RS-04-020, Consolidated List of Commitments for License Renewal

Consolidated List of Commitments for License Renewal

ML040420164
Person / Time
Site:	Dresden, Quad Cities
Issue date:	02/03/2004
From:	Simpson P Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-04-020
Download: ML040420164 (18)

Text

Exelkan.

Exelon Generation 4300 Winfield Road Warrenville, IL 60555 www~exeloncorpxcor Nuclear 10 CFR 54 RS-04-020 February 3, 2004 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-001 Dresden Nuclear Power Station, Units 2 and 3 Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket No. 50-237 and 50-249 Quad Cities Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

Consolidated List of Commitments for License Renewal

References:

(1)

Letter from J. A. Benjamin (Exelon Generation Company, LLC) to U. S. NRC, "Application for Renewed Operating Licenses," dated January 3, 2003 (2)

Letter from Pao-Tsin Kuo (USNRC) to Alan Nelson (NEI) and David Lochbaum (UCS), uConsolidated List of Commitments for License Renewal," dated December 16, 2002 Exelon Generation Company, LLC (EGC) is submitting the consolidated list of commitments requested in Reference 2. This additional information is a summary list of the commitments made in Reference 1 and in subsequent responses to requests for additional information that were submitted to support the NRC review.

Should you have any questions, please contact Al Fulvio at 610-765-5936.

A- (1),

q q A09 E)

February 3, 2004 U. S. Nuclear Regulatory Commission Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Respectfully, 213/oU Executed on A,., Rat Patrick R. Simpson Manager - Licensing

Attachment:

Consolidated List of Commitments for License Renewal cc:

Regional Administrator - NRC Region Ill NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station Illinois Emergency Management Agency - Division of Nuclear Safety

Attachment Consolidated List of Commitments for License Renewal

Dresden and Quad Cities draft SER Commitment List UFSAR Item Number Commitment Supplement Implementation Source Location Schedule

__(LRA App. A)

1) ASME Section Xl Existing program is credited. Both Dresden and Quad A.1.1 Responses to RAI 3.1-25 and Inservice Inspection, Cities will be implementing RI-ISI and its alternative RAI B.1.1, letter RS-03-181, Subsections IWB, inspections for Class 1 and 2 piping within the scope of dated October 3, 2003 IWC, and IWD license renewal. The requirements of ASME Section Xl will be implemented in accordance with 10 CFR 50.55(a).

2) Water Chemistry Existing program is credited. The program will be A. 1.2 Prior to the period LRA Section B. 1.2 enhanced to provide increased sampling to verify of extended corrective actions are taken to address abnormal operation chemistry conditions. The Quad Cities procedure for turbine building sample panel collection will be revised to assure maintenance of the integrity of chemistry samples.

3) Reactor Head Existing program is credited.

A.1.3 Closure Studs

4) BWR Vessel ID Existing program is credited A.1.4 Attachment Welds

5) BWR Feedwater Existing program is credited. The program will be A.1.5 Prior to the period Response to Supplemental Nozzle enhanced to implement the recommendations of of extended RAI B.1.5, letter RS-03-223, Revision 1, Version A of report GE-NE-523-A71-0594-operation dated November 21, 2003 A, Revision 1, which was approved by the NRC staff.

6) BWR Control Rod Existing program is credited.

A.1.6 Drive Return Line Nozzle

7) BWR Stress Existing program is credited. The program will be A.1.7 End of 2018 (plus Response to Supplemental Corrosion Cracking enhanced to include an additional ultrasonic or minus 2 years) RAI 3.1-1, letter RS-03-235, examination of the Quad Cities Unit 2 reactor vessel dated December 17, 2003 head crack (detected in 1990) to verify that the relevant indication has remained essentially unchanged. The examination will be completed by the end of 2018 (plus or minus 2 years).

1

Dresden and Quad Cities draft SER Commitment List UFSAR Item Number Commitment Supplement Implementation Source Location Schedule (LRA App. A)

8) BWR Existing program is credited.

A.1.8 Penetrations

9) BWR Vessel Existing program is credited. The program will be A.1.9 As approved by Response to RAls 4.2-Internals enhanced as follows:

the NRC BWRVIPs and B.1.9, letter (1) Additional inspections will be performed when RS-03-181, dated October 3, new inspection techniques and tooling are developed, 2003; responses to incorporated into applicable BWRVIP document(s),

Supplemental RAls 4.2-and approved by the NRC.

BWRVIP and B.1.9(d), letter (2)

Dresden and Quad Cities agree to perform RS-03-223, dated November nspections of the top guide similar to inspections of 21, 2003 the control rod drive housing guide tube. However, Exelon reserves the right to modify the above agreed upon inspection program should the BWRVIP-26 be revised in the future.

10) Thermal Aging An aging management program will be implemented A.1.10 Prior to the period LRA Section B.1.10 and Neutron for thermal aging and neutron irradiation embrittlement of extended Irradiation of CASS reactor internal components within the scope operation Embrittlement of Cast of license renewal. A component specific evaluation ustenitic Stainless for the loss of fracture toughness will be included. For Steel (CASS) those components where the loss of fracture toughness may affect the function of the component, an inspection will be performed as part of the ISI program.

11) Flow-Accelerated Existing program is credited. The program will be A.1.11 Prior to the period LRA Section B. 1.11, and Corrosion enhanced to include portions of the main steam and of extended response to RAI 3.1-18, letter the reactor vessel head vent systems that are within operation RS-03-181, dated October 3, the scope of license renewal.

2003

12) Bolting Integrity Existing program is credited. The program will be A.1.12 Prior to the period LRA Section B.1.12 and enhanced to:

of extended response to Supplemental RAI (1) Credit periodic In-Service Inspection piping and operation 3.5-13, letter RS-03-227, component preventive maintenance inspections, dated December 5, 2003; system engineering walkdowns, and routine response to RAI 3.1-13, letter 2

Dresden and Quad Cities draft SER Commitment List UFSAR Item Number Commitment Supplement Implementation Source Location Schedule

__ (LRA App. A) alkdowns to inspect for leakage and visual RS-03-181, dated October 3, indications of loose bolts. Walkdown results will be 2003 and response to trended.

Supplemental RAI 3.1-13, (2)

Manage the loss of preload for closure bolting in letter RS-03-223, dated the reactor vessel system, recirculation pumps, reactor November 21, 2003 recirculation valves, reactor vessel head vent valves, and the reactor pressure boundary portion of all other systems.

(3)

Credit periodic inspections of the closure bolting in accordance with the ASME Code Section Xi requirements.

(4) Inspect bolted joints of diesel generator system components, component bolted joint inspections in high-humidity/moisture areas (pump vaults), and reactor vessel-to-ring girder bolting.

13) Open-Cycle Existing program is credited. The program will be A.1.13 Prior to the period LRA Section B.1.13 and Cooling Water enhanced to include periodic inspections of cooling of extended response to Supplemental RAI Program water pump internal linings, additional heat exchangers operation B.1.13(a), letter RS-03-235, and sub-components, external surfaces of various dated December 17, 2003 submerged pumps, components in the high humidity/moisture environments of the pump vaults, and piping. At Dresden only, periodic visual inspections will be performed of strainer internals in the CCSW supply line to the Main Control Room HVAC.

14) Closed-Cycle Existing program is credited. The program will be A.1.14 Prior to the period LRA Section B.1.14 Cooling Water enhanced to provide monitoring of specific parameters of extended Program in accordance with EPRI TR-107396 guidance. This operation ill include provisions for monitoring parameters such as pH, specific gravity, freeze point, reserve alkalinity, percent glycol and suspended solids in glycol based systems as appropriate. At Dresden, the program will include monitoring of pH and ammonia in the diesel generator jacket water.

3

Dresden and Quad Cities draft SER Commitment List UFSAR Item Number Commitment Supplement Implementation Source Location Schedule

__(LRA App. A)

15) Inspection of Existing program is credited. The program will be A.1.15 Prior to the period LRA Section B. 1.15 Overhead Heavy enhanced to include specific inspections for rail wear of extended Load and Light Load and proper crane travel on the rails, and for corrosion operation (Related to of crane structural components.

Refueling) Handling Systems

16) Compressed Air Existing program is credited. The program will be A.1.16 Prior to the period LRA Section B. 1.16 Monitoring enhanced to include periodic inspections on those of extended portions of the instrument air distribution piping in the operation scope of license renewal. The program will also include additional air sample points representative of the in-scope piping. Additionally, at Dresden only, periodic blowdowns will be provided of the instrument air distribution piping.

17) BWR Reactor Existing program is credited.

A.1.17 Water Cleanup System

18) Fire Protection Existing program is credited. The program will be A.1.18 Prior to the period LRA Section B.1.18 and enhanced as follows:

of extended response to Supplemental RAI (1) Specific guidance will be provided to check fire operation B.1.18-01, letter RS-03-222, doors for wear and holes in skin. At Quad Cities only, dated November 20, 2003; the program will be revised to include the requirement NRC Aging Management to check fire door clearances.

Program Audit Report ( to be (2)

Periodic inspections will be performed for issued) corrosion on the external surfaces of piping and components for the carbon dioxide systems; and for the external surfaces of the Dresden halon system.

(3)

Specific guidance will be provided for examining the fire pumps and the Dresden isolation condenser makeup pump diesel fuel supply systems for leaks during pump tests.

(4)

Periodic capacity tests will be performed on the 4

Dresden and Quad Cities draft SER Commitment List UFSAR Item Number Commitment Supplement Implementation Source Location Schedule

__(LRA App. A)

Dresden isolation condenser diesel-driven makeup pumps.

(5) At Dresden, frequency of inspections will be provided for fire doors and spill barriers.

(6)

The program will be revised to perform a visual inspection (VT-1 or equivalent) on a 10% sample population of each type of fire seal on a refueling outage frequency. Additionally, the program will be revised to expand the sample population by 10% if any of the inspected seals are found to have abnormal degradation that could prevent the seal from performing its intended function.

19) Fire Water Existing program is credited. The program will be A.1.19 Prior to the period LRA Section B.1.19 System enhanced as follows:

of extended (1) Periodic non-intrusive wall thickness operation measurements will be provided of selected portions of the fire water system.

(2) Periodic inspections will be performed on the external surfaces of submerged fire pumps, outdoor fire hydrants, and outdoor transformer deluge system components.

(3) Sampling of sprinklers will be performed in accordance with NFPA 25, "Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems."

20) Above-ground Existing program is credited. The program will be A.1.20 Prior to the period LRA Section B.1.20 and Carbon Steel Tanks enhanced as follows:

of extended responses to Supplemental (1) Periodic system engineer walkdowns will be operation RAls B.1.2 and 8.1.20, letter performed on the nitrogen storage tanks utilizing RS-03-222, dated November stand-alone procedures.

20, 2003; NRC Aging (2) At Quad Cities, a one-time UT thickness Management Program inspection will be performed of the aluminum Inspection Report Condensate Storage Tank or Demineralized Water 05000237/200301 0(DRS);

5

Dresden and Quad Cities draft SER Commitment List UFSAR Item Number Commitment Supplement Implementation Source Location Schedule

__ (LRA App. A)

Storage Tank.

05000249/200301 0(DRS);

(3) At Dresden, periodic internal/external inspections 05000254/2003014(DRS);

will be performed of the aluminum storage tanks, and 05000265/2003014(DRS),

periodic UT thickness inspections will be performed of dated December 5, 2003 the bottoms.

21) Fuel Oil Existing program is credited. The program will be A. 1.21 Prior to the period LRA Section B. 1.21 and Chemistry enhanced to include inspection of the fuel oil storage of extended response to RAI B.1.21, letter tank interiors for corrosion during regularly scheduled operation RS-03-180, dated October 3, tank cleanings.

2003

22) Reactor Vessel Existing program is credited. The program will be A.1.22 Prior to the period LRA Section 3.1.1.1.4, LRA Surveillance enhanced as follows:

of extended Section B.1.22, response to (1) The Integrated Surveillance Program (ISP) for the operation RAI B.1.22, letter RS-03-181, license renewal period (in accordance with proposed dated October 3, 2003, BWRVIP-116) will be implemented when approved by response to Supplemental RAI the NRC.

B.1.22, letter RS-03-223, (2) If BWRVIP-1 16 is not approved, a plant-specific dated November 21, 2003 surveillance plan will be provided for the license renewal period in accordance with 10 CFR Part 50, ppendices G and H.

23) One-Time One-time inspection sampling will be performed on the A.1.23 Prior to the period LRA Sections 3.2.1.1.3, Inspection following:

of extended 3.2.1.1.5, 3.5.1.1.6, B.1.23; (1) at Dresden, spent fuel pool cooling and operation response to Supplemental RAI demineralizer system components for corrosion in B.1.23-2.1, letter RS-04-014 stagnant locations dated January 26, 2004; (2) condensate and torus water components for response to RAIs 3.5-7 and corrosion in stagnant locations 3.1-9, letter RS-03-201 dated (3) compressed gas system piping components for October 3, 2003; response to corrosion Supplemental RAI 3.1-21(b),

(4) compressed gas system flexible hoses for age letter RS-03-223, dated related degradation November 21, 2003; response (5) lower sections of carbon steel fuel oil and to Supplemental RAls B.1.2, lubricating oil tanks for reduced thickness B.1.2-1, and 3.1-21(a), letter 6

Dresden and Quad Cities draft SER Commitment List UFSAR

.tem Number Commitment Supplement Implementation Source Item Number Commitment Location Schedule LRAA

.A

p. A)

(6) fuel oil and lubricating oil piping and components RS-03-238, dated December for corrosion 22, 2003; responses to (7) control room ventilation, EDG ventilation, SBO Supplemental RAIs 3.5-15 and building ventilation, and reactor building ventilation, 3.5-17, letter RS-03-227, and standby gas treatment system components for dated December 5, 2003 loss of material (8) HPCI lubrication oil hoses for age related degradation (9) non-safety related vent and drain components for age related degradation (10) 10 CFR 54.4(a)(2) components for corrosion (11) piping exposed to containment atmosphere for loss of material (12) torus saddle supports to confirm condition of drywell radial beam lubrite baseplates (13) 10% of high and medium risk butt welds in ASME Class 1, NPS < 4" piping (14) stainless steel components in CRD hydraulic system and stainless steel clevis pins in torus water environment for stress corrosion cracking; clevis pin interface with uncoated carbon steel in torus water environment for galvanic corrosion (15) sample of stainless steel standby liquid control system components not in reactor coolant pressure boundary section of SBLC system for cracking

24) Selective sample of components that are made of susceptible A.1.24 Prior to the period LRA Section B.1.24 Leaching of Materials materials will be visually inspected for evidence of of extended selective leaching. The sample will be expanded if operation failed conditions are identified.

25) Buried Piping and Existing program is credited. The program will be A.1.25 Prior to the period LRA Section B.1.25; response Tanks Inspection enhanced as follows:

of extended to RAI B.1.25, letter RS (1) A one-time visual inspection will be performed on operation 181, dated October 3, 2003; the external surface of a section of buried ductile iron response to Supplemental RAI 7

Dresden and Quad Cities draft SER Commitment List UFSAR Item Number Commitment Supplement Implementation Source Location Schedule (LRA App. A) fire main piping (including a mechanical joint).

B.1.25-1, letter RS-YYY, dated (2) A one-time internal UT of one buried steel tank YYY per site will be performed.

(3) At Quad Cities, periodic leakage checks will be performed of Quad Cities buried carbon steel fuel oil storage tanks.

26) ASME Section XI, Existing program is credited. The program will be A.1.26 Prior to the period Response to RAI B.1.26, letter Subsection IWE enhanced as follows:

of extended RS-03-180, dated October 3, (1) The program will be based on the latest edition operation 2003; responses to and addenda, which is approved by the NRC 12 Supplemental RAls 2.4-3, 3.5-months prior to the end of the current 120-month 5, 4.7.2.2-1, and 4.7.2.2-02, inspection interval.

letter RS-03-227, dated (2) The program will be updated in accordance with December 5, 2003; response 10 CFR 50.55(a).

to Supplemental RAI B.1.27, (3) Additional inspections of the Dresden Unit 3 letter RS-YYY, dated YYY containment shell for corrosion will be provided.

(4) Requirements will be provided in Quad Cities procedures to ensure that sand pocket drains are clear.

27)ASME Section XI, Existing program is credited. The program will be A.1.27 Priorto the period LRA Section B.1.27; Open Subsection IWF enhanced to include inspection of Class MC of extended Item 3.5.2.3.2.2-1; response to component supports consistent with NUREG-1 801, operation RAI 3.5-7, letter RS-03-180, Chapter 1II, Section B1.3. The ASME Section Xl, dated October 3, 2003; Subsection IWF program will manage the aging of the response to Supplemental RAI following Class MC supports:

2.4-2, letter RS-03-0227, (1) Biological Shield to Containment Stabilizer dated December 5, 2003; (2) RPV Male Stabilizer Attached to Outside of response to Supplemental RAI Drywell Shell B.1.27, letter RS-YYY, dated (3) RPV Female Stabilizer and Anchor Rods YYY (4) Suppression Chamber Ring Girder Vertical Supports and Base Plates (5) Suppression Chamber Saddle Supports and Base Plates 8

Dresden and Quad Cities draft SER Commitment List UFSAR Item Number Commitment Supplement Implementation Source Location Schedule (LRA App. A)

(6) Suppression Chamber Seismic Restraints and Base Plates (7)

Vent Header Vertical Column Supports

28) 10 CFR Part 50, Existing program is credited.

A.1.28 Appendix J

29) Masonry Wall Existing program is credited.

A.1.29 Program

30) Structures Existing program is credited. The program will be A.1.30 Prior to the period LRA Sections B.1.30, Monitoring Program enhanced to add the following:

of extended 3.3.1.2.1, 3.5.1.1.7, 3.5.1.2.6, (1) inspections of structural steel components in operation and 3.5.1.2.7; response to secondary containment, flood barriers, electrical Supplemental RAI B.1.27, panels and racks, junction boxes, instrument racks and letter RS-YYY, dated YYY panels, offsite power structural components and their foundations, and the Quad Cities discharge canal weir as part of the ultimate heat sink (2) periodic reviews of chemistry data on below-grade water to confirm that environment remains non-aggressive for corrosion of embedded steel and aggressive chemical attack of concrete (3) inspection of sample of non-insulated indoor piping external surfaces at locations immediately adjacent to periodically inspected piping supports (4) program reference to specific insulation inspection criteria for outdoor insulation, and the establishment of new inspections for various indoor area piping and equipment insulation (5) inspection parameter specificity for non-structural joints, roofing, grout pads and isolation gaps 31)RG 1.127, Existing program is credited. The program will be A.1.31 Prior to the period LRA Section B.1.31; Inspection of Water-enhanced to add the following:

of extended responses to Supplemental Control Structures (1) monitoring of crib house concrete walls and slabs operation RAls 3.5-12 and B.1.31, letter ssociated with with an opposing side in contact with river water RS-03-227, dated December Nuclear Power Plants (2) inspection for structural integrity of concrete and 5, 2003 9

Dresden and Quad Cities draft SER Commitment List UFSAR Item Number Commitment Supplement Implementation Source Location Schedule (LRA App. A) steel components and identification of specific types of components to be inspected (3) periodic monitoring of the Dresden discharge outfall concrete structure (4) at Quad Cities, periodic inspections of the concrete of the discharge flume/canal and the weir gate in the discharge canal

32) Protective Existing program is credited. The program will be A.1.32 Prior to the period LRA Section B. 1.32 Coating Monitoring enhanced as follows:

of extended and Maintenance (1) visual inspection of Service Level I coatings near operation Program sumps or screens associated with the emergency core cooling system (2) pre-inspection review of previous reports so that trends can be identified for the program (3) analysis of coating failures to determine reasons for failures

33) Electrical Cables A program will be developed that is consistent with A.1.33 Prior to the period LRA Section B.1.33; response and Connections Not NUREG-1801 aging management program Xl.E1 for of extended to RAI B.1.33-3, letter RS Subject to 10 CFR electrical cables and connections installed in adverse operation 177, dated October 3, 2003 50.49 Environmental localized environments not subject to 10 CFR 50.49 Qualification environmental qualification requirements.

Requirements

34) Metal Fatigue of Existing program is credited. The program will be A.1.34, A.3.4 Prior to the period LRA Sections 4.3.1, 4.3.3.1, Reactor Coolant enhanced to utilize the EPRI-licensed FatiguePro of extended 4.6.1, 4.6.2 and B.1.34; Pressure Boundary computer program for monitoring fatigue at bounding operation.

response to RAI B.1.34, letter locations for reactor pressure vessel, Class I piping, RS-03-180, dated October 3, torus, torus vents, and torus attached piping and 2003 penetrations, SRV discharge lines, and the Dresden isolation condenser.

35) Environmental Existing program is credited.

A.1.35 Qualification (EQ) of Electrical Components 10

Dresden and Quad Cities draft SER Commitment List UFSAR Item Number Commitment Supplement Implementation Source Location Schedule (LRA App. A)

36) Boraflex Existing program is credited.

A.1.36 Monitoring

37) Electrical Cables A program will be developed to manage aging of A.1.37 Prior to the period Responses to RAIs 3.6-9 and Not Subject to 10 cables in sensitive instrumentation circuits with low-of extended B.1.33-1, letter RS-03-177, CFR 50.49 level signals in the Nuclear Instrumentation Systems operation dated October 3; response to Environmental and Radiation Monitoring Systems. The program will Supplemental RAI 3.6-09, Requirements Used include a review of calibration and surveillance results letter RS-03-238, dated in Instrument Circuits for cable aging degradation before the period of December 22, 2003 extended operation and every 10 years thereafter.

This program applies to the cables of the Nuclear Instrumentation Systems which includes source range monitors, intermediate range monitors, local power range monitors, and Radiation Monitoring Systems which includes drywell high range radiation monitors, main steam line radiation monitors, and the steam jet air ejector radiation monitors.

38) Inaccessible t Dresden, a new condition monitoring program will A.1.38 Prior to the period Response to Supplemental Medium-Voltage be provided in accordance with NUREG-1801, of extended RAI 3.6-3, letter RS-03-222, Cables Not Subject to Program XI.E3 to manage aging of five inaccessible operation dated November 20, 2003 10 CFR 50.49 medium-voltage cables feeding the service water Environmental pumps. The cables will be tested at least once every Requirements ten years. The end of the cribhouse duct bank will be inspected annually to verify the duct run is not plugged ith debris.

39) Corrective Action Existing program is credited.

A.2.1 Program

40) Periodic A program will be developed and implemented to A.2.2 Prior to the period LRA Section B.2.2; response Inspection of Non-periodically inspect non-segregated bus ducts that of extended to RAI 3.6-4, letter RS-03-177, EQ, Non-Segregated connect the reserve auxiliary transformers (RATs) to operation dated October 3, 2003; Electrical Bus Ducts 4160V ESS buses, the non-segregated bus ducts that responses to Supplemental connect the EDG to the ESS buses, and, for Dresden RAIs 3.6-4, 3.6-7, and B.2.2-only, the non-segregated bus ducts that connect ESS 01, letter RS-03-227, dated buses. The bus duct internal components and December 5, 2003; response 11

Dresden and Quad Cities draft SER Commitment List UFSAR Item Number Commitment Supplement Implementation Source Location Schedule (LRA App. A) materials will be visually inspected for signs of aging to Supplemental RAI B.2.2-1, degradation. The program will include:

letter RS-03-238, dated (1) inspection of accessible normally energized non-December 22, 2003.

segregated bus duct internal components such as insulation materials, bus duct support pieces, gaskets, insulating boots, taped connections, and bus bar sleeves for material surface anomalies for non-egregated bus duct that connects the RATs to the l160V ESS buses (2) inspection of bus bar insulation material at the accessible bolted connections of the non-segregated bus duct that connects the RATs to the 4160V ESS buses (3) inspection of 10% of the splice insulation material at the bolted connections (including all visible insulation in both directions beyond the location of the bolted connection splice insulation inspected) for the non-segregated bus duct that connects the EDG to the ESS buses and, for Dresden only, the non-segregated bus duct that connects the ESS buses for signs of aging degradation that indicate possible loose connections (4) inspections for the presence of dirt or moisture in l he bus duct

41) Periodic Existing program is credited. The program will be A.2.3 Prior to the period LRA Section B.2.3 Inspection of enhanced to include inspection of aging of all flexible of extended entilation System boots, access door seals and gaskets, filter seals and operation Elastomers gaskets, and RTV silicone used as a duct sealant, in the components of the SBO ventilation and Reactor Building ventilation systems for Dresden, and the SBO entilation and EDG Room ventilation systems for Quad Cities. The inspections will be performed to detect cracking, loss of material, and other evidence of 12

Dresden and Quad Cities draft SER Commitment List UFSAR Item Number Commitment Supplement Implementation Source Location Schedule (LRA App. A) aging. Tests of seals for hardening will be included if evidence of aging is found.

42) Periodic Testing Existing program is credited.

A.2.4 of Drywell and Torus Spray Nozzles

43) Lubricating Oil Existing program is credited. The program will be A.2.5 Response to RAI B.1.23-2, Monitoring Activities enhanced to include those components exposed to an letter RS-03-180, dated environment of lubricating oil in:

October 3, 2003 and (1) the reactor core isolation cooling system (Quad Supplemental RAls B.1.23-Cities only) 02.3 and RAI B.1.23-02.4, (2) the main generator hydrogen seal oil system letter RS-04-014, dated (Quad Cities only)

January 26, 2004 (3) the high pressure coolant injection system (4) the emergency diesel generator and auxiliaries system (5) the station blackout diesel system (6) the electro-hydraulic control system

44) Heat Exchanger An aging management program will be developed and A.2.6 Prior to the period LRA Section B.2.6; response Test and Inspection implemented for heat exchangers in the scope of of extended to Supplemental RAI 3.1-11, Activities license renewal that are not tested and inspected by operation letter RS-03-223, dated the Open-Cycle Cooling Water System and Closed-November 21, 2003; response Cycle Cooling Water System aging management to Supplemental RAI 3.1-11, programs.

letter RS-03-238, dated Specifically, for the Dresden isolation condensers, the December 22, 2003 augmentation activities identified in NUREG-1 801, lines IV.C1.4-a and IV.C1.4-b to manage loss of material and cracking will also be included in this aging management program, and will provide:

(1) temperature and radioactivity monitoring of the shell-side (cooling) water (2) eddy current testing of the tubes (3) visual inspections of the channel head, tube sheets, and internal surfaces of the shell 13

Dresden and Quad Cities draft SER Commitment List UFSAR Item Number Commitment Supplement Implementation Source Location Schedule (LRA App. A)

45) Generator Stator Existing program is credited.

A.2.7 Water Chemistry ctivities l

46) Periodic An aging management program will be developed and A.2.8 Prior to the period Response to RAI B.1.23-2, Inspection of Plant implemented to inspect components in the Plant of extended letter RS-03-180, dated Heating System Heating system once before the end of the current operation October 3, 2003; response to operating term and periodically at intervals not to Supplemental RAI exceed once every 5 years during the period of 3.3.2.4.24(a), letter RS extended operation.

238, dated December 22, 2003

47) Time-Limited Revised P-T limits will be prepared and submitted to A.3.1.5 Prior to the period LRA Section 4.2.5; response Aging Analysis the NRC for approval prior to the start of the extended of extended to RAI 4.3.0, letter RS-03-180, (TLAA) - Neutron period of operation using an approved fluence operation dated October 3, 2003 Embrittlement of the methodology for Dresden and Quad Cities.

Reactor Vessel and Internals n extension of the current Dresden relief from the A.3.1.6 Prior to the period LRA Section 4.2.6 requirements for inspection of RPV circumferential of extended welds will be submitted to the NRC for approval for the operation period of extended operation.

48) TLAA - Metal The Dresden Unit 2 jet pump riser braces will be A.3.2.2.1 Prior to the period LRA Section 4.3.2.2; response Fatigue repaired or replaced prior to the period of extended of extended to RAI 4.3.0, letter RS-03-1 80, operation.

operation dated October 3, 2003; response to RAI 4.3.2.2, letter RS-03-180, dated October 3, 2003 Plant-specific calculations will be performed for A.3.2.4 Prior to the period LRA Section 4.3.4; Response applicable locations identified in NUREG/CR 6260, of extended to Supplemental RAI 4.3.4, "Application of NUREG/CR-5999 Interim Fatigue operation letter RS-03-235, dated Curves to Selected Nuclear Power Plant December 17, 2003 Components," for older-vintage BWR plants, to assess potential effects of reactor coolant on component fatigue life in accordance with 10 CFR 54.21(c)(1)(ii).

14

Dresden and Quad Cities draft SER Commitment List UFSAR Item Number Commitment Supplement Implementation Source Location Schedule

__ (LRA App. A)

Exelon reserves the right to modify this position in the future based on the results of industry activities currently underway, or based on other results of improvements in methodology, subject to NRC approval prior to changes in this position.

49) TLAA -

reanalysis will be applied to EQ components now A.3.3 Prior to the period LRA Section 4.4; response to Environmental qualified for the current operating term of 40 years.

of extended RAI 4.3.0, letter RS-03-180, Qualification of The EQ Binders for components within the scope of 10 operation dated October 3, 2003 Electrical Equipment CFR 50.49 will be updated to include environmental conditions associated with EPU implementation together with an extended operating period of 60 years.

50) TLAA - Other The corrosion rate assumptions used in the calculation A.3.5.2.1 Prior to the period LRA Section 4.7.2.2 Plant-Specific TLAAs of the drywell steel plate remaining thickness at the of extended sand pocket level will be confirmed by a Dresden Unit operation 3 UT inspection prior to the period of extended operation. The results will be used to revise the associated corrosion calculation and validate that an acceptable wall thickness will remain to the end of the 60-year licensed operating period.

The corrosion rate assumptions used in the calculation A.3.5.2.2 Prior to the period LRA Section 4.7.2.3 of the ECCS Suction strainer flange remaining of extended thickness will be confirmed by an ultrasonic inspection.

operation One bounding inspection will be performed and results ill be used to validate the corrosion rate for both sites.

Based upon the results of the inspection, a revised galvanic corrosion calculation will be performed to ensure acceptable wall thickness to the end of the 60-year licensed operating period.

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