ML052000173

License Renewal Application - Clarification to Responses to Previously Answered NRC Requests for Additional Information

ML052000173
Person / Time
Site:	Nine Mile Point
Issue date:	07/14/2005
From:	Spina J Constellation Energy Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NMPIL 1960, TAC MC3272, TAC MC3273
Download: ML052000173 (15)

Text

Constellation Energy-P.O. Box 63 Lycoming, NY 13093 Nine Mile Point Nuclear Station July 14, 2005 NMP1L 1960 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Nine Mile Point Units 1 and 2 Docket Nos. 50-220 and 50-410 Facility Operating License Nos. DPR-63 and NPF-69 License Renewal Application - Clarification to Responses to Previously Answered NRC Requests for Additional Information (TAC Nos. MC3272 and MC3273)

Gentlemen:

By letter NMPIL 1962, dated July 14, 2005, Nine Mile Point Nuclear Station, LLC (NMPNS) submitted an amended License Renewal Application (LRA) and requested that the formal NRC review that was temporarily suspended recommence at the earliest time practicable. This temporary suspension was a result of our letter NMP1L 1933, dated March 3, 2005, that requested a grace period to develop and implement a recovery plan designed to address several NRC issues. The NRC granted the request in a letter dated March 7, 2005, and the recovery plan was presented to the NRC staff in a meeting held on March 30, 2005.

During the recovery plan implementation, several tasks modified work that had been previously completed. As a result of these changes, a number of earlier RAI responses were modified or superceded. Attachment 1 lists the specific responses affected by this process. Where applicable, the more recent information has been appropriately incorporated into the amended LRA and is referenced in the editorial features of the included "road map." This "road map" concept is explained in the cover letter for the amended LRA (NMPIL 1962) and was discussed with the NRC staff in our meeting on June 9, 2005. In addition to incorporating the results of the responses in the amended LRA, we believe it is appropriate to specifically address these modified or superceded responses in a separate letter to assure all information is current and accurate. summarizes those responses.

Page 2 NMP1L 1960 Any commitments associated with the information contained in this submittal have been incorporated into the amended LRA and summarized in Appendix A thereof.

If you have any questions about this submittal, please contact David Dellario, NMPNS License Renewal Project Manager, at (315) 349-7141.

Very truly yours, J

es A. Spina ice President Nine Mile Point JAS/JJ/sac

Page 3 NMP1L 1960 STATE OF NEW YORK

TO WIT COUNTY OF OSWEGO I, James A. Spina, being duly sworn, state that I am Vice President Nine Mile Point, and that I am duly authorized to execute and file this supplemental information on behalf of Nine Mile Point Nuclear Station, LLC. To the best of my knowledge and belief, the statements contained in this submittal are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Nine Mile Point employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.

Subscribed and sworn before me, a Notary Public in and for the State of New York and County of Oswego, this WI dayof Ad 2005.

WITNESS my Hand and Notarial Seal:

SANDRA A. OSWALD Notary Public. State of New York No. 010S6032276 Qualified in Oswego Cpunty Commission Expires

{o/nS/eS_

My Commission Expires: d oloslos Notary Public ai

}a, 066 5 IJ 'Date Attachments:

1. List of RAIs Modified or Superceded by Recovery Project Tasks

2. Clarification of Responses cc:

Mr. S. J. Collins, NRC Regional Administrator, Region I Mr. G. K. Hunegs, NRC Senior Resident Inspector Mr. T. G. Colburn, Senior Project Manager, NRR Mr. N. B. (Tommy) Le, License Renewal Project Manager, NRR Mr. J. P. Spath, NYSERDA

ATTACHMENT 1 Nine Mile Point Nuclear Station (NMPNS)

NRC Requests for Additional Information (RAI)

List of RAIs Modified or Superceded by Recovery Proiect Tasks Page I of 9 to NMP IL 1960 RAI Number Letter Letter Date Status (NMP1L) 16 1900 12/17/2004 RAI response uses term "NSR Functional support." LRA modified to "NSR Structural support" subsequent to this RAI.

2.1-2 RO 1904 12/22/2004 RAI response was modified by RAI 2.1-1 in NMP1L 1922 dated 1/31/2005.

2.1-2 RI 1922 1/31/2005 RAI response replaces response provided in NMP1L 1904 dated 12/22/2004.

2.1-4 RO 1904 12/22/2004 Portions are superseded by response to RAI 2.1-4 in NMP1L 1958 dated 7/15/2005.

2.1-4 RI 1958 7/15/2005 RAI response replaces response provided in NMP1L 1904 dated 12/22/2004.

2.1-7 RO 1904 12/22/2004 RAI response was modified in RAI 2.1-7 in NMP1L 1922 dated 1/31/2005.

2.1-7 RI 1922 1/31/2005 RAI response replaces response provided in NMP1L 1904 dated 12/22/2004.

2.3.3.A.02-2 1905 12/22/2004 RAI response was modified in RAI 2.3.3.A.2-2 in RO NMP1L 1927 dated 2/11/2005.

2.3.3.A.02-2 1927 2/11/2005 RAI response replaces response provided in RI NMP1L 1905 dated 12/22/2004.

2.3.3.A.09-07 1899 12/17/2004 RAI response was modified in RAI NMP1L 1927 RO dated 2/11/2005. RAI response uses term "NSR Functional support." LRA modified to "NSR Structural support" subsequent to this RAI.

2.3.3.A.09-07 1927 2/11/2005 RAI response replaces response provided in RI NMP1L 1899 dated 12/17/2004.

2.3.3.A.09-08 1899 12/17/2004 No change to RAI response is required. B2.1.20, One-Time Inspection Program, was modified subsequent to this RAI.

2.3.3.A.09-14 1899 12/17/2004 B2.1.17, Fire Water System Program, was modified after this RAI response. No technical changes to the response. RAI not referenced but change is correct.

2.3.3.A.16-1 1905 12/22/2004 RAI response was modified in NMP1L 1927 dated RO 2/11/2005.

2.3.3.A.16-1 1927 2/11/2005 RAI response replaces response provided in RI NMPIL 1905 dated 12/22/2004.

2.3.3.A.16-6 1905 12/22/2004 RAI response was modified in NMP1L 1927 dated RO 2/11/2005.

2.3.3.A.16-6 1927 2/11/2005 RAI response replaces response provided in R I NMP1L 1905 dated 12/22/2004.

Page 2 of 9 to NMP1L 1960 RAT Number Letter Letter Date Status (NMP1L) 2.3.3.A.19-1 1905 12/22/2004 RAI response was modified in NMP1L 1027.

RO Drawing/scoping issue. No change to RAI response is required.

2.3.3.A.19-1 1927 2/11/2005 RAI response replaces response provided in RI NMP1L 1905 dated 12/22/2004.

2.3.3.A.22-2 1905 12/22/2004 RAI T3.1-1 in NMP1L 1919 commits NMP to a Bolting Integrity Program (GALL XI.M 18, LRA B2.1.36) which supersedes this response.

2.3.3.A.4-2 1922 1/31/2005 RAI response replaces response provided in NMP1L 1905 dated 12/22/2004.

2.3.3.B.05-4 1905 12/22/2004 RAI response was modified in NMP1L 1922 dated RO 1/31/2005.

2.3.3.B.05-4 1922 1/31/2005 RAI response replaces response provided in RI NMP1L 1905 dated 12/22/2004.

2.3.3.B.13-01 1899 12/17/2004 RAI response was modified in NMPIL 1927 dated RO 2/11/2005.

2.3.3.B.13-01 1927 2/11/2005 RAI response replaces response provided in RI NMP1L 1899 dated 12/17/2004.

2.3.3.B.13-22 1899 12/17/2004 RAI response uses term "NSR Functional support." LRA modified to "NSR Structural support" subsequent to this RAI.

2.3.3.B.13-23 1899 12/17/2004 RAI response was modified in NMP1L 1927 dated RO 2/11/2005.

2.3.3.B.13-23 1927 2/11/2005 RAI response replaces response provided in RI NMP1L 1899 dated 12/17/2004.

2.3.3.B.13-25 1899 12/17/2004 RAI response was modified in NMPIL 1927 dated RO 2/11/2005.

2.3.3.B.13-25 1927 2/11/2005 RAI response replaces response provided in RI NMP1L 1899 dated 12/17/2004.

2.3.3.B.13-26 1899 12/17/2004 RAI response was modified in NMP1L 1927 dated RO 2/11/2005.

2.3.3.B.13-26 1927 2/11/2005 RAI response replaces response provided in RI NMP1L 1899 dated 12/17/2004.

2.3.3.B.13-29 1899 12/17/2004 B2.1.17, Fire Water System Program, was modified after this RAI response. No technical changes to the response. RAI not referenced but change is correct.

2.3.3.B.17-2 1905 12/22/2004 RAI response was modified in NMP1L 1927 dated RO 2/11/2005.

2.3.3.B.17-2 1927 2/11/2005 RAI response replaces response provided in RI NMP1L 1905 dated 12/22/2004.

2.3.3.B.22-1 1905 12/22/2004 RAI response was modified in NMPIL 1922 dated RO 1/31/2005.

Page 3 of 9 to NMP1L 1960 RAI Number Letter Letter Date Status (NMP1L) 2.3.3.B.22-1 1922 1/31/2005 RAI response replaces response provided in R I NMP1L 1905 dated 12/22/2004.

2.3.3.B.25-2 1905 12/22/2004 RAI response was modified in NMP1L 1927 dated RO 2/11/2005.

2.3.3.B.25-2 1927 2/11/2005 RAI response replaces response provided in RI NMP1L 1905 dated 12/22/2004.

2.3.3.B.27-2 1905 12/22/2004 Portions are superseded by responses to RAIs 2.1-4, 2.2-3 and 3.1.2.C.4-1 in NMP1L 1958 dated 7/15/2005.

2.3.3.B.27-3 1905 12/22/2004 Portions are superseded by responses to RAIs 2.1-4, 2.2-3 and 3.1.2.C.4-1 in NMP1L 1958 dated 7/15/2005.

2.3.3.B.27-4 1905 12/22/2004 Portions are superseded by responses to RAIs 2.1-4, 2.2-3 and 3.1.2.C.4-1 in NMP1L 1958 dated l_

7/15/2005.

2.3.4.A.3-2 RO 1905 12/22/2004 RAI response was modified in NMP1L 1927.

Minor change. RAI response uses term "NSR Functional support." LRA modified to "NSR Structural support" subsequent to this RAI.

2.3.4.A.3-2 RI 1927 2/11/2005 RAI response replaces response provided in NMP1L 1905 dated 12/22/2004.

2.3.4.B.4-2 RO 1905 12/22/2004 RAI response was modified in NMP1L 1922 dated 1/31/2005.

2.3.4.B.4-2 Ri 1922 1/31/2005 RAI response replaces response provided in NMP1L 1905 dated 12/22/2004.

2.4.A-1 RO 1913 1/10/2005 RAI response was modified in RAI 2.14 in NMP1L 1958 dated 7/15/2005.

2.4.A-2 RO 1913 1/10/2005 Portions are superseded by responses to RAIs 2.2-3 and 3.1.2.C.4-1 in NMP1L 1958 dated 7/15/2005.

2.4.A-3 RO 1913 1/10/2005 RAI response was modified in RAI 2.1-4 in NMP1L 1958 dated 7/15/2005.

2.4.A-4 RO 1913 1/10/2005 RAI response was modified in RAI 2.1-4 in NMP1L 1958 dated 7/15/2005.

2.4.A-5 RO 1913 1/10/2005 Portions are superseded by responses to RAIs 2.1-4,2.2-3 and 3.1.2.C.4-1 in NMP1L 1958 dated 7/15/2005.

2.4.A-6 RO 1913 1/10/2005 Portions are superseded by responses to RAIs 2.1-4,2.2-3 and 3.1.2.C.4-1 in NMP1L 1958 dated 7/15/2005.

2.4.A-7 RO 1913 1/10/2005 RAI response was modified in RAI 2.1-4 in NMP1L 1958 dated 7/15/2005.

2.4.B-1 RO 1913 1/10/2005 RAI response was modified in RAI 2.1-4 in NMP1L 1958 dated 7/15/2005.

Page 4 of 9 to NMP1L 1960 RAI Number Letter Letter Date Status (NMP1L) 2.4.B-2 RO 1913 1/10/2005 RAI response was modified in RAI 2.1-4 in NMP1L 1958 dated 7/15/2005.

2.4.B-3 RO 1913 1/10/2005 RAI response was modified in RAI 2.1-4 in NMP1L 1958 dated 7/15/2005.

2.4.B-4 RO 1913 1/10/2005 RAI response was modified in NMP1L 1958 dated 7/15/2005.

2.4.B-5 RO 1913 1/10/2005 RAI response was modified in RAI 2.1-4 in NMP1L 1958 dated 7/15/2005.

2.4.B-6 RO 1913 1/10/2005 RAI response was modified in NMP1L 1958 dated 7/15/2005.

2.4.B-7 RO 1913 1/10/2005 RAI response was modified in RAI 2.1-4 in NMP1L 1958 dated 7/15/2005.

2.4-1 RI 1958 7/15/2005 RAI response replaces response provided in NMP1L 1913 dated 1/10/2005.

3.1.1-20 1958 7/15/2005 Modifies response provided to RAI 3.1.2.C.4-08 in MNP1L 1909 dated 1/3/2005.

3.1.1-21 1958 7/15/2005 Modifies response provided to RAI CRDRL RI in NMP IL 1927 dated 2/11/2005.

3.1.2.C.4-01 1909 1/3/2005 RAI response was modified in NMP1L 1958 dated RO 7/15/2005.

3.1.2.C.4-01 1958 7/15/2005 RAI response replaces response provided in RI NMP1L 1909 dated 1/3/2005.

3.1.2.C.4-03 1909 1/3/2005 RAIT3.1-1 in NMP1L 1919 commits NMP to a Bolting Integrity Program (GALL XI.M 18, LRA B2.1.36) which supersedes this response.

3.1.2.C.4-08 1909 1/3/2005 Superseded by the responses to RAIs 3.1.1-20 and 3.1.2-21 in NMP1L 1958 dated 7/15/2005.

3.1.2.C.4-09 1909 1/3/2005 Response modified by RAI B2.1.19-1 in NMP1L 1928, dated Response modified by RAIs B2.1.19-1 and BWRVIP-1 in MP1L 1928, dated 2/14/2005, which provide details for BWRVIP.

3.1.2-01 1928 2/14/2005 Response modified in NMP1L 1960. NMP will implement final ASME code change or provide an alternative plan for NMP1 stub tubes at least 1 year prior to the expiration of the current operating license.

3.2-01 1902 12/21/2004 RAI T3.1-1 in NMP1L 1919 commits NMP to a Bolting Integrity Program (GALL XI.M18, LRA B2.1.36) which supersedes this response.

Page 5 of 9

Attachment I to NMPIL 1960 RAI Number Letter Letter Date Status (NMP1L) 3.2-05 1902 12/21/2004 No change to RAI response is required. B2.1.10, Open-cycle Cooling Water System Program, was modified subsequent to the RAI response. No change in intent.

3.2-11 1902 12/21/2004 RAI T3.1-1 in NMP1L 1919 commits NMP to a Bolting Integrity Program (GALL XI.M 18, LRA B2.1.36) which supersedes portions of this response.

3.3.2.A-03.1 1920 1/26/2005 Portions are superseded by response RAI 3.5.1-20 in NMP1L dated 7/15/2005.

3.3.2.A-04.1 1920 1/26/2005 Portions are superseded by responses to RAls 2.2-3 and 3.1.2.C.4-1 in NMP1L 1958 dated 7/15/2005.

3.3.2.A-17.1 1920 1/26/2005 Portions are superseded by responses to RAIs 2.2-3 and 3.1.2.C.4-1 in NMP1L 1958 dated 7/15/2005.

3.3.2-2 1920 1/26/2005 Portions are superseded by responses to RAIs 2.2-3 and 3.1.2.C.4-1 in NMP1L 1958 dated 7/15/2005.

3.4-03 1902 12/21/2004 No change to RAI response is required. Editorial difference: RAI added "Aluminum alloy" but LRA reads "Aluminum alloys containing copper or zinc as the primary alloying elements."

3.4-05 1902 12/21/2004 RAI T3.1-1 in NMP1L 1919 commits NMP to a Bolting Integrity Program (GALL XI.M18, LRA B2.1.36) which supersedes portions of this response.

3.4-07 1902 12/21/2004 Portions are superseded by responses to RAIs 2.2-3 and 3.1.2.C.4-1 in NMP1L 1958 dated 7/15/2005.

3.5.B-02 1913 1/10/2005 Superseded by RAI 3.5.1-20 in NMP1L 1958 dated 7/15/2005.

3.6.2.C-03 RO 1912 1/10/2005 RAI response was modified in NMP1L 1958 dated 7/15/2005.

3.6.2.C-03 RI 1958 7/15/2005 RAI response replaces response provided in NMP1L 1912 dated 1/10/2005.

3.6.2.C-10 1912 1/10/2005 Program B2.1.34, Non-Segregated Bus Inspection Program, was modified subsequent to this response. Modified program requires 6 year inspections interval versus 10 year interval specified in this response.

3.6.2.C-I 1 1912 1/10/2005 Program B2.1.34, Non-Segregated Bus Inspection Program, was modified subsequent to this response.

Page 6 of 9 to NMP IL 1960 RAI Number Letter Letter Date Status (NMP1L) 3.6.2.C-12 1912 1/10/2005 Program B2.1.34, Non-Segregated Bus Inspection Program, was modified subsequent to this response. Modified program requires 6 year inspections interval versus 10 year interval specified in this response.

4.3.1-3 RO 1891 12/6/2004 Portions are superseded by response to RAI 4.3.1-3 in NMP1L 1958 dated 7/15/2005.

4.3.1-3 Ri 1958 7/15/2005 RAI response replaces response provided in NMP1L 1891 dated 2/6/2004.

4.6.2-1 RO 1891 12/6/2004 RAI response was modified in RAI 4.6.2-1 in NMP1L 1958 dated 7/15/2005.

4.6.2-1 RI 1958 7/15/2005 RAI response replaces response provided in NMP1L 1891 dated 2/6/2004.

4.7.2-1 RO 1915 1/14/2005 RAI response was modified in NMP1L 1958 dated 7/15/2005.

4.7.2-1 RI 1958 7/15/2005 RAI response replaces response provided in NMP1L 1915 dated 1/14/2005.

4.7.2-2 RO 1915 1/14/2005 RAI response was modified in NMP1L 1958 dated 7/15/2005.

4.7.2-2 Ri 1958 7/15/2005 RAI response replaces response provided in NMP1L 1915 dated 1/14/2005.

Audit 003 1880 10/29/2005 Response modified in NMP1L 1960. B2.1.2, Boraflex Monitoring Program, is an existing program that, upon enhancement, will be consistent with the ten elements of Aging Management Program XI.M22, "Boraflex Monitoring," specified in NUREG-1801.

Audit 004, 5, 6, 1880 10/29/2005 Response modified in NMPlL 1960. B2.1.2, 7, 8, 9, 147 Boraflex Monitoring Program, is an existing program that, upon enhancement, will be consistent with the ten elements of Aging Management Program XI.M22, "Boraflex Monitoring," specified in NUREG-1801.

Audit 018, 23, 1880 10/29/2005 Subsequent to RAI response, B2.1.2, Water 24, 25, 54, 60, Chemistry Program was modified to read 62, 63, 66 "determine concentration of monitored species."

Audit 032 1880 10/29/2005 Minor revisions to response as described in RAI 3.6.2.C-3 in NMP1L 1958 dated 7/15/2005.

Audit 100, 101.

1888 11/19/2004 No change to RAI response is required. B2.1.15, 102, 103 and BWR Reactor Water Cleanup System Program, 104 was modified subsequent to this RAI.

Page 7 of 9 to NMP1L 1960 RAI Number Letter Letter Date Status (NMP1L)

Audit 126 1880 10/29/2005 No change to RAI response is required. NMP did adopt GALL Program XI.E2 for Non-EQ Electrical Cables Used in Instrumentation Circuits Program. See LRA Section B2.1.30.

Audit 131 1880 10/29/2005 Response modified in NMP1L 1960. NMP not required to have a Medium Voltage Cable Program.

Audit 148 1880 10/29/2005 Response modified by changes to LRA Section B2.1.6, BWR Stress Corrosion Cracking Program.

Audit 156 (For 1892 12/6/2004 NMP1L 1927, dated 2/11/2005, provides response VFLD) on this subject (except for VFLD). Response replaces response provided in NMPIL 1880 and 1888. Position on VFLD is explained in NMP1L 1960.

Audit 156 1927 2/11/2005 NMP1L 1927, dated 2/11/2005, provides response (VFLD) on this subject (except for VFLD). Response replaces response provided in NMPIL 1880 and 1888. Position on VFLD is explained in NMP1L 1960.

Audit 156 RO 1880 10/29/2005 NMP1L 1927, dated 2/11/2005, provides response on this subject (except for VFLD). Response replaces response provided in NMP1L 1880 and 1888. Position on VFLD is explained in NMP1L 1960.

Audit 156 RI 1888 11/19/2004 NMP1L 1927, dated 2/11/2005, provides response on this subject (except for VFLD). Response replaces response provided in NMP1L 1880 and 1888. Position on VFLD is explained in NMP1L 1960.

Audit 156 R2 1927 2/11/2005 NMP1L 1927, dated 2/11/2005, provides response on this subject (except for VFLD). Response replaces response provided in NMP1L 1880 and 1888. Position on VFLD is explained in NMP1L 1960.

B2.1.11-2 RO 1915 1/14/2005 Response clarified in NMP1L 1958 dated 7/15/2005.

B2.1.11-2 RI 1958 7/15/2005 RAI response replaces response provided in NMP1L 1915 dated 01/14/2005.

B2.1.19-1 1928 2/14/2005 Supersedes portions of response in RAI 3.1.2.C.4-09 in NMP1L 1909 dated 1/3/2005.

B2.1.33-1 1901 12/17/2004 Portions are superseded by responses to RAIs 2.1-4, 2.2-3 and 3.1.2.C.4-1 in NMP1L 1958 dated 7/15/2005.

Page 8 of 9 to NMP1L 1960 RAI Number Letter Letter Date Status (NMPIL)

B2.1.33-2 1901 12/17/2004 No change to RAI response is required. B2.1.33, Systems Walkdown Program, was modified subsequent to the RAI response. No change in intent.

B2.1.33-4 1901 12/17/2004 No change to RAI response is required. B2.1.33, Systems Walkdown Program, was modified subsequent to the RAI response. No change in intent.

B2.1-33-5 1901 12/17/2004 No change to RAI response is required. B2.1.33, Systems Walkdown Program, was modified subsequent to the RAI response. No change in intent.

CRDRL RI 1927 2/11/2005 Supplemented by the response to RAI 3.1.1-21 in I_

_NMP1L 1958 dated 7/15/2005.

Page 9 of 9

ATTACHMENT 2 Nine Mile Point Nuclear Station (NMPNS)

Clarification of Responses Related To:

1. Vessel Flange Leak Detection Line (VFLDL)

2. Non-EQ Inaccessible Medium Voltage Cable Program

3. Bolting Integrity Program

4. Boraflex Monitoring Program

5. Control Rod Stub Tubes Page 1 of 3 to NMP1L 1960 Vessel Flange Leak Detection Line:

The NMPl Vessel Flange Leak Detection Line (VFLDL) has been re-classified as 'Within the Scope of License Renewal' (WSLR). Classification of the NMP1 VFLDL as WSLR reverses the NMP position previously stated in letters NMP1L 1888 dated November 19, 2004, NMPIL 1892 dated December 6, 2004, and NMP1L 1927 dated February 11, 2005.

NMP1 classified the NMP1 VFLDL as WSLR as a result of the NMP NSR re-scoping efforts.

Although the NMP1 VFLDL does not perform an RPV a pressure boundary function, leakage around the reactor vessel seal rings could accumulate in the VFLD line and cause cracking.

Therefore, the VFLDL is considered to contain NSR systems and components whose failure could prevent satisfactory accomplishment of functions identified in 10 CFR 54.4(a)(1).

Previously, the NMP1 VFLDL was considered out of scope because it is not part of the RPV pressure boundary.

The NMP LRA was revised to show that the NMP1 VFLDL is in-scope with cracking identified as an aging effect requiring management. Aging management for the NMP1 VFLDL is provided by the One-Time Inspection, Water Chemistry, and ASME Section XI programs.

The NMP2 VFLD was already classified as WSLR.

Non-EQ Inaccessible Medium Voltage Cable Program:

Program B2.1.31, Non-EQ Inaccessible Medium Voltage Cables (NUREG 1801, Program XI.E3), has been deleted from the NMP LRA because the scoping performed to develop the program determined that NMP has no inaccessible medium voltage cables subject to aging management review (AMR). NMP1 has no inaccessible medium voltage cables that are WSLR.

NMP2 has no inaccessible medium voltage cables within the scope of license renewal that meet the criteria specified in NUREG 1801, Program XI.E3, for requiring aging management.

Therefore, the program for non-EQ inaccessible medium voltage cables in LRA Section B2.1.31 is not required.

NMP LRA Appendix A, Sections Al.1.26 and A2.1.26 and Appendix B, Section B2.1.32 have been replaced with "There are no inaccessible medium voltage cables at NMP1 or NMP2 that meet the NUREG-1801,Section XI.E3 Program criteria for being subject to AMR; therefore, this program is not being implemented at NMP." Other sections of the NMP LRA have been revised accordingly.

Page 2 of 3 to NMP1L 1960 Bolting Integrity Program:

NMP has revised the LRA to include Program B2.1.36, "Bolting Integrity" consistent with commitments made in letter NMPIL 1919 dated 1/20/2005. The NMP bolting integrity program is an existing program that will be enhanced, as described in LRA Section B2.1.36, to be consistent with NUREG-1801, Section XL.M18, Bolting Integrity, and the latest industry and regulatory License Renewal precedence. The enhanced bolting integrity program will be implemented prior to the start of the period of extended operation.

NMP LRA Appendix A, Sections A1.1.38 and A2.1.37 and Appendix B, Section B2.1.36 have been added to describe the NMP Bolting Integrity Program. Applicable sections of the NMP LRA have revised to credit the Bolting Integrity Program for aging management where appropriate.

Boraflex Monitoring Program (NMP1 only):

NMP has revised LRA Section B2.1.12, Boraflex Monitoring Program, to specify that the program for NMP1 will be enhanced to require periodic in-situ neutron attenuation testing and measurement of boron areal density to confirm the correlation of the conditions of test coupons to those of Boraflex racks that remain in use during the period of extended operation. After enhancement, the NMP1 Boraflex Monitoring Program will be consistent with the ten elements of Aging Management Program XI.M22, "Boraflex Monitoring," specified in NUREG-1801.

The enhanced program will be implemented prior to the period of extended operation.

Control Rod Drive Stub Tubes (NMP1 Only):

NMP has revised LRA Section B2.1.8, BWR Vessel Internals Program (NUREG 1801, Program XI.M9), to clarify its positions related to the use of roll/expansion techniques for the repair of leaking NMP1 CRD stub tubes. In the response to RAI 3.1.2-1 in NMP1L 1928 dated 2/14/2005, NMP committed to implement a strategy whereby during the period of extended operation a leaking CRD stub tube penetration would be roll repaired. If, following the roll repair, this stub tube were to leak within acceptable limits, then a weld repair would be effected no later than one operating cycle following discovery of the leakage.

As acknowledged by the NRC in RAI 3.1.2-2, the ASME Code Committee is evaluating the acceptability of roll/expansion techniques as a permanent repair for CRD stub tubes. Therefore, NMP will follow the status of the proposed ASME Code change with respect to allowing roll/expansion techniques of CRD stub tubes, and will implement the final code change or provide an alternative plan for the repair of the NMPI CRD stub tubes during the period of extended operation. If an alternative plan is proposed, it will be submitted at least 1 year prior to the expiration of the current operating license.

Page 3 of 3