangers identified in the scope ofthe program. Establish acceptance criteria for heatexchangers visually inspected to include no indication of tube erosion, vibration wear, corrosion, pitting, fouling, or scaling.IP2:September 28, 2013IP3:December 12,2015NL-07-039NL-07-153NL-09-018A.2.1.16A.3.1.16B.1.17,Audit Item 5211 Delete commitment

. DeletedNL-09-056 NL-11-101 NL-11-101Attachment 2Page 8 of 18

  1. COMMITMENTIMPLEMENTATION SCHEDULESOURCERELATEDLRA SECTION/ AUDIT ITEM12 Enhance the Masonry Wall Program for IP2 and IP3to specify that the IP1 intake structure is included in the program.IP2:September 28, 2013IP3:December 12,2015NL-07-039A.2.1.18A.3.1.18B.1.19 13Enhance the Metal-Enclosed Bus Inspection Programto add IP2 480V bus associated with substation A to the scope of bus inspected.Enhance the Metal-Enclosed Bus Inspection Programfor IP2 and IP3 to visually inspect the external surfaceof MEB enclosure assemblies for loss of material atleast 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 ofmaterial.Enhance the Metal-Enclosed Bus Inspection Programto add acceptance criteria for MEB internal visualinspections 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 ofindications 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 leastonce every ten years using quantitativemeasurements 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 siteprocedure to remove the reference to "re-torquing"connections for phase bus maintenance and boltedconnection maintenance.IP2:September 28, 2013IP3:December 12,2015NL-07-039NL-07-153NL-08-057A.2.1.19A.3.1.19B.1.20Audit Items124,133, 51914 Implement the Non-EQ Bolted Cable ConnectionsProgram for IP2 and IP3 as described in LRA SectionB.1.22.IP2:September 28,2013IP3:December 12,2015NL-07-039A.2.1.21A.3.1.21B.1.22 NL-11-101Attachment 2Page 9 of 18
  1. COMMITMENTIMPLEMENTATION SCHEDULESOURCERELATEDLRA SECTION/ AUDIT ITEM15 Implement the Non-EQ Inaccessible Medium-VoltageCable Program for IP2 and IP3 as described in LRA Section B.1.23.This new program will be implemented consistent withthe corresponding program described in NUREG-1801 Section XI.E3, Inaccessible Medium-VoltagePower Cables Not Subject To 10 CFR 50.49Environmental Qualification Requirements.IP2:September 28, 2013IP3:December 12,2015NL-07-039NL-07-153NL-11-032NL-11-096 NL-11-101A.2.1.22A.3.1.22B.1.23Audit item17316 Implement the Non-EQ Instrumentation Circuits TestReview Program for IP2 and IP3 as described in LRA Section B.1.24.This new program will be implemented consistent withthe corresponding program described in NUREG-1801 Section XI.E2, Electrical Cables and Connections Not Subject to 10 CFR 50.49Environmental Qualification Requirements Used inInstrumentation Circuits.IP2:September 28, 2013IP3:December 12, 2015NL-07-039NL-07-153A.2.1.23A.3.1.23B.1.24Audit item17317 Implement the Non-EQ Insulated Cables andConnections Program for IP2 and IP3 as described inLRA Section B.1.25.This new program will be implemented consistent withthe corresponding program described in NUREG-1801 Section XI.E1, Electrical Cables andConnections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.IP2:September 28,2013IP3:December 12,2015NL-07-039NL-07-153A.2.1.24A.3.1.24B.1.25Audit item17318 Enhance the Oil Analysis Program for IP2 to sampleand analyze lubricating oil used in the SBO/AppendixR diesel generator consistent with the oil analysis forother site diesel generators.Enhance the Oil Analysis Program for IP2 and IP3 tosample 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 andparticulates and laboratory analyses including defined acceptance criteria for all components included in thescope of this program. The program will specifycorrective actions in the event acceptance criteria are not met.Enhance the Oil Analysis Program for IP2 and IP3 toformalize trending of preliminary oil screening results as well as data provided from independent laboratories.IP2:September 28,2013IP3:December 12, 2015NL-07-039NL-11-101A.2.1.25A.3.1.25B.1.26 NL-11-101Attachment 2Page 10 of 18
  1. COMMITMENTIMPLEMENTATION SCHEDULESOURCERELATEDLRA SECTION/ AUDIT ITEM19 Implement the One-Time Inspection Program for IP2and IP3 as described in LRA Section B.1.27.This new program will be implemented consistent withthe corresponding program described in NUREG-1801,Section XI.M32, One-Time Inspection.IP2:September 28, 2013IP3:December 12,2015NL-07-039NL-07-153A.2.1.26A.3.1.26B.1.27Audit item17320 Implement the One-Time Inspection - Small BorePiping Program for IP2 and IP3 as described in LRA Section B.1.28.This new program will be implemented consistent withthe corresponding program described in NUREG-1801,Section XI.M35, One-Time Inspection of ASMECode Class I Small-Bore Piping.IP2:September 28, 2013IP3:December 12,2015NL-07-039NL-07-153A.2.1.27A.3.1.27B.1.28Audit item17321 Enhance the Periodic Surveillance and PreventiveMaintenance Program for IP2 and IP3 as necessary to assure that the effects of aging will be managedsuch that applicable components will continue toperform their intended functions consistent with the current licensing basis through the period of extended operation.IP2:September 28, 2013IP3:December 12, 2015NL-07-039A.2.1.28A.3.1.28B.1.2922 Enhance the Reactor Vessel Surveillance Program forIP2 and IP3 revising the specimen capsule withdrawal schedules to draw and test a standby capsule to cover the peak reactor vessel fluence expectedthrough the end of the period of extended operation.Enhance the Reactor Vessel Surveillance Program forIP2 and IP3 to require that tested and untestedspecimens from all capsules pulled from the reactorvessel are maintained in storage.IP2:September 28, 2013IP3:December 12, 2015NL-07-039A.2.1.31A.3.1.31B.1.3223 Implement the Selective Leaching Program for IP2and IP3 as described in LRA Section B.1.33.This new program will be implemented consistent withthe corresponding program described in NUREG-1801,Section XI.M33 Selective Leaching of Materials.IP2:September 28,2013IP3:December 12,2015NL-07-039NL-07-153A.2.1.32A.3.1.32B.1.33Audit item17324 Enhance the Steam Generator Integrity Program forIP2 and IP3 to require that the results of the conditionmonitoring assessment are compared to theoperational assessment performed for the prior operating cycle with differences evaluated.IP2:September 28,2013IP3:December 12,2015NL-07-039A.2.1.34A.3.1.34B.1.35 NL-11-101Attachment 2Page 11 of 18
  1. COMMITMENTIMPLEMENTATION SCHEDULESOURCERELATEDLRA SECTION/ AUDIT ITEM 25Enhance the Structures Monitoring Program toexplicitly specify that the following structures are included in the program.

Appendix R diesel generator foundation (IP3)

Appendix R diesel generator fuel oil tank vault(IP3) Appendix R diesel generator switchgear andenclosure (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 (IP2/3) 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-elevatedpassageway (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 pits (IP2/3)Enhance the Structures Monitoring Program for IP2and IP3 to clarify that in addition to structural steel and concrete, the following commodities (includingtheir anchorages) are inspected for each structure asapplicable.

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 monorailsIP2:September 28, 2013IP3:December 12,2015NL-07-039NL-07-153 NL-08-057A.2.1.35A.3.1.35B.1.36Audit items86, 87, 88,417 NL-11-101Attachment 2Page 12 of 18

  1. COMMITMENTIMPLEMENTATION SCHEDULESOURCERELATEDLRA SECTION/ AUDIT ITEM new fuel storage racks sumps, sump screens, strainers and flow barriersEnhance the Structures Monitoring Program for IP2and IP3 to inspect inaccessible concrete areas that are exposed by excavation for any reason. IP2 and IP3 will also inspect inaccessible concrete areas inenvironments where observed conditions inaccessible areas exposed to the same environment indicate that significant concrete degradation isoccurring.Enhance the Structures Monitoring Program for IP2and IP3 to perform inspections of elastomers (seals, gaskets, seismic joint filler, and roof elastomers) to identify cracking and change in material propertiesand for inspection of aluminum vents and louvers toidentify loss of material.Enhance the Structures Monitoring Program for IP2and IP3 to perform an engineering evaluation ofgroundwater samples to assess aggressiveness ofgroundwater 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 groundwater surrounding below-grade site structures andperform 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 spent fuel pool at least once every 3 months.Enhance the Structures Monitoring Program for IP2and IP3 to perform inspection of normally submergedconcrete portions of the intake structures at least onceevery 5 years. Inspect the baffling/grating partition and support platform of the IP3 intake structure at leastonce every 5 years.Enhance the Structures Monitoring Program for IP2and IP3 to perform inspection of the degraded areasof the water control structure once per 3 years ratherthan the normal frequency of once per 5 years during the PEO.NL-08-127Audit Item360Audit Item358 NL-11-101Attachment 2Page 13 of 18
  1. COMMITMENTIMPLEMENTATION SCHEDULESOURCERELATEDLRA SECTION/ AUDIT ITEMEnhance the Structures Monitoring Program toinclude more detailed quantitative acceptance criteria for inspections of concrete structures in accordancewith ACI 349.3R, "Evaluation of Existing NuclearSafety-Related Concrete Structures" prior to the period of extended operation (PEO)

.NL-11-032NL-11-10126 Implement the Thermal Aging Embrittlement of CastAustenitic Stainless Steel (CASS) Program for IP2 and IP3 as described in LRA Section B.1.37.This new program will be implemented consistent withthe corresponding program described in NUREG-1801,Section XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) Program.IP2:September 28, 2013IP3:December 12, 2015NL-07-039NL-07-153A.2.1.36A.3.1.36B.1.37Audit item17327 Implement the Thermal Aging and Neutron IrradiationEmbrittlement of Cast Austenitic Stainless Steel(CASS) Program for IP2 and IP3 as described in LRA Section B.1.38.This new program will be implemented consistent withthe corresponding program described in NUREG-1801 Section XI.M13, Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel(CASS) Program.IP2:September 28,2013IP3:December 12, 2015NL-07-039NL-07-153A.2.1.37A.3.1.37B.1.38Audit item17328 Enhance the Water Chemistry Control - ClosedCooling Water Program to maintain water chemistry of the IP2 SBO/Appendix R diesel generator coolingsystem per EPRI guidelines.Enhance the Water Chemistry Control - ClosedCooling Water Program to maintain the IP2 and IP3security generator and fire protection diesel coolingwater pH and glycol within limits specified by EPRI guidelines.IP2:September 28, 2013IP3:December 12,2015NL-07-039NL-08-057A.2.1.39A.3.1.39B.1.40Audit item50929 Enhance the Water Chemistry Control - Primary andSecondary Program for IP2 to test sulfates monthly inthe RWST with a limit of <150 ppb.IP2:September 28,2013NL-07-039A.2.1.40B.1.4130 For aging management of the reactor vessel internals,IPEC will (1) participate in the industry programs forinvestigating and managing aging effects on reactorinternals; (2) evaluate and implement the results of the industry programs as applicable to the reactorinternals; 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 reactor internals to the NRC for review and approval.IP2:September 28,2011IP3:December 12,2013NL-07-039A.2.1.41A.3.1.41 NL-11-101Attachment 2Page 14 of 18

  1. COMMITMENTIMPLEMENTATION SCHEDULESOURCERELATEDLRA SECTION/ AUDIT ITEM31 Additional P-T curves will be submitted as requiredper 10 CFR 50, Appendix G prior to the period of extended operation as part of the Reactor VesselSurveillance Program.IP2:September 28, 2013IP3:December 12,2015NL-07-039A.2.2.1.2A.3.2.1.2 4.2.3 32As required by 10 CFR 50.61(b)(4), IP3 will submit aplant-specific safety analysis for plate B2803-3 to the NRC three years prior to reaching the RTPTSscreening criterion. Alternatively, the site may choose to implement the revised PTS rule when approved.IP3:December 12, 2015NL-07-039NL-08-127A.3.2.1.4 4.2.533 At least 2 years prior to entering the period ofextended operation, for the locations identified in LRATable 4.3-13 (IP2) and LRA Table 4.3-14 (IP3), underthe 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 accountingfor the effects of reactor water environment. Thisincludes applying the appropriate Fen factors to valid CUFs determined in accordance with one of thefollowing:1. For locations in LRA Table 4.3-13 (IP2) and LRATable 4.3-14 (IP3), with existing fatigue analysis validfor the period of extended operation, use the existing CUF.2. Additional plant-specific locations with a valid CUFmay 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 ASMEcode 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.IP2:September 28,2011IP3:December 12,2013CompleteNL-07-039NL-07-153NL-08-021NL-10-082A.2.2.2.3A.3.2.2.3 4.3.3Audit item146 NL-11-101Attachment 2Page 15 of 18

  1. COMMITMENTIMPLEMENTATION SCHEDULESOURCERELATEDLRA SECTION/ AUDIT ITEM34 IP2 SBO / Appendix R diesel generator will beinstalled and operational by April 30, 2008. This committed change to the facility meets therequirements of 10 CFR 50.59I (c)(1) and, therefore, alicense amendment pursuant to 10 CFR 50.90 is not required.April 30, 2008CompleteNL-07-078NL-08-074NL-11-1012.1.1.3.535 Perform a one-time inspection of representativesample area of IP2 containment liner affected by the 1973 event behind the insulation, prior to entering the period of extended period of operation, to assure linerdegradation is not occurring in this area.Perform a one-time inspection of representativesample area of the IP3 containment steel liner at thejuncture with the concrete floor slab, prior to enteringthe period of extended period of operation, to assureliner degradation is not occurring in this area.Any degradation will be evaluated for updating of thecontainment liner analyses as needed.IP2:September 28, 2013IP3:December 12,2015NL-08-127NL-11-101NL-09-018Audit Item 2736 Perform a one-time inspection and evaluation of asample of potentially affected IP2 refueling cavity concrete prior to the period of extended operation.The sample will be obtained by core boring therefueling cavity wall in an area that is susceptible to exposure to borated water leakage. The inspectionwill include an assessment of embedded reinforcingsteel.Additional core bore samples will be taken, if theleakage is not stopped, prior to the end of the first tenyears of the period of extended operation.A sample of leakage fluid will be analyzed todetermine the composition of the fluid. If additionalcore samples are taken prior to the end of the first tenyears of the period of extended operation, a sample of leakage fluid will be analyzed.IP2:September 28, 2013NL-08-127NL-11-101NL-09-056NL-09-079Audit Item35937 Enhance the Containment Inservice Inspection (CII-IWL) Program to include inspections of thecontainment using enhanced characterization of degradation (i.e., quantifying the dimensions of notedindications through the use of optical aids) during theperiod of extended operation. The enhancement includes obtaining critical dimensional data ofdegradation where possible through directmeasurement or the use of scaling technologies for photographs, and the use of consistent vantage points for visual inspections.IP2:September 28,2013IP3:December 12, 2015NL-08-127Audit Item361 NL-11-101Attachment 2Page 16 of 18
  1. COMMITMENTIMPLEMENTATION SCHEDULESOURCERELATEDLRA SECTION/ AUDIT ITEM38 For Reactor Vessel Fluence, should future coreloading patterns invalidate the basis for the projected values of RTpts or C VUSE, updated calculations willbe provided to the NRC.IP2:September 28, 2013IP3:December 12,2015NL-08-1434.2.139 DeletedNL-09-07940 Evaluate plant specific and appropriate industryoperating experience and incorporate lessons learnedin establishing appropriate monitoring and inspection frequencies to assess aging effects for the new aging management programs. Documentation of theoperating experience evaluated for each new programwill be available on site for NRC review prior to the period of extended operation.IP2:September 28,2013IP3:December 12,2015NL-09-106B.1.6B.1.22B.1.23 B.1.24 B.1.25B.1.27B.1.28 B.1.33B.1.37B.1.3841 IPEC will perform an inspection of inspect steamgenerators for both units to assess the condition ofthe divider plate assembly. The examinationtechnique used will be capable of detecting PWSCC in the steam generator divider plate assemblyassemblies. The IP2 steam generator divider plateinspections will be completed within the first ten yearsof the period of extended operation (PEO). The IP3 steam generator divider plate inspections will becompleted within the first refueling outage followingthe beginning of the PEO.IP2:After thebeginning of thePEO and prior toSeptember 28, 2023IP3:Prior to the endof the firstrefueling outage following thebeginning of the PEO.NL-11-032NL-11-074NL-11-090 NL-11-101 N/A NL-11-101Attachment 2Page 17 of 18
  1. COMMITMENTIMPLEMENTATION SCHEDULESOURCERELATEDLRA SECTION/ AUDIT ITEM42 IPEC will develop a plan for each unit to address thepotential for cracking of the primary to secondary pressure boundary due to PWSCC of tube-to-tubesheet welds using one of the following twooptions.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 thatthe tubesheet cladding and welds are not susceptibleto PWSCC, or redefining the pressure boundary in which the tube-to-tubesheet weld is no longer included and, therefore, is not required for reactorcoolant pressure boundary function. The redefinitionof the reactor coolant pressure boundary must be approved by the NRC as a license amendmentrequest.Option 2 (Inspection)IPEC will perform a one-time inspection of arepresentative 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 repairor engineering evaluation to justify continued service, as appropriate, andb. An ongoing monitoring program will beestablished to perform routine tube-to-tubesheet weld inspections for the remaining life of the steam generators.IP2:Prior to March2024 IP3: Prior to the end of the firstrefueling outagefollowing the beginning of the PEO.IP2:Between March 2020 and March2024IP3: Prior to theend of the firstrefueling outage following the beginning of the PEO.NL-11-032NL-11-074NL-11-090NL-11-096 N/A43 IPEC will review design basis ASME Code Class 1fatigue evaluations to determine whether the NUREG/CR-6260 locations that have been evaluated for the effects of the reactor coolant environment onfatigue usage are the limiting locations for the IP2 andIP3 configurations. If more limiting locations are identified, the most limiting location will be evaluatedfor the effects of the reactor coolant environment onfatigue usage.IPEC will use the NUREG/CR-6909 methodology inthe evaluation of the limiting locations consisting ofnickel alloy, if any.IP2:Prior to September 28, 2013IP3: Prior toDecember 12,2015NL-11-032NL-11-101 4.3.3 NL-11-101Attachment 2Page 18 of 18
  1. COMMITMENTIMPLEMENTATION SCHEDULESOURCERELATEDLRA SECTION/ AUDIT ITEM44 IPEC will include written explanation and justificationof any user intervention in future evaluations using the WESTEMS "Design CUF" module.Within 60 daysof issuance ofthe renewedoperating license.IP2:Prior toSeptember 28,2013IP3: Prior toDecember 12,2015NL-11-032NL-11-101 N/A45 IPEC will not use the NB-3600 option of theWESTEMS program in future design calculations untilthe issues identified during the NRC review of theprogram has have been resolved.Within 60 da ysof issuance ofthe renewedoperating license.IP2:Prior toSeptember 28,2013IP3: Prior toDecember 12,2015NL-11-032NL-11-101 N/A46 Include in the IP2 ISI Program that IPEC will performtwenty-five volumetric weld metal inspections ofsocket welds during each 10-year ISI intervalscheduled as specified by IWB-2412 of the ASME Section XI Code during the period of extendedoperation.In lieu of volumetric examinations, destructiveexaminations may be performed, where onedestructive examination may be substituted for twovolumetric examinations.IP2:Prior toSeptember 28,2013NL-11-032NL-11-074 N/A ATTACHMENT 3 TO NL-11-101AMENDMENT 9 TO THE LICENSE RENEWAL APPLICATION (LRA)REACTOR VESSEL INSPECTION PROGRAM ERRATAENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3DOCKET NOS. 50-247 AND 50-286 NL-11-101Attachment 3Page 1 of 1INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3AMMENMENT 9 TO LICENSE RENEWAL APPLICATION (LRA)REACTOR VESSEL INSPECTION PROGRAM ERRATAThe LRA is revised as described below. (underline - added, strikethrough - deleted)NL-10-063 submitted Amendment 9 to the LRA - Reactor Vessel Internals Program, however, the update toSection 3.1.2.2.12 was inadvertently not included. The update is provided below.3.1.2.2.12 Cracking due to Stress Corrosion Cracking and Irradiation-Assisted Stress Corrosion Cracking (IASCC)Cracking due to SCC and IASCC could occur in PWR stainless steel reactor internals exposed to reactorcoolant will be managed by the Water Chemistry Control - Primary and Secondary and Reactor VesselInternals (RVI) Programs. The RVI Program will implement the EPRI Pressurized Water Reactor InternalsInspection and Evaluation Guidelines, MRP- 227. The RVI Program will use nondestructive examinations(NDE) and other inspection methods to manage aging effects for reactor vessel internals.To manage crackingin vessel internals components, IPEC maintains theWater Chemistry Control

- Primary and SecondaryProgram and will (1) participate in the industry programs for investigating and managing aging effects onreactor internals; (2) evaluate and implement the results of the industry programs as applicable to the reactorinternals; and (3) upon completion of these programs, but not less than 24 months before entering the periodof extended operation, submit an inspection plan for reactor internals to the NRC for review and approval. TheIPEC commitment to these RVI programs is included in UFSAR Supplement, Appendix A,Sections A.2.1.41andA.3.1.41.

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