ML16083A471

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Redacted - Updated Final Safety Analysis Report (UFSAR) Part 6 - November 2015
ML16083A471
Person / Time
Site: Pilgrim
Issue date: 11/30/2015
From:
Entergy Nuclear Operations
To: Booma Venkataraman
Plant Licensing Branch 1
Ventkataraman V, DORL/LPLI-I, 415-2934
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ML16083A494 List:
References
CAC MF7229
Download: ML16083A471 (248)
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PNPS-FSAR APPENDIX Q SUPPLEMENTAL RELOAD LICENSING REPORTS TABLE OF CONTENTS Section Title Page Q.1 INTRODUCTION Q.1-1 Q-i Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX Q LIST OF TABLES Table Title Not Used Q-ii Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX Q LIST OF FIGURES Figure Title Q.2-1 through QD-2 Deleted Q-iii Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX Q SUPPLEMENTAL RELOAD LICENSING REPORTS Q.1 INTRODUCTION The latest plant supplemental reload licensing report is "Suppleemental Reload Licensing Report for Pilgrim Nuclear Power Station Reeload 20/Cycle 21", 000N9841-SRLR, Revision 0, Class I, Feebruary 2015 (ECH-NE- 15-00008, Revision 0). This report provides the cycle core loading pattern and the results of the cycle specific nuclear transient and vessel overpressurization analyses. This report also addresses the applicability of generic stability and accident analyses. Refer to this report for reload information.

All other sections of Appendix Q have been removed from the FSAR.

References for previous cycle specific reports are as follows:

RELOAD SUBMITTAL REFERENCES Reload No. Reference 1 "Reload 1 Licensing Submittal of Pilgrim Nuclear Power Station", NEDO-20286, Revision 1, February 1974.

2 "General Electric Boiling Water Reactor Reload No. 2 Licensing Submittal for Pilgrim Nuclear Power Station Unit 1", NEDO-20855, June 1975.

"Reload No. 2 Licensing Submittal for Pilgrim Nuclear Power Station Unit 1 with Bypass Flow Holes Plugged",

NEDO-20855-01, September 1975.

3 "General Electric Boiling Water Reactor Reload No. 3 Licensing Submittal for Pilgrim Nuclear Power Station Unit 1", NEDO-21460-01, May 1977.

4 "Supplemental Reload Licensing Submittal for Pilgrim Nuclear Power Station Unit 1 Reload 4", NEDO-24224, November 1979.

"Supplement 1 to Supplemental Reload Licensing Submittal for Pilgrim Nuclear Power Station Unit 1 Reload 4",

NEDO-24224-1, Supplement 1, March 1980.

"Supplement 2 to Supplemental Reload Licensing Submittal for Pilgrim Nuclear Power Station Unit 1 Reload 4 (Load Line Limit Analysis Reverification)", NEDO-24224-2, April 1981.

5 Supplemental Reload Licensing Submittal for Pilgrim Nuclear Power Station Unit 1 Reload 5", Y1003J01A28, Revision 2, February 1983.

Q.1-1 Rev. 30 - Nov. 2015

PNPS-FSAR Reload No. Reference 6 "Supplement Reload Licensing Submittal for Pilgrim Nuclear Power Station Unit 1 Reload 6", 23A1694, March 1984.

7 "Supplemental Reload Licensing Submittal for Pilgrim Nuclear Power Station Reload 7", 23A4800, December 1986.

8 "Supplemental Reload Licensing Report for Pilgrim Nuclear Power Station Reload 8, Cycle 9," 23A7101, March 1991.

(Note: the generator load reduction without bypass analyzed in the above licensing report is updated in another analysis (BECo SUDDS 91-44). All results presented here reflect this updated analysis).

9 "Supplemental Reload Licensing Report for Pilgrim Nuclear Power Station Reload 9, Cycle 10" 23A7195, February 1993.

10 Supplemental Reload Licensing Report for Pilgrim Nuclear Power Station Reload 10, Cycle 11, 24A5172, Revision 0, February 1995.

11 Supplemental Reload Licensing Report for Pilgrim Nuclear Power Station Reload 11/Cycle 12, J11-03014SRL, Revision 0), February 1997.

12 "Supplemental Reload Licensing Report for Pilgrim Nuclear Power Station Reload 12/Cycle 13", J11-03474-10 SRLR, Revision 0, Class I, April 1999 (SUDDS RF99-142).

13 "Supplemental Reload Licensing Report for Pilgrim Nuclear Power Station Reload 13/Cycle 14", J11-03878-10 SRLR, Revision 0, Class I, February 2001 (SUDDS/RF 00-112).

14 "Supplemental Reload Licensing Report for Pilgrim Nuclear Power Station Reload 14/Cycle 15", 0000-0008-6613-SRLR, Revision 1, Class I, March 2003 (SUDDS RFO258).

15 "Supplemental Reload Licensing Report for Pilgrim Nuclear Power Station Reload 15/Cycle 16", 0000-0030-7302-SRLR, Revision 0, Class I, February 2005.

16 "Supplemental Reload Licensing Report for Pilgrim Nuclear Power Station Reload 16/Cycle 17", 0000-0056-6173-SRLR, Revision 0, Class I, February 2007.

17 "Supplemental Reload Licensing Report for Pilgrim Nuclear Power Station Reload 17/Cycle 18", 0000-0083-7478-SRLR, Revision 0, Class I, February 2009.

Q.1-2 Rev. 30 - Nov. 2015

PNPS-FSAR 18 "Supplemeental Reload Licensing Report for Pilgrim Nuclear Power Station Reload 2019/Cycle 210",

0000-0147-0084-SRLRN9841-SRLR,, Revision 01, Class I, February 2015April 2013.

Q.1-3 Rev. 30 - Nov. 2015

PNPS-FSAR Sections Q.2, Q.A, Q.B, Q.C, and Q.D have been removed.

Please refer to "Supplemental Reload Licensing Report for Pilgrim Nuclear Power Station Reload 19/Cycle 20", 0000-0147-0084-SRLR, Revision 1, Class I, April 2013 (ECH-NE-13-00002, Revision 0), and "Updated Loading Pattern GESTAR II Licensing Assessment for Pilgrim Cycle 20", GNF S-0000-0160-1647, Revision 1, April 2013 (ECH-NE-13-00002, Revision 0).

Q.1-4 Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX S LICENSE RENEWAL COMMITMENTS TABLE OF CONTENTS Section Title Page S.1 Supplement for Renewed Operating License S.1-1 S.2 Aging Management Programs and Activities S.2-1 S.2.1 Boraflex Monitoring Program S.2-3 S.2.2 Buried Piping and Tanks Inspection Program S.2-3 S.2.3 BWR CRD Return Line Nozzle Program S.2-4 S.2.4 BWR Feedwater Nozzle Program S.2-4 S.2.5 BWR Penetrations Program S.2-5 S.2.6 BWR Stress Corrosion Cracking Program S.2-5 S.2.7 BWR Vessel ID Attachment Welds Program S.2-5 S.2.8 BWR Vessel Internals Program S.2-6 S.2.9 Containment Leak Rate Program S.2-6 S.2.10 Diesel Fuel Monitoring Program S.2-6 S.2.11 Environmental Qualification (EQ) of Electric Components Program S.2-7 S.2.12 Fatigue Monitoring Program S.2-7 S.2.13 Fire Protection Program S.2-8 S.2.14 Fire Water System Program S.2-8 S.2.15 Flow-Accelerated Corrosion Program S.2-9 S.2.16 Heat Exchanger Monitoring Program S.2-9 S.2.17 Inservice Inspection - Containment Inservice Inspection (CII) Program S.2-10 S.2.18 Inservice Inspection Inspection(ISI)Program S.2-10 S.2.19 Instrument Air Quality Program S.2-11 S.2.20 Metal-Enclosed Bus Inspection Program S.2-11 S.2.21 Non-EQ Inaccessible Medium-Voltage Cable Program S.2-12 S.2.22 Non-EQ Instrumentation Circuits Test Review Program S.2-12 S.2.23 Non-EQ Insulated Cables and Connections Program S.2-13 S.2.24 Oil Analysis Program S.2-13 S.2.25 One-Time Inspection Program S.2-13 S.2.26 Periodic Surveillance and Preventive Maintenance Program S.2-15 S.2.27 Reactor Head Closure Studs Program S.2-16 S.2.28 Reactor Vessel Surveillance Program S.2-16 S-i Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX S LICENSE RENEWAL COMMITMENTS TABLE OF CONTENTS Section Title Page S.2.29 Selective Leaching Program S.2-17 S.2.30 Service Water Integrity Program S.2-18 S.2.31 Structures Monitoring - Masonry Wall Program S.2-18 S.2.32 Structures Monitoring - Structures Monitoring Program S.2-18 S.2.33 Structures Monitoring - Water Control Structures Monitoring Program S.2-19 S.2.34 System Walkdown Program S.2-19 S.2.35 Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program S.2-20 S.2.36 Water Chemistry Control - Auxiliary Systems Program S.2-20 S.2.37 Water Chemistry Control - BWR Program S.2-20 S.2.38 Water Chemistry Control - Closed Cooling Water Program S.2-21 S.2.39 Bolting Integrity Program S.2-21 S.2.40 Bolted Cable Connections Program S.2-22 S.2.41 Neutron Absorber Monitoring Program S.2-22 S.2.42 Protective Containment Coatings S.2-22 S.3 Evaluation of Time-Limited Aging Analyses S.3-1 S.3.1 Reactor Vessel Neutron Embrittlement S.3-1 S.3.1.1 Reactor Vessel Fluence S.3-1 S.3.1.2 Pressure-Temperature Limits S.3-2 S.3.1.3 Charpy Upper-Shelf Energy S.3-2 S.3.1.4 Adjusted Reference Temperature S.3-4 S.3.1.5 Reactor Vessel Circumferential Weld Inspection Relief S.3-5 S.3.1.6 Reactor Vessel Axial Weld Failure Probability S.3-6 S.3.2 Metal Fatigue S.3-7 S.3.2.1 Class 1 Metal Fatigue S.3-7 S.3.2.2 Non-Class 1 Metal FatigueS.3-7 S.3.2.3 Environmental Effects on FatigueS.3-8 S.3.3 Environmental Qualification of Electrical Components S.3-9 S.3.4 Fatigue of Primary Containment, Attached Piping, and Components S.3-9 S.4 References S.4-1 S-ii Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX S LICENSE RENEWAL COMMITMENTS S.2 Aging Management Programs and Activities The integrated plant assessment for license renewal identified aging management programs necessary to provide reasonable assurance that components within the scope of license renewal will continue to perform their intended functions consistent with the current licensing basis (CLB) for the period of extended operation. This section describes the aging management programs and activities required during the period of extended operation.

All aging management programs have been initiated prior to entering the period of extended operation.

PNPS quality assurance (QA) procedures, review and approval processes, and administrative controls are implemented in accordance with the requirements of 10 CFR 50, Appendix B. The Entergy Quality Assurance Program applies to safety-related structures and components. Corrective actions and administrative (document) control for both safety-related and nonsafety-related structures and components are accomplished per the existing PNPS corrective action program and document control program and are applicable to all aging management programs and activities that will be required during the period of extended operation. The confirmation process is part of the corrective action program and includes reviews to assure that proposed actions are adequate, tracking and reporting of open corrective actions, and review of corrective action effectiveness. Any follow-up inspection required by the confirmation process is documented in accordance with the corrective action program.

The corrective action controls of the Entergy (10 CFR Part 50, Appendix B) Quality Assurance Program are applicable to all aging management programs and activities that will be required during the period of extended operation.

Operating experience is used at PNPS to enhance plant aging management programs. External nuclear industry operating experience, including operating experience related to the effects of aging, is screened, evaluated, and acted on to prevent or mitigate the consequences of similar events or conditions.

External operating experience includes NRC generic communications (e.g., generic letters, bulletins, information notices, and regulatory information summaries) and other documents (e.g., 10 S.2-1 Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX S LICENSE RENEWAL COMMITMENTS CFR 21 reports, licensee event reports, vendor bulletins, information for INPO and other industry groups). Internal operating experience includes information from event investigation reports, trending reports, lessons learned from in-house events, self-assessments, and the 10 CFR 50 Appendix B corrective action process. Operating experience is operating information pertinent to plant safety and reliability originating both within and outside the Entergy organization. Operating experience information describes events, issues, equipment failures, etc.,

including those resulting from the effects of aging, that represent opportunities to apply lessons learned to avoid negative consequences or to recreate positive experiences.

Entergy procedures provide direction for the evaluation of operating experience continuing through the period of extended operation. These procedures implement two programs that monitor, on an ongoing basis, industry and plant-specific operating experience that includes, but is not limited to, operating experience related to the effects of aging on in-scope structures and components. These programs are the Operating Experience Program and the Corrective Action Program. Procedures for these programs provide a method for evaluating and initiating action for operating experience information at all Entergy nuclear stations.

The primary objective of assessing operating experience is to identify and transfer lessons learned into actions that enhance the safety and reliability of Entergys nuclear plants. Operating experience involving age-related degradation mechanisms or aspects of programs that manage the effects of aging is provided to the respective program point of contact. Operating experience involving age-related degradation mechanisms for which no program can be readily identified is reviewed as documented in a written evaluation by the aging management operating experience point of contact for the station. The evaluations completed under these two programs ensure that aging management programs remain effective in managing the effects of aging for which they are credited.

S.2-2 Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX S LICENSE RENEWAL COMMITMENTS S.2.1 Boraflex Monitoring Program The Boraflex Monitoring Program assures that degradation of the Boraflex panels in the spent fuel racks does not compromise the criticality analysis in support of the design of the spent fuel storage racks. The program relies on (1) neutron attenuation testing, (2) determination of boron loss through correlation of silica levels in spent fuel pool water samples and periodic areal density measurements, and (3) analysis of criticality to assure that the required 5% subcriticality margin is maintained.

License renewal commitment 49 governs implementation of this program. This program is being tracked by administrative controls.

S.2.2 Buried Piping and Tanks Inspection Program The Buried Piping and Tanks Inspection Program included in its scope the Firewater, CST inlet to HPCI/RCIC, SSW, SBO fuel and coolant, EDG fuel, and the SBGTS piping.

The Firewater piping is addressed through the adoption of NFPA25 flow testing. The CST SS piping has been addressed through the GW testing, and is subject to future surveillance. The SSW inlet piping was determined to be non-susceptible. The SSW outlet has been modified with a non-susceptible CIPP, and is subject to the NRC credited Service Water Integrity Program, GL 89-13, which include regular internal visual surveillance and ongoing flow rate testing. The two EDG fuel oil tanks have been NDE tested and both tanks are subject to future NDE testing. The SBO, EDG, and the SBGTS piping have been excavated and inspected and are subject to future inspections. The Cathodic Protection Systems are operable and subject to ongoing surveillance. Pilgrim has committed to the Corporate Buried Pipe and Tank Program for all underground piping.

These inspections will be conducted at least once every ten years during the PEO. If measured soil resistivity is <20,000 ohms or scores higher than 10 points using the American Water Works Association C10S, or if backfill is found to have damaged the coating, the length of SBGTS pipe inspected will be doubled during subsequent ten (10) year inspections.

The two buried carbon steel EDG fuel oil tanks were inspected prior to the PEO and will be reinspected on a ten (10) year interval following the PEO.

S.2-3 Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX S LICENSE RENEWAL COMMITMENTS If trending within the corrective action program identifies susceptible locations, the areas with a history of corrosion problems are evaluated for the need for additional inspection, alternate coating, or replacement.

License renewal commitment 1 governs implementation of this program.

This program is being tracked by administrative controls.

S.2.3 BWR CRD Return Line Nozzle Program Under the BWR CRD Return Line Nozzle Program, PNPS has cut and capped the CRD return line nozzle to mitigate cracking and continues in-service inspection (ISI) examinations to monitor the effects of crack initiation and growth on the intended function of the control rod drive return line nozzle and cap. ISI examinations include ultrasonic inspection of the nozzle-to-vessel weld and ultrasonic inspection of the dissimilar metal weld overlay at the nozzle.

License renewal commitment 30 specifies enhancement(s) to this program.

This program is being tracked by administrative controls.

S.2.4 BWR Feedwater Nozzle Program Under the BWR Feedwater Nozzle Program, PNPS has removed feed water blend radii flaws, removed feed water nozzle cladding, and installed a triple-sleeve-double-piston sparger to mitigate cracking. This program continues with enhanced in-service inspection (ISI) of the feed water nozzles in accordance with the requirements of ASME Section XI, Subsection IWB and the recommendation of General Electric (GE) NE-523-A71-0594 to monitor the effects of cracking on the intended function of the feed water nozzles.

This program is being tracked by administrative controls.

S.2-4 Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX S LICENSE RENEWAL COMMITMENTS S.2.5 BWR Penetrations Program The BWR Penetrations Program includes (a) inspection and flaw evaluation in conformance with the guidelines of staff-approved boiling water reactor vessel and internals project (BWRVIP) documents BWRVIP-27 and BWRVIP-49 and (b) monitoring and control of reactor coolant water chemistry in accordance with the guidelines of BWRVIP-130 to ensure the long-term integrity of vessel penetrations and nozzles.

This program is being tracked by administrative controls.

S.2.6 BWR Stress Corrosion Cracking Program The BWR Stress Corrosion Cracking Program includes (1) preventive measures to mitigate intergranular stress corrosion cracking (IGSCC), and (2) inspection and flaw evaluation to monitor IGSCC and its effects on reactor coolant pressure boundary components made of stainless steel or CASS.

PNPS has taken actions to prevent IGSCC and will continue to use materials resistant to IGSCC for component replacements and repairs following the recommendations delineated in NUREG-0313, Generic Letter 88-01, and the staff-approved BWRVIP-75 report.

Inspection of piping identified in NRC Generic Letter 88-01 to detect and size cracks is performed in accordance with the staff positions on schedule, method, personnel qualification and sample expansion included in the generic letter and the staff-approved BWRVIP-75 report.

License renewal commitment 2 specifies enhancement(s) to this program.

This program is being tracked by administrative controls.

S.2.7 BWR Vessel ID Attachment Welds Program The BWR Vessel ID Attachment Welds Program includes (1) inspection and flaw evaluation in accordance with the guidelines of staff-approved BWR Vessel and Internals Project (BWRVIP) BWRVIP-48, and (2) monitoring and control of reactor coolant water chemistry in accordance with the guidelines of BWRVIP-130 to ensure the long-term integrity and safe operation of reactor vessel inside diameter (ID) attachment welds and support pads.

This program is being tracked by administrative controls.

S.2-5 Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX S LICENSE RENEWAL COMMITMENTS S.2.8 BWR Vessel Internals Program The BWR Vessel Internals Program includes (a) inspection, flaw evaluation, and repair in conformance with the applicable, staff-approved BWR Vessel and Internals Project (BWRVIP) documents, and (b) monitoring and control of reactor coolant water chemistry in accordance with the guidelines of BWRVIP-130 to ensure the long-term integrity of vessel internals components.

License renewal commitments 3, 33, 34, and 37 specify enhancement(s) to this program.

This program is being tracked by administrative controls.

S.2.9 Containment Leak Rate Program As described in 10 CFR 50, Appendix J, containment leak rate tests are required to assure that (a) leakage through primary reactor containment and systems and components penetrating primary containment shall not exceed allowable values specified in technical specifications or associated bases and (b) periodic surveillance of reactor containment penetrations and isolation valves is performed so that proper maintenance and repairs are made during the service life of containment, and systems and components penetrating primary containment. Corrective actions are taken if leakage rates exceed acceptance criteria.

This program is being tracked by administrative controls.

S.2.10 Diesel Fuel Monitoring Program The Diesel Fuel Monitoring Program entails sampling to ensure that adequate diesel fuel quality is maintained to prevent plugging of filters, fouling of injectors, and corrosion of fuel systems.

Exposure to fuel oil contaminants such as water and microbiological organisms is minimized by periodic draining and cleaning of tanks and by verifying the quality of new oil before its introduction into the storage tanks.

License renewal commitments 4, 5, 6, and 38 specify enhancement(s) to this program.

This program is being tracked by administrative controls.

S.2-6 Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX S LICENSE RENEWAL COMMITMENTS S.2.11 Environmental Qualification (EQ) of Electric Components Program The PNPS EQ of Electric Components program manages the effects of thermal, radiation, and cyclic aging through the use of aging evaluations based on 10 CFR 50.49(f) qualification methods. As required by 10 CFR 50.49, EQ components not qualified for the current license term are refurbished, replaced, or their qualification extended prior to reaching the aging limits established in the evaluations. Aging evaluations for EQ components are considered time-limited aging analyses (TLAAs) for license renewal.

This program is being tracked by administrative controls.

S.2.12 Fatigue Monitoring Program In order not to exceed design limits on fatigue usage, the Fatigue Monitoring Program tracks the number of critical thermal and pressure transients for selected reactor coolant system components. The program ensures the validity of analyses that explicitly assumed a fixed number of thermal and pressure fatigue transients by assuring that the actual effective number of transients does not exceed the assumed limit.

The transient cycles tracked by this program are referenced in Section 4.2.6.

License renewal commitments 31 and 35 specify enhancement(s) to this program.

This program is being tracked by administrative controls.

S.2-7 Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX S LICENSE RENEWAL COMMITMENTS S.2.13 Fire Protection Program The Fire Protection Program includes a fire barrier inspection and a diesel-driven fire pump inspection. The fire barrier inspection requires periodic visual inspection of fire barrier penetration seals, fire barrier walls, ceilings, and floors, and periodic visual inspection and functional tests of fire rated doors to ensure that their operability is maintained. The diesel-driven fire pump inspection requires that the pump be periodically tested and system components internally inspected to ensure that the fuel supply line can perform its intended function. The program also includes periodic inspection and testing of the Halon fire suppression system.

Corrective actions, confirmation process, and administrative controls in accordance with the requirements of 10 CFR 50 Appendix B are applied to the Fire Protection Program.

License renewal commitments 7 and 8 specify enhancement(s) to this program.

This program is being tracked by administrative controls.

S.2.14 Fire Water System Program The Fire Water System Program applies to water-based fire protection systems that consist of sprinklers, nozzles, fittings, valves, hydrants, hose stations, standpipes, and aboveground and underground piping and components that are tested in accordance with applicable National Fire Protection Association (NFPA) codes and standards. Such testing assures functionality of systems. To determine if significant corrosion has occurred in water-based fire protection systems, periodic flushing, system performance testing, and inspections are conducted. Also, many of these systems are normally maintained at required operating pressure and monitored such that leakage resulting in loss of system pressure is immediately detected and corrective actions initiated.

In addition, wall thickness evaluations of fire protection piping are periodically performed on system components using non-intrusive techniques (e.g., volumetric testing) to identify evidence of loss of material due to corrosion.

A sample of sprinkler heads will be inspected using the guidance of NFPA 25 (2002 Edition) Section 5.3.1.1.1, which states, Where sprinklers have been in place for 50 years, they shall be replaced or representative samples from one or more sample areas shall be submitted to a recognized testing laboratory for field service testing.

S.2-8 Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX S LICENSE RENEWAL COMMITMENTS This sampling will be repeated every 10 years after initial field service testing.

License renewal commitments 9, 10, and 11 specify enhancement(s) to this program.

This program is being tracked by administrative controls.

S.2.15 Flow-Accelerated Corrosion Program The Flow-Accelerated Corrosion Program applies to safety-related and nonsafety-related carbon steel components in systems containing high-energy fluids carrying two-phase or single-phase high-energy fluid > 2% of plant operating time.

The program, based on EPRI recommendations for an effective flow-accelerated corrosion program, predicts, detects, and monitors FAC in plant piping and other pressure retaining components. This program includes (a) an evaluation to determine critical locations, (b) initial operational inspections to determine the extent of thinning at these locations, and (c) follow-up inspections to confirm predictions. The program specifies repair or replacement of components as necessary.

This program is being tracked by administrative controls.

S.2.16 Heat Exchanger Monitoring Program The Heat Exchanger Monitoring Program inspects heat exchangers for degradation. If degradation is found, then an evaluation is performed to evaluate its effects on the heat exchanger's design functions including its ability to withstand a seismic event.

Representative tubes within the population of heat exchangers are eddy current tested at a frequency determined by internal and external operating experience and trended to ensure that effects of aging are identified prior to loss of intended function. Along with each eddy current test, visual inspections are performed on accessible heat exchanger heads, covers and tube sheets to monitor surface condition for indications of loss of material. The population of heat exchangers includes the RHR heat exchangers, RHR pump seal heat exchangers, core spray pump motor thrust bearing lube oil coolers, HPCI gland seal condenser, HPCI turbine lube oil cooler, RCIC lube oil cooler, recirculation pump motor generator set fluid coupling oil and bearing coolers, CRD pump oil coolers, recirculation pump motor lube oil coolers, clean up recirculation pump lube oil coolers and stuffing box cooler, fuel pool heat exchangers, CRD pump thrust bearing coolers, recirculation pump seal water coolers, clean up demineralizer S.2-9 Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX S LICENSE RENEWAL COMMITMENTS non-regeneration heat exchangers, and EDG lube oil coolers.

License renewal commitment 12 governs implementation of this program.

This program is being tracked by administrative controls.

S.2.17 In-service Inspection - Containment In-service Inspection (CII) Program The Containment In-service Inspection Program outlines the requirements for the inspection of Class MC pressure-retaining components (primary containment) and their integral attachments in accordance with the requirements of 10 CFR 50.55a(b)(2) and the 1998 Edition of ASME Section XI with 2000 Addenda, Inspection Program B.

The primary inspection method for the primary containment and its integral attachments is visual examination. Visual examinations are performed either directly or remotely with illumination and resolution suitable for the local environment to assess general conditions that may affect either the containment structural integrity or leak tightness of the pressure retaining component.

The program includes augmented ultrasonic exams to measure wall thickness of the containment drywell structure.

License renewal commitment 41 specifies enhancement(s) to this program.

License renewal commitment 44 specified the performance of another set of UT measurements just above and adjacent to the sand cushion region prior to the period of extended operation and an additional set of measurements will be taken once within the first 10 years of the period of extended operation.

These programs are being tracked by administrative controls.

S.2.18 In-service Inspection - In-service Inspection (ISI) Program The ISI Program is based on ASME Inspection Program B (Section XI, IWA-2432), which has 10-year inspection intervals. Every 10 years the program is updated to the latest ASME Section XI code edition and addendum approved in 10 CFR 50.55a.

S.2-10 Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX S LICENSE RENEWAL COMMITMENTS The program consists of periodic volumetric, surface, and visual examination of components and their supports for assessment, signs of degradation, flaw evaluation, and corrective actions.

This program is being tracked by administrative controls.

S.2.19 Instrument Air Quality Program The Instrument Air Quality Program ensures that instrument air supplied to components is maintained free of water and significant contaminants, thereby preserving an environment that is not conducive to loss of material. Dewpoint, particulate contamination, and hydrocarbon concentration are periodically checked to verify the instrument air quality is maintained.

License renewal commitment 13 specifies enhancement(s) to this program.

This program is being tracked by administrative controls.

S.2.20 Metal-Enclosed Bus Inspection Program Under the Metal-Enclosed Bus Inspection Program, internal portions of the non-segregated phase bus which connects the 4.16kV switchgear (A3 through A6) are inspected for cracks, corrosion, foreign debris, excessive dust buildup, and evidence of water intrusion. Bus insulation is inspected for signs of embrittlement, cracking, melting, swelling, or discoloration, which may indicate overheating or aging degradation. Internal bus supports have been and will be inspected for structural integrity and signs of cracks. Since bolted connections are covered with heat shrink tape or insulating boots per manufacturer's recommendations, a sample of accessible bolted connections is visually inspected for insulation material surface anomalies.

Enclosure assemblies have been and will be visually inspected for evidence of loss of material and, where applicable, enclosure assembly elastomers are visually inspected and manually flexed to manage cracking and change in material properties.

These inspections are performed at least once every five years.

License renewal commitment 14 governs implementation of this program.

This program is being tracked by administrative controls.

S.2-11 Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX S LICENSE RENEWAL COMMITMENTS S.2.21 Non-EQ Inaccessible Medium-Voltage Cable Program The Non-EQ Inaccessible Medium Voltage Cable Program is based on, and consistent with NUREG-1801, Rev 2, section XI.E3. In scope, inaccessible medium-voltage and low-voltage (400V to 35KV) cables exposed to significant moisture are tested at least once every six years to provide an indication of the condition of the insulation.

Significant moisture is defined as periodic exposures that last more than a few days. The specific test performed is a proven test for detecting deterioration of the insulation, such as power factor, partial discharge, polarization index, or other testing that is state-of-the-art at the time the test is performed.

Evaluation of the test results are used to determine the need for increased test frequencies.

Inspections for water collection in cable manholes and conduit containing in scope medium and low voltage cables with a license renewal intended function (400V to 35KV) occur at least once every year. Additional condition-based inspections of these manholes are performed based on natural events for a coastal site. The results of the inspections are reviewed to determine if the inspection frequency, and/or testing frequency should be modified.

License renewal commitment 15 governs implementation of this program.

This program is being tracked by administrative controls.

S.2.22 Non-EQ Instrumentation Circuits Test Review Program Under the Non-EQ Instrumentation Circuits Test Review Program, calibration or surveillance results for non-EQ electrical cables in circuits with sensitive, high voltage, low-level signals; (i.e., neutron flux monitoring instrumentation); are reviewed.

Most neutron flux monitoring system cables and connections are calibrated as part of the instrumentation loop calibration at the normal calibration frequency, which provides sufficient indication of the need for corrective actions based on acceptance criteria related to instrumentation loop performance. The review of calibration results is performed once every 10 years.

For neutron flux monitoring system cables that are disconnected during instrument calibrations, testing is performed at least once every 10 years using a proven method for detecting deterioration for the insulation system (such as insulation resistance tests or time domain reflectometry).

A review of the neutron monitoring system calibration and cable testing was completed before the period of extended operation and future tests will occur at least once every 10 years.

S.2-12 Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX S LICENSE RENEWAL COMMITMENTS License renewal commitment 16 governs implementation of this program.

This program is being tracked by administrative controls.

S.2.23 Non-EQ Insulated Cables and Connections Program The Non-EQ Insulated Cables and Connections Program provides reasonable assurance that intended functions of insulated cables and connections exposed to adverse localized environments caused by heat, radiation and moisture can be maintained consistent with the current licensing basis through the period of extended operation. An adverse localized environment is significantly more severe than the specified service condition for the insulated cable or connection.

A site walkdown of accessible insulated cables and connections is visually inspected at least once every 10 years for cable and connection jacket surface anomalies such as embrittlement, discoloration, cracking, or surface contamination.

License renewal commitment 17 governs implementation of this program.

This program is being tracked by administrative controls.

S.2.24 Oil Analysis Program The Oil Analysis Program maintains oil systems free of contaminants (primarily water and particulates) thereby preserving an environment that is not conducive to loss of material, cracking, or fouling. Activities include sampling and analysis of lubricating oil for detrimental contaminants, water, and particulates.

Sampling frequencies are based on vendor recommendations, accessibility during plant operation, equipment importance to plant operation, and previous test results.

License renewal commitments 18, 19, and 40 specify enhancement(s) to this program.

This program is being tracked by administrative controls.

S.2.25 One-Time Inspection Program A one-time inspection activity is used to verify the effectiveness of the water chemistry control programs by confirming that unacceptable cracking, loss of material, and fouling is not occurring on components within systems covered by water chemistry control programs [Sections S.2.36, S.2.37, and S.2.38].

S.2-13 Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX S LICENSE RENEWAL COMMITMENTS The elements of the One-Time Inspection Program include (a) determination of the sample size based on an assessment of materials of fabrication, environment, plausible aging effects, and operating experience, (b) identification of the inspection locations in the system or component based on the aging effect, (c) determination of the examination technique, including acceptance criteria that would be effective in managing the aging effect for which the component is examined, and (d) evaluation of the need for follow-up examinations to monitor the progression of any aging degradation.

One-time inspection activities included:

  • bottom surface of the condensate storage tanks
  • main stack foundation
  • verify absence of fatigue cracking for miscellaneous items not covered by a fatigue TLAA
  • internal surfaces of compressed air and EDG system components containing untreated air,
  • internal surfaces of stainless steel radioactive waste and sanitary soiled waste and vent system components containing untreated water,
  • reactor vessel flange leak-off line, and
  • main steam flow restrictors The results were used to confirm that loss of material, and cracking as applicable, are not occurring or are so insignificant that an aging management program is not warranted.

When evidence of an aging effect was revealed by a one-time inspection, the corrective action process was used.

License renewal commitments 20, 36, and 39 govern implementation of this program.

S.2-14 Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX S LICENSE RENEWAL COMMITMENTS S.2.26 Periodic Surveillance and Preventive Maintenance Program The Periodic Surveillance and Preventive Maintenance Program include periodic inspections and tests that manage aging effects not managed by other aging management programs. The preventive maintenance and surveillance testing activities are generally implemented through repetitive tasks or routine monitoring of plant operations.

Temperatures are monitored during periodic emergency diesel generator (EDG), station blackout diesel, and security diesel surveillance tests to verify that associated heat exchangers are capable of removing the required amount of heat, thereby managing fouling of the heat exchanger tubes.

Periodic inspections using visual or other non-destructive examination techniques verify that the following components are capable of performing their intended function.

  • reactor building crane, rails, and girders
  • refueling platform carbon steel components
  • main stack components
  • carbon steel piping in the waterline region of the torus
  • HPCI gland seal condenser blower and suction piping
  • RCIC steam supply and exhaust piping downstream of the strainers and steam traps
  • drain lines from each reactor building auxiliary bay passing into the water trough in the torus
  • clean-up recirculation pump P-204B stuffing box cooler
  • EDG, station blackout diesel, and security diesel intake air, air start, and exhaust components S.2-15 Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX S LICENSE RENEWAL COMMITMENTS

  • EDG, station blackout diesel, and security diesel jacket water radiators
  • security diesel oil cooler and aftercooler
  • area coolers VAC-210A/B, VAC-202A/B, and VAC-204A/B/C/D
  • VSF-103A/B, VAC-202A/B, VAC-204A/B/C/D, and EDG engine driven fan duct flexible connections
  • condensate storage tanks
  • circulating water, potable and sanitary water, radioactive waste, sanitary soiled waste and vent, plumbing and drains, and screen wash system components
  • flex/expansion joints in the circulating water, HVAC/chilled water, and radioactive waste systems
  • diesel fuel oil emergency transfer skid hoses, piping, pump casing, strainer, and valve bodies License renewal commitment 21 specifies enhancement(s) to this program.

This program is being tracked by administrative controls.

S.2.27 Reactor Head Closure Studs Program The Reactor Head Closure Studs Program includes in-service inspection (ISI) in conformance with the requirements of the ASME Code, Section XI, Subsection IWB, and preventive measures (e.g.

rust inhibitors, stable lubricants, appropriate materials) to mitigate cracking and loss of material of reactor head closure studs, nuts, washers, and bushings.

This program is being tracked by administrative controls.

S.2.28 Reactor Vessel Surveillance Program PNPS is a participant in the BWR vessel and internals project (BWRVIP) Integrated Surveillance Program (ISP) as incorporated into the plant Technical Specifications by License Amendment 209.

The Reactor Vessel Surveillance Program monitors changes in the fracture toughness properties of ferritic materials in the reactor pressure vessel (RPV) beltline region. As BWRVIP-ISP capsule test reports become available for RPV materials representative of PNPS, the actual shift in the reference temperature for nil-ductility S.2-16 Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX S LICENSE RENEWAL COMMITMENTS transition of the vessel material may be updated. In accordance with 10 CFR 50 Appendices G and H, PNPS reviews relevant test reports to assure compliance with fracture toughness requirements and P-T limits.

BWRVIP-116, BWR Vessel and Internals Project Integrated Surveillance Program (ISP) Implementation for License Renewal, describes the design and implementation of the ISP during the period of extended operation. BWRVIP-116 identifies additional capsules, their withdrawal schedule, and contingencies to ensure that the requirements of 10 CFR 50 Appendix H are met for the period of extended operation. The BWRVIP-116 report which was approved by the Staff will be implemented at PNPS with the conditions documented in Sections 3 and 4 of the Staff's final SE dated March 1, 2006, for the BWRVIP-116 report.

The Reactor Vessel Surveillance Program has been enhanced to proceduralize the data analysis, acceptance criteria, and corrective actions described in this program description.

If the PNPS standby capsule is removed from the reactor vessel without the intent to test it, the capsule will be stored in a manner which would permit its future use if necessary.

License renewal commitment 22 specifies enhancement(s) to this program.

S.2.29 Selective Leaching Program The Selective Leaching Program ensures the integrity of components made of cast iron, aluminum, bronze, brass, and other alloys exposed to raw water, treated water, or groundwater that may lead to selective leaching. The program includes a one-time visual inspection and/or hardness measurement of selected components that may be susceptible to selective leaching to determine whether loss of material due to selective leaching is occurring, and whether the process will affect the ability of the components to perform their intended function for the period of extended operation.

License renewal commitment 23 governs implementation of this program.

This program is being tracked by administrative controls.

S.2-17 Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX S LICENSE RENEWAL COMMITMENTS S.2.30 Service Water Integrity Program The Service Water Integrity Program relies on implementation of the recommendations of NRC GL 89-13 to ensure that the effects of aging on the salt service water (SSW) system are managed for the period of extended operation. The program includes component inspections for erosion, corrosion, and blockage and performance monitoring to verify the heat transfer capability of the safety-related heat exchangers cooled by SSW. Chemical treatment using biocides and chlorine and periodic cleaning and flushing of redundant or infrequently used loops are the methods used to control or prevent fouling within the heat exchangers and loss of material in SSW components.

License renewal commitment 24 specifies enhancement(s) to this program.

This program is being tracked by administrative controls.

S.2.31 Structures Monitoring - Masonry Wall Program The objective of the Masonry Wall Program is to manage cracking so that the evaluation basis established for each masonry wall within the scope of license renewal remains valid through the period of extended operation.

The program includes all masonry walls identified as performing intended functions in accordance with 10 CFR 54.4. Included components are the 10 CFR 50.48 required masonry walls, radiation shielding masonry walls, masonry walls with the potential to affect safety-related components, and the torus compartment water trough.

Masonry walls are visually examined at a frequency selected to ensure there is no loss of intended function between inspections.

This program is being tracked by administrative controls.

S.2.32 Structures Monitoring - Structures Monitoring Program Structures monitoring is 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 structure or structural component intended function.

License renewal commitments 25, 26, and 43 specify enhancement(s) to this program.

S.2-18 Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX S LICENSE RENEWAL COMMITMENTS License renewal commitment 45 specifies that if groundwater continues to collect on the Torus Room floor, obtain samples and test such water to determine its pH and verify the water is non-aggressive as defined in NUREG-1801 Section III.A1 item III.A.1-4 once prior to the period of extended operation and once every five years during the period of extended operation.

License renewal commitment 46 specifies inspection of the condition of a sample of torus hold-down bolts and associated grout and determine appropriate actions based on the findings prior to the period of extended operations.

This program is being tracked by administrative controls.

S.2.33 Structures Monitoring - Water Control Structures Monitoring Program The Water Control Structures Monitoring Program includes visual inspections to manage loss of material and loss of form for water-control structures (breakwaters, jetties, and revetments). The water-control structures are of rubble mound construction with the outer layer protected by heavy capstone. Parameters monitored include settlement (vertical displacement) and rock displacement.

These parameters are consistent with those described in RG 1.127.

License renewal commitment 27 specifies enhancement(s) to this program.

This program is being tracked by administrative controls.

S.2.34 System Walkdown Program The System Walkdown Program entails inspections of external surfaces of components subject to aging management review. The program is also credited with managing loss of material from internal surfaces, for situations in which internal and external material and environment combinations are the same such that external surface condition is representative of internal surface condition.

Surfaces that are inaccessible during plant operations are inspected during refueling outages. Surfaces are inspected at frequencies to provide reasonable assurance that effect of aging will be managed such that applicable components will perform their intended function during the period of extended operation.

S.2-19 Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX S LICENSE RENEWAL COMMITMENTS System walkdown guidance includes visual inspection of high voltage insulators required for station blackout recovery.

License renewal commitment 28 specifies enhancement(s) to this program.

This program is being tracked by administrative controls.

S.2.35 Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program The purpose of the Thermal Aging and Neutron Irradiation Embrittlement of CASS Program is to assure that reduction of fracture toughness due to thermal aging and reduction of fracture toughness due to radiation embrittlement will not result in loss of intended function during the period of extended operation.

This program evaluates CASS components in the reactor vessel internals and requires non-destructive examinations as appropriate.

License renewal commitment 29 governs implementation of this program.

This program is being tracked by administrative controls.

S.2.36 Water Chemistry Control - Auxiliary Systems Program The purpose of the Water Chemistry Control - Auxiliary Systems Program is to manage loss of material for components exposed to treated water.

Program activities include sampling and analysis of the stator cooling water system to minimize component exposure to aggressive environments.

The One-Time Inspection Program confirmed the effectiveness of the program.

S.2.37 Water Chemistry Control - BWR Program The objective of the Water Chemistry Control - BWR Program is to manage aging effects caused by corrosion and cracking mechanisms.

The program relies on monitoring and control of water chemistry based on EPRI Report 1008192 (BWRVIP-130). BWRVIP-130 has three sets of guidelines: one for primary water, one for condensate and feed water, and one for control rod drive (CRD) mechanism cooling water. EPRI guidelines in BWRVIP-130 also include recommendations for controlling water chemistry in the torus, condensate storage tank, demineralized water storage tanks, and spent fuel pool.

S.2-20 Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX S LICENSE RENEWAL COMMITMENTS The Water Chemistry Control - BWR Program optimizes the primary water chemistry to minimize the potential for loss of material and cracking. This is accomplished by limiting the levels of contaminants in the RCS that could cause loss of material and cracking. Additionally, PNPS has instituted hydrogen water chemistry (HWC) to limit the potential for intergranular SCC (IGSCC) through the reduction of dissolved oxygen in the treated water.

The One-Time Inspection Program confirmed the effectiveness of the program.

S.2.38 Water Chemistry Control - Closed Cooling Water Program The Water Chemistry Control - Closed Cooling Water Program includes preventive measures that manage loss of material, cracking, and fouling for components in closed cooling water systems (reactor building closed cooling water, turbine building closed cooling water, emergency diesel generator cooling water, station blackout diesel cooling water, security diesel generator cooling water, and plant heating). These chemistry activities provide for monitoring and controlling closed cooling water chemistry using PNPS procedures and processes based on EPRI guidance for closed cooling water chemistry.

The One-Time Inspection Program confirmed the effectiveness of the program.

S.2.39 Bolting Integrity Program The Bolting Integrity Program relies on recommendations for a comprehensive bolting integrity program, as delineated in NUREG-1339, and industry recommendations, as delineated in the Electric Power Research Institute (EPRI) NP-5769, with the exceptions noted in NUREG-1339 for safety-related bolting. The program relies on industry recommendations for comprehensive bolting maintenance, as delineated in EPRI TR-104213 for pressure retaining bolting and structural bolting.

License renewal commitment 32 specifies enhancement(s) to this program.

This program is being tracked by administrative controls.

S.2-21 Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX S LICENSE RENEWAL COMMITMENTS S.2.40 Bolted Cable Connections Program The Bolted Cable Connections Program focused on the metallic parts of the cable connections. This sampling program provides a one-time inspection to verify that the loosening of bolted connections due to thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation was not an aging issue that requires a periodic aging management program. A representative sample of the electrical cable connection population subject to aging management review were inspected or tested. Connections covered under the EQ program, or connections inspected or tested as part of a preventive maintenance program were excluded from aging management review.

The factors considered for sample selection were application (medium and low voltage), circuit loading (high loading), and location (high temperature, high humidity, vibration, etc.) The technical basis for the sample selection was documented.

This program was completed prior to the period of extended operation.

License renewal commitment 42 governed implementation of the program.

S.2.41 Neutron Absorber Monitoring Program The Neutron Absorber Monitoring Program is a new program that manages loss of material and reduction of neutron absorption capacity of Boral and Metamic neutron absorption panels in the spent fuel racks. The program will rely on periodic inspection, testing, monitoring of coupons, and analysis of the criticality design to assure that the required five percent subcriticality margin is maintained during the period of extended operation.

The program was initiated prior to the period of extended operation. One test on each material was performed within the five years preceding the period of extended operation, with additional testing performed on each material at least once every ten years during the period of extended operation.

This program is being tracked by administrative controls.

S.2.42 Protective Containment Coatings The Protective Coating Monitoring and Maintenance Program manage the effects of aging on Service Level 1 coatings inside containment by means of periodic visual inspections. The program also includes direction to select and review the suitability of S.2-22 Rev. 30 - Nov. 2015

PNPS-FSAR APPENDIX S LICENSE RENEWAL COMMITMENTS the coatings applied to surfaces inside containment (e.g., steel containment shell, structural steel, supports, penetrations, and concrete walls and floors). Inspection of coatings inside containment is performed of accessible areas in accordance with the IWE requirements of ASME Section XI during every other refueling outage (once per ASME Section XI IWE period) which is a maximum of four years.

This program is being tracked by administrative controls.

S.2-23 Rev. 30 - Nov. 2015

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