Text

License Renewal Application Changes to Associated with Revised and Completed Commitments
	ML16035A245
Person / Time
Site:	Seabrook
Issue date:	01/29/2016
From:	Dean Curtland; NextEra Energy Seabrook
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	SBK-L-16003
	Download: ML16035A245 (24)
	v • d • e

N EXTe ra ENERGY SEABROOK January 29, 2016 10 CFR 54 SBK-L-16003 Docket No. 5 0-443 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-000 1 Seabrook Station LRA Commitments Update NextEra Energy Seabrook License Renewal Application

References:

1.

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

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

At the request of the Staff, NextEra has reviewed the current status of commitments and is providing updates as appropriate. Provided in Enclosure 1 are changes to the License Renewal Application (LRA) Table A.3 License Renewal Commitment List. To facilitate understanding, the changes are explained, and where appropriate, portions of the LRA are repeated with the change highlighted by strikethroughs for deleted text and bolded italics for inserted text. provides the revised LRA Appendix A - Updated Final Safety Analysis Report Supplement Table A.3, License Renewal Commitment List. This letter contains four revised Commitments; 63, 65, 67 and 68.

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

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

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

I declare under penalty of perjury that the foregoing is true and correct.

Executed on January Z.8, 2016.

Sincerely, NextEra Energy Seabrook, LLC Dean Curtland Site Vice President - Changes to the LRA Associated with Revised and Completed Commitments. - LRA Appendix A - Final Safety Report Supplement Table A.3, License Renewal Commitment List Updated to Reflect Revised and Completed Commitments.

cc:

D. H. Dorman NRC Region I Administrator J. G. Lamb NRC Project Manager P. C. Cataldo NRC Senior Resident Inspector T. M. Tran NRC Project Manager, License Renewal L. M. James NRC Project Manager, License Renewal Mr. Perry Plummer Director Homeland Security and Emergency Management New Hampshire Department of Safety Division of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen Drive Concord, NH 03305 Mr. John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399 to SBK-L-16003 Seabrook Station License Renewal Application Changes to the LRA Associated with Revised and Completed Commitments.

U.S. Nuclear Regulatory Commission SBK-L-16003 / Enclosure 1 / Page 2 to SBK-L-16003 Changes to the LRA Associated with Revised and Completed Commitments Commitment #63 - Flow Induced Erosion Commitment #63 previously had an LRA Appendix A - Final Safety Report Supplement Table A.3, UFSAR LOCATION of "N/A". The Staff presented a concern on whether or not the "N/A'"

designation is appropriate for this Commitment. Seabrook evaluated the concern, and modified the UFSAR LOCATION for this Commitment to appropriately reflect Seabrook's response from RAJ 3.2.2.2.6-02. The new UFSAR LOCATION has been changed to A.2.1.2.

Background -

SRP-LR, Section 3.2.2.2.6 discusses stainless steel miniflow orifices in the high pressure safety injection pumps' minimum flow lines. The SRP-LR references LER 50-275 / 94-023 which documents operating experience where extended use of a centrifugal high pressure safety injection pump for charging caused erosion in the miniflow orifice and resulted in lower than required flow being available through the injection line.

The SRP-LR also states that a plant-specific AMP should be evaluated for erosion of the orifice due to extended use of the centrifugal HPSI pump for normal charging.

Seabrook Station addressed the evaluation criteria of the SRP-LR, by stating that the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is adequate to manage the aging effect in these components.

RAI 3.2.2.2.6 Requested Seabrook to explain whether opportunities for inspection of the charging pump bypass orifices are routinely available. The staff also asked Seabrook to justify how the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program will be capable of detecting degradation in these components before failure of their intended function if routine opportunities for inspection are not available. (Reference 1)

RAI 3.2.2.2.6-01 Response -

Seabrook's response stated that the CVCS high-pressure pump minimum flow orifices are welded in place and are not routinely available for internal visual inspection. The applicant further stated that the minimum flow orifices have multiple internal plates with multiple orifice holes and that these design features of the minimum flow orifices make volumetric examination for dimensional comparison impractical. Seabrook proposed to manage loss of material due to erosion in minimum flow orifices with the Water Chemistry Program.

Seabrook also stated that its Technical Specifications require quarterly in service testing of the CVCS high-pressure pumps and that this testing can provide early indication of orifice degradation. (Reference 2)

U.S. Nuclear Regulatory Commission SBK-L-16003 / Enclosure 1 / Page 3 RAI 3.2.2.2.6 The staff asked Seabrook to include in the AMP(s) for these components an inspection or testing activity to confirm effectiveness of the Water Chemistry Program to mitigate or prevent unacceptable loss of material due to erosion in the stainless steel CVCS high-pressure pump minimum flow orifices. (Reference.3)

RAL 3.2.2.2.6-02 Response-Seabrook stated that it will credit its high-pressure SI pump (CVCS charging pump) TS Performance Monitoring Program to detect loss of material due to erosion in the minimum flow orifices and to confirm effectiveness of the Water Chemistry Program for this component. (Reference 4)

SER 3.2.2.2.6 - Loss of Material Due to Erosion "The staff noted that SRP-LR Appendix A, Section A. 1.1, states that a Performance Monitoring Program, which tests the ability of a structure or component to perform its intended function, is an acceptable method for aging management. The staff also noted that the applicant will use its existing quarterly TS Performance Monitoring Program for the CVCS high-pressure SI pump (charging pump) to confirm effectiveness of the Water Chemistry Program in mitigating or preventing unacceptable loss of material due to erosion in the stainless steel minimum flow orifices exposed to treated borated water. The staff further noted that the applicant added a new commitment (Commitment No. 63) to ensure that quarterly CVCS charging pump testing is continued during the period of extended operation. The staff finds that the applicant has met the further evaluation criteria and that the applicant's proposal to manage aging using the Water Chemistry Program and performance monitoring of the CVCS charging pump is acceptable." (Reference 5)

As a result of the information presented above, the UFSAR Location for Commitment #63 has been modified from N/A to A.2. 1.2, as shown below.

Ensure that the quarterly CVCS Charging Pump testing is Flw continued during the PEO. Additionally, add a precaution to the Prior to the Flow test procedure to state that an increase in the CVCS Charging NI period of 63osiondue Pump mini flow above the acceptance criteria may be indicative A.2.1.2 extended Eoin of erosion of the mini flow orifice as described in LER 50-operation.

275/94-023.

References

1. NRC Letter "Request for Additional Information Related to the Review of the Seabrook Station License Renewal Application (TAC NO. ME4028) - Aging Management Review

- Set 6," January 5, 2011 (Accession Number ML103420585)

2. NextEra Energy Seabrook, LLC letter SBK-L-1 1015, "Seabrook Station Response to Request for Additional Information, NextEra Energy Seabrook License Renewal Application Sets 6,7 and 8," February 3,2011. (Accession Number ML110380081)

U.S. Nuclear Regulatory Commission SBK-L-16003 / Enclosure 1 / Page 4

3. NRC Letter "Request for Additional Information Related to the Review of the Seabrook Station License Renewal Application (TAC NO. ME4028) - Request for Additional Information Set 11," March 7, 2011. (Accession Number ML110550920)

4. NextEra Energy Seabrook, LLC letter SBK-L-1 1062, "Seabrook Station Response to Request for Additional Information, NextEra Energy Seabrook License Renewal Application, Request for Additional Information - Set 11," April 5, 2011. (Accession Number ML110960647)

5. NRC Letter "'Safety Evaluation Report with Open Items Related to the License Renewal of Seabrook Station," June 8, 2012. (Accession Number ML12053A192)

Commitment #65 - Flux Thimble Tubes This commitment was to complete design changes that prevent the insertion of a moveable detector into the bottom mounted instrument tubes. To date 38 of 58 Thimble Tubes have been replaced with new detectors that do not have a hollow annulus to accept a Moveable In core Detector (MID). The remaining 20 are scheduled for OR1 8 replacement in the spring of 2017.

In the current configuration, the number of available MID's does not meet the requirements of the Technical Requirement and would not be able to be used for the designed flux mapping purpose, even if the MID's equipment (hardware and software) were usable. The new, solid design does not allow for a Moveable In core Detector in these locations.

As the modification to replace the remaining 20 detectors in the spring of 2017 is in progress, Commitment #65 has been changed to In Progress.

5.Flux Implement measures to ensure that the movable in core NA Prior to the period of 6.Thimble detectors are not returned to service during the period of extended operation. -

Tube extended operation.

IN/ Progress

U.S. Nuclear Regulatory Commission SBK-L-16003 / Enclosure 1 / Page 5 Commitment #67 - Structures Monitoring Program Commitment #67 has been completed and the appropriate section within Table A.3 has been updated as shown below. Removal of the core and exposure of the rebar showed no evidence of damage from boric acid exposure. The core did show early indications of ASR progression.

Perform one shallow core bore in an area that was continuously wetted from borated water to No-later Structures be examined for concrete degradation and also ta

67.

Monitoring expose rebar to detect any degradation such as A.2.1.31 Deeemhe Porm loss of material. The removed core will also be m

Program subjected to petrographic examination for concrete degradation due to ASR per ASTM Complete Standard Practice C856.

Commitment #68 - Structures Monitoring Program NextEra has established a routine preventative maintenance activity to perform quarterly leak off collections and chemical testing as of 01/29/2014. Due to meeting the intent of Commitment

68, the status of this commitment has been updated to "Complete".

68.

,Qurtrl enti...

Structures Perforn sampling at the leak off collection Maintenance Activity 6.Monitoring points for chlorides, sulfates, pH and iron A.2. 1.31 TI...

Program once every three months.

Complete to SBK-L-16003 LRA Appendix A - Final Safety Report Supplement Table A.3, License Renewal Commitment List Updated to Reflect Revised and Completed Commitments

United States Nuclear Regulatory Commission SBK-L-16003 / Enclosure 2 Page 2 of 17 A.3 LICENSE RENEWAL COMMITMENT LIST UFSAR No.

PROGRAM or TOPIC COMMITMENT SCHEDULE LOCATIOI' Provide confirmation and acceptability of the implementation of

1.

PWR Vessel Internals MRP-227-A by addressing the plant-specific Applicant/Licensee A.2.1.7 Complete Action Items outlined in section 4.2 of the NRC SER.

Enhance the program to include visual inspection for cracking,Protohepidofxend

2.

Closed-Cycle Cooling Water loss of material and fouling when the in-scope systems are opened A.2.1.12 operation.

for maintenance.

Inspection of Overhead Heavy Enhance the program to monitor general corrosion on the crane

3.

Load and Light Load (Related and trolley structural components and the effects of wear on the A.2.1.13 Proprationteprido.etne to Refueling) Handling Systems rails in the rail system.

oeain Inspection of Overhead Heavy Prior to the period of extended

4.

Load and Light Load (Related Enhance the program to list additional cranes for monitoring.

A.2.1.13 operation.

to Refueling) Handling Systems Enhance the program to include an annual air quality test Prior to the period of extended

5.

Compressed Air Monitoring requirement for the Diesel Generator compressed air sub system.

A.2.1.14 operation.

Enhance the program to perform visual inspection of penetration Prior to the period of extended

6.

Fire Protection seals by a fire protection qualified inspector.

A.2.1.15 operation.

Enhance the program to add inspection requirements such asProtohepidofxend

7.

Fire Protection spalling, and loss of material caused by freeze-thaw, chemical A.2.1.15 oeain attack, and reaction with aggregates by qualified inspector.

United States Nuclear Regulatory Commission SBK-L-16003 / Enclosure 2 Page 3 of 17 Enhance the program to include the performance of visualProtohepidofxend

8.

Fire Protection inspection of fire-rated doors by a fire protection qualified A.2.1.15 operation.

inspector.

Enhance the program to include NFPA 25 (2011 Edition) guidance for "where sprinklers have been in place for 50 years,

9.

Fire Water System they shall be replaced or representative samples from one or more A.2.1.16 Protohepidofxend

,sample areas shall be submitted to a recognized testing laboratory oeain for field service testing".

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

10.

Fire Water System testing of the fire water system in accordance with the guidance of A.2. 1.16 oeain NFPA 25 (2011 Edition).

oeain Enhance the program to include the performance of periodic visual or volumetric inspection of the internal surface of the fire protection system upon each entry to the system for routine or corrective maintenance to evaluate wall thickness and inner diameter of the fire protection piping ensuring that corrosion product buildup will not result in flow blockage due to fouling.

Where surface irregularities are detected, follow-up volumetric examinations are performed. These inspections will be Within ten years prior to the

~ ieWte ytmdocumented and trended to determine if a representative number A...6 period of extended operation.

of inspections have been performed prior to the period of extended operation. If a representative number of inspections have not been performed prior to the period of extended operation, focused inspections will be conducted. These inspections will commence during the ten year period prior to the period of extended operation and continue through the period of extended operation

United States Nuclear Regulatory Commission SBK-L-16003 / Enclosure 2 Page 4 of 17 Aboveground Steel Tanks Enhance the program to include 1) In-scope outdoor tanks, except fire water storage tanks, constructed on soil or concrete, 2) Indoor large volume storage tanks (greater than 100,000 gallons) designed to near-atmospheric internal pressures, sit on concrete or soil, and exposed internally to water, 3) Visual, surface, and volumetric examinations of the outside and inside surfaces for managing the aging effects of loss of material and cracking, 4)

External visual examinations to monitor degradation of the protective paint or coating, and 5) Inspection of sealant and caulking for degradation by performing visual and tactile examination (manual manipulation) consisting of pressing on the sealant or caulking to detect a reduction in the resiliency and pliability.

A.2.1.17 Within 10 years prior to the period of extended operation.

4

.1.

Fire Water System Enhance the program to perform exterior inspection of the fire water storage tanks annually for signs of degradation and include an ultrasonic inspection and evaluation of the internal bottom surface of the two Fire Protection Water Storage Tanks per the guidance provided in NFPA 25 (2011 Edition).

A.2.1.16 Within ten years prior to the period of extended operation.

Enhance program to add requirements to 1) sample and analyze new fuel deliveries for biodiesel prior to offloading to the Prior to the period of extended FulOlCeityAuxiliary Boiler fuel oil storage tank and 2) periodically sample A...8 operation.

stored fuel in the Auxiliary Boiler fuel oil storage tank.

Enhance the program to add requirements to check for the Fuel Oil Chemistry presence of water in the Auxiliary Boiler fuel oil storage tank at A.2.1.18 Protohepidofxend least once per quarter and to remove Water as necessary.

operation.

United States Nuclear Regulatory Commission SBK-L-16003 / Enclosure 2 Page 5 of 17 Enhance the program to require draining, cleaning and inspectionProtohepidofxend

16.

Fuel Oil Chemistry of the diesel fire pump fuel oil day tanks on a frequency of at least A.2.1.18 oeain once every ten years.

Enhance the program to require ultrasonic thickness measurement of the tank bottom during the 10-year draining, cleaning andProtohepidofxend

17.

Fuel Oil Chemistry inspection of the Diesel Generator fuel oil storage tanks, Diesel A.2.1.18 oeain Generator fuel oil day tanks, diesel fire pump fuel oil day tanks and auxiliary boiler fuel oil storage tank.

18 Rato VselSuvilane Enhance the program to specify that all pulled and tested capsules, A19 Prior to the period of extended 18 Rato VselSuvilane unless discarded before August 31, 2000, are placed in storage.

A...9 operation.

Enhance the program to specify that if plant operations exceed the limitations or bounds defined by the Reactor Vessel Surveillance 19 eatr ese urellne Program, such as~ operating at a lower cold leg temperature or A...9 Prior to the period of extended 19 RacorVese Srvilane higher fluence, the impact of plant operation changes on the extent A...9 operation.

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

Enhance the program as necessary to ensure the appropriate withdrawal schedule for capsules remaining in the vessel such that one capsule will be withdrawn at an outage in which the capsule receives a neutron fluence that meets the schedule requirements of Prior to the period of extended

20.

Reactor Vessel Surveillance 10 CFR 50 Appendix H and ASTM E185-82 and that bounds the A.2.1.19 operation.

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

Enhance the program to ensure that any capsule removed, without 21 RecorVssl uvelane the intent to test it, is stored in a manner which maintains it in a A...9 Prior to the period of extended 21 R acorVese S rv ilan e condition which would permit its future use, including during the A...9 operation.

period of extended operation.

Within ten years prior to the

22.

One-Time Inspection Implement the One Time Inspection Program.

A.2.1.20 peidoexnedpraon

United States Nuclear Regulatory Commission SBK-L-16003 / Enclosure 2 Page 6 of 17 Implement the Selective Leaching of Materials Program. The program will include a one-time inspection of selected Wti ieyaspirt h

23.

Selective Leaching of Materials components where selective leaching has not been identified and A.2.1.21 peidoexnedprao.

periodic inspections of selected components where selective leaching has been identified.

Buried Piping And Tanks Implement the Buried Piping And Tanks Inspection Program.

Within ten years prior to the

24. ! npcinA.2.1.22 period of extended operation OeTmInpcinoAME Implement the One-Time Inspection of ASME Code Class 1 Within ten years prior to the

25.

Code Class 1 Small Bore-Sml oePpn rga.A.2.1.23 peidoexnedprao.

Piping SalBr-iigPorm eido xeddoeain Enhance the program to specifically address the scope of the program, relevant degradation mechanisms and effects of interest, Prior to the period of extended

26.

External Surfaces Monitoring the refueling outage inspection frequency, the training A.2.1.24 oeain requirements for inspector~s and the required periodic reviews to oeain determine program effectiveness.

Inpcino ntra ufcs Implement the Inspection of Internal Surfaces in Miscellaneous Prior to the period of extended

27.

in Miscellaneous Piping and Piping and Ducting Components Program.

A.2.1.25 operation.

Ducting Components Enhance the program to add required equipment, lube oil analysis Prior to the period of extended 28 urctn i nlss required, sampling frequency, and periodic oil changes.

A...6 operation.

29 ubiatn ilAalssEnhance the program to sample the oil for the Reactor Coolant A21.6 Prior to the period of extended 29 urctn i nlss pump oil collection tanks.

A...6 operation.

Enhance the program to require the performance of a one-time ultrasonic thickness measurement of the lower portion of the Prior to the period of extended

30.

Lubricating Oil Analysis Reactor Coolant pump oil collection tanks prior to the period of A.2.1.26 operation.

extended operation.

ASME Section Xl, Subsection Enhance procedure to include the definition of "Responsible Prior to the period of extended

31.

IWL Engineer".

A.2.1.28 operation.

United States Nuclear Regulatoiy¢ Commission SBK-L-16003 / Enclosure 2 Page 7 of 17 Enhance procedure to add the aging effects, additional locations, Prior to the period of extended

32.

Structures Monitoring Program inspection frequency and ultrasonic test requirements.

A.2.1.31 operation.

Enhance procedure to include inspection of opportunity whenProtohepidofxend

33.

Structures Monitoring Program planning excavation work that would expose inaccessible A.2.1.31 operation.

concrete.

Electrical Cables and Connctins ot Sbjet t 10 Implement the Electrical Cables and Connections Not Subject to 3.CER 50.49 Environmental 10 CFR 50.49 Environmental Qualification Requirements A.2.1.32 Proprationteprido.etne Qualification Requirements program.

Electrical Cables and Conetin Not4 Subjonectatl1 Implement the Electrical Cables and Connections Not Subject to Prior to the period of extended

35. Qulfcto eurmns 10 CFR 50.49 Environmental Qualification Requirements Used in A.2.1.33 operation.

QualfictionReqiremnts Instrumentation Circuits program.

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

36.

Environmental Qualification 50.49 Environmental Qualification Requirements program.

A.2.1.34 operation.

Requirements Prior to the period of extended

37.

Metal Enclosed Bus Implement the Metal Enclosed Bus program.

A.2.1.35 oeain Prior to the period of extended

38.

Fuse Holders Implement the Fuse Holders program.

A.2.1.36 operation.

United States Nuclear Regulatory Commission SBK-L-16003 / Enclosure 2 Page 8 of 17 Electrical Cable Connections Not Subject to 10 CFR 50.49 Implement the Electrical Cable Connections Not Subject to 10 A...7 Prior to the period of extended 9.Environmental Qualification CFR 50.49 Environmental Qualification Requirements program.,

213 operation.

Requirements Prior to the period of extended

40.

345 KV SF6 Bus Implement the 345 KV SF6 Bus program.

A.2.2.1 oeain Metal Fatigue of Reactor Enhance the program to include additional transients beyond those A231 Prior to the period of extended

41.

Coolant Pressure Boundary defined in the Technical Specifications and UFSAR.

A231 operation.

Metal Fatigue of Reactor Enhance the program to implement a software program, to count A231 Prior tothe period of extended

42.

Coolant Pressure Boundary transients to monitor cumulative usage on selected components.,

operation.

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

43.

including Low Temperature limits to the NRC at the appropriate time to comply with 10 CFR A.2.4.1.4 time to comply with 10 CFR 50 Overpressure Protection Limits 50 Appendix 0.

Appendix 0, Fracture Toughness Requirements.

United States Nuclear Regulatory Commission SBK-L-16003 / Enclosure 2 Page 9 of 17 44.

Environmentally-Assisted Fatigue Analyses (TLAA)

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

(1) Consistent with the Metal Fatigue of Reactor Coolant Pressure Boundary Program Seabrook Station will update the fatigue usage calculations using refined fatigue analyses, if necessary, to determine acceptable CUFs (i.e., less than 1.0) when accounting for the effects of the reactor water environment. This includes applying the appropriate Fen factors to valid CUFs determined from an existing fatigue analysis valid for the period of extended operation or from an analysis using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case).

(2) If acceptable CUFs cannot be demonstrated for all the selected locations, then additional plant-specific locations will be evaluated. For the additional plant-specific locations, if CUF, including environmental effects is greater than 1.0, then Corrective Actions will be initiated, in accordance with the Metal Fatigue of Reactor Coolant Pressure Boundary Program, B.2.3.1.

Corrective Actions will include inspection, repair, or replacement of the affected locations before exceeding a CUF of 1.0 or the effects of fatigue will be managed by an inspection program that has been reviewed and approved by the NRC (e.g., periodic non-destructive examination of the affected locations at inspection intervals to be determined by a method accepted by the NRC).

A.2.4.2.3 At least two years prior to the period of extended operation.

United States Nuclear Regulatoty, Commission SBK-L-16003 / Enclosure 2 Page 10 of 17 5.Number Not Used Protective Coating Monitoring Enhance the program by designating and qualify'ing an Inspector 8

Prior to the period of extended

46.

and Maintenance Coordinator and an Inspection Results Evaluator.

A...8 operation.

Enhance the program by including, "Instruments and Equipment Monitring needed for inspection may include, but not be limited to, Protective Coating Moioig flashlight, spotlights, marker pen, mirror, measuring tape, A.2.1.38 Prior to the period of extended

47. and Maintenancemagnifier, binoculars, camera with or without wide angle lens, oeain and self sealing polyethylene sample bags."

Protective Coating Monitoring Enhance the program to include a review of the previous two A...8 Prior to the period of extended

48.

and Maintenance monitoring reports.,..13 operation.

Enhance the program to require that the inspection report is to be Protective Coating Monitoring evaluated by the responsible evaluation personnel, who is to A...8 Prior to the period of extended 4.and Maintenance prepare a summary of findings and recommendations for future A...8 operation.

surveillance or repair.

Baseline inspections were Perform UT of the accessible areas of the containment liner plate completed during OR16.

ASME Section XI, Subsection inte

~

o h osuebrirfrls fmtra.Prom A17 Repeat containment liner UT

50.

IWE intevcnt ftemitr are o oso aeil efr 7

thickness examinations at opportunistic UT of inaccessible areas.

nevl fnomr hnfv (5) refueling outages.

51.

Number Not Used ASMESecionXISubsection.

Implement measures to maintain the exterior surface of the A5M2SetioWXI Containment Structure, from elevation -30 feet to +20 feet, in a A.2.1.28 Complete dewatered state.

Replace the spare reactor head closure stud(s) manufactured fromProtohepidofxend

53.

Reactor Head Closure Studs the bar that has a yield strength > 150 ksi with ones that do not A.2.1.3 oeain exceed 150 ksi.

oeain

United States Nuclear Regulatory Commission SBK-L-16003 / Enclosure 2 Page 11 ofl17

54. ISteam Generator Tube Integrity NextEra will address the potential for cracking of the primary to secondary pressure boundary due to PWSCC of tube-to-tubesheet welds using one of the following two options:

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

2) Perform an analytical evaluation showing that the structural integrity of the steam generator tube-to-tubesheet interface is adequately maintaining the pressure boundary in the presence of tube-to-tubesheet weld cracking, or redefining the pressure boundary in which the tube-to-tubesheet weld is no longer included and, therefore, is not required for reactor coolant pressure boundary function. The redefinition of the reactor coolant pressure boundary must be approved by the NRC as part of a license amendment request.

A.2.1.10 Complete ntgiy Seabrook will perform an inspection of each steam generator to Within five years prior to the 5 StaGeeaoTueassess the condition of the divider plate assembly.,..11 period of extended operation.

Closed-Cycle Cooling Water Reietesainpormdcmnst elc h PIPrior to the period of extended

56.

System Guideline operating ranges and Action Level values for hydrazine A.2.1.12 operation.

and sulfates.

Closed-Cycle Cooling Water Reietesainpormdcmnst elc h PIPrior to the period of extended

57.

SytmGuideline operating ranges and Action Level values for Diesel A.2.1.12 operation.

SystemGenerator Cooling Water Jacket pH.

Update Technical Requirement Program 5.1, (Diesel Fuel OilProtohepidofxend 58 Fuel Oil Chemistry Testing Program) ASTM standards to ASTM D2709-96 and A.2.1.18 oeain ASTM D4057-95 required by the GALL XI.M30 Rev 1

United States Nuclear Regulatory Commission SBK-L-16003 / Enclosure 2 Page 12 of 17 Nickl Aloy Nzzle and The Nickel Alloy Aging Nozzles and Penetrations program will Peneratonsimplement applicable Bulletins, Generic Letters, and staff A.2.2.3 Proroteperaiodnf.xene 59 eertosaccepted industry guidelines.

oeain Burie Pipig andTanks Implement the design change replacing the buried AuxiliaryProtohepidofxend

60. ] npcinBoiler supply piping with a pipe-within-pipe configuration with A.2. 1.22 operation.

Inspetionleak detection capability.

Compressed Air Monitoring Replace the flexible hoses associated with the Diesel Generator air A...4 Within ten years prior to the

61.

Program compressors on a frequency of every 10 years.,..11 period of extended operation.

Enhance the program to include a statement that sampling Prior to the period of extended

62.

Water Chemistry frequencies are increased when chemistry action levels are A.2.1.2 operation.

exceeded.

Ensure that the quarterly CVCS Charging Pump testing is continued during the PEO. Additionally, add a precaution to the 63 lwIdcdEointest procedure to state that an increase in the CVCS Charging bAPrior to the period of extended 63.Flw ndce EosonPump mini flow above the acceptance criteria may be indicative A.2.1.2 operation.

of erosion of the mini flow orifice as described in LER 50-275/94-023.

Soil analysis shall be performed prior to entering the period of extended operation to determine the corrosivity of the soil in the vicinity of non-cathodically protected steel pipe within the scope A.2.1.22 Prior to the period of extended

64.

Buried Piping and Tanks of this program. If the initial analysis shows the soil to be non-operation.

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

Implement measures to ensure that the movable incore detectors Prior to the period of

65. Flux Thimble Tube are not returned to service during the period of extended extended operation. - hi operation.

N/A Progress

66.

Number Not Used

United States Nuclear Regulatoty Commission SBK-L-16003 / Enclosure 2 Page 13 of 17 Perform one shallow core bore in an area that was continuously wetted from borated water to be examined for concrete No l1~

Deo mb-

or 31, degradation and also expose rebar to detect any degradation such A213

67. Stuctues onitrin Proram as loss of material. The removed core will also be subjected to petrographic examination for concrete degradation due to ASR Complete per ASTM Standard Practice C856.

6.SrcueMoioigPorm Perform sampling at the leak off collection points for chlorides, A................1

68.

trucuresMoniorin Proram sulfates, pH and iron once every three months.A.131 Complete OpenCycl Cooing ater Replace the Diesel Generator Heat Exchanger Plastisol PVC lined 6.Service Water piping with piping fabricated from AL6XN A.2.1.1 1 Complete 6.System material.

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

70.

System erosion has been eliminated or whether this remains an issue in

,A.2.1.12 period of extended operation.

the primary component cooling water system.

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

Program. Testing will be performed to confirm that parameters A2.3A Prior to the period of extended 7.Monitoring Program being monitored and acceptance criteria used are appropriate oeain to manage the effects of ASR.

72 lwAclrtdCroin Enhance the program othncuer thanFaCeetofwl.tinn Prior to the period of extended

72.

lowAcceeraed Crroion caused by mechanisms ohrta A.A218 oeain Enhance the program to include performance of focused Inspection of Internal Surfaces examinations to provide a representative sample of 20%, or a

73.

in Miscellaneous Piping and maximum of 25, of each identified material, environment, and A.2.l.25 Prior to the period of extended Ducting Components aging effect combinations during each 10 year period in the period operation.

of extended operation.

United States Nuclear Regulatory Commission SBK-L-16003 / Enclosure 2 Page 14 of 17 Enhance the program to perform sprinkler inspections annually per the guidance provided in NFPA 25 (2011 Edition). Inspection will ensure that sprinklers are free of corrosion, foreign materials, paint, and physical damage and installed in the proper orientation

74.

ireWate Sytem(e.g.,

upright, pendant, or sidewall). Any sprinkler that is painted, corroded, damaged, loaded, or in the improper orientation, and any glass bulb sprinkler where the bulb has emptied, will be evaluated for replacement.

Enhance the program to a) conduct an inspection of piping and branch line conditions every 5 years by opening a flushing connection at the end of one main and by removing a sprinkler toward the end of one branch line for the purpose of inspecting for the presence of foreign organic and inorganic material per the guidance provided in NFPA 25 (2011 Edition) and b) If the

75.

Fire Water System presence of sufficient foreign organic or inorganic material to obstruct pipe or sprinklers is detected during pipe inspections, the material will be removed and its source is determined and corrected.

In buildings having multiple wet pipe systems, every other system shall have an internal inspection of piping every 5 years as described in NFPA 25 (2011 Edition), Section 14.2.2.

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

main drain tests

76.

Fire Water System deluge valve trip tests fire water storage tank exterior surface inspections Prior to the period of extended operation.

Prior to the period of extended operation.

United States Nuclear Regulatoiy, Commission SBK-L-16003 / Enclosure 2 Page 15 of 17 The Fire Water System Program will be enhanced to include the following requirements related to the main drain testing per the guidance provided in NFPA 25 (2011 Edition).

The requirement that if there is a 10 percent reduction in full Prior to the period of extended

77.

Fire Water System flow pressure when compared to the original acceptance tests A.2.1.16 oeain or previously performed tests, the cause of the reduction shall oeain be identified and corrected if necessary.

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

Enhance the program to include periodic inspections of in-scope insulated components for possible corrosion under insulation. A sample of outdoor component surfaces that are insulated and aProtohepidofxend

78.

External Surfaces Monitoring sample of indoor insulated components exposed to condensation A.2.1.24 oeain (due to the in-scope component being operated below the dew point), will be periodically inspected every 10 years during the period of extended operation.

Enhance the program to include visual inspection of internal 7.Open-Cycle Cooling Water cotnslnnsfor loss of coating integrity.

A.2. 1.11 Within 10 years prior to the System cotnslnnsperiod of extended operation.

Enhance the program to include visual inspection of internal Within 10 years prior to the

80.

Fire Water System coatings/linings for loss of coating integrity.

A.2.1.16 peidoexnedprao.

81.

uel il hemitryperiod of extended operation.

Inspctio ofIntenalSurfces Enhance the program to include visual inspection of internal Within 10 years prior to the

82.

in Miscellaneous Piping and coatings/linings for loss of coating integrity.

A.2.1.25 peidoexnedprao.

Ducting Componentspeidoexnedprao.

United States Nuclear Regulatory Commission SBK-L-16003 / Enclosure 2 Page 16 of 17 Enhance the ASR AMP to install extensometers in Tier 3 areas of structures to monitor expansion due to alkali-silica reaction in the

83.

Alkali-Silica Reaction out-of-plane direction.

A.2.1.31A December 31,2016.

Monitoring Monitoring expansion in the out-of-plane direction will commence upon installation of the extensometers in 2016 and continue through the period of extended operation.

8.ASME Section XI, Subsection Evaluate the acceptability of inaccessible areas for structures A...8 Prior to the period of extended IWL within the scope of ASME Section XI, Subsection IWL Program.

oeain Enhance the program to perform additional tests and inspections on the Fire Water Storage Tanks as specified in Section 9.2.7 of

85.

Fire Water System NFPA 25 (2011 Edition) in the event that it is required by Section A...6 Prior to the period of extended 9.2.6.4, which states "Steel tanks exhibiting signs of interior A...6 operation.

pitting, corrosion, or failure of coating shall be tested in accordance with 9.2.7."

86 ieWte ytmEnhance the program to include disassembly, inspection, and A.2.1.16 Prior to the period of extended 8.FrWaeSytmcleaning of the mainline strainers every 5 years.

operation.

Increase the frequency of the Open Head Spray Nozzle Air Flow

87.

Fire Water System Test from every 3 years to every refueling outage to be consistent A.2.1.16 Prior to the period of extended with LR-ISG-2012-02, AMP XI.M27, Table 4a.

operation.

88.

Fire Water System Enhance the program to include verification that a) the drain holes associated with the transformer deluge system are draining to ensure complete drainage of the system after each test, b) the deluge system drains and associated piping are configured to completely drain the piping, and c) normally-dry piping that could have been wetted by inadvertent system actuations or those that occur after a fire are restored to a dry state as part of the suppression system restoration.

A.2.1.16 Within five years prior to the period of extended operation.

United States Nuclear Regulatory Commission Page 17 of 17 SBK-L-16003 / Enclosure 2 Incorporate Coating Service Level III requirements into the RCP Motor Refurbishment Specification for the internal painting of the

Inspection of Internal Surfaces motor upper bearing coolers and motor air coolers. All four RCP Prior to the period of extended 89.in isellneus ipng nd motors will be refurbished and replaced using the Coating Service A.2.1.25 operation.

Ductng CmponntsLevel III requirements prior to entering the period of extended operation.

Implement the PWR Vessel Internals Program. The program will be implemented in accordance with MRP-227-A (PressurizedProtohepidofxend PWR Vessel Internals Water Reactor Internals Inspection and Evaluation Guidelines)

A.2.1.7 oprtn 90, and NEI 03-08 (Guideline for the Management of Materialsoprtn Issues).

Enhance the ASR Aging Management Program to require structural evaluations be performed on buildings and components affected by deformation as necessary to ensure that the structural function is maintained. Evaluations of structures will validate structural performance against the design basis, and may use results from the large-scale test programs, as appropriate.

Evaluations for structural deformation will also consider the impact to functionality of affected systems and components (e.g.,

Alkali-Silica Reaction conduit expansion joints). NextEra will evaluate the specific A213A Mrh1,22 91 Monitoring circumstances against the-design basis of the affected system or A213A Mrh1,22 component.

Enhance the ASR AMP to include additional parameters to be monitored based on the results of the CEB Root Cause, Structural Evaluation and walk downs. Additional parameters monitored will include: alignment of ducting, conduit, and piping; seal integrity; laser target measurements; key seismic gap measurements; and additional instrumentation.