L-2022-043, Subsequent License Renewal Application Revision 1 - Supplement 1

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Subsequent License Renewal Application Revision 1 - Supplement 1
ML22097A202
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 04/07/2022
From: Maher W
Florida Power & Light Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2022-043
Download: ML22097A202 (391)
v • d • e


Text

April 7, 2022 L-2022-043 10 CFR 54.17 U.S. Nuclear Regulatory Commission Attn: Document Control Desk 11545 Rockville Pike One White Flint North Rockville, MD 20852-2746 St. Lucie Nuclear Plant Units 1 and 2 Dockets 50-335 and 50-389 Facility Operating Licenses DPR-67 and NPF-16 SUBSEQUENT LICENSE RENEWAL APPLICATION REVISION 1 - SUPPLEMENT 1

References:

1. FPL Letter L-2021-192 dated October 12, 2021 - Subsequent License Renewal Application - Revision 1 (ADAMS Accession No. ML21285A107)
2. U.S. Nuclear Regulatory Commission (NRC) Letter dated September 24, 2021, St. Lucie Plant, Units 1 and 2 - Aging Management Audit Plan Regarding the Subsequent License Renewal Application Review (ADAMS Accession No. ML21245A305)

FPL, owner and licensee for St. Lucie Nuclear Plant (PSL) Units 1 and 2, has submitted a revised subsequent license renewal application (SLRA) for the Facility Operating Licenses for PSL Units 1 and 2 (Reference 1).

During NRCs aging management audit of the SLRA with FPL (Reference 2), FPL agreed to supplement the SLRA (Enclosure 3, Attachment 1 of Reference 1) with new or clarifying information. The attachments to this letter provide that information.

For ease of reference, the index of attachment topics is provided on page 3 of this letter. In each attachment, changes are described along with the affected section(s) and page number(s) of the docketed SLRA (Enclosure 3, Attachment 1 of Reference 1) where the changes are to apply. For clarity, revisions to the SLRA are provided with deleted text by strikethroughs and inserted text by bold red underline. Revisions to SLRA tables are shown by providing excerpts from each affected table.

Should you have any questions regarding this submittal, please contact me at (561) 304-6256 or William.Maher@fpl.com.

Florida Power & Light Company 15430 Endeavor Drive, Jupiter, FL 33478

St. Lucie Nuclear Plant Units 1 and 2 Dockets 50-335 and 50-389 L-2022-043 Page 2 of 3 I declare under penalty of perjury that the foregoing is true and correct.

Executed on the 7th day of April 2022.

Sincerely, William Digitally signed by William Maher DN: cn=William Maher, o=Nuclear, ou=Nuclear Licensing Projects, Maher email=william.maher@fpl.com, c=US Date: 2022.04.07 12:49:39 -04'00' William D. Maher Licensing Director - Nuclear Licensing Projects Cc: Regional Administrator, USNRC, Region II Senior Resident Inspector, USNRC, St. Lucie Plant Chief, USNRC, Division of New and Renewed Licenses Senior Project Manager, USNRC, Division of New and Renewed Licenses Chief, Bureau of Radiation Control, Florida Department of Health

St. Lucie Nuclear Plant Units 1 and 2 Dockets 50-335 and 50-389 L-2022-043 Page 3 of 3 Attachments Index Attachment PSL SLRA Revision 1 Enclosure 3 Attachment 1 Topic No.

1 Scoping and Screening EDG and CCW 2 Fire Rated Assemblies 3 Electrical: Fuse Holder Scoping/Screening and Update to SLR-ISG-2021 ELECTRICAL Language 4 Stress Corrosion Cracking and Loss of Material (pitting, crevice) for Stainless Steel, Nickel Alloys, and Aluminum 5 Concrete: Clarification of Related Further Evaluations 6 Plant Structures Corrosion: Clarified AMR Results and Related Further Evaluation 7 Clarifications to Implementation Schedule for Selected Aging Management Programs 8 SLRA Section 4.6, Containment Liner Plate, Metal Containments, and Penetration Fatigue -

Clarification 9 TLAA Section 4.7.1 Leak-Before Break of Reactor Coolant System Piping - Clarification 10 SLRA Section 4.7.7 Flaw Tolerance Evaluation for CASS RCS Piping Components -

Clarification 11 Fatigue Monitoring AMP - Clarification of Enhancements 12 ASME Section XI Inservice Inspection, Subsections IWB, IWC, IWD: Clarified Discussion of Operating Experience for Pressurizer Manway Studs 13 Reactor Head Closure Stud Bolting: Clarified Exceptions 14 Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components AMP Clarification of Industry OE 15 Reactor Vessel Internals Aging Management Review Clarifications 16 Flow-Accelerated Corrosion 17 Bolting Integrity: Clarified Excessive and added Confirmatory Statements 18 Steam Generators: Clarified AMR Results and AMP Scope 19 Open-Cycle Cooling Water System Pipe Replacement Clarification 20 Fire Protection: Clarified AMR Results and Related Further Evaluation 21 Fire Water System Aging Effects and NFPA Clarifications 22 Outdoor and Large Atmospheric Metallic Storage Tanks - Refueling Water Tank Inspection Frequency Clarification 23 Fuel Oil Chemistry - Diesel Oil Storage Tanks Sampling Clarification 24 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components 25 Buried and Underground Piping and Tanks AMP and AMR Updates 26 Clarification of Internal Coatings Items 27 ASME Section XI, Subsection IWE AMP: Clarified Discussions for Enhancements and Related Further Evaluations 28 ASME Section XI, Subsection IWF AMP: AMR corrections, clarified discussions for exception, and enhancement updates 29 Masonry Walls AMP: Clarification to Enhancement 30 Structures Monitoring AMP: Clarifications, Enhancements, and Commitments 31 Inspection of Water-Control Structures Associated with Nuclear Power Plants AMP:

Clarified Discussions for Enhancements and Exceptions End

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 1 Page 1 of 5 Scoping and Screening EDG and CCW Affected SLRA Sections: Table 2.3.3-4, 3.3.2.1.4, 3.3.2.2.8, 3.3.2.2.10, Table 3.3.2-4 SLRA Page Numbers: 2.3-37, 3.3-5, 3.3-23, 3.3-26, 3.3-110, 3.3-120 Description of Change:

Review of original vendor information indicates there are caps on the ends of the Unit 2 EDG day tank vents. These caps are composed of a copper alloy > 15% Zn wire mesh screen, a carbon steel cap, and an aluminum alloy body and are designed to protect the day tank vent lines. Therefore, SLRA Table 3.3.2-4 is revised to add these components. The Unit 1 EDG day tanks vents do not have caps or screens.

There are also no flame arrestors on the day tank vent lines as they are not required per the NFPA 37 and NFPA 30 codes of record.

The clarifications provided above are consistent with the Unit 1 and 2 EDG boundary drawings.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 1 Page 2 of 5 SLRA Table 2.3.3-4, page 2.3-37 is revised as follows:

Table 2.3.3-4 Diesel Generators and Support System Components Subject to Aging Management Review Component Type Component Intended Function(s)

Air motor Pressure boundary Air motor lubricator Pressure boundary Bolting Mechanical closure Expansion joint Fire barrier Pressure boundary Filter (Unit 2 only) Filter Flame arrestor Flame suppression Flexible hose Pressure boundary Heat exchanger (lube oil) Heat transfer Pressure boundary Heat exchanger (radiator) Heat transfer Pressure boundary Orifice Pressure boundary Throttle Piping Pressure boundary Piping and piping components Pressure boundary Structural integrity (attached)

Pump casing (cooling water) Fire barrier Pump casing (engine-driven fuel) Fire barrier Pressure boundary Pump casing (fuel oil transfer) Fire barrier Pump casing (lube oil) Pressure boundary Pump casing (priming) Pressure boundary Sight glass Pressure boundary Silencer Pressure boundary Strainer Filter Pressure boundary Tank (air start) Pressure boundary Tank (day) Pressure boundary Tank (diesel oil storage) Pressure boundary Tank (expansion) Pressure boundary Thermowell Pressure boundary Valve body Pressure boundary

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 1 Page 3 of 5 SLRA Section 3.3.2.1.4, page 3.3-5 is revised as follows:

3.3.2.1.4 Diesel Generators and Support Systems Materials The materials of construction for the emergency diesel generator system components are:

  • Aluminum
  • Aluminum alloy
  • Coating
  • Glass
  • Plexiglas
  • Polyester
  • Rubber
  • Stainless steel SLRA Section 3.3.2.2.8, page 3.3-23 is revised as follows:

Auxiliary Systems contain aluminum piping and piping components exposed to uncontrolled indoor air and outdoor air. A review of PSL OE confirms halides are potentially present in the indoor environment at PSL. As such, all aluminum components exposed to uncontrolled indoor air and outdoor air in the Auxiliary Systems are susceptible to cracking due to SCC and require management via an appropriate program.

SLRA Section 3.3.2.2.10, page 3.3-26 is revised as follows:

Auxiliary Systems contain aluminum piping and piping components exposed to uncontrolled indoor air or outdoor air. A review of PSL OE confirms halides are potentially present in the uncontrolled indoor air and outdoor air environments at PSL. As such, all aluminum components exposed to uncontrolled outdoor air and outdoor air in the Auxiliary Systems are susceptible to loss of material and require management via an appropriate program.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 1 Page 4 of 5 SLRA Table 3.3.2-4, page 3.3-110 is revised as follows:

Table 3.3.2-4: Diesel Generators and Support Systems - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG-2191 Table Notes Type Function Requiring Management Item 1 Item Management Program Filter (Unit 2 Filter Copper Air - outdoor (ext) Cracking External VIII.H.S-454 3.4-1, A only) alloy > Surfaces 106 15% Zn Monitoring of Mechanical Components (B.2.3.23)

Filter (Unit 2 Filter Copper Air - outdoor (int) None None VII.J.AP-144 3.3-1, A only) alloy > 114 15% Zn SLRA Table 3.3.2-4, page 3.3-120 is revised as follows:

Table 3.3.2-4: Diesel Generators and Support Systems - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG-2191 Table Notes Type Function Requiring Management Item 1 Item Management Program Piping (Unit Pressure Aluminum Air - outdoor (ext) Cracking External VII.F3.A- 3.3-1, A 2 only) boundary alloy Surfaces 451b 189 Monitoring of Mechanical Components (B.2.3.23)

Piping (Unit Pressure Aluminum Air - outdoor (ext) Loss of material External VII.F3.A- 3.3-1, A 2 only) boundary alloy Surfaces 763b 234 Monitoring of Mechanical Components (B.2.3.23)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 1 Page 5 of 5 Table 3.3.2-4: Diesel Generators and Support Systems - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG-2191 Table Notes Type Function Requiring Management Item 1 Item Management Program Piping (Unit Pressure Aluminum Air - outdoor (int) Cracking Inspection of VII.F3.A- 3.3-1, A 2 only) boundary alloy Internal 451c 189 Surfaces in Miscellaneous Piping and Ducting Components (B.2.3.24)

Piping (Unit Pressure Aluminum Air - outdoor (int) Loss of material Inspection of VII.F3.A- 3.3-1, A 2 only) boundary alloy Internal 763c 234 Surfaces in Miscellaneous Piping and Ducting Components (B.2.3.24)

Piping (Unit Pressure Carbon Air - outdoor (int) Loss of material Inspection of V.A.E-29 3.2-1, A 2 only) boundary steel Internal 044 Surfaces in Miscellaneous Piping and Ducting Components (B.2.3.24)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 2 Page 1 of 3 Fire Rated Assemblies Affected SLRA Sections: 2.4.17, Table 2.4-17, Table 3.5.2-17 SLRA Page Numbers: 2.4-34, 2.4-36, 3.5-144 Description of Change:

The components type Fire wrap (conduit and steel supports) listed in SLRA Table 2.4-17 also includes cable trays. SLRA Section 2.4.17, Table 2.4-17, and Table 3.5.2-17 are revised to clarify that the fire wrap at St. Lucie also includes cable tray fire wrap. SLRA Table 2.4-17 is also revised to remove a duplicate row.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 2 Page 2 of 3 SLRA Section 2.4.17, page 2.4-34 is revised as follows:

2.4.17 Fire Rated Assemblies Description Fire rated assemblies include fire barriers, fire doors, fire dampers, and penetration seals. The fire rated assemblies are described in Section 9.5.1 of the Unit 1 and Unit 2 UFSARs.

Fire barriers are provided to ensure that the function of one train of redundant equipment necessary to achieve and maintain safe shutdown conditions remains free of fire damage. Fire barriers provide a means of limiting fire travel by compartmentalization and containment. PSL Units 1 and 2 fire barriers include walls, floors, ceilings, radiant energy shields, flame impingement shields, conduit fire wrap, cable tray fire wrap, and conduit plugs. Wall type barriers and shields include concrete and masonry walls.

Fire-resistant panels (e.g., Thermo-lag, sheet metal/ceramic fiber) mounted on steel framing are also used as fire barriers.

SLRA Table 2.4-17, page 2.4-36 is revised as follows:

Table 2.4-17 Fire Rated Assemblies Subject to Aging Management Review Component Type Component Intended Function(s)

Conduit caps Fire barrier Pressure boundary Conduit plugs Fire barrier Fire damper housings Fire barrier Fire doors - airtight Fire barrier Pressure boundary Fire doors - watertight Fire barrier Flood barrier Fire doors (NFPA 805 barriers) Fire barrier Pressure boundary Fire wrap (conduit and steel supports) Fire barrier Fire sealed isolation joint Fire barrier Fire seals - cable tray penetrations Fire barrier Pressure boundary Fire seals - mechanical penetrations Fire barrier Pressure boundary Fire wrap (conduit, cable tray, and steel supports) Fire barrier Flame impingement shields (insulating blankets Fire barrier for cable trays)

Miscellaneous fire barriers Fire barrier Pressure boundary Radiant energy shields Fire barrier

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 2 Page 3 of 3 SLRA Table 3.5.2-17, page 3.5-144 is revised as follows:

Table 3.5.2-17: Fire Rated Assemblies - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Type Function Requiring Management Item Item Management Program Fire wrap Fire barrier Subliming Air Change in Fire Protection VII.G.A-805 3.3-1, B (conduit, cable Pressure compounds: material (B.2.3.15) 267 tray, and steel boundary thermo-lag properties supports 330-1 Cracking Delamination Loss of material Separation

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 3 Page 1 of 10 Electrical: Fuse Holder Scoping/Screening and Update to SLR-ISG-2021-04-ELECTRICAL Language Affected SLRA Sections: Table 2.2-1, 2.5.1.2, 2.5.1.3, Table 2.5-2, 3.6.1.1, Table 3.6.2-1, Table 19-3 (Appendices A1 and A2), B.2.3.38, B.2.3.39, B.2.3.40 SLRA Page Numbers: 2.2-5, 2.5-2, 2.5-4, 2.5-8, 3.6-2, 3.6-28, A1-107, A2-107, B-270, B-271, B-277, B-278, B-284, B-285, B-286 Description of Change:

The SLRA is revised to correct a typographical error for an electrical item in Table 2.2-1.

The SLRA requires revision to clearly identify that certain fuse holders at PSL are in the scope of SLR and require an aging management review. Additionally, a corresponding line item is added to Table 3.6.2-1. The conclusions that there are no aging effects requiring management as presented in SLRA Section 2.5.1.3 remain valid.

Accordingly, SLRA Sections 2.5 and 3.6 are revised to clarify the above.

The SLRA is revised to correct typographical errors for Commitment 42 on Table 19-3 in appendices A1 and A2 Additional clarifying statements in SLRA sections B.2.3.38, B.2.3.39, and B.2.3.40 are required to demonstrate conformance with SLR-ISG-2021 ELECTRICAL, as described in SLRA Section 2.1.6.1.

Accordingly, SLRA Sections B.2.3.38, B.2.3.39, and B.2.3.40 are revised as noted below. These Appendix B sections now reflect the overall statement found in SLRA Section 2.1.6.1 and the specific language updates in the ISG.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 3 Page 2 of 10 SLRA Table 2.2-1, page 2.2-5, is revised as follows:

Table 2.2-1 Plant Level Scoping Report Results In Scope for In Scope for SLRA System Name PSL System Name Sections SLR Unit 1 SLR Unit 2 120/208V Electrical Y Y 2.5 120V Vital AC Y Y 2.5 125VDC (Unit 2) Y Y 2.5 4.16kV Electrical Y Y 2.5 Generation and Distribution Y Y 2.5 Diesel Generator Y Y 2.5 Station Grounding Y Y 2.5 Communications Y Y 2.5 Reactor Protection Y Y 2.5 Nuclear Instrumentation Y Y 2.5 Control Element Drive Mechanism/Control Y Y 2.5 Containment Electrical Penetrations (conductor, non-metallic, and Y Y 2.5 non-pressure boundary portions)

Safeguards Panels Y Y 2.5 Data Acquisition Remote Terminal Unit Y Y 2.5 Miscellaneous Y Y 2.5 Meteorological Monitoring N N N/A Reactor Regulating N N N/A Computer - Process and Reactivity N N N/A Loose Parts Monitoring N N N/A Security N N N/A Cathodic Protection N N N/A Seismic Monitoring N N N/A Meteorological Monitoring N N N/A

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 3 Page 3 of 10 SLRA Section 2.5.1.2, page 2.5-2, bulletized list is revised as follows:

Electrical Penetration Assemblies Insulated cables and connections Metal Enclosed Bus High-voltage insulators Switchyard bus Transmission conductors Uninsulated ground conductors Fuse holders (see discussion below)

SLRA Section 2.5.1.3, page 2.5-4 is revised as follows:

The PSL plant design basis was reviewed to determine that the population of fuses (those not part of a larger assembly) within the scope of SLR had not changed since the approval of the initial LR application. In addition, the PSL transition to the NFPA-805 standard for Fire Protection was reviewed to determine if any new fuses (those not part of a larger assembly) were now considered within the scope of the initial LR evaluation. A plant modification was identified in 2020 (for Unit 2 only) which added a junction box in the 6.9 kV switchgear room (for 125 VDC control power circuits) that contains only fuses and wiring. The PSL Unit 2 125 VDC system is within the scope of SLR. An AMR of the metallic clamp portion of the fuse holders was performed for aging effects consistent with the screening guidance in NUREG-2191, Sect. XI.E5. This fuse box is located in a controlled (benign) environment, the fuses are not manipulated, and the fuses are not subject to electrical stress (high cycling or high heating). There are no relevant aging mechanisms or aging effects for these fuse holders, relative to the insulating material, the metallic clamps, or the fuse box itself (i.e., there are no stressors to cause corrosion or age-related degradation). These fuse holders are within the scope of SLR, but because they do not have relevant aging mechanisms and are not manipulated and are not subject to aging effects, they do not require aging management, consistent with the guidance of NUREG-2191,Section XI.E5.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 3 Page 4 of 10 SLRA Table 2.5-2, page 2.5-8, is revised as follows Table 2.5-2 Electrical and I&C System Commodities Subject to Aging Management Review Component/ Commodities Component Intended Function(s)

Insulated cables and connections Electrical continuity Metal enclosed bus - conductors Electrical continuity Metal enclosed bus - insulators Insulate (electrical)

(sections used for SBO offsite power recovery)

Cable bus - insulated cables (sections used Electrical continuity for SBO offsite power recovery) Insulate (electrical)

Fuse holders (not part of an active Electrical continuity assembly) Insulate (electrical)

High-voltage insulators (for SBO recovery) Insulate (electrical)

Switchyard bus and connections Electrical continuity (for SBO recovery)

Transmission conductors and connections Electrical continuity (for SBO recovery)

Uninsulated ground conductors Electrical continuity (for lightning / fire protection)

SLRA Section 3.6.1, page 3.6-2, is revised to add a new Section 3.6.1.1 as follows:

3.6.1.1 Electrical Commodity Groups Not Requiring Aging Management As described in Section 2.5.1.3, relative to Fuse Holders (not part of active equipment) at PSL, this commodity group is within the scope of SLR and is screened in for aging management review (as passive), but the metallic portions of the fuse holder are not subject to aging management because they do not experience aging mechanisms and do not exhibit aging effects. The subject fuse holders are located in a junction box in a benign environment, are not exposed to environmental stressors (thermal or radiation or moisture), and do not experience electrical stress (high voltage or high cycling). The fuse holders therefore do not warrant aging management, and do not require an aging management program at PSL.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 3 Page 5 of 10 Table 3.6.2-1 on Page 3.6-28 is revised as follows:

Table 3.6.2-1: Electrical and Instrumentation & Control Commodities - Summary of Aging Management Evaluation Structure and/or Component Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Component Intended Requiring Management Item Item Function Management Program (AMP) /

TLAA Fuse Holders (not part Insulate Electrical insulation: Air - indoor None None VI.A.LP-24 3.6-1, 022 I of active equipment) (electrical) Bakelite, Phenolic, controlled or Electrical Insulation Melamine, or uncontrolled Ceramic; Molded Polycarbonate, or other Organic Polymers Fuse Holders (not part Electrical Various Metals used Air - indoor None None VI.A.LP-23 3.6.1, 016 I of active equipment) Continuity for Electrical uncontrolled Metallic Clamp Connection Fuse Holders (not part Electrical Various Metals used Air - indoor None None VI.A.LP-31 3.6.1, 018 I of active equipment) Continuity for Electrical controlled Metallic Clamp Connection Fuse Holders (not part Electrical Various Metals used Air-indoor None None VI.A.LP-7 3.6.1, 017 I of active equipment) Continuity for Electrical uncontrolled Metallic Clamp Connection General Notes A. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

E. Consistent with NUREG-2191 material, environment, and aging effect but a different AMP is credited or NUREG-2191 identifies a plant-specific AMP.

I. Aging effect in NUREG-2191 for this component, material and environment combination is not applicable.

Plant Specific Notes None.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 3 Page 6 of 10 SLRA Section A1 Table 19-3, page A1-107 is revised as follows:

No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 42 Electrical Insulation for XI.E3B Implement the new PSL Inaccessible Instrument and Control Cables No later than 6 months prior to Inaccessible Instrument Not Subject to 10 CFR 50.49 Environmental Qualification the SPEO, or no later than the and Control Cables Not Requirements AMP including the following: last refueling outage prior to Subject to 10 CFR 50.49 the SPEO i.e.:

Environmental Qualification a) Perform sample I&C cable visual inspections and tests (if Requirements (19.2.2.39) necessary) at least every six years. PSL1: 09/01/2035 b) Perform manhole inspections (containing I&C cables in the program) for water accumulations, cable structural supports integrity, sump pump operability verification, and manhole drainage path integrity on at least an annual basis.

c) Perform manhole inspections (containing I&C cables in the program) following a major water event for water accumulations, sump pump operability verification (and associated alarms), and manhole drainage path integrity.

d) Inspection of manholes equipped with water level monitoring and alarms that result in consistent and subsequent pump out of accumulated water prior to wetting or submergence of cables can be performed at least once every five years, if supported by plant OE. Inspections of manholes with water level monitoring and alarms are also performed following event-driven occurrences if water accumulation is indicated by the monitoring system (e.g.,

frequent water level alarms).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 3 Page 7 of 10 SLRA Section A2 Table 19-3, page A2-107 is revised as follows:

No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 42 Electrical Insulation for XI.E3B Implement the new PSL Inaccessible Instrument and Control Cables No later than 6 months prior to Inaccessible Instrument and Not Subject to 10 CFR 50.49 Environmental Qualification the SPEO, or no later than the Control Cables Not Subject Requirements AMP including the following: last refueling outage prior to to 10 CFR 50.49 the SPEO i.e.:

Environmental Qualification a) Perform sample I&C cable visual inspections and tests (if Requirements (19.2.2.39) necessary) at least every six years. PSL2: 10/06/2042 b) Perform manhole inspections (containing I&C cables in the program) for water accumulations, cable structural supports integrity, sump pump operability verification, and manhole drainage path integrity on at least an annual basis.

c) Perform manhole inspections (containing I&C cables in the program) following a major water event for water accumulations, sump pump operability verification (and associated alarms), and manhole drainage path integrity.

d) Inspection of manholes equipped with water level monitoring and alarms that result in consistent and subsequent pump out of accumulated water prior to wetting or submergence of cables can be performed at least once every five years, if supported by plant OE. Inspections of manholes with water level monitoring and alarms are also performed following event-driven occurrences if water accumulation is indicated by the monitoring system (e.g., frequent water level alarms).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 3 Page 8 of 10 SLRA Section B.2.3.38, page B-270, second paragraph, is revised as follows:

This AMP applies to all inaccessible or underground (e.g., installed in buried conduit, embedded raceway, cable trenches, cable troughs, duct banks, vaults, manholes, or direct buried installations) non-EQ medium-voltage cables that are within the scope of SLR and potentially exposed to wetting or submergence (i.e., significant moisture).

Significant moisture is defined as exposure to moisture that lasts more than three (3) days (i.e., long-term wetting or submergence over a continuous period) that, if left unmanaged, could potentially lead to a loss of intended function. Cable wetting or submergence that results from event driven occurrences and is mitigated by occurs for a limited time, as in the case of automatic or passive drainage, is not considered significant moisture for this AMP.

SLRA Section B.2.3.38, page B-270, third paragraph, is revised as follows:

Periodic actions to mitigate inaccessible medium-voltage cable exposure to significant moisture will include inspection for water accumulation in cable manholes and conduits and removing water, as needed. Inspections are performed periodically based on water accumulation over time. The periodic inspections will occur at least once annually with the first inspection for subsequent license renewal (SLR) completed no later than six months prior to entering the SPEO if a water level monitoring system is not installed.

SLA Section B.2.3.38, page B-271, above the first paragraph, is revised to add the following new paragraph:

Proper and reliable operation, as well as self-monitoring features of continuous water level and alarm capabilities of such devices, if installed and credited for five-year inspection intervals, are demonstrated routinely to be functional according to the requirements and attributes of the specific equipment used.

SLRA Section B.2.3.38, page B-271, bottom of page, is revised as follows:

NUREG-2191 Consistency The PSL Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirement AMP will be consistent without exception to the 10 elements of NUREG-2191,Section XI.E3A, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements as modified by NRC SLR-ISG-2021-04-ELECTRICAL, Updated Aging Management Criteria for Electrical Portions of the Subsequent License Renewal Guidance. The PSL Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements AMP therefore conforms to the guidance of SLR-ISG-2021-04-ELECTRICAL, for the NUREG-2191,Section XI.E3A AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 3 Page 9 of 10 SLRA Section B.2.3.39, page B-277, first paragraph, is revised as follows:

This AMP applies to inaccessible (e.g., installed in buried conduit, embedded raceway, cable trenches, cable troughs, duct banks, vaults, manholes, or direct buried installations) (I&C) instrumentation and control cables that are within the scope of SLR and potentially exposed to significant moisture.

SLRA Section B.2.3.39, page B-277, third paragraph, is revised as follows:

Inspection of manholes with water level monitoring and alarms are performed following event-driven occurrences if water accumulation is indicated by the monitoring system (e.g., frequent water level alarms). Proper and reliable operation, as well as self-monitoring features of continuous water level and alarm capabilities of such devices, if installed and credited for five-year inspection intervals, are demonstrated routinely to be functional according to the requirements and attributes of the specific equipment used.

SLRA Section B.2.3.39, page B-278, third paragraph, is revised as follows:

NUREG-2191 Consistency The PSL Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements AMP will be consistent without exception to the 10 elements of NUREG-2191,Section XI.E3B, Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements as modified by SLR-ISG-2021-04-ELECTRICAL, Updated Aging Management Criteria for Electrical Portions of the Subsequent License Renewal Guidance. The PSL Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements AMP therefore conforms to the guidance of SLR-ISG-2021-04-ELECTRICAL, for the NUREG-2191,Section XI.E3B AMP.

SLRA Section B.2.3.39, page B-278, bottom paragraph, is revised as follows:

Industry Operating Experience OE has shown that cable electrical insulation materials undergo increased degradation through aging mechanisms when subjected to significant moisture. Inaccessible I&C cables subjected to significant moisture may result in increased age-related degradation of electrical insulation.

SLRA Section B.2.3.40, page B-284 (second paragraph) is revised as follows:

This AMP applies to underground (e.g., installed in buried conduit, embedded raceway, cable trenches, cable troughs, duct banks, vaults, manholes, or direct buried installations) non-EQ low-voltage power cables, including those designed for continuous wetting or submergence, that are within the scope of SLR and potentially exposed to significant moisture.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 3 Page 10 of 10 SLRA Section B.2.3.40, page B-285 (second paragraph) is revised as follows:

Inspection of manholes with water level monitoring and alarms are performed following event-driven occurrences if water accumulation is indicated by the monitoring system (e.g., frequent water level alarms). Parameters are established for the initiation of an event driven inspection. Proper and reliable operation, as well as self-monitoring features of continuous water level and alarm capabilities of such devices, if installed and credited for five-year inspection intervals, are demonstrated routinely to be functional according to the requirements and attributes of the specific equipment used.

SLRA Section B.2.3.40, page B-286 is revised as follows:

NUREG-2191 Consistency The PSL Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements AMP will be consistent without exception to the 10 elements of NUREG-2191,Section XI.E3C, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements as modified by SLR-ISG-2021 ELECTRICAL, Updated Aging Management Criteria for Electrical Portions of the Subsequent License Renewal Guidance. The PSL Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements AMP therefore conforms to the guidance of SLR-ISG-2021-04-ELECTRICAL, for the NUREG-2191,Section XI.3EC AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 4 Page 1 of 2 Stress Corrosion Cracking and Loss of Material (pitting, crevice) for Stainless Steel, Nickel Alloys, and Aluminum Affected SLRA Sections: Table 3.3-1 SLRA Page Numbers: 3.3-69 Description of Change:

Item 3.3-1, 233 was inadvertently omitted from SLRA Table 3.3-1. Accordingly, SLRA Table 3.3-1 is being revised to add item 3.3-1, 233 even though there are no insulated aluminum components in the Auxiliary Systems.

Additionally, there are no underground stainless steel piping or piping components in the Steam and Power Conversion Systems at St. Lucie. The buried portion is comprised of stainless steel but the underground portion is carbon steel. Underground carbon steel piping is added to SLRA Table 3.4.2-3 per Attachment 25 of this letter.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 4 Page 2 of 2 SLRA Table 3.3-1, page 3.3-69 is revised as follows:

Table 3.3-1: Summary of Aging Management Evaluations for the Auxiliary Systems Item Component Aging Effect / Aging Management Further Discussion Number Mechanism Programs Evaluation Recommended 3.3-1, 233 Insulated aluminum Cracking due to SCC AMP XI.M29, "Outdoor Yes (SRP-SLR Not applicable.

piping, piping and Large Atmospheric Section 3.3.2.2.8) There are no insulated components, tanks Metallic Storage Tanks," aluminum piping, piping exposed to air, AMP XI.M32, "One-Time components, or tanks condensation Inspection," AMP XI.M36, exposed to air in the Auxiliary "External Surfaces Systems.

Monitoring of Mechanical Components," or AMP XI.M42, "Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks"

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 5 Page 1 of 13 Concrete: Clarification of Related Further Evaluations Affected SLRA Sections: 3.5.2.2.1.2, 3.5.2.2.1.8, 3.5.2.2.2.1.2, 3.5.2.2.2.1.4, 3.5.2.2.2.2, 3.5.2.2.2.3.2, 3.5.2.2.2.3.3, Table 3.5.2-1, Table 3.5.2-16, Table 19-3 (Appendices A1 and A2),

B.2.3.33 SLRA Page Numbers: 3.5-21, 3.5-26 through 3.5-27, 3.5-29, 3.5-30, 3.5-31, 3.5-32, 3.5-80, 3.5-86, 3.5-140, 3.5-141, A1-103, A2-103, B-248, B-251 Description of Change:

SLRA Section 3.5.2.2.1.2 concluded that a reduction of strength and modulus of elasticity due to elevated temperatures does not require management for the PSL concrete shield building. To clarify this conclusion with respect to applicable limits specified by NUREG-2192, a brief summary regarding normal (120°F), penetration specification (150°F), and design (264°F) temperature conditions is added to SLRA Section 3.5.2.2.1.2. Additionally, SLRA Table 3.5.2-1 is revised to include an entry addressing thermal insulation used in Type III penetrations through the shield building concrete.

The PSL Structures Monitoring AMP is credited for identifying cracking due to reaction with aggregates in inaccessible concrete areas. Although NRC Information Notice 2011-20 was identified as a developmental reference, further review has determined that an enhancement is needed to incorporate specific indicators of alkali-silica reaction into implementing procedures.

Accordingly, text in SLRA Sections 3.5.2.2.1.8, 3.5.2.2.2.1.2, and 3.5.2.2.2.3.2 is revised. A new enhancement is added to SLRA Section B.2.3.33 along with a brief summary of pertinent documented plant operating experience. The new enhancement is also reflected in updates to the associated commitments presented in SLRA Table 19-3 of both Appendices A1 and A2.

SLRA Section 3.5.2.2.2.1.4 and SLRA Section 3.5.2.2.2.3.3 mention instances where leaching has been observed in accessible areas at PSL. A review of evaluations documented in related action requests confirmed that intended functions of the affected structures are not impacted.

Accordingly, text is added to these SLRA Sections to clarify.

SLRA Section 3.5.2.2.2.2 addresses aging management for insulation on high-temperature process piping outside containment. Text is added to the discussion to clarify that applicable concrete temperature limits specified by NUREG-2192 are not exceeded and no evaluation of elevated temperature is necessary for the subject concrete penetrations. Additionally, a new Plant Specific Note is associated with the applicable entry in SLRA Table 3.5.2-16 to distinguish insulation used in such applications (addressed by the PSL External Surfaces Monitoring of Mechanical Components AMP) from insulation used in Type I and Type III penetrations through the shield building concrete (which does not require aging management).

Note that the markups for SLRA Table 3.5.2-1 include changes associated with Attachments 6, 8, and 20.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 5 Page 2 of 13 SLRA Section 3.5.2.2.1.2, page 3.5-21, is revised as follows:

As described above, the PSL Units 1 and 2 containment building structures have an ASME Class MC Containment Vessel surrounded by a Shield Building, also known as Reactor Containment Building, with a 4 ft annulus separating the Containment Vessel and the Shield Building. As such, there are no concrete containments (ASME Class CC) that would be susceptible to a reduction of strength and modulus of elasticity due to elevated temperatures and the ASME Code Section XI Subsection IWL is not applicable at PSL. The containment air temperature during normal plant operation is less than or equal to 120°F; design temperature is 264°F (a short-term conditioncoincident with maximum accident pressurethat does not require aging management).

Elevated temperature impacts on PSL Shield Building concrete were addressed for the current renewed license in the PSL LRA. Localized hotspots are limited in area and are designed to be maintained below the degradation threshold temperature limits of the ACI standards (i.e., 150°F, except for local areas, such as around penetrations, which are allowed to have increased temperatures not to exceed 200°F).

The potential sources of localized heat environments at PSL Units 1 and 2 containment building structures are from Type I and Type III mechanical penetrations. Type I (hot) penetrations include main steam and feedwater lines which are designed to accommodate high thermal movements and temperature differentials. Type III (semi-hot) penetrations are designed to accommodate moderate thermal movements. Type III penetrations include blowdown, letdown, charging, safety injection, shutdown cooling, RCP bleed-off, and integrated leak rate test (ILRT) lines. Type I (hot) penetration assemblies are insulated to limit Containment Vessel nozzle thermal stresses. Insulation between the process pipe and guard pipe in Type I and Type III penetration assembliesthat also serves to limit Shield Building concrete temperatures.

SLRA Section 3.5.2.2.1.8, second paragraph (page 3.5-26 and continuing to page 3.5-27), is revised as follows:

However, the Structures Monitoring (B.2.3.33) AMP includes opportunistic inspection of inaccessible concrete locations and willhas been enhancedrefined, based on industry/fleet information, to include visual examination for patterned cracking, darkened crack edges, water ingress and misalignment that would be indicative of reaction with aggregates, such as alkali silica reaction (ASR) and alkali carbonate reaction (ACR), and includes opportunistic inspection of inaccessible concrete locations. As such, a plant specific program or plant specific enhancement of the Structures Monitoring (B.2.3.33) AMP is not required to manage this aging effect; rather, inspections and evaluations performed in accordance with the Structures Monitoring (B.2.3.33) AMP will identify the presence of expansion and cracking due to reaction with aggregates should it occur.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 5 Page 3 of 13 SLRA Section 3.5.2.2.2.1.2, page 3.5-29 (paragraph continued from page 3.5-28), is revised as follows:

with pertinent ASTM standards at the time of construction. The Structures Monitoring (B.2.3.33) AMP includes opportunistic inspection of inaccessible concrete locations and willhas been enhancedrefined, based on industry/fleet information, to include visual examination for patterned cracking, darkened crack edges, water ingress and misalignment that would be indicative of reaction with aggregates, such as alkali silica reaction (ASR) and alkali carbonate reaction (ACR),

and includes opportunistic inspection of inaccessible concrete locations.

As such, a plant specific program or plant specific enhancement of the Structures Monitoring (B.2.3.33) AMP is not required to manage this aging effect; rather, inspections and evaluations performed in accordance with the Structures Monitoring (B.2.3.33) AMP will identify the presence of expansion and cracking due to reaction with aggregates should it occur.

SLRA Section 3.5.2.2.2.1.4, page 3.5-29, is revised as follows:

4. PSL Units 1 and 2 concrete structures and concrete components are designed in accordance with ACI 318-63 and 71 and constructed in accordance with ACI 301 using ingredients conforming to ACI and ASTM standards, which provide for a good quality, dense, low permeability concrete. The exterior walls of the PSL concrete structures are exposed to the outside environment and are expected to have rainwater passing over the exterior surface. Components of select foundations are located below groundwater elevation and thus could be susceptible to leaching of calcium hydroxide. Cracks and improperly prepared construction joints provide the easiest mechanism for entry of water and are likely areas for leaching. Leaching has been observed several times in the Unit 1 RAB ECCS Room; evaluations confirmed that the intended function of the concrete structure was not impacted. These structures will continue to be managed by the Structures Monitoring (B.2.3.33) AMP during the SPEO.

SLRA Section 3.5.2.2.2.2, page 3.5-30, is revised as follows:

Reduction of strength and modulus of elasticity due to elevated temperatures of Class 1 structures was evaluated for the current renewed PSL licenses (LRA 3.5.2.3.2), however,. Concrete structural components outside containment do not exceed ACI threshold limits (i.e., 150°F, except for local areas, such as around hot spots for concrete penetrations outside containment, which are allowed to have increased temperatures not to exceed 200°F) and were not evaluated. Conservatively, insulation on process piping with internal temperatures above 200F is included in the scope of SLR to assist in maintaining local concrete temperatures. The aging management of this insulation is provided by the PSL External Surfaces Monitoring of Mechanical Components (B.2.3.23) AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 5 Page 4 of 13 SLRA Section 3.5.2.2.2.3.2, page 3.5-31, is revised as follows:

2. Group 6 structures at PSL are designed and constructed in accordance with ACI 318-63 (Unit 1) and ACI 318-71 (Unit 2) using ingredients/materials conforming to ACI and ASTM standards. The aggregates used in the concrete of the PSL concrete components did not come from a region known to yield aggregates suspected of or known to cause aggregate reactions. All aggregates used at PSL conform to all the requirements of Specification of Concrete Aggregates ASTM-C33-67 and -71, to ensure that the hardness, weight, strength, durability, reactivity, and gradation fall within the limits established for a good grade of concrete. PSL concrete components were constructed using aggregates from approved sources whose acceptability was based on established industry standards and ASTM tests]. The concrete mix uses Type II Portland cement conforming to ASTM C150. Also, for Unit 2, the cement contains no more than 0.60 percent by weight of total alkalis, which prevents harmful expansion due to alkali aggregate reaction.

Materials for concrete used in PSL concrete SSCs were specifically investigated, tested, and examined in accordance with pertinent ASTM standards at the time of construction. However, this testing may not fully conform to ASTM C295 specified in NUREG 2192, and, therefore, cracking due to expansion and reaction with aggregates, including alkali silicate reactions (ASR) and alkali carbonate reactions, is a potential aging effect in below grade inaccessible concrete areas for PSL Group 6 structures and will be managed by the PSL Structures Monitoring (B.2.3.33) AMP. The Structures Monitoring (B.2.3.33) AMP includes opportunistic inspection of inaccessible concrete locations and willhas been enhancedrefined, based on industry/fleet information, to include visual examination for patterned cracking, darkened crack edges, water ingress and misalignment that would be indicative of reaction with aggregates, such as alkali silica reaction (ASR) and alkali carbonate reaction (ACR), and includes opportunistic inspection of inaccessible concrete locations. As such, a plant specific program or plant specific enhancement of the Structures Monitoring (B.2.3.33) AMP is not required to manage this aging effect; rather, inspections and evaluations performed in accordance with the Structures Monitoring (B.2.3.33) AMP will identify the presence of cracking due to expansion and cracking due to reaction with aggregates should it occur.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 5 Page 5 of 13 SLRA Section 3.5.2.2.2.3.3, page 3.5-32 (discussion continued from page 3.5-31), is revised as follows:

degradation caused by leaching of calcium hydroxide is not significant. In addition, concrete components are normally exposed to flowing water (not just filling a crack or void) through the concrete component.

Leaching is readily noticeable because of the white deposit that remains on the concrete surface after the carbon dioxide dries. No significant signs of leachate have been documented during inspection walkdowns under the Structures Monitoring (B.2.3.33) AMP. However, CR 01-1603 reported that minor concrete leaching was reportedis evident on the interior surface of the concrete walls at the ultimate heat sink dam. The suspected cause is rainwater passing through cracks or cold joints in the concrete. Engineering evaluation stated that drying shrinkage was the most likely cause of the cracks and that dDue to the small amount of efflorescence at the location of the cracks, any degradation of the existing concrete due to precipitation of calcium carbonate and/or calcium hydroxide would be negligible. The evaluationCR concludes that the condition will not affect the structural integrity of the concrete and confirmed that the intended function of the concrete structure was not impactedno generic actions are required. For SLR, the UHS dam will be monitored in accordance with the requirements of the Structures Monitoring (B.2.3.33) AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 5 Page 6 of 13 SLRA Table 3.5.2-1, page 3.5-80, is revised as follows:

Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Aging Intended NUREG-2191 Table Component Type Material Environment Requiring Management Notes Function Item 1 Item Management Program Penetrations (mechanical), Fire barrier Dissimilar metal Air - indoor Cumulative fatigue TLAA - Section II.A3.C-13 3.5-1, A, 11 including bellows Pressure welds uncontrolled damage 4.6, 009 boundary "Containment Structural Liner Plate, support Metal Containments, and Penetrations Fatigue" Penetrations bellows Fire barrier Stainless steel Air - indoor Cumulative fatigue TLAA - Section II.A3.C-13 3.5-1, A, 11 (mechanical), including Pressure uncontrolled damage 4.6, 009 bellows boundary "Containment Structural Liner Plate, support Metal Containments, and Penetrations Fatigue" Penetrations (mechanical), Fire barrier Steel Air - indoor Cumulative fatigue TLAA - Section II.A3.C-13 3.5-1, A, 11 including bellows Pressure uncontrolled damage 4.6, 009 boundary "Containment Structural Liner Plate, support Metal Containments, and Penetrations Fatigue" Penetrations (mechanical), Insulate (thermal) Calcium silicate Air - indoor None None VIII.H.S-403 3.4-1, I, 5 thermal insulation (type I uncontrolled 064 hot penetrations)

Penetrations Insulate Calcium Air - indoor None None V.E.E-422 3.2-1, I, 13, (mechanical), thermal (thermal) silicate uncontrolled 087 11 insulation (type III semi-hot penetrations)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 5 Page 7 of 13 SLRA Table 3.5.2-1, page 3.5-86:

General Notes A. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

B. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

C. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

D. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

E. Consistent with NUREG-2191 material, environment, and aging effect but a different AMP is credited or NUREG-2191 identifies a plant-specific AMP.

F. Material not in NUREG-2191 for this component.

H. Aging effect not in NUREG-2191 for this component, material, and environment combination.

I. Aging effect in NUREG-2191 for this component, material and environment combination is not applicable.

Plant Specific Notes

1. Consistent with SLR-ISG-2021-03-STRUCTURES, Appendix A, Containment components with no fatigue analysis or waiver are susceptible to cracking due to cyclic loading.Deleted.
2. Manway at the top of the Containment Vessel is a permanently sealed (welded) shut part of the Containment Vessel.
3. Consistent with SLR-ISG-2021-03-STRUCTURES, the Structures Monitoring (B.2.3.33) AMP manages loss of material for stainless steel exposed to air, instead of plant-specific program, whereas cracking due to SCC of the same penetration components is managed by 10 CFR Part 50, Appendix J and ASME Section XI Subsection IWE AMPs.Deleted.
4. Eight Type III (semi-hot) penetration assemblies per unit and, conservatively, both units fuel transfer tubes are stainless steel or dissimilar metal weld and exposed to process temperatures > 140°F during normal plant operation and, therefore, susceptible to stress corrosion.Deleted.
5. Insulation for main steam and feedwater penetrations isare fully encased in the multiple flued head and guard pipes and there are no plausible moisture, contaminants, or exposures that could degrade the (calcium silicate) insulation.
6. The Sstainless steel fuel transfer tube and flange penetration assemblies include stainless steel pressure-retaining bolting that is managed by the ASME Section XI, Subsection IWE AMP.
7. Irradiation of the concrete primary shield wall is addressed in Section 3.5.2.2.2.6 and is managed by the Structures Monitoring (B.2.3.33) AMP.
8. The loss of fracture toughness aging effect due to irradiation embrittlement of the steel reactor vessel supports and bolting is addressed in Section 3.5.2.2.2.7 and is managed by the ASME Section XI, Subsection IWF (B.2.3.30) AMP.
9. Consistent with SLR-ISG-2021-03-STRUCTURES, the Structures Monitoring AMP manages cracking of concrete due to reaction with aggregates.
10. Bottom portion and bottom head of the Containment Vessel are completely encased in concrete fill inside the (Group 1) Shield Building. The operating floor inside the Containment Vessel is this concrete fill.
11. Component also provides a fire barrier function as evaluated in the Fire Protection Program Design Document that is physically equivalent to the structural functions managed under the associated Containment structural programs or other applicable AMPs.
12. Evidence of cracking due to SCC and loss of material due to pitting and crevice corrosion (i.e., leakage) would be readily detected during refueling operations prior to loss of intended function for these components.
13. Insulation for Type III penetrations is fully encased in the multiple flued head and guard pipes and there are no plausible moisture, contaminants, or exposures that could degrade the (calcium silicate) insulation.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 5 Page 8 of 13 SLRA Table 3.5.2-16, pages 3.5-140 and 3.5-141, is revised as follows:

Table 3.5.2-16: Component Support Commodity - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table Component Type Material Environment Requiring Notes Function Program Item 1 Item Management Electrical and Shelter, Galvanized Air with borated Loss of material Boric Acid Corrosion III.B3.TP-3 3.5-1, A instrument panels and protection steel water leakage (B.2.3.4) 089 enclosures Structural support Electrical and Shelter, Steel Air - indoor None None VIII.I.SP-1 3.4-1, C instrument panels and protection controlled 059 enclosures Structural support Electrical and Shelter, Galvanized Air - indoor None None III.B3.TP-8 3.5-1, A instrument panels and protection steel uncontrolled 095 enclosures Structural support Electrical and Shelter, Stainless Air - indoor Cracking Structures Monitoring III.B3.T-37b 3.5-1, B instrument panels and protection steel uncontrolled Loss of material (B.2.3.33) 100 enclosures Structural Air - outdoor support Electrical and Shelter, Steel Air - indoor Loss of material Structures Monitoring III.B3.TP-43 3.5-1, B instrument panels and protection uncontrolled (B.2.3.33) 092 enclosures Structural Air - outdoor support Electrical and Shelter, Galvanized Air - outdoor Loss of material Structures Monitoring III.B3.TP-274 3.5-1, D instrument panels and protection steel (B.2.3.33) 082 enclosures Structural support Non-metallic thermal Insulate Any Air Reduce thermal External Surfaces V.E.E-422 3.2-1, A, 4 insulation (thermal) insulation Monitoring of 087 resistance Mechanical Components (B.2.3.23)

Pipe whip restraints Pipe whip Steel Air with borated Loss of material Boric Acid Corrosion III.B5.T-25 3.5-1, A restraint water leakage (B.2.3.4) 089 Pipe whip restraints Pipe whip Steel Air - indoor Loss of material Structures Monitoring III.B5.TP-43 3.5-1, B restraint uncontrolled (B.2.3.33) 092 Air - outdoor Sliding support Structural Graphite Air - outdoor Loss of ASME Section XI, III.B1.2.TP-45 3.5-1, B, 2 surfaces (Unit 1 CCW support lubricated mechanical Subsection IWF 075 heat exchangers) steel function (B.2.3.30)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 5 Page 9 of 13 Table 3.5.2-16: Component Support Commodity - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table Component Type Material Environment Requiring Notes Function Program Item 1 Item Management Sliding support Structural Graphite Air - indoor Loss of ASME Section XI, III.B1.2.TP-45 3.5-1, B, 2 surfaces (Unit 2 CCW support lubricated uncontrolled mechanical Subsection IWF 075 heat exchangers) steel function (B.2.3.30)

Structural bolting Structural Steel Air - indoor Loss of material Structures Monitoring III.B5.TP-248 3.5-1, B, 3 support uncontrolled (B.2.3.33) 080 Air - outdoor Structural bolting Structural Steel Air Loss of preload Structures Monitoring III.B5.TP-261 3.5-1, B, 3 support (B.2.3.33) 088 Structural bolting Structural Galvanized Air - outdoor Loss of material Structures Monitoring III.B5.TP-274 3.5-1, B, 3 support steel (B.2.3.33) 082 General Notes A. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

B. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

C. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

D. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

Plant Specific Notes

1. RCS Class 1 supports (inside containment) are addressed in Table 3.5.2-1.
2. Sliding support surfaces for the Unit 1 and Unit 2 CCW heat exchangers will be managed by the ASME Section XI, Subsection IWF AMP.
3. Structural bolting for non-ASME and nonsafety-related supports will be managed under the Structure Monitoring AMP.
4. Thermal insulation for Type I (hot) and Type III (semi-hot) containment penetrations is addressed in Table 3.5.2-1.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 5 Page 10 of 13 SLRA Appendix A1, Section 19.4, commitment No. 36 portion of Table 19-3 on page A1-103, is revised as follows:

Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) has not invalidated the original evaluation assumptions or impacted the capability to perform the intended functions.

36 Structures Monitoring XI.S6 Continue the existing PSL Structures Monitoring AMP, including No later than 6 months prior to (19.2.2.33) enhancements to: the SPEO, or no later than the last refueling outage prior to the a) Monitor and inspect steel edge supports on masonry walls.

SPEO i.e.:

b) Specify the use of high-strength bolt storage requirements discussed in Section 2 of the Research Council for Structural PSL1: 09/01/2035 Connections publication, Specification for Structural Joints Using High-Strength Bolts, for structural bolting consisting of ASTM A325, ASTM A490, and equivalent bolts.

c) Inspect concrete structures for increase in porosity and permeability, loss of strength, indications of cracking and expansion due to reaction with aggregates, and reduction in concrete anchor capacity due to local concrete degradation.

d) Inspect elastomers for loss of material and loss of strength.

e) Inspect stainless steel and aluminum components for pitting and crevice corrosion, and evidence of cracking due to SCC.

f) Include monitoring and trending of leakage volumes and chemistry for signs of concrete or steel reinforcement degradation if active through-wall leakage or groundwater infiltration is identified.

g) Include tactile inspection in addition to visual inspection of elastomeric elements to detect hardening.

h) Include evidence of water in-leakage as a finding requiring further evaluation. This may include engineering evaluation, more frequent inspections, or destructive testing of affected concrete to validate existing concrete properties, including concrete pH levels. When leakage volumes allow, assessment may include

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 5 Page 11 of 13 SLRA Appendix A2, Section 19.4, commitment No. 36 portion of Table 19-3 on page A2-103, is revised as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 35 Masonry Walls (19.2.2.32) XI.S5 Continue the existing PSL Masonry Walls AMP, including No later than 6 months prior to enhancement to: the SPEO, or no later than the last refueling outage prior to a) Revise the implementing procedure to monitor and inspect for the SPEO i.e.:

gaps between the supports and masonry walls that could potentially impact the intended function or potentially invalidate its PSL2: 10/06/2042 evaluation basis.

b) Revise the implementing procedure to include specific monitoring, measurement, and trending of 1) widths and lengths of cracks in masonry walls and mortar joints, and 2) gaps between supports and masonry walls.

c) Revise the implementing procedure to include specific guidance for the assessment of the acceptability of the widths and lengths of cracks in masonry walls and mortar joints and of gaps between supports and masonry walls, using evaluation bases established in response to IE Bulletin 80-11 to confirm that the degradation has not invalidated the original evaluation assumptions or impacted the capability to perform the intended functions.

36 Structures Monitoring XI.S6 Continue the existing PSL Structures Monitoring AMP, including No later than 6 months prior to (19.2.2.33) enhancement to: the SPEO, or no later than the last refueling outage prior to a) Monitor and inspect steel edge supports on masonry walls.

the SPEO i.e.:

b) Specify the use of high-strength bolt storage requirements discussed in Section 2 of the Research Council for Structural PSL2: 10/06/2042 Connections publication, Specification for Structural Joints Using High-Strength Bolts, for structural bolting consisting of ASTM A325, ASTM A490, and equivalent bolts.

c) Inspect concrete structures for increase in porosity and permeability, loss of strength, indications of cracking and expansion due to reaction with aggregates, and reduction in concrete anchor capacity due to local concrete degradation.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 5 Page 12 of 13 SLRA Appendix B, Section B.2.3.33, element 3 portion of Enhancements Table on page B-248, is revised as follows:

Element Affected Enhancement

3. Parameters Monitored or Update the governing AMP procedure and other applicable Inspected procedures to inspect concrete structures for increase in porosity and permeability, loss of strength, and reduction in concrete anchor capacity due to local concrete degradation.
3. Parameters Monitored Update the governing AMP procedure and other applicable or Inspected procedures to inspect concrete structures for patterned cracking, darkened crack edges, water ingress and misalignment that would be indicative of reaction with aggregates.
3. Parameters Monitored or Update the governing AMP procedure and other applicable Inspected procedures to inspect elastomers for loss of material and loss of strength.
3. Parameters Monitored or Update the governing AMP procedure and other applicable Inspected procedures to inspect SS and aluminum components for pitting and crevice corrosion, and evidence of cracking due to SCC.
3. Parameters Monitored or Update the governing AMP procedure and other applicable Inspected procedures to include monitoring and trending of leakage volumes and chemistry for signs of concrete or steel reinforcement degradation if active through-wall leakage or groundwater infiltration is identified.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 5 Page 13 of 13 SLRA Appendix B, Section B.2.3.33, page B-251, is revised as follows:

  • The evaluation of results was performed in accordance with the programs implementing procedures, based on a review of the results of the latest program walkdowns.

PSL Structures Monitoring health reports are developed and trended. Program health reports from 2015 to present indicate that inspections, procedures, and plans meet the program requirements. The overall performance of the PSL Structures Monitoring AMP is WHITE. The path to GREEN involves reducing a backlog of mostly white and some yellow work orders.

The following review of site-specific OE demonstrates how PSL is managing aging effects associated with the PSL Structures Monitoring AMP.

  • In 2012, concrete cracks were discovered in the roof of the Unit 1 Reactor Auxiliary Building. Although the crack pattern resembled that depicted in NRC IN 2011-20, a subsequent engineering evaluation determined that other critical characteristics of the alkali-silica reaction (i.e., gel deposits or dark stains as a result of the gel) were missing and that there was insufficient ponding in the roof concrete slab to develop a reaction in the concrete components. A follow-up inspection confirmed that a new roof membrane had been installed to seal the roof.
  • Corroded pipe support spring cans were observed during a Structures Monitoring Program walkdown for the Unit 2 Refueling Water Tank.

Corrosion had been identified on the two spring supports, as documented in previous ARs. The evaluation noted that no additional degradation had occurred, and the spring cans were replaced.

  • Observations during Structures Monitoring walkdowns of the Unit 1 and Unit 2 Reactor Containment Buildings included localized corroded embedded steel, abandoned corroded anchors, pop-outs, degraded weatherproofing (concrete joint sealant), and spalling. As part of each AR, an evaluation was performed on the extent of conditions, and the evaluations concluded that in each case the structural or functional integrity of the structure was not impacted. The ARs were closed to the work management process for implementing the necessary repairs.
  • Observations during walkdowns of the Unit 1 and Unit 2 Component Cooling Water Buildings included localized concrete cracks, spalls, honeycomb and rust bleeding, degraded elastomer seals for concrete joints, corroded embedded steel in concrete, abandoned anchors in concrete, steel locations with corrosion and degraded coatings, and corroded supporting steel, handrail, and bolted connections on stairs. The conditions were evaluated and determined to be minor, and the structural and functional integrity of the structures were not impacted. The ARs were closed to the work management process for implementing the necessary repairs.
  • Corrosion greater than 1/32 inches was observed on lighting conduit on the exterior east wall of the Unit 1 reactor auxiliary building. An evaluation determined that no immediate repairs were required, and that the condition did not impact the structural components function, integrity, or ability to withstand a design basis event. The AR was closed to the work management process for implementing the necessary repairs.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 1 of 33 Plant Structures Corrosion: Clarified AMR Results and Related Further Evaluation Affected SLRA Sections: 2.4.17, Table 2.4-17, 3.5.2.1.9, 3.5.2.2.2.4, Table 3.5-1, Table 3.5.2-1, Table 3.5.2-7, Table 3.5.2-16, Table 3.5.2-17, Table 19-3 (Appendices A1, A2),

B.2.3.30, B.2.3.33 SLRA Page Numbers: 2.4-35, 2.4-36, 3.5-10, 3.5-33, 3.5-69, 3.5-70, 3.5-81, 3.5-82, 3.5-86, 3.5-105 through 3.5-108, 3.5-136, 3.5-137, 3.5-142 through 3.5-145, A1-100, A1-101, A1-102, A1-103, A1-104, A2-102, A2-104, B-233, B-235, B-249 Description of Change:

A pressure boundary function was assigned to fire rated assembly component types associated with halon in the PSL cable spreading room. Upon further review, it was confirmed that maintaining the concentration of halon when discharged into an area is relied upon only as part of active fire suppression and that a pressure boundary designation is unnecessary.

Accordingly, the pressure boundary function is removed from discussion/tabulation in SLRA Section 2.4.17 and associated entries in SLRA Table 3.5.2-17.

The sole use of stainless steel in structural components of the PSL intake structures is as a material of construction for component supports, which are all addressed as a commodity in SLRA Table 3.5.2-16. Accordingly, stainless steel is removed from the list of materials in SLRA Section 3.5.2.1.9.

Applicability of the Fire Protection and ASME Section XI, Subsection IWF AMPs for aging management was inadvertently omitted from discussion of cracking due to SCC and loss of material due to pitting and crevice corrosion in stainless steel and aluminum portions of fire rated assemblies and safety-related component supports (respectively). Text is added to SLRA Section 3.5.2.2.2.4 to correct this discrepancy and align with the related items in SLRA Table 3.5.-1.

PSL does not have any aluminum Class 1, 2, or 3 supports; however stainless steel is not precluded from such applications. Recent piping modifications implemented in the PSL intake structures included stainless steel as a material of construction for Class 3 component supports.

Accordingly, the Discussion column for AMR line item 3.5-1, 099 in SLRA Table 3.5-1 is updated to reflect use of the ASME Section XI, Subsection IWF AMP, supplemented by the Structures Monitoring AMP, to manage the applicable aging effects. Corresponding entries are inserted in SLRA Table 3.5.2-16 and new enhancements are added to SLRA Section B.2.3.30 and SLRA Section B.2.3.33. The new enhancements are also reflected in updates to the associated commitments presented in SLRA Table 19-3 of both Appendices A1 and A2.

The entry for AMR line item 3.5-1, 100 in SLRA Table 3.5-1 is revised to align with Table 3.5-1 in NUREG-2192 (Structures Monitoring replacing ASME Section XI, Subsection IWF in the Aging Management Program / TLAA column) and to reflect the AMP credited with managing loss of material for nonsafety-related component supports in the intake structures at PSL (Structures Monitoring replacing External Surfaces Monitoring of Mechanical Components in the Discussion column).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 2 of 33 Portions of certain other stainless steel component types (i.e., not component supports) that perform pressure boundary functions are exposed to an uncontrolled indoor air environment and have been associated with AMR line item 3.5-1, 100 in SLRA Table 3.5.2-1 (reactor cavity seal ring, refueling cavity liner plate) and SLRA Table 3.5.2-7 (fuel pool gates, pool liner plates).

Since evidence of cracking due to SCC and loss of material due to pitting and crevice corrosion (i.e., leakage) would be readily detected during refueling operations prior to loss of intended function for these components, it is concluded that these aging effects are adequately managed by the Water Chemistry AMP and monitoring associated with both the refueling cavity and spent fuel pool water levels. Accordingly, new note(s) reflecting the above conclusion are associated with the applicable entries in SLRA Table 3.5.2-1 and SLRA Table 3.5.2-7 and unnecessary references to the Structures Monitoring AMP are removed.

Note that the markups for SLRA pages 2.4-35, 2.4-36 3.5-33 and 3.5-70, include changes associated with Attachment 20 to this supplement. The markups for SLRA page 3.5-86 include changes associated with Attachments 5, 8 and 20 of this supplement. The markups for SLRA pages A1-100, A1-101, A1-102, A1-103, A1-104, A2-101, A2-102, A2-103 and A2-104 include changes associated with Attachments 28 and 30 of this supplement

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 3 of 33 SLRA Section 2.4.17 on page 2.4-35, is revised as follows:

on steel framing are also used as fire barriers. Concrete and masonry walls, floors, and ceilings are evaluated with the specific structure in which they reside.

Fire door assemblies prevent the spread of fire through fire barrier passageways.

Fire dampers are provided to prevent the spread of fire through ventilation penetrations. Fire dampers are evaluated with Ventilation in Subsection 2.3.3.15.

Penetration seals are provided to maintain the integrity of fire barriers at barrier penetrations. The types of materials used for the various penetrations range from silicone elastomers gels for piping and heating, ventilation, and air conditioning (HVAC) penetrations to grouts (cementitious fire barrier materials) for conduit and plumbing. Cable tray penetrations are sealed with Marinite board, ceramic fiber filler material, and a protective fire-retardant cable coating.

Boundary The evaluation boundary for fire rated assemblies is the external surface of that assembly. The fire area boundaries (walls, ceilings, and floors) define the NFPA 805 Areas. Concrete and masonry fire barriers (i.e., walls) are screened with the structure in which they reside.

System Intended Functions SR functions (10 CFR 54.4(a)(1)):

None.

NNS components that could affect SR functions (10 CFR 54.4(a)(2)):

1) Airtight fire doors and fFire barrier penetration seals associated with SR ventilation system boundaries (e.g., control room air conditioning, ECCS area ventilation, etc.) and watertight fire doors associated with flood protection are NNS fire rated assemblies which could affect SR functions.

FP, EQ, PTS, ATWS, and SBO functions (10 CFR 54.4(a)(3)):

1) FP - Relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the NRC's regulations for FP. Generally, the FP System protects plant equipment in the event of a fire to ensure safe plant shutdown and minimize the risk of a radioactive release to the environment. Fire assemblies with an intended function of providing pressure boundary for this commodity group are for halon in the Unit 1 cable spreading room.

UFSAR References Unit 1 6.4.1 and 9.5.1 (Unit 1) 6.4.5 and 9.5.1 (Unit 2)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 4 of 33 SLRA Table 2.4-17, page 2.4-36, is revised as follows:

Table 2.4-17 Fire Rated Assemblies Subject to Aging Management Review Component Type Component Intended Function(s)

Conduit caps Fire barrier Pressure boundary Conduit plugs Fire barrier Fire damper housings Fire barrier Fire doors - airtight Fire barrier Pressure boundary Fire doors - watertight Fire barrier Flood barrier Fire doors (NFPA 805 barriers) Fire barrier Pressure boundary Fire wrap (conduit and steel supports) Fire barrier Fire sealed isolation joint Fire barrier Fire seals - cable tray penetrations Fire barrier Pressure boundary Fire seals - mechanical penetrations Fire barrier Pressure boundary Fire wrap (conduit and steel supports) Fire barrier Flame impingement shields (insulating Fire barrier blankets for cable trays)

Miscellaneous fire barriers Fire barrier Pressure boundary Miscellaneous fire barriers - straps Fire barrier Radiant energy shields Fire barrier

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 5 of 33 SLRA Section 3.5.2.1.9, Materials listing on page 3.5-10, is revised as follows:

The materials of construction for the intake structure components are:

  • Caulking and sealants
  • Concrete (reinforced)
  • Galvanized steel
  • Stainless steel
  • Steel SLRA Section 3.5.2.2.2.4, second paragraph on page 3.5-33, is revised as follows:

Stainless steel structural components are limited in comparison to the amount of stainless-steel mechanical components at the site. Aluminum in plant structures is limited to fire barrier mechanical penetrations. Furthermore, tThere has been no site OE of cracking or localized corrosion of SS or aluminum SSCs. However, cracking due to SCC and loss of material due to pitting and crevice corrosion is a potentially applicable aging effect at PSL plant structures for SS and aluminum, and is managonitored with the PSL Structures Monitoring (B.2.3.33) AMP, the ASME Section XI, Subsection IWF (B.2.3.30) AMP, and the Fire Protection (B.2.3.15) AMP. To provide reasonable assurance that the aging effect of cracking is managed during the SPEO for ASME class 1 (non-RCS), class 2, and class 3 stainless steel supports, the visual inspections of the ASME Section XI, Subsection IWF (B.2.3.30) AMP will be supplemented by the Structures Monitoring (B.2.3.33) AMP. Should cracking due to SCC be identified for stainless steel mechanical or non-ASME structural components, engineering evaluation will determine the appropriate refined acceptance criteria, expansion criteria, examination frequency, and corrective actions. This evaluation, conducted through the Structures Monitoring (B.2.3.33) AMP, will also include ASME class 1 (non-RCS),

class 2, or class 3 stainless steel support members, welds, bolted connections, or anchorage to structures.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 6 of 33 SLRA Table 3.5-1, page 3.5-69, is revised as follows:

Table 3.5-1: Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Item Aging Aging Management Further Evaluation Component Discussion Number Effect/Mechanism Program / TLAA Recommended 3.5-1, 097 Group 4: Concrete Reduction of strength; Plant-specific AMP or Yes (SRP-SLR Not applicable.

(reactor cavity area loss of mechanical plant-specific Section 3.5.2.2.2.6) A plant-specific AMP or enhancement of existing proximate to the properties due to enhancements to selected AMPs is not required. The impacts of irradiation on reactor vessel): irradiation (i.e., radiation AMPs the primary shield wall and reactor vessel supports reactor interactions with have been evaluated for end of plant life/license (the (primary/biological) material and subsequent period of extended operation).

shield wall; sacrificial radiation-induced The primary shield wall will continue to satisfy the shield wall; reactor heating) design criteria considering the long-term radiation vessel effects. The Structures Monitoring (B.2.3.33) AMP support/pedestal will continue to manage the primary shield wall structure condition.

The RV supports will continue to satisfy the design criteria considering the long-term radiation effects and loss of fracture toughness will be managed by the ASME Section XI, Subsection IWF (B.2.3.30)

AMP.

Further evaluation is described in Sections 3.5.2.2.2.6 and 3.5.2.2.2.7.

3.5-1, 098 Stainless steel, None None No Consistent with NUREG-2191 aluminum alloy Stainless steel components exposed to borated support members; water leakage do not require aging management for welds; bolted boric acid corrosion.

connections; support anchorage to building structure 3.5-1, 099 Aluminum, stainless Loss of material due to AMP XI.M32, "One-Time Yes (SRP-SLR Consistent with NUREG-2191, as clarifiedNot steel support pitting and crevice Inspection," AMP XI.S3, Section 3.5.2.2.2.4) used.

members; welds; corrosion, cracking due "ASME Section XI, PSL does not have any aluminum or stainless steel bolted connections; to SCC Subsection IWF," or AMP Class 1, 2, or 3 supports. Supports for Class 1, 2, support anchorage to XI.M36, "External or 3 components are typically steel but may building structure Surfaces Monitoring of include stainless steel. Stainless steel support Mechanical Components components are managed for loss of material and cracking by the ASME Section XI, Subsection IWF (B.2.3.30) AMP, supplemented by the Structures Monitoring (B.2.3.33) AMP.

Further evaluation is documented in Section 3.5.2.2.2.4.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 7 of 33 SLRA Table 3.5-1, page 3.5-70, is revised as follows:

Table 3.5-1: Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Item Aging Aging Management Further Evaluation Component Discussion Number Effect/Mechanism Program / TLAA Recommended 3.5-1, 100 Aluminum, Loss of material due AMP XI.M32, Yes (SRP-SLR Consistent with NUREG-2191, as clarified.

stainless steel to pitting and crevice "One-Time Inspection," Section 3.5.2.2.2.4) The External Surfaces Monitoring of support members; corrosion, cracking AMP XI.S36, "ASME Mechanical Components (B.2.3.23) AMP is welds; bolted due to SCC Section XI, Subsection credited with managing loss of material and connections; IWF"Structures cracking of aluminum and stainless steel support anchorage Monitoring," or AMP non-safety related supports at the Intake to building structure XI.M36, "External Structures. The Structures Monitoring Surfaces Monitoring of (B.2.3.33) AMP is credited with managing loss Mechanical of material and cracking of nonsafety-related Components aluminum and stainless steel component supports, anchorage embedment, electrical and instrument panel and enclosures, conduits and cable trays, and aluminum supports exposed to air.

The Fire Protection (B.2.3.156) AMP is credited with managing loss of material and cracking in aluminum and stainless steel fire barrier penetrations and radiant energy shields.

Further evaluation is documented in Section 3.5.2.2.2.4.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 8 of 33 SLRA Table 3.5.2-1, pages 3.5-81 and 3.5-82, is revised as follows:

Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Pressure retaining bolting Pressure Steel Air with borated Loss of material Boric Acid Corrosion III.B1.1.T-25 3.5-1, 089 C boundary water leakage (B.2.3.4)

Structural support Primary shield wall Radiation Concrete Air - indoor Loss of Structures Monitoring III.A4.T-35 3.5-1, 097 B, 7 shielding (reinforced) uncontrolled mechanical (B.2.3.33)

Shelter, properties; protection reduction of Structural strength support RCS Class 1 support Structural Steel Air - indoor Loss of preload ASME Section XI, III.B1.1.TP-229 3.5-1, 087 B bolting support uncontrolled Subsection IWF (B.2.3.30)

RCS Class 1 support Structural Steel Air - indoor Cracking ASME Section XI, III.B1.1.TP-41 3.5-1, 068 B bolting support uncontrolled Subsection IWF (B.2.3.30)

RCS Class 1 support Structural Steel Air - indoor Loss of material ASME Section XI, III.B1.1.T-24 3.5-1, 091 B bolting support uncontrolled Subsection IWF (B.2.3.30)

RCS Class 1 support Structural Steel Air with borated Loss of material Boric Acid Corrosion III.B1.1.T-25 3.5-1, 089 A bolting support water leakage (B.2.3.4)

RCS Class 1 supports Structural Steel Air - indoor Loss of material ASME Section XI, III.B1.1.T-24 3.5-1, 091 B support uncontrolled Subsection IWF (B.2.3.30)

RCS Class 1 supports Structural Steel Air with borated Loss of material Boric Acid Corrosion III.B1.1.T-25 3.5-1, 089 A support water leakage (B.2.3.4)

Reactor cavity seal ring Pressure Stainless steel Air - indoor Cracking Water Chemistry III.B2.T-37b 3.5-1, 100 DE, 12 boundary uncontrolled Loss of material Structures Monitoring (B.2.3.233) and monitoring cavity, pool water levels Reactor cavity seal ring Pressure Stainless steel Treated borated Cracking Water Chemistry III.A5.T-14 3.5-1, 078 A boundary water Loss of material (B.2.3.2) and monitoring of thecavity, pool water levels

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 9 of 33 Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Reactor cavity seal ring Pressure Elastomer Air - indoor Loss of sealing Structures Monitoring III.A6.TP-7 3.5-1, 072 D seals boundary uncontrolled; (B.2.3.33) treated borated water Refueling cavity liner Pressure Stainless steel Air - indoor Cracking Water Chemistry III.B5.T-37b 3.5-1, 100 DE, 12 plate boundary uncontrolled Loss of material Structures Monitoring (B.2.3.233) and monitoring cavity, pool water levels and leakage from the leak chase channels Refueling cavity liner Pressure Stainless steel Treated borated Cracking Water Chemistry III.A5.T-14 3.5-1, 078 A plate boundary water Loss of material (B.2.3.2) and monitoring of thecavity, pool water levels and leakage from the leak chase channels Refueling upender Structural Stainless steel Treated borated Loss of material One-Time Inspection VII.A2.A-99 3.3-1, 125 D (passive components) support water (B.2.3.20)

Water Chemistry (B.2.3.2)

RV supports and bolting Structural Steel Air-indoor Loss of fracture ASME Section XI, N/A N/A H, 8 support uncontrolled toughness Subsection IWF (B.2.3.30)

Service Level I coatings Coating Coatings Air - indoor Loss of coating Protective Coating II.A3.CP-152 3.5-1, 034 A integrity uncontrolled or lining Monitoring and integrity Maintenance (B.2.3.35)

Service Level I coatings Coating Coatings Air - indoor Loss of coating Protective Coating II.A3.CP-152 3.5-1, 073 A integrity uncontrolled or lining Monitoring and integrity Maintenance (Section B.2.3.35)

Shield building airtight Pressure Elastomer Air - indoor Loss of sealing Structures Monitoring III.A6.TP-7 3.5-1, 072 D bulkhead door seals boundary uncontrolled (B.2.3.33)

Shelter, protection

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 10 of 33 SLRA Table 3.5.2-1, page 3.5-86 (notes for Table 3.5.2-1), is revised as follows:

General Notes A. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

B. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

C. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

D. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

E. Consistent with NUREG-2191 material, environment, and aging effect but a different AMP is credited or NUREG-2191 identifies a plant-specific AMP.

F. Material not in NUREG-2191 for this component.

H. Aging effect not in NUREG-2191 for this component, material, and environment combination.

I. Aging effect in NUREG-2191 for this component, material and environment combination is not applicable.

Plant Specific Notes

1. Consistent with SLR-ISG-2021-03-STRUCTURES, Appendix A, Containment components with no fatigue analysis or waiver are susceptible to cracking due to cyclic loading.Deleted.
2. Manway at the top of the Containment Vessel is a permanently sealed (welded) shut part of the Containment Vessel.
3. Consistent with SLR-ISG-2021-03-STRUCTURES, the Structures Monitoring (B.2.3.33) AMP manages loss of material for stainless steel exposed to air, instead of plant-specific program, whereas cracking due to SCC of the same penetration components is managed by 10 CFR Part 50, Appendix J and ASME Section XI Subsection IWE AMPs.Deleted.
4. Eight Type III (semi-hot) penetration assemblies per unit and, conservatively, both units fuel transfer tubes are stainless steel or dissimilar metal weld and exposed to process temperatures > 140°F during normal plant operation and, therefore, susceptible to stress corrosion.Deleted.
5. Insulation for main steam and feedwater penetrations isare fully encased in the multiple flued head and guard pipes and there are no plausible moisture, contaminants, or exposures that could degrade the (calcium silicate) insulation.
6. The Sstainless steel fuel transfer tube and flange penetration assemblies include stainless steel pressure-retaining bolting that is managed by the ASME Section XI, Subsection IWE AMP.
7. Irradiation of the concrete primary shield wall is addressed in Section 3.5.2.2.2.6 and is managed by the Structures Monitoring (B.2.3.33) AMP.
8. The loss of fracture toughness aging effect due to irradiation embrittlement of the steel reactor vessel supports and bolting is addressed in Section 3.5.2.2.2.7 and is managed by the ASME Section XI, Subsection IWF (B.2.3.30) AMP.
9. Consistent with SLR-ISG-2021-03-STRUCTURES, the Structures Monitoring AMP manages cracking of concrete due to reaction with aggregates.
10. Bottom portion and bottom head of the Containment Vessel are completely encased in concrete fill inside the (Group 1) Shield Building. The operating floor inside the Containment Vessel is this concrete fill.
11. Component also provides a fire barrier function as evaluated in the Fire Protection Program Design Document that is physically equivalent to the structural functions managed under the associated Containment structural programs or other applicable AMPs.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 11 of 33

12. Evidence of cracking due to SCC and loss of material due to pitting and crevice corrosion (i.e., leakage) would be readily detected during refueling operations prior to loss of intended function for these components.
13. Insulation for Type III penetrations is fully encased in the multiple flued head and guard pipes and there are no plausible moisture, contaminants, or exposures that could degrade the (calcium silicate) insulation.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 12 of 33 SLRA Table 3.5.2-7, pages 3.5-105 through 3.5-108, is revised as follows:

Table 3.5.2-7: Fuel Handling Buildings - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table Component Type Material Environment Requiring Notes Function Program Item 1 Item Management Concrete: Flood protection Concrete Air - indoor Cracking Structures Monitoring III.A5.TP-28 3.5-1, B foundation/base mat, Missile barrier (reinforced) uncontrolled Increase in (B.2.3.33) 067 fuel pool and transfer Shelter, Air - outdoor porosity and canal walls, walls protection permeability Structural Loss of material support Concrete: Structural Concrete Groundwater/soil Cracking Structures Monitoring III.A5.TP-204 3.5-1, B, 1 foundation/base mat, support (reinforced) (B.2.3.33) 043 fuel pool and transfer canal walls, walls (inaccessible)

Concrete: Flood protection Concrete Water - flowing Increase in Structures Monitoring III.A5.TP-67 3.5-1, B, 1, 2, foundation/base mat, Missile barrier (reinforced) porosity and (B.2.3.33) 047 3 fuel pool and transfer Shelter, permeability Loss canal walls, walls protection of strength (inaccessible) Structural support Concrete: roof, walls Flood protection Concrete Water - flowing Increase in Structures Monitoring III.A5.TP-24 3.5-1, B (accessible) Missile barrier (reinforced) porosity and (B.2.3.33) 063 Shelter, permeability Loss protection of strength Structural support Fuel pool gates Pressure Stainless steel Air - indoor Cracking Water Chemistry III.B5.T-37b 3.5-1, DE, 6 boundary uncontrolled Loss of material Structures Monitoring 100 (B.2.3.233) and monitoring cavity, pool water levels Fuel pool gates Pressure Stainless steel Treated borated Cracking Water Chemistry III.A5.T-14 3.5-1, C, 4 boundary water Loss of material (B.2.3.2) and 078 monitoring of the spent fuelcavity, pool water levels

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 13 of 33 Table 3.5.2-7: Fuel Handling Buildings - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table Component Type Material Environment Requiring Notes Function Program Item 1 Item Management Fuel upender (passive Structural Stainless steel Treated borated Loss of material One-Time Inspection VII.A2.A-99 3.3-1, C components) support water (B.2.3.20) 125 Water Chemistry (B.2.3.2)

HVAC louver Structural Steel Air - outdoor Loss of material Structures Monitoring III.B4.TP-43 3.5-1, B support (B.2.3.33) 092 Masonry wall (Unit 2 Shelter, Concrete block Air - indoor Cracking Masonry Walls III.A5.T-12 3.5-1, A Only) protection (reinforced) uncontrolled (B.2.3.32) 070 Structural Air - outdoor support Masonry wall (Unit 1 Shelter, Concrete block Air - indoor Cracking Masonry Walls III.A5.T-12 3.5-1, A Only) protection (unreinforced) uncontrolled (B.2.3.32) 070 Metamic inserts Absorb neutrons 6061 aluminum Treated borated Reduction of Monitoring of Neutron- VII.A2.AP-235 3.3-1, A alloy reinforced water neutron Absorbing Materials 102 w/ type 1 ASTM absorbing Other Than Boraflex C-750 boron capacity (B.2.3.26) carbide Change in dimensions Loss of material Miscellaneous steel Missile barrier Steel Air with borated Loss of material Boric Acid Corrosion III.B5.T-25 3.5-1, A (i.e., barriers, frame, Structural water leakage (B.2.3.4) 089 frame covers, hatch, support missile barriers, radiation shielding, etc.)

Miscellaneous steel Missile barrier Steel Air - indoor Loss of material Structures Monitoring III.A5.TP-302 3.5.1, D (i.e., barriers, frame, Structural uncontrolled (B.2.3.33) 077 frame covers, hatch, support Air - outdoor missile barriers, radiation shielding, etc.)

Pool liner plates Pressure Stainless steel Air - indoor Cracking Water Chemistry III.B5.T-37b 3.5-1, DE, 6 boundary uncontrolled Loss of material Structures Monitoring 100 (B.2.3.233) and monitoring cavity, pool water levels and leakage from the leak chase channels

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 14 of 33 Table 3.5.2-7: Fuel Handling Buildings - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table Component Type Material Environment Requiring Notes Function Program Item 1 Item Management Pool liner plates Pressure Stainless steel Treated borated Cracking Water Chemistry III.A5.T-14 3.5-1, A boundary water Loss of material (B.2.3.2) and 078 monitoring of thecavity, pool water levels and leakage from the leak chase channels Spent fuel pool Structural Stainless steel Air - indoor Cracking Structures Monitoring III.B5.T-37b 3.5-1, D storage brackets support uncontrolled Loss of material (B.2.3.33) 100 Spent fuel pool Structural Stainless steel Treated borated Loss of material One-Time Inspection VII.A2.A-99 3.3-1, C storage brackets support water (B.2.3.20) 125 Water Chemistry (B.2.3.2)

Spent fuel storage Shelter, Stainless steel Treated borated Loss of material One-Time Inspection VII.A2.A-99 3.3-1, A racks protection water (B.2.3.20) 125 Structural Water Chemistry support (B.2.3.2)

Structural bolting Structural Steel Air with borated Loss of material Boric Acid Corrosion III.B5.T-25 3.5-1, A support water leakage (B.2.3.4) 089 Structural bolting Structural Galvanized steel Air with borated Loss of material Boric Acid Corrosion III.B5.TP-3 3.5-1, A support water leakage (B.2.3.4) 089 Structural bolting Structural Galvanized steel Air - indoor None None III.B3.TP-8 3.5-1, A support uncontrolled 095 Structural bolting Structural Galvanized steel Air - outdoor Loss of material Structures Monitoring III.A5.TP-274 3.5-1, B support (B.2.3.33) 082 Structural bolting/ Structural Steel Air - indoor Loss of material Structures Monitoring III.A5.TP-248 3.5-1, B connections support uncontrolled (B.2.3.33) 080 Air - outdoor Structural bolting/ Structural Steel Air - indoor Loss of preload Structures Monitoring III.A5.TP-261 3.5-1, B connections support uncontrolled (B.2.3.33) 088 Air - outdoor Structural bolting/ Structural Stainless steel Treated borated Loss of preload One-Time Inspection III.A5.TP-261 3.5-1, E, 5 connections support water (B.2.3.20) 088 Water Chemistry (B.2.3.2)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 15 of 33 Table 3.5.2-7: Fuel Handling Buildings - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table Component Type Material Environment Requiring Notes Function Program Item 1 Item Management Structural steel Structural Steel Air with borated Loss of material Boric Acid Corrosion III.B1.2.T-25 3.5-1, C framing (beams, support water leakage (B.2.3.4) 089 columns, connections, etc.)

Structural steel Structural Steel Air - indoor Loss of material Structures Monitoring III.A5.TP-302 3.5-1, B framing (beams, support uncontrolled (B.2.3.33) 077 columns, connections, etc.)

Weatherproofing Shelter, Caulking and Air - outdoor Loss of sealing Structures Monitoring III.A6.TP-7 3.5-1, B protection sealants (B.2.3.33) 072 General Notes A. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

B. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

C. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

D. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

E. Consistent with NUREG-2191 material, environment, and aging effect but a different AMP is credited or NUREG-2191 identifies a plant-specific AMP.

Plant Specific Notes

1. Whereas the NUREG-2191/2192 item calls for a plant-specific AMP, PSL credits an existing AMP based on SLR-ISG-2021-03-STRUCTURE, Updated Aging Management Criteria for Structures Portions of Subsequent License Renewal Guidance.
2. Groundwater is considered to be water-flowing.
3. Conservatively, spent fuel pool leakage is identified as water-flowing.
4. There are no leak chase channels to monitor for the fuel pool gates.
5. Structural bolting/connection associated with the spent fuel pool will be managed under the Water Chemistry and One-Time Inspection AMP's.
6. Evidence of cracking due to SCC and loss of material due to pitting and crevice corrosion (i.e., leakage) would be readily detected during refueling operations prior to loss of intended function for these components.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 16 of 33 SLRA Table 3.5.2-16, pages 3.5-136 and 3.5-137, is revised as follows:

Table 3.5.2-16: Component Support Commodity - Summary of Aging Management Evaluation Aging Effect Aging Intended NUREG-2191 Table Component Type Material Environment Requiring Management Notes Function Item 1 Item Management Program Anchorage / embedment Structural Steel Air with borated Loss of material Boric Acid Corrosion III.B5.T-25 3.5-1, C support water leakage (B.2.3.4) 089 Anchorage / embedment Structural Steel Air - indoor Loss of preload Structures Monitoring III.B3.TP-261 3.5-1, B support uncontrolled (B.2.3.33) 088 Anchorage / embedment Structural Stainless Air - indoor Cracking Structures Monitoring III.B3.T-37b 3.5-1, B support steel uncontrolled Loss of material (B.2.3.33) 100 Anchorage / embedment Structural Steel Air - outdoor Loss of material Structures Monitoring III.B3.TP-248 3.5-1, B support (B.2.3.33) 080 ASME class 1 structural bolting Structural Steel Air - indoor Loss of material ASME Section XI, III.B1.1.TP-226 3.5-1, B, 1 support uncontrolled Subsection IWF 081 (B.2.3.30)

ASME class 1 structural bolting Structural Steel Air - indoor Loss of preload ASME Section XI, III.B1.1.TP-229 3.5-1, B, 1 support uncontrolled Subsection IWF 087 (B.2.3.30)

ASME class 1 structural bolting Structural High - Air Cracking ASME Section XI, III.B1.1.TP-41 3.5-1, B, 1 support strength steel Subsection IWF 068 (B.2.3.30)

ASME class 1 (non-RCS) pipe Structural Steel Air - indoor Loss of material ASME Section XI, III.B1.1.T-24 3.5-1, B, 1 supports and component support uncontrolled Subsection IWF 091 supports Air - outdoor (B.2.3.30)

ASME class 1 (non-RCS) pipe Structural Steel Air with borated Loss of material Boric Acid Corrosion III.B1.1.T-25 3.5-1, A, 1 supports and component support water leakage (B.2.3.4) 089 supports ASME class 1 (non-RCS) Structural Stainless Air Cracking ASME Section XI, III.B1.1.T-36b 3.5-1, B pipe supports and support Steel Loss of material Subsection IWF 099 component supports (B.2.3.30)

ASME class 2 and 3 structural Structural Galvanized Air - outdoor Loss of material ASME Section XI, III.B1.2.TP-235 3.5-1, B bolting support steel Subsection IWF 086 (B.2.3.30)

ASME class 2 and 3 structural Structural Steel Air - indoor Loss of preload ASME Section XI, III.B1.2.TP-229 3.5-1, B bolting support uncontrolled Subsection IWF 087 Air - outdoor (B.2.3.30)

ASME class 2 and 3 structural Structural Steel Air with borated Loss of material Boric Acid Corrosion III.B1.2.T-25 3.5-1, A bolting support water leakage (B.2.3.4) 089

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 17 of 33 Table 3.5.2-16: Component Support Commodity - Summary of Aging Management Evaluation Aging Effect Aging Intended NUREG-2191 Table Component Type Material Environment Requiring Management Notes Function Item 1 Item Management Program ASME class 2 and class 3 pipe Structural Steel Air - indoor Loss of material ASME Section XI, III.B1.2.T-24 3.5-1, B supports and component support uncontrolled Subsection IWF 091 supports Air - outdoor (B.2.3.30)

ASME class 2 and class 3 pipe Structural Steel Air with borated Loss of material Boric Acid Corrosion III.B1.2.T-25 3.5-1, A supports and component support water leakage (B.2.3.4) 089 supports ASME class 2 and class Structural Stainless Air Cracking ASME Section XI, III.B1.2.T-36b 3.5-1, B 3 pipe supports and support Steel Loss of material Subsection IWF 099 component supports (B.2.3.30)

Building concrete at locations Structural Concrete; Air - indoor Reduction in Structures Monitoring III.B2.TP-42 3.5-1, B of expansion and grouted support grout uncontrolled concrete anchor (B.2.3.33) 055 anchors; grout pads for support Air - outdoor capacity base plates Building concrete at locations Structural Grout Air - indoor Reduction in Structures Monitoring III.B2.TP-42 3.5-1, D of expansion and grouted support uncontrolled concrete anchor (B.2.3.33) 055 anchors; grout pads for support capacity base plates Building concrete at locations Structural Grout Air - outdoor Reduction in Structures Monitoring III.B2.TP-42 3.5-1, D of expansion and grouted support concrete anchor (B.2.3.33) 055 anchors; grout pads for support capacity base plates Building concrete at locations Structural Concrete Air - indoor Reduction in Structures Monitoring III.B5.TP-42 3.5-1, D of expansion and grouted support (reinforced) uncontrolled concrete anchor (B.2.3.33) 055 anchors; grout pads for support capacity base plates Component supports Structural Steel Air with borated Loss of material Boric Acid Corrosion III.B2.T-25 3.5-1, A (nonsafety-related) support water leakage (B.2.3.4) 089 Component supports Structural Galvanized Air with borated Loss of material Boric Acid Corrosion III.B2.TP-3 3.5-1, A (nonsafety-related) support steel water leakage (B.2.3.4) 089 Component supports Structural Aluminum Air Cracking Structures Monitoring III.B2.T-37b 3.5-1, B (nonsafety-related) support Stainless Loss of material (B.2.3.33) 100 steel

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 18 of 33 SLRA Table 3.5.2-17, pages 3.5-142 through 3.5-145, is revised as follows:

Table 3.5.2-17: Fire Rated Assemblies - Summary of Aging Management Evaluation Aging Effect Aging Intended NUREG-219 Table 1 Component Type Material Environment Requiring Management Notes Function 1 Item Item Management Program Conduit caps Fire barrier Galvanized steel Air - indoor None None III.B5.TP-8 3.5-1, C Pressure uncontrolled 095 boundary Conduit plugs Fire barrier Silicone foam Air Hardening Fire Protection VII.G.A-19 3.3-1, BC Pressure Loss of strength (B.2.3.15) 057 boundary Shrinkage Conduit plugs Fire barrier Cementitious Air Change in material Fire Protection VII.G.A-806 3.3-1, BA Pressure coating: quelpyre properties (B.2.3.15) 268 boundary mastic 703B Cracking Delamination Loss of material Separation Conduit plugs Fire barrier Fire retardant Air Change in material Fire Protection VII.G.A-807 3.3-1, BA Pressure coating properties (B.2.3.15) 269 boundary (Flamemastic) Cracking Delamination Loss of material Separation Conduit plugs Fire barrier Silicate: ceramic Air Change in material Fire Protection VII.G.A-807 3.3-1, BA Pressure fiber properties (B.2.3.15) 269 boundary Cracking Delamination Loss of material Separation Fire damper Fire barrier Steel Air Loss of material Fire Protection VII.G.A-789 3.3-1, BA housings (B.2.3.15) 255 Fire doors - airtight Fire barrier Steel Air Loss of material Fire Protection VII.G.A-21 3.3-1, B Pressure (B.2.3.15) 059 boundary Fire doors - Fire barrier Steel Air Loss of material Fire Protection VII.G.A-21 3.3-1, B watertight Flood barrier (B.2.3.15) 059 Fire doors (NFPA Fire barrier Steel Air Loss of material Fire Protection VII.G.A-21 3.3-1, BA 805 barriers) Pressure (B.2.3.15) 059 boundary

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 19 of 33 Table 3.5.2-17: Fire Rated Assemblies - Summary of Aging Management Evaluation Aging Effect Aging Intended NUREG-219 Table 1 Component Type Material Environment Requiring Management Notes Function 1 Item Item Management Program Fire sealed isolation Fire barrier Elastomer: Air Hardening Fire Protection VII.G.A-19 3.3-1, BA joint dymeric sealant, Loss of strength (B.2.3.15) 057 ethafoam Shrinkage Fire sealed isolation Fire barrier Silicates: Air Change in material Fire Protection VII.G.A-807 3.3-1, BA joint cerablanket properties (B.2.3.15) 269 Cracking Delamination Loss of material Separation Fire sealed isolation Fire barrier Carbon steel Air Loss of material Fire Protection III.B5.TP-43 3.5-1, E, 1 joint plate (B.2.3.15) 092 Fire seals: cable tray Fire barrier Elastomer Air Hardening Fire Protection VII.G.A-19 3.3-1, BA penetrations Pressure Loss of strength (B.2.3.15) 057 boundary Shrinkage Fire seals: cable tray Fire barrier Silicone Air Hardening Fire Protection VII.G.A-19 3.3-1, BA penetrations Pressure Loss of strength (B.2.3.15) 057 boundary Shrinkage Fire seals: cable tray Fire barrier Marinite board Air Change in material Fire Protection VII.G.A-807 3.3-1, BA penetrations Pressure Ceramic fiber properties (B.2.3.15) 269 boundary Fire retardant Cracking coating Delamination (Flamemastic) Loss of material Separation Fire seals: Fire barrier Silicone Air Hardening Fire Protection VII.G.A-19 3.3-1, BA mechanical Pressure Loss of strength (B.2.3.15) 057 penetrations: (Type boundary Shrinkage M-1, M-2, M-3, M-4, M-6, M-7, M-9)

Fire seals: Fire barrier Silicate: Air Change in material Fire Protection VII.G.A-807 3.3-1, BA mechanical Pressure durablanket, properties (B.2.3.15) 269 penetrations: (Type boundary ceramic fiber Cracking M-1, M-2, M-3, M-4, Delamination M-6, M-7, M-9) Loss of material Separation

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 20 of 33 Table 3.5.2-17: Fire Rated Assemblies - Summary of Aging Management Evaluation Aging Effect Aging Intended NUREG-219 Table 1 Component Type Material Environment Requiring Management Notes Function 1 Item Item Management Program Fire seals: Fire barrier Aluminum Air Cracking Fire Protection III.B5.T-37b 3.5-1, E, 1 mechanical Pressure Loss of material (B.2.3.15) 100 penetrations: (Type boundary M-1, M-2, M-3, M-4, M-6, M-7, M-9)

Fire seals: Fire barrier Stainless steel Air Cracking Fire Protection III.B5.T-37b 3.5-1, E, 1 mechanical Pressure Loss of material (B.2.3.15) 100 penetrations: (Type boundary M-1, M-2, M-3, M-4, M-6, M-7, M-9)

Fire seals: Fire barrier Galvanized steel Air - indoor None None III.B5.TP-8 3.5-1, C mechanical Pressure uncontrolled 095 penetrations: (Type boundary M-1, M-2, M-3, M-4, M-6, M-7, M-9)

Fire wrap (conduit Fire barrier Subliming Air Change in material Fire Protection VII.G.A-805 3.3-1, BA and steel supports) compound: properties (B.2.3.15) 267 thermo-lag 330-1 Cracking Delamination Loss of material Separation Flame impingement Fire barrier Insulating Air Change in material Fire Protection VII.G.A-807 3.3-1, BA shields (insulating blankets (B&B properties (B.2.3.15) 269 blankets for cable or Mecatiss) Cracking trays) Delamination Loss of material Separation Miscellaneous fire Fire barrier Subliming Air Change in material Fire Protection VII.G.A-805 3.3-1, BA barriers Pressure compounds: properties (B.2.3.15) 267 boundary thermo-lag 330-1 Cracking (panels, wrap, Delamination spray, or Loss of material troweled) Separation Thermo-lag 770-1 (panels)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 21 of 33 Table 3.5.2-17: Fire Rated Assemblies - Summary of Aging Management Evaluation Aging Effect Aging Intended NUREG-219 Table 1 Component Type Material Environment Requiring Management Notes Function 1 Item Item Management Program Miscellaneous fire Fire barrier Ceramic fiber Air Change in material Fire Protection VII.G.A-807 3.3-1, BA barriers Pressure (panels) properties (B.2.3.15) 269 boundary Cracking Delamination Loss of material Separation Miscellaneous fire Fire barrier Stainless steel Air Cracking Fire Protection III.B5.T-37b 3.5-1, E, 1 barriers Pressure sheet metal Loss of material (B.2.3.15) 100 boundary (panels)

Miscellaneous fire Fire barrier Stainless steel Air Cracking Fire Protection III.B5.T-37b 3.5-1, E, 1 barriers - straps Loss of material (B.2.3.15) 100 Miscellaneous fire Fire barrier Aluminum Air Cracking Fire Protection III.B5.T-37b 3.5-1, E, 1 barriers - straps Loss of material (B.2.3.15) 100 Radiant energy Fire barrier Subliming Air Change in material Fire Protection VII.G.A-805 3.3-1, BA shields compound: properties (B.2.3.15) 267 thermo-lag 330-1 Cracking Delamination Loss of material Separation Radiant energy Fire barrier Insulating Air Change in material Fire Protection VII.G.A-807 3.3-1, BA shields blankets (B&B properties (B.2.3.15) 269 or Mecatiss) Cracking Delamination Loss of material Separation Radiant energy Fire barrier Stainless steel Air Cracking Fire Protection III.B5.T-37b 3.5-1, E, 1 shields Loss of material (B.2.3.15) 100 General Notes BA.Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to is consistent with NUREG-2191 AMP description.

C. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

E. Consistent with NUREG-2191 material, environment, and aging effect but a different AMP is credited or NUREG-2191 identifies a plant-specific AMP.

Plant Specific Notes

1. Metal components of fire barrier assemblies will be managed by the Fire Protection AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 22 of 33 SLRA Appendix A1, Section 19.4, commitment No. 33 portion of Table 19-3 on pages A1-100, A1-101 and A1-102, is revised as follows:

Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 33 ASME Section XI, XI.S3 Continue the existing PSL ASME Section XI, Subsection IWF AMP, 33 Subsection IWF (19.2.2.30) including enhancement to:

a) Identify the population of ASME Class 1, 2, and 3 high-strength structural bolting greater than one-inch nominal diameter within the boundaries of IWF-1300.

b) Augment existing procedures to evaluate the acceptability of inaccessible areas (e.g., portions of supports encased in concrete, buried underground, or encapsulated by guard pipe) when conditions in accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas.

c) Augment existing procedures to reference EPRI Reports 1015336 and 1015337 and to incorporate guidance for proper selection of bolting material and lubricants and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting.

Additionally, update procedures to explicitly prohibit the use of molybdenum disulfide and other lubricants containing sulfur on structural bolting.

cd) Augment existing procedures to specify the use of high-strength boltpreventive actions for storage, lubricant selection, and bolting and coating material selection requirements discussed in Section 2 of RCSC (Research Council for Structural Connections) publication Specification for Structural Joints Using High-StrengthASTM A325 or A490 Bolts, for structural bolting consisting of ASTM A325, ASTM A490, and equivalent bolts.

de) Augment existing procedures to specify that bolting within the scope of this program is inspected for loss of integrity of bolted connections due to self-loosening.

ef) Augment existing procedures to specify that accessible sliding surfaces are monitored for significant loss of material due to wear and accumulation of debris or dirt.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 23 of 33 Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) fg) Perform and document a one-time inspection of an additional 5%

of the sample populations for Class 1, 2, and 3 piping supports.

The additional supports will be selected from the remaining population of IWF piping supports and will include components that are most susceptible to age-related degradation.

gh) Augment existing procedures to specify that, for component supports with high-strength bolting greater than one-inch nominal diameter, volumetric examination comparable to that of ASME Code,Section XI, Table IWB-2500-1, Examination Category B-G-1 will be performed to detect cracking in addition to the VT-3 examination. A representative sample of bolts will be inspected during the inspection interval prior to the start of the SPEO and in each 10-year period during the SPEO. The sample will be 20% of the population (for a material / environment combination) up to a maximum of 25 bolts.

hi) Augment existing procedures to increase or modify the component support inspection population when a component is repaired to as-new condition by including another support that is representative of the remaining population of supports that were not repaired.

ij) Augment existing procedures to specify that the following conditions are also unacceptable:

  • Loss of material due to corrosion or wear;
  • Debris, dirt, or excessive wear that could prevent or restrict sliding of the sliding surfaces as intended in the design basis of the support; and
  • Cracked or sheared bolts, including high-strength bolts, and anchors; and loss of material, cracking.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 24 of 33 Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) k) If necessary based on related Structures Monitoring AMP evaluation results (of stainless steel cracking in the uncontrolled indoor and outdoor air at PSL), develop an augmented examination plan in accordance with IWF-2430 for a representative sample of stainless steel ASME Class 1, 2, or 3 supports as a separate part of the ASME Section XI, Subsection IWF AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 25 of 33 SLRA Appendix A1, Section 19.4, commitment No. 36 portion of Table 19-3 on pages A1-103 and A1-104, is revised as follows:

Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 36 Structures Monitoring XI.S6 Continue the existing PSL Structures Monitoring AMP, including No later than 6 months prior to the (19.2.2.33) enhancement to: SPEO, or no later than the last refueling outage prior to the SPEO a) Monitor and inspect steel edge supports on masonry walls. i.e.:

b) Specify the use of high-strength bolt storage requirements discussed in PSL1: 09/01/2035 Section 2 of the Research Council for Structural Connections publication, Specification for Structural Joints Using High-Strength Bolts, for structural bolting consisting of ASTM A325, ASTM A490, and equivalent bolts.

c) Inspect concrete structures for increase in porosity and permeability, loss of strength, and reduction in concrete anchor capacity due to local concrete degradation.

d) Inspect elastomers for loss of material and crackingloss of strength.

e) Inspect stainless steel and aluminum components for pitting and crevice corrosion, and evidence of cracking due to SCC.

f) Include monitoring and trending of leakage volumes and chemistry for signs of concrete or steel reinforcement degradation if active through-wall leakage or groundwater infiltration is identified.

g) Specify that all bolting is monitored for loss of material, loose bolts, missing or loose nuts, and other conditions indicative of loss of preload.

hg) Include tactile inspection in addition to visual inspection of elastomeric elements to detect hardening.

ih) Include evidence of water in-leakage as a finding requiring further evaluation. This may include engineering evaluation, more frequent inspections, or destructive testing of affected concrete to validate existing concrete properties, including concrete pH levels. When leakage volumes allow, assessment may include analysis of the leakage pH, along with mineral, chloride, sulfate, and iron content in the water.

ji) Develop a new implementing procedure or attachment to an existing implementing procedure to address aging management of inaccessible areas exposed to groundwater/soil and water-flowing.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 26 of 33 Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section)

The document will include guidance to conduct a baseline visual inspection, pH analysis, and a chloride concentration test prior to the SPEO at a location close to the coastline/intake and a location in the main plant area for comparison. The baseline inspection results will be used to conduct a baseline evaluation that will determine the additional actions (if any) that are warranted.

Additionally, the baseline evaluation results will set the subsequent inspection requirements and inspection intervals (not to exceed 5 years). Periodic inspections (focused) and evaluation updates (not to exceed 5 years) will be performed throughout the SPEO to ensure aging of inaccessible concrete is adequately managed.

Opportunistic inspections may be used to replace or supplement the focused inspections if the inspection location is excavated for other reasons during the periodic inspection interval.Address the aggressive groundwater/soil environment to account for the extent of the degradation experienced. Specific requirements include evaluations, destructive testing, and/or focused inspections of representative accessible (leading indicator) or below-grade, inaccessible concrete structural elements exposed to aggressive groundwater/soil, on an interval not to exceed 5 years.

kj) Require inspections of the Condensate Storage Tank (CST) and Auxiliary Feedwater (AFW) Structures and Piping Inspections in the Trenches every third refueling outage, which will ensure that these inspections are performed at least once per 5 years.

l) Include stainless steel ASME Class 1, 2, or 3 support members, welds, bolted connections, or anchorage in the engineering evaluation of acceptance criteria, expansion criteria, and examination frequency if cracking due to SCC in the uncontrolled indoor and outdoor air at PSL is detected for stainless steel mechanical or non-ASME structural components.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 27 of 33 SLRA Appendix A2, Section 19.4, commitment No. 33 portion of Table 19-3 on pages A2-101 and A2-102, is revised as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 33 ASME Section XI, XI.S3 Continue the existing PSL ASME Section XI, Subsection IWF AMP, No later than 6 months prior to Subsection IWF (19.2.2.30) including enhancement to: the SPEO, or no later than the last refueling outage prior to a) Identify the population of ASME Class 1, 2, and 3 high-strength the SPEO i.e.:

structural bolting greater than one-inch nominal diameter within the boundaries of IWF-1300. PSL2: 10/06/2042 b) Augment existing procedures to evaluate the acceptability of Start the one-time inspection inaccessible areas (e.g., portions of supports encased in no earlier than 5 years prior to concrete, buried underground, or encapsulated by guard pipe) the SPEO (04/06/2038).

when conditions in accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas.

c) Augment existing procedures to reference EPRI Reports 1015336 and 1015337 and to incorporate guidance for proper selection of bolting material and lubricants and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting.

Additionally, update procedures to explicitly prohibit the use of molybdenum disulfide and other lubricants containing sulfur on structural bolting.

cd) Augment existing procedures to specify the use of high-strength boltpreventive actions for storage, lubricant selection, and bolting and coating material selection requirements discussed in Section 2 of RCSC (Research Council for Structural Connections) publication Specification for Structural Joints Using High-StrengthASTM A325 or A490 Bolts, for structural bolting consisting of ASTM A325, ASTM A490, and equivalent bolts.

de) Augment existing procedures to specify that bolting within the scope of this program is inspected for loss of integrity of bolted connections due to self-loosening.

ef) Augment existing procedures to specify that accessible sliding surfaces are monitored for significant loss of material due to wear and accumulation of debris or dirt.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 28 of 33 Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) fg) Perform and document a one-time inspection of an additional 5%

of the sample populations for Class 1, 2, and 3 piping supports.

The additional supports will be selected from the remaining population of IWF piping supports and will include components that are most susceptible to age-related degradation.

gh) Augment existing procedures to specify that, for component supports with high-strength bolting greater than one-inch nominal diameter, volumetric examination comparable to that of ASME Code,Section XI, Table IWB-2500-1, Examination Category B-G-1 will be performed to detect cracking in addition to the VT-3 examination. A representative sample of bolts will be inspected during the inspection interval prior to the start of the SPEO and in each 10-year period during the SPEO. The sample will be 20%

of the population (for a material / environment combination) up to a maximum of 25 bolts.

hi) Augment existing procedures to increase or modify the component support inspection population when a component is repaired to as-new condition by including another support that is representative of the remaining population of supports that were not repaired.

ij) Augment existing procedures to specify that the following conditions are also unacceptable:

  • Loss of material due to corrosion or wear;
  • Debris, dirt, or excessive wear that could prevent or restrict sliding of the sliding surfaces as intended in the design basis of the support; and
  • Cracked or sheared bolts, including high-strength bolts, and anchors; and loss of material, cracking.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 29 of 33 Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) k) If necessary based on related Structures Monitoring AMP evaluation results (of stainless steel cracking in the uncontrolled indoor and outdoor air at PSL), develop an augmented examination plan in accordance with IWF-2430 for a representative sample of stainless steel ASME Class 1, 2, or 3 supports as a separate part of the ASME Section XI, Subsection IWF AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 30 of 33 SLRA Appendix A2, Section 19.4, commitment No. 36 portion of Table 19-3 on pages A2-103 and A2-104, is revised as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 36 Structures Monitoring XI.S6 Continue the existing PSL Structures Monitoring AMP, including No later than 6 months prior to (19.2.2.33) enhancement to: the SPEO, or no later than the a) Monitor and inspect steel edge supports on masonry walls. last refueling outage prior to the SPEO i.e.:

b) Specify the use of high-strength bolt storage requirements discussed in Section 2 of the Research Council for Structural Connections publication, PSL2: 10/06/2042 Specification for Structural Joints Using High-Strength Bolts, for structural bolting consisting of ASTM A325, ASTM A490, and equivalent bolts.

c) Inspect concrete structures for increase in porosity and permeability, loss of strength, and reduction in concrete anchor capacity due to local concrete degradation.

d) Inspect elastomers for loss of material and crackingloss of strength.

e) Inspect stainless steel and aluminum components for pitting and crevice corrosion, and evidence of cracking due to SCC.

f) Include monitoring and trending of leakage volumes and chemistry for signs of concrete or steel reinforcement degradation if active through-wall leakage or groundwater infiltration is identified.

g) Specify that all bolting is monitored for loss of material, loose bolts, missing or loose nuts, and other conditions indicative of loss of preload.

hg) Include tactile inspection in addition to visual inspection of elastomeric elements to detect hardening.

ih) Include evidence of water in-leakage as a finding requiring further evaluation. This may include engineering evaluation, more frequent inspections, or destructive testing of affected concrete to validate existing concrete properties, including concrete pH levels. When leakage volumes allow, assessment may include analysis of the leakage pH, along with mineral, chloride, sulfate, and iron content in the water.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 31 of 33 Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) ji) Develop a new implementing procedure or attachment to an existing implementing procedure to address aging management of inaccessible areas exposed to groundwater/soil and water-flowing. The document will include guidance to conduct a baseline visual inspection, pH analysis, and a chloride concentration test prior to the SPEO at a location close to the coastline/intake and a location in the main plant area for comparison. The baseline inspection results will be used to conduct a baseline evaluation that will determine the additional actions (if any) that are warranted.

Additionally, the baseline evaluation results will set the subsequent inspection requirements and inspection intervals (not to exceed 5 years). Periodic inspections (focused) and evaluation updates (not to exceed 5 years) will be performed throughout the SPEO to ensure aging of inaccessible concrete is adequately managed. Opportunistic inspections may be used to replace or supplement the focused inspections if the inspection location is excavated for other reasons during the periodic inspection interval. Address the aggressive groundwater/soil environment to account for the extent of the degradation experienced. Specific requirements include evaluations, destructive testing, and/or focused inspections of representative accessible (leading indicator) or below-grade, inaccessible concrete structural elements exposed to aggressive groundwater/soil, on an interval not to exceed 5 years.

kj) Require inspections of the Condensate Storage Tank (CST) and Auxiliary Feedwater (AFW) Structures and Piping Inspections in the Trenches every third refueling outage, which will ensure that these inspections are performed at least once per 5 years.

l) Include stainless steel ASME Class 1, 2, or 3 support members, welds, bolted connections, or anchorage in the engineering evaluation of acceptance criteria, expansion criteria, and examination frequency if cracking due to SCC in the uncontrolled indoor and outdoor air at PSL is detected for stainless steel mechanical or non ASME structural components.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 32 of 33 SLRA Appendix B, Section B.2.3.30, following the second paragraph in Program Description on page B-233, is revised as follows:

The ASME Section XI, Subsection IWF AMP will be supplemented by the Structures Monitoring AMP should cracking due to SCC in the uncontrolled indoor and outdoor air at PSL be identified for mechanical or non-ASME structural components. If necessary based on the Structures Monitoring AMP evaluation results, an augmented examination plan for a representative sample of stainless steel ASME Class 1, 2 or 3 supports will be developed in accordance with IWF-2430 as a separate part of the ASME Section XI, Subsection IWF AMP.

SLRA Appendix B, Section B.2.3.30, element 1 portion of Enhancements Table on page B-235, is revised as follows:

Element Affected Enhancement

1. Scope of Program Identify the population of ASME Class 1, 2, and 3 high-strength structural bolting greater than one-inch nominal diameter within the boundaries of IWF-1300.
1. Scope of Program Procedures will be revised to evaluate the acceptability of inaccessible areas (e.g., portions of supports encased in concrete, buried underground, or encapsulated by guard pipe) when conditions are identified in accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas.
1. Scope of Program If necessary based on related Structures Monitoring AMP evaluation results (of stainless steel cracking in the uncontrolled indoor and outdoor air at PSL), develop an augmented examination plan in accordance with IWF-2430 for surface examination of a representative sample of stainless steel ASME Class 1, 2, or 3 supports as a separate part of the ASME Section XI, Subsection IWF AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 6 Page 33 of 33 SLRA Appendix B, Section B.2.3.33, portion of Enhancements Table on page B-249, is revised as follows:

Element Affected Enhancement

4. Detection of Aging Update the governing AMP procedure and other applicable Effects procedures to include tactile inspection in addition to visual inspection of elastomeric elements to detect hardening.
4. Detection of Aging Update the governing AMP procedure and other applicable Effects procedures to include evidence of water in-leakage as a finding requiring further evaluation. This may include engineering evaluation, more frequent inspections, or destructive testing of affected concrete to validate existing concrete properties, including concrete pH levels. When leakage volumes allow, assessment may include analysis of the leakage pH, along with mineral, chloride, sulfate, and iron content in the water.
4. Detection of Aging Update the governing AMP procedure and other applicable Effects procedures to address the aggressive groundwater/soil environment to account for the extent of the degradation experienced. Specific requirements include evaluations, destructive testing, and/or focused inspections of representative accessible (leading indicator) or below-grade, inaccessible concrete structural elements exposed to aggressive groundwater/soil, on an interval not to exceed 5 years.
4. Detection of Aging Update the governing AMP procedure and other applicable Effects procedures to require inspections of the Condensate Storage Tank (CST) and Auxiliary Feedwater (AFW) Structures and Piping Inspections in the Trenches every third refueling outage, which will ensure that these inspections are performed at least once per 5 years.
7. Corrective Actions Update the governing AMP procedure and other applicable procedures to include stainless steel ASME Class 1, 2, or 3 support members, welds, bolted connections, or anchorage in the engineering evaluation of acceptance criteria, expansion criteria, and examination frequency if cracking due to SCC in the uncontrolled indoor and outdoor air at PSL is detected for stainless steel mechanical or non-ASME structural components.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 1 of 33 Clarifications to Implementation Schedule for Selected Aging Management Programs Affected SLRA Sections: 19.2.2.27 (Appendices A1 and A2), Table 19-3 (Appendices A1 and A2), B.2.3.16, B.2.3.21, B.2.3.27, B.2.3.28, B.2.3.29, B.2.3.30, B.2.3.36 SLRA Page Numbers: A1-31, A1-77, A1-82, A1-86, A1-89, A1-98, A1-99, A1-100, A1-106, A2-31, A2-78, A2-83, A2-87, A2-89, A2-90, A2-98, A2-99, A2-101, A2-106, B-129, B-178, B-216, B-222, B-228, B-233, B-234, B-261 Description of Change:

NUREG-2191 (GALL-SLR) Table XI-01 uses the following language to describe the implementation schedule for several aging management programs (AMPs): Program is implemented and inspections or tests begin [#] years before the subsequent period of extended operation. The implementation schedules for the selected AMPs in the PSL SLRA are worded slightly differently. An inconsistency was noted between GALL-SLR Table XI-01 and the implementation schedules in the SLRA for the following AMPs:

  • XI.M27, Fire Water System
  • XI.M29, Outdoor and Large Atmospheric Metallic Storage Tanks
  • XI.M30, Fuel Oil Chemistry
  • XI.M32, One-Time Inspection
  • XI.M33, Selective Leaching
  • XI.M35, ASME Code Class 1 Small-Bore Piping
  • XI.M41, Buried and Underground Piping and Tanks
  • XI.M42, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks In addition to these AMPs, similar language was identified in the SLRA implementation schedules for the following AMPs that do not have corresponding language in GALL-SLR Table XI-01:
  • XI.E1, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements For clarification, the implementation schedules for the above listed AMPs are revised to reflect the wording in GALL-SLR Table XI-01.

Accordingly, SLRA Section 19.2.2.27 (Appendices A1, A2), Table 19-3 (Appendices A1, A2),

Section B.2.3.16, Section B.2.3.21, Section B.2.3.27, Section B.2.3.28, Section B.2.3.29, Section B.2.3.30, and Section B.2.3.36 are revised, as follows, to clarify the implementation schedules.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 2 of 33 SLRA Appendix A1, Section 19.2.2.27, page A1-31, is revised as follows:

19.2.2.27 Buried and Underground Piping and Tanks The PSL Buried and Underground Piping and Tanks AMP is a new AMP. This a condition monitoring AMP that manages the aging effects associated with the external surfaces of buried and underground piping.

There are no buried or underground tanks at PSL.

This AMP manages the external surface condition of buried and underground piping for loss of material and cracking for the external surfaces of buried piping fabricated of steel (cast iron, carbon steel, ductile iron) and stainless steel through preventive measures (e.g., coatings, backfill, and compaction), mitigative measures (e.g.,

electrical isolation between piping and supports of dissimilar metals, etc.), and periodic inspection activities (e.g., direct visual inspection of external surfaces, protective coatings, wrappings and quality of backfill) during opportunistic or directed excavations. The number of inspections is based on the effectiveness of the preventive and mitigative actions.

Inspections are conducted by qualified individuals. Where the coatings, backfill or the condition of exposed piping does not meet acceptance criteria, such that the depth or extent of degradation of the base metal could have resulted in a loss of pressure boundary function when the loss of material rate is extrapolated to the end of the SPEO, an increase in the sample size is conducted. Direct visual inspections are performed on the external surfaces, protective coatings, wrappings, quality of backfill and wall thickness measurements using NDE techniques. Additional inspections are performed on steel piping in lieu of fire main testing.

The table below provides additional information related to inspections. Preventive Action Category F has been selected for monitoring steel piping during the initial monitoring period since the proposed cathodic protection system will not be operational during that time period. Upon entering the SPEO, Preventive Action Category C has been selected for buried steel piping after the cathodic protection system has been in service for approximately 10 years and annual effectiveness reviews are performed. However, if these conditions were to change, the Preventive Action Category would require reevaluation and could potentially change.

The number of inspections for each 10-year inspection period, beginningcommencing 10 years beforeprior to the start of SPEO, are based on the inspection quantities noted in NUREG-2191, Table XI.M41-2, adjusted for a 2-Unit plant site.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 3 of 33 SLRA Appendix A1, Section 19.4, commitment No. 19 portion of Table 19-3 on page A1-77, is revised as follows:

Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 19 Fire Water System XI.M27 Continue the existing PSL Fire Water System AMP, including Program inspections or tests (19.2.2.16) enhancement to: begin 5 years before the SPEO. Inspections of the a) Update the governing AMP procedure to clearly state which City Water Storage Tank procedures perform visual inspections for detecting loss of bottoms begin 10 years material, as well as state which procedures perform surface before the SPEO.

examinations or ASME Code,Section XI, VT-1 visual Inspections or tests that are examinations for identifying SCC of copper alloy (>15% Zn) valve to be completed prior to the bodies, nozzles, and strainers. Such visual inspections will SPEO are completed require using an inspection technique capable of detecting 6 months prior to the SPEO surface irregularities that could indicate an unexpected level of or no later than the last degradation due to corrosion and corrosion product deposition. refueling outage prior to the Where such irregularities are detected, follow-up volumetric wall SPEO.

thickness examinations shall be performed. The internal inspections will be performed during the periodic system and Program and SLR component surveillances or during the performance of enhancements are maintenance activities when the surfaces are made accessible for implemented 6 months prior visual inspection. At a minimum, in each 10-year period during to the SPEO, i.e.:No later than the SPEO, a representative sample of 20% of the population 6 months prior to the SPEO, or (defined as components having the same combination of no later than the last refueling material, environment, and aging effect) or a maximum of 19 outage prior to the SPEO i.e.:

components per population at each Unit is inspected. Where practical, the inspections will focus on the bounding or lead PSL1: 09/01/2035 components most susceptible to aging. Implement the AMP and start b) Update the governing AMP procedure to clearly state which inspections and tests no earlier procedures perform volumetric wall thickness inspections. than 5 years prior to the SPEO Volumetric inspections shall be conducted on the portions of the (03/01/2031).

Perform the 10 year City Water Storage Tank bottom inspections within 10 years prior to the SPEO (03/01/2026).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 4 of 33 SLRA Appendix A1, Section 19.4, commitment No. 20 portion of Table 19-3 on page A1-82, is revised as follows:

Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 20 Outdoor and Large XI.M29 Continue the existing PSL Outdoor and Large Atmospheric Metallic Program inspections or tests Atmospheric Metallic Storage Storage Tanks AMP, including enhancement to: begin 10 years before the Tanks (19.2.2.17) SPEO. One-time inspections a) Create a new procedure, and/or associated preventive begin 5 years prior to the maintenance activities, to: SPEO. Inspections or tests

  • Address the interfaces, handoffs, and overlaps between the that are to be completed prior PSL Outdoor and Large Atmospheric Metallic Storage to the SPEO are completed Tanks AMP and the following AMPs: 6 months prior to the SPEO or no later than the last o PSL Structures Monitoring AMP; refueling outage prior to the SPEO.

o PSL External Surfaces Monitoring of Mechanical Components AMP; Program and SLR enhancements are o PSL Water Chemistry AMP; implemented 6 months prior o PSL Fuel Oil Chemistry AMP; to the SPEO, i.e.:No later than 6 months prior to the SPEO, or o PSL One-Time Inspection AMP; no later than the last refueling outage prior to the SPEO i.e.:

o PSL Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks PSL1: 09/01/2035 AMP; and Implement the AMP and start the 10-year interval inspections no earlier than 10 years prior to the SPEO (03/01/2026).

Start the one-time inspections no earlier than 5 years prior to the SPEO (03/01/2031).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 5 of 33 SLRA Appendix A1, Section 19.4, commitment No. 21 portion of Table 19-3 on page A1-86, is revised as follows:

Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 21 Fuel Oil Chemistry XI.M30 Continue the existing PSL Fuel Oil Chemistry AMP, including Program inspections begin (19.2.2.18) enhancement to: 10 years before the SPEO.

Inspections that are to be a) Address the analysis of stored fuels in the day tanks describing completed prior to the SPEO analytical techniques and test frequencies for determining water are completed 6 months prior and sediment content, total particulate concentration, and to the SPEO or no later than microbiological contamination levels. the last refueling outage prior b) Address periodic tank cleaning, and visual or alternative internal to the SPEO.

inspections of the day tanks. Program and SLR c) Drain, clean, and visually inspect all DOSTs at least once during enhancements are the 10-year period prior to the SPEO, and repeat the inspection at implemented 6 months prior least once every 10 years. to the SPEO, i.e.:No later than 6 months prior to the SPEO, or d) Require any pressure retaining boundary degradation identified no later than the last refueling during visual inspection be supplemented with volumetric (UT) outage prior to the SPEO i.e.:

wall thickness testing including bottom thickness measurements for the DOSTs if warranted. PSL1: 09/01/2035 Implement the AMP and start the one-time and 10-year interval inspections no earlier than 10 years prior to the SPEO (03/01/2026).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 6 of 33 SLRA Appendix A1, Section 19.4, commitment No. 23 portion of Table 19-3 on page A1-89, is revised as follows:

Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 23 One Time inspection XI.M32 Implement the new PSL One-Time Inspection AMP. Program inspections begin (19.2.2.20) 10 years before the SPEO.

Inspections that are to be completed prior to the SPEO are completed 6 months prior to the SPEO or no later than the last refueling outage prior to the SPEO.

Program and SLR enhancements are implemented 6 months prior to the SPEO, i.e.:No later than 6 months prior to the SPEO, or no later than the last refueling outage prior to the SPEO i.e.:

PSL1: 09/01/2035 Implement the AMP and start the one-time inspections no earlier than 10 years prior to the SPEO (03/01/2026).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 7 of 33 SLRA Appendix A1, Section 19.4, commitment No. 24 portion of Table 19-3 on page A1-89, is revised as follows:

Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 24 Selective Leaching XI.M33 Implement the new PSL Selective Leaching AMP. Program inspections begin (19.2.2.21) 10 years before the SPEO.

Inspections that are to be completed prior to the SPEO are completed 6 months prior to the SPEO or no later than the last refueling outage prior to the SPEO.

Program and SLR enhancements are implemented 6 months prior to the SPEO, i.e.:No later than 6 months prior to the SPEO, or no later than the last refueling outage prior to the SPEO i.e.:

PSL1: 09/01/2035 Implement the AMP and start the one-time and 10-year interval inspections no earlier than 10 years prior to the SPEO (03/01/2026).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 8 of 33 SLRA Appendix A1, Section 19.4, commitment No. 25 portion of Table 19-3 on page A1-89, is revised as follows:

Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 25 ASME Code Class 1 XI.M35 Continue the existing PSL ASME Code Class 1 Small-Bore Piping Program inspections are Small-Bore Piping AMP, which includes: completed within 6 years (19.2.2.22) before the SPEO.

a) Perform one-time inspection of small-bore piping using the Inspections that are to be methods, frequencies, and acceptance criteria as outlined in completed prior to the SPEO NUREG-2191,Section XI.M35. are completed 6 months prior b) Evaluate the results to determine if additional or periodic to the SPEO or no later than inspections are required and perform any required additional the last refueling outage prior inspections. to the SPEO.

Program and SLR enhancements are implemented 6 months prior to the SPEO, i.e.:No later than 6 months prior to the SPEO, or no later than the last refueling outage prior to the SPEO i.e.:

PSL1: 09/01/2035 Implement the AMP and start the inspections within 6 years prior to the SPEO (03/01/2030).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 9 of 33 SLRA Appendix A1, Section 19.4, commitment No. 30 portion of Table 19-3 on page A1-98, is revised as follows:

Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 30 Buried and Underground XI.M41 Implement the new PSL Buried and Underground Piping and Tanks Program inspections begin Piping and Tanks (19.2.2.27) AMP. 10 years before the SPEO.

Inspections that are to be a) Install cathodic protection systems and perform effectiveness completed prior to the SPEO reviews in accordance with Table XI.M41-2 in NUREG-2191, are completed 6 months prior Section XI.M41. to the SPEO or no later than b) If after five years of operation the cathodic protection system the last refueling outage prior does not meet the effectiveness acceptance criteria defined by to the SPEO.

NUREG-2191, Tables XI.M41-2 and -3 (-850 mV relative to a Install cathodic protection CSE, instant off, for at least 80% of the time, and in operation for systems at least 10 years at least 85% of the time), FPL commits to performing two before the SPEO.

additional buried steel piping inspections beyond the number required by Preventive Action Category F resulting in a total of 13 Program and SLR inspections being completed 6 months prior to the SPEO. enhancements are implemented 6 months prior to the SPEO, i.e.:Implement AMP and start inspections no earlier than 10 years prior to the SPEO (03/01/2026). Install cathodic protection systems no later than 10 years prior to the SPEO (03/01/2026). Complete pre-SPEO inspections no later than 6 months or the last RFO prior to SPEO i.e.:

PSL1: 09/01/2035

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 10 of 33 SLRA Appendix A1, Section 19.4, commitment No. 31 portion of Table 19-3 on page A1-98, is revised as follows:

Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 31 Internal Coatings/Linings For XI.M42 Implement the new PSL Internal Coatings/Linings for In-Scope Piping, Program inspections begin In-scope Piping, Piping Piping Components, Heat Exchangers, and Tanks AMP and complete 10 years before the SPEO.

Components, Heat the initial inspections. Inspections that are to be Exchangers, and Tanks completed prior to the SPEO (19.2.2.28) are completed 6 months prior to the SPEO or no later than the last refueling outage prior to the SPEO.

Program and SLR enhancements are implemented 6 months prior to the SPEO, i.e.:No later than 6 months prior to the SPEO, or no later than the last refueling outage prior to the SPEO i.e.:

PSL1: 09/01/2035 Implement the AMP and perform baseline inspections no earlier than 10 years prior to the SPEO (03/01/2026).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 11 of 33 SLRA Appendix A1, Section 19.4, commitment No. 32 portion of Table 19-3 on page A1-99, is revised as follows:

Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 32 ASME Section XI, XI.S1 Continue the existing PSL ASME Section XI, Subsection IWE AMP, Program one-time Subsection IWE (19.2.2.29) including enhancement to: inspections for cracking due a) Augment existing procedures to specify that whenever to SCC begin 5 years before replacement of bolting is required, bolting material, installation the SPEO. Inspections that torque or tension, and use of lubricants and sealants are in are to be completed prior to accordance with the guidelines of EPRI NP-5769, Degradation the SPEO are completed and Failure of Bolting in Nuclear Power Plants and EPRI 6 months prior to the SPEO TR-104213, Bolted Joint Maintenance & Application Guide. or no later than the last b) Augment existing procedures to specify that for structural bolting refueling outage prior to the consisting of ASTM A325, ASTM A490, and equivalent materials, SPEO.

the preventive actions for storage, lubricants, and stress corrosion cracking potential discussed in Section 2 of RCSC (Research Program and SLR Council for Structural Connections) publication Specification for enhancements are Structural Joints Using ASTM A325 or A490 Bolts, will be used. implemented 6 months prior c) Augment existing procedures to implement periodic supplemental to the SPEO, i.e.:No later than surface or enhanced visual examinations at intervals no greater 6 months prior to the SPEO, or than 10 years to detect cracking due to cyclic loading of all no later than the last refueling non-piping penetrations (hatches, electrical penetrations, etc.) outage prior to the SPEO i.e.:

that are subject to cyclic loading but have no current licensing PSL1: 09/01/2035 bases fatigue analysis and are not subject to local leak rate testing. Start the one-time inspections d) Augment existing procedures to implement supplemental for cracking due to SCC no one-time surface or enhanced visual examinations, performed by earlier than 5 years prior to the qualified personnel using methods capable of detecting cracking, SPEO (03/01/2031).

comprising (a) a representative sample (two) of the stainless steel penetrations or dissimilar metal welds associated with high-temperature (temperatures above 140°F) stainless steel piping systems in frequent use on each unit; and (b) the stainless steel fuel transfer tube on each unit. These inspections are intended to confirm the absence of SCC aging effects. If SCC is

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 12 of 33 SLRA Appendix A1, Section 19.4, commitment No. 33 portion of Table 19-3 on page A1-100, is revised as follows:

Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 33 ASME Section XI, XI.S3 Continue the existing PSL ASME Section XI, Subsection IWF AMP, Program one-time Subsection IWF (19.2.2.30) including enhancement to: inspections begin 5 years before the SPEO.

a) Identify the population of ASME Class 1, 2, and 3 high-strength Inspections that are to be structural bolting greater than one-inch nominal diameter within completed prior to the SPEO the boundaries of IWF-1300. are completed 6 months prior b) Augment existing procedures to evaluate the acceptability of to the SPEO or no later than inaccessible areas (e.g., portions of supports encased in the last refueling outage prior concrete, buried underground, or encapsulated by guard pipe) to the SPEO.

when conditions in accessible areas that could indicate the Program and SLR presence of, or result in, degradation to such inaccessible areas. enhancements are c) Augment existing procedures to specify the use of high-strength implemented 6 months prior bolt storage requirements discussed in Section 2 of RCSC to the SPEO, i.e.:No later than 6 months prior to the SPEO, or no later than the last refueling outage prior to the SPEO i.e.:

PSL1: 09/01/2035 Start the one-time inspection no earlier than 5 years prior to the SPEO (03/01/2031).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 13 of 33 SLRA Appendix A1, Section 19.4, commitment No. 39 portion of Table 19-3 on page A1-106, is revised as follows:

Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 39 Electrical Insulation for XI.E1 Continue the existing PSL Electrical Insulation for Electrical Cables Program inspections begin Electrical Cables and and Connections Not Subject to 10 CFR 50.49 Environmental 10 years before the SPEO.

Connections Not Subject to Qualification Requirements (formerly the Containment Cable Inspections that are to be 10 CFR 50.49 Environmental Inspection Program), including enhancement to: completed prior to the SPEO Qualification Requirements are completed 6 months prior (19.2.2.36) a) Review plant-specific OE for previously identified and mitigated to the SPEO or no later than adverse localized environments cumulative aging effects the last refueling outage prior applicable to in-scope cable and connection electrical insulation to the SPEO.

during the original PEO. Evaluate to confirm that the dispositioned corrective actions continue to support in-scope Program and SLR cable and connection intended functions during the SPEO. enhancements are implemented 6 months prior b) If cable testing is deemed necessary, utilize sampling to the SPEO, i.e.:No later than methodology consistent with guidance of Section XI.E1 of 6 months prior to the SPEO, or NUREG-2191. no later than the last refueling outage prior to the SPEO i.e.:

PSL1: 09/01/2035 Implement the AMP and start the 10-year interval inspections no earlier than 10 years prior to the SPEO (03/01/2026).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 14 of 33 SLRA Appendix A2, Section 19.2.2.27, page A2-31, is revised as follows:

This AMP manages the external surface condition of buried and underground piping for loss of material and cracking for the external surfaces of buried piping fabricated of steel (cast iron, carbon steel, ductile iron) and stainless steel through preventive measures (e.g., coatings, backfill, and compaction), mitigative measures (e.g.,

electrical isolation between piping and supports of dissimilar metals, etc.), and periodic inspection activities (e.g., direct visual inspection of external surfaces, protective coatings, wrappings and quality of backfill) during opportunistic or directed excavations. The number of inspections is based on the effectiveness of the preventive and mitigative actions.

Inspections are conducted by qualified individuals. Where the coatings, backfill or the condition of exposed piping does not meet acceptance criteria, such that the depth or extent of degradation of the base metal could have resulted in a loss of pressure boundary function when the loss of material rate is extrapolated to the end of the SPEO, an increase in the sample size is conducted. Direct visual inspections are performed on the external surfaces, protective coatings, wrappings, quality of backfill and wall thickness measurements using NDE techniques. Additional inspections are performed on steel piping in lieu of fire main testing.

The table below provides additional information related to inspections. Preventive Action Category F has been selected for monitoring steel piping during the initial monitoring period since the proposed cathodic protection system will not be operational during that time period. Upon entering the SPEO, Preventive Action Category C has been selected for buried steel piping after the cathodic protection system has been in service for approximately 10 years and annual effectiveness reviews are performed. However, if these conditions were to change, the Preventive Action Category would require reevaluation and could potentially change.

The number of inspections for each 10-year inspection period, beginningcommencing 10 years beforeprior to the start of SPEO, are based on the inspection quantities noted in NUREG-2191, Table XI.M41-2, adjusted for a 2-Unit plant site.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 15 of 33 SLRA Appendix A2, Section 19.4, commitment No. 19 portion of Table 19-3 on page A2-78, is revised as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 19 Fire Water System XI.M27 Continue the existing PSL Fire Water System AMP, including Program inspections or tests (19.2.2.16) enhancement to: begin 5 years before the a) Update the governing AMP procedure to clearly state which SPEO. Inspections of the procedures perform visual inspections for detecting loss of City Water Storage Tank material, as well as state which procedures perform surface bottoms begin 10 years examinations or ASME Code,Section XI, VT-1 visual before the SPEO.

examinations for identifying SCC of copper alloy (>15% Zn) valve Inspections or tests that are bodies, nozzles, and strainers. Such visual inspections will to be completed prior to the require using an inspection technique capable of detecting SPEO are completed surface irregularities that could indicate an unexpected level of 6 months prior to the SPEO degradation due to corrosion and corrosion product deposition. or no later than the last Where such irregularities are detected, follow-up volumetric wall refueling outage prior to the thickness examinations shall be performed. The internal SPEO.

inspections will be performed during the periodic system and component surveillances or during the performance of Program and SLR maintenance activities when the surfaces are made accessible for enhancements are visual inspection. At a minimum, in each 10-year period during implemented 6 months prior the SPEO, a representative sample of 20% of the population to the SPEO, i.e.:No later than (defined as components having the same combination of material, 6 months prior to the SPEO, or environment, and aging effect) or a maximum of 19 components no later than the last refueling per population at each Unit is inspected. Where practical, the outage prior to the SPEO i.e.:

inspections will focus on the bounding or lead components most PSL2: 10/06/2042 susceptible to aging.

b) Update the governing AMP procedure to clearly state which Implement the AMP and start procedures perform volumetric wall thickness inspections. inspections and tests no earlier Volumetric inspections shall be conducted on the portions of the than 5 years prior to the SPEO water-based fire protection system components that are (04/06/2038).

periodically subjected to flow but are normally dry.

Perform the 10-year City Water c) Update existing inspection/testing procedures and create new Storage Tank bottom procedures to incorporate the surveillance requirements stated in inspections within 10 years prior NUREG-2191,Section XI.M27, Element 4 and Table XI.M27-1, to the SPEO (04/06/2033).

which are based on NFPA 25, 2011 edition. This includes testing

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 16 of 33 SLRA Appendix A2, Section 19.4, commitment No. 20 portion of Table 19-3 on page A2-83, is revised as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 20 Outdoor and Large XI.M29 Continue the existing PSL Outdoor and Large Atmospheric Metallic Program inspections or tests Atmospheric Metallic Storage Storage Tanks AMP, including enhancement to: begin 10 years before the Tanks (19.2.2.17) SPEO. One-time inspections a) Create a new procedure, and/or associated preventive begin 5 years prior to the maintenance activities, to: SPEO. Inspections or tests

  • Address the interfaces, handoffs, and overlaps between the that are to be completed prior PSL Outdoor and Large Atmospheric Metallic Storage to the SPEO are completed Tanks AMP and the following AMPs: 6 months prior to the SPEO or no later than the last o PSL Structures Monitoring AMP; refueling outage prior to the SPEO.

o PSL External Surfaces Monitoring of Mechanical Components AMP; Program and SLR enhancements are o PSL Water Chemistry AMP; implemented 6 months prior o PSL One-Time Inspection AMP, to the SPEO, i.e.:No later than 6 months prior to the SPEO, or o PSL Internal Coatings/Linings for In-Scope Piping, no later than the last refueling Piping Components, Heat Exchangers, and Tanks outage prior to the SPEO i.e.:

AMP; and PSL2: 10/06/2042 o PSL ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD AMP. Implement the AMP and start the 10-year interval inspections

  • Direct periodic (18-month interval) visual inspection of no earlier than 10 years prior to tank-to-concrete caulking/sealants, with mechanical the SPEO (04/06/2033).

manipulation as appropriate. Update or reactivate existing caulking/sealant inspection preventive maintenance Start the one-time inspections activities and create new caulking/sealant inspection no earlier than 5 years prior to preventive maintenance activities as needed. These the SPEO (04/06/2038).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 17 of 33 SLRA Appendix A2, Section 19.4, commitment No. 21 portion of Table 19-3 on page A2-87, is revised as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 21 Fuel Oil Chemistry XI.M30 Continue the existing PSL Fuel Oil Chemistry AMP, including Program inspections begin (19.2.2.18) enhancement to: 10 years before the SPEO.

Inspections that are to be a) Address the analysis of stored fuels in the day tanks describing completed prior to the SPEO analytical techniques and test frequencies for determining water are completed 6 months prior and sediment content, total particulate concentration, and to the SPEO or no later than microbiological contamination levels. the last refueling outage prior b) Address periodic tank cleaning, and visual or alternative internal to the SPEO.

inspections of the day tanks. Program and SLR c) Drain, clean, and visually inspect all DOSTs at least once during enhancements are the 10-year period prior to the SPEO, and repeat the inspection at implemented 6 months prior least once every 10 years. to the SPEO, i.e.:No later than 6 months prior to the SPEO, or d) Require any pressure retaining boundary degradation identified no later than the last refueling during visual inspection be supplemented with volumetric (UT) outage prior to the SPEO i.e.:

wall thickness testing including bottom thickness measurements for the DOSTs if warranted. PSL2: 10/06/2042 e) Prior to the SPEO, perform a one-time inspection of selected Implement the AMP and start components exposed to diesel fuel oil in accordance with the PSL the one-time and 10-year One-Time Inspection AMP to verify the effectiveness of the PSL interval inspections no earlier Fuel Oil Chemistry AMP. than 10 years prior to the SPEO (04/06/2033).

f) Enhance monitoring and trending by;

  • Perform periodic fuel oil sampling of the day tanks.
  • Clarify that the sampling specifically monitors the following parameters for trending purposes: water content, sediment content, biological activity, and total particulate concentration for all DOSTs and day tanks.
  • Update frequency of ASTM D975 analysis to quarterly.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 18 of 33 SLRA Appendix A2, Section 19.4, commitment No. 23 portion of Table 19-3 on page A2-89, is revised as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 23 One Time inspection XI.M32 Implement the new PSL One-Time Inspection AMP. Program inspections begin (19.2.2.20) 10 years before the SPEO.

Inspections that are to be completed prior to the SPEO are completed 6 months prior to the SPEO or no later than the last refueling outage prior to the SPEO.

Program and SLR enhancements are implemented 6 months prior to the SPEO, i.e.:No later than 6 months prior to the SPEO, or no later than the last refueling outage prior to the SPEO i.e.:

PSL2: 10/06/2042 Implement the AMP and start the one-time inspections no earlier than 10 years prior to the SPEO (04/06/2033).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 19 of 33 SLRA Appendix A2, Section 19.4, commitment No. 24 portion of Table 19-3 on page A2-89, is revised as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 24 Selective Leaching XI.M33 Implement the new PSL Selective Leaching AMP. Program inspections begin (19.2.2.21) 10 years before the SPEO.

Inspections that are to be completed prior to the SPEO are completed 6 months prior to the SPEO or no later than the last refueling outage prior to the SPEO.

Program and SLR enhancements are implemented 6 months prior to the SPEO, i.e.:No later than 6 months prior to the SPEO, or no later than the last refueling outage prior to the SPEO i.e.:

PSL2: 10/06/2042 Implement the AMP and start the one-time and 10-year interval inspections no earlier than 10 years prior to the SPEO (04/06/2033).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 20 of 33 SLRA Appendix A2, Section 19.4, commitment No. 25 portion of Table 19-3 on page A2-90, is revised as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 25 ASME Code Class 1 XI.M35 Continue the existing PSL ASME Code Class 1 Small-Bore Piping Program inspections are Small-Bore Piping AMP, which includes: completed 6 years before the (19.2.2.22) SPEO. Inspections that are a) Perform one-time inspection of small-bore piping using the to be completed prior to the methods, frequencies, and acceptance criteria as outlined in SPEO are completed NUREG-2191,Section XI.M35. 6 months prior to the SPEO b) Evaluate the results to determine if additional or periodic or no later than the last inspections are required and perform any required additional refueling outage prior to the inspections. SPEO.

Program and SLR enhancements are implemented 6 months prior to the SPEO, i.e.:No later than 6 months prior to the SPEO, or no later than the last refueling outage prior to the SPEO i.e.:

PSL2: 10/06/2042 Implement the AMP and start the inspections within 6 years prior to the SPEO (04/06/2037).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 21 of 33 SLRA Appendix A2, Section 19.4, commitment No. 30 portion of Table 19-3 on page A2-98, is revised as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 30 Buried and Underground XI.M41 Implement the new PSL Buried and Underground Piping and Tanks Program inspections begin Piping and Tanks (19.2.2.27) AMP. 10 years before the SPEO.

Inspections that are to be a) Install cathodic protection systems and perform effectiveness completed prior to the SPEO reviews in accordance with Table XI.M41-2 in NUREG-2191, are completed 6 months prior Section XI.M41. to the SPEO or no later than b) If after five years of operation the cathodic protection system the last refueling outage prior does not meet the effectiveness acceptance criteria defined by to the SPEO.

NUREG-2191, Tables XI.M41-2 and -3 (-850 mV relative to a Install cathodic protection CSE, instant off, for at least 80% of the time, and in operation for systems at least 10 years at least 85% of the time), FPL commits to performing two before the SPEO.

additional buried steel piping inspections beyond the number required by Preventive Action Category F resulting in a total of Program and SLR enhancements are implemented 6 months prior to the SPEO, i.e.:Implement AMP and start inspections no earlier than 10 years prior to the SPEO (04/06/2033). Install cathodic protection systems no later than 10 years prior to the SPEO (04/06/2033).

Complete pre-SPEO inspections no later than 6 months or the last RFO prior to SPEO i.e.:

PSL2: 10/06/2042

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 22 of 33 SLRA Appendix A2, Section 19.4, commitment No. 31 portion of Table 19-3 on page A2-99, is revised as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 31 Internal Coatings/Linings For XI.M42 Implement the new PSL Internal Coatings/Linings for In-Scope Piping, Program inspections begin In-scope Piping, Piping Piping Components, Heat Exchangers, and Tanks AMP and complete 10 years before the SPEO.

Components, Heat the initial inspections. Inspections that are to be Exchangers, and Tanks completed prior to the SPEO (19.2.2.28) are completed 6 months prior to the SPEO or no later than the last refueling outage prior to the SPEO.

Program and SLR enhancements are implemented 6 months prior to the SPEO, i.e.:No later than 6 months prior to the SPEO, or no later than the last refueling outage prior to the SPEO i.e.:

PSL2: 10/06/2042 Implement the AMP and perform baseline inspections no earlier than 10 years prior to the SPEO (04/06/2033).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 23 of 33 SLRA Appendix A2, Section 19.4, commitment No. 32 portion of Table 19-3 on page A2-99, is revised as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 32 ASME Section XI, XI.S1 Continue the existing PSL ASME Section XI, Subsection IWE AMP, Program one-time Subsection IWE (19.2.2.29) including enhancement to: inspections for cracking due to SCC begin 5 years before a) Augment existing procedures to specify that whenever the SPEO. Inspections that replacement of bolting is required, bolting material, installation are to be completed prior to torque or tension, and use of lubricants and sealants are in the SPEO are completed accordance with the guidelines of EPRI NP-5769, Degradation 6 months prior to the SPEO and Failure of Bolting in Nuclear Power Plants and EPRI or no later than the last TR-104213, Bolted Joint Maintenance & Application Guide. refueling outage prior to the b) Augment existing procedures to specify that for structural bolting SPEO.

consisting of ASTM A325, ASTM A490, and equivalent materials, Program and SLR the preventive actions for storage, lubricants, and stress enhancements are corrosion cracking potential discussed in Section 2 of RCSC implemented 6 months prior (Research Council for Structural Connections) publication to the SPEO, i.e.:No later than Specification for Structural Joints Using ASTM A325 or A490 6 months prior to the SPEO, or Bolts, will be used. no later than the last refueling c) Augment existing procedures to implement periodic supplemental outage prior to the SPEO i.e.:

surface or enhanced visual examinations at intervals no greater PSL2: 10/06/2042 than 10 years to detect cracking due to cyclic loading of all Start the one-time inspections for cracking due to SCC no earlier than 5 years prior to the SPEO (04/06/2038).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 24 of 33 SLRA Appendix A2, Section 19.4, commitment No. 33 portion of Table 19-3 on page A2-101, is revised as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 33 ASME Section XI, XI.S3 Continue the existing PSL ASME Section XI, Subsection IWF AMP, Program one-time Subsection IWF (19.2.2.30) including enhancement to: inspections begin 5 years before the SPEO.

a) Identify the population of ASME Class 1, 2, and 3 high-strength Inspections that are to be structural bolting greater than one-inch nominal diameter within completed prior to the SPEO the boundaries of IWF-1300. are completed 6 months prior b) Augment existing procedures to evaluate the acceptability of to the SPEO or no later than inaccessible areas (e.g., portions of supports encased in the last refueling outage prior concrete, buried underground, or encapsulated by guard pipe) to the SPEO.

when conditions in accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas. Program and SLR c) Augment existing procedures to specify the use of high-strength enhancements are bolt storage requirements discussed in Section 2 of RCSC implemented 6 months prior (Research Council for Structural Connections) publication to the SPEO, i.e.:No later than Specification for Structural Joints Using ASTM A325 or A490 6 months prior to the SPEO, or Bolts, for structural bolting consisting of ASTM A325, ASTM no later than the last refueling A490, and equivalent bolts. outage prior to the SPEO i.e.:

d) Augment existing procedures to specify that bolting within the scope of this program is inspected for loss of integrity of bolted PSL2: 10/06/2042 connections due to self-loosening. Start the one-time inspection no e) Augment existing procedures to specify that accessible sliding earlier than 5 years prior to the surfaces are monitored for significant loss of material due to wear SPEO (04/06/2038).

and accumulation of debris or dirt.

f) Perform and document a one-time inspection of an additional 5%

of the sample populations for Class 1, 2, and 3 piping supports.

The additional supports will be selected from the remaining population of IWF piping supports and will include components that are most susceptible to age-related degradation.

g) Augment existing procedures to specify that, for component supports with high-strength bolting greater than one-inch nominal

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 25 of 33 SLRA Appendix A2, Section 19.4, commitment No. 39 portion of Table 19-3 on page A2-106, is revised as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 39 Electrical Insulation for XI.E1 Continue the existing PSL Electrical Insulation for Electrical Cables Program inspections begin Electrical Cables and and Connections Not Subject to 10 CFR 50.49 Environmental 10 years before the SPEO.

Connections Not Subject to Qualification Requirements (formerly the Containment Cable Inspections that are to be 10 CFR 50.49 Environmental Inspection Program), including enhancement to: completed prior to the SPEO Qualification Requirements are completed 6 months prior (19.2.2.36) a) Review plant-specific OE for previously identified and mitigated to the SPEO or no later than adverse localized environments cumulative aging effects the last refueling outage prior applicable to in-scope cable and connection electrical insulation to the SPEO.

during the original PEO. Evaluate to confirm that the dispositioned corrective actions continue to support in-scope Program and SLR cable and connection intended functions during the SPEO. enhancements are implemented 6 months prior b) If cable testing is deemed necessary, utilize sampling to the SPEO, i.e.:No later than methodology consistent with guidance of Section XI.E1 of 6 months prior to the SPEO, or NUREG-2191. no later than the last refueling outage prior to the SPEO i.e.:

PSL2: 10/06/2042 Implement the AMP and start the 10-year interval inspections no earlier than 10 years prior to the SPEO (04/06/2033).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 26 of 33 SLRA Section B.2.3.16, page B-129 is revised as follows:

system also verify unobstructed flow and integrity of the piping/components.

Continuous fire water system pressure monitoring is performed and low-pressure alarms alert the operators to abnormal system conditions or leaks. Therefore, loss of system pressure is immediately detected and corrected when acceptance criteria are exceeded. Additionally, periodic functional testing, internal inspections, and wall thickness evaluations of selected portions of the system provides reasonable assurance that corrosion and biofouling are not occurring to an extent that an intended function would be compromised.

The CWSTs are externally inspected annually and internally inspected and volumetrically (UT) examined on a 5-year interval, which includes UT examination of the tank bottoms. These wall thickness examinations will also examine the CWST bottom surfaces in accordance with the NUREG-2191, Table XI.M29 1. Specifically, for each 10-year period beginningstarting 10 years before the SPEO, a volumetric inspection will be required to be performed from the inside surface of the tanks. The new tank bottom thickness inspections will use a low-frequency electromagnetic testing (LFET) technique and, as necessary, follow-up ultrasonic examinations. Any regions below nominal plate thickness will have a follow-up ultrasonic thickness reading. If there are areas of significant loss of material that could impact the pressure boundary function, future ultrasonic thickness measurements and trending will be performed.

Results from the various surveillances are evaluated per the respective procedures.

Any degradation identified by visual/volumetric inspections or flushes/flow testing is reported, evaluated, and corrected through the PSL corrective action program.

Acceptance criteria for observed degradation, flow obstruction, discharge flow/pressures, or minimum wall thickness are defined in the PSL Fire Water System AMP procedures used to perform the respective inspections and tests.

NUREG-2191 Consistency The PSL Fire Water System AMP, with enhancements, will be consistent without exception to the 10 elements of NUREG-2191,Section XI.M27, Fire Water System.

Exceptions to NUREG-2191 None.

Enhancements The PSL Fire Water System AMP will be enhanced as follows, for alignment with NUREG-2191. This AMP is to be implemented and its iInspections and tests begin no earlier than 5 years beforeprior to the SPEO. The inspections and tests are to be completed no later than six months prior to entering the SPEO or no later than the last refueling outage prior to the SPEO.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 27 of 33 SLRA Section B.2.3.21, page B-178 is revised as follows:

a. For gray cast iron and ductile iron, the absence of a surface layer that can be easily removed by chipping or scraping or identified in the destructive examinations.
b. The presence of no more than a superficial layer of dealloying, as determined by removal of the dealloyed material by mechanical removal.
c. The components meet system design requirements such as minimum wall thickness, when extended to the end of the SPEO.

When the acceptance criteria are not met such that it is determined that the affected component should be replaced prior to the end of the SPEO, additional inspections are performed if the cause of the aging effect for each applicable material and environment is not corrected by repair or replacement for all components constructed of the same material and exposed to the same environment. The number of additional inspections is equal to the number of failed inspections for each material and environment population, with a minimum of five additional visual and mechanical inspections when visual and mechanical inspections did not meet acceptance criteria, or 20 percent of each applicable material and environment combination is inspected, whichever is less, and a minimum of one additional destructive examination when destruction examination(s) did not meet acceptance criteria.

If subsequent inspections do not meet acceptance criteria, an extent of condition and extent of cause analysis is conducted to determine the further extent of inspections.

The timing of the additional inspections is based on the severity of the degradation identified and is commensurate with the potential for loss of intended function.

However, in all cases, the additional inspections are completed within the interval in which the original inspection was conducted or, if identified in the latter half of the current inspection interval, within the next RFO interval. These additional inspections conducted in the next inspection interval cannot also be credited towards the number of inspections in the latter interval. Additional samples are inspected for any recurring degradation to ensure corrective actions appropriately address the associated causes. Since PSL is a multi-Unit site, the additional inspections include inspections at both Units 1 and 2 when the two Units have the same material, environment, and aging effect combination.

The PSL Selective Leaching AMP will have new governing and inspection procedures consistent with NUREG-2191,Section XI.M33.

The PSL Selective Leaching AMP implementation and pre-SPEO inspections will be completed no later than 6 months prior to the SPEO or no later than the last refueling outage prior to the SPEO. The pre-SPEO inspections will beginstart no earlier than 10 years beforeprior to the SPEO.

NUREG-2191 Consistency The PSL Selective Leaching AMP will be consistent without exception to the 10 elements of NUREG-2191,Section XI.M33, Selective Leaching.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 28 of 33 SLRA Section B.2.3.27, page B-216 is revised as follows:

selected for buried steel piping after the cathodic protection system has been in service for approximately 10 years and annual effectiveness reviews are performed.

However, if these conditions were to change, the Preventive Action Category would require reevaluation and could potentially change.

The number of inspections for each 10-year inspection period, beginning commencing 10 years beforeprior to the start of SPEO, are based on the inspection quantities noted in NUREG-2191, Table XI.M41-2, adjusted for a 2-Unit plant site.

Material No. of Inspections Notes Steel (buried) 11* prior to the SPEO (Category Includes 2 additional inspections to meet F) the requirements of NUREG-2191 4 in each 10-year period in the Section XI.M41, paragraph 4.e.i regarding SPEO (Category C) the aging effects associated with fire mains.

Steel (underground) 3 Stainless steel 2 (buried)

  • If after five years of operation the cathodic protection system does not meet the effectiveness acceptance criteria defined by NUREG-2191, Tables XI.M41-2 and -3 (-850 mV relative to a CSE, instant off, for at least 80 percent of the time, and in operation for at least 85 percent of the time), FPL commits to performing two additional buried steel piping inspections beyond the number required by Preventive Action Category F resulting in a total of thirteen (13) inspections being completed six months prior to the SPEO.

This AMP does not provide aging management of selective leaching. The PSL Selective Leaching of Materials (Section B.2.3.21) AMP is applied in addition to this program for applicable materials and environments.

The PSL Buried and Underground Piping and Tanks AMP requires the creation of new governing and inspection procedures consistent with NUREG-2191,Section XI.M41, as well as a new sampling plan and work orders to support the new inspections. A new cathodic protection system will also be installed, and an effectiveness review per Table XI.M41-2 of NUREG-2191,Section XI.M41 will be performed throughout each of the 10-year inspection periods. This AMP is implemented, and the iInitial inspections begin no earlier than 10 years beforeprior to the SPEO and are completed no later than six months prior to entering the SPEO or no later than the last RFO prior to the SPEO.

NUREG-2191 Consistency The PSL Buried and Underground Piping and Tanks AMP will be consistent without exception to the 10 elements of NUREG-2191,Section XI.M41, Buried and Underground Piping and Tanks.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 29 of 33 SLRA Section B.2.3.28, page B-222 is revised as follows:

consistent with NUREG-2191,Section XI.M42. Existing procedures that supplement the governing procedure are also required to be updated to ensure that the inspection frequency and sampling criteria are followed, and that in-scope internal coatings are captured.

The PSL Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks AMP implementation and pre-SPEO inspections will be completed no later than 6 months prior to the SPEO or no later than the last refueling outage prior to the SPEO. The pre-SPEO baseline inspections will beginstart no earlier than 10 years beforeprior to the SPEO.

NUREG-2191 Consistency The PSL Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks AMP will be consistent without exception to the 10 elements of NUREG-2191,Section XI.M42, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks as modified by SLR-ISG-2021-02-Mechanical, Updated Aging Management Criteria for Mechanical Portions of Subsequent License Renewal Guidance.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 30 of 33 SLRA Section B.2.3.29, page B-228 is revised as follows:

addressed in the Containment Liner Plate, Metal Containments, and Penetrations Fatigue Analysis TLAA for SLR (Section 4.6). Cracking due to cyclic loading of all non-piping penetrations (equipment hatch, personnel locks, electrical penetrations, etc.) that are subject to cyclic loading but have no current licensing bases fatigue analysis will be managed by the 10 CFR Part 50, Appendix J AMP (Section B.2.3.31) or by periodic supplemental surface or enhanced visual examinations incorporated into and consistent with the frequency of this AMP. This AMP will also include supplemental one-time inspections beginningwithin 5 years beforeprior to the SPEO for a representative sample of SS penetrations and dissimilar metal welds, including the fuel transfer tubes, that may be susceptible to SCC.

Examinations and evaluations are performed in accordance with the requirements of ASME Section XI, Subsection IWE, which provides acceptance standards for the containment pressure boundary components. Areas identified with damage or degradation that exceed acceptance standards require an engineering evaluation or require correction by repair or replacement. Such areas are corrected by repair or replacement in accordance with IWE-3000 or accepted by engineering evaluation.

NUREG-2191 Consistency The PSL ASME Section XI, Subsection IWE AMP, with enhancements, will be consistent without exception to the 10 elements of NUREG-2191,Section XI.S1, ASME Section XI, Subsection IWE.

Exceptions to NUREG-2191 None.

Enhancements The PSL ASME Section XI, Subsection IWE AMP will be enhanced as follows, for alignment with NUREG-2191. The one-time inspections for cracking due to SCC will beginbe started no earlier than five years beforeprior to the SPEO. The enhancements are to be implemented and one-time inspections completed no later than 6 months prior to entering the SPEO.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 31 of 33 SLRA Section B.2.3.30, page B-233 is revised as follows:

B.2.3.30 ASME Section XI, Subsection IWF Program Description The PSL ASME Section XI, Subsection IWF AMP is an existing AMP that consists of periodic visual examination of ASME Code Section XI Class 1, 2, and 3 supports for ASME piping and components for signs of degradation such as corrosion; cracking, deformation; misalignment of supports; missing, detached, or loosened support items; loss of integrity of welds; improper clearances of guides and stops; and improper hot or cold settings of spring supports and constant load supports. This AMP is also credited for identifying visible indications of loss of fracture toughness due to irradiation embrittlement of the reactor vessel supports. Bolting for Class 1, 2, and 3 piping and component supports is also included and inspected for corrosion, loss of integrity of bolted connections due to self-loosening, and material conditions that can affect structural integrity. This AMP will use the edition and addenda of ASME Section XI required by 10 CFR 50.55a, as reviewed and approved by the NRC staff for aging management under 10 CFR 54. Alternatives to these requirements that are aging management related will be evaluated from an aging management point of view in accordance with 10 CFR 50.59 and reviewed/

approved by the NRC staff under 10 CFR 50.55a, if required, before they are implemented.

The ASME Section XI, Subsection IWF AMP provides inspection and acceptance criteria and meets the requirements of the ASME Boiler and Pressure Vessel Code,Section XI, 2007 edition with addenda through 2008, for Class 1, 2, and 3 piping and component supports. The primary inspection method employed is visual examination. Non-destructive examination (NDE) indications are evaluated against the acceptance standards of ASME Code Section XI. Examinations that reveal indications are evaluated. Examinations that reveal flaws or relevant conditions that exceed the referenced acceptance standard are expanded to include additional examinations during the current outage. The scope of inspection for supports is based on sampling of the total support population. The sample size varies depending on the ASME Code Class. The largest sample size is specified for the most critical supports (ASME Code Class 1). The sample size decreases for the less critical supports (ASME Code Class 2 and 3).

This AMP emphasizes proper selection of bolting material, lubricants, and installation torque or tension to prevent or minimize loss of bolting preload of structural bolting and cracking of high-strength bolting. As noted below in the enhancement discussion, the AMP also includes preventive actions for storage of high-strength bolts. The requirements of ASME Code Section XI, Subsection IWF are supplemented to include volumetric examination of high-strength bolting for cracking.

This AMP will also include a one-time inspection beginningwithin 5 years beforeprior to the SPEO of an additional 5 percent of piping supports from the remaining IWF population that are considered most susceptible to age-related degradation.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 32 of 33 SLRA Section B.2.3.30, page B-234 is revised as follows:

Exceptions to NUREG-2191 The PSL ASME Section XI, Subsection IWF AMP includes the following exceptions to the NUREG-2191 guidance:

1. Inspection of supports for Class MC components under ASME Section XI, Subsection IWF is not required by 10 CFR 50.55a and PSL does not include such inspections in its IWF ISI program. (Note: There are no Class MC component supports at PSL.) This is an exception to the AMP described in Section XI.S3 of NUREG-2191, whose scope of program addresses Class MC supports. Inspection of the steel containment vessel and its integral attachments, including penetrations and fuel transfer tube components, is included in the scope of the PSL ASME Section XI, Subsection IWE (Section B.2.3.29) AMP. Structural supports other than ASME Class 1, 2, and 3 supports and in other areas of the plant outside containment are inspected under the PSL Structures Monitoring (Section B.2.3.33) AMP.

Therefore, PSL meets the intent of this NUREG-2191 program element.

2. Site documentation indicates that high-strength bolts (including bolts conforming to ASTM A490, Standard Specification for Structural Bolts, Alloy Steel, Heat Treated, 150 ksi Minimum Tensile Strength) are acceptable for use in structural applications at PSL. This is an exception to the AMP described in Section XI.S3 of NUREG-2191, which recommends using bolting material for structural applications that have an actual measured yield strength limited to less than 1,034 megapascals (MPa)(150 kilo-pounds per square inch) as a preventive measure that can reduce the potential for SSC.

Although current specifications allow for the use of A490 high-strength bolting, the original construction specifications required the use of ASTM A325 bolting. Structural field connections were specified to be friction type joints, assembled with 7/8-inch diameter high-strength bolts, unless otherwise noted on drawings. PSL performs visual inspection of high-strength bolting in accordance with ASTM A325 and ASTM A490. As discussed above, PSL prohibits the use of MoS2 and other sulfur containing lubricants as a preventive measure to reduce SCC of high-strength bolting.

The other preventive actions (use of appropriate lubricants, appropriate installation torque, and appropriate storage) in NUREG-2191 XI.S3 AMP that can reduce the potential cracking are implemented by the PSL ASME Section XI, Subsection IWF AMP. This AMP includes enhancements for identification of high-strength structural bolting and for additional actions to provide reasonable assurance that SCC is not occurring. The exception is acceptable because PSL meets all other program element requirements for structural bolting.

Enhancements The PSL ASME Section XI, Subsection IWF AMP will be enhanced as follows, for alignment with NUREG-2191. The one-time inspection will beginbe started no earlier than five years beforeprior to the SPEO. The enhancements will be implemented and one-time inspection completed no later than six months prior to entering the SPEO.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 7 Page 33 of 33 SLRA Section B.2.3.36, page B-261 is revised as follows:

B.2.3.36 Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program Description The PSL Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements AMP is an existing AMP, formerly a portion of the PSL Containment Cable Inspection Program. This AMP provides reasonable assurance that the intended functions of cable and connection electrical insulation exposed to adverse localized environments (ALEs) caused by heat, radiation, and moisture can be maintained consistent with the CLB through the SPEO.

This AMP applies to accessible non-EQ electrical cable and connection electrical insulation material within the scope of SLR subjected to adverse (e.g., excessive heat, radiation, and/or moisture) localized environment(s). ALEs are identified through the use of an integrated approach which includes, but is not limited to, a review of relevant site-specific and industry OE, a review of EQ zone maps, real-time infrared thermographic inspections, conversations with plant personnel cognizant of specific area and room environmental conditions, etc. To facilitate the identification of an ALE, a temperature threshold and a radiation threshold will be identified in the plant implementing procedure for cable and connection insulation materials within the scope of this program.

Accessible non-EQ insulated cables and connections within the scope of SLR installed in ALEs are visually inspected for cable and connection jacket surface anomalies such as embrittlement, discoloration, cracking, melting, swelling, or surface contamination. The inspection of accessible cable and connection insulation material is used to evaluate the adequacy of inaccessible cable and connection electrical insulation. If visual inspections identify cable jacket and connection insulation surface anomalies, then testing may be performed. A sample population of cable and connection insulation is utilized if testing is performed. The component sampling methodology includes a representative sample of in-scope non-EQ electrical cable and connection types regardless of whether or not the component was included in a previous aging management or maintenance program. The technical basis for the sample selections is documented.

The first inspection for SLR is to begin be completed no earlier than 10 years beforeprior to the SPEO and be completed no later than six months prior to entering the SPEO or no later than the last refueling outage prior to the SPEO. Recurring inspections are to be performed at least once every 10 years thereafter.

Site-specific OE will be evaluated to identify in-scope cable and connection insulation previously subjected to ALE during the initial PEO. Cable and connection insulation will be evaluated to confirm that the dispositioned corrective actions continue to support in-scope cable and connection intended functions during the SPEO.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 1 of 35 SLRA Section 4.6, Containment Liner Plate, Metal Containments, and Penetration Fatigue - Clarification Affected SLRA Sections: Table 2.4-1, 3.5.2.2.1.5, 3.5.2.2.1.6, Table 3.5-1, Table 3.5.2-1, 4.6, 19.3.5 (Appendices A1 and A2), Table 19-3 (Appendices A1 and A2), B.2.3.29 SLRA Page Numbers: 2.4-5, 3.5-24, 3.5-25, 3.5-51, 3.5-54, 3.5-56, 3.5-71 through 3.5-80, 3.5-86, 4.6-1, 4.6-3 through 4.6-4, A1-55 through A1-56, A2-56 through A2-57, A1-99 through A1-100, A2-100, B-228 through B-229 Description of Change:

PSL SLRA Table 3.5-1, Item Number 009 includes a discussion for cumulative fatigue damage to the containment vessel shell (metal containment). However, SLRA Table 3.5.2-1 does not include an equivalent AMR line item for Item Number 009. Accordingly, SLRA Table 3.5.2-1 is updated to include this AMR line item and to correct the title for table entries referencing TLAA Section 4.6 "Containment Liner Plate, Metal Containments, and Penetrations Fatigue".

SLRA Table 3.5-1, Item Number 009 includes a component type called containment vessel nozzle and mechanical penetration assemblies. SLRA Section 3.5.2.2.1.5, Table 3.5-1, Item Number 009, Table 3.5.2-1 and Section 4.6 are revised to identify the containment vessel components that are included in the CLB fatigue analyses. Also included in SLRA Section 4.6 is a description of the methodology utilized for each of the fatigue analyses.

SLRA Table 3.5-1, Item Number 027 is no longer consistent with the revision made to Item Number 009 discussed above and is not applicable to the PSL containment vessel design.

SLRA Table 3.5-1, Item Number 027 is revised accordingly.

The SLRA UFSAR supplement descriptions in Section 19.3.5 of Appendices A1 and A2 do not provide a summary description of the specific Code paragraph(s) used for the containment vessel fatigue waiver evaluations. Clarification is provided to SLRA Section 19.3.5 of Appendices A1 and A2 to provide this information. Similar clarification is also provided for SLRA Section 4.6.

SLRA Section 4.6 includes a TLAA evaluation subsection for fatigue of both the metal containments and the containment penetrations. Additional information is added to SLRA Section 4.6 to clarify which components of the mechanical penetration assemblies include a fatigue analysis and to clarify their design does not include any dissimilar metal welds. SLRA Tables 2.4-1, 3.5-1 Item Number 010, 3.5.2-1 and Sections 3.5.2.2.1.6 and 19.3.5 of Appendices A1 and A2 are also updated accordingly. As noted in Attachment 27 to this supplement, specific methods for detecting cracking due to SCC of penetration components are also added to the discussion in SLRA Section 3.5.2.2.1.6. Clarification of the thermal cycles and the operating basis earthquake (OBE) cycles the penetrations expansion bellows are projected to be exposed to for the SPEO is also provided in Section 4.6.

SLRA Table 3.5.2-1 contains plant specific note 3 regarding cracking due to SCC of penetration components. Additional review concludes note 3 is not applicable and should be deleted. SLRA Table 3.2.5-1 has been revised accordingly.

Additional changes to the SLRA have been made to further clarify that only the Unit 2

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 2 of 35 electrical penetrations include a dissimilar metal weld inside containment. These changes include SLRA Table 3.5-1, Item Number 035, Table 3.5.2-1, and Section B.2.3.29. Changes are also made to the enhancements associated with commitment 32 presented in SLRA Table 19-3 (both Appendices A1 and A2).

Section 3.8 of the Unit 2 UFSAR identifies a Type VI penetration for the containment vacuum breaker. This same penetration is included in the Unit 1 containment design. SLRA Section 4.6 is revised to include a description of the penetration and the applicable fatigues analysis utilized in its design.

Note that the markups for SLRA Section 3.5.2.2.1.6, Table 19-3 (Appendices A1 and A2), and Section B.2.3.29 include changes associated with Attachment 27 of this supplement. In addition, the markups for SLRA Table 3.5.2-1 include changes associated with Attachments 5, 6, and 20.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 3 of 35 SLRA Table 2.4-1, first mechanical penetration line item, page 2.4-5 is revised as follows:

Table 2.4-1 Containment Building Structure Components Subject to Aging Management Review Component Type Component Intended Function(s)

Penetrations bellows (mechanical), including bellows Fire barrier Pressure boundary Structural support SLRA Section 3.5.2.2.1.5, pages 3.5-24 and 3.5-25 are revised as follows:

The PSL Units 1 and 2 Containment Vessels are designed in accordance with the ASME Boiler and Pressure Vessel Code,Section III. For the current renewed licenses, the Containment Vessels compliance with these design requirements precludes cyclic fatigue cracking that may result in leakage.

However, compliance with leakage design criteria to ensure containment integrity is verified through periodic visual examination and testing in accordance with ASME Section XI, Subsection IWE, Inservice Inspection AMP and 10 CFR Part 50, Appendix J AMP.

The CLB for the PSL Units 1 and 2 containment vessels includes fatigue waiver evaluations that preclude the need for detailed fatigue analyses. The fatigue waiver evaluations are included in the containment vessel stress reports provided by the supplier. Components included in the stress reports include the steel containment vessels, containment vessel penetration nozzles, equipment hatches, and personnel air locks. Fatigue analyses of the mechanical penetration assembly stainless steel expansion bellows were performed by the original equipment supplier. Computation of the bellows cyclic life is included in Appendix 3G of the PSL Unit 1 UFSAR. Note that a previous engineering evaluation concluded this computation of the bellows cyclic life is applicable to the PSL Unit 2 mechanical penetrations. The fatigue analyses for the mechanical penetration process piping are described in SLRA Sections 4.3.1, Metal Fatigue of Class 1 Components and 4.3.2 Metal Fatigue of Non-Class 1 Components. Additional discussion of the fatigue analyses for these containment components is included in SLRA Section 4.6 Containment Liner Plate, Metal Containments and Penetrations Fatigue. The original PSL containment design analyses include a fatigue waiver for the Containment Vessels and fatigue analyses for the mechanical penetrations. However, there were no fatigue waivers or fatigue analyses for the equipment hatches, personnel hatches, and the electrical penetrations because these containment penetrations were not subject to cyclical loads. Therefore, there are no fatigue waivers or fatigue analyses for the equipment hatches, personnel hatches, and the electrical penetrations. However, cyclic loading evidenced as cracking for these non-piping penetrations at PSL will be managed for SLR by the enhanced ASME Section XI, Subsection IWE (B.2.3.29) AMP and 10 CFR Part 50, Appendix J (B.2.3.31) AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 4 of 35 Cumulative fatigue damage for the PSL mechanical penetrations was addressed for the current renewed licenses. It was demonstrated that, other than the safety injection penetrations which are ASME Class 1, penetration bellows at PSL Units 1 and 2 are specified to withstand a lifetime total of 7000 cycles of expansion and compression and that the Fatigue Monitoring (B.2.2.1) AMP (FMP) manages the safety injection penetrations and provides assurance that the other penetrations will not exceed the specified cycles, as summarized in UFSAR Sections 18.2.7 (Unit 1) and 18.3.4 (Unit 2).

For SLR, cumulative fatigue damage is also an aging effect requiring management for mechanical penetrations that is addressed in Section 4.6, Containment Liner Plate, Metal Containments and Penetrations Fatigue.

SLRA Section 3.5.2.2.1.6, page 3.5-25 is revised as follows:

3.5.2.2.1.6 Cracking Due to Stress Corrosion Cracking Stress corrosion cracking (SCC) of stainless steel (SS) penetration sleeves, penetration bellows, vent line bellows, suppression chamber shell (interior surface), and dissimilar metal welds could occur in PWR and/or BWR containments. The existing program relies on ASME Code Section XI, Subsection IWE and 10 CFR Part 50, Appendix J, to manage this aging effect. Further evaluation, including consideration of SCC susceptibility and applicable operating experience (OE) related to detection, is recommended of additional appropriate examinations/evaluations implemented to detect this aging effect for these SS components and dissimilar metal welds.

Stainless steel mechanical penetration expansion bellows and PSL Unit 2 electrical penetration dissimilar metal welds are exposed to an uncontrolled indoor air environment at PSL. A review of PSL OE confirms halides are potentially present in the indoor environments at PSL.

Additionally, these indoor components, particularly those in standby or periodically operated systems, could conservatively see an accumulation of contaminants. As such, the stainless steel mechanical penetration expansion bellows and PSL Unit 2 electrical penetration dissimilar metal welds exposed to uncontrolled indoor air in the containment buildings are susceptible to SCC and require management via an appropriate program.

Consistent with the recommendation of NUREG-2191, cracking of these components will be managed by the ASME Section XI, Subsection IWE (B.2.3.29) AMP and 10 CFR Part 50, Appendix J (B.2.3.31) AMP. The ASME Section XI, Subsection IWE AMP provides for the management of aging effects through surface examinations (magnetic particle, dye penetrant) or enhanced visual examinations (EVT-1 or equivalent), performed by qualified personnel using methods capable of detecting cracking. Any visual evidence of cracking will be evaluated for acceptability and additional surface examinations or enhanced visual examinations, if required, will be conducted in accordance with the sites corrective action process. The 10 CFR Part 50, Appendix J AMP is a performance monitoring program that monitors the leakage rates through the containment system,

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 5 of 35 its vessel, associated welds, penetrations, isolation valves, fittings, and other access openings to detect degradation of the containment pressure boundary. Adverse conditions will be documented in accordance with the 10 CFR Part 50, Appendix B Corrective Action Program.

Cracking due to SCC was also addressed as part of the current renewed licenses and determined not to require management for containment steel in air structural components. Typical details for containment piping and fuel transfer penetrations are provided in the Unit 1 UFSAR [Figure 3.8-9] and Unit 2 UFSAR

[Figure 3.8-7]. These penetration assemblies (e.g., sleeves, flued heads, or caps), are carbon steel or SS depending on the system. The fuel transfer penetration is SS. The fuel transfer penetration includes (primary) bellows that function as barriers against leakage of refueling water from either the fuel transfer canal inside the fuel handling building or refueling cavity inside containment. Other penetration assemblies include secondary bellows.

Stainless steel penetrations may involve dissimilar metal welds (DMWs) to the carbon steel vessel nozzle, penetration sleeve. Carbon steel is not susceptible to SCC.

The containment air temperature during normal plant operation is less than or equal to 120°F and localized temperatures at penetrations are less than 150°F by design. High temperature (Type I) penetration nozzles, bellows, and sleeves are carbon steel. Stainless steel penetrations, and any DMWs, associated with systems that are exposed to temperatures >140°F during normal operation may be susceptible to SCC. Penetrations with SS process lines that see temperatures > 140°F include those for:

  • Letdown (#26),
  • Hot Leg Sampling (#28),
  • Safety injection (#36, #37, #38, #39, and #41), and

Conservatively, the SS fuel transfer tube penetration (#25) components are also susceptible to cracking due to SCC. The Containment Vessel nozzles for the above penetrations are carbon steel. As such, the penetrations are considered to include DMWs. Therefore, cracking of SS penetration components, and any DMWs, for nine (9) penetrations per Unit will be managed by the ASME Section XI, Subsection IWE (B.2.3.29) AMP, which includes enhancement for surface, or enhanced visual, examination to detect evidence of cracking in a representative sample of the penetrations.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 6 of 35 SLRA Table 3.5-1, page 3.5-51 is revised as follows:

Table 3.5-1: Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Item Aging Aging Management Further Evaluation Component Discussion Number Effect/Mechanism Program / TLAA Recommended 3.5-1, 009 Metal liner, metal Cumulative fatigue TLAA, SRP-SLR Yes (SRP-SLR Consistent with NUREG-2191.

plate, personnel damage due to "Containment Liner Section 3.5.2.2.1.5) The CLB for the PSL Units 1 and 2 airlock, equipment cyclic loading (Only Plate, Metal containment vessels includes fatigue hatch, control rod if CLB fatigue Containments, and waiver evaluations that preclude the need drive (CRD) hatch, analysis exists)due Penetrations Fatigue for detailed fatigue analyses. The fatigue penetration to fatigue Analysis" waiver evaluations are included in the sleeves; containment vessel stress reports penetration provided by the supplier. Components bellows, steel included in the stress reports include the elements: torus; steel containment vessels, containment vent line; vent vessel penetration nozzles, equipment header; vent line hatches, and personnel air locks.

bellows; Fatigue analyses of the mechanical downcomers, penetration assembly stainless steel suppression pool expansion bellows were performed by the shell; unbraced original equipment supplier.

downcomers, steel The fatigue analyses for the mechanical elements: vent penetration process piping are described header; in SLRA Sections 4.3.1 and 4.3.2.

downcomers Additional discussion of the fatigue analyses for these containment components is included in SLRA Section 4.6 Containment Liner Plate, Metal Containments and Penetrations Fatigue.

for containment vessel, containment vessel nozzle and mechanical penetration assemblies and fuel transfer tube assemblies.

Cyclic loading of Airlocks, Hatches and Electrical Penetration assemblies are addressed for item number 3.5-1, 027.

Further evaluation is documented in Section 3.5.2.2.1.5.

In addition, cracking due to SCC of high and moderate temperature mechanical penetration assemblies that are stainless steel or include

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 7 of 35 Table 3.5-1: Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Item Aging Aging Management Further Evaluation Component Discussion Number Effect/Mechanism Program / TLAA Recommended dissimilar metal welds is addressed for item number 3.5-1, 010.

3.5-1, 010 Penetration Cracking due to SCC AMP XI.S1, ASME Yes (SRP-SLR Consistent with NUREG-2191.

Sleeves Section XI, Subsection Section 3.5.2.2.1.6) The ASME Section XI, Subsection IWE Penetration bellows IWE, and AMP XI.S4, (B.2.3.29) AMP and 10 CFR Part 50, 10 CFR Part 50, Appendix J (B.2.3.31) AMP manage cracking Appendix J of Type III (semi-hot) stainless steel and dissimilar metal weld stainless steel mechanical penetration expansion bellowsassemblies and PSL Unit 2 electrical penetration dissimilar metal welds exposed to an uncontrolled indoor air environment.

Further evaluation is documented in Section 3.5.2.2.1.6.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 8 of 35 SLRA Table 3.5-1, page 3.5-54 is revised as follows:

Table 3.5-1: Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Item Aging Aging Management Further Evaluation Component Discussion Number Effect/Mechanism Program / TLAA Recommended 3.5-1, 027 Metal liner, metal Cracking due to AMP XI.S1, "ASME Yes (SRP-SLR Not applicable.

plate, airlock, cyclic loading (CLB Section XI, Section 3.5.2.2.1.5) CLB fatigue analyses exist for PSL equipment hatch, fatigue analysis does Subsection IWE," and containment components susceptible to CRD hatch; not exist) AMP XI.S4, cracking due to cyclic loading and are penetration "10 CFR Part 50, addressed with item number 3.5-1, 009 sleeves; Appendix J" above.

penetration Consistent with NUREG-2191.

bellows, steel A fatigue analysis was not performed for the elements: torus; Containment Vessel and a fatigue waiver vent line; vent could not be located for airlock, hatch and header; vent line electrical penetration assemblies.

bellows; As such, the ASME Section XI, Subsection downcomers, IWE (B.2.3.29) AMP and 10 CFR Part 50, suppression pool Appendix J (B.2.3.31) AMP manage cyclic shell loading of air lock, hatch, and electrical penetration assemblies and accessories, exposed to uncontrolled indoor air.

Further evaluation is documented in Section 3.5.2.2.1.5.

Mechanical penetration assemblies, including piping, ventilation and fuel transfer tube, are addressed with item numbers 3.5-1, 009 and 3.5-1, 010 above.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 9 of 35 SLRA Table 3.5-1, page 3.5-56 is revised as follows:

Table 3.5-1: Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Item Aging Aging Management Further Evaluation Component Discussion Number Effect/Mechanism Program / TLAA Recommended 3.5-1, 035 Steel elements Loss of material due AMP XI.S1, ASME Yes (SRP-SLR Consistent with NUREG-2191.

(accessible areas): to general, pitting, Section XI, Section 3.5.2.2.1.3) The ASME Section XI, Subsection IWE liner; liner anchors; crevice corrosion Subsection IWE, and (B.2.3.29) AMP and 10 CFR Part 50, integral AMP XI.S4, Appendix J (B.2.3.31) AMP manage loss of attachments, 10 CFR Part 50, material of accessible areas of the steel penetration Appendix J Containment Vessel steel and or PSL Unit 2 sleeves, drywell electrical penetration dissimilar metal welds shell; drywell head; and penetration components exposed to drywell shell in uncontrolled indoor air.

sand pocket Further evaluation is documented in regions; Section 3.5.2.2.1.3.

suppression chamber; drywell; embedded shell; region shielded by diaphragm floor (as applicable)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 10 of 35 SLRA Table 3.5.2-1, page 3.5-71 is revised as follows:

Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Air locks, maintenance Fire barrier Steel Air - outdoor Cracking 10 CFR Part 50, II.A3.CP-37 3.5-1, A, 1, 11 hatch and accessories Pressure Cumulative Appendix J (B.2.3.31) II.A3.C-13 027009 boundary fatigue ASME Section XI, damage Subsection IWE (B.2.3.29)

TLAA - Section 4.6, "Containment Liner Plate, Metal Containments, and Penetrations Fatigue" Air locks, maintenance Fire barrier Steel Air - outdoor Loss of leak 10 CFR Part 50, II.A3.CP-39 3.5-1, A, 11 hatch and accessories Pressure tightness Appendix J (B.2.3.31) 029 boundary ASME Section XI, Subsection IWE (B.2.3.29)

Air locks, maintenance Fire barrier Steel Air - outdoor Loss of 10 CFR Part 50, II.A3.C-16 3.5-1, A, 11 hatch and accessories Pressure material Appendix J (B.2.3.31) 028 boundary ASME Section XI, Subsection IWE (B.2.3.29)

Air locks, maintenance Fire barrier Steel Air - indoor Cracking 10 CFR Part 50, II.A3.CP-37 3.5-1, A, 1, 11 hatch and accessories Pressure uncontrolled Cumulative Appendix J (B.2.3.31) II.A3.C-13 027009 boundary fatigue ASME Section XI, damage Subsection IWE (B.2.3.29)

TLAA - Section 4.6, "Containment Liner Plate, Metal Containments, and Penetrations Fatigue"

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 11 of 35 Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Air locks, maintenance Fire barrier Steel Air - indoor Loss of leak 10 CFR Part 50, II.A3.CP-39 3.5-1, A, 11 hatch and accessories Pressure uncontrolled tightness Appendix J (B.2.3.31) 029 boundary ASME Section XI, Subsection IWE (B.2.3.29)

Air locks, maintenance Fire barrier Steel Air - indoor Loss of 10 CFR Part 50, II.A3.C-16 3.5-1, A, 11 hatch and accessories Pressure uncontrolled material Appendix J (B.2.3.31) 028 boundary ASME Section XI, Subsection IWE (B.2.3.29)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 12 of 35 SLRA Table 3.5.2-1, page 3.5-72 is revised as follows:

Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Air locks, maintenance Fire barrier Steel Air with borated Loss of Boric Acid Corrosion III.B1.1.T-25 3.5-1, C, 11 hatch and accessories Pressure water leakage material (B.2.3.4) 089 boundary Construction hatch and Fire barrier Steel Air - indoor Cracking 10 CFR Part 50, II.A3.CP-37 3.5-1, A, 1, 11 cover Pressure uncontrolled Cumulative Appendix J (B.2.3.31) II.A3.C-13 027009 boundary fatigue ASME Section XI, damage Subsection IWE (B.2.3.29)

TLAA - Section 4.6, "Containment Liner Plate, Metal Containments, and Penetrations Fatigue" Construction hatch and Fire barrier Steel Air - indoor Loss of 10 CFR Part 50, II.A3.C-16 3.5-1, A, 11 cover Pressure uncontrolled material Appendix J (B.2.3.31) 028 boundary ASME Section XI, Subsection IWE (B.2.3.29)

Construction hatch and Fire barrier Steel Air with borated Loss of Boric Acid Corrosion III.B1.1.T-25 3.5-1, C, 11 cover Pressure water leakage material (B.2.3.4) 089 boundary

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 13 of 35 SLRA Table 3.5.2-1, page 3.5-73 is revised as follows:

Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Containment vessel Pressure Steel Air - indoor Cracking 10 CFR Part 50, II.A3.CP-37 3.5-1, A, 2 (accessible) boundary uncontrolled Cumulative Appendix J (B.2.3.31) II.A3.C-13 027009 Structural fatigue ASME Section XI, support damage Subsection IWE (B.2.3.29)

TLAA - Section 4.6, "Containment Liner Plate, Metal Containments, and Penetrations Fatigue" Containment Fire barrier Steel Air - indoor Cracking 10 CFR Part 50, II.A3.CP-37 3.5-1, A, 1, 11 vessel nozzle Pressure uncontrolled Cumulative Appendix J (B.2.3.31) II.A3.C-13 027009 (electrical) boundary fatigue ASME Section XI, Structural damage Subsection IWE support (B.2.3.29)

TLAA - Section 4.6, "Containment Liner Plate, Metal Containments, and Penetrations Fatigue" Containment vessel Fire barrier Steel Air - indoor Loss of 10 CFR Part 50, II.A3.C-16 3.5-1, A, 11 nozzle (electrical) Pressure uncontrolled material Appendix J (B.2.3.31) 028 boundary ASME Section XI, Structural Subsection IWE support (B.2.3.29)

Containment vessel Fire barrier Steel Air with borated Loss of Boric Acid Corrosion III.B1.1.T-25 3.5-1, C, 11 nozzle (electrical) Pressure water leakage material (B.2.3.4) 089 boundary Structural support

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 14 of 35 SLRA Table 3.5.2-1, page 3.5-74 is revised as follows:

Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Containment vessel Fire barrier Steel Air - indoor Loss of 10 CFR Part 50, II.A3.C-16 3.5-1, A, 11 nozzle (fuel Pressure uncontrolled material Appendix J (B.2.3.31) 028 transfer) boundary ASME Section XI, Structural support Subsection IWE (B.2.3.29)

Containment vessel Fire barrier Steel Air with borated Loss of Boric Acid Corrosion III.B1.1.T-25 3.5-1, C, 11 nozzle (fuel Pressure water leakage material (B.2.3.4) 089 transfer) boundary Structural support Containment vessel Fire barrier Steel Air - indoor Cumulative TLAA - Section 4.6, II.A3.C-13 3.5-1, A, 11 nozzle (fuel Pressure uncontrolled fatigue "Containment Liner 009 transfer) boundary damage Plate, Metal Structural support Containments, and Penetrations Fatigue" Containment vessel Fire barrier Nickel alloy Air - indoor Loss of 10 CFR Part 50, II.A3.C-16 3.5-1, A, 11 nozzle Pressure uncontrolled material Appendix J (B.2.3.31) 028 (mechanical) boundary ASME Section XI, Structural support Subsection IWE (B.2.3.29)

Containment vessel Fire barrier Steel Air - indoor Loss of 10 CFR Part 50, II.A3.C-16 3.5-1, A, 11 nozzle Pressure uncontrolled material Appendix J (B.2.3.31) 028 (mechanical) boundary ASME Section XI, Structural support Subsection IWE (B.2.3.29)

Containment vessel Fire barrier Steel Air with borated Loss of Boric Acid Corrosion III.B1.1.T-25 3.5-1, C, 11 nozzle Pressure water leakage material (B.2.3.4) 089 (mechanical) boundary Structural support Containment vessel Fire barrier Nickel alloy Air - indoor Cumulative TLAA - Section 4.6, II.A3.C-13 3.5-1, A, 11 nozzle Pressure uncontrolled fatigue "Containment Liner 009 (mechanical) boundary damage Plate, Metal Structural support Containments, and Penetrations Fatigue"

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 15 of 35 SLRA Table 3.5.2-1, page 3.5-75 is revised as follows:

Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Containment vessel Fire barrier Steel Air - indoor Cumulative TLAA - Section 4.6, II.A3.C-13 3.5-1, A, 11 nozzle (mechanical) Pressure uncontrolled fatigue "Containment Liner 009 boundary damage Plate, Metal Structural Containments, and support Penetrations Fatigue" Fuel transfer Fire barrier Dissimilar Air - indoor Cracking 10 CFR Part 50, II.A3.CP-38 3.5-1, A, 11 penetration sleeve Pressure metal welds uncontrolled Appendix J (B.2.3.31) 010 boundary ASME Section XI, Structural Subsection IWE support (B.2.3.29)

Fuel transfer Fire barrier Dissimilar Air - indoor Loss of 10 CFR Part 50, II.A3.CP-36 3.5-1, A, 11 penetration sleeve Pressure metal welds uncontrolled material Appendix J (B.2.3.31) 035 boundary ASME Section XI, Structural Subsection IWE support (B.2.3.29)

Fuel transfer Fire barrier Steel Air - indoor Loss of 10 CFR Part 50, II.A3.C-16 3.5-1, A, 11 penetration sleeve Pressure uncontrolled material Appendix J (B.2.3.31) 028 boundary ASME Section XI, Structural Subsection IWE support (B.2.3.29)

Fuel transfer Fire barrier Steel Air with borated Loss of Boric Acid Corrosion III.B1.1.T-25 3.5-1, C, 11 penetration sleeve Pressure water leakage material (B.2.3.4) 089 boundary Structural support Fuel transfer Fire barrier Steel Air - indoor Cumulative TLAA - Section 4.6, II.A3.C-13 3.5-1, A, 11 penetration sleeve Pressure uncontrolled fatigue "Containment 009 boundary damage Penetrations Fatigue" Structural support

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 16 of 35 SLRA Table 3.5.2-1, page 3.5-76 is revised as follows:

Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Fuel transfer tube, Fire barrier Stainless steel Air - indoor Cracking 10 CFR Part 50, II.A3.CP-38 3.5-1, A, 11 expansion bellows, and Pressure uncontrolled Appendix J (B.2.3.31) 010 flange boundary ASME Section XI, Structural Subsection IWE support (B.2.3.29)

Fuel transfer tube, Fire barrier Stainless steel Treated borated Loss of One-Time Inspection VII.A2.AP-79 3.3-1, D, 11 expansion bellows, and Pressure water material (B.2.3.20) 125 flange boundary Water Chemistry Structural (B.2.3.2) support Fuel transfer tube, Fire barrier Stainless steel Air - indoor Cumulative TLAA - Section 4.6, II.A3.C-13 3.5-1, A, 11 expansion bellows, and Pressure uncontrolled fatigue "Containment Liner 009 flange boundary damage Plate, Metal Structural Containments, and support Penetrations Fatigue" SLRA Table 3.5.2-1, page 3.5-77 is revised as follows:

Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Interior beams, fill, Missile Concrete Air - indoor Cracking Structures Monitoring III.A1.TP-204 3.5-1, B, 3 shields, slabs, and walls barrier (reinforced) uncontrolled (B.2.3.33) 043 (inaccessible) Shelter, protection Structural support

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 17 of 35 SLRA Table 3.5.2-1, page 3.5-78 is revised as follows:

Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Miscellaneous steel Fire barrier Steel Air - indoor Loss of Structures Monitoring III.A1.TP-302 3.5-1, B, 11 (missile barriers, hatch Missile uncontrolled material (B.2.3.33) 077 frame covers, framing barrier for radiant energy Shelter, shields, etc.) protection Structural support Penetrations (electrical), Fire barrier Steel Air - indoor Cracking 10 CFR Part 50, II.A3.CP-37 3.5-1, A, 1, 11 Unit 1 Pressure uncontrolled Appendix J (B.2.3.31) 027 boundary ASME Section XI, Structural Subsection IWE support (B.2.3.29)

Penetrations (electrical), Fire barrier Steel Air - indoor Loss of 10 CFR Part 50, II.A3.C-16 3.5-1, A, 11 Unit 1 Pressure uncontrolled material Appendix J (B.2.3.31) 028 boundary ASME Section XI, Structural Subsection IWE support (B.2.3.29)

Penetrations (electrical), Fire barrier Steel Air with borated Loss of Boric Acid Corrosion III.B1.1.T-25 3.5-1, C, 11 Unit 1 Pressure water leakage material (B.2.3.4) 089 boundary Structural support Penetrations (electrical), Fire barrier Dissimilar Air - indoor Cracking 10 CFR Part 50, II.A3.CP-37 3.5-1, A, 1, 11 Unit 2 Pressure metal welds uncontrolled Appendix J (B.2.3.31) II.B4.CP-38 027010 boundary ASME Section XI, Structural Subsection IWE support (B.2.3.29)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 18 of 35 SLRA Table 3.5.2-1, page 3.5-79 is revised as follows:

Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Aging Intended NUREG-2191 Table 1 Component Type Material Environment Requiring Management Notes Function Item Item Management Program Penetrations Fire barrier Dissimilar Air - indoor Loss of material 10 CFR Part 50, II.A3.CP-36 3.5-1, A, 11 (electrical), Unit 2 Pressure metal welds uncontrolled Appendix J 035 boundary (B.2.3.31)

Structural ASME Section XI, support Subsection IWE (B.2.3.29)

Penetrations Fire barrier Stainless Air - indoor Cracking 10 CFR Part 50, II.A3.CP-37 3.5-1, A, 1, 11 (electrical), Unit 2 Pressure steel uncontrolled Appendix J 027 boundary (B.2.3.31)

Structural ASME Section XI, support Subsection IWE (B.2.3.29)

Penetrations Fire barrier Dissimilar Air - indoor Cracking 10 CFR Part 50, II.A3.CP-38 3.5-1, A, 4, 11 (mechanical), Pressure metal welds uncontrolled Appendix J 010 including bellows boundary (B.2.3.31)

Structural ASME Section XI, support Subsection IWE (B.2.3.29)

Penetrations Structural Dissimilar Air - indoor Loss of material 10 CFR Part 50, II.A3.CP-36 3.5-1, A, 11 (mechanical), support metal welds uncontrolled Appendix J 035 including bellows Pressure (B.2.3.31) boundary ASME Section XI, Subsection IWE (B.2.3.29)

Penetrations Fire barrier Stainless Air - indoor Cracking 10 CFR Part 50, II.A3.CP-38 3.5-1, A, 4, 11 bellows Pressure steel uncontrolled Appendix J 010 (mechanical), boundary (B.2.3.31) including bellows Structural ASME Section XI, support Subsection IWE (B.2.3.29)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 19 of 35 Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Aging Intended NUREG-2191 Table 1 Component Type Material Environment Requiring Management Notes Function Item Item Management Program Penetrations Fire barrier Steel Air - indoor Loss of material 10 CFR Part 50, II.A3.CP-36 3.5-1, A, 11 (mechanical), Pressure uncontrolled Appendix J 035 including bellows boundary (B.2.3.31)

Structural ASME Section XI, support Subsection IWE (B.2.3.29)

Penetrations Fire barrier Steel Air with borated water Loss of material Boric Acid III.B1.1.T-25 3.5-1, C, 11 (mechanical), Pressure leakage Corrosion (B.2.3.4) 089 including bellows boundary Structural support

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 20 of 35 SLRA Table 3.5.2-1, page 3.5-80 is revised as follows:

Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Penetrations Fire barrier Dissimilar Air - indoor Cumulative TLAA - Section 4.6, II.A3.C-13 3.5-1, A, 11 (mechanical), including Pressure metal welds uncontrolled fatigue "Containment Liner 009 bellows boundary damage Plate, Metal Structural Containments, and support Penetrations Fatigue" Penetrations bellows Fire barrier Stainless steel Air - indoor Cumulative TLAA - Section 4.6, II.A3.C-13 3.5-1, A, 11 (mechanical), including Pressure uncontrolled fatigue "Containment Liner 009 bellows boundary damage Plate, Metal Structural Containments, and support Penetrations Fatigue" Penetrations Fire barrier Steel Air - indoor Cumulative TLAA - Section 4.6, II.A3.C-13 3.5-1, A, 11 (mechanical), including Pressure uncontrolled fatigue "Containment Liner 009 bellows boundary damage Plate, Metal Structural Containments, and support Penetrations Fatigue" Penetrations Insulate Calcium Air - indoor None None VIII.H.S-403 3.4-1, I, 5 (mechanical), thermal (thermal) silicate uncontrolled 064 insulation (type I hot penetrations)

Penetrations Insulate Calcium Air - indoor None None V.E.E-422 3.2-1, I, 13 (mechanical), thermal (thermal) silicate uncontrolled 087 insulation (type III semi-hot penetrations)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 21 of 35 SLRA Table 3.5.2-1, page 3.5-86 is revised as follows:

General Notes E. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

F. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

G. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

H. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

E. Consistent with NUREG-2191 material, environment, and aging effect but a different AMP is credited or NUREG-2191 identifies a plant-specific AMP.

F. Material not in NUREG-2191 for this component.

J. Aging effect not in NUREG-2191 for this component, material, and environment combination.

K. Aging effect in NUREG-2191 for this component, material and environment combination is not applicable.

Plant Specific Notes

1. Consistent with SLR-ISG-2021-03-STRUCTURES, Appendix A, Containment components with no fatigue analysis or waiver are susceptible to cracking due to cyclic loading.Deleted
2. Manway at the top of the Containment Vessel is a permanently sealed (welded) shut part of the Containment Vessel.
3. Consistent with SLR-ISG-2021-03-STRUCTURES, the Structures Monitoring (B.2.3.33) AMP manages loss of material for stainless steel exposed to air, instead of plant-specific program, whereas cracking due to SCC of the same penetration components is managed by 10 CFR Part 50, Appendix J and ASME Section XI Subsection IWE AMPs.Deleted
4. Eight Type III (semi-hot) penetration assemblies per unit and, conservatively, both units fuel transfer tubes are stainless steel or dissimilar metal weld and exposed to process temperatures > 140°F during normal plant operation and, therefore, susceptible to stress corrosion.Deleted
5. Insulation for main steam and feedwater penetrations isare fully encased in the multiple flued head and guard pipes and there are no plausible moisture, contaminants, or exposures that could degrade the (calcium silicate) insulation.
6. The Sstainless steel fuel transfer tube and flange penetration assemblies include stainless steel pressure-retaining bolting that is managed by the ASME Section XI, Subsection IWE AMP.
7. Irradiation of the concrete primary shield wall is addressed in Section 3.5.2.2.2.6 and is managed by the Structures Monitoring (B.2.3.33) AMP.
8. The loss of fracture toughness aging effect due to irradiation embrittlement of the steel reactor vessel supports and bolting is addressed in Section 3.5.2.2.2.7 and is managed by the ASME Section XI, Subsection IWF (B.2.3.30) AMP.
9. Consistent with SLR-ISG-2021-03-STRUCTURES, the Structures Monitoring AMP manages cracking of concrete due to reaction with aggregates.
10. Bottom portion and bottom head of the Containment Vessel are completely encased in concrete fill inside the (Group 1) Shield Building. The operating floor inside the Containment Vessel is this concrete fill.
11. Component also provides a fire barrier function as evaluated in the Fire Protection Program Design Document that is physically equivalent to the structural functions managed under the associated Containment structural programs or other applicable AMPs.
12. Evidence of cracking due to SCC and loss of material due to pitting and crevice corrosion (i.e., leakage) would be readily detected during refueling operations prior to loss of intended function for these components.
13. Insulation for Type III penetrations is fully encased in the multiple flued head and guard pipes and there are no plausible moisture, contaminants, or exposures that could degrade the (calcium silicate) insulation.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 22 of 35 SLRA Section 4.6, page 4.6-1 is revised as follows:

4.6 CONTAINMENT LINER PLATE, METAL CONTAINMENTS AND PENETRATIONS FATIGUE Metal Containment Fatigue TLAA Description As stated in Sections 3.8.2.1.5 and 3.8.2.6.1 of the PSL Unit 1 and 2 UFSARs, respectively, the containment vessels are fabricated from welded ASME-SA 516 Grade 70 steel plates to provide an essentially leak-tight barrier. Design criteria applied to the steel containment vessels assure that the specified leak rate is not exceeded under the design basis accident conditions. The PSL Unit 1 containment vessel is designed in accordance with the 1968 Edition of ASME Boiler and Pressure Vessel Code,Section III (Reference 4.8.20) and the PSL Unit 2 containment vessel is designed in accordance with the 1971 Edition of ASME Boiler and Pressure Vessel Code,Section III (Reference 4.8.21). The CLB for the PSL Unit 1 and 2 containment vessels includes fatigue waiver evaluations that preclude the need for a detailed fatigue analysis. The fatigue waiver evaluation includes the steel containments vessel shells, containment penetration nozzles, personnel air locks, and equipment hatches. The PSL Unit 1 fatigue waiver was performed in accordance with Article 4 of the 1968 Edition of ASME Section III, Nuclear Vessels, Section N-415, Analysis for Cyclic Operation. The fatigue waiver for PSL Unit 2 was performed in accordance with the 1971 Edition of ASME Section III, Nuclear Vessels, Section NB-3222.4, Analysis for Cyclic Operation. Fatigue waivers that consider transient cycles which occur over the life of the plant constitute TLAAs.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 23 of 35 SLRA Section 4.6, pages 4.6-3 and 4.6-4 are revised as follows:

Penetrations Fatigue TLAA Description The PSL containment penetration design includes the following components that utilize different fatigue analysis methods:

1. The containment vessel nozzles are included as part of the containment vessel design. Each containment penetration includes a nozzle welded to the containment vessel. The fatigue analysis for the containment vessel nozzles is included in the fatigue waiver evaluations discussed above for the steel containment vessels.
2. The mechanical penetration assembly design includes a process pipe, a shield building penetration sleeve and an expansion bellows. In the case of hot and semi-hot penetrations, a multiple fluid head is provided as an integral part of the process pipe. The only mechanical penetration assembly components that include a fatigue analysis are the penetration expansion bellows and the process piping. A fatigue analysis of the stainless steel expansion bellows was performed by the original equipment supplier.

Computation of the bellows cyclic life is included in Appendix 3G of the PSL Unit 1 UFSAR. Note that a previous engineering evaluation concluded this computation of the bellows cyclic life is applicable to the PSL Unit 2 mechanical penetrations.

The process piping for the majority of the PSL Unit 1 piping penetrations is designed in accordance with ANSI B31.7 Class 2 requirements and the process piping for all PSL Unit 2 piping penetrations is designed in accordance with ASME Section III Class 2 requirements. The evaluation of the implicit fatigue TLAA for this process piping is included in SLRA Section 4.3.2, Metal Fatigue of Non-Class 1 Components. The exception to the design requirements above are the four PSL Unit 1 safety injection piping penetrations which are designed in accordance with ANSI B31. 7 Class 1 requirements. The evaluation of the explicit fatigue TLAA for this process piping is included in SLRA Section 4.3.1, Metal Fatigue of Class 1 Components.

Other than the containment vessel nozzles described above, the design of the electrical penetrations does not include a fatigue analysis.

In accordance with the original PSL containment mechanical penetration assembly specificationsSection 4.5.2 of NUREG-1779, each of the PSL Unit 1 and 2 containment penetrations types specified below include a stainless steel expansion bellows. The expansion bellows are designedspecified to withstand a lifetime total of 7,000 cycles of expansion and compression due to maximum operating thermal expansion, and 200 cycles each of other movements (seismic motion and differential settlement). Note that the 200 seismic motions assumed in the penetration fatigue analysis represent five

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 24 of 35 (5) operational basis earthquake (OBE) events over the life of the units with 40 cycles each.

The PSL Unit 1 and 2 containment mechanical penetrations are categorized as follows:

  • Type I - those which must accommodate considerable thermal movements (hot penetrations)
  • Type II - those which are not required to accommodate thermal movements (low temperature penetrations)
  • Type III - those which must accommodate moderate thermal movements (semi-hot penetrations)
  • Type IV - containment sump recirculation suction lines
  • Type V - fuel transfer tubes Section 3.8 of the PSL Unit 2 UFSAR identifies a Type VI penetration for the containment vacuum breaker. This same penetration is included in the PSL Unit 1 containment design. This penetration was not included in the mechanical penetration assembly specifications discussed above because the penetration does not include process piping or an expansion bellows. As discussed in PSL Unit 2 UFSAR Section 3.8.2.1.1.1.f, the penetration consists of a containment vessel nozzle with a check valve installed on the end of the nozzle inside the containment and a butterfly valve installed directly to nozzle on the outside of the steel containment vessel. Since the penetration does not include an expansion bellows, the only applicable fatigue analysis for the penetration is the containment nozzle which is included in the fatigue waiver evaluations for the containment vessel.

Therefore, the fatigue analyses for stainless steel expansion bellows for the Type I, II, III, IV, and V mechanical penetrations Each of the above items require evaluation for the 80-year SPEO.

TLAA Evaluation Type I and Type III Penetrations The thermal fatigue design limits of the Type I and Type III containment penetration bellows (7,000 expansion and contraction thermal cycles) are bounded by the thermal fatigue design limits of their associated piping systems. Type I hot penetrations are used for the main steam line and the main feedwater piping. Type III semi-hot penetrations are used for the following piping systems:

  • Chemical and volume control system (charging and letdown)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 25 of 35

  • Safety injection (including shutdown cooling and the safety injection tank test line)

The piping systems associated with Type I and Type III penetration bellows have been evaluated in Sections 4.3.1 and 4.3.2. SLRA Table 4.3.2-2 evaluated each of the above piping systems and concludes that the 7,000 thermal cycles limit will not be exceeded for 80 years of operation. Therefore, the stainless steel expansion bellows associated with these hot and semi-hot penetrations will not experience thermal cycles exceeding their thermal design cycle limit and found are determined to be acceptable for the SPEO.

The 200 cycles of assumed for both differential settlement and OBE seismic motion are also bounding for the SPEO since they are not susceptible to any significant differential settlement they have not been subjected to any seismic loading to date. Differential settlement between the steel containment vessel and the concrete shield building is unlikely through the SPEO as the bottom of the steel containment vessel is integral to concrete shield building basemat. 80-year projected cycles for OBE seismic motion are included in SLRA Tables 4.3.1-5 and 4.3.1-6 and are less than to 200 design cycle limit.

Type II, Type IV, and Type V Penetrations Type II penetrations are low temperature penetrations, Type IV penetrations are low temperature penetrations that are only used in post-accident scenarios, and Type V penetrations are the Unit 1 and 2 fuel transfer tubes. As such, these penetrations are not exposed to large thermal loads or thermal movements; however, these penetrations were conservatively designed for 7,000 cycles of expansion and compression due to operating thermal expansion and 200 cycles each of differential settlement and seismic motion.

Consistent with the evaluation above for Type I and III penetrations, The the 7,000 thermal cycles and 200 cycles each forof differential settlement and OBE seismic motion for Type II, Type IV, and Type V penetrations are bounding for the SPEO.

TLAA Disposition: 10 CFR 54.21(c)(1)(i)

The existing fatigue analyses for the PSL Unit 1 and 2 containment piping mechanical penetrations stainless steel expansion bellows have been evaluated and determined to remain valid for the SPEO, in accordance with 10 CFR 54.21(c)(1)(i).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 26 of 35 SLRA Section A-1, pages A1-55 through A1-56 are revised as follows:

19.3.5 Containment Liner Plate, Metal Containments, and Penetrations Fatigue Metal Containment Fatigue The PSL Unit 1 containment vessel is fabricated from welded ASME-SA 516 Grade 70 steel plates to provide an essentially leak-tight barrier. Design criteria applied to the steel containment vessels assure that the specified leak rate is not exceeded under the design basis accident conditions. The PSL Unit 1 containment vessel is designed in accordance with the 1968 Edition of ASME Boiler and Pressure Vessel Code,Section III. The CLB for the PSL Unit 1 containment vessel includes a fatigue waiver evaluation performed in accordance with Article 4 of the 1968 Edition of ASME Section III, Nuclear Vessels, Section N-415, Analysis for Cyclic Operation that precludes the need for a detailed fatigue analysis. The fatigue waiver evaluation includes the steel containments vessel shells, containment penetration nozzles, personnel air locks, and equipment hatches.

A common evaluation of the PSL Units 1 and 2 containment vessel fatigue waivers was performed for SLR and concluded that the fatigue waivers remain valid through the 80-year SPEO since the service loading of the vessels met all the following six fatigue waiver conditions of the applicable ASME Codes:

1) Atmospheric to operating pressure cycles
2) Normal service pressure fluctuations
3) Temperature difference - startup and shutdown
4) Temperature difference - normal service
5) Temperature difference - dissimilar materials
6) Mechanical loads Therefore, the fatigue waiver for the PSL Unit 1 containment vessel remains valid through the SPEO in accordance with 10 CFR 54.21(c)(1)(i).

Penetrations Fatigue The PSL containment penetration design includes the following components that utilize different fatigue analysis methods:

1. The containment vessel nozzles are included as part of the containment vessel design. Each containment penetration includes a nozzle welded to the containment vessel. The fatigue analysis for the containment vessel nozzles is included in the fatigue waiver evaluations discussed above for the steel containment vessels.
2. The mechanical penetration assembly design includes a process pipe, a shield building penetration sleeve and an expansion bellows. In the case of hot and semi-hot penetrations, a multiple fluid head is provided as an integral part of the process pipe. The only mechanical penetration assembly components that include a fatigue analysis are the penetration expansion bellows and the process piping. A fatigue analysis of the stainless steel expansion bellows was performed by the original equipment supplier.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 27 of 35 Computation of the bellows cyclic life is included in Appendix 3G of the PSL Unit 1 UFSAR.

The process piping for the majority of the Unit 1 piping penetrations is designed in accordance with ANSI B31. 7 Class 2. The exception to the design requirements above are the four Unit 1 safety injection piping penetrations which are designed in accordance with ANSI B31. 7 Class 1 requirements.

Note that other than the containment vessel nozzles described above, the design of the electrical penetrations do not include a fatigue analysis.

The PSL Unit 1 containment penetrations expansion bellows are specified to withstand a lifetime total of 7,000 cycles of expansion and compression due to maximum operating thermal expansion, and 200 cycles of other movements (seismic motion and differential settlement). The PSL Unit 1 containment penetrations are categorized as follows:

1) Type I - those which must accommodate considerable thermal movements (hot penetrations)
2) Type II - those which are not required to accommodate thermal movements (low temperature penetrations)
3) Type III - those which must accommodate moderate thermal movements (semi-hot penetrations)
4) Type IV - containment sump recirculation suction lines
5) Type V - fuel transfer tube The thermal fatigue design limits of the Type I and Type III containment penetration expansion bellows (7,000 thermal cycles) are bounded by the thermal fatigue design limits of their associated piping systems as discussed in UFSAR Sections 19.34.3.1 and 19.34.3.2. The 200 cycles of differential settlement and seismic motion are also bounding for the SPEO since they are not susceptible to any significant differential settlement they have not been subjected to any seismic loading to date. Differential settlement between the steel containment vessel and the concrete shield building is unlikely through the SPEO as the bottom of the steel containment vessel is integral to concrete shield building basemat. 80-year projected cycles for OBE seismic motion are less than to 200 design cycle limit.

Type II penetrations are low temperature penetrations, Type IV penetrations are low temperature penetrations that are only used during post-accident scenarios, and the Type V penetration is the PSL Unit 1 fuel transfer tube. As such, these penetrations are not exposed to large thermal loads or thermal movements; however, these penetrations were conservatively designed for 7,000 cycles of expansion and compression due to operating thermal expansion and 200 cycles each of differential settlement and seismic motion. Consistent with the evaluation above for Type I and III penetrations, The the7,000 thermal cycles and 200 cycles of differential settlement and seismic motion for Type II, Type IV, and Type V penetrations are bounding for the SPEO.

The fatigue analyses associated with the PSL Unit 1 containment mechanical penetration stainless steel expansion bellows fatigue have been evaluated and determined to remain valid for the SPEO, in accordance with 10 CFR 54.21(c)(1)(i).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 28 of 35 SLRA Section A-2, pages A2-56 through A2-57 are revised as follows:

19.3.5 Containment Liner Plate, Metal Containments and Penetrations Fatigue Metal Containment Fatigue The PSL Unit 2 containment vessel is fabricated from welded ASME-SA 516 Grade 70 steel plates to provide an essentially leak-tight barrier. Design criteria applied to the steel containment vessels assure that the specified leak rate is not exceeded under the design basis accident conditions. The PSL Unit 2 containment vessel is designed in accordance with the 1971 Edition of ASME Boiler and Pressure Vessel Code,Section III. The CLB for the PSL Unit 2 containment vessel includes a fatigue waiver evaluation performed in accordance with the 1971 Edition of ASME Section III, Nuclear Vessels, Section NB-3222.4, Analysis for Cyclic Operation that precludes the need for a detailed fatigue analysis. The fatigue waiver evaluation includes the steel containments vessel shells, containment penetration nozzles, personnel air locks, and equipment hatches.

A common evaluation of the PSL Units 1 and 2 containment vessel fatigue waivers was performed for SLR and concluded that the fatigue waivers remain valid through the 80-year SPEO since the service loading of the vessels meet all the following six fatigue waiver conditions of the applicable ASME Codes:

1) Atmospheric to operating pressure cycles
2) Normal service pressure fluctuations
3) Temperature difference - startup and shutdown
4) Temperature difference - normal service
5) Temperature difference - dissimilar materials
6) Mechanical loads Therefore, the fatigue waiver for the PSL Unit 2 containment vessel remains valid through the SPEO in accordance with 10 CFR 54.21(c)(1)(i).

Penetrations Fatigue The PSL containment penetration design includes the following components that utilize different fatigue analysis methods:

1. The containment vessel nozzles are included as part of the containment vessel design. Each containment penetration includes a nozzle welded to the containment vessel. The fatigue analysis for the containment vessel nozzles is included in the fatigue waiver evaluations discussed above for the steel containment vessels.
2. The mechanical penetration assembly design includes a process pipe, a shield building penetration sleeve and an expansion bellows. In the case of hot and semi-hot penetrations, a multiple fluid head is provided as an integral part of the process pipe. The only mechanical penetration assembly components that include a fatigue analysis are the penetration expansion bellows and the process piping. A fatigue analysis of the stainless steel expansion bellows was performed by the original equipment supplier.

Computation of the bellows cyclic life is included in Appendix 3G of the PSL Unit 1 UFSAR. Note that a previous engineering evaluation concluded this

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 29 of 35 computation of the bellows cyclic life is applicable to the PSL Unit 2 mechanical penetrations.

The process piping for the PSL Unit 2 piping penetrations is designed in accordance with ASME Section III Class 2 requirements.

Other than the containment vessel nozzles described above, the design of the electrical penetrations do not include a fatigue analysis.

The PSL Unit 2 containment penetrations are specified to withstand a lifetime total of 7,000 cycles of expansion and compression due to maximum operating thermal expansion, and 200 cycles of other movements (seismic motion and differential settlement). The PSL Unit 2 containment penetrations are categorized as follows:

1) Type I - those which must accommodate considerable thermal movements (hot penetrations)
2) Type II - those which are not required to accommodate thermal movements (low temperature penetrations)
3) Type III - those which must accommodate moderate thermal movements (semi-hot penetrations)
4) Type IV - containment sump recirculation suction lines
5) Type V - fuel transfer tube The thermal fatigue design limits of the Type I and Type III containment penetration bellows (7,000 thermal cycles) are bounded by the thermal fatigue design limits of their associated piping systems as discussed in UFSAR Sections 419.3.3.1 and 419.3.3.2. The 200 cycles of differential settlement and seismic motion are also bounding for the SPEO since they are not susceptible to any significant differential settlement they have not been subjected to any seismic loading to date. Differential settlement between the steel containment vessel and the concrete shield building is unlikely through the SPEO as the bottom of the steel containment vessel is integral to concrete shield building basemat. 80-year projected cycles for OBE seismic motion are less than 200 design cycle limit.

Type II penetrations are low temperature penetrations, Type IV penetrations are low temperature penetrations that are only used during post-accident scenarios, and the Type V penetration is the PSL Unit 2 transfer tube. As such, these penetrations are not exposed to large thermal loads or thermal movements; however, these penetrations were conservatively designed for 7,000 cycles of expansion and compression due to operating thermal expansion and 200 cycles each of differential settlement and seismic motion. Consistent with the evaluation above for Type I and III penetrations, The the 7,000 thermal cycles and 200 cycles of differential settlement and seismic motion for Type II, Type IV, and Type V penetrations are bounding for the SPEO.

The fatigue analyses associated with the PSL Unit 2 containment mechanical penetration stainless steel expansion bellows fatigue have been evaluated and determined to remain valid for the SPEO, in accordance with 10 CFR 54.21(c)(1)(i).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 30 of 35 SLRA Section A-1, pages A1-99 and A1-100 are revised as follows:

Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Program or Activity Section Schedule (Section) 32 ASME Section XI, XI.S1 Continue the existing PSL ASME Section XI, Subsection IWE AMP, including No later than 6 months Subsection IWE (19.2.2.29) enhancement to: prior to the SPEO, or no later than the last a) Augment existing procedures to reference EPRI Reports 1015336 and refueling outage prior to 1015337 and to incorporate guidance for proper selectionspecify that the SPEO i.e.:

whenever replacement of bolting is required, bolting material, and lubricants and appropriate installation torque or tension, and use of PSL1: 09/01/2035 lubricants and sealants are in accordance with the guidelines of EPRI NP-5769, Degradation and Failure of Bolting in Nuclear Power Plants Start the one-time and EPRI TR-104213, Bolted Joint Maintenance & Application Guide to inspections for cracking prevent or minimize loss of bolting preload and cracking of due to SCC no earlier high-strength bolting. Additionally, update procedures to explicitly than 5 years prior to the prohibit the use of molybdenum disulfide and other lubricants SPEO (03/01/2031).

containing sulfur on structural bolting.

b) Augment existing procedures to specify that for structural bolting consisting of ASTM A325, ASTM A490, and equivalent materials, the use of preventive actions for storage, lubricant selection, and stress corrosion cracking potentialbolting and coating material selection discussed in Section 2 of RCSC (Research Council for Structural Connections) publication Specification for Structural Joints Using High-StrengthASTM A325 or A490 Bolts, will be usedfor structural bolting consisting of ASTM A325, ASTM A490, and equivalent bolts.

c) Augment existing procedures to implement periodic supplemental surface or enhanced visual examinations at intervals no greater than 10 years to detect cracking due to cyclic loading of all non-piping penetrations (hatches, electrical penetrations, etc.) that are subject to cyclic loading but have no current licensing bases fatigue analysis and are not subject to local leak rate testing.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 31 of 35 Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Program or Activity Section Schedule (Section) d) Augment existing procedures to implement supplemental one-time surface or enhanced visual examinations performed by qualified personnel using methods capable of detecting cracking, comprising (a) a representative sample (two) of the stainless steel penetrations or dissimilar metal welds associated with high-temperature (temperatures above 140°F) stainless steel piping systems in frequent use on each unit; and (b) the stainless steel fuel transfer tube on each unit. These inspections are intended to confirm the absence of SCC aging effects. If SCC is identified as a result of the supplemental one-time inspections, additional inspections will be conducted in accordance with the sites corrective action process. This will include one additional penetration with dissimilar metal welds associated with greater than 140°F stainless steel piping systems for each Unit until cracking is no longer detected.

Periodic inspection of subject penetrations with dissimilar metal welds for cracking will be added to the PSL ASME Section XI, Subsection IWE AMP if necessary, depending on the inspection results.

ec) Augment existing procedures to implement a one-time supplemental volumetric examinationinspection of containment vesselmetal shell surfaces for both units that samples one-foot squarerandomly selected as well as focused locations including both randomly-selected and focused areas most likely to experience degradation based on OE and/or other relevant considerations such as environmentsusceptible to loss of thickness due to corrosion from the inaccessible side if triggered by plant-specific OE identified through code inspections after the date of issuance of the first renewed license in eitherfor each unit. This sampling is conducted to demonstrate, with 95% confidence, that 95% of the accessible portion of the containment vesselmetal shell is not experiencing greater than 10% wall loss.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 32 of 35 SLRA Appendix A2, Section 19.4, commitment No. 32 portion of Table 19-3 beginning on page A2-99, is revised as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Program or Activity Section Schedule (Section) 32 ASME Section XI, XI.S1 Continue the existing PSL ASME Section XI, Subsection IWE AMP, including No later than 6 Subsection IWE (19.2.2.29) enhancement to: months prior to the a) Augment existing procedures to reference EPRI Reports 1015336 and SPEO, or no later 1015337 and to incorporate guidance for proper selectionspecify that than the last whenever replacement of bolting is required, bolting material, and lubricants refueling outage and appropriate installation torque or tension, and use of lubricants and prior to the SPEO sealants are in accordance with the guidelines of EPRI NP-5769, i.e.:

Degradation and Failure of Bolting in Nuclear Power Plants and EPRI PSL2: 10/06/2042 TR-104213, Bolted Joint Maintenance & Application Guide to prevent or minimize loss of bolting preload and cracking of high-strength bolting. Start the one-time Additionally, update procedures to explicitly prohibit the use of inspections for molybdenum disulfide and other lubricants containing sulfur on cracking due to SCC structural bolting. no earlier than 5 b) Augment existing procedures to specify that for structural bolting consisting years prior to the of ASTM A325, ASTM A490, and equivalent materials, the use of preventive SPEO (04/06/2038).

actions for storage, lubricant selection, and stress corrosion cracking potentialbolting and coating material selection discussed in Section 2 of RCSC (Research Council for Structural Connections) publication Specification for Structural Joints Using High-StrengthASTM A325 or A490 Bolts, will be usedfor structural bolting consisting of ASTM A325, ASTM A490, and equivalent bolts.

c) Augment existing procedures to implement periodic supplemental surface or enhanced visual examinations at intervals no greater than 10 years to detect cracking due to cyclic loading of all non-piping penetrations (hatches, electrical penetrations, etc.) that are subject to cyclic loading but have no current licensing bases fatigue analysis and are not subject to local leak rate testing.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 33 of 35 Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Program or Activity Section Schedule (Section) dc) Augment existing procedures to implement supplemental one-time surface examinations (magnetic particle, dye penetrant) or enhanced visual examinations (EVT-1 or equivalent), performed by qualified personnel using methods capable of detecting cracking, comprising (a) a representative sample (tentwo) of the PSL Unit 2 electrical stainless steel penetrations or dissimilar metal welds associated with high-temperature (temperatures above 140°F) stainless steel piping systems in frequent use on each unit; and (b) the stainless steel fuel transfer tube on each unit. These inspections are intended to confirm the absence of SCC aging effects. If SCC is identified as a result of these supplemental one-time inspections, additional surface examinations (magnetic particle, dye penetrant) or enhanced visual examinations (EVT-1 or equivalent)inspections will be conducted in accordance with the sites corrective action process. This will include one additional PSL Unit 2 electrical penetration with dissimilar metal welds associated with greater than 140°F stainless steel piping systems for each Unit until cracking is no longer detected. Periodic inspection of PSL Unit 2 electrical subject penetrations with dissimilar metal welds for cracking will be added to the PSL ASME Section XI, Subsection IWE AMP if necessary, depending on the inspection results. Frequency of inspections will be consistent with the approved IWE inspection interval.

d) ed) Augment existing procedures to implement a one-time supplemental volumetric examinationinspection of containment vesselmetal shell surfaces for both units that samples one-foot squarerandomly selected as well as focused locations including both randomly-selected and focused areas most likely to experience degradation based on OE and/or other relevant considerations such as environmentsusceptible to loss of thickness due to corrosion from the inaccessible side if triggered by plant-specific OE identified through code inspections after the date of issuance of the first renewed license in eitherfor each unit. This sampling is conducted to demonstrate, with 95% confidence, that 95% of the accessible portion of the containment vesselmetal shell is not experiencing greater than 10% wall loss.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 34 of 35 SLRA Appendix B, Section B.2.3.29, continuing paragraph at top of page B-228 is revised as follows:

addressed in the Containment Liner Plate, Metal Containments, and Penetrations Fatigue Analysis TLAA for SLR (Section 4.6). Cracking due to cyclic loading of all non-piping penetrations (equipment hatch, personnel locks, electrical penetrations, etc.) that are subject to cyclic loading but have no current licensing bases fatigue analysis will be managed by the 10 CFR Part 50, Appendix J AMP (Section B.2.3.31) or by periodic supplemental surface or enhanced visual examinations incorporated into and consistent with the frequency of this AMP. This AMP will also include supplemental one-time inspections within 5 years prior to the SPEO for a representative sample of SS PSL Unit 2 electrical penetrations and dissimilar metal welds, including the fuel transfer tubes, that may be susceptible to SCC.

SLRA Appendix B, Section B.2.3.29, Enhancements Table beginning on page B-228 is revised as follows:

Element Affected Enhancement

2. Preventive Actions Procedures will be revised to specify that whenever replacementreference EPRI Reports 1015336 and 1015337 and to incorporate guidance for proper selection of bolting is required, bolting material, and lubricants and appropriate installation torque or tension, and use of lubricants and sealants are in accordance with the guidelines of EPRI NP-5769, Degradation and Failure of Bolting in Nuclear Power Plants and EPRI TR-104213, Bolted Joint Maintenance & Application Guide to prevent or minimize loss of bolting preload and cracking of high-strength bolting.

Additionally, procedures will be updated to explicitly prohibit the use of molybdenum disulfide and other lubricants containing sulfur on structural bolting.

2. Preventive Actions Procedures will be revised to specify that for structural bolting consisting of ASTM A325, ASTM A490, and equivalent materials, the use of preventive actions for storage, lubricant selection, and bolting and coating material selectionstress corrosion cracking potential discussed in Section 2 of RCSC (Research Council for Structural Connections) publication Specification for Structural Joints Using High-StrengthASTM A325 or A490 Bolts, will be usedfor structural bolting consisting of ASTM A325, ASTM A490, and equivalent bolts.
4. Detection of Aging Effects Procedures will be revised to perform periodic supplemental surface or enhanced visual examinations at intervals no greater than 10 years to detect cracking due to cyclic loading of all non-piping penetrations (hatches, electrical penetrations, etc.) that are subject to cyclic loading but have no current licensing bases fatigue analysis and are not subject to local leak rate testing.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 8 Page 35 of 35 Element Affected Enhancement

4. Detection of Aging Effects Procedures will be revised to implement supplemental one-time surface examinations (magnetic particle, dye penetrant) or enhanced visual examinations (EVT-1 or equivalent), performed by qualified personnel using methods capable of detecting cracking, comprising (a) a representative sample (tentwo) of the SS PSL Unit 2 electrical penetrations or dissimilar metal welds associated with high-temperature (temperatures above 140°F) SS piping systems in frequent use on each unit; and (b) the SS fuel transfer tube on each unit. These inspections are intended to confirm the absence of SCC aging effects.
4. Detection of Aging Effects Procedures will be revised to specify a one-time volumetric examination of containment vesselmetal shell surfaces that are inaccessible from one side if triggered by plant-specific OE identified after the date of issuance of the first renewed license in eitherfor each unit. If triggered, this inspection will be performed for both units by sampling randomly selected, as well as focused, one-foot squaremetal shell locations including both randomly-selected and focused areas most likely to experience degradation based on OE and/or other relevant considerations such as environmentsusceptible to corrosion that are inaccessible from one side. The trigger for this one-time examination is site-specific occurrence or recurrence of containment vesselmetal shell corrosion (base metal material loss exceeding 10% of nominal plate thickness) that is determined to originate from the inaccessible areasside. Any such instance would be identified through code inspections performed since 10/02/2003. Guidance provided in EPRI TR-107514 will be considered when establishing a sampling plan.

This sampling is conducted to demonstrate, with 95% confidence, that 95% of the accessible portion of the containment vesselmetal shell is not experiencing greater than 10% wall loss.

7. Corrective Actions If SCC is identified as a result of the supplemental one-time inspections, additional surface examinations (magnetic particle, dye penetrant) or enhanced visual examinations (EVT-1 or equivalent)inspections will be conducted in accordance with the sites corrective action process. This will include one additional PSL Unit 2 electrical penetration with dissimilar metal welds associated with greater than 140°F SS piping systems for each Unit until cracking is no longer detected. Periodic inspection of subject PSL Unit 2 electrical penetrations with dissimilar metal welds for cracking will be added to the PSL ASME Section XI, Subsection IWE AMP if necessary, depending on the inspection results. Frequency of inspections will be consistent with the approved IWE inspection interval.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 9 Page 1 of 4 TLAA Section 4.7.1 Leak-Before Break of Reactor Coolant System Piping - Clarification Affected SLRA Sections: 4.7.1, 4.8 SLRA Page Numbers: 4.7-1 through 4.7-2, 4.8-2 Description of Change:

The evaluation of the PSL leak-before-break (LBB) TLAA included in SLRA Section 4.7.1 states that Westinghouse analysis WCAP-18617-P (proprietary) and WCAP-18617-NP (non-proprietary) performed LBB evaluations assuming the 80-year subsequent period of extended operation (SPEO). Section 6.4 of the analysis states that flaw sizes to yield a leak rate of 10 gpm were calculated for the reactor coolant loop piping at the critical locations. Therefore, to satisfy the required margin of 10 on the assumed leak rate, the PSL RCS boundary leakage detection systems must have a leakage detection capability of 1.0 gpm.

As stated in Sections 5.2.4 and 5.2.5 of the PSL Unit 1 and Unit 2 UFSARs, respectively, the RCS pressure boundary leakage detection systems meet the intent of NRC Regulatory Guide 1.45, "Reactor Coolant Pressure Boundary Leakage Detection Systems, Revision 0, May 1973 and are capable of detecting unidentified leakage as low as 1.0 gpm. SLRA Section 4.7.1 is updated to include this clarification.

The following discussion provides clarification on the version of NUREG/CR-4513 that was used for the fracture toughness correlations in the analysis.

NUREG/CR-4513 Revision 2 (May 2016) was utilized within the SLR LBB analysis but the analysis had not considered or referenced the NUREG/CR-4513 errata (March 15, 2021) before the final archival of WCAP-18617-P and WCAP-18617-NP. Review of the errata shows that the typographical error (the symbol ) does not change the thermal aging results of A351-CF8M CASS material and the related effective full power years (EFPY) conditions for this material.

This typographical error was carried into SLRA Section 4.7.1 consistent with statements within WCAP-18617-P and WCAP-18617-NP.

However, by incorporation of this errata, the overall technical content and results would be unchanged with the use of the errata for NUREG/CR-4513, Revision 2. The analysis per WCAP-18617-P and WCAP-18617-NP, uses the lower bound fully aged conditions (saturated) provided by NUREG/CR-4513 Revision 2 and have been determined to be appropriate for the SPEO. Reference to the errata does not change the thermal aging analysis of the A351-CF8M materials for the SPEO. Accordingly, SLRA Section 4.7.1 is revised to remove the statement regarding the EFPY condition and replaces it with a statement describing the use of the lower bound fully aged conditions for the A351-CF8M material. SLRA Reference 4.8.25 is also revised to include a reference to the errata.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 9 Page 2 of 4 SLRA Section 4.7.1, pages 4.7-1 through 4.7-2 are revised as follows:

4.7.1 Leak-Before-Break of Reactor Coolant System Piping TLAA Description The Combustion Engineering Owners Group (CEOG) performed the leak-before-break (LBB) evaluation CEN-367-A (Reference 4.8.22, for the PSL Units 1 and 2 primary loop piping in February 1991 along with other Combustion Engineering designed nuclear steam supply systems of similar layouts. The LBB evaluation was updated in 2009 for Unit 1 and in 2010 for Unit 2 as part of the extended power uprate (EPU) project. In comparing the revised plant-specific loads for the EPU to the evaluation performed in CEN-367-A, it was concluded that the PSL Unit 1 and 2 RCS hot and cold leg piping remained qualified for the LBB under EPU conditions and that CEN-367-A remained applicable for both Unit 1 and 2.

Considering the current PSL Unit 1 and 2 LBB analysis includes a postulated crack stability analysis that is related to the period of plant operation, the primary loop piping LBB analysis is a TLAA for SLR.

TLAA Evaluation WCAP-18617-NP and WCAP-18617-P (References 4.8.23 and 4.8.24) performed the LBB evaluation for PSL Units 1 and 2 assuming an 80-year plant life. The analysis documented the plant-specific geometry, loading, and material properties used in the fracture mechanics evaluation.

The PSL Units 1 and 2 primary loop piping is constructed from carbon steel (SA-516-70) material with SS cladding. The carbon steel cold leg piping is connected to the RCP suction and discharge nozzles and the four nozzle safe-ends contain A351-CF8M CASS material and Alloy 82/182 dissimilar weld material. The A351-CF8M material is susceptible to the thermal aging at the reactor operating temperatures the Alloy 82/182 weld material is susceptible to primary water stress corrosion cracking (PWSCC).

Based on NUREG/CR-4513 (Reference 4.8.25) the lower bound fully aged fracture toughness correlations are used for the full aged condition is applicable for plants operating at 15 EFPY for the A351-CF8M materials. For the 80-year SPEO, the materials will thermally age. Therefore, the use of the fracture toughness correlations is applicable for the fully aged or saturated condition of the PSL Units 1 and 2 RCP nozzle safe-ends.

WCAP-18617-NP and WCAP-18617-P include a recalculation of delta ferrite and fracture toughness properties based on NUREG/CR-4513. The chemistry data for the fracture mechanics parameters are obtained from the primary loop piping material Certified Materials Test Reports (CMTRs).

The fatigue crack growth analysis originally included in CEN-367-A used generic design basis transient cycles that envelope the projected 80-year transient cycles for PSL Units 1 and 2 to calculate the crack growth. Therefore, the generic fatigue crack growth analysis results are representative of the PSL Unit 1 and 2 fatigue crack growth and are applicable for the 80-year SPEO.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 9 Page 3 of 4 WCAP-18617-NP and WCAP-18617-P justify the elimination of RCS primary loop pipe breaks from the structural design basis for the 80-year plant life as follows:

a. Stress corrosion cracking is precluded by use of fracture resistant materials in the piping system and controls on reactor coolant chemistry, temperature, pressure, and flow during normal operation. Alloy 82/182 welds are present at the PSL Unit 1 and Unit 2 RCP suction and discharge nozzles. The Alloy 82/182 welds are susceptible to PWSCC and have been conservatively evaluated to consider the effects of PWSCC.
b. For global failure mechanisms, all locations are evaluated using the limiting material properties. For local failure mechanisms, all locations are evaluated using the A351-CF8M cast SS material properties which present a limiting condition due to the thermal aging effects.
c. Evaluation of the RCS piping considering the thermal aging effects for the 80-year SPEO and the use of the most limiting fracture toughness properties ensures that each material profile is appropriately bounded by the LBB results presented in WCAP-18617-NP and WCAP-18617-P.
d. Water hammer should not occur in the RCS piping because of system design, testing, and operational considerations.
e. The effects of low and high cycle fatigue on the integrity of the primary piping are negligible.
f. Ample margin exists between the leak rate of small stable flaws and the capability of the PSL Unit 1 and 2 RCS pressure boundary leakage detection system. The PSL Unit 1 and Unit 2 RCS pressure boundary leakage detection systems meet the intent of NRC Regulatory Guide 1.45, Revision 0, and are capable of detecting unidentified leakage as low as 1.0 gpm.
g. Ample margin exists between the small stable flaw sizes of item (f) and larger stable flaws.
h. Ample margin exists in the material properties used to demonstrate end-of-service life (fully aged) stability of the critical flaws.

For the critical locations, flaws are identified that will be stable because of the ample margins described in f, g, and h above.

The LBB analysis results for the RCP suction and discharge nozzle safe-end locations are acceptable for A351-CF8M CASS material from thermal aging effect and for Alloy 82/182 dissimilar metal weld material from PWSCC effect. All the LBB criteria are satisfied. The results for the reactor coolant loop remaining locations not evaluated in WCAP-18617-NP and WCAP-18617-P remain bounded by the analysis of record, CEN-367-A.

WCAP-18617-NP and WCAP-18617-P demonstrates that the conclusions reached in CEN-367-A remain applicable to PSL Unit 1 and 2 and the dynamic effects of reactor coolant system primary loop pipe breaks need not be considered in the structural design basis for the 80-year SPEO.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 9 Page 4 of 4 SLRA Section 4.8, page 4.8-2 is revised as follows:

4.8.25 NUREG/CR-4513, Revision 2 (May 2016, including March 15, 2021 Errata) and Revision 1 (May 1994), Estimation of Fracture Toughness of Cast Stainless Steels During Thermal Aging in LWR Systems, O. K. Chopra, U.S. Nuclear Regulatory Commission, Washington, DC

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 10 Page 1 of 11 SLRA Section 4.7.7 Flaw Tolerance Evaluation for CASS RCS Piping Components -

Clarification Affected SLRA Sections: Table 3.1-1, Table 3.1.2-3, Table 3.1.2-4, Table 3.2-1, Table 3.3.2-1, Table 3.3.2-10, 4.8, B.1.1, Table B-4, B.2.3.6 SLRA Page Numbers: 3.1-31, 3.1-71, 3.1-73, 3.1-80, 3.1-83, 3.1-88, 3.2-20, 3.3-92, 3.3-93, 3.3-217, 4.8-4, B-6, B-20, B-62, B-63 Description of Change:

For the 80-year subsequent period of extended operation (SPEO), Structural Integrity Associates (SI) prepared Report No. 2001262.402 (SLRA Reference 4.8.42), which documents the results of the flaw tolerance evaluation of CASS RCS piping components for PSL Units 1 and 2. Section 4.7.7 of the PSL SLRA makes the statement The same stresses used in the PEO report were also utilized in SI Report No. 2001262.402 for the SPEO. For the SPEO, the SI Report used an updated version of crack growth software pc-Crack, which eliminated some of the unnecessary conservatisms in the PEO report.

The following additional information provides details regarding these conservatisms:

  • What conservatisms were removed?
  • How these conservatisms decrease the maximum flaw growth so greatly from the previous analysis that 80-year operation is now justified?
  • How the removal of these conservatisms will ensure safe operation of the plant up to 80 years?

Description of Conservatisms The cast austenitic stainless steel (CASS) components in the surge line for PSL Units 1 and 2 were identified as the most limiting, compared to the CASS Unit 1 safety injection (SI) safe-ends and Unit 2 reactor coolant pump (RCP) safe-ends. As such, this response will focus on the surge line components, and the discussion of conservatisms for the surge line analysis are applicable to the analysis of the other CASS components with the exception of those subjected to thermal stratification, which only occurs in the surge line.

In the CASS reevaluation of the fatigue crack growth for 80 years, two conservatisms were reduced.

1. First, for the heatup and cooldown transients, the average rate of accumulation based on 80-year cycle projections is lower than those previously used for the 60-year cycle projections.
2. Second, the application of the fatigue crack growth law for transients was refined in the fracture mechanics software.

Item 1 Compared to other transients, thermal stratification has significantly higher stresses and is dominant for fatigue crack growth in the surge line. Thermal stratification occurs during heatup and cooldown, and thus, the effects of thermal stratification scale with heatup and cooldown cycles. As shown in the table below from Table 8 of the SLR CASS evaluation Report No.

2001262.402, the average rate of accumulation used, based on 80-year cycle projections for

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 10 Page 2 of 11 heatup and cooldown, is about 25% lower than those previously used for the 60-year cycle projections. Thus, the reductions in annual projected cycles for heatup and cooldown based on plant operating experience resulted in a reduction in conservatism for fatigue crack growth due to thermal stratification. Although the 60-year and 80-year cycles remain the same, the yearly reduction in the number of cycles for the 80-year case results in relatively slower crack growth per year, which compounds with time.

For the Unit 1 SI nozzle safe-ends and Unit 2 RCP safe-ends, thermal stratification does not occur, but the reductions in heatup and cooldown cycles are applicable.

60-Year Cycles [Reference 1] 80 Year Cycles (SLRA Table 4.3.1-1)

Thermal Initial License Renewal Subsequent License Renewal Transients Total Projected Annual Projected Total Projected Annual Projected Cycles Cycles Cycles Cycles Plant Heatup 143 2.4 143 1.788 Plant 143 2.4 141 1.763 Cooldown Item 2 Fatigue crack growth calculations were performed using the safety-related, nuclear QA-verified fracture mechanics software, pc-CRACK [References 2 and 3]. For the initial license renewal evaluation, the fatigue crack growth law [Reference 4] was input generically in pc-CRACK Version 4.1 [Reference 2] as an exponential form for three transient groupings (low pressure stratification, hot standby stratification, and all other transients) in the surge line analysis with the following conservatisms:

  • R-Ratio - High R-ratio (ratio of the stress intensity factor, Kmin / Kmax) for each transient grouping
  • Temperature - Maximum temperature for each transient grouping
  • Rise Time - Long rise time for each transient grouping For the subsequent license renewal evaluation, the same fatigue crack growth law was published as ASME Code Case N-809 [Reference 5] and was precisely implemented in pc-CRACK, Version 5.0 [Reference 3] with the following transient-specific inputs for each transient based on stress analyses to reduce conservatisms:
  • R-Ratio - Calculated internally by the software for each transient at each crack growth step
  • Temperature - Maximum temperature specified for each transient
  • Rise Time - Rise time specified for each transient By considering transient-specific parameters rather than transient groupings, the refined implementation of the fatigue crack growth law resulted in a reduction in conservatism for fatigue crack growth in the surge line analyses.

For the Unit 1 SI nozzle safe-ends and Unit 2 RCP safe-ends, the transients for each component were analyzed as one grouping for the crack growth rate in the initial license renewal evaluation. For the subsequent license renewal evaluation, the transient-specific values for the R-ratio, temperature, and rise time were used.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 10 Page 3 of 11 Effect of Conservatisms on Fatigue Crack Growth The table below compares the input parameters for the fatigue crack growth laws. For the initial license renewal evaluation, the parameters for the transient groupings for the surge line are shown since the surge line crack growth bounds that of the SI and RCP safe ends. For the subsequent license renewal evaluation, selected example transients with the greatest stress intensity range, K = Kmax - Kmin, from the groupings are shown.

Also shown is C0, which is the pre-exponential coefficient for the crack growth laws in exponential form and is calculated from the crack growth law parameters:

(da/dN) = C0 (K)n where, da/dN = crack growth rate, in/cycle C0 = material parameter for loading rate and environment K = stress intensity factor range, ksi-in1/2 The reduction in conservatism by applying transient-specific parameters resulted in reducing C0 by approximately an order of magnitude for the example transients in the subsequent license renewal evaluation compared to the transient groupings in the initial license renewal evaluation.

Crack Growth Law Parameters Coefficient Transient Maximum Rise Time R-Ratio C0 Temperature (°F) (s)

Transient Groupings for the Surge Line in the Initial License Renewal Evaluation Low Pressure Stratification 0.5 440 10000 5.20 x 10-8 Hot Standby Stratification 0.9 653 1400 2.91 x 10-7 All other transients 0.9 653 10000 5.24 x 10-7 Select Transients for the Surge Line in the Subsequent License Renewal Evaluation (Note 1) 1 Low Pressure Stratification at 320°F 0.45 440 3.05 x 10-9 (Note 3) 1 Hot Standby Stratification at 90°F 0.72 650 1.19 x 10-8 (Note 3)

<0 50 Plant Unloading B (Note 4) 540 1.54 x 10-8 (Note 2) (Note 3)

Notes:

1. The crack growth law parameters (R-Ratio and C0) at Year 1 are shown as examples and are comparable to the parameters calculated internally for each year by pc-CRACK, Version 5.0.
2. ASME Code Case N-809 specifies an alternative equation for negative R-ratios.
3. The rise times were adjusted based on a review of every transient in the finite element stress analyses and were significantly lower for some transients.
4. Plant Unloading B is most severe transient with the greatest stress intensity range among the all other transients grouping.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 10 Page 4 of 11 The table below compares the crack growth at Year 1 and Year 21 with a postulated initial flaw depth of 0.25 a/t for the limiting Stress Path 4 in the surge line. 21 years was the maximum operating period for the limiting Stress Path 4 in the initial license renewal evaluation. For reference, the final flaw size at Year 80 is shown for the subsequent license renewal evaluation.

Crack Growth Time Flaw Depth-to-Flaw Depth, a Thickness, (in) a/t Limiting Stress Path 4 in Surge Line from the initial License Renewal Evaluation Year 1 0.37 0.28 Year 21 0.97 0.74 Limiting Stress Path 4 in the Surge Line from the Subsequent License Renewal Evaluation Year 1 0.33 0.25 Year 21 0.36 0.27 Year 80 0.45 0.34 Safe Operation of the Plant for Subsequent License Renewal The reduction in conservatisms is summarized as:

  • Reduction in the annual accumulation of cycles of heatup, cooldown, and thus thermal stratification transients (thermal stratification is only applicable to the surge line). This is based on the latest projections for transient cycles.
  • A more refined implementation of the crack growth rate using transient-specific parameters rather than transient groupings. This results in a more accurate calculation of the fatigue crack growth rate for each transient.

The methodology for the subsequent license renewal evaluation uses the same fracture mechanics model for fatigue crack growth as the initial license renewal evaluation and follows the revised NRC guidance for CASS materials in the GALL-SLR Report. The initial license renewal evaluation showed that the allowable operation was 21 years for the limiting location, and the CASS components at PSL Units 1 and 2 are very flaw tolerant. The subsequent license renewal evaluation showed additional margin for up to 80 years of operation for all CASS components and further confirmed the flaw tolerance conclusions for the CASS materials for the subsequent period of extended operation.

Additional clarification is also provided in this supplemental response to address whether the PSL SLRA considered the Interim Staff Guidance (ISG) SLR-ISG-2021-02-Mechanical, Updated Aging Management Criteria for Mechanical Portions of Subsequent License Renewal Guidance. Specifically, Appendix C of the ISG contains revisions to NUREG-2191 AMP XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel. Element 5, Acceptance Criteria, was revised to add the 2019 Edition of the ASME Code, Non-mandatory Appendix C which provides flaw evaluation procedures for CASS with ferrite content 20 percent. The ISG states that those procedures may be used for flaw evaluations or flaw tolerance evaluations in this AMP until Appendix C to the 2019 Edition of ASME Code,Section XI is incorporated by reference in 10 CFR 50.55a.

While the updated ISG was taken into account in developing the PSL SLR AMP, an exception is required for the acceptance criteria used for the flaw tolerance evaluation of the CASS piping components. In lieu of using the criteria for CASS piping components provided in ASME Code,

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 10 Page 5 of 11 Section XI, Appendix C, 2019 edition, the evaluation used the same criteria as the flaw tolerance evaluation of CASS piping in the 60-year license renewal application for the 80-year SLRA. The flaw tolerance acceptance criteria used in both the 60-year evaluation for initial license renewal and the 80-year evaluation for subsequent license renewal was based on the technical guidance provided in MRP-362 [Reference 6] which formed the basis for ASME Code,Section XI Code Case N-838 [Reference 7].

There are two reasons for adopting this approach for the PSL SLR. The first reason is to maintain consistency between the 60-year and the 80-year CASS flaw tolerance evaluations.

The second reason is that the flaw acceptance criteria used in the 60-year evaluation was verified by the NRC in support of the initial license renewal application and should, therefore, be considered acceptable for the 80-year evaluation. The review by the NRC of the CASS piping flaw tolerance acceptance criteria for the 60-year license renewal for PSL Unit 1 is documented in Reference 8 under Commitment 8, Thermal Aging Embrittlement of Cast Stainless Steel Embrittlement Program. Similarly, the review by the NRC of the CASS piping flaw tolerance acceptance criteria for the 60-year license renewal for St. Lucie Unit 2 is documented in Reference 9 under Commitment 7, UFSAR Section 18.1.5, Thermal Aging Embrittlement of Cast Stainless Steel Embrittlement Program. SLRA Tables 3.1.2-3, 3.1.2-4, 3.2-1, 3.3.2-1, 3.3.2-10, B-4 and Sections 4.8, B.1.1 and B.2.3.6 are revised to identify this exception.

References

1. FPL letter L-2002-165, Response to NRC Request for Additional Information for Review of the St. Lucie Units 1 and 2 License Renewal Application, dated October 10, 2002, ADAMS Accession No. ML022890450
2. pc-CRACK, Version 4.1 CS, Structural Integrity Associates, Inc., 2013
3. pc-CRACK, Version 5.0 CS, Structural Integrity Associates, Inc., 2020
4. W. J. Mills, Critical Review of Fatigue Crack Growth Rates for Stainless Steel in Deaerated Water - Parts 1 and 2, EPRI MRP-2010 Conference and Exhibition:

Materials Reliability in PWR Nuclear Power Plants, Colorado Springs, CO, June 28 -

July 01, 2010

5. ASME Section XI Code Case N-809, "Reference Fatigue Crack Growth Rate Curves for Austenitic Stainless Steels in Pressurized Water Reactor EnvironmentsSection XI, Division 1," Approval date June 23, 2015
6. Materials Reliability Program: Technical Basis for ASME Section XI Code Case N-838 Flaw Tolerance Evaluation of Cast Austenitic Stainless Steel (CASS) Piping Components (MRP-362). EPRI, EPRI, Palo Alto, CA: 2013. 3002000672.
7. Code Case N-838, Flaw Tolerance Evaluation of Cast Austenitic Stainless Steel Piping, ASME Code Section XI, Division 1
8. Letter from Shakur A. Walker (NRC) to Mano Nazar (NextEra Energy), Saint Lucie Plant Unit 1 - U. S. Nuclear Regulatory Commission Post-Approval Site Inspection for License Renewal, Inspection Report 05000335/2015010, dated January 4, 2016, ADAMS Accession No. ML16004A248
9. Letter from Brian R. Bonser (NRC) to Mano Nazar (Florida Power & Light Company),

Saint Lucie Plant Unit 2 - U. S. Nuclear Regulatory Commission Post-Approval Site Inspection for License Renewal, Inspection Report 05000389/2017009, dated November 30, 2017, ADAMS Accession No. ML17334A308

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 10 Page 6 of 11 SLRA Table 3.1-1, page 3.1-31 is revised as follows:

Table 3.1-1: Summary of Aging Management Evaluations for the Reactor Vessel, Internals, and Reactor Coolant System Item Component Aging Aging Management Further Evaluation Discussion Number Effect/Mechanism Program / TLAA Recommended 3.1-1, 050 Cast austenitic stainless Loss of fracture AMP XI.M12, No Consistent with NUREG-2191 with steel Class 1 piping, toughness due to "Thermal Aging exception. The Bolting IntegrityThermal piping components thermal aging Embrittlement of Cast Aging Embrittlement of Cast Austenitic (including pump casings embrittlement Austenitic Stainless Stainless Steel AMP is used to manage and control rod drive Steel (CASS)" loss of fracture toughness due to pressure housings) thermal aging embrittlement preload due exposed to reactor to thermal effects, gasket creep, and coolant >250 °C (>482 °F) self-loosening in the steel pressurizer manway cover bolts and steel closure bolting for RCS piping components exposed to air-indoor uncontrolled for the CASS Unit 2 surge line nozzle safe end, Class 1 piping components, and reactor coolant pump casing and covers exposed to reactor coolant >250 °C

(>482 °F).

SLRA Table 3.1.2-3, page 3.1-71 is revised as follows:

Table 3.1.2-3: Pressurizers - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging Management NUREG-2191 Table 1 Notes Function Requiring Program Item Item Management Surge nozzle safe Pressure CASS Reactor coolant Loss of fracture Thermal Aging IV.C2.R-52 3.1-1, 050 AB end (Unit 2) boundary (int) toughness Embrittlement of Cast Austenitic Stainless Steel (B.2.3.6)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 10 Page 7 of 11 SLRA Table 3.1.2-3, page 3.1-73 is revised as follows:

General Notes A. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

B. Consistent with component, material, environment, aging effect, and AMP listed for NUREG 2191 line item. AMP has exceptions to NUREG 2191 AMP description.

C. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

E. Consistent with NUREG-2191 material, environment, and aging effect but a different AMP is credited or NUREG-2191 identifies a plant-specific AMP.

G. Environment not in NUREG-2191 for this component and material.

SLRA Table 3.1.2-4, page 3.1-80 is revised as follows:

Table 3.1.2-4: Reactor Coolant Piping - Summary of Aging Management Evaluation Component Type Intended Function Material Environment Aging Effect Aging Management NUREG-2191 Table Notes Requiring Program Item 1 Item Management Piping Pressure boundary CASS Reactor Loss of fracture Thermal Aging IV.C2.R-52 3.1-1, AB coolant (int) toughness Embrittlement of 050 Cast Austenitic Stainless Steel (B.2.3.6)

SLRA Table 3.1.2-4, page 3.1-83 is revised as follows:

Table 3.1.2-4: Reactor Coolant Piping - Summary of Aging Management Evaluation Component Type Intended Function Material Environment Aging Effect Aging Management NUREG-2191 Table Notes Requiring Program Item 1 Item Management Pump casing and Pressure boundary CASS Reactor Loss of fracture Thermal Aging IV.C2.R-52 3.1-1, AB cover coolant (int) toughness Embrittlement of 050 Cast Austenitic Stainless Steel (B.2.3.6)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 10 Page 8 of 11 SLRA Table 3.1.2-4, page 3.1-88 is revised as follows:

General Notes A. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

B. Consistent with component, material, environment, aging effect, and AMP listed for NUREG 2191 line item. AMP has exceptions to NUREG 2191 AMP description.

C. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

E. Consistent with NUREG-2191 material, environment, and aging effect but a different AMP is credited or NUREG-2191 identifies a plant-specific AMP.

G. Environment not in NUREG-2191 for this component and material.

SLRA Table 3.2-1, page 3.2-20 is revised as follows:

Table 3.2-1: Summary of Aging Management Evaluations for the Engineered Safety Features Item Component Aging Aging Management Further Discussion Number Effect/Mechanism Program / TLAA Evaluation Recommended 3.2-1, 010 Cast austenitic Loss of fracture AMP XI.M12, No Consistent with NUREG-2191 with exception.

stainless steel toughness due to "Thermal Aging This item applies to components in the Auxiliary piping, piping thermal aging Embrittlement of Systems. The Thermal Aging Embrittlement of components embrittlement Cast Austenitic Cast Austenitic Stainless Steel AMP is used to exposed to treated Stainless steel manage loss of fracture toughness of CASS borated water (CASS)" components exposed to treated borated water

>250°C (>482°F), with temperatures greater than 250°C (482°F).

treated water

>250°C (>482°F)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 10 Page 9 of 11 SLRA Table 3.3.2-1, page 3.3-92 is revised as follows:

Table 3.3.2-1: Chemical and Volume Control - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging Management NUREG-2191 Table 1 Notes Function Requiring Program Item Item Management Valve body Pressure CASS Treated borated Loss of fracture Thermal Aging V.D1.E-47 3.2-1, 010 AB boundary water >482°F toughness Embrittlement of (int) Cast Austenitic Stainless Steel (B.2.3.6)

SLRA Table 3.3.2-1, page 3.3-93 is revised as follows:

General Notes A. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

B. Consistent with component, material, environment, aging effect, and AMP listed for NUREG 2191 line item. AMP has exceptions to NUREG 2191 AMP description.

C. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

SLRA Table 3.3.2-10, page 3.3-217 is revised as follows:

Table 3.3.2-10: Sampling - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging Management NUREG-2191 Table 1 Notes Function Requiring Program Item Item Management Valve body (Unit 2 Pressure CASS Treated borated Loss of fracture Thermal Aging V.D1.E-47 3.2-1, 010 AB only) boundary water >482°F toughness Embrittlement of Cast (int) Austenitic Stainless Steel (B.2.3.6)

General Notes A. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

B. Consistent with component, material, environment, aging effect, and AMP listed for NUREG 2191 line item. AMP has exceptions to NUREG 2191 AMP description.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 10 Page 10 of 11 SLRA Section 4.8, page 4.8-4 adds the following two references:

4.8.48 Letter from Shakur A. Walker (NRC) to Mano Nazar (NextEra Energy), Saint Lucie Plant Unit 1 - U. S. Nuclear Regulatory Commission Post-Approval Site Inspection for License Renewal, Inspection Report 05000335/2015010, dated January 4, 2016, ADAMS Accession No. ML16004A248 4.8.49 Letter from Brian R. Bonser (NRC) to Mano Nazar (Florida Power & Light Company), Saint Lucie Plant Unit 2 - U. S. Nuclear Regulatory Commission Post-Approval Site Inspection for License Renewal, Inspection Report 05000389/2017009, dated November 30, 2017, ADAMS Accession No. ML17334A308 SLRA Section B.1.1, page B-6 is revised as follows:

The following programs each have exception(s) justified by technical data:

  • PSL Reactor Head Closure Stud Bolting AMP (Section B.2.3.3),
  • Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (Section B.2.3.6),
  • PSL Outdoor and Large Atmospheric Metallic Storage Tank AMP (Section B.2.3.17),
  • PSL Fuel Oil Chemistry AMP (Section B.2.3.18),
  • PSL Reactor Vessel Material Surveillance AMP (Section B.2.3.19),
  • PSL Structures Monitoring AMP (Section B.2.3.33)

SLRA Table B-4, page B-20 is revised as follows:

Table B-4 PSL Aging Management Program Consistency with NUREG-2191 PSL Aging Section PSL NUREG-2191 Comparison Management Plant-Specific? NUREG-2191 Enhancements? Exceptions?

Program Section Thermal Aging B.2.3.6 No XI.M12 No NoYes Embrittlement of Cast Austenitic Stainless Steel SLRA Section B.2.3.6, page B-62 is revised as follows:

NUREG-2191 Consistency The PSL Thermal Aging Embrittlement of Cast Austenitic Stainless Steel AMP is consistent without exception to the 10 elements of NUREG-2191,Section XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel as modified by SLR-ISG-2021-02-Mechanical, Updated Aging Management Criteria for Mechanical Portions of Subsequent License Renewal Guidance.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 10 Page 11 of 11 SLRA Section B.2.3.6, Exceptions to NUREG-2191 section, page B-63 is revised as follows:

Exceptions to NUREG-2191 None.The PSL Thermal Aging Embrittlement of Cast Austenitic Stainless Steel AMP will take the following exception to the NUREG-2191 guidance:

The PSL Thermal Aging Embrittlement of Cast Austenitic Stainless Steel AMP will take an exception to Element 5, Acceptance Criteria, included in Appendix C of (ISG) SLR-ISG-2021-02-Mechanical, Updated Aging Management Criteria for Mechanical Portions of Subsequent License Renewal Guidance.

Specifically, Appendix C of the ISG was revised to add the 2019 Edition of the ASME Code, Non-mandatory Appendix C, which provides flaw evaluation procedures for CASS with ferrite content 20 percent. Those procedures may be used for flaw evaluations or flaw tolerance evaluations in this program until Appendix C to the 2019 Edition of ASME Code,Section XI is incorporated by reference in 10 CFR 50.55a.

In lieu of using the criteria for CASS piping components provided in ASME Code,Section XI, Appendix C, 2019 edition, the PSL SLR evaluation used the same criteria as the flaw tolerance evaluation of CASS piping in the 60-year license renewal application for the 80-year SLRA. The flaw tolerance acceptance criteria used in both the 60-year evaluation for initial license renewal and 80-year evaluation for subsequent license renewal was based on the technical guidance provided in MRP-362 which formed the basis for ASME Code,Section XI Code Case N-838.

There are two reasons for adopting this approach for the PSL SLR. The first reason is to maintain consistency between the 60-year and the 80-year CASS flaw tolerance evaluations. The second reason is that the flaw acceptance criteria used in the 60-year evaluation was verified by the NRC in support of the initial license renewal application and should, therefore, be considered acceptable for the 80-year evaluation. The review by the NRC of the CASS piping flaw tolerance acceptance criteria for the 60-year license renewal for PSL Unit 1 is documented in Reference 4.8.48 under Commitment 8. Similarly, the review by the NRC of the CASS piping flaw tolerance acceptance criteria for the 60-year license renewal for St. Lucie Unit 2 is documented in Reference 4.8.49 under Commitment 7.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 11 Page 1 of 4 Fatigue Monitoring AMP - Clarification of Enhancements Affected SLRA Sections: B.2.2.1, Table 19-3 of Appendix A2 SLRA Page Numbers: B-25, B-26, A2-65 Description of Change:

The first enhancement to Element 3, Parameters Monitored or Inspected, of the Fatigue Monitoring program updates the program governing procedure in order to monitor the chemistry parameters that provide inputs to environmental fatigue correction factors (Fen) used in environmental cumulative usage factor (CUFen) calculations. The enhancement identifies reactor coolant dissolved oxygen and sulfate concentration chemistry parameters as those requiring monitoring. Upon further review, the reactor coolant sulfate concentration does not require monitoring as it is not used as an input parameter for the PSL calculations of Fen and CUFen values. The sulfate concentration input used in the PSL calculations is the sulfur content (wt%) in the steel material consistent with the guidance in NUREG/CR-6909, Revision 1.

Therefore, monitoring of the reactor coolant sulfate chemistry is not required and clarifying text is added to this enhancement in SLRA Section B.2.2.1.

The enhancement related to Element 6, Acceptance Criteria, of the Fatigue Monitoring program updates the program governing procedure to add an additional acceptance criterion associated with high-energy line break (HELB) CUF criteria for PSL Unit 2. This enhancement is not required as the acceptance criteria for the PSL Fatigue Monitoring program is consistent with the general acceptance criteria specified in Element 6 of NUREG-2191 Section X.M1.

Therefore, this enhancement is deleted from SLRA Table 19-3 of Appendix A2 and SLRA Section B.2.2.1.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 11 Page 2 of 4 SLRA Appendix A2, Section 19.4, commitment No. 1 portion of Table 19-3 beginning on page A2-65, is revised as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 1 Fatigue Monitoring (19.2.1.1) X.M1 Continue the existing PSL Fatigue Monitoring AMP, including No later than 6 months prior to enhancement to: the SPEO, or no later than the last refueling outage prior to a) Update the plant procedure to monitor chemistry parameters that the SPEO i.e.:

provide inputs to Fen factors used in CUFen calculations.

PSL2: 10/06/2042 b) Update the plant procedure to identify and require monitoring of the 80-year projected plant transients that are utilized as inputs to CUFen calculations.

c) Update the plant procedure to monitor and track the loss of letdown flow transient during the SPEO.

d) Update the plant procedure to identify the corrective action options to take if component specific fatigue limits are approached.

e) Update the plant procedure to add additional acceptance criterion associated with HELB CUF criteria.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 11 Page 3 of 4 SLRA Section B.2.2.1, page B-25 is revised as follows:

Enhancements The PSL Fatigue Monitoring AMP will be enhanced as follows, for alignment with NUREG-2191. The enhancements are to be implemented no later than 6 months prior to entering the SPEO.

Element Affected Enhancement

3. Parameters Monitored or Update the AMP governing procedure to monitor the chemistry Inspected parameters that provide inputs to Fen factors used in CUFen calculations. Thisese chemistry parameters includes reactor coolant dissolved oxygen and sulfate and are which is controlled and tracked in accordance with the PSL Water Chemistry (Section B.2.3.2) AMP.
3. Parameters Monitored or Update the AMP governing procedure to identify and require Inspected monitoring of the 80-year plant design cycles, or projected cycles that are utilized as inputs to component CUFen calculations, as applicable.
3. Parameters Monitored or Update the plant procedure to monitor and track the loss of Inspected letdown flow transient during the SPEO.
5. Monitoring and Trending Update the AMP governing procedure to identify the corrective action options if the values assumed for fatigue parameters are approached, transient severities exceed the design or assumed severities, transient counts exceed the design or

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 11 Page 4 of 4 SLRA Section B.2.2.1, page B-26 is revised as follows:

Element Affected Enhancement assumed quantities, transient definitions have changed, unanticipated new fatigue loading events are discovered, or the geometries of components are modified.

6. Acceptance Criteria Update the AMP governing procedure to add an additional acceptance criterion associated with HELB CUF criteria.

(Unit 2 only)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 12 Page 1 of 1 ASME Section XI Inservice Inspection, Subsections IWB, IWC, IWD: Clarified Discussion of Operating Experience for Pressurizer Manway Studs Affected SLRA Sections: B.2.3.1 SLRA Page Numbers: B-40 Description of Change:

As described in the Plant Specific Operating Experience section of PSL SLRA Section B.2.3.1 for the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD AMP, review of the last five years of Owners Activity Reports (OARs) identified no flaws nor any other significant issues during the time period. However, a clarification is warranted regarding the repeated instances of pressurizer manway stud replacements. These stud replacements are not due to aging but are performed as a convenience for inservice inspection purposes. The pressurizer manways are removed every outage to provide a reactor coolant system vent path, and typically four of the twenty-four studs are removed and replaced each outage for inspection.

Accordingly, SLRA Section B.2.3.1 is revised to add this clarification.

SLRA Section B.2.3.1, page B-40, is revised as follows:

Plant Specific Operating Experience

  • Owners Activity Reports (OARs) were reviewed over the last five years (2015-2020). There were no flaws identified nor any other significant issues reported during this time period. As a clarification regarding the repeated replacement of pressurizer manway studs, the stud replacements are not due to aging, but are performed as a convenience for inservice inspection purposes. The pressurizer manways are removed every outage to provide a reactor coolant system vent path, and typically four of the twenty-four studs are removed and replaced each outage for inspection.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 13 Page 1 of 2 Reactor Head Closure Stud Bolting: Clarified Exceptions Affected SLRA Sections: B.2.3.3 SLRA Page Numbers: B-48 Description of Change:

As described in PSL SLRA Section B.2.3.3 for the Reactor Head Closure Stud Bolting AMP, an exception to Element 4 of Section XI.M3 of the GALL-SLR is taken due to a relief request that impacts the requirements of Table IWB-2500-1.

However, for XI.M3, the GALL-SLR discusses the frequency of inspections per Table IWB-2500-1 in both Elements 4 (Detection of Aging Effects) and 5 (Monitoring and Trending).

Since Element 5 of the Reactor Head Closure Stud Bolting AMP also discusses the frequency of inspections required in Table IWB-2500-1, an exception to Element 5 will be added due to the same relief request discussed in the SLRA.

Accordingly, SLRA Section B.2.3.3 is revised to add an exception to Element 5.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 13 Page 2 of 2 SLRA Section B.2.3.3, page B-48, is revised as follows:

2. For Element 4, Detection of Aging Effects, and Element 5, Monitoring and Trending, relief for the Unit 1 Fifth 10-Year ISI Interval and Unit 2 Fourth 10-Year ISI Interval has been requested from the schedule of reactor pressure vessel (RPV) bolting examinations specified in ASME Section XI Code, Table IWB-2500-1, Category B-G-1, and IWB-2420, in order to accommodate an additional set of reactor vessel closure studs, nuts, and washers that are shared between PSL Units 1 and 2 in rotation. Use of three sets of reactor vessel closure studs, nuts, and washers does not make it feasible to maintain an inspection cycle which meets the requirements of successive examinations per ASME Section XI, IWB-2420(a). Note that PSL Units 1 and 2 were granted similar relief for the Fourth and Third 10-Year ISI Intervals respectively.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 14 Page 1 of 2 Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components AMP Clarification of Industry OE Affected SLRA Sections: B.2.3.5 SLRA Page Numbers: B-59 Description of Change:

Additional industry operating experience discussion is required related to an update to EPRI Technical Report 3002012244, Nondestructive Evaluation: Guideline for Conducting Ultrasonic Examinations of Dissimilar Metal Welds, published in February 2018.

Accordingly, SLRA B.2.3.5 is revised to add discussion of PSLs review and implementation of this guidance.

SLRA Section B.2.3.5, page B-59 is revised as follows:

Industry OE and information from NSSS vendors is evaluated for effect on inspection requirements. Industry OE includes:

  • IN 2005-02 (NRC Event 41048): Pressure Boundary Leakage at Steam Generator Bowl Drain Welds. This NRC event was evaluated for PSL under an AR. PSL Units 1 and 2 do not contain pressure boundary drain nozzles in the steam generator bowls. However, the PSL Unit 2 steam generator did at the time have eight instrument nozzles in the cold leg bowls that were made of alloy 600 material. These nozzles were already identified and were part of the boric acid walkdown visual inspections in each refueling outage (with insulation in place). Since these were cold leg nozzles, they were of lower susceptibility than the hot leg temperature Catawba Unit 2 nozzles. However, they were added to the next Unit 2 refueling outage for bare metal visual inspection. These Unit 2 alloy 600 nozzles were replaced with alloy 690 as part of the steam generator replacement in 2007. The Unit 1 replacement steam generators already had incorporated alloy 690 instrument cold leg nozzles in the design.
  • IN 2006-27 (NSAL-06-8), Circumferential Cracking in the Stainless Steel Pressurizer Heater Sleeves of Pressurized Water Reactors. This issue is only applicable to pressurizer heater sleeves made of SS. PSL pressurizer heater sleeves are alloy 690 (Unit 1) and alloy 600 (Unit 2). These nickel-based materials are not subject to the same SCC mechanisms as the SS pressurizer heater sleeve penetrations; therefore, there were no implications or impact to PSL Units 1 or 2.
  • NRC Regulatory Issue Summary 2008-25 (October 2, 2008) Regulatory Approach For Primary Water Stress Corrosion Cracking Of Dissimilar Metal Butt Welds In Pressurized Water Reactor Primary Coolant System Piping described the regulatory approach for ensuring the integrity of primary coolant system dissimilar metal (DM) butt welds containing Alloy 82/182 in pressurized-water reactor (PWR) power plants. This RIS concluded that

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 14 Page 2 of 2 MRP-139 and the MRP interim guidance letters, with the exception of the reinspection interval for unmitigated pressurizer DM butt welds as addressed by the Confirmatory Action Letters (CALs), provide adequate protection of public health and safety for addressing PWSCC in butt welds for the near term pending incorporation by reference into 10 CFR 50.55a of an ASME Code Case containing comprehensive inspection requirements. PSL follows MRP-139 and therefore also addressed PWSCC in butt welds applicable to this IN.

  • EPRI Technical Report 3002012244, Revision 3, Nondestructive Evaluation: Guideline for Conducting Ultrasonic Examinations of Dissimilar Metal Welds, published in February 2018, was issued in response to industry issues regarding the performance of dissimilar metal weld examinations. The update to this EPRI TR resulted in a requirement to perform encoded phased array examinations on uncracked butt welds and mitigated cracked butt welds. These guidelines will be implemented through the fleet dissimilar metal weld guidance via an implementing procedure. This procedure provides a decision tool for selecting the appropriate examination technology (encoded or non-encoded) for welds with stress corrosion cracking susceptibility.

10CFR50.55a(g)(6)(ii)(F) covers examination requirements for Class 1 piping and nozzle dissimilar metal butt welds which is required for PWR as of or after June 3, 2020. 10CFR50.55a(g)(6)(ii)(F) requires implementation of Code Case N-770-5. This Code Case requires encoded ultrasonic examination of non-mitigated or cracked mitigated dissimilar metal butt welds. This applies to both PSL Units 1 and 2.

  • NRC Regulator Issue Summary 2018-06 (December 2018) Clarification of the Requirements for Reactor Pressure Vessel Upper Head Bare Metal Visual Examinations clarified the requirements for bare-metal visual examination to meet the requirements of Notes 1 and 4 in Table 1 of American Society of Mechanical Engineers (ASME) Code Case N-729-4. As identified in the RIS, some recent events illustrate how the requirements of Code Case N-729-4 can be misinterpreted by licensees. The clarification from this RIS for the requirements for the RPV upper head has been incorporated in fleet NDE procedures.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 15 Page 1 of 4 Reactor Vessel Internals Aging Management Review Clarifications Affected SLRA Sections: Table 3.1.2-2 SLRA Page Numbers: 3.1-59, 3.1-61, 3.1-62 Description of Change:

PSL SLRA Table 3.1.2-2 does not fully address the applicable aging effects for each reactor vessel internal (RVI) component. In the case of the core shroud tie rods, Table 3.1.2-2 identifies cracking, loss of material, and changes in dimension as applicable aging effects requiring management. This is inconsistent with the aging effects identified in Appendix C of the SLRA which includes those aging effects listed in Table 3.1.2-2 as well as loss of fracture toughness and loss of preload. The aging effects cited in Appendix C for the core shroud tie rods are correct. Accordingly, SLRA Table 3.1.2-2 is revised to include the additional aging effects identified as applicable in Appendix C.

In the case of the core support plate, Table 3.1.2-2 cites cracking and loss of fracture toughness as the applicable aging effects requiring management. Based on MRP-191, Revision 2, these aging effects are applicable in addition to loss of material and changes in dimension.

Accordingly, SLRA Table 3.1.2-2 is revised to include the additional aging effects.

In the case of the fuel alignment plates, Table 3.1.2-2 identifies cracking, loss of material, and changes in dimension as applicable aging effects requiring management. This is inconsistent with the aging effects identified in Appendix C of the SLRA which cites cracking, loss of material, and loss of fracture toughness. The aging effects cited in Appendix C for the fuel alignment plate are correct. Accordingly, SLRA Table 3.1.2-2 is revised to include the aging effects identified as applicable in Appendix C.

The stainless steel core support columns are recognized in Table 3.1.2-2 as subjected to the aging effects of cracking and loss of fracture toughness. These statements are accurate but do not fully reflect the detailed screening which supports them. The PSL Unit 1 core support columns are cast austenitic stainless steel (CASS) and the PSL Unit 2 core support columns are stainless steel. As such, each of these components are subject to the aging effect of loss of fracture toughness. The Unit 1 CASS core support columns are subject loss of fracture toughness due to irradiation embrittlement as well as loss of fracture toughness due to thermal aging embrittlement. The Unit 2 stainless steel core support columns are subject to loss of fracture toughness due to irradiation embrittlement. Table 3.1.2-2 only recognizes aging effects and does not list degradation mechanisms. As such, all applicable aging effects are adequately addressed by NUREG-2191 item IV.B3.RP-364 which cites the applicable material as Stainless steel (including CASS). There are no changes necessary to Table 3.1.2-2 and the above is included as clarifying information.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 15 Page 2 of 4 SLRA Table 3.1.2-2 on page 3.1-59 is revised as follows:

Table 3.1.2-2: Reactor Vessel Internals - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging Management NUREG-2191 Table 1 Notes Function Requiring Program Item Item Management Core shroud tie rods Structural Stainless steel Reactor coolant Cracking Reactor Vessel IV.B3.R-423 3.1-1, 118 A, 1 support Neutron flux Internals (B.2.3.7)

Water Chemistry (B.2.3.2)

Core shroud tie rods Structural Stainless steel Reactor coolant Loss of material Reactor Vessel IV.B3.R-424 3.1-1, 119 A, 1 support Neutron flux Changes in Internals (B.2.3.7) dimension Loss of fracture toughness Loss of preload

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 15 Page 3 of 4 SLRA Table 3.1.2-2 on page 3.1-61 is revised as follows:

Table 3.1.2-2: Reactor Vessel Internals - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging Management NUREG-2191 Table 1 Notes Function Requiring Program Item Item Management Core support plate Structural Stainless steel Reactor coolant Cracking Reactor Vessel IV.B3.RP-343 3.1-1, A support Neutron flux Internals (B.2.3.7) 052a Flow distribution Core support plate Structural Stainless steel Reactor coolant Loss of fracture Reactor Vessel IV.B3.RP-365 3.1-1, A support Neutron flux toughness Internals (B.2.3.7) 056a Flow distribution Core support plate Structural Stainless Reactor coolant Changes in Reactor Vessel IV.B3.R-424 3.1-1, 119 A, 3 support steel Neutron flux dimensions Internals (B.2.3.7)

Flow Loss of distribution material

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 15 Page 4 of 4 SLRA Table 3.1.2-2 on page 3.1-62 is revised as follows:

Table 3.1.2-2: Reactor Vessel Internals - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging Management NUREG-2191 Table 1 Notes Function Requiring Program Item Item Management Fuel alignment plate Structural Stainless steel Reactor coolant Cracking Reactor Vessel IV.B3.R-423 3.1-1, 118 A, 2 support Neutron flux Internals (B.2.3.7)

Water Chemistry (B.2.3.2)

Fuel alignment plate Structural Stainless steel Reactor coolant Loss of material Reactor Vessel IV.B3.R-424 3.1-1, 119 A, 2 support Neutron flux Changes in Internals (B.2.3.7) dimension Loss of fracture toughness SLRA Page 3.1-63 is revised as follows:

Plant Specific Notes

1. Per Appendix C these components are added to the Primary inspection category in the Reactor Vessel Internals AMP.
2. Per Appendix C the fuel alignment plate is added to the Expansion category in the Reactor Vessel Internals AMP.
3. Per Appendix C, the newly screened in aging effects are managed by the Reactor Vessel Internals AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 16 Page 1 of 2 Flow-Accelerated Corrosion Affected SLRA Sections: B.2.3.11 SLRA Page Numbers: B-96 Description of Change:

SLRA Section B.2.3.11 is revised to clarify that the Intake Cooling Water AMP manages aging effects for piping greater than or equal to 20 inches in diameter, and the vents, drains, and instrument lines associated with this piping.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 16 Page 2 of 2 SLRA Section B.2.3.11, page B-96 is revised as follows:

Program Description The PSL Open-Cycle Cooling Water System AMP is an existing AMP, previously part of the Intake Cooling Water System Inspection Program and the Periodic Surveillance and Preventive Maintenance (PSPM) Program, that manages the effects of aging on internal piping component surfaces exposed to a raw water environment from the intake cooling water (ICW) system. The PSL Open-Cycle Cooling Water System AMP applies to components constructed of various materials, including steel (e.g., carbon steel and gray cast iron), SS, nickel alloy (Monel), copper alloys (including copper alloys with greater than 8 % Aluminum or greater than 15% Zn), and fiberglass. The components managed by this include the ICW system piping/fittings and valves with a diameter greater than or equal to 20-inches, vents, drains, and instrument lines associated with the piping greater than or equal to 20-inches, ICW strainers, component cooling water (CCW) heat exchangers (tube side), ICW orifices and thermowells, the connections between small bore and large bore piping, the turbine cooling water (TCW) heat exchangers ICW system isolation valves, and the casings of the ICW pumps.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 17 Page 1 of 2 Bolting Integrity: Clarified Excessive and added Confirmatory Statements Affected SLRA Sections: 19.2.2.9, B.2.3.9 SLRA Page Numbers: A1-17, A2-17, B-83 Description of Change:

For XI.M18 of the GALL-SLR, Element 3 (Parameters Monitored or Inspected) states that a Bolting Integrity program monitors the effects of aging on the intended function of closure bolting. In addition, Element 4 (Detection of Aging Effects) and Element 5 (Monitoring and Trending) discuss maintaining the components intended functions.

The RAI response for Point Beach Nuclear (PBN) (Supplement 1, Attachment 9, NEPB letter L-2021-81 dated 4/21/21, ADAMS Accession No. ML21111A155) replaced the phase leakage becomes excessive with a loss of components intended functions can occur.

Accordingly, SLRA Section 19.2.2.9 is revised to replace the phase leakage becomes excessive with a loss of components intended functions can occur.

An enhancement related to update of procedure(s) to ensure that lubricants containing molybdenum disulfide (disulfide or polysulfide) or other lubricants containing sulfur will not be used on pressure-retaining bolted joints requires clarification. The approved lubricants at PSL for threaded fasteners on pressure boundaries are Neolube for stainless steel and Fel-Pro N-5000 for carbon and alloy steel, neither of which include molybdenum disulfide or other lubricants containing sulfur. Therefore, a confirmatory statement will be added to this existing enhancement.

Accordingly, this confirmatory declaration is added to SLRA Section B.2.3.9 in the subject enhancement.

A search of the plant database identified the Unit 1 and Unit 2 reactor coolant pumps (RCPs) and the Unit 2 main steam isolation valves as potential locations with high-strength bolting (greater than 2 inches in diameter with a suspected yield strength greater than 150 ksi). No evidence of the use of high-strength steel closure bolting in the engineered safety features systems and auxiliary systems was found.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 17 Page 2 of 2 SLRA Section 19.2.2.9, page A1-17, 3rd paragraph, is revised as follows:

This AMP supplements the inspection activities required by ASME Code Section XI for ASME Code Class 1, 2 and 3 bolting. For ASME Code Class 1, 2, and 3, and non-ASME Code class bolts, periodic system walkdowns and inspections are performed at least once per refueling cycle to provide reasonable assurance that indications of loss of preload (leakage), cracking, and loss of material are identified before leakage becomes excessive a loss of components intended functions can occur.

SLRA Section 19.2.2.9, page A2-17, 3rd paragraph, is revised as follows:

This AMP will supplement the inspection activities required by ASME Code Section XI for ASME Code Class 1, 2 and 3 bolting. For ASME Code Class 1, 2, and 3, and non-ASME Code class bolts, periodic system walkdowns and inspections are performed at least once per refueling cycle to provide reasonable assurance that indications of loss of preload (leakage), cracking, and loss of material are identified before leakage becomes excessivea loss of components intended functions can occur.

SLRA Section B.2.3.9, page B-83, Enhancements, is revised as follows:

Element Affected Enhancement

2. Preventive Actions Currently approved lubricants for PSL threaded fasteners do not include molybdenum disulfide or other lubricants containing sulfur. Update of procedure(s) to prohibitensure that lubricants containing molybdenum disulfide (disulfide or polysulfide) or other lubricants containing sulfur from being will not be used on pressure-retaining bolted joints will ensure that this requirement is maintained in the future.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 1 of 38 Steam Generators: Clarified AMR Results and AMP Scope Affected SLRA Sections: Table 2.3.1-5, Table 3.1-1, Table 3.1.2-5, Table 19-3, 19.2.2.10 (Appendices A1 and A2), B.1.1, Table B-4, B.2.3.10, B.2.3.20 SLRA Page Numbers: 2.3-13, 3.1-23, 3.1-27, 3.1-37, 3.1-38, 3.1-39, 3.1-42, 3.1-45, 3.1-89 through 3.1-101, A1-18, A1-19, A1-71, A2-18, A2-19, A2-72, B-6, B-20, B-88 through B-91, B-92, B-93, B-95, B-174 Description of Change:

The PSL SLRA Table 2.3.1-5 lists the intended functions of the tube bundle wrapper and wrapper supports as Structural support and Direct flow. In Table 3.1.2-5, the intended function of the tube bundle wrapper and wrapper supports only lists Structural support. Table 2.3.1-5 is accurate and as such SLRA Table 3.1.2-5 is modified to include the intended function of Direct flow in the line entry for the tube bundle wrapper and wrapper support.

PSL SLRA Appendices A1 and A2 Section 19.2.2.10 cite that the PSL Steam Generators AMP is modeled after NEI 97-06, Steam Generator Program Guidelines and the referenced EPRI Guidelines of NEI 97-06. These sections are edited to specify that the Steam Generators AMP is modeled after Revision 3 of NEI 97-06 consistent with SLRA general reference 1.6.32 on SLRA page 1-15.

Further evaluation item 3.1.2.2.11.1 evaluates the PSL steam generator divider plates with respect to PWSCC susceptibility and whether or not a plant-specific AMP is necessary. The Unit 1 RSG design includes a floating divider plate that has no crack initiation point. The Unit 2 RSG divider plate design utilizes highly resistant materials. Both Unit 1 and Unit 2 RSG divider plates are dispositioned as not requiring additional aging management from a plant-specific AMP. PSL SLRA Section B.2.3.20 summarizes this disposition and correctly cites that no plant-specific AMP is necessary but does not cite the associated justifications. Accordingly, SLRA Section B.2.3.20 is revised to cite the associated justifications provided in further evaluation item 3.1.2.2.11.1. In addition, plant specific note 1 to Table 3.1.2-5 is clarified to recognize that the nickel alloy divider plate is highly resistant but remains susceptible to PWSCC.

The Unit 1 stainless steel divider plate exposed to reactor coolant is susceptible to loss of material and cracking. The line items in Table 3.1.2-5 do not address the aging effect of loss of material in the Unit 1 divider plate. To recognize the aging effect and appropriate aging management program, an additional line item is added to Table 3.1.2-5 citing NUREG-2191 item IV.C2.RP-23 which credits the Water Chemistry program to manage loss of material.

Further evaluation item 3.1.2.2.11.2 evaluates the PSL steam generator tube-to-tubesheet welds with respect to PWSCC and whether or not a plant-specific AMP is necessary. Both Unit 1 and Unit 2 steam generators are dispositioned to not require additional management from a plant-specific AMP but remain susceptible to PWSCC and require management by the Steam Generators and Water Chemistry AMPs. Accordingly, SLRA Table 2.3.1-5, Table 3.1-1, and Table 3.1.2-5 are modified to identify that the tube-to-tubesheet welds are in scope, susceptible to PWSCC and loss of material, and managed by the Steam Generators and Water Chemistry AMPs. In addition, discussions of the Steam Generators AMP in PSL SLRA Appendices A1 and A2 Section 19.2.2.10, and Appendix B Section B.2.3.10 are modified to identify that the tube-to-tubesheet welds are within the scope of the AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 2 of 38 The PSL steam generator component type feedwater feedring included in SLRA Table 2.3.1-5 does not fully address the feedwater feedring and its supports. The feedwater feedring includes intended functions of Structural integrity (attached) as well as Direct flow. The associated feedwater feedring supports have an intended function of Structural integrity (attached). In addition, the Unit 2 feedwater feedring is composed of stainless steel and the supports are carbon steel. To clarify this, the component type feedwater feedring supports is added in SLRA Tables 2.3.1-5, 3.1-1, and 3.1.2-5 and the appropriate intended functions and material types are identified for the feedwater feedring supports. The discussion in SLRA Table 3.1-1 for item 072 is revised to distinguish the group of components that are common to both units and those components that are only applicable to Unit 1. In addition, Appendix B Section B.2.3.10 is revised to discuss Unit 1 operating experience regarding feedwater feedring support inspections.

The PSL Steam Generators AMP remedies steam generator tubes which do not satisfy the performance criteria through tube plugging. The scope of the Steam Generators AMP is clarified in SLRA Sections Appendices A1 and A2 Section 19.2.2.10, and Appendix B Section B.2.3.10.

The PSL Steam Generators AMP inspections are performed in accordance with the Degradation Assessment for both the primary-side and secondary-side components. This is clarified in SLRA Section B.2.3.10.

The implementation schedule for the Steam Generators AMP includes a condition that it will be implemented no later than the last refueling outage prior to the SPEO. However, there are no enhancements or SLR-specific inspections required to be implemented prior to entry into the SPEO. To clarify the state of the AMP, this condition is removed from the implementation schedule in SLRA Table 19-3.

SLRA Tables 2.3.1-5, 3.1-1, and 3.1.2-5 include the component type Tube support plates and anti-vibration bars (Unit 2). While the tube support plates are unique to Unit 2, anti-vibration bars are an applicable component type for both Unit 1 and Unit 2. The component type of anti-vibration bars is inclusive of the design specific names of anti-vibration support components such as the flat fan bars used by the Unit 1 design and v-shaped support pads and bars used for the Unit 2 design. This is clarified in SLRA Tables 2.3.1-5, 3.1-1, and 3.1.2-5.

The PSL steam generators are susceptible to cumulative fatigue damage and cracking due to fatigue or cyclic loading. Table 3.1.2-5 includes NUREG-2191 line item IV.D1.R-221 to recognize the primary side steam generator components exposed to reactor coolant being managed for cumulative fatigue damage and cracking through the Section 4.3.1 TLAA, Metal Fatigue of Class 1 Components. In addition to the primary side components, the Section 4.3.1 TLAA addresses the secondary side carbon steel components exposed to treated water and steam and bolting exposed to air. To recognize this, NUREG-2191 line items IV.D1.R-33 and IV.C2.R-18 are added to SLRA Table 3.1.2-5 to manage the carbon steel steam generator components exposed to treated water and steam and bolting exposed to air respectively. These changes are also captured in Table 3.1-1, Item number 3.1-1, 005.

Following the submittal of the PSL SLRA, PSL submitted a license amendment request to implement Revision 5 of NUREG-1432, Standard Technical Specifications-Combustion Engineering Plants (ML21265A285) in accordance with TSTF 577 Revision 1 (ML21098A188).

Implementation of NUREG-1432 at PSL includes a new interval for the inspection period for the steam generator tubes. Following NRC review and approval of the license amendment request,

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 3 of 38 including any applicable conditions or limitations, implementation of this license amendment will increase the inspection interval for 100% of the tubes to 96 EFPM. The 96 EFPM inspection interval for the tubes will also allow for visual inspection of the divider plates, tube-to-tubesheet welds, channel heads, and tubesheets in accordance with the Steam Generators AMP. SLRA Appendices A1 and A2 Section 19.2.2.10 and Appendix B Section B.2.3.10 are revised to identify the inspection frequency. SLRA Table 3.1.2-5, Section B.1.1, Section B.2.1, Section B.2.3.10, and Table B-4 are revised to identify the exception to the Steam Generators AMP.

PSL performs condition monitoring assessments to determine if tube integrity was met during the prior operating interval. PSL performs tube plugging and operational assessments to provide assurance that tube integrity will be maintained through the next inspection. SLRA Appendices A1 and A2 Section 19.2.2.10 are revised to discuss the performance of condition monitoring assessments consistent with the discussion in SLRA B.2.3.10.

SLRA Table 2.3.1-5 on page 2.3-13 is revised as follows:

Table 2.3.1-5 Steam Generator Components Subject to Aging Management Review Component Type Component Intended Function(s)

Anti-vibration bars Structural support Blowdown nozzles Pressure boundary Bolting Mechanical closure Conical skirt Structural support Divider plates Flow distribution Feedwater feedring Structural integrity (attached)

Direct flow Feedwater feedring supports Structural integrity (attached)

Feedwater j-nozzle Structural integrity (attached)

Direct flow Feedwater nozzle Pressure boundary Moisture separators Structural integrity (attached)

Primary heads Pressure boundary Primary inlet and outlet nozzles Pressure boundary Primary instrument nozzles Pressure boundary Primary manway covers Pressure boundary Recirculation nozzles and end caps (Unit 2) Pressure boundary Secondary instrument nozzles Pressure boundary Secondary manway and handhole closure Pressure boundary covers Stay cylinders (Unit 1) Pressure boundary Steam generator components with fatigue Pressure boundary analysis Steam generator components: external Pressure boundary surfaces Mechanical closure Steam outlet nozzle (Unit 2) Pressure boundary Steam outlet nozzle venturis (Unit 2) Throttle Steam outlet nozzle with integral flow Pressure boundary orifices (Unit 1) Throttle

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 4 of 38 Table 2.3.1-5 Steam Generator Components Subject to Aging Management Review Component Type Component Intended Function(s)

Tube bundle wrapper and wrapper supports Structural support Direct flow Tube-to-tubesheet welds Pressure boundary Tube plugs Pressure boundary Tube stabilizers (stakes) (Unit 2) Structural support Tube support lattice bars (Unit 1) Structural support Tube support plates and anti-vibration bars Structural support (Unit 2)

Tubesheets Pressure boundary Upper and lower shells, secondary head, Pressure boundary transition cone Upper vessel clevises and shear keys Structural support U-tubes Pressure boundary Heat transfer

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 5 of 38 SLRA Table 3.1-1 on page 3.1-23 is revised as follows:

Table 3.1-1: Summary of Aging Management Evaluations for the Reactor Vessel, Internals, and Reactor Coolant System Item Component Aging Aging Management Further Evaluation Discussion Number Effect/Mechanism Program / TLAA Recommended 3.1-1, 005 Steel, stainless steel, Cumulative fatigue TLAA, SRP-SLR Yes (SRP-SLR Consistent with NUREG-2191. Cumulative steel (with stainless steel damage: cracking Section 4.3 "Metal Section 3.1.2.2.1) fatigue damage of steel, stainless steel, or nickel alloy cladding) due to fatigue, cyclic Fatigue" and steel (with stainless steel cladding),

steam generator loading piping components and bolting is components, pressurizer addressed as a TLAA in Section 4.3.1.

relief tank components, Cumulative fatigue damage in the piping components, pressurizer surge line is addressed with a bolting plant specific AMP. Further evaluation is documented in Section 3.1.2.2.1.

SLRA Table 3.1-1 on pages 3.1-27 is revised as follows:

Table 3.1-1: Summary of Aging Management Evaluations for the Reactor Vessel, Internals, and Reactor Coolant System Item Component Aging Aging Management Further Evaluation Discussion Number Effect/Mechanism Program / TLAA Recommended 3.1-1, 025 Steel (with nickel alloy Cracking due to AMP XI.M2, "Water Yes (SRP-SLR Consistent with NUREG-2191 with cladding) or nickel alloy primary water SCC Chemistry," and AMP Sections 3.1.2.2.11.1 exception for the Steam Generators steam generator primary XI.M19, and AMP. The Steam Generators and Water side components: divider "Steam Generators." 3.1.2.2.11.2) Chemistry AMPs are used to manage plate and tube-to-tube In addition, a cracking due to primary water SCC in the sheet welds exposed to plant- specific tube-to-tubesheet welds and the Unit 2 reactor coolant program is to be divider plates.

evaluated. Further evaluation is documented in Section 3.1.2.2.11.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 6 of 38 SLRA Table 3.1-1 on pages 3.1-37 through 3.1-39 is revised as follows:

Table 3.1-1: Summary of Aging Management Evaluations for the Reactor Vessel, Internals, and Reactor Coolant System Item Component Aging Aging Management Further Evaluation Discussion Number Effect/Mechanism Program / TLAA Recommended 3.1-1, 068 Nickel alloy steam Changes in AMP XI.M19, "Steam No Not applicable.

generator tubes exposed dimension Generators," and The PSL steam generator tube support to secondary feedwater or ("denting") due to AMP XI.M2, "Water plates are not carbon steel.

steam corrosion of carbon Chemistry" steel tube support plate 3.1-1, 069 Nickel alloy steam Cracking due to AMP XI.M19, "Steam No Consistent with NUREG-2191 with generator tubes and outer diameter SCC, Generators," and exception for the Steam Generators sleeves exposed to intergranular attack AMP XI.M2, "Water AMP. The Steam Generators and Water secondary feedwater or Chemistry" Chemistry AMPs are used to manage steam cracking due to outer diameter SCC and intergranular attack in nickel alloy U-tubes exposed to treated feedwater and steam.

3.1-1, 070 Nickel alloy steam Cracking due to AMP XI.M19, "Steam No Consistent with NUREG-2191 with generator tubes, repair primary water SCC Generators," and exception for the Steam Generators sleeves, and tube plugs AMP XI.M2, AMP. The Steam Generators and Water exposed to reactor "Water Chemistry" Chemistry AMPs are used to manage coolant cracking due to primary water SCC in nickel alloy U-tubes, tube plugs, and Unit 2 tube stabilizers (stakes) exposed to reactor coolant.

3.1-1, 071 Steel, chrome plated Cracking due to AMP XI.M19, "Steam No Consistent with NUREG-2191 with steel, stainless steel, SCC or other Generators," and exception for the Steam Generators nickel alloy steam mechanism(s); loss AMP XI.M2, AMP. The Steam Generators and Water generator U-bend of material due "Water Chemistry" Chemistry AMPs are used to manage supports including general (steel only), cracking due to SCC, loss of material due anti-vibration bars pitting, crevice to general (steel only), pitting, and crevice exposed to secondary corrosion corrosion in stainless steel, and nickel alloy feedwater or steam steam generator components exposed to treated water and steam.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 7 of 38 Table 3.1-1: Summary of Aging Management Evaluations for the Reactor Vessel, Internals, and Reactor Coolant System Item Component Aging Aging Management Further Evaluation Discussion Number Effect/Mechanism Program / TLAA Recommended 3.1-1, 072 Steel steam generator Loss of material due AMP XI.M19, "Steam No Consistent with NUREG-2191 with tube support plate, tube to general, pitting, Generators," and exception for the Steam Generators bundle wrapper, supports crevice corrosion, AMP XI.M2, "Water AMP. The Steam Generators and Water and mounting hardware erosion, ligament Chemistry" (corrosion Chemistry AMPs are used to manage loss exposed to secondary cracking due to based aging effects of material due to general, pitting, and feedwater or steam corrosion and mechanisms only) crevice corrosion, erosion, and ligament cracking due to corrosion in the steel steam generator tube bundle wrapper and supports, feedwater feedring supports, tubesheets, Unit 1 moisture separators, tubesheets, and Unit 1 feedwater feedring exposed to treated water or steam.

3.1-1, 073 Nickel alloy steam Loss of material due AMP XI.M19, "Steam No Not applicable. Phosphate chemistry is not generator tubes and to wastage, pitting Generators," and used in the PSL Steam Generators.

sleeves exposed to corrosion AMP XI.M2, phosphate chemistry in "Water Chemistry" secondary feedwater or steam 3.1-1, 074 Steel steam generator Wall thinning due to AMP XI.M19, "Steam No Consistent with NUREG-2191 with upper assembly and flow-accelerated Generators," and exception for the Steam Generators separators including corrosion AMP XI.M2, AMP. The Steam Generators and Water feedwater inlet ring and "Water Chemistry" Chemistry AMPs are used to manage wall support exposed to thinning due to flow-accelerated corrosion secondary feedwater or in the Unit 1 steel feedwater ring and steam moisture separators exposed to treated water or steam.

3.1-1, 075 Steel steam generator Wall thinning due to AMP XI.M19, "Steam No Not applicable.

tube support lattice bars flow-accelerated Generators," and Steel tube support lattice bars are not a exposed to secondary corrosion, general AMP XI.M2, PSL steam generator component.

feedwater or steam corrosion "Water Chemistry"

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 8 of 38 Table 3.1-1: Summary of Aging Management Evaluations for the Reactor Vessel, Internals, and Reactor Coolant System Item Component Aging Aging Management Further Evaluation Discussion Number Effect/Mechanism Program / TLAA Recommended 3.1-1, 076 Steel, chrome plated Loss of material due AMP XI.M19, No Consistent with NUREG-2191 with steel, stainless steel, to wear, fretting "Steam Generators" exception for the Steam Generators nickel alloy steam AMP. The Steam Generators AMP is used generator U-bend to manage loss of material due to wear and supports including fretting of the stainless steel anti-vibration anti-vibration bars bars, the stainless steel Unit 1 tube exposed to secondary support lattice bars, and the stainless steel feedwater or steam Unit 2 tube support plates and anti-vibration bars exposed to treated water or steam.

3.1-1, 077 Nickel alloy steam Loss of material due AMP XI.M19, No Consistent with NUREG-2191 with generator tubes and to wear, fretting "Steam Generators" exception for the Steam Generators sleeves exposed to AMP. The Steam Generators AMP is used secondary feedwater or to manage loss of material due to wear and steam fretting of the nickel alloy U-tubes exposed to treated water or steam.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 9 of 38 SLRA Table 3.1-1 on page 3.1-42 is revised as follows:

Table 3.1-1: Summary of Aging Management Evaluations for the Reactor Vessel, Internals, and Reactor Coolant System Item Component Aging Aging Management Further Evaluation Discussion Number Effect/Mechanism Program / TLAA Recommended 3.1-1, 111 Nickel alloy steam Reduction of heat AMP XI.M2, "Water No Consistent with NUREG-2191 with generator tubes exposed transfer due to Chemistry," and AMP exception for the Steam Generators to secondary feedwater or fouling XI.M19, "Steam AMP. The Water Chemistry and Steam steam Generators" Generators AMPs are used to manage reduction of heat transfer due to fouling in the nickel alloy steam generator U-tubes exposed to treated water or steam.

SLRA Table 3.1-1 on page 3.1-45 is revised as follows:

Table 3.1-1: Summary of Aging Management Evaluations for the Reactor Vessel, Internals, and Reactor Coolant System Item Component Aging Aging Management Further Evaluation Discussion Number Effect/Mechanism Program / TLAA Recommended 3.1-1, 125 Nickel alloy steam Cracking due to AMP XI.M19, No Consistent with NUREG-2191 with generator tubes at support flow- induced "Steam Generators" exception for the Steam Generators plate locations exposed to vibration, high- cycle AMP. The Steam Generators AMP is used secondary feedwater or fatigue to manage cracking due to flow-induced steam vibration and high-cycle fatigue in nickel alloy U-tubes exposed to treated water or steam.

3.1-1, 127 Steel (with stainless steel Loss of material due AMP XI.M2, "Water No Consistent with NUREG-2191 with or nickel alloy cladding) to boric acid Chemistry," and AMP exception for the Steam Generators steam generator heads corrosion XI.M19, AMP. The Water Chemistry and Steam and tubesheets exposed "Steam Generators" Generator AMPs are used to manage loss to reactor coolant of material due to boric acid corrosion in steel with stainless steel and nickel alloy cladding steam generator channel head nozzles, stay cylinders, primary heads, and tubesheets exposed to reactor coolant.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 10 of 38 SLRA Table 3.1.2-5 pages 3.1-89 through 3.1-101 are revised as follows Table 3.1.2-5: Steam Generators - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Function Requiring Management Item Item Management Program Anti-vibration bars Structural Stainless Treated water Loss of material Steam Generators IV.D1.RP-225 3.1-1, 076 B support steel (ext) Steam (ext) (B.2.3.10)

Anti-vibration bars Structural Stainless Treated water Loss of material Steam Generators IV.D1.RP-226 3.1-1, 071 B support steel (ext) Steam (ext) (B.2.3.10)

Water Chemistry A (B.2.3.2)

Anti-vibration bars Structural Stainless Treated water Cracking Steam Generators IV.D1.RP-384 3.1-1, 071 B support steel >140°F (ext) (B.2.3.10)

Steam (ext) Water Chemistry A (B.2.3.2)

Blowdown nozzles Pressure Carbon steel Air - indoor Loss of material External Surfaces IV.C2.R-431 3.1-1, 124 A boundary uncontrolled (ext) Monitoring of Mechanical Components (B.2.3.23)

Blowdown nozzles Pressure Carbon steel Treated water Loss of material ASME Section XI IV.D1.RP-368 3.1-1, 012 C boundary (int) Inservice Inspection, Subsections IWB, IWC, and IWD (B.2.3.1) Water Chemistry (B.2.3.2)

Blowdown nozzles Pressure Carbon steel Treated water Wall thinning - Flow-Accelerated IV.D1.R-37 3.1-1, 061 C boundary (int) FAC Corrosion (B.2.3.8)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 11 of 38 Table 3.1.2-5: Steam Generators - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Function Requiring Management Item Item Management Program Bolting Mechanical Carbon steel Air - indoor Loss of material Bolting Integrity IV.D1.RP-166 3.1-1, 064 A closure uncontrolled (ext) (B.2.3.9)

Bolting Mechanical Carbon steel Air - indoor Loss of preload Bolting Integrity IV.D1.RP-46 3.1-1, 067 A closure uncontrolled (ext) (B.2.3.9)

Bolting Mechanical Carbon steel Air - indoor Cumulative TLAA - Section IV.C2.R-18 3.1-1, 005 A closure uncontrolled fatigue damage 4.3.1, Metal (ext) Cracking Fatigue of Class 1 Components Conical skirt Structural Carbon steel Air - indoor Loss of material External Surfaces IV.C2.R-431 3.1-1, 124 C support uncontrolled (ext) Monitoring of Mechanical Components (B.2.3.23)

Divider plates Flow Stainless steel Reactor coolant Cracking Water Chemistry IV.D1.RP-17 3.1-1, 086 A (Unit 1) distribution (ext) (B.2.3.2)

Divider plates Flow Stainless Reactor coolant Loss of material Water Chemistry IV.C2.RP-23 3.1-1, 088 C (Unit 1) distribution steel (ext) (B.2.3.2)

Divider plates Flow Nickel alloy Reactor coolant Cracking Steam Generators IV.D1.RP-367 3.1-1, 025 B (Unit 2) distribution (ext) (B.2.3.10)

Water Chemistry A, 1 (B.2.3.2)

Divider plates Flow Nickel alloy Reactor coolant Loss of material Water Chemistry IV.C2.RP-23 3.1-1, 088 C (Unit 2) distribution (ext) (B.2.3.2)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 12 of 38 Table 3.1.2-5: Steam Generators - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Function Requiring Management Item Item Management Program Feedwater feedring Structural Carbon steel Treated water Loss of material Steam Generators IV.D1.RP-161 3.1-1, 072 D (Unit 1) integrity (ext) Steam (ext) (B.2.3.10)

(attached) Water Chemistry C Direct flow (B.2.3.2)

Feedwater feedring Structural Carbon steel Treated water Loss of material Steam Generators IV.D1.RP-161 3.1-1, 072 D (Unit 1) integrity (int) (B.2.3.10)

(attached) Water Chemistry C Direct flow (B.2.3.2)

Feedwater feedring Structural Carbon steel Treated water Wall thinning - Steam Generators IV.D1.RP-49 3.1-1, 074 B (Unit 1) integrity (int) FAC (B.2.3.10)

(attached) Water Chemistry A Direct flow (B.2.3.2)

Feedwater feedring Structural Carbon steel Treated water Loss of material Steam Generators IV.D1.RP-161 3.1-1, 072 D supports integrity (ext) Steam (ext) (B.2.3.10)

(attached) Water Chemistry C (B.2.3.2)

Feedwater feedring Structural Stainless steel Treated water Loss of material Steam Generators IV.D1.RP-226 3.1-1, 071 D (Unit 2) integrity (ext) Steam (ext) (B.2.3.10)

(attached) Water Chemistry C Direct flow (B.2.3.2)

Feedwater feedring Structural Stainless steel Treated water Loss of material Steam Generators IV.D1.RP-226 3.1-1, 071 D (Unit 2) integrity (int) (B.2.3.10)

(attached) Water Chemistry C Direct flow (B.2.3.2)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 13 of 38 Table 3.1.2-5: Steam Generators - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Function Requiring Management Item Item Management Program Feedwater feedring Structural Stainless steel Treated water Cracking Steam Generators IV.D1.RP-384 3.1-1, 071 D (Unit 2) integrity >140°F (ext) (B.2.3.10)

(attached) Steam (ext) Water Chemistry C Direct flow (B.2.3.2)

Feedwater feedring Structural Stainless steel Treated water Cracking Steam Generators IV.D1.RP-384 3.1-1, 071 D (Unit 2) integrity >140°F (int) (B.2.3.10)

(attached) Water Chemistry C Direct flow (B.2.3.2)

Feedwater j- nozzle Structural Nickel alloy Treated water Loss of material Steam Generators IV.D1.RP-226 3.1-1, 071 D (Unit 1) integrity (ext) Steam (ext) (B.2.3.10)

(attached) Water Chemistry C Direct flow (B.2.3.2)

Feedwater j- nozzle Structural Nickel alloy Treated water Loss of material Steam Generators IV.D1.RP-226 3.1-1, 071 D (Unit 1) integrity (int) (B.2.3.10)

(attached) Water Chemistry C Direct flow (B.2.3.2)

Feedwater j- nozzle Structural Nickel alloy Treated water Cracking Steam Generators IV.D1.RP-384 3.1-1, 071 D (Unit 1) integrity >140°F (ext) (B.2.3.10)

(attached) Steam (ext) Water Chemistry C Direct flow (B.2.3.2)

Feedwater j- nozzle Structural Nickel alloy Treated water Cracking Steam Generators IV.D1.RP-384 3.1-1, 071 D (Unit 1) integrity >140°F (int) (B.2.3.10)

(attached) Water Chemistry C Direct flow (B.2.3.2)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 14 of 38 Table 3.1.2-5: Steam Generators - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Function Requiring Management Item Item Management Program Feedwater j-nozzle Structural Stainless steel Treated water Loss of material Steam Generators IV.D1.RP-226 3.1-1, 071 D (Unit 2) integrity (ext) Steam (ext) (B.2.3.10)

(attached) Water Chemistry C Direct flow (B.2.3.2)

Feedwater j-nozzle Structural Stainless steel Treated water Loss of material Steam Generators IV.D1.RP-226 3.1-1, 071 D (Unit 2) integrity (int) (B.2.3.10)

(attached) Water Chemistry C Direct flow (B.2.3.2)

Feedwater j-nozzle Structural Stainless steel Treated water Cracking Steam Generators IV.D1.RP-384 3.1-1, 071 D (Unit 2) integrity >140°F (ext) (B.2.3.10)

(attached) Steam (ext) Water Chemistry C Direct flow (B.2.3.2)

Feedwater j-nozzle Structural Stainless steel Treated water Cracking Steam Generators IV.D1.RP-384 3.1-1, 071 D (Unit 2) integrity >140°F (int) (B.2.3.10)

(attached) Water Chemistry C Direct flow (B.2.3.2)

Feedwater nozzle Pressure Carbon steel Air - indoor Loss of material External Surfaces IV.C2.R-431 3.1-1, 124 A boundary uncontrolled (ext) Monitoring of Mechanical Components (B.2.3.23)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 15 of 38 Table 3.1.2-5: Steam Generators - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Function Requiring Management Item Item Management Program Feedwater nozzle Pressure Carbon steel Treated water Loss of material ASME Section XI IV.D1.RP-368 3.1-1, 012 C boundary (int) Inservice Inspection, Subsections IWB, IWC, and IWD (B.2.3.1) Water Chemistry (B.2.3.2)

Feedwater nozzle Pressure Carbon steel Treated water Wall thinning - Flow-Accelerated IV.D1.R-37 3.1-1, 061 A boundary (int) FAC Corrosion (B.2.3.8)

Moisture separators Structural Carbon steel Treated water Loss of material Steam Generators IV.D1.RP-161 3.1-1, 072 D (Unit 1) integrity (ext) Steam (ext) (B.2.3.10)

(attached) Water Chemistry C (B.2.3.2)

Moisture separators Structural Carbon steel Treated water Wall thinning - Steam Generators IV.D1.RP-49 3.1-1, 074 B (Unit 1) integrity (ext) Steam (ext) FAC (B.2.3.10)

(attached) Water Chemistry A (B.2.3.2)

Moisture separators Structural Stainless steel Treated water Loss of material Steam Generators IV.D1.RP-226 3.1-1, 071 D (Unit 2) integrity (ext) Steam (ext) (B.2.3.10)

(attached) Water Chemistry C (B.2.3.2)

Moisture separators Structural Stainless steel Treated water Cracking Steam Generators IV.D1.RP-384 3.1-1, 071 D (Unit 2) integrity >140°F (ext) (B.2.3.10)

(attached) Steam (ext) Water Chemistry C (B.2.3.2)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 16 of 38 Table 3.1.2-5: Steam Generators - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Function Requiring Management Item Item Management Program Primary heads Pressure Carbon steel Air - indoor Loss of material External Surfaces IV.C2.R-431 3.1-1, 124 C boundary with stainless uncontrolled (ext) Monitoring of steel cladding Mechanical Components (B.2.3.23)

Primary heads Pressure Carbon steel Reactor coolant Cracking ASME Section XI IV.D1.RP-232 3.1-1, 033 C boundary with stainless (int) Inservice Inspection, steel cladding Subsections IWB, IWC, and IWD (B.2.3.1) Water Chemistry (B.2.3.2)

Primary heads Pressure Carbon steel Reactor coolant Loss of material Steam Generators IV.D1.R-436 3.1-1, 127 B boundary with stainless (int) (B.2.3.10) steel cladding Water Chemistry A (B.2.3.2)

Primary heads Pressure Carbon steel Reactor coolant Loss of material Water Chemistry IV.C2.RP-23 3.1-1, 088 A boundary with stainless (int) (B.2.3.2) steel cladding Primary inlet and Pressure Carbon steel Air - indoor Loss of material External Surfaces IV.C2.R-431 3.1-1, 124 A outlet nozzles boundary with stainless uncontrolled (ext) Monitoring of steel cladding Mechanical Components (B.2.3.23)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 17 of 38 Table 3.1.2-5: Steam Generators - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Function Requiring Management Item Item Management Program Primary inlet and Pressure Carbon steel Reactor coolant Cracking ASME Section XI IV.D1.RP-232 3.1-1, 033 A outlet nozzles boundary with stainless (int) Inservice Inspection, steel cladding Subsections IWB, IWC, and IWD (B.2.3.1) Water Chemistry (B.2.3.2)

Primary inlet and Pressure Carbon steel Reactor coolant Loss of material Steam Generators IV.D1.R-436 3.1-1, 127 D outlet nozzles boundary with stainless (int) (B.2.3.10) steel cladding Water Chemistry C (B.2.3.2)

Primary inlet and Pressure Carbon steel Reactor coolant Loss of material Water Chemistry IV.C2.RP-23 3.1-1, 088 A outlet nozzles boundary with stainless (int) (B.2.3.2) steel cladding Primary instrument Pressure Nickel alloy Air - indoor Loss of material External Surfaces IV.C2.R-452b 3.1-1, 136 A nozzles boundary uncontrolled (ext) Monitoring of Mechanical Components (B.2.3.23)

Primary instrument Pressure Nickel alloy Reactor coolant Loss of material Water Chemistry IV.C2.RP-23 3.1-1, 088 A nozzles boundary (int) (B.2.3.2)

Primary manway Pressure Carbon steel Air - indoor Loss of material External Surfaces IV.C2.R-431 3.1-1, 124 C covers (Unit 1) boundary with nickel uncontrolled (ext) Monitoring of alloy Mechanical diaphragm Components (B.2.3.23)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 18 of 38 Table 3.1.2-5: Steam Generators - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Function Requiring Management Item Item Management Program Primary manway Pressure Carbon steel Reactor coolant Cracking ASME Section XI IV.D1.RP-36 3.1-1, 045 C covers (Unit 1) boundary with nickel (int) Inservice Inspection, alloy Subsections IWB, diaphragm IWC, and IWD (B.2.3.1)

Water Chemistry (B.2.3.2)

Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in RCPB Components (B.2.3.5)

Primary manway Pressure Carbon steel Reactor coolant Loss of material Water Chemistry IV.C2.RP-23 3.1-1, 088 A covers (Unit 1) boundary with nickel (int) (B.2.3.2) alloy diaphragm Primary manway Pressure Carbon steel Air - indoor Loss of material External Surfaces IV.C2.R-431 3.1-1, 124 C covers (Unit 2) boundary with stainless uncontrolled (ext) Monitoring of steel Mechanical diaphragm Components (B.2.3.23)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 19 of 38 Table 3.1.2-5: Steam Generators - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Function Requiring Management Item Item Management Program Primary manway Pressure Carbon steel Reactor coolant Cracking ASME Section XI IV.D1.RP-232 3.1-1, 033 A covers (Unit 2) boundary with stainless (int) Inservice Inspection, steel Subsections IWB, diaphragm IWC, and IWD (B.2.3.1) Water Chemistry (B.2.3.2)

Primary manway Pressure Carbon steel Reactor coolant Loss of material Water Chemistry IV.C2.RP-23 3.1-1, 088 C covers (Unit 2) boundary with stainless (int) (B.2.3.2) steel diaphragm Recirculation Pressure Carbon steel Air - indoor Loss of material External Surfaces IV.C2.R-431 3.1-1, 124 A nozzles and end boundary uncontrolled (ext) Monitoring of caps (Unit 2) Mechanical Components (B.2.3.23)

Recirculation Pressure Carbon steel Treated water Loss of material ASME Section XI IV.D1.RP-368 3.1-1, 012 C nozzles and end boundary (int) Inservice Inspection, caps (Unit 2) Subsections IWB, IWC, and IWD (B.2.3.1) Water Chemistry (B.2.3.2)

Secondary Pressure Nickel alloy Air - indoor Loss of material External Surfaces IV.C2.R-452b 3.1-1, 136 A instrument nozzles boundary uncontrolled (ext) Monitoring of (Unit 1) Mechanical Components (B.2.3.23)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 20 of 38 Table 3.1.2-5: Steam Generators - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Function Requiring Management Item Item Management Program Secondary Pressure Nickel alloy Treated water Loss of material Steam Generators IV.D1.RP-226 3.1-1, 071 D instrument nozzles boundary (ext) Steam (ext) (B.2.3.10)

(Unit 1) Water Chemistry C (B.2.3.2)

Secondary Pressure Nickel alloy Treated water Cracking Steam Generators IV.D1.RP-384 3.1-1, 071 D instrument nozzles boundary >140°F (ext) (B.2.3.10)

(Unit 1) Steam (ext) Water Chemistry C (B.2.3.2)

Secondary Pressure Carbon steel Treated water Loss of material ASME Section XI IV.D1.RP-368 3.1-1, 012 C instrument nozzles boundary (int) Inservice Inspection, (Unit 2) Steam (int) Subsections IWB, IWC, and IWD (B.2.3.1) Water Chemistry (B.2.3.2)

Secondary Pressure Carbon steel Treated water Wall thinning - Flow-Accelerated IV.D1.R-37 3.1-1, 061 C instrument nozzles boundary (int) FAC Corrosion (B.2.3.8)

(Unit 2) Steam (int)

Secondary Pressure Carbon steel Air - indoor Loss of material External Surfaces IV.C2.R-431 3.1-1, 124 A instrument nozzles boundary uncontrolled (ext) Monitoring of (Unit 2) Mechanical Components (B.2.3.23)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 21 of 38 Table 3.1.2-5: Steam Generators - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Function Requiring Management Item Item Management Program Secondary manway Pressure Carbon steel Air - indoor Loss of material External Surfaces IV.C2.R-431 3.1-1, 124 C and handhole boundary uncontrolled (ext) Monitoring of closure covers Mechanical Components (B.2.3.23)

Secondary manway Pressure Carbon steel Treated water Loss of material ASME Section XI IV.D1.R-31 3.1-1, 044 A and handhole boundary (int) Inservice Inspection, closure covers Steam (int) Subsections IWB, (Unit 1) IWC, and IWD (B.2.3.1)

Secondary manway Pressure Carbon steel Treated water Loss of material ASME Section XI IV.D1.RP-368 3.1-1, 012 C and handhole boundary (int) Inservice Inspection, closure covers Steam (int) Subsections IWB, (Unit 1) IWC, and IWD (B.2.3.1) Water Chemistry (B.2.3.2)

Secondary manway Pressure Carbon steel Treated water Loss of material Steam Generators IV.D1.RP-226 3.1-1, 071 D and handhole boundary with stainless (int) (B.2.3.10) closure covers steel Steam (int) Water Chemistry C (Unit 2) diaphragm (B.2.3.2)

Secondary manway Pressure Carbon steel Treated water Cracking Steam Generators IV.D1.RP-384 3.1-1, 071 D and handhole boundary with stainless >140°F (ext) (B.2.3.10) closure covers steel Steam (ext) Water Chemistry C (Unit 2) diaphragm (B.2.3.2)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 22 of 38 Table 3.1.2-5: Steam Generators - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Function Requiring Management Item Item Management Program Stay cylinders Pressure Carbon steel Reactor coolant Cracking ASME Section XI IV.D1.RP-232 3.1-1, 033 C (Unit 1) boundary with stainless (int) Inservice Inspection, steel cladding Subsections IWB, IWC, and IWD (B.2.3.1) Water Chemistry (B.2.3.2)

Stay cylinders Pressure Carbon steel Reactor coolant Loss of material Steam Generators IV.D1.R-436 3.1-1, 127 D (Unit 1) boundary with stainless (int) (B.2.3.10) steel cladding Water Chemistry C (B.2.3.2)

Stay cylinders Pressure Carbon steel Reactor coolant Loss of material Water Chemistry IV.C2.RP-23 3.1-1, 088 A (Unit 1) boundary with stainless (int) (B.2.3.2) steel cladding Steam generator Pressure Carbon steel Reactor coolant Cumulative TLAA - Section IV.D1.R-221 3.1-1, 008 A components with boundary with stainless (int) fatigue damage 4.3.1, Metal Fatigue fatigue analysis steel cladding Cracking of Class 1 Carbon steel Components with nickel alloy cladding Nickel alloy Stainless steel Steam generator Pressure Carbon steel Treated water Cumulative TLAA - Section IV.D1.R-33 3.1-1, 005 A components with boundary (ext) Steam (ext) fatigue damage 4.3.1, Metal fatigue analysis Cracking Fatigue of Class 1 Components

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 23 of 38 Table 3.1.2-5: Steam Generators - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Function Requiring Management Item Item Management Program Steam generator Pressure Steel Air with borated Loss of material Boric Acid Corrosion IV.D1.R-17 3.1-1, 049 A components: boundary water leakage (B.2.3.4) external surfaces Mechanical (ext) closure Steam outlet nozzle Pressure Carbon steel Air - indoor Loss of material External Surfaces IV.C2.R-431 3.1-1, 124 A (Unit 2) boundary uncontrolled (ext) Monitoring of Mechanical Components (B.2.3.23)

Steam outlet nozzle Pressure Carbon steel Steam (int) Loss of material ASME Section XI IV.D1.RP-368 3.1-1, 012 C (Unit 2) boundary Inservice Inspection, Subsections IWB, IWC, and IWD (B.2.3.1) Water Chemistry (B.2.3.2)

Steam outlet nozzle Pressure Carbon steel Steam (int) Wall thinning - Flow-Accelerated IV.D1.R-37 3.1-1, 061 A (Unit 2) boundary FAC Corrosion (B.2.3.8)

Steam outlet nozzle Throttle Nickel alloy Steam (ext) Cracking Steam Generators IV.D1.RP-384 3.1-1, 071 D venturis (Unit 2) (B.2.3.10)

Water Chemistry C (B.2.3.2)

Steam outlet nozzle Throttle Nickel alloy Steam (ext) Loss of material Steam Generators IV.D1.RP-226 3.1-1, 071 D venturis (Unit 2) (B.2.3.10)

Water Chemistry C (B.2.3.2)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 24 of 38 Table 3.1.2-5: Steam Generators - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Function Requiring Management Item Item Management Program Steam outlet nozzle Pressure Carbon steel Air - indoor Loss of material External Surfaces IV.C2.R-431 3.1-1, 124 A with integral flow boundary uncontrolled (ext) Monitoring of orifices (Unit 1) Throttle Mechanical Components (B.2.3.23)

Steam outlet nozzle Pressure Carbon steel Steam (int) Loss of material ASME Section XI IV.D1.RP-368 3.1-1, 012 C with integral flow boundary Inservice Inspection, orifices (Unit 1) Throttle Subsections IWB, IWC, and IWD (B.2.3.1) Water Chemistry (B.2.3.2)

Steam outlet nozzle Pressure Carbon steel Steam (int) Wall thinning - Flow-Accelerated IV.D1.R-37 3.1-1, 061 A with integral flow boundary FAC Corrosion (B.2.3.8) orifices (Unit 1) Throttle Tube bundle Structural Carbon steel Treated water Loss of material Steam Generators IV.D1.RP-161 3.1-1, 072 B wrapper and support (ext) Steam (ext) (B.2.3.10) wrapper supports Direct flow Water Chemistry A (B.2.3.2)

Tube-to-tubesheet Pressure Nickel alloy Reactor coolant Cracking Steam Generators IV.D1.RP-385 3.1-1, 025 B welds boundary (ext) (B.2.3.10)

Water Chemistry A (B.2.3.2)

Tube-to-tubesheet Pressure Nickel alloy Reactor coolant Loss of material Water Chemistry IV.C2.RP-23 3.1-1, 088 C welds boundary (ext) (B.2.3.2)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 25 of 38 Table 3.1.2-5: Steam Generators - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Function Requiring Management Item Item Management Program Tube plugs Pressure Nickel alloy Reactor coolant Cracking Steam Generators IV.D1.R-40 3.1-1, 070 B boundary (ext) (B.2.3.10)

Water Chemistry A (B.2.3.2)

Tube plugs Pressure Nickel alloy Reactor coolant Loss of material Water Chemistry IV.C2.RP-23 3.1-1, 088 C boundary (ext) (B.2.3.2)

Tube stabilizers Structural Nickel alloy Reactor coolant Cracking Steam Generators IV.D1.R-40 3.1-1, 070 D (stakes) (Unit 2) support (ext) (B.2.3.10)

Water Chemistry C (B.2.3.2)

Tube stabilizers Structural Nickel alloy Reactor coolant Loss of material Water Chemistry IV.C2.RP-23 3.1-1, 088 C (stakes) (Unit 2) support (ext) (B.2.3.2)

Tube stabilizers Structural Stainless steel Reactor coolant Cracking Water Chemistry IV.D1.RP-17 3.1-1, 086 C (stakes) (Unit 2) support (ext) (B.2.3.2)

Tube support lattice Structural Stainless steel Treated water Loss of material Steam Generators IV.D1.RP-225 3.1-1, 076 BA bars (Unit 1) support (ext) Steam (ext) (B.2.3.10)

Tube support lattice Structural Stainless steel Treated water Loss of material Steam Generators IV.D1.RP-226 3.1-1, 071 D bars (Unit 1) support (ext) Steam (ext) (B.2.3.10)

Water Chemistry C (B.2.3.2)

Tube support lattice Structural Stainless steel Treated water Cracking Steam Generators IV.D1.RP-384 3.1-1, 071 B bars (Unit 1) support >140°F (ext) (B.2.3.10)

Steam (ext) Water Chemistry A (B.2.3.2)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 26 of 38 Table 3.1.2-5: Steam Generators - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Function Requiring Management Item Item Management Program Tube support plates Structural Stainless steel Treated water Loss of material Steam Generators IV.D1.RP-225 3.1-1, 076 BA and anti-vibration support (ext) Steam (ext) (B.2.3.10) bars (Unit 2)

Tube support plates Structural Stainless steel Treated water Loss of material Steam Generators IV.D1.RP-226 3.1-1, 071 B and anti-vibration support (ext) Steam (ext) (B.2.3.10) bars (Unit 2) Water Chemistry A (B.2.3.2)

Tube support plates Structural Stainless steel Treated water Cracking Steam Generators IV.D1.RP-384 3.1-1, 071 B and anti-vibration support >140°F (ext) (B.2.3.10) bars (Unit 2) Steam (ext) Water Chemistry A (B.2.3.2)

Tubesheets Pressure Carbon steel Treated water Loss of material Steam Generators IV.D1.RP-161 3.1-1, 072 D boundary (int) (B.2.3.10)

Water Chemistry C (B.2.3.2)

Tubesheets Pressure Carbon steel Reactor coolant Loss of material Steam Generators IV.D1.R-436 3.1-1, 127 B boundary with nickel (int) (B.2.3.10) alloy cladding Water Chemistry A (B.2.3.2)

Upper and lower Pressure Carbon steel Air - indoor Loss of material External Surfaces IV.C2.R-431 3.1-1, 124 C shells, secondary boundary uncontrolled (ext) Monitoring of head, transition Mechanical cone Components (B.2.3.23)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 27 of 38 Table 3.1.2-5: Steam Generators - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Function Requiring Management Item Item Management Program Upper and lower Pressure Carbon steel Treated water Loss of material ASME Section XI IV.D1.RP-368 3.1-1, 012 A shells, secondary boundary (int) Inservice Inspection, head, transition Steam (int) Subsections IWB, cone IWC, and IWD (B.2.3.1) Water Chemistry (B.2.3.2)

Upper vessel Structural Carbon steel Air - indoor Loss of material External Surfaces IV.C2.R-431 3.1-1, 124 C clevises and shear support uncontrolled (ext) Monitoring of keys Mechanical Components (B.2.3.23)

U-tubes Pressure Nickel alloy Reactor coolant Cracking Steam Generators IV.D1.R-44 3.1-1, 070 B boundary (int) (B.2.3.10)

Heat transfer Water Chemistry A (B.2.3.2)

U-tubes Pressure Nickel alloy Reactor coolant Cumulative TLAA - Section IV.D1.R-46 3.1-1, 002 A boundary (int) fatigue damage 4.3.1, Metal Fatigue Heat transfer Cracking of Class 1 Components U-tubes Pressure Nickel alloy Reactor coolant Loss of material Water Chemistry IV.C2.RP-23 3.1-1, 088 A boundary (int) (B.2.3.2)

Heat transfer U-tubes Pressure Nickel alloy Treated water Loss of material Steam Generators IV.D1.RP-233 3.1-1, 077 BA boundary (ext) Steam (ext) (B.2.3.10)

Heat transfer

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 28 of 38 Table 3.1.2-5: Steam Generators - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Function Requiring Management Item Item Management Program U-tubes Pressure Nickel alloy Treated water Reduction of heat Steam Generators IV.D1.R-407 3.1-1, 111 B boundary (ext) Steam (ext) transfer (B.2.3.10)

Heat transfer Water Chemistry A (B.2.3.2)

U-tubes Pressure Nickel alloy Treated water Cracking Steam Generators IV.D1.R-437 3.1-1, 125 BA boundary >140°F (ext) (B.2.3.10)

Heat transfer Steam (ext)

U-tubes Pressure Nickel alloy Treated water Cracking Steam Generators IV.D1.R-47 3.1-1, 069 B boundary >140°F (ext) (B.2.3.10)

Heat transfer Steam (ext) Water Chemistry A (B.2.3.2)

General Notes A. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

B. Consistent with component, material, environment, aging effect, and AMP listed for NUREG 2191 line item. AMP has exceptions to NUREG 2191 AMP description.

C. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

D. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG 2191 line item. AMP has exceptions to NUREG 2191 AMP description.

Plant Specific Notes

1. Per further evaluation 3.1.2.2.11.1 the Unit 2 divider plates are fabricated from materials that are non-susceptible highly resistant to PWSCC and do not require further aging management.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 29 of 38 SLRA Appendix A1, Section 19.2.2.10 on pages A1-18 and A1-19, is revised as follows:

The PSL Steam Generators AMP, previously the PSL Steam Generator Integrity Program (SGIP), is an existing AMP that manages the aging of steam generator tubes, plugs, divider plate assemblies, tube-to-tubesheet welds, heads (interior surfaces of channel or lower heads), tubesheet(s) (primary side), and secondary side components that are contained within the steam generator (i.e., secondary side internals). PSL has submitted a license amendment request (ML21265A285) for the Technical Specifications conversion to NUREG-1432 Revision 5 in accordance with TSTF 577 Revision 1 (ML21098A188).

Following NRC review and approval, including any applicable conditions or limitations, implementation of this license amendment will increase the inspection interval for 100% of the tubes to 96 EFPM. The 96 EFPM inspection interval for the tubes will also allow for visual inspection of the divider plates, tube-to-tubesheet welds, channel heads, and tubesheets in accordance with the Steam Generators AMP. The AMP is modeled after NEI 97-06 Revision 3, Steam Generator Program Guidelines and the referenced EPRI Guidelines of NEI 97-06 Revision 3.

The establishment of a steam generator program for ensuring steam generator tube integrity is required by the PSL Technical Specifications. Additionally, administrative controls require tube integrity to be maintained to specific performance criteria, condition monitoring requirements, inspection scope and frequency, acceptance criteria for the tube plugging or repair of flawed tubes, acceptable tube repair plugging methods, and leakage monitoring requirements.

Condition monitoring assessments are performed to determine whether tube integrity was met during the prior operating interval. Operational assessments are performed to ensure that tube integrity will be maintained until the next inspection. The nondestructive examination (NDE) techniques used to inspect steam generator components covered by this AMP are intended to identify components (e.g., tubes, plugs) with degradation that may need to be removed from service (e.g., tubes), repaired, or replaced (e.g., plugs), as appropriate.

Volumetric inspections are performed on steam generator tubes to identify degradation such as PWSCC, outer diameter stress corrosion cracking (ODSCC), and loss of material (mechanical wear) due to foreign objects and tube support structures. General visual inspections are also performed to identify any evidence of cracking, loss of material or corrosion where accessible.

This AMP also performs general visual inspections of the steam generator heads (internal surfaces) looking for evidence of cracking or loss of material (e.g., rust stains). Additionally, the AMP includes foreign material exclusion as a means to inhibit wear degradation, and secondary side maintenance activities, such as sludge lancing, for removing deposits that may contribute to component degradation.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 30 of 38 SLRA Appendix A1, Section 19.4, commitment No. 13 portion of Table 19-3 on page A1-71, is revised as follows:

Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 13 Steam Generators XI.M19 a) Continue the existing PSL Steam Generators AMP. No later than 6 months prior to (19.2.2.10) the SPEO, or no later than the last refueling outage prior to the SPEO i.e.:

PSL1: 09/01/2035

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 31 of 38 SLRA Appendix A2, Section 19.2.2.10, on pages A2-18 and A2-19, is revised as follows:

The PSL Steam Generators AMP, previously the PSL Steam Generator Integrity Program (SGIP), is an existing AMP that manages the aging of steam generator tubes, plugs, divider plate assemblies, tube-to-tubesheet welds, heads (interior surfaces of channel or lower heads), tubesheet(s) (primary side), and secondary side components that are contained within the steam generator (i.e., secondary side internals. PSL has submitted a license amendment request (ML21265A285) for the Technical Specifications conversion to NUREG-1432 Revision 5 in accordance with TSTF 577 Revision 1 (ML21098A188).

Following NRC review and approval, including any applicable conditions or limitations, implementation of this license amendment will increase the inspection interval for 100% of the tubes to 96 EFPM. The 96 EFPM inspection interval for the tubes will also allow for visual inspection of the divider plates, tube-to-tubesheet welds, channel heads, and tubesheets in accordance with the Steam Generators AMP. The AMP is modeled after NEI 97-06 Revision 3, Steam Generator Program Guidelines and the referenced EPRI Guidelines of NEI 97-06 Revision 3.

The establishment of a steam generator program for ensuring steam generator tube integrity is required by the PSL Technical Specifications. Additionally, administrative controls require tube integrity to be maintained to specific performance criteria, condition monitoring requirements, inspection scope and frequency, acceptance criteria for tubethe plugging or repair of flawed tubes, acceptable tube repair plugging methods, and leakage monitoring requirements.

Condition monitoring assessments are performed to determine whether tube integrity was met during the prior operating interval. Operational assessments are performed to ensure that tube integrity will be maintained until the next inspection. The nondestructive examination (NDE) techniques used to inspect steam generator components covered by this AMP are intended to identify components (e.g., tubes, plugs) with degradation that may need to be removed from service (e.g., tubes), repaired, or replaced (e.g., plugs), as appropriate.

Volumetric inspections are performed on steam generator tubes to identify degradation such as PWSCC, outer diameter stress corrosion cracking (ODSCC), and loss of material (mechanical wear) due to foreign objects and tube support structures. General visual inspections are also performed to identify any evidence of cracking, loss of material or corrosion where accessible.

This AMP also performs general visual inspections of the steam generator heads (internal surfaces) looking for evidence of cracking or loss of material (e.g., rust stains). Additionally, the AMP includes foreign material exclusion as a means to inhibit wear degradation, and secondary side maintenance activities, such as sludge lancing, for removing deposits that may contribute to component degradation.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 32 of 38 SLRA Appendix A2, Section 19.4, commitment No. 13 portion of Table 19-3 on page A2-72 is revised as follows:

Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 13 Steam Generators XI.M19 a) Continue the existing PSL Steam Generators AMP. No later than 6 months prior to (19.2.2.10) the SPEO, or no later than the last refueling outage prior to the SPEO i.e.:

PSL2: 10/06/2042

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 33 of 38 SLRA Section B.1.1 page B-6 is revised as follows:

The following programs each have exception(s) justified by technical data:

  • PSL Reactor Head Closure Stud Bolting AMP (Section B.2.3.3),
  • PSL Outdoor and Large Atmospheric Metallic Storage Tank AMP (Section B.2.3.17),
  • PSL Fuel Oil Chemistry AMP (Section B.2.3.18),
  • PSL Reactor Vessel Material Surveillance AMP (Section B.2.3.19),
  • PSL Structures Monitoring AMP (Section B.2.3.33)

SLRA Section B.2.1 page B-20 is revised as follows:

Table B-4 PSL Aging Management Program Consistency with NUREG-2191 PSL Aging Section PSL NUREG-2191 Comparison Management Plant-Specific?

Program NUREG-2191 Enhancements? Exceptions?

Section Steam Generators B.2.3.10 No XI.M19 No NoYes SLRA Section B.2.3.10 pages B-88 through B-91 are revised as follows:

Program Description The PSL Steam Generators AMP, previously the PSL Steam Generator Integrity program, is an existing AMP that manages the aging of steam generator tubes, plugs, divider plate assemblies, tube-to-tubesheet welds, heads (interior surfaces of channel or lower heads), tubesheet(s) (primary side), and secondary side components that are contained within the steam generator (i.e., secondary side internals). The aging of steam generator pressure vessel welds is managed by other AMPs such as the PSL ASME Section XI ISI, Subsections IWB, IWC, and IWD AMP (Section B.2.3.1), and the PSL Water Chemistry AMP (Section B.2.3.2).

The establishment of a steam generator program for ensuring steam generator tube integrity is required by the PSL Technical Specifications (TS). Additionally, Administrative Control requires tube integrity to be maintained to specific performance criteria, condition monitoring requirements, inspection scope and frequency, acceptance criteria for the plugging or repair of flawed tubes, acceptable tube repair methods, and leakage monitoring requirements. Condition monitoring assessments are performed to determine whether tube integrity was met during the prior operating interval. Operational assessments are performed to ensure that tube integrity will be maintained until the next inspection. The NDE techniques used to inspect steam generator components covered by this AMP are

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 34 of 38 intended to identify components (e.g., tubes, plugs) with degradation that may need to be removed from service (e.g., tubes), repaired, or replaced (e.g., plugs), as appropriate.

The PSL Steam Generators AMP is based on the guidelines provided in NEI 97-06 (Reference 1.6.32), Revision 3, Steam Generator Program Guidelines. As such, this AMP incorporates the following industry guidelines:

  • EPRI 1022832, PWR Primary-to-Secondary Leak Guidelines (Reference 1.6.34);
  • EPRI 3002000505, Pressurized Water Reactor Primary Water Chemistry Guidelines;
  • EPRI 3002010645, Pressurized Water Reactor Secondary Water Chemistry Guidelines;

Through these guidelines, a balance of prevention, mitigation, inspection, evaluation, repair, and leakage monitoring measures are incorporated. Specifically, this AMP incorporates the following from NEI 97-06:

a. Performance criteria are intended to provide assurance that tube integrity is being maintained consistent with the CLB.
b. Guidance for monitoring and maintaining the tubes, which provides assurance that the performance criteria are met at all times between scheduled tube inspections.

Since degradation of divider plate assemblies, tube-to-tubesheet welds, channel heads (internal surfaces), or tubesheets (primary side) may have safety implications, the PSL Steam Generators AMP addresses degradation associated with steam generator tubes, plugs, divider plates, tube-to-tubesheet welds, interior surfaces of channel heads, tubesheets (primary side), and secondary side components that are contained within the steam generator (i.e., secondary side internals). This AMP does not include in its scope the steam generator secondary side shell, any nozzles attached to the secondary side shell or steam generator head, or the welds associated with these components. In addition, the scope of this AMP does not include steam generator primary side chamber welds (other than general corrosion of these welds caused as a result of degradation (defects/flaws) in the primary side cladding).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 35 of 38 The PSL Steam Generators AMP includes preventive and mitigative actions for addressing degradation. This includes foreign material exclusion as a means to inhibit wear degradation and secondary side maintenance/cleaning activities, such as sludge lancing, for removing deposits that may contribute to degradation. Sludge lancing occurs when the steam generator is inspected, and inspections for remaining foreign material are performed after sludge lancing is completed. Primary side preventive maintenance activities include tube plug inspection, and replacement of tube plugs which are suspected of leakage. Additionally, this AMP works in conjunction with the PSL Water Chemistry AMP (Section B.2.3.2), which monitors and maintains water chemistry to reduce susceptibility to SCC or IGSCC.

The procedures associated with this AMP provide parameters to be monitored or inspected except for steam generator divider plates, tube-to-tubesheet welds, channel heads, and tubesheets. PSL has submitted a license amendment request (ML21265A285) for the Technical Specifications conversion to NUREG-1432 Revision 5 in accordance with TSTF 577 Revision 1 (ML21098A188). Following NRC review and approval, including any applicable conditions or limitations, implementation of this license amendment will increase the inspection interval for 100% of the tubes to 96 EFPM. The 96 EFPM inspection interval for the tubes will also allow for visual inspection of the divider plates, tube-to-tubesheet welds, channel heads, and tubesheets in accordance with the Steam Generators AMP.For these latter components, visual inspections are performed at least every 72 effective full power months or every third refueling outage (RFO), whichever results in more frequent inspections. These inspections of the steam generator head interior surfaces, including the divider plate, are intended to identify signs that cracking, or loss of material may be occurring (e.g.,

through identification of rust stains).

Condition monitoring assessments are performed to determine whether the structural and accident-induced leakage performance criteria were satisfied during the prior operating interval. Operational assessments are performed to verify that structural and leakage integrity will be maintained for the planned operating interval before the next inspection. If tube integrity cannot be maintained for the planned operating interval before the next inspection, corrective actions are taken in accordance with the PSL CAP. Comparisons of the results of the condition monitoring assessment to the predictions of the previous operational assessment are performed to evaluate the adequacy of the previous operational assessment methodology. If the operational assessment was not conservative in terms of the number and/or severity of the condition, corrective actions are taken in accordance with the Steam Generator Integrity Assessment Guidelines. Assessment of tube integrity and plugging or repair criteria of flawed tubes is in accordance with the PSL TS.

Degraded plugs, divider plates, tube-to-tubesheet welds, channel heads (interior surfaces), tubesheets (primary side), and secondary side internals are evaluated for continued acceptability on a case-by-case basis. The intent of all evaluations is to provide reasonable assurance that the components will continue to perform their functions consistent with the design and licensing basis of the facility and will not

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 36 of 38 affect the integrity of other components (e.g., by generating loose parts). In addition, when degradation of the steam generator tubes is identified, the TS specified actions are followed. For degradation of other components, the appropriate corrective action is evaluated per NEI 97-06 and the associated EPRI guidelines, the ASME Code Section XI, 10 CFR 50.65, and 10 CFR Part 50, Appendix B, as appropriate.

Procedures implement the performance criteria for tube integrity, condition monitoring requirements, inspection scope and frequency, acceptance criteria for the plugging or repair of flawed tubes, acceptable tube repair methods, leakage monitoring requirements, and operational leakage and accident-induced leakage requirements from the TS.

Steam generator tubes not meeting the TS limits for continued operation are removed from service by installation of tube plugs. This plug installation redefines the reactor coolant pressure boundary and loss of steam generator tube plug integrity can impact the ability of the steam generators to perform its intended function if permitted to continue without corrective action. Tube plugs installed are fabricated from heat treated Inconel Alloy 690 material. Although these plugs have a high resistance to primary water stress corrosion cracking (PWSCC), they are routinely inspected.

Aging is managed through assessment of potential degradation mechanisms, inspections, tube integrity assessments, plugging and repairs, Primary-to-Secondary Leak Monitoring, maintenance of secondary-side component integrity, primary-side and secondary-side water chemistry, and foreign material exclusion.

Volumetric inspections are performed to identify degradations of steam generator tubes such as PWSCC, outer diameter stress corrosion cracking (ODSCC), and loss of material due to foreign objects and tube support structures. Visual inspections are performed on other primary-side and secondary-side components. The visual inspections of the primary-side and secondary side components listed above are performed in accordance with the Degradation Assessment (DA) that is prepared as each steam generator is scheduled for examination.

The PSL Steam Generators AMP includes a DA in accordance with the requirements defined in the EPRI Steam Generator Integrity Assessment Guidelines; a DA is performed to determine the type and location of flaws to which the tube may be susceptible, and implementation of inspection methods capable of detecting those forms of degradation are addressed. The DA includes a review of applicable industry OE, as well as plant-specific OE which has occurred since the previous DA was performed.

A condition monitoring assessment is performed at the conclusion of each inspection to determine whether inspection criteria is met. A forward-looking evaluation, operational assessment is used to predict that the structural integrity and accident leakage performance will be acceptable during the operating interval until the next in-service inspection.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 37 of 38 NUREG-2191 Consistency The PSL Steam Generators AMP is consistent without exception to the 10 elements of NUREG-2191,Section XI.M19, Steam Generators.

Exceptions to NUREG-2191 None.The PSL Steam Generators AMP will take the following exception to the NUREG-2191 guidance:

PSL has submitted a license amendment request (ML21265A285) for the Technical Specifications conversion to NUREG-1432 Revision 5 in accordance with TSTF 577 Revision 1 (ML21098A188). Following NRC review and approval, including any applicable conditions or limitations, implementation of this license amendment will increase the inspection interval for 100% of the tubes to 96 EFPM. The 96 EFPM inspection interval for the tubes will also allow for visual inspection of the divider plates, tube-to-tubesheet welds, channel heads, and tubesheets in accordance with the Steam Generators AMP.

Enhancements None.

SLRA Section B.2.3.10 page B-92 and B-93 is revised as follows:

Plant Specific Operating Experience

  • A program health report review was performed covering the range of the first quarter of 2015 through the fourth quarter 2020. Health report attributes including owner proficiency, infrastructure, implementation, and equipment were Green for the majority of the review period. However, high tubing plugging rate in Unit 2 steam generator BA due to mechanical wear at AVBs, and water hammer condition vulnerability on Unit 2 steam generators were gaps to Green. The plugging rate is being monitored during every outage.

Visual inspection of the feedring and its supports in the Unit 2 steam generators is performed every outage regularly due to a prior history of condensation-induced water hammer events. Due to design differences the Unit 1 feedring supports are not completely accessible for inspection.

However, limited Unit 1 feedwater feedring support inspections have not revealed any support degradation.

SLRA Section B.2.3.10 page B-95 is revised as follows:

Conclusion The PSL Steam Generators AMP, with exception, provides reasonable assurance that the effects of aging will be managed so that the intended function(s) of components within the scope of the AMP will be maintained consistent with the CLB during the SPEO.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 18 Page 38 of 38 SLRA Section B.2.3.20 page B-174 are revised as follows:

Recent industry OE was reviewed from the SLR Safety Evaluation Reports for the first three submitted SLRAs (Turkey Point, Peach Bottom, and Surry). Two main points of interest include (a) ensuring that the PSL One-Time Inspection AMP is not used for managing aging of systems or components with known age-related degradation issues, and (b) ensuring that one-time inspections are completed on steam generator components, as necessary. The steam generator inspection locations of interest for the One-Time Inspection AMP are the divider plate assemblies (based on evaluation per EPRI 3002002850) and any circumferential transition cone welds (if replacement activities resulted in a circumferential field weld).

  • The PSL steam generator divider plates are constructed of materials not susceptible to primary water stress corrosion cracking. The PSL Unit 1 RSG design includes a floating divider plate that has no crack initiation point.

The PSL Unit 2 RSG divider plates are Alloy 690 and Alloy 690 type weld materials. Therefore, the PSL Unit 1 and Unit 2 steam generator divider plates do not require inspection per the PSL One-Time Inspection AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 19 Page 1 of 6 Open-Cycle Cooling Water System Pipe Replacement Clarification Affected SLRA Sections: Table 19-3 (Appendices A1 and A2), B.2.3.11 SLRA Page Numbers: A1-71, A2-72, B-99, B-104, B-106 Description of Change:

The PSL SLRA Commitment and Implementation Schedule (Table 19-3 in Appendices A1 and A2) contains Commitment 14 d) which states Ensure that all above-ground, large-bore, safety-related ICW piping is replaced with AL6XN stainless steel.

The commitment requires revision in order to further clarify the scope of the piping replacement.

The replacement scope includes, as a minimum, the safety-related intake cooling water (ICW) system main lines and strainer bypass lines that are within the scope of GL 89-13.

Accordingly, SLRA Appendices A1 and A2 and Section B.2.3.11 are revised to clarify that the scope of this piping replacement includes the safety-related ICW system main lines and strainer bypass lines and to remove large-bore.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 19 Page 2 of 6 SLRA Appendix A1, Table 19-3 (Item 14), page A1-71 is revised as follows:

No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 14 Open-Cycle Cooling Water XI.M20 Continue the existing PSL Open-Cycle Cooling Water System AMP, No later than 6 months prior to System (19.2.2.11) including enhancement to: the SPEO, or no later than the last refueling outage prior to the a) Ensure program tests and inspections follow site procedures that SPEO i.e.:

include requirements for items such as lighting, distance offset, surface coverage, presence of protective coatings, and cleaning PSL1: 09/01/2035 processes.

b) Ensure the primary program document and applicable procedures and preventive maintenance activities include trending of wall thickness measurements at locations susceptible to ongoing degradation due to specific aging mechanisms (e.g., MIC). The PSL Open-Cycle Cooling Water System AMP will adjust the monitoring frequency based on the trending.

c) Ensure the primary program document and applicable procedures and preventive maintenance activities clarify that when components do not meet or are projected to not meet the next inspections minimum wall thickness requirements, the program includes reevaluation, repair, or replacement such components.

d) Ensure that all above-ground, large-bore main line and strainer bypass line, safety-related ICW piping is replaced with AL6XN stainless steel piping.

e) Clarify within the applicable procedures, specifications, and preventive maintenance activities that the 100% internal inspections of the ICW header piping will be supplemented with localized volumetric examinations (UT, radiography, etc.) as applicable for areas where visual inspection alone is not adequate or as needed to determine the extent of degradation.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 19 Page 3 of 6 SLRA Appendix A2, Table 19-3 (Item 14), page A2-72 is revised as follows:

No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 14 Open-Cycle Cooling Water XI.M20 Continue the existing PSL Open-Cycle Cooling Water System AMP, No later than 6 months prior to System (19.2.2.11) including enhancement to: the SPEO, or no later than the last refueling outage prior to the a) Ensure program tests and inspections follow site procedures that SPEO i.e.:

include requirements for items such as lighting, distance offset, surface coverage, presence of protective coatings, and cleaning PSL2: 10/06/2042 processes.

b) Ensure the primary program document and applicable procedures and preventive maintenance activities include trending of wall thickness measurements at locations susceptible to ongoing degradation due to specific aging mechanisms (e.g., MIC). The PSL Open-Cycle Cooling Water System AMP will adjust the monitoring frequency based on the trending.

c) Ensure the primary program document and applicable procedures and preventive maintenance activities clarify that when components do not meet or are projected to not meet the next inspections minimum wall thickness requirements, the program includes reevaluation, repair, or replacement such components.

d) Ensure that all above-ground, large-bore main line and strainer bypass line, safety-related ICW piping is replaced with AL6XN stainless steel piping.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 19 Page 4 of 6 SLRA Appendix B, Section B.2.3.11, page B-99 is revised as follows:

Element Affected Enhancement

4. Detection of Aging Ensure program tests and inspections follow site procedures Effects that include requirements for items such as lighting, distance offset, surface coverage, presence of protective coatings, and cleaning processes.
5. Monitoring and Trending Ensure the primary program document and applicable procedures and preventive maintenance activities to include trending of wall thickness measurements at locations susceptible to ongoing degradation due to specific aging mechanisms (e.g., MIC). The PSL Open-Cycle Cooling Water System AMP will adjust the monitoring frequency based on the trending.
7. Corrective Actions Ensure the primary program document and applicable procedures and preventive maintenance activities clarify that when components do not meet or are projected to not meet the next inspections minimum wall thickness requirements, the program includes reevaluation, repair, or replacement of such components.
10. Operating Experience Ensure that all above-ground, large-bore main line and strainer bypass line, SR ICW piping is replaced with AL6XN SS piping.
10. Operating Experience Clarify within the applicable procedures, specifications, and preventive maintenance activities that the 100% internal inspections of the ICW header piping will be supplemented with localized volumetric examinations (UT, radiography, etc.) as applicable for areas where visual inspection alone is not adequate or as needed to determine the extent of degradation.

Operating Experience Industry Operating Experience PSL evaluates industry OE items for applicability per the NextEra Energy Fleet OE Program and takes appropriate corrective actions.

The list below provides aging mechanisms and industry OE relevant to the PSL Open-Cycle Cooling Water System AMP, as described in NUREG-2191,Section XI.M20:

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 19 Page 5 of 6 SLRA Appendix B, Section B.2.3.11, page B-104 is revised as follows:

  • In November 2015, a 15-20 gpm leak was identified on the inside elbow of the Unit 2 30-inch ICW header upstream of a temperature control valve and downstream of a flow element and the CCW heat exchanger. The pipe hole was roughly the diameter of a pencil. As corrective actions, a UT examination was performed and a work order performed the pipe repair.
  • In June 2017, as a result of troubleshooting a leak in the Unit 2 CCW system, operations identified a CCW to ICW leak in the Unit 2 B CCW heat exchanger. An apparent cause analysis identified tubes with marine fouling inside, primarily oyster shells. Considering the sodium hypochlorite system was functioning again, lack of pipe cleaning during the most recent outage was identified as the primary cause of the fouling induced leakage. As a corrective action to prevent future occurrence, the procedures and outage preventive maintenance activities were updated to ensure cleaning of the ICW piping upstream of the CCW heat exchangers and downstream of the strainers.
  • In October 2019, during the installation of a new valve the existing flange mating surface had created a leak path for residual water flow. The flange was resurfaced by the coatings team in accordance with station procedures as part of the work order.
  • In February 2020, an approximately 1/2-inch leak, was found on the Unit 2 A ICW discharge header piping elbow. A work request and work order resolved the leak by replacing the elbow.
  • In April 2020, a leak at a Unit 1 ICW isolation valve and tee connection flange interface was identified. The leak appeared to be due to internal and external corrosion. A UT examination was performed. A work request, work order, and engineering change replaced the piping.

Due, primarily, to the external corrosion on the above-ground ICW system piping, an effort to replace the large-bore, above-ground main line and strainer bypass line portions of the SR ICW piping with AL6XN SS was initiated. This will also address internal corrosion concerns identified in the OE listed above.

For Unit 1, the piping between the Unit 1 B and C ICW pump discharge to the crosstie is currently in the process of being replaced. The piping from the A ICW pump discharge to the crosstie is scheduled for replacement during the refueling outage starting in 2021. For Unit 2, an elbow on the A train was replaced in 2020.

The piping from the B and C ICW pump discharge to the crosstie is currently in the process of being replaced. The piping from the A ICW pump discharge to the crosstie is scheduled for replacement during the refueling outage starting in 2021.

The large-bore, replacement of the above-ground, main line and strainer bypass line portions of the SR ICW piping replacement is scheduled to be complete prior to the SPEO. With this replacement, a majority of the degradation mechanisms in the OE listed above will be eliminated.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 19 Page 6 of 6 SLRA Appendix B, Section B.2.3.11, page B-106 is revised as follows:

recommended. As evaluated above, internal corrosion has occurred within multiple outages during the evaluated 10-year period and several of these occurrences involved a wall reduction of greater than 50 percent. Therefore, the PSL Open-Cycle Cooling Water AMP will need to manage recurring internal corrosion. One proactive action to reduce the number of internal corrosion issues is to replace the above-ground, large-bore, main line and strainer bypass line portions of the SR ICW piping with AL6XN SS piping. For the piping that is not replaced, the PSL Open-Cycle Cooling Water System AMP meets the recurring internal corrosion management recommendations from NUREG-2192 as follows:

a) The existing examination methods are sufficient to detect recurring internal corrosion before affecting the ability of a component to perform its intended function. These methods primarily include an internal visual inspection of 100 percent of the large-bore ICW header piping length. The visual inspections are currently augmented with brushing, scraping, and hammer testing as applicable to provide assurance that all internal piping degradation is identified. An enhancement will be created to perform volumetric inspections as applicable for areas where visual inspection alone is not adequate or as needed to determine the extent of degradation b) The existing ICW header inspections are 100 percent visual and are performed at an interval of every 2 refueling outages. When degradation is identified, it is repaired during the same refueling outage. This provides reasonable assurance that all degradation is identified along the ICW header length and that pressure boundary integrity will be maintained until the next inspection.

c) The existing inspection specification provides instructions for documenting inspection results within an Inspectors Report attached to an AR. The specification also provides instructions for the system engineer to map and trend the locations of patches, epoxy, or cement, within the ICW piping. The trending of the inspection parameters/results (e.g., repair locations) provides reasonable assurance that recurring internal corrosion will remain adequately managed.

d) Inspections of components that are buried, underground, or submerged are conducted per the same inspection specification, procedure, and preventive maintenance activities and personnel have been able to perform internal inspections of these sections of ICW piping. The implementation of the existing inspection activities provides reasonable assurance that recurring internal corrosion of the buried, underground, or submerged ICW system components will be adequately managed.

e) The PSL Open-Cycle Cooling Water System AMP uses system instrumentation and/or performance monitoring to identify leaks in involved buried, underground, or submerged ICW piping components. When leaks are identified, an AR is initiated to determine the cause, extent of degradation, and initiate corrective actions. Using instrumentation and/or performance monitoring to identify leaks and adjusting inspections to proactively identify leaks on other susceptible piping provides reasonable

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 1 of 70 Fire Protection: Clarified AMR Results and Related Further Evaluation Affected SLRA Sections: 2.4.17; Table 2.4-17; Table 3.3-1 Items 3.3-1, 060, 3.3-1, 179, and 3.3-1, 255; 3.5.2.1.2; 3.5.2.1.4; 3.5.2.1.5; 3.5.2.1.6; 3.5.2.1.10; 3.5.2.1.11; 3.5.2.1.17; 3.5.2.2.2.4; Table 3.5-1, Items 3.5-1, 043, 044, 047, 054, 063, 065, 066, 067, 070, 077, 082, and 100; Table 3.5.2-1; Table 3.5.2-1 Plant Specific Notes; Table 3.5.2-2; Table 3.5.2-2 General and Plant Specific Notes; Table 3.5.2-4; Table 3.5.2-4 General and Plant Specific Notes; Table 3.5.2-5; Table 3.5.2-5 General and Plant Specific Notes; Table 3.5.2-6; Table 3.5.2-6 General and Plant Specific Notes; Table 3.5.2-10 and notes; Table 3.5.2-11 and notes; Table 3.5.2-13; Table 3.5.2-17; 19.2.2.15 (Appendices A1 and A2); Table 19-3 (Appendices A1 and A2),

Commitment Nos. 18(b) and 18(c); B.2.3.15 SLRA Page Numbers: 2.4-35, 2.4-36, 3.3-37, 3.3-59, 3.3-76, 3.5-4, 3.5-6, 3.5-7, 3.5-12, 3.5-13, 3.5-18, 3.5-33, 3.5-57, 3.5-58, 3.5-60, 3.5-62 through 3.5-66, 3.5-70 through 3.5-80, 3.5-86, 3.5-87, 3.5-89, 3.5-92 through 3.5-98, 3.5-100 through 3.5-102, 3.5-114 through 3.5-120, 3.5-125, 3.5-142 through 3.5-145, A1-21, A1-22, A1-76, A1-77, A2-21, A2-22, A2-77, A2-78, B-121, B-122, B-123 Description of Change:

Item 3.3-1, 255 in NUREG-2191 identifies the aging effects for fire damper assemblies. Fire damper assemblies include all elements of a fire damper (the parts of the damper itself and the parts of the damper frame). However, 10 CFR 54 (as supported by the guidance in NEI 95-10 Appendix B, page B-15) indicates that license renewal activities are supposed to manage the aging of passive, long-lived components. The elements of the damper subcomponent of the fire damper assembly are classified as active components and thus do not require an aging management review. Elements of the housing subcomponent of the fire damper assembly are passive and managed for aging. The fire damper housings at PSL are constructed of steel (elastomers are not part of the housing) and do not experience the cracking, loss of strength, or shrinkage aging effects identified in NUREG-2192, Table 3.3-1, Item 255. The discussion of NUREG-2192, Table 3.3-1, Item 255 in the subsequent license renewal application (SLRA) is updated to reflect this. Additionally, the statement that indicates that the fire dampers are evaluated with the ventilation subsection is in error and is deleted. To ensure that this position is clearly and consistently applied in the St.

Lucie Nuclear Plant (PSL) SLRA, changes are made in SLRA Section 2.4.17; Table 3.3-1 Item 3.3-1, 255; Appendices A1 and A2, Section 19.2.2.15; Appendices A1 and A2, Table 19-3, Commitment No. 18(c); and Appendix B, Section B.2.3.15.

A review of SLRA Appendix A2, Section 19.2.2.15 identified that the section had incorrectly included a discussion of the halon fire suppression system with the Unit 2 UFSAR changes.

This is an oversight and the only halon suppression system is in Unit 1, not Unit 2. The incorrect sentence is deleted. Additional details regarding the frequency of testing of the halon system in Unit 1 is added to SLRA Appendix A1, Section 19.2.2.15 and Appendix B, Section B.2.3.15.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 2 of 70 A review of section 3.5 indicates a lack of consistency and/or a lack of clarity regarding structural components with a fire barrier function.

  • Table 3.5.2-1 has several entries that include a fire barrier intended function but do not identify the Fire Protection aging management program (AMP) as responsible for managing the aging effects of these components. A similar situation was identified in Point Beach (PBN) RAI B.2.3.15-2 (discussed on page 3-67 of PBN SLRA SER -

ML22054A108), and use of the inspection and acceptance criteria for the 10 CFR Part 50, Appendix J; ASME Section XI, Subsection IWE; and ASME Section XI, Subsection IWL AMPs cited to manage the applicable aging effects for structural components that have a fire barrier intended function are equivalent or better than those in the Fire Protection AMP. Consistent with the resolution of the PBN RAI, a plant specific note is added to all table 3.5.2-1 items that have a fire barrier function indicating, Component also provides a fire barrier function as evaluated in the Fire Protection Program Design Document that is physically equivalent to the structural functions managed under the associated Containment structural programs or other applicable AMPs.

  • Tables 3.5.2-2, 3.5.2-4, 3.5.2-5, 3.5.2-6, 3.5.2-10, and 3.5.2-11 have a general note E and a plant specific note added to indicate that fire barrier functions are managed by the Fire Protection AMP, similar to the plant specific note added by PBN in response to RAI B.2.3.15-2 (discussed on page 3-68 of ML22054A108).

Table 3.5.2-10 (Reactor Auxiliary Buildings, the only location with masonry walls credited for fire barriers) is revised to include a second plant specific note to address masonry walls separately from reinforced concrete fire barriers. Table 3.5-1 items associated with these entries and sections 3.5.2.1.2; 3.5.2.1.4; 3.5.2.1.5; 3.5.2.1.6; 3.5.2.1.10; and 3.5.2.1.11 have been edited to include discussion of the fire protection AMP.

  • In Table 3.5.2-10, the fire barrier intended function is removed from the airtight doors component because the fire barrier function for all fire door component types are addressed in Table 3.5.2-17.
  • Items 3.3-1, 060 and 3.3-1, 179 discussions are updated to reflect all the 3.5-1 items that are used to address reinforced concrete and masonry walls respectively. Item 3.3-1, 179 discussion includes the basis for not including loss of material as an aging effect requiring management for masonry walls (specifically that the aging mechanism - freeze-thaw does not apply to southern Florida).
  • Table 3.5.2-13 mistakenly listed fire protection as the intended function for concrete curbs in the 2B switchgear room. These entries are corrected to indicate the intended function is fire prevention.
  • Occasionally, it was necessary to add a qualifier to the component type listed in some of the 9-column tables in section 3.5 (e.g., accessible and inaccessible).

These qualifiers were necessary to match GALL-SLR line items in the structural AMR tables since the environments were different. Because the intended functions in the 9-column tables still match the intended functions for the unqualified component type described in the tables in section 2.4, no discrepancy exists and no change to the SLRA is required.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 3 of 70 Section 3.5.2.1.17 and entries in Table 3.5.2-17 are revised to specify that the fire retardant coating used at PSL is Flamemastic.

Table 3.5.2-17 is revised as follows:

  • The Fire Protection AMP does not have any exceptions so general notes B and D should not be used in the table. Thus, all items crediting the Fire Protection AMP and using generic note Bs are replaced with note As.
  • The line item for silicone foam conduit plugs is revised to reflect generic note C because item 3.3-1, 057 is for elastomers.
  • The rows associated with airtight and watertight doors are removed. For the purposes of the fire barrier commodities tables and all aspects of the Fire Protection AMP that will manage their aging, these doors are just fire doors and are addressed in the sole line item for fire doors (NFPA 805 barriers). The other functions these doors have are addressed in other section 3.5 tables and aging effects for these doors are managed by the Structures Monitoring AMP. Note that the changes identified in Attachment 6 of this supplement are performed in conjunction to the entries in this table and a review of these changes does not indicate a conflict between the two responses. The associated rows are deleted from Table 2.4-17 as well.
  • Rows are added to the table to address the stainless steel and aluminum straps used to secure fire wrap. The Fire Protection AMP will manage the aging of these straps for both loss of material and cracking. A row is added to Table 2.4-17 as well.
  • Entries for Miscellaneous barriers will be revised to state Miscellaneous fire barriers to match with Table 2.4-17 entries.

Fire door inspection procedures will have limitations added to the hole size for which installation of a steel screw would be acceptable for a corrective action. These limitations will ensure that the procedural guidance aligns with the requirements in National Fire Protection Association (NFPA) codes and engineering evaluations, which are consistent with NUREG-2191 guidance.

Table 3.5-1 is revised to add the cracking aging effect to item 3.5-1, 100 in the fire protection portion of the discussion and correct the AMPs listed in the Aging Management Program / TLAA column. Cracking was inadvertently omitted from the discussion for item 3.5-1, 100, but was included everywhere that it was applied in Table 3.5.2-17. Section 3.5.2.2.2.4 is revised to delete the statement indicating that the only aluminum in plant structures is for fire barrier mechanical penetrations because Table 3.5.2-16 indicates that nonsafety-related component supports, conduits, and cable trays are also constructed of aluminum. The AMPs that are listed for 3.5-1, 100 in NUREG-2192 are AMP XI.M32, "One Time Inspection," AMP XI.S6, Structures Monitoring," or AMP XI.M36, "External Surfaces Monitoring of Mechanical Components. AMP XI.S3, "ASME Section XI, Subsection IWF,"

should not be there and is deleted, and AMP XI.S6, Structures Monitoring," is added.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 4 of 70 Appendices A1 and A2, Table 19-3, Commitment No. 18(b); and Appendix B, Section B.2.3.15 are revised to include the inadvertently omitted aging effect of separation for fireproofing/fire barriers. Appendices A1 and A2, Section 19.2.2.15 and Appendix B, Section B.2.3.15 are revised to remove the word abnormal from discussions involving deterioration of the penetration seals to more closely align with GALL-SLR guidance.

The last paragraph of the Description subsection of Section 2.4.17 is revised to provide additional information regarding the silicone gels and grout that are part of some penetration seals.

Note that the markups for SLRA pages 2.4-35, 2.4-36, 3.5-33, 3.5-70, 3.5-142, 3.5-143, 3.5-144 and 3.5-145 include changes associated with Attachment 6 to this supplement.

Markups for SLRA pages 3.5-71, 3.5-72, 3.5-73, 3.5-74, 3.5-75, 3.5-76, 3.5-77, 3.5-78, 3.5-79, 3.5-80 and 3.5-86 include changes associated with Attachment 8 to this supplement.

Markups for SLRA page 3.5-80 include markups associated with Attachment 5 and Table 3.5.2-1 include changes associated with Attachments 6 and 8 to this supplement.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 5 of 70 SLRA Section 2.4.17 on page 2.4-35, is revised as follows:

on steel framing are also used as fire barriers. Concrete and masonry walls, floors, and ceilings are evaluated with the specific structure in which they reside.

Fire door assemblies prevent the spread of fire through fire barrier passageways.

Fire dampers are provided to prevent the spread of fire through ventilation penetrations. Fire dampers are evaluated with Ventilation in Subsection 2.3.3.15.

Penetration seals are provided to maintain the integrity of fire barriers at barrier penetrations. The types of materials used for the various penetrations range from silicone elastomers gels for piping and heating, ventilation, and air conditioning (HVAC) penetrations to grouts (cementitious fire barrier materials) for conduit and plumbing. Cable tray penetrations are sealed with Marinite board, ceramic fiber filler material, and a protective fire-retardant cable coating.

Boundary The evaluation boundary for fire rated assemblies is the external surface of that assembly. The fire area boundaries (walls, ceilings, and floors) define the NFPA 805 Areas. Concrete and masonry fire barriers (i.e., walls) are screened with the structure in which they reside.

System Intended Functions SR functions (10 CFR 54.4(a)(1)):

None.

NNS components that could affect SR functions (10 CFR 54.4(a)(2)):

1) Airtight fire doors and fFire barrier penetration seals associated with SR ventilation system boundaries (e.g., control room air conditioning, ECCS area ventilation, etc.) and watertight fire doors associated with flood protection are NNS fire rated assemblies which could affect SR functions.

FP, EQ, PTS, ATWS, and SBO functions (10 CFR 54.4(a)(3)):

1) FP - Relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the NRC's regulations for FP. Generally, the FP System protects plant equipment in the event of a fire to ensure safe plant shutdown and minimize the risk of a radioactive release to the environment. Fire assemblies with an intended function of providing pressure boundary for this commodity group are for halon in the cable spreading room.

UFSAR References Unit 1 6.4.1 and 9.5.1 (Unit 1) 6.4.5 and 9.5.1 (Unit 2)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 6 of 70 SLRA Table 2.4-17, page 2.4-36, is revised as follows:

Table 2.4-17 Fire Rated Assemblies Subject to Aging Management Review Component Type Component Intended Function(s)

Conduit caps Fire barrier Pressure boundary Conduit plugs Fire barrier Fire damper housings Fire barrier Fire doors - airtight Fire barrier Pressure boundary Fire doors - watertight Fire barrier Flood barrier Fire doors (NFPA 805 barriers) Fire barrier Pressure boundary Fire wrap (conduit and steel supports) Fire barrier Fire sealed isolation joint Fire barrier Fire seals - cable tray penetrations Fire barrier Pressure boundary Fire seals - mechanical penetrations Fire barrier Pressure boundary Fire wrap (conduit and steel supports) Fire barrier Flame impingement shields (insulating Fire barrier blankets for cable trays)

Miscellaneous fire barriers Fire barrier Pressure boundary Miscellaneous fire barriers - straps Fire barrier Radiant energy shields Fire barrier

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 7 of 70 SLRA Table 3.3-1 Item 3.3-1, 060 on page 3.3-37 is revised as follows:

Table 3.3 1: Summary of Aging Management Evaluations for the Auxiliary Systems Item Component Aging Effect/Mechanism Aging Management Further Discussion Number Program (AMP)/TLAA Evaluation Recommended 3.3-1, 060 Reinforced concrete Cracking due to chemical AMP XI.M26, No Not applicable. There are no reinforced structural fire reaction, weathering, "Fire Protection," and concrete structural fire barriers exposed to barriers: walls, settlement, or corrosion of AMP XI.S6, air in the Auxiliary Systems. Line items ceilings and floors reinforcement; loss of "Structures Monitoring" 3.5-1, 043, 3.5-1, 044, 3.5-1, 047, exposed to air material due to 3.5-1, 054, 3.5-1, 063, 3.5-1, 065, delamination, exfoliation, 3.5-1, 066, and 3.5-1, 067 are is used for spalling, popout, or scaling reinforced concrete structural fire barriers.

SLRA Table 3.3-1 Item 3.3-1, 179 on page 3.3-59 is revised as follows:

Table 3.3 1: Summary of Aging Management Evaluations for the Auxiliary Systems Item Component Aging Effect/Mechanism Aging Management Further Discussion Number Program (AMP)/TLAA Evaluation Recommended 3.3-1, 179 Masonry walls: Cracking due to restraint AMP XI.M26, "Fire No Not used.

structural fire shrinkage, creep, Protection," and AMP While there are fire barriers exposed to air, barriers exposed to aggressive environment; XI.S5, they are covered by line items 3.3-1, 267, air loss of material (spalling, "Masonry Walls" 3.3-1, 268, and 3.3-1, 269.

scaling) and cracking due Not applicable. There are no masonry to freeze-thaw wall structural fire barriers exposed to air in the Auxiliary Systems. Line item 3.5-1, 070 is used for masonry wall structural fire barriers. Masonry walls at PSL are not susceptible to cracking because the aging mechanism (freeze-thaw) does not occur in the southern Florida climate.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 8 of 70 SLRA Table 3.3-1 Item 3.3-1, 255 on page 3.3-76 is revised as follows:

Table 3.3 1: Summary of Aging Management Evaluations for the Auxiliary Systems Item Component Aging Effect/Mechanism Aging Management Further Discussion Number Program (AMP)/TLAA Evaluation Recommended 3.3-1, 255 Any material fire Loss of material due to AMP XI.M26, No Consistent with NUREG-2191.

damper assemblies general, pitting, crevice "Fire Protection" The Fire Protection AMP is used to manage exposed to air corrosion; cracking due to loss of material for steel fire damper SCC; hardening, loss of housings (i.e., the passive portion of the strength, shrinkage due to fire damper assemblies, which do not elastomer degradation include elastomers) exposed to air.

Cracking, hardening, loss of strength, and shrinkage are not applicable aging effects for fire damper housings, which have steel construction. This line item is used to evaluate structural items in Section 3.5.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 9 of 70 SLRA Section 3.5.2.1.2 on page 3.5-4, is revised as follows:

  • Masonry Walls (B.2.3.32)
  • One Time Inspection (B.2.3.20)
  • Protective Coating Monitoring and Maintenance (B.2.3.35)
  • Structures Monitoring (B.2.3.33)
  • Water Chemistry (B.2.3.2) 3.5.2.1.2 Component Cooling Water Areas Materials The materials of construction for the component cooling water area components are:
  • Concrete (reinforced)
  • Galvanized steel
  • Steel Environments The component cooling water area components are exposed to the following environments:
  • Air - indoor uncontrolled
  • Air - outdoor
  • Groundwater / soil
  • Soil
  • Water - flowing Aging Effects Requiring Management The following aging effects associated with the component cooling water areas require management:
  • Cracking
  • Distortion
  • Increase in porosity and permeability
  • Loss of bond
  • Loss of material
  • Loss of preload
  • Loss of strength Aging Management Programs The following AMPs manage the aging effects for the component cooling water area components:
  • Fire Protection (B.2.3.15)
  • Structures Monitoring (B.2.3.33)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 10 of 70 SLRA Section 3.5.2.1.4 on page 3.5-6, is revised as follows:

Environments The condensate storage tank enclosure components are exposed to the following environments:

  • Air - indoor uncontrolled
  • Air - outdoor
  • Groundwater / soil
  • Soil
  • Water - flowing Aging Effects Requiring Management The following aging effects associated with the condensate storage tank enclosures require management:
  • Cracking
  • Distortion
  • Increase in porosity and permeability
  • Loss of bond
  • Loss of material
  • Loss of preload
  • Loss of strength Aging Management Programs The following AMPs manage the aging effects for the condensate storage tank enclosure components:
  • Fire Protection (B.2.3.15)
  • Structures Monitoring (B.2.3.33) 3.5.2.1.5 Diesel Oil Equipment Enclosures Materials The materials of construction for the diesel oil equipment enclosure components are:
  • Concrete (reinforced)
  • Galvanized steel
  • Steel Environments The diesel oil equipment enclosure components are exposed to the following environments:
  • Air - indoor uncontrolled
  • Air - outdoor
  • Groundwater / soil

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 11 of 70 SLRA Section 3.5.2.1.5 on page 3.5-7, is revised as follows:

  • Soil
  • Water - flowing Aging Effects Requiring Management The following aging effects associated with the diesel oil equipment enclosures require management:
  • Cracking
  • Distortion
  • Increase in porosity and permeability
  • Loss of bond
  • Loss of material
  • Loss of preload
  • Loss of strength Aging Management Programs The following AMPs manage the aging effects for the diesel oil equipment enclosure components:
  • Fire Protection (B.2.3.15)
  • Concrete (reinforced)
  • Galvanized steel
  • Air - indoor uncontrolled
  • Air - outdoor
  • Groundwater / soil
  • Soil
  • Water - flowing

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 12 of 70 SLRA Section 3.5.2.1.10 on page 3.5-12, is revised as follows:

Aging Effects Requiring Management The following aging effects associated with the reactor auxiliary buildings require management:

  • Cracking
  • Distortion
  • Increase in porosity and permeability
  • Loss of bond
  • Loss of material
  • Loss of preload
  • Loss of sealing
  • Loss of strength Aging Management Programs The following AMPs manage the aging effects for the reactor auxiliary building components:
  • Fire Protection (B.2.3.15)
  • Masonry Walls (B.2.3.32)
  • Structures Monitoring (B.2.3.33) 3.5.2.1.11 Steam Trestle Areas Materials The materials of construction for the steam trestle area components are:
  • Concrete (reinforced)
  • Galvanized steel
  • Steel Environments The steam trestle area components are exposed to the following environments:
  • Air - outdoor
  • Groundwater / soil
  • Soil
  • Water - flowing Aging Effects Requiring Management The following aging effects associated with the steam trestle areas require management:
  • Cracking
  • Distortion
  • Increase in porosity and permeability

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 13 of 70 SLRA Section 3.5.2.1.11 on page 3.5-13, is revised as follows:

  • Loss of bond
  • Loss of material
  • Loss of preload
  • Loss of strength Aging Management Programs The following AMPs manage the aging effects for the steam trestle area components:
  • Fire Protection (B.2.3.15)
  • Structures Monitoring (B.2.3.33) 3.5.2.1.12 Switchyard Materials The materials of construction for the switchyard components are:
  • Caulking and sealants
  • Concrete (reinforced)
  • Concrete block (reinforced)
  • Steel (galvanized steel)

Environments The switchyard components are exposed to the following environments:

  • Air - indoor uncontrolled
  • Air - outdoor
  • Groundwater / soil
  • Soil
  • Water - flowing Aging Effects Requiring Management The following aging effects associated with the switchyard require management:
  • Cracking
  • Distortion
  • Increase in porosity and permeability
  • Loss of bond
  • Loss of material
  • Loss of preload
  • Loss of sealing
  • Loss of strength

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 14 of 70 SLRA Section 3.5.2.1.17 on page 3.5-18, is revised as follows:

  • Fire retardant coating (Flamemastic)
  • Galvanized steel
  • Elastomer
  • Elastomer: dymeric sealant, ethafoam
  • Insulating blankets (B&B or Mecatiss)
  • Marinite board
  • Silicate: ceramic fiber
  • Silicates: cerablanket
  • Silicone
  • Silicone foam
  • Stainless steel
  • Steel
  • Subliming compound: thermo-lag 330-1, thermo-lag 770-1 Environments The fire rated assembly components are exposed to the following environments:
  • Air
  • Air - indoor controlled
  • Air - indoor uncontrolled Aging Effects Requiring Management The following aging effects associated with the fire rated assemblies require management:
  • Change in material properties
  • Cracking
  • Delamination
  • Hardening
  • Loss of material
  • Loss of strength
  • Separation
  • Shrinkage Aging Management Programs The following AMPs manage the aging effects for the fire rated assembly components:
  • Fire Protection (B.2.3.15)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 15 of 70 SLRA Section 3.5.2.2.2.4 on page 3.5-33, is revised as follows:

Stainless steel structural components are limited in comparison to the amount of stainless-steel mechanical components at the site. Aluminum in plant structures is limited to fire barrier mechanical penetrations. Furthermore, tThere has been no site OE of cracking or localized corrosion of SS or aluminum SSCs. However, cracking due to SCC and loss of material due to pitting and crevice corrosion is a potentially applicable aging effect at PSL plant structures for SS and aluminum, and is managonitored with the PSL Structures Monitoring (B.2.3.33) AMP, the ASME Section XI, Subsection IWF (B.2.3.30) AMP, and the Fire Protection (B.2.3.15) AMP. To provide reasonable assurance that the aging effect of cracking is managed during the SPEO for ASME class 1 (non-RCS), class 2, and class 3 stainless steel supports, the visual inspections of the ASME Section XI, Subsection IWF (B.2.3.30) AMP will be supplemented by the Structures Monitoring (B.2.3.33) AMP. Should cracking due to SCC be identified for stainless steel mechanical or non-ASME structural components, engineering evaluation will determine the appropriate refined acceptance criteria, expansion criteria, examination frequency, and corrective actions. This evaluation, conducted through the Structures Monitoring (B.2.3.33) AMP, will also include ASME class 1 (non-RCS),

class 2, or class 3 stainless steel support members, welds, bolted connections, or anchorage to structures.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 16 of 70 SLRA Table 3.5-1, Items 3.5-1, 043, 044, 047, 054, 063, 065, 066, 067, 070, 077, 082, and 100 on pages 3.5-57, 3.5-58, 3.5-60, 3.5-62 through 3.5-66, and 3.5-70, is revised as follows:

Table 3.5-1: Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Item Aging Aging Management Further Evaluation Component Discussion Number Effect/Mechanism Program / TLAA Recommended 3.5-1, 043 All Groups except Cracking due to Plant-specific AMP or Yes (SRP-SLR Group 2 and 9 structures are not applicable to Group 6: concrete expansion from AMP XI.S6, "Structures Section 3.5.2.2.2.1.2) PSL.

(inaccessible reaction with Monitoring," enhanced Consistent with the current renewed licenses, areas): all aggregates as necessary a plant-specific AMP is not required to manage cracking in inaccessible areas due to reaction with aggregates. PSL concrete components did not come from a region known to yield suspected of or known to cause aggregate reactions. The Structures Monitoring AMP includes examination for cracking, darkened crack edges, water ingress and misalignment that would be indicative of reaction with aggregates. The Structures Monitoring AMP also includes opportunistic examination of below-grade inaccessible concrete areas. The Fire Protection AMP also manages cracking due to chemical reaction for structural fire barriers.

Further evaluation is documented in Section 3.5.2.2.2.1, item 2.

3.5-1, 044 All Groups: Cracking and AMP XI.S6, "Structures Yes (SRP-SLR Group 2 and 9 structures are not applicable to concrete: all distortion due to Monitoring" Section 3.5.2.2.2.1.3) PSL.

increased stress PSL does not rely upon a de-watering system levels from to control groundwater level and settlement is settlement included in the Structures Monitoring (B.2.3.33) AMP and, for structural fire barriers, the Fire Protection AMP.

Further evaluation is documented in Section 3.5.2.2.2.1, item 3.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 17 of 70 Table 3.5-1: Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Item Aging Aging Management Further Evaluation Component Discussion Number Effect/Mechanism Program / TLAA Recommended 3.5-1, 047 Groups 1-5, 7-9: Increase in porosity Plant-specific AMP or Yes (SRP-SLR Group 2 and 9 structures are not applicable to concrete and permeability; loss AMP XI.S6, "Structures Section 3.5.2.2.2.1.4) PSL.

(inaccessible of strength due to Monitoring" enhanced Consistent with the current renewed licenses, areas): exterior, leaching of calcium as necessary a plant-specific AMP is not required for above-and hydroxide and inaccessible area.

below-grade; carbonation. For SLR, groundwater is considered to be foundation flowing water where leaching or carbonation could potentially occur. The Structures Monitoring (B.2.3.33) AMP includes opportunistic inspection of inaccessible concrete surfaces, when excavated for other reasons, and evaluation of impact to inaccessible area intended functions if degradation, such as leaching or carbonation, is observed in accessible area. The Fire Protection AMP manages loss of material for structural fire barriers as well.

Further evaluation is documented in Section 3.5.2.2.2.1, item 4.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 18 of 70 Table 3.5-1: Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Item Aging Aging Management Further Evaluation Component Discussion Number Effect/Mechanism Program / TLAA Recommended 3.5-1, 054 All groups except 6: Cracking due to AMP XI.S6, "Structures No Consistent with NUREG-2191. Group 2 and 9 concrete expansion from Monitoring" structures are not applicable to PSL.

(accessible areas): reaction with PSL concrete components did not come from all aggregates a region known to yield suspected of or known to cause aggregate reactions. The Structures Monitoring (B.2.3.33) AMP includes examination for cracking, darkened crack edges, water ingress and misalignment that would be indicative of reaction with aggregates. The Fire Protection AMP also manages cracking due to chemical reaction for structural fire barriers. The Structures Monitoring (B.2.3.33) AMP is credited with managing cracking of accessible concrete exposed to uncontrolled indoor air, and outdoor air environments.

Table 3.5-1: Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Item Aging Aging Management Further Evaluation Component Discussion Number Effect/Mechanism Program / TLAA Recommended 3.5-1, 063 Groups 1-3, 5, 7-9: Increase in porosity AMP XI.S6, "Structures No Consistent with NUREG-2191.

concrete and permeability; loss Monitoring" The Structures Monitoring (B.2.3.33) AMP is (accessible areas): of strength due to credited with managing leaching or exterior above-and leaching of calcium carbonation of exterior plant structure below-grade; hydroxide and concrete and foundations where groundwater foundation carbonation or precipitation run-off forms a flowing water environment. The Fire Protection AMP manages loss of material for structural fire barriers as well.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 19 of 70 Table 3.5-1: Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Item Aging Aging Management Further Evaluation Component Discussion Number Effect/Mechanism Program / TLAA Recommended 3.5-1, 065 Groups 1-3, 5, 7-9: Cracking; loss of AMP XI.S6, "Structures No Consistent with NUREG-2191.

concrete bond; and loss of Monitoring" The Structures Monitoring (B.2.3.33) AMP is (inaccessible material (spalling, credited with managing cracking, loss of bond, areas): scaling) due to loss of material for inaccessible plant structure below-grade corrosion of concrete exposed to groundwater/soil or soil.

exterior; embedded steel The Fire Protection AMP also manages foundation, cracking and loss of material (spalling, scaling) due to corrosion of reinforcement Groups 1-3, 5, 7-9: for structural fire barriers.

concrete (accessible areas):

below-grade exterior; foundation, Groups 6: concrete (inaccessible areas): all 3.5-1, 066 Groups 1-5, 7, 9: Cracking, Loss of AMP XI.S6, "Structures No Consistent with NUREG-2191 concrete bond, Loss of Monitoring" The Structures Monitoring (B.2.3.33) AMP is (accessible areas): material (spalling, credited with managing cracking, loss of bond, interior and scaling) due to and loss of material for accessible plant above-grade corrosion of structure concrete exposed to uncontrolled exterior embedded steel indoor air, and outdoor air environments. The Fire Protection AMP also manages cracking and loss of material (spalling, scaling) due to corrosion of reinforcement for structural fire barriers.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 20 of 70 Table 3.5-1: Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Item Aging Aging Management Further Evaluation Component Discussion Number Effect/Mechanism Program / TLAA Recommended 3.5-1, 067 Groups 1-5, 7, 9: Increase in porosity AMP XI.S6, "Structures No Consistent with NUREG-2191.

Concrete: interior; and permeability, Monitoring" The Structures Monitoring (B.2.3.33) AMP is above-grade Cracking, Loss of credited with managing potential increase in exterior, Groups material (spalling, porosity and permeability, cracking, and loss 1-3, 5, scaling) due to of material due to aggressive chemical attack 7 concrete aggressive chemical for inaccessible plant structure concrete in (inaccessible attack uncontrolled indoor air, outdoor air, and areas): groundwater/soil environments. The Fire below-grade Protection AMP also manages cracking exterior; and loss of material (spalling, scaling) due foundation, Group to chemical reaction for structural fire 6: concrete barriers.

(inaccessible areas): all Table 3.5-1: Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Item Aging Aging Management Further Evaluation Component Discussion Number Effect/Mechanism Program / TLAA Recommended 3.5-1, 070 Masonry walls: all Cracking due to AMP XI.S5, "Masonry No Consistent with NUREG-2191.

restraint shrinkage, Walls" The Masonry Walls (B.2.3.32) AMP is credited creep, aggressive with managing cracking of masonry walls environment exposed to uncontrolled indoor air and outdoor air. The Fire Protection AMP also manages cracking for structural fire barriers.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 21 of 70 Table 3.5-1: Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Item Aging Aging Management Further Evaluation Component Discussion Number Effect/Mechanism Program / TLAA Recommended 3.5-1, 077 Steel components: Loss of material due AMP XI.S6, "Structures No Consistent with NUREG-2191.

all structural steel to corrosion Monitoring" The Structures Monitoring (B.2.3.33) AMP is credited with managing loss of material of structural steel components exposed to uncontrolled indoor air and outdoor air. The Fire Protection AMP also manages loss of material for structural fire barriers.

Table 3.5-1: Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Item Aging Aging Management Further Evaluation Component Discussion Number Effect/Mechanism Program / TLAA Recommended 3.5-1, 082 Structural bolting Loss of material due AMP XI.S6, "Structures No Consistent with NUREG-2191.

to general, pitting, Monitoring" The Structures Monitoring (B.2.3.33) AMP is crevice corrosion credited with managing loss of material for structural bolting exposed to outdoor air. The Fire Protection AMP also manages loss of material for structural fire barriers.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 22 of 70 Table 3.5-1: Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Item Aging Aging Management Further Evaluation Component Discussion Number Effect/Mechanism Program / TLAA Recommended 3.5-1, 100 Aluminum, Loss of material due AMP XI.M32, Yes (SRP-SLR Consistent with NUREG-2191, as clarified.

stainless steel to pitting and crevice "One-Time Inspection," Section 3.5.2.2.2.4) The External Surfaces Monitoring of support members; corrosion, cracking AMP XI.S36, "ASME Mechanical Components (B.2.3.33) AMP is welds; bolted due to SCC Section XI, Subsection credited with managing loss of material and connections; IWF Structures cracking of stainless steel and aluminum support anchorage Monitoring," or AMP insulation jacketing, and aluminum and to building structure XI.M36, "External stainless steel non-safety related supports at Surfaces Monitoring of the Intake Structures. The Structures Mechanical Monitoring (B.2.3.33) AMP is credited with Components managing loss of material and cracking of nonsafety-related aluminum and stainless steel component supports, anchorage embedment, electrical and instrument panel and enclosures, conduits and cable trays, and aluminum supports exposed to air.

The Fire Protection (B.2.3.156) AMP is credited with managing loss of material and cracking in aluminum and stainless steel fire barrier penetrations and radiant energy shields.

Further evaluation is documented in Section 3.5.2.2.2.4.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 23 of 70 SLRA Table 3.5.2-1 on pages 3.5-71 through 3.5-80, is revised as follows:

Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Aging Intended NUREG-2191 Table 1 Component Type Material Environment Requiring Management Notes Function Item Item Management Program Air locks, maintenance Fire barrier Steel Air - outdoor Cracking 10 CFR Part 50, II.A3.CP-37 3.5-1, A, 1, 11 hatch and accessories Pressure Cumulative Appendix J II.A3.C-13 027009 boundary fatigue (B.2.3.31) damage ASME Section XI, Subsection IWE (B.2.3.29)

TLAA - Section 4.6, "Containment Liner Plate, Metal Containments, and Penetrations Fatigue" Air locks, maintenance Fire barrier Steel Air - outdoor Loss of leak 10 CFR Part 50, II.A3.CP-39 3.5-1, A, 11 hatch and accessories Pressure tightness Appendix J 029 boundary (B.2.3.31)

ASME Section XI, Subsection IWE (B.2.3.29)

Air locks, maintenance Fire barrier Steel Air - outdoor Loss of material 10 CFR Part 50, II.A3.C-16 3.5-1, A, 11 hatch and accessories Pressure Appendix J 028 boundary (B.2.3.31)

ASME Section XI, Subsection IWE (B.2.3.29)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 24 of 70 Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Aging Intended NUREG-2191 Table 1 Component Type Material Environment Requiring Management Notes Function Item Item Management Program Air locks, maintenance Fire barrier Steel Air - indoor Cracking 10 CFR Part 50, II.A3.CP-37 3.5-1, A, 1, 11 hatch and accessories Pressure uncontrolled Cumulative Appendix J II.A3.C-13 027009 boundary fatigue (B.2.3.31) damage ASME Section XI, Subsection IWE (B.2.3.29)

TLAA - Section 4.6, "Containment Liner Plate, Metal Containments, and Penetrations Fatigue" Air locks, maintenance Fire barrier Steel Air - indoor Loss of leak 10 CFR Part 50, II.A3.CP-39 3.5-1, A, 11 hatch and accessories Pressure uncontrolled tightness Appendix J 029 boundary (B.2.3.31)

ASME Section XI, Subsection IWE (B.2.3.29)

Air locks, maintenance Fire barrier Steel Air - indoor Loss of material 10 CFR Part 50, II.A3.C-16 3.5-1, A, 11 hatch and accessories Pressure uncontrolled Appendix J 028 boundary (B.2.3.31)

ASME Section XI, Subsection IWE (B.2.3.29)

Air locks, maintenance Fire barrier Steel Air with borated Loss of material Boric Acid III.B1.1.T-25 3.5-1, C, 11 hatch and accessories Pressure water leakage Corrosion 089 boundary (B.2.3.4)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 25 of 70 Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Aging Intended NUREG-2191 Table 1 Component Type Material Environment Requiring Management Notes Function Item Item Management Program Construction hatch and Fire barrier Steel Air - indoor Cracking 10 CFR Part 50, II.A3.CP-37 3.5-1, A, 1, 11 cover Pressure uncontrolled Cumulative Appendix J II.A3.C-13 027009 boundary fatigue (B.2.3.31) damage ASME Section XI, Subsection IWE (B.2.3.29)

TLAA - Section 4.6, "Containment Liner Plate, Metal Containments, and Penetrations Fatigue" Construction hatch and Fire barrier Steel Air - indoor Loss of material 10 CFR Part 50, II.A3.C-16 3.5-1, A, 11 cover Pressure uncontrolled Appendix J 028 boundary (B.2.3.31)

ASME Section XI, Subsection IWE (B.2.3.29)

Construction hatch and Fire barrier Steel Air with borated Loss of material Boric Acid III.B1.1.T-25 3.5-1, C, 11 cover Pressure water leakage Corrosion 089 boundary (B.2.3.4)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 26 of 70 Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Aging Intended NUREG-2191 Table 1 Component Type Material Environment Requiring Management Notes Function Item Item Management Program Containment vessel Pressure Steel Air - indoor Cracking 10 CFR Part 50, II.A3.CP-37 3.5-1, A, 2 (accessible) boundary uncontrolled Cumulative Appendix J II.A3.C-13 027009 Structural fatigue (B.2.3.31) support damage ASME Section XI, Subsection IWE (B.2.3.29)

TLAA - Section 4.6, "Containment Liner Plate, Metal Containments, and Penetrations Fatigue" Containment Fire barrier Steel Air - indoor Cracking 10 CFR Part 50, II.A3.CP-37 3.5-1, A, 1, 11 vessel nozzle Pressure uncontrolled Cumulative Appendix J II.A3.C-13 027009 (electrical) boundary fatigue (B.2.3.31)

Structural damage ASME Section support XI, Subsection IWE (B.2.3.29)

TLAA - Section 4.6, "Containment Liner Plate, Metal Containments, and Penetrations Fatigue" Containment vessel Fire barrier Steel Air - indoor Loss of material 10 CFR Part 50, II.A3.C-16 3.5-1, A, 11 nozzle (electrical) Pressure uncontrolled Appendix J 028 boundary (B.2.3.31)

Structural ASME Section support XI, Subsection IWE (B.2.3.29)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 27 of 70 Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Aging Intended NUREG-2191 Table 1 Component Type Material Environment Requiring Management Notes Function Item Item Management Program Containment vessel Fire barrier Steel Air with borated Loss of material Boric Acid III.B1.1.T-25 3.5-1, C, 11 nozzle (electrical) Pressure water leakage Corrosion 089 boundary (B.2.3.4)

Structural support Containment vessel Fire barrier Steel Air - indoor Loss of material 10 CFR Part 50, II.A3.C-16 3.5-1, A, 11 nozzle (fuel transfer) Pressure uncontrolled Appendix J 028 boundary (B.2.3.31)

Structural ASME Section support XI, Subsection IWE (B.2.3.29)

Containment vessel Fire barrier Steel Air with borated Loss of material Boric Acid III.B1.1.T-25 3.5-1, C, 11 nozzle (fuel transfer) Pressure water leakage Corrosion 089 boundary (B.2.3.4)

Structural support Containment vessel Fire barrier Steel Air - indoor Cumulative TLAA - Section II.A3.C-13 3.5-1, A, 11 nozzle (fuel transfer) Pressure uncontrolled fatigue damage 4.6, 009 boundary "Containment Structural Liner Plate, support Metal Containments, and Penetrations Fatigue" Containment vessel Fire barrier Nickel alloy Air - indoor Loss of material 10 CFR Part 50, II.A3.C-16 3.5-1, A, 11 nozzle (mechanical) Pressure uncontrolled Appendix J 028 boundary (B.2.3.31)

Structural ASME Section support XI, Subsection IWE (B.2.3.29)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 28 of 70 Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Aging Intended NUREG-2191 Table 1 Component Type Material Environment Requiring Management Notes Function Item Item Management Program Containment vessel Fire barrier Steel Air - indoor Loss of material 10 CFR Part 50, II.A3.C-16 3.5-1, A, 11 nozzle (mechanical) Pressure uncontrolled Appendix J 028 boundary (B.2.3.31)

Structural ASME Section support XI, Subsection IWE (B.2.3.29)

Containment vessel Fire barrier Steel Air with borated Loss of material Boric Acid III.B1.1.T-25 3.5-1, C, 11 nozzle (mechanical) Pressure water leakage Corrosion 089 boundary (B.2.3.4)

Structural support Containment vessel Fire barrier Nickel alloy Air - indoor Cumulative TLAA - Section II.A3.C-13 3.5-1, A, 11 nozzle (mechanical) Pressure uncontrolled fatigue damage 4.6, 009 boundary "Containment Structural Liner Plate, support Metal Containments, and Penetrations Fatigue" Containment vessel Fire barrier Steel Air - indoor Cumulative TLAA - Section II.A3.C-13 3.5-1, A, 11 nozzle (mechanical) Pressure uncontrolled fatigue damage 4.6, 009 boundary "Containment Structural Liner Plate, support Metal Containments, and Penetrations Fatigue" Fuel transfer Fire barrier Dissimilar metal Air - indoor Cracking 10 CFR Part 50, II.A3.CP-38 3.5-1, A, 11 penetration sleeve Pressure welds uncontrolled Appendix J 010 boundary (B.2.3.31)

Structural ASME Section support XI, Subsection IWE (B.2.3.29)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 29 of 70 Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Aging Intended NUREG-2191 Table 1 Component Type Material Environment Requiring Management Notes Function Item Item Management Program Fuel transfer Fire barrier Dissimilar metal Air - indoor Loss of material 10 CFR Part 50, II.A3.CP-36 3.5-1, A, 11 penetration sleeve Pressure welds uncontrolled Appendix J 035 boundary (B.2.3.31)

Structural ASME Section support XI, Subsection IWE (B.2.3.29)

Fuel transfer Fire barrier Steel Air - indoor Loss of material 10 CFR Part 50, II.A3.C-16 3.5-1, A, 11 penetration sleeve Pressure uncontrolled Appendix J 028 boundary (B.2.3.31)

Structural ASME Section support XI, Subsection IWE (B.2.3.29)

Fuel transfer Fire barrier Steel Air with borated Loss of material Boric Acid III.B1.1.T-25 3.5-1, C, 11 penetration sleeve Pressure water leakage Corrosion 089 boundary (B.2.3.4)

Structural support Fuel transfer Fire barrier Steel Air - indoor Cumulative TLAA - Section II.A3.C-13 3.5-1, A, 11 penetration sleeve Pressure uncontrolled fatigue damage 4.6, 009 boundary "Containment Structural Penetrations support Fatigue" Fuel transfer tube, Fire barrier Stainless steel Air - indoor Cracking 10 CFR Part 50, II.A3.CP-38 3.5-1, A, 11 expansion bellows, and Pressure uncontrolled Appendix J 010 flange boundary (B.2.3.31)

Structural ASME Section support XI, Subsection IWE (B.2.3.29)

Fuel transfer tube, Fire barrier Stainless steel Treated borated Loss of material One-Time VII.A2.AP-79 3.3-1, D, 11 expansion bellows, and Pressure water Inspection 125 flange boundary (B.2.3.20)

Structural Water support Chemistry (B.2.3.2)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 30 of 70 Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Aging Intended NUREG-2191 Table 1 Component Type Material Environment Requiring Management Notes Function Item Item Management Program Fuel transfer tube, Fire barrier Stainless steel Air - indoor Cumulative TLAA - Section II.A3.C-13 3.5-1, A, 11 expansion bellows, and Pressure uncontrolled fatigue damage 4.6, 009 flange boundary "Containment Structural Liner Plate, support Metal Containments, and Penetrations Fatigue" Interior beams, fill, Missile Concrete Air - indoor Cracking Structures III.A1.TP-25 3.5-1, B shields, slabs, and barrier (reinforced) uncontrolled Monitoring 054 walls (accessible) Shelter, (B.2.3.33) protection Structural support Interior beams, fill, Missile Concrete Air - indoor Cracking, loss Structures III.A1.TP-26 3.5-1, B shields, slabs, and barrier (reinforced) uncontrolled of bond, loss of Monitoring 066 walls (accessible) Shelter, material (B.2.3.33) protection Structural support Interior beams, fill, Missile Concrete Air - indoor Increase in Structures III.A1.TP-28 3.5-1, B shields, slabs, and barrier (reinforced) uncontrolled porosity and Monitoring 067 walls (accessible) Shelter, permeability, (B.2.3.33) protection cracking, loss of Structural material support Interior beams, fill, Missile Concrete Air - indoor Cracking Structures III.A1.TP-204 3.5-1, B, 3 shields, slabs, and barrier (reinforced) uncontrolled Monitoring 043 walls (inaccessible) Shelter, (B.2.3.33) protection Structural support

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 31 of 70 Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Aging Intended NUREG-2191 Table 1 Component Type Material Environment Requiring Management Notes Function Item Item Management Program Interior beams, fill, Missile Concrete Air - indoor Cracking, loss Structures II.A2.CP-75 3.5-1, D shields, slabs, and barrier (reinforced) uncontrolled of bond, loss of Monitoring 023 walls (inaccessible) Shelter, material (B.2.3.33) protection Structural support Masonry walls Shelter, Concrete block Air - indoor Cracking Masonry Walls III.A1.T-12 3.5-1, A protection (unreinforced) uncontrolled (B.2.3.32) 070 Structural support Masonry walls Shelter, Concrete block Air - indoor Cracking Masonry Walls III.A1.T-12 3.5-1, A protection (reinforced) uncontrolled (B.2.3.32) 070 Structural support Miscellaneous steel Fire barrier Steel Air with borated Loss of material Boric Acid III.B5.T-25 3.5-1, C, 11 (missile barriers, hatch Missile water leakage Corrosion 089 frame covers, framing barrier (B.2.3.4) for radiant energy Shelter, shields, etc.) protection Structural support Miscellaneous steel Fire barrier Galvanized steel Air with borated Loss of material Boric Acid III.B5.TP-3 3.5-1, C, 11 (missile barriers, hatch Missile water leakage Corrosion 089 frame covers, framing barrier (B.2.3.4) for radiant energy Shelter, shields, etc.) protection Structural support Miscellaneous steel Fire barrier Steel Air - indoor Loss of material Structures III.A1.TP-302 3.5-1, B, 11 (missile barriers, hatch Missile uncontrolled Monitoring 077 frame covers, framing barrier (B.2.3.33) for radiant energy Shelter, shields, etc.) protection Structural support

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 32 of 70 Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Aging Intended NUREG-2191 Table 1 Component Type Material Environment Requiring Management Notes Function Item Item Management Program Penetrations Fire barrier Steel Air - indoor Cracking 10 CFR Part 50, II.A3.CP-37 3.5-1, A, 1, 11 (electrical), Unit 1 Pressure uncontrolled Appendix J 027 boundary (B.2.3.31)

Structural ASME Section support XI, Subsection IWE (B.2.3.29)

Penetrations Fire barrier Steel Air - indoor Loss of material 10 CFR Part 50, II.A3.C-16 3.5-1, A, 11 (electrical), Unit 1 Pressure uncontrolled Appendix J 028 boundary (B.2.3.31)

Structural ASME Section support XI, Subsection IWE (B.2.3.29)

Penetrations Fire barrier Steel Air with borated Loss of material Boric Acid III.B1.1.T-25 3.5-1, C, 11 (electrical), Unit 1 Pressure water leakage Corrosion 089 boundary (B.2.3.4)

Structural support Penetrations Fire barrier Dissimilar metal Air - indoor Loss of material 10 CFR Part 50, II.A3.CP-36 3.5-1, A, 11 (electrical), Unit 2 Pressure welds uncontrolled Appendix J 035 boundary (B.2.3.31)

Structural ASME Section support XI, Subsection IWE (B.2.3.29)

Penetrations Fire barrier Stainless steel Air - indoor Cracking 10 CFR Part 50, II.A3.CP-37 3.5-1, A, 1, 11 (electrical), Unit 2 Pressure uncontrolled Appendix J 027 boundary (B.2.3.31)

Structural ASME Section support XI, Subsection IWE (B.2.3.29)

Penetrations Fire barrier Dissimilar metal Air - indoor Cracking 10 CFR Part 50, II.A3.CP-38 3.5-1, A, 4, 11 (mechanical), including Pressure welds uncontrolled Appendix J 010 bellows boundary (B.2.3.31)

Structural ASME Section support XI, Subsection IWE (B.2.3.29)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 33 of 70 Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Aging Intended NUREG-2191 Table 1 Component Type Material Environment Requiring Management Notes Function Item Item Management Program Penetrations Structural Dissimilar metal Air - indoor Loss of material 10 CFR Part 50, II.A3.CP-36 3.5-1, A, 11 (mechanical), including support welds uncontrolled Appendix J 035 bellows Pressure (B.2.3.31) boundary ASME Section XI, Subsection IWE (B.2.3.29)

Penetrations bellows Fire barrier Stainless steel Air - indoor Cracking 10 CFR Part 50, II.A3.CP-38 3.5-1, A, 4, 11 (mechanical), including Pressure uncontrolled Appendix J 010 bellows boundary (B.2.3.31)

Structural ASME Section support XI, Subsection IWE (B.2.3.29)

Penetrations Fire barrier Stainless steel Air - indoor Cracking 10 CFR Part 50, II.A3.CP-38 3.5-1, A, 4, 11 (mechanical), including Pressure uncontrolled Appendix J 010 bellows boundary (B.2.3.31)

Structural ASME Section support XI, Subsection IWE (B.2.3.29)

Penetrations Fire barrier Steel Air - indoor Loss of material 10 CFR Part 50, II.A3.CP-36 3.5-1, A, 11 (mechanical), including Pressure uncontrolled Appendix J 035 bellows boundary (B.2.3.31)

Structural ASME Section support XI, Subsection IWE (B.2.3.29)

Penetrations Fire barrier Dissimilar metal Air - indoor Cumulative TLAA - Section II.A3.C-13 3.5-1, A, 11 (mechanical), including Pressure welds uncontrolled fatigue damage 4.6, 009 bellows boundary "Containment Structural Liner Plate, support Metal Containments, and Penetrations Fatigue"

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 34 of 70 Table 3.5.2-1: Containment Building Structures - Summary of Aging Management Evaluation Aging Effect Aging Intended NUREG-2191 Table 1 Component Type Material Environment Requiring Management Notes Function Item Item Management Program Penetrations bellows Fire barrier Stainless steel Air - indoor Cumulative TLAA - Section II.A3.C-13 3.5-1, A, 11 (mechanical), including Pressure uncontrolled fatigue damage 4.6, 009 bellows boundary "Containment Structural Liner Plate, support Metal Containments, and Penetrations Fatigue" Penetrations Fire barrier Steel Air - indoor Cumulative TLAA - Section II.A3.C-13 3.5-1, A, 11 (mechanical), including Pressure uncontrolled fatigue damage 4.6, 009 bellows boundary "Containment Structural Liner Plate, support Metal Containments, and Penetrations Fatigue" Penetrations Insulate Calcium silicate Air - indoor None None VIII.H.S-403 3.4-1, I, 5 (mechanical), thermal (thermal) uncontrolled 064 insulation (type I hot penetrations)

Penetrations Insulate Calcium silicate Air - indoor None None V.E.E-422 3.2-1, I, 13 (mechanical), thermal (thermal) uncontrolled 087 insulation (type III semi-hot penetrations)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 35 of 70 SLRA Table 3.5.2-1 Plant Specific Notes on page 3.5-86, are revised as follows:

General Notes A. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

B. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

C. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

D. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

E. Consistent with NUREG-2191 material, environment, and aging effect but a different AMP is credited or NUREG-2191 identifies a plant-specific AMP.

F. Material not in NUREG-2191 for this component.

H. Aging effect not in NUREG-2191 for this component, material, and environment combination.

I. Aging effect in NUREG-2191 for this component, material and environment combination is not applicable.

Plant Specific Notes

1. Consistent with SLR-ISG-2021-03-STRUCTURES, Appendix A, Containment components with no fatigue analysis or waiver are susceptible to cracking due to cyclic loading.Deleted.
2. Manway at the top of the Containment Vessel is a permanently sealed (welded) shut part of the Containment Vessel.
3. Consistent with SLR-ISG-2021-03-STRUCTURES, the Structures Monitoring (B.2.3.33) AMP manages loss of material for stainless steel exposed to air, instead of plant-specific program, whereas cracking due to SCC of the same penetration components is managed by 10 CFR Part 50, Appendix J and ASME Section XI Subsection IWE AMPs.Deleted.
4. Eight Type III (semi-hot) penetration assemblies per unit and, conservatively, both units fuel transfer tubes are stainless steel or dissimilar metal weld and exposed to process temperatures > 140°F during normal plant operation and, therefore, susceptible to stress corrosion.Deleted.
5. Insulation for main steam and feedwater penetrations isare fully encased in the multiple flued head and guard pipes and there are no plausible moisture, contaminants, or exposures that could degrade the (calcium silicate) insulation.
6. The Sstainless steel fuel transfer tube and flange penetration assemblies include stainless steel pressure-retaining bolting that is managed by the ASME Section XI, Subsection IWE AMP.
7. Irradiation of the concrete primary shield wall is addressed in Section 3.5.2.2.2.6 and is managed by the Structures Monitoring (B.2.3.33) AMP.
8. The loss of fracture toughness aging effect due to irradiation embrittlement of the steel reactor vessel supports and bolting is addressed in Section 3.5.2.2.2.7 and is managed by the ASME Section XI, Subsection IWF (B.2.3.30) AMP.
9. Consistent with SLR-ISG-2021-03-STRUCTURES, the Structures Monitoring AMP manages cracking of concrete due to reaction with aggregates.
10. Bottom portion and bottom head of the Containment Vessel are completely encased in concrete fill inside the (Group 1) Shield Building. The operating floor inside the Containment Vessel is this concrete fill.
11. Component also provides a fire barrier function as evaluated in the Fire Protection Program Design Document that is physically equivalent to the structural functions managed under the associated Containment structural programs or other applicable AMPs.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 36 of 70

12. Evidence of cracking due to SCC and loss of material due to pitting and crevice corrosion (i.e., leakage) would be readily detected during refueling operations prior to loss of intended function for these components.
13. Insulation for Type III penetrations is fully encased in the multiple flued head and guard pipes and there are no plausible moisture, contaminants, or exposures that could degrade the (calcium silicate) insulation.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 37 of 70 SLRA Table 3.5.2-2 on page 3.5-87, is revised as follows:

Table 3.5.2-2: Component Cooling Water Area Structures - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Checkered plate, Structural Galvanized Air - indoor None None III.B5.TP 8 3.5 1, A grating, handrails, support steel uncontrolled 095 ladders, platforms, stairs Checkered plate, Structural Steel Air - indoor Loss of material Structures Monitoring III.A7.TP-302 3.5-1, B grating, handrails, support uncontrolled (B.2.3.33) 077 ladders, platforms, stairs Air - outdoor Checkered plate, Structural Galvanized Air - outdoor Loss of material Structures Monitoring III.A7.TP-274 3.5-1, D grating, handrails, support steel (B.2.3.33) 082 ladders, platforms, stairs Concrete: columns, Fire barrier Concrete Air - indoor Cracking Fire Protection III.A7.TP-25 3.5-1, E, 3 foundation, pedestals, Flood protection (reinforced) uncontrolled (B.2.3.15) 054 roof, shield walls, Missile barrier Air - outdoor Structures Monitoring B (accessible) Shelter, (B.2.3.33) protection Structural support Concrete: columns, Fire barrier Concrete Air - indoor Cracking Fire Protection III.A7.TP-26 3.5-1, E, 3 foundation, pedestals, Flood protection (reinforced) uncontrolled Loss of bond (B.2.3.15) 066 roof, shield walls, Missile barrier Air - outdoor Loss of material Structures Monitoring B (accessible) Shelter, (B.2.3.33) protection Structural support Concrete: columns, Fire barrier Concrete Water - flowing Increase in Fire Protection III.A7.TP-24 3.5-1, E, 3 foundation, pedestals, Flood protection (reinforced) porosity and (B.2.3.15) 063 roof, shield walls, Missile barrier permeability Structures Monitoring B, 1 (accessible) Shelter, Loss of strength (B.2.3.33) protection Structural support Concrete: columns, Fire barrier Concrete Air - indoor Cracking Fire Protection III.A7.TP-28 3.5-1, E, 3 pedestals, roof, shield Flood protection (reinforced) uncontrolled Increase in (B.2.3.15) 067 walls, slabs Missile barrier Air - outdoor porosity and Structures Monitoring B Shelter, permeability (B.2.3.33) protection Loss of material Structural support

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 38 of 70 SLRA Table 3.5.2-2 General and Plant Specific Notes on page 3.5-89, are revised as follows:

General Notes A. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

B. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

D. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

E. Consistent with NUREG 2191 material, environment, and aging effect but a different AMP is credited or NUREG 2191 identifies a plant specific AMP.

Plant Specific Notes

1. Groundwater is considered to be water-flowing.
2. Whereas the NUREG-2191/2192 item calls for a plant-specific AMP, PSL credits an existing AMP based on SLR-ISG-2021-03-STRUCTURE, Updated Aging Management Criteria for Structures Portions of Subsequent License Renewal Guidance.
3. Consistent with NUREG 2191 material, environment, and aging effect, but the Fire Protection AMP, in conjunction with the Structures Monitoring AMP, is credited with managing the fire barrier function on certain fire barriers in the yard, recognizing that other barriers in the yard have additional functions that are managed by the Structures Monitoring AMP or related AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 39 of 70 SLRA Table 3.5.2-4 on pages 3.5-92 through 3.5-93, is revised as follows:

Table 3.5.2-4: Condensate Storage Tank Enclosures - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Checkered plate, Structural Galvanized Air - indoor None None III.B5.TP-8 3.5-1, A grating, handrails, support steel uncontrolled 095 ladders, platforms, stairs Checkered plate, Structural Steel Air - indoor Loss of material Structures Monitoring III.A7.TP-302 3.5-1, B grating, handrails, support uncontrolled (B.2.3.33) 077 ladders, platforms, Air - outdoor stairs Checkered plate, Structural Galvanized Air - outdoor Loss of material Structures Monitoring III.B5.TP-274 3.5-1, D grating, handrails, support steel (B.2.3.33) 082 ladders, platforms, stairs Concrete: Structural Concrete Soil Cracking and Structures Monitoring III.A7.TP-30 3.5-1, B foundation/base mat support (reinforced) distortion (B.2.3.33) 044 Concrete: Fire barrier Concrete Air - indoor Cracking Fire Protection III.A7.TP-28 3.5-1, E, 3 foundation/base mat, Missile barrier (reinforced) uncontrolled Increase in (B.2.3.15) 067 dome, shield walls, Shelter, Air - outdoor porosity and Structures Monitoring B etc. protection permeability (B.2.3.33)

Structural Loss of material support Concrete: Structural Concrete Groundwater/soil Cracking Structures Monitoring III.A7.TP-212 3.5-1, B foundation/base mat, support (reinforced) Loss of bond (B.2.3.33) 065 ring pedestals Loss of material (inaccessible)

Concrete: Structural Concrete Groundwater/soil Cracking Structures Monitoring III.A7.TP-29 3.5-1, B foundation/base mat, support (reinforced) Increase in (B.2.3.33) 067 ring pedestals porosity and (inaccessible) permeability Loss of material Concrete: Structural Concrete Groundwater/soil Cracking Structures Monitoring III.A7.TP-204 3.5-1, B, 1 foundation/base mat, support (reinforced) (B.2.3.33) 043 ring pedestals (inaccessible)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 40 of 70 Table 3.5.2-4: Condensate Storage Tank Enclosures - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Concrete: Structural Concrete Water - flowing Increase in Structures Monitoring III.A7.TP-67 3.5-1, B, 1, 2 foundation/base mat, support (reinforced) porosity and (B.2.3.33) 047 ring pedestals permeability (inaccessible) Loss of strength Concrete: Fire barrier Concrete Air - indoor Cracking Fire Protection III.A7.TP-25 3.5-1, E, 3 roof/dome, shield Missile barrier (reinforced) uncontrolled (B.2.3.15) 054 walls (Unit 2 only) Shelter, Air - outdoor Structures Monitoring B (accessible) protection (B.2.3.33)

Structural support Concrete: Fire barrier Concrete Air - indoor Cracking Fire Protection III.A7.TP-26 3.5-1, E, 3 roof/dome, shield Missile barrier (reinforced) uncontrolled Loss of bond (B.2.3.15) 066 walls (Unit 2 only) Shelter, Air - outdoor Loss of material Structures Monitoring B (accessible) protection (B.2.3.33)

Structural support Concrete: Fire barrier Concrete Water - flowing Increase in Fire Protection III.A7.TP-24 3.5-1, E, 3 roof/dome, shield Missile barrier (reinforced) porosity and (B.2.3.15) 063 walls (Unit 2 only) Shelter, permeability Structures Monitoring B, 1 (accessible) protection Loss of strength (B.2.3.33)

Structural support Missile protection Missile barrier Steel Air - outdoor Loss of material Structures Monitoring III.A8.TP-302 3.5-1, B hood (Unit 2 only) (B.2.3.33) 077 Structural bolting Structural Galvanized Air - indoor None None III.B3.TP-8 3.5-1, A support steel uncontrolled 095 Structural bolting Structural Steel Air - indoor Loss of material Structures Monitoring III.A8.TP-248 3.5-1, B support uncontrolled (B.2.3.33) 080 Air - outdoor Structural bolting Structural Steel Air - indoor Loss of preload Structures Monitoring III.A8.TP-261 3.5-1, B support uncontrolled (B.2.3.33) 088 Air - outdoor Structural bolting Structural Galvanized Air - outdoor Loss of material Structures Monitoring III.A8.TP-274 3.5-1, B support steel (B.2.3.33) 082 Structural steel Structural Steel Air - outdoor Loss of material Structures Monitoring III.A8.TP-302 3.5-1, B support (B.2.3.33) 077

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 41 of 70 SLRA Table 3.5.2-4 General and Plant Specific Notes on page 3.5-94, are revised as follows:

General Notes A. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

B. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

D. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

E. Consistent with NUREG 2191 material, environment, and aging effect but a different AMP is credited or NUREG 2191 identifies a plant specific AMP.

Plant Specific Notes

1. Whereas the NUREG-2191/2192 item calls for a plant-specific AMP, PSL credits an existing AMP based on SLR-ISG-2021-03-STRUCTURE, Updated Aging Management Criteria for Structures Portions of Subsequent License Renewal Guidance.
2. Groundwater is considered to be water-flowing.
3. Consistent with NUREG 2191 material, environment, and aging effect, but the Fire Protection AMP, in conjunction with the Structures Monitoring AMP, is credited with managing the fire barrier function on certain fire barriers in the yard, recognizing that other barriers in the yard have additional functions that are managed by the Structures Monitoring AMP or related AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 42 of 70 SLRA Table 3.5.2-5 on pages 3.5-95 through 3.5-97, is revised as follows:

Table 3.5.2-5: Diesel Oil Equipment Enclosures - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Checkered plate, Structural support Galvanized Air - indoor None None III.B5.TP-8 3.5-1, A grating, handrails, steel uncontrolled 095 ladders, platforms, stairs Checkered plate, Structural support Steel Air - indoor Loss of material Structures Monitoring III.A3.TP-302 3.5-1, B grating, handrails, uncontrolled (B.2.3.33) 077 ladders, platforms, Air - outdoor stairs Checkered plate, Structural support Galvanized Air - outdoor Loss of material Structures Monitoring III.A3.TP-274 3.5-1, D grating, handrails, steel (B.2.3.33) 082 ladders, platforms, stairs Concrete: enclosure Structural support Concrete Soil Cracking and Structures Monitoring III.A3.TP-30 3.5-1, B foundations (reinforced) distortion (B.2.3.33) 044 Concrete: enclosure Structural support Concrete Groundwater/soil Cracking Structures Monitoring III.A3.TP-212 3.5-1, B foundations (reinforced) Loss of bond (B.2.3.33) 065 (inaccessible) Loss of material Concrete: enclosure Structural support Concrete Groundwater/soil Cracking Structures Monitoring III.A3.TP-29 3.5-1, B foundations (reinforced) Increase in (B.2.3.33) 067 (inaccessible) porosity and permeability Loss of material Concrete: enclosure Structural support Concrete Groundwater/soil Cracking Structures Monitoring III.A3.TP-204 3.5-1, B, 1 foundations (reinforced) (B.2.3.33) 043 (inaccessible)

Concrete: enclosure Structural support Concrete Water - flowing Increase in Structures Monitoring III.A3.TP-67 3.5-1, B, 1, 2 foundations (reinforced) porosity (B.2.3.33) 047 (inaccessible) and permeability Loss of strength Concrete: enclosure Fire barrier Concrete Water - flowing Increase in Fire Protection III.A3.TP-24 3.5-1, E, 3 foundations, roof, Flood protection (reinforced) porosity (B.2.3.15) 063 walls (accessible) Missile barrier and permeability Structures Monitoring B Shelter, protection Loss of strength (B.2.3.33)

Structural support

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 43 of 70 Table 3.5.2-5: Diesel Oil Equipment Enclosures - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Concrete: roof, slabs, Fire barrier Concrete Air - indoor Cracking Fire Protection III.A3.TP-28 3.5-1, E, 3 walls Flood protection (reinforced) uncontrolled Increase in (B.2.3.15) 067 Missile barrier Air - outdoor porosity and Structures Monitoring B Shelter, protection permeability (B.2.3.33)

Structural support Loss of material Concrete: roof, slabs, Fire barrier Concrete Air - indoor Cracking Fire Protection III.A3.TP-25 3.5-1, E, 3 walls (accessible) Flood protection (reinforced) uncontrolled (B.2.3.15) 054 Missile barrier Air - outdoor Structures Monitoring B Shelter, protection (B.2.3.33)

Structural support Concrete: roof, slabs, Fire barrier Concrete Air - indoor Cracking Fire Protection III.A3.TP-26 3.5-1, E, 3 walls (accessible) Flood protection (reinforced) uncontrolled Loss of bond (B.2.3.15) 066 Missile barrier Air - outdoor Loss of material Structures Monitoring B Shelter, protection (B.2.3.33)

Structural support Diesel oil storage Structural support Concrete Air - indoor Cracking Structures Monitoring III.A3.TP-28 3.5-1, B tanks foundations (reinforced) uncontrolled Increase in (B.2.3.33) 067 Air - outdoor porosity and permeability Loss of material Diesel oil storage Structural support Concrete Soil Cracking and Structures Monitoring III.A3.TP-30 3.5-1, B tanks foundations (reinforced) distortion (B.2.3.33) 044 Diesel oil storage Structural support Concrete Air - indoor Cracking Structures Monitoring III.A3.TP-25 3.5-1, B tanks foundations (reinforced) uncontrolled (B.2.3.33) 054 (accessible) Air - outdoor Diesel oil storage Structural support Concrete Air - indoor Cracking Structures Monitoring III.A3.TP-26 3.5-1, B tanks foundations (reinforced) uncontrolled Loss of bond (B.2.3.33) 066 (accessible) Air - outdoor Loss of material Diesel oil storage Structural support Concrete Water - flowing Increase in Structures Monitoring III.A3.TP-24 3.5-1, B tanks foundations (reinforced) porosity (B.2.3.33) 063 (accessible) and permeability Loss of strength Diesel oil storage Structural support Concrete Groundwater/soil Cracking Structures Monitoring III.A3.TP-212 3.5-1, B tanks foundations (reinforced) Loss of bond (B.2.3.33) 065 (inaccessible) Loss of material

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 44 of 70 Table 3.5.2-5: Diesel Oil Equipment Enclosures - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Diesel oil storage Structural support Concrete Groundwater/soil Cracking Structures Monitoring III.A3.TP-29 3.5-1, B tanks foundations (reinforced) Increase in (B.2.3.33) 067 (inaccessible) porosity and permeability Loss of material Diesel oil storage Structural support Concrete Groundwater/soil Cracking Structures Monitoring III.A3.TP-204 3.5-1, B, 1 tanks foundations (reinforced) (B.2.3.33) 043 (inaccessible)

Diesel oil storage Structural support Concrete Water - flowing Increase in Structures Monitoring III.A3.TP-67 3.5-1, B, 1, 2 tanks foundations (reinforced) porosity (B.2.3.33) 047 (inaccessible) and permeability Loss of strength Miscellaneous steel Fire barrier Steel Air - indoor Loss of material Fire Protection III.A8.TP-302 3.5-1, E, 3 (i.e., missile barrier Missile barrier uncontrolled (B.2.3.15) 077 doors) (Unit 2 only) Air - outdoor Structures Monitoring B (B.2.3.33)

Structural bolting Structural support Galvanized Air - indoor None None III.B3.TP-8 3.5-1, A steel uncontrolled 095 Structural bolting Structural support Steel Air - indoor Loss of material Structures Monitoring III.A3.TP-248 3.5-1, B uncontrolled (B.2.3.33) 080 Air - outdoor Structural bolting Structural support Steel Air - indoor Loss of preload Structures Monitoring III.A3.TP-261 3.5-1, B uncontrolled (B.2.3.33) 088 Air - outdoor Structural bolting Structural support Galvanized Air - outdoor Loss of material Structures Monitoring III.A3.TP-274 3.5-1, B steel (B.2.3.33) 082

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 45 of 70 SLRA Table 3.5.2-5 General and Plant Specific Notes on page 3.5-98, are revised as follows:

General Notes A. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

B. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

D. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

E. Consistent with NUREG 2191 material, environment, and aging effect but a different AMP is credited or NUREG 2191 identifies a plant specific AMP.

Plant Specific Notes

1. Whereas the NUREG-2191/2192 item calls for a plant-specific AMP, PSL credits an existing AMP based on SLR-ISG-2021-03-STRUCTURE, Updated Aging Management Criteria for Structures Portions of Subsequent License Renewal Guidance.
2. Groundwater is considered to be water-flowing.
3. Consistent with NUREG 2191 material, environment, and aging effect, but the Fire Protection AMP, in conjunction with the Structures Monitoring AMP, is credited with managing the fire barrier function on certain fire barriers in the yard recognizing that other barriers in the yard have additional functions that are managed by the Structures Monitoring AMP or related AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 46 of 70 SLRA Table 3.5.2-6 on pages 3.5-100 through 3.5-101, is revised as follows:

Table 3.5.2-6: Emergency Diesel Generator Buildings - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Concrete air inlet Structural support Concrete Groundwater/soil Cracking Structures Monitoring III.A3.TP-29 3.5-1, B, 1 louvers foundation (reinforced) Increase in (B.2.3.33) 067 (inaccessible) porosity and permeability Loss of material Concrete air inlet Structural support Concrete Water - flowing Increase in Structures Monitoring III.A3.TP-67 3.5-1, B, 1, 2 louvers foundation (reinforced) porosity (B.2.3.33) 047 (inaccessible) and permeability Loss of strength Concrete: Fire barrier Concrete Groundwater/soil Cracking Fire Protection III.A3.TP-212 3.5-1, E, 3 foundation/base mat, Flood protection (reinforced) Loss of bond (B.2.3.15) 065 walls (inaccessible) Missile barrier Loss of material Structures Monitoring B Shelter, protection (B.2.3.33)

Structural support Concrete: Fire barrier Concrete Groundwater/soil Cracking Fire Protection III.A3.TP-29 3.5-1, E, 3 foundation/base mat, Flood protection (reinforced) Increase in (B.2.3.15) 067 walls (inaccessible) Missile barrier porosity and Structures Monitoring B Shelter, protection permeability (B.2.3.33)

Structural support Loss of material Concrete: Structural support Concrete Groundwater/soil Cracking Structures Monitoring III.A3.TP-204 3.5-1, B, 1 foundation/base mat, (reinforced) (B.2.3.33) 043 walls (inaccessible)

Concrete: Fire barrier Concrete Water - flowing Increase in Fire Protection III.A3.TP-67 3.5-1, E, 3 foundation/base mat, Flood protection (reinforced) porosity (B.2.3.15) 047 walls (inaccessible) Missile barrier and permeability Structures Monitoring B, 1, 2 Shelter, protection Loss of strength (B.2.3.33)

Structural support Concrete: slabs, Fire barrier Concrete Air - indoor Cracking Fire Protection III.A3.TP-28 3.5-1, E, 3 walls, roofs Flood protection (reinforced) uncontrolled Increase in (B.2.3.15) 067 Missile barrier Air - outdoor porosity and Structures Monitoring B Shelter, protection permeability (B.2.3.33)

Structural support Loss of material

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 47 of 70 Table 3.5.2-6: Emergency Diesel Generator Buildings - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Concrete: slabs, Fire barrier Concrete Air - indoor Cracking Fire Protection III.A3.TP-25 3.5-1, E, 3 walls, roofs, trenches Flood protection (reinforced) uncontrolled (B.2.3.15) 054 (accessible) Missile barrier Air - outdoor Structures Monitoring B Shelter, protection (B.2.3.33)

Structural support Concrete: slabs, Fire barrier Concrete Air - indoor Cracking Fire Protection III.A3.TP-26 3.5-1, E, 3 walls, roofs, trenches Flood protection (reinforced) uncontrolled Loss of bond (B.2.3.15) 066 (accessible) Missile barrier Air - outdoor Loss of material Structures Monitoring B Shelter, protection (B.2.3.33)

Structural support Concrete: slabs, Fire barrier Concrete Soil Cracking and Fire Protection III.A3.TP-30 3.5-1, E, 3 walls, roofs, trenches Flood protection (reinforced) distortion (B.2.3.15) 044 Missile barrier Structures Monitoring B Shelter, protection (B.2.3.33)

Structural support Concrete: walls, Fire barrier Concrete Water - flowing Increase in Fire Protection III.A3.TP-24 3.5-1, E, 3 roofs (accessible) Flood protection (reinforced) porosity (B.2.3.15) 063 Missile barrier and permeability Structures Monitoring B Shelter, protection Loss of strength (B.2.3.33)

Structural support Exterior louvers (for Missile barrier Galvanized Air - outdoor Loss of material Structures Monitoring III.A8.TP-274 3.5-1, D ventilation and missile Shelter, protection steel (B.2.3.33) 082 protection)

(Unit 1 only)

Exterior louvers (for Missile barrier Steel Air - outdoor Loss of material Structures Monitoring III.A3.TP-302 3.5-1, B ventilation and missile Shelter, protection (B.2.3.33) 077 protection) (Unit 1 only)

Miscellaneous steel Structural support Steel Air - indoor Loss of material Structures Monitoring III.A3.TP-302 3.5-1, B uncontrolled (B.2.3.33) 077 Air - outdoor Missile protection Flood protection Steel Air - indoor Loss of material Structures Monitoring III.A3.TP-302 3.5-1, B doors Missile barrier uncontrolled (B.2.3.33) 077 Air - outdoor

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 48 of 70 SLRA Table 3.5.2-6 General and Plant Specific Notes on page 3.5-102, are revised as follows:

Table 3.5.2-6: Emergency Diesel Generator Buildings - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Missile protection Missile barrier Steel Air - outdoor Loss of material Structures Monitoring III.A3.TP-302 3.5-1, B exhaust hoods Shelter, protection (B.2.3.33) 077 (Unit 2 only)

Missile protection Missile barrier Galvanized Air - outdoor Loss of material Structures Monitoring III.A8.TP-274 3.5-1, D exhaust hoods Shelter, protection steel (B.2.3.33) 082 (Unit 2 only)

Structural bolting Structural support Steel Air - indoor Loss of material Structures Monitoring III.A3.TP-248 3.5-1, B uncontrolled (B.2.3.33) 080 Air - outdoor Structural bolting Structural support Steel Air - indoor Loss of preload Structures Monitoring III.A3.TP-261 3.5-1, B uncontrolled (B.2.3.33) 088 Air - outdoor Structural bolting Structural support Galvanized Air - outdoor Loss of material Structures Monitoring III.A3.TP-274 3.5-1, B steel (B.2.3.33) 082 General Notes B. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

D. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

E. Consistent with NUREG 2191 material, environment, and aging effect but a different AMP is credited or NUREG 2191 identifies a plant specific AMP.

Plant Specific Notes

1. Whereas the NUREG-2191/2192 item calls for a plant-specific AMP, PSL credits an existing AMP based on SLR-ISG-2021-03-STRUCTURE, Updated Aging Management Criteria for Structures Portions of Subsequent License Renewal Guidance.
2. Groundwater is considered to be water-flowing.
3. Consistent with NUREG 2191 material, environment, and aging effect, but the Fire Protection AMP, in conjunction with the Structures Monitoring AMP, is credited with managing the fire barrier function on certain fire barriers in the yard recognizing that other barriers in the yard have additional functions that are managed by the Structures Monitoring AMP or related AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 49 of 70 SLRA Table 3.5.2-10 and notes on pages 3.5-114 through 3.5-117, are revised as follows:

Table 3.5.2-10: Reactor Auxiliary Buildings - Summary of Aging Management Evaluation Aging Effect Table Aging Management NUREG-2191 Component Type Intended Function Material Environment Requiring 1 Notes Program Item Management Item Airtight door seals Pressure boundary Elastomers Air - indoor Loss of sealing Structures Monitoring III.A6.TP-7 3.5-1, B uncontrolled (B.2.3.33) 072 Air - indoor controlled Air - outdoor Airtight doors Fire barrier Steel Air - indoor Loss of material Structures Monitoring III.A3.TP-302 3.5-1, B Pressure boundary uncontrolled (B.2.3.33) 077 Structural support Checkered plate, Structural support Steel Air with borated Loss of material Boric Acid Corrosion III.B5.T-25 3.5-1, C grating, handrails, water leakage (B.2.3.4) 089 ladders, platforms, stairs Checkered plate, Structural support Galvanized Air with borated Loss of material Boric Acid Corrosion III.B5.TP-3 3.5-1, C grating, handrails, steel water leakage (B.2.3.4) 089 ladders, platforms, stairs Checkered plate, Structural support Galvanized Air - indoor None None III.B5.TP-8 3.5-1, C grating, handrails, steel uncontrolled 095 ladders, platforms, stairs Checkered plate, Structural support Steel Air - indoor Loss of material Structures Monitoring III.A3.TP-302 3.5-1, B grating, handrails, uncontrolled (B.2.3.33) 077 ladders, platforms, stairs Concrete: exterior Fire barrier Concrete Water - flowing Increase in Fire Protection III.A3.TP-24 3.5-1, E, 4 walls, roofs Flood protection (reinforced) porosity and (B.2.3.15) 063 (accessible) Missile barrier permeability Structures Monitoring B Pressure boundary Loss of (B.2.3.33)

Shelter, protection strength Structural support Concrete: Fire barrier Concrete Soil Cracking and Fire Protection III.A3.TP-30 3.5-1, E, 4 foundation/base mat, Flood protection (reinforced) distortion (B.2.3.15) 044 exterior walls Missile barrier Structures Monitoring B Pressure boundary (B.2.3.33)

Shelter, protection Structural support

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 50 of 70 Table 3.5.2-10: Reactor Auxiliary Buildings - Summary of Aging Management Evaluation Aging Effect Table Aging Management NUREG-2191 Component Type Intended Function Material Environment Requiring 1 Notes Program Item Management Item Concrete: Fire barrier Concrete Groundwater/soil Cracking Fire Protection III.A3.TP-212 3.5-1, E, 4 foundation/base mat, Flood protection (reinforced) Loss of bond (B.2.3.15) 065 exterior walls Missile barrier Loss of material Structures Monitoring B (inaccessible) Pressure boundary (B.2.3.33)

Shelter, protection Structural support Concrete: Fire barrier Concrete Groundwater/soil Cracking Fire Protection III.A3.TP-29 3.5-1, E, 4 foundation/base mat, Flood protection (reinforced) Increase in (B.2.3.15) 067 exterior walls Missile barrier porosity and Structures Monitoring B (inaccessible) Pressure boundary permeability (B.2.3.33)

Shelter, protection Loss of Structural support material Concrete: Fire barrier Concrete Groundwater/soil Cracking Fire Protection III.A3.TP-204 3.5-1, E, 4 foundation/base mat, Flood protection (reinforced) (B.2.3.15) 043 exterior walls Missile barrier Structures Monitoring B, 1 (inaccessible) Pressure boundary (B.2.3.33)

Shelter, protection Structural support Concrete: Fire barrier Concrete Water - flowing Increase in Fire Protection III.A3.TP-67 3.5-1, E, 4 foundation/base mat, Flood protection (reinforced) porosity and (B.2.3.15) 047 exterior walls Missile barrier permeability Structures Monitoring B, 1, 2 (inaccessible) Pressure boundary Loss of (B.2.3.33)

Shelter, protection strength Structural support Concrete: roofs, slabs, Fire barrier Concrete Air - indoor Cracking Fire Protection III.A3.TP-28 3.5-1, E, 4 walls Flood protection (reinforced) uncontrolled Increase in (B.2.3.15) 067 Missile barrier Air - outdoor porosity and Structures Monitoring B Pressure boundary permeability (B.2.3.33)

Shelter, protection Loss of Structural support material Concrete: roofs, slabs, Fire barrier Concrete Air - indoor Cracking Fire Protection III.A3.TP-25 3.5-1, E, 4 walls (accessible) Flood protection (reinforced) uncontrolled (B.2.3.15) 054 Missile barrier Air - outdoor Structures Monitoring B Pressure boundary (B.2.3.33)

Shelter, protection Structural support

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 51 of 70 Table 3.5.2-10: Reactor Auxiliary Buildings - Summary of Aging Management Evaluation Aging Effect Table Aging Management NUREG-2191 Component Type Intended Function Material Environment Requiring 1 Notes Program Item Management Item Concrete: roofs, slabs, Fire barrier Concrete Air - indoor Cracking Fire Protection III.A3.TP-26 3.5-1, E, 4 walls (accessible) Flood protection (reinforced) uncontrolled Loss of bond (B.2.3.15) 066 Missile barrier Air - outdoor Loss of material Structures Monitoring B Pressure boundary (B.2.3.33)

Shelter, protection Structural support HVAC louvers Shelter, protection Steel Air - outdoor Loss of material Structures Monitoring III.A3.TP-302 3.5-1, B Structural support (B.2.3.33) 077 HVAC louvers Shelter, protection Stainless steel Air - outdoor Cracking Structures Monitoring III.B5.T-37b 3.5-1, D Structural support Loss of material (B.2.3.33) 100 HVAC louvers Shelter, protection Galvanized Air - outdoor Loss of material Structures Monitoring III.A3.TP-274 3.5-1, D Structural support steel (B.2.3.33) 082 Miscellaneous Fire barrier Steel Air - indoor Loss of material Fire Protection III.A3.TP-302 3.5-1, E, 4 steel (i.e., radiation Missile barrier uncontrolled (B.2.3.15) 077 shielding, missile Shelter, protection Air - outdoor Structures Monitoring B barriers, hatch frame Structural support (B.2.3.33) covers, etc.)

Missile protection Missile barrier Steel Air - outdoor Loss of material Structures Monitoring III.A3.TP-302 3.5-1, B doors and barriers (B.2.3.33) 077 Reinforced concrete Fire barrier Concrete block Air - indoor Cracking Fire Protection III.A3.T-12 3.5-1, E, 5 masonry block walls Pressure boundary (reinforced) uncontrolled (B.2.3.15) 070 Shelter, protection Masonry Walls A, 3 Structural support (B.2.3.32)

Structural bolting Structural support Steel Air with borated Loss of material Boric Acid Corrosion III.B5.T-25 3.5-1, A water leakage (B.2.3.4) 090 Structural bolting Structural support Galvanized Air with borated Loss of material Boric Acid Corrosion III.B5.TP-3 3.5-1, A steel water leakage (B.2.3.4) 089 Structural bolting Structural support Galvanized Air - indoor None None III.B3.TP-8 3.5-1, A steel uncontrolled 095 Structural bolting Structural support Steel Air - indoor Loss of material Structures Monitoring III.A3.TP-248 3.5-1, B uncontrolled (B.2.3.33) 080 Air - outdoor Structural bolting Structural support Steel Air - indoor Loss of preload Structures Monitoring III.A3.TP-261 3.5-1, B uncontrolled (B.2.3.33) 088 Air - outdoor Structural bolting Structural support Galvanized Air - outdoor Loss of material Structures Monitoring III.A3.TP-274 3.5-1, B steel (B.2.3.33) 082

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 52 of 70 Table 3.5.2-10: Reactor Auxiliary Buildings - Summary of Aging Management Evaluation Aging Effect Table Aging Management NUREG-2191 Component Type Intended Function Material Environment Requiring 1 Notes Program Item Management Item Structural steel Structural support Steel Air with borated Loss of material Boric Acid Corrosion III.B5.T-25 3.5-1, C framing (columns, water leakage (B.2.3.4) 089 beams, connections, etc.)

Structural steel Structural support Steel Air - indoor Loss of material Structures Monitoring III.A3.TP-302 3.5-1, B framing (columns, uncontrolled (B.2.3.33) 077 beams, connections, Air - outdoor etc.)

Unreinforced concrete Fire barrier Concrete block Air - indoor Cracking Fire Protection III.A3.T-12 3.5-1, E, 5 masonry block walls Shelter, protection (unreinforced) uncontrolled (B.2.3.15) 070 Structural support Masonry Walls A (B.2.3.32)

Watertight door seals Flood protection Elastomers Air - indoor Loss of sealing Structures Monitoring III.A6.TP-7 3.5-1, B Pressure boundary uncontrolled (B.2.3.33) 072 Air - indoor controlled Air - outdoor Watertight doors Flood protection Steel Air - indoor Loss of material Structures Monitoring III.A3.TP-302 3.5-1, B Pressure boundary uncontrolled (B.2.3.33) 077 Weatherproofing Shelter, protection Caulking and Air - outdoor Loss of sealing Structures Monitoring III.A6.TP-7 3.5-1, B sealants (B.2.3.33) 072 General Notes A. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

B. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

C. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

D. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

E. Consistent with NUREG 2191 material, environment, and aging effect but a different AMP is credited or NUREG 2191 identifies a plant specific AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 53 of 70 SLRA Table 3.5.2-10 Plant Specific Notes on page 3.5-118, are revised as follows:

Plant Specific Notes

1. Whereas the NUREG-2191/2192 item calls for a plant-specific AMP, PSL credits an existing AMP based on SLR-ISG-2021-03-STRUCTURES, Updated Aging Management Criteria for Structures Portions of Subsequent License Renewal Guidance.
2. Groundwater is considered to be water-flowing.
3. The structural component provides a pressure boundary intended function for Halon in the Unit 1 cable spreading room or the control room envelope.
4. Consistent with NUREG 2191 material, environment, and aging effect, but the Fire Protection AMP, in conjunction with the Structures Monitoring AMP, is credited with managing the fire barrier function on certain fire barriers in the yard recognizing that other barriers in the yard have additional functions that are managed by the Structures Monitoring AMP or related AMP.
5. Consistent with NUREG 2191 material, environment, and aging effect, but the Fire Protection AMP, in conjunction with the Masonry Walls AMP, is credited with managing the fire barrier function on certain fire barriers in the yard recognizing that other barriers in the yard have additional functions that are managed by the Masonry Walls AMP or related AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 54 of 70 SLRA Table 3.5.2-11 and notes on pages 3.5-119 through 3.5-120, are revised as follows:

Table 3.5.2-11: Steam Trestle Areas - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table Component Type Material Environment Requiring Notes Function Program Item 1 Item Management Checkered plate, Structural support Steel Air - outdoor Loss of material Structures Monitoring III.A3.TP-302 3.5-1, B grating, handrails, (B.2.3.33) 077 ladders, platforms, stairs Concrete: (accessible; Structural support Concrete Air - outdoor Cracking Structures Monitoring III.A3.TP-28 3.5-1, B above grade) (reinforced) Increase in (B.2.3.33) 067 porosity and permeability Loss of material Concrete: (accessible; Structural support Concrete Air - outdoor Cracking Structures Monitoring III.A3.TP-26 3.5-1, B interior and above- (reinforced) Loss of bond (B.2.3.33) 066 grade exterior) Loss of material Concrete: foundations Structural support Concrete Soil Cracking and Structures Monitoring III.A3.TP-30 3.5-1, B (reinforced) distortion (B.2.3.33) 044 Concrete: foundations Structural support Concrete Water - flowing Increase in Structures Monitoring III.A3.TP-24 3.5-1, B (accessible) (reinforced) porosity and (B.2.3.33) 063 permeability Loss of strength Concrete: foundations Structural support Concrete Groundwater/soil Cracking Structures Monitoring III.A3.TP-212 3.5-1, B (inaccessible) (reinforced) Loss of bond (B.2.3.33) 065 Loss of material Concrete: foundations Structural support Concrete Groundwater/soil Cracking Structures Monitoring III.A3.TP-29 3.5-1, B (inaccessible) (reinforced) Increase in (B.2.3.33) 067 porosity and permeability Loss of material Concrete: foundations Structural support Concrete Groundwater/soil Cracking Structures Monitoring III.A3.TP-204 3.5-1, B, 1 (inaccessible) (reinforced) (B.2.3.33) 043 Concrete: foundations Structural support Concrete Water - flowing Increase in Structures Monitoring III.A3.TP-67 3.5-1, B, 1, 2 (inaccessible) (reinforced) porosity and (B.2.3.33) 047 permeability Loss of strength Concrete: foundations, Fire barrier Concrete Air - outdoor Cracking Fire Protection III.A3.TP-25 3.5-1, E, 3 slabs (accessible) Shelter, protection (reinforced) (B.2.3.15) 054 Structural support Structures Monitoring B (B.2.3.33)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 55 of 70 Table 3.5.2-11: Steam Trestle Areas - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table Component Type Material Environment Requiring Notes Function Program Item 1 Item Management Miscellaneous steel (i.e., Fire barrier Steel Air - outdoor Loss of material Fire Protection III.A3.TP-302 3.5-1, E, 3 missile barriers, steel Missile barrier (B.2.3.15) 077 grating, etc.) Shelter, protection Structures Monitoring B Structural support (B.2.3.33)

Miscellaneous steel (i.e., Fire barrier Galvanized Air - outdoor Loss of material Fire Protection III.A3.TP-274 3.5-1, E, 3 missile barriers, steel Missile barrier steel (B.2.3.15) 082 grating, etc.) Shelter, protection Structures Monitoring D Structural support (B.2.3.33)

Structural bolting Structural support Steel Air - outdoor Loss of material Structures Monitoring III.A3.TP-248 3.5-1, B (B.2.3.33) 080 Structural bolting Structural support Steel Air - outdoor Loss of preload Structures Monitoring III.A3.TP-261 3.5-1, B (B.2.3.33) 088 Structural bolting Structural support Galvanized Air - outdoor Loss of material Structures Monitoring III.A3.TP-274 3.5-1, B steel (B.2.3.33) 082 Structural steel framing Missile barrier Steel Air - outdoor Loss of material Structures Monitoring III.A3.TP-302 3.5-1, B (columns, beams, Structural support (B.2.3.33) 077 connections, etc.)

General Notes B. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

D. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

E. Consistent with NUREG 2191 material, environment, and aging effect but a different AMP is credited or NUREG 2191 identifies a plant specific AMP.

Plant Specific Notes

1. Whereas the NUREG-2191/2192 item calls for a plant-specific AMP, PSL credits an existing AMP based on SLR-ISG-2021-03-STRUCTURES, Updated Aging Management Criteria for Structures Portions of Subsequent License Renewal Guidance.
2. Groundwater is considered to be water-flowing.
3. Consistent with NUREG 2191 material, environment, and aging effect, but the Fire Protection AMP, in conjunction with the Structures Monitoring AMP, is credited with managing the fire barrier function on certain fire barriers in the yard recognizing that other barriers in the yard have additional functions that are managed by the Structures Monitoring AMP or related AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 56 of 70 SLRA Table 3.5.2-13 on page 3.5-125, is revised as follows:

Table 3.5.2-13: Turbine Buildings - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Concrete curbs Fire Concrete Air - indoor Cracking Structures Monitoring III.A3.TP-25 3.5-1, B (Unit 2, 2B switchgear prevention (reinforced) uncontrolled (B.2.3.33) 054 room) (accessible) protection Concrete curbs Fire Concrete Air - indoor Cracking Structures Monitoring III.A3.TP-26 3.5-1, B (Unit 2, 2B switchgear prevention (reinforced) uncontrolled Loss of bond (B.2.3.33) 066 room) (accessible) protection Loss of material Concrete curbs Fire Concrete Air - indoor Cracking Structures Monitoring III.A3.TP-28 3.5-1, B (Unit 2, 2B switchgear prevention (reinforced) uncontrolled Increase in porosity (B.2.3.33) 067 room) (accessible) protection and permeability Loss of material Concrete: Structural Concrete Soil Cracking and Structures Monitoring III.A3.TP-30 3.5-1, B foundation/base mat support (reinforced) distortion (B.2.3.33) 044 Concrete: Structural Concrete Groundwater/soil Cracking Structures Monitoring III.A3.TP-212 3.5-1, B foundation/base mat support (reinforced) Loss of bond (B.2.3.33) 065 (inaccessible) Loss of material Concrete: Structural Concrete Groundwater/soil Cracking Structures Monitoring III.A3.TP-29 3.5-1, B foundation/base mat support (reinforced) Increase in porosity (B.2.3.33) 067 (inaccessible) and permeability Loss of material Concrete: Structural Concrete Groundwater/soil Cracking Structures Monitoring III.A3.TP-204 3.5-1, B, 1 foundation/base mat support (reinforced) (B.2.3.33) 043 (inaccessible)

Concrete: Structural Concrete Water - flowing Increase in porosity Structures Monitoring III.A3.TP-67 3.5-1, B, 1, 2 foundation/base mat support (reinforced) and permeability (B.2.3.33) 047 (inaccessible) Loss of strength Concrete: slabs Structural Concrete Air - outdoor Cracking Structures Monitoring III.A3.TP-28 3.5-1, B support (reinforced) Increase in porosity (B.2.3.33) 067 and permeability Loss of material Concrete: slabs Structural Concrete Water - flowing Increase in porosity Structures Monitoring III.A3.TP-24 3.5-1, B (accessible) support (reinforced) and permeability (B.2.3.33) 063 Loss of strength Concrete: slabs Structural Concrete Air - outdoor Cracking Structures Monitoring III.A3.TP-25 3.5-1, B (accessible) support (reinforced) (B.2.3.33) 054

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 57 of 70 SLRA Table 3.5.2-17 on pages 3.5-142 through 3.5-145, is revised as follows:

Table 3.5.2-17: Fire Rated Assemblies - Summary of Aging Management Evaluation Aging Effect Aging Intended NUREG-2191 Table 1 Component Type Material Environment Requiring Management Notes Function Item Item Management Program Conduit caps Fire barrier Galvanized steel Air - indoor None None III.B5.TP-8 3.5-1, C Pressure uncontrolled 095 boundary Conduit plugs Fire barrier Silicone foam Air Hardening Fire Protection VII.G.A-19 3.3-1, BC Pressure Loss of strength (B.2.3.15) 057 boundary Shrinkage Conduit plugs Fire barrier Cementitious Air Change in material Fire Protection VII.G.A-806 3.3-1, BA Pressure coating: properties (B.2.3.15) 268 boundary quelpyre mastic Cracking 703B Delamination Loss of material Separation Conduit plugs Fire barrier Fire retardant Air Change in material Fire Protection VII.G.A-807 3.3-1, BA Pressure coating properties (B.2.3.15) 269 boundary (Flamemastic) Cracking Delamination Loss of material Separation Conduit plugs Fire barrier Silicate: ceramic Air Change in material Fire Protection VII.G.A-807 3.3-1, BA Pressure fiber properties (B.2.3.15) 269 boundary Cracking Delamination Loss of material Separation Fire damper Fire barrier Steel Air Loss of material Fire Protection VII.G.A-789 3.3-1, BA housings (B.2.3.15) 255 Fire doors - airtight Fire barrier Steel Air Loss of material Fire Protection VII.G.A-21 3.3-1, B Pressure (B.2.3.15) 059 boundary Fire doors - Fire barrier Steel Air Loss of material Fire Protection VII.G.A-21 3.3-1, B watertight Flood barrier (B.2.3.15) 059 Fire doors (NFPA Fire barrier Steel Air Loss of material Fire Protection VII.G.A-21 3.3-1, BA 805 barriers) Pressure (B.2.3.15) 059 boundary

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 58 of 70 Table 3.5.2-17: Fire Rated Assemblies - Summary of Aging Management Evaluation Aging Effect Aging Intended NUREG-2191 Table 1 Component Type Material Environment Requiring Management Notes Function Item Item Management Program Fire sealed isolation Fire barrier Elastomer: Air Hardening Fire Protection VII.G.A-19 3.3-1, BA joint dymeric sealant, Loss of strength (B.2.3.15) 057 ethafoam Shrinkage Fire sealed isolation Fire barrier Silicates: Air Change in material Fire Protection VII.G.A-807 3.3-1, BA joint cerablanket properties (B.2.3.15) 269 Cracking Delamination Loss of material Separation Fire sealed isolation Fire barrier Carbon steel Air Loss of material Fire Protection III.B5.TP-43 3.5-1, E, 1 joint plate (B.2.3.15) 092 Fire seals: cable tray Fire barrier Elastomer Air Hardening Fire Protection VII.G.A-19 3.3-1, BA penetrations Pressure Loss of strength (B.2.3.15) 057 boundary Shrinkage Fire seals: cable tray Fire barrier Silicone Air Hardening Fire Protection VII.G.A-19 3.3-1, BA penetrations Pressure Loss of strength (B.2.3.15) 057 boundary Shrinkage Fire seals: cable tray Fire barrier Marinite board Air Change in material Fire Protection VII.G.A-807 3.3-1, BA penetrations Pressure Ceramic fiber properties (B.2.3.15) 269 boundary Fire retardant Cracking coating Delamination (Flamemastic) Loss of material Separation Fire seals: Fire barrier Silicone Air Hardening Fire Protection VII.G.A-19 3.3-1, BA mechanical Pressure Loss of strength (B.2.3.15) 057 penetrations: (Type boundary Shrinkage M-1, M-2, M-3, M-4, M-6, M-7, M-9)

Fire seals: Fire barrier Silicate: Air Change in material Fire Protection VII.G.A-807 3.3-1, BA mechanical Pressure durablanket, properties (B.2.3.15) 269 penetrations: (Type boundary ceramic fiber Cracking M-1, M-2, M-3, M-4, Delamination M-6, M-7, M-9) Loss of material Separation

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 59 of 70 Table 3.5.2-17: Fire Rated Assemblies - Summary of Aging Management Evaluation Aging Effect Aging Intended NUREG-2191 Table 1 Component Type Material Environment Requiring Management Notes Function Item Item Management Program Fire seals: Fire barrier Aluminum Air Cracking Fire Protection III.B5.T-37b 3.5-1, E, 1 mechanical Pressure Loss of material (B.2.3.15) 100 penetrations: (Type boundary M-1, M-2, M-3, M-4, M-6, M-7, M-9)

Fire seals: Fire barrier Stainless steel Air Cracking Fire Protection III.B5.T-37b 3.5-1, E, 1 mechanical Pressure Loss of material (B.2.3.15) 100 penetrations: (Type boundary M-1, M-2, M-3, M-4, M-6, M-7, M-9)

Fire seals: Fire barrier Galvanized steel Air - indoor None None III.B5.TP-8 3.5-1, C mechanical Pressure uncontrolled 095 penetrations: (Type boundary M-1, M-2, M-3, M-4, M-6, M-7, M-9)

Fire wrap (conduit Fire barrier Subliming Air Change in material Fire Protection VII.G.A-805 3.3-1, BA and steel supports) compound: properties (B.2.3.15) 267 thermo-lag 330- Cracking 1 Delamination Loss of material Separation Flame impingement Fire barrier Insulating Air Change in material Fire Protection VII.G.A-807 3.3-1, BA shields (insulating blankets (B&B properties (B.2.3.15) 269 blankets for cable or Mecatiss) Cracking trays) Delamination Loss of material Separation Miscellaneous fire Fire barrier Subliming Air Change in material Fire Protection VII.G.A-805 3.3-1, BA barriers Pressure compounds: properties (B.2.3.15) 267 boundary thermo-lag 330- Cracking 1 (panels, wrap, Delamination spray, or Loss of material troweled) Separation Thermo-lag 770-1 (panels)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 60 of 70 Table 3.5.2-17: Fire Rated Assemblies - Summary of Aging Management Evaluation Aging Effect Aging Intended NUREG-2191 Table 1 Component Type Material Environment Requiring Management Notes Function Item Item Management Program Miscellaneous fire Fire barrier Ceramic fiber Air Change in material Fire Protection VII.G.A-807 3.3-1, BA barriers Pressure (panels) properties (B.2.3.15) 269 boundary Cracking Delamination Loss of material Separation Miscellaneous fire Fire barrier Stainless steel Air Cracking Fire Protection III.B5.T-37b 3.5-1, E, 1 barriers Pressure sheet metal Loss of material (B.2.3.15) 100 boundary (panels)

Miscellaneous fire Fire barrier Stainless steel Air Cracking Fire Protection III.B5.T-37b 3.5-1, E, 1 barriers - straps Loss of material (B.2.3.15) 100 Miscellaneous fire Fire barrier Aluminum Air Cracking Fire Protection III.B5.T-37b 3.5-1, E, 1 barriers - straps Loss of material (B.2.3.15) 100 Radiant energy Fire barrier Subliming Air Change in material Fire Protection VII.G.A-805 3.3-1, BA shields compound: properties (B.2.3.15) 267 thermo-lag 330- Cracking 1 Delamination Loss of material Separation Radiant energy Fire barrier Insulating Air Change in material Fire Protection VII.G.A-807 3.3-1, BA shields blankets (B&B properties (B.2.3.15) 269 or Mecatiss) Cracking Delamination Loss of material Separation Radiant energy Fire barrier Stainless steel Air Cracking Fire Protection III.B5.T-37b 3.5-1, E, 1 shields Loss of material (B.2.3.15) 100 General Notes BA. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions tois consistent with NUREG-2191 AMP description.

C. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

E. Consistent with NUREG-2191 material, environment, and aging effect but a different AMP is credited or NUREG-2191 identifies a plant-specific AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 61 of 70 Plant Specific Notes

1. Metal components of fire barrier assemblies will be managed by the Fire Protection AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 62 of 70 SLRA Appendix A1, Section 19.2.2.15 on pages A1-21 and A1-22, is revised as follows:

19.2.2.15 Fire Protection The PSL Fire Protection AMP is an existing AMP, formerly a portion of the PSL Fire Protection Program. This AMP manages aging effects (loss of material, cracking, separation and loss of seal) associated with fire barriers and non-water suppression systems (halon). The PSL Fire Protection AMP includes fire barrier inspections. The fire barrier inspection portion of this AMP requires periodic visual inspection of fire barrier penetration seals, fire barrier walls, ceilings, floors, fire damper housings (i.e., the passive portion of the fire damper assemblies), electrical raceway fire barrier systems, as well as periodic visual inspection and functional tests of fire-rated doors so that their operability is maintained. The PSL Fire Protection AMP also requires periodic visual inspection of other passive fire protection features credited for the Fire Protection Program like oil collection dikes. The PSL Fire Protection AMP includes periodic inspection and testing of the halon fire suppression systems (visual inspection for corrosion every 90 days and functional and air flow testing every 18 months). UFSAR Section 9.5.1 provides for additional information on the PSL Fire Protection Program.

With respect to preventive actions, PSL has adopted the National Fire Protection Association (NFPA) 805 fire protection program to meet the requirements of 10 CFR 50.48(c) and ensure that regulatory requirements are met for fire prevention, fire detection, fire suppression, and fire containment and alternative shutdown capability for each fire area containing SSCs important to safety.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 63 of 70 Inspection results are acceptable if there are no signs of degradation that could result in the loss of the fire protection capability due to loss of material or elastomer degradation. The acceptance criteria include:

a) No visual indications (outside of those allowed by approved penetration seal configurations) of cracking, separation of seals from structures and components, indications of increased hardness, shrinkage, loss of strength, or ruptures or punctures of seals; b) No significant indications of cracking, loss of material, delamination, separation, and changes to elastomer properties of fire barrier walls, ceilings, floors, passive fire protection features credited by the fire protection program, and in other fire barrier materials; c) No visual indication of loss of material, cracking, or elastomer degradation as applicable on fire damper housingsassemblies; d) No visual indications of missing parts, holes, and wear; and e) No conditions in the functional tests of fire doors (i.e., the door swings easily, freely, and achieves positive latching).

Periodic inspections and testing of the halon fire suppression systems are performed to demonstrate that they are functional, and the surface condition of components is inspected for corrosion, nozzle obstructions, and other damage at a frequency in accordance with the plants NRC-approved fire protection program.

Visual inspection of at least 10 percent of each type of sealed penetration is performed at a frequency in accordance with the plants NRC-approved fire protection program or at least once every refueling outage. Visual inspections of fire-rated structures (fire barrier walls, ceilings, and floors), combustible liquid spill retaining features (oil collection dikes), fire-rated assemblies, and fire damper housings assemblies are conducted at a frequency in accordance with the plants NRC-approved fire protection program. Periodic visual inspections and functional tests are conducted on fire doors, and their closing mechanisms and latches are verified functional, at a frequency in accordance with the plants NRC-approved fire protection program.

The results of inspections and functional testing of the in-scope fire protection equipment are collected and analyzed, and unacceptable results are documented in the corrective action program. When performance degrades to unacceptable levels, the PSL corrective action program is utilized to drive improvement. During the inspection of penetration seals, if any sign of abnormal degradation is detected within the sample, the inspection sample size is expanded, in accordance with the approved PSL fire protection program, to include an additional 10 percent of each type of sealed penetration.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 64 of 70 SLRA Appendix A1, Table 19-3, Commitment Nos. 18(b) and 18(c) on pages A1-76 and A1-77, are revised as follows:

Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 18 Fire Protection (19.2.2.15) XI.M26 Continue the existing PSL Fire Protection AMP, including No later than 6 months prior to enhancement to: the SPEO, or no later than the last refueling outage prior to the a) Enhance plant procedures to specify that penetration seals will be SPEO i.e.:

inspected for indications of increased hardness and loss of strength such as cracking, seal separation from walls and PSL1: 09/01/2035 components, separation of layers of material, rupture, and puncture of seals.

b) Enhance plant procedures to specify that subliming, cementitious, and silicate materials used in fireproofing and fire barriers will be inspected for loss of material, separation, change in material properties, and cracking/delamination.

c) Enhance plant procedures to specify that any loss of material (e.g., general, pitting, or crevice corrosion), cracking, or elastomer degradation (e.g., hardening, loss of strength, or shrinkage) as applicable to the fire damper housings assembly is unacceptable.

d) Enhance plant procedures to require projection of identified degradation to the next scheduled inspection for all monitored fire protection SSCs, where practical.

e) Enhance plant procedures to require that projections are evaluated against acceptance criteria to confirm that the timing of subsequent inspections will maintain the components intended functions throughout the subsequent period of extended operation based on the projected rate of degradation.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 65 of 70 SLRA Appendix A2, Section 19.2.2.15 on pages A2-21 and A2-22, is revised as follows:

19.2.2.15 Fire Protection The PSL Fire Protection AMP is an existing AMP, formerly a portion of the PSL Fire Protection Program. This AMP manages aging effects (loss of material, cracking, separation and loss of seal) associated with fire barriers. The PSL Fire Protection AMP includes fire barrier inspections. The fire barrier inspection portion of this AMP requires periodic visual inspection of fire barrier penetration seals, fire barrier walls, ceilings, floors, fire damper housings (i.e., the passive portion of the fire damper assemblies), electrical raceway fire barrier systems, as well as periodic visual inspection and functional tests of fire-rated doors so that their operability is maintained. The PSL Fire Protection AMP also requires periodic visual inspection of other passive fire protection features credited for the Fire Protection Program like oil collection curbs. The PSL Fire Protection AMP includes periodic inspection and testing of the halon fire suppression systems. UFSAR Section 9.5.1 provides for additional information on the PSL Fire Protection Program.

With respect to preventive actions, PSL has adopted the National Fire Protection Association (NFPA) 805 fire protection program to meet the requirements of 10 CFR 50.48(c) and ensure that regulatory requirements are met for fire prevention, fire detection, fire suppression, and fire containment and alternative shutdown capability for each fire area containing SSCs important to safety.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 66 of 70 Inspection results are acceptable if there are no signs of degradation that could result in the loss of the fire protection capability due to loss of material or elastomer degradation. The acceptance criteria include:

a) No visual indications (outside of those allowed by approved penetration seal configurations) of cracking, separation of seals from structures and components, indications of increased hardness, shrinkage, loss of strength, or ruptures or punctures of seals; b) No significant indications of cracking, loss of material, delamination, separation, and changes to elastomer properties of fire barrier walls, ceilings, floors, passive fire protection features credited by the fire protection program, and in other fire barrier materials; c) No visual indication of loss of material, cracking, or elastomer degradation as applicable on fire damper housingsassemblies; d) No visual indications of missing parts, holes, and wear; and e) No conditions in the functional tests of fire doors (i.e., the door swings easily, freely, and achieves positive latching).

Visual inspection of at least 10 percent of each type of sealed penetration is performed at a frequency in accordance with the plants NRC-approved fire protection program or at least once every refueling outage. Visual inspections of fire-rated structures (fire barrier walls, ceilings, and floors), combustible liquid spill retaining features (oil collection curbs), fire-rated assemblies, and fire damper housings assemblies are conducted at a frequency in accordance with the plants NRC-approved fire protection program. Periodic visual inspections are performed and functional tests are conducted on fire doors and their closing mechanisms and latches are verified functional in accordance with the plants NRC-approved fire protection program.

The results of inspections and functional testing of the in-scope fire protection equipment are collected and analyzed, and unacceptable results are documented in the corrective action program. When performance degrades to unacceptable levels, the PSL corrective action program is utilized to drive improvement. During the inspection of penetration seals, if any sign of abnormal degradation is detected within the sample, the inspection sample size is expanded, in accordance with the approved PSL fire protection program, to include an additional 10 percent of each type of sealed penetration.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 67 of 70 SLRA Appendix A2, Table 19-3, Commitment Nos. 18(b) and 18(c) on pages A2-77 and A2-78, are revised as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 18 Fire Protection (19.2.2.15) XI.M26 Continue the existing PSL Fire Protection AMP, including No later than 6 months prior to enhancement to: the SPEO, or no later than the last refueling outage prior to the a) Enhance plant procedures to specify that penetration seals will be SPEO i.e.:

inspected for indications of increased hardness and loss of strength such as cracking, seal separation from walls and PSL1: 09/01/2035 components, separation of layers of material, rupture, and puncture of seals.

b) Enhance plant procedures to specify that subliming, cementitious, and silicate materials used in fireproofing and fire barriers will be inspected for loss of material, separation, change in material properties, and cracking/delamination.

c) Enhance plant procedures to specify that any loss of material (e.g., general, pitting, or crevice corrosion), cracking, or elastomer degradation (e.g., hardening, loss of strength, or shrinkage) as applicable to the fire damper housings assembly is unacceptable.

d) Enhance plant procedures to require projection of identified degradation to the next scheduled inspection for all monitored fire protection SSCs, where practical.

e) Enhance plant procedures to require that projections are evaluated against acceptance criteria to confirm that the timing of subsequent inspections will maintain the components intended functions throughout the subsequent period of extended operation based on the projected rate of degradation.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 68 of 70 SLRA Appendix B, Section B.2.3.15, Program Description and Enhancement subsections on pages B-121, B-122, and B-123, are revised as follows:

B.2.3.15 Fire Protection Program Description The PSL Fire Protection AMP is an existing AMP, formerly a portion of the PSL Fire Protection Program. This AMP manages aging effects (loss of material, cracking, separation and loss of seal) associated with fire barriers and non-water suppression systems (halon). The PSL Fire Protection AMP includes fire barrier inspections. The fire barrier inspection portion of this AMP requires periodic visual inspection of fire barrier penetration seals, fire barrier walls, ceilings, floors, fire damper housings (i.e., the passive portion of the fire damper assemblies),

electrical raceway fire barrier systems, as well as periodic visual inspection and functional tests of fire-rated and in scope exterior non-fire rated doors so that their operability is maintained. The PSL Fire Protection AMP also requires periodic visual inspection of other passive fire protection features credited for the Fire Protection Program like oil collection dikes and curbs. The PSL Fire Protection AMP also includes periodic inspection and testing of the halon fire suppression systems (visual inspection for corrosion every 90 days and functional and air flow testing every 18 months).

With respect to preventive actions, PSL has adopted the National Fire Protection Association (NFPA) 805 fire protection program to meet the requirements of 10 CFR 50.48(c) and ensure that regulatory requirements are met for fire prevention, fire detection, fire suppression, and fire containment and alternative shutdown capability for each fire area containing SSCs important to safety.

Inspection results are acceptable if there are no signs of degradation that could result in the loss of the fire protection capability due to loss of material or elastomer degradation. The acceptance criteria include:

a) No visual indications (outside of those allowed by approved penetration seal configurations) of cracking, separation of seals from structures and components, indications of increased hardness, shrinkage, loss of strength, or ruptures or punctures of seals; b) No significant indications of cracking, loss of material, delamination, separation, and changes to elastomer properties of fire barrier walls, ceilings, floors, passive fire protection features credited by the fire protection program, and in other fire barrier materials; c) No visual indication of loss of material, cracking, or elastomer degradation as applicable on fire damper housingsassemblies; d) No visual indications of missing parts, holes, and wear; and e) No conditions in the functional tests of fire and non-fire rated exterior doors (i.e., the door swings easily, freely, and achieves positive latching assisted or unassisted).

Periodic inspections and testing of the halon fire suppression systems are performed to demonstrate that it is functional, and the surface condition of components is inspected for corrosion, nozzle obstructions, and other damage.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 69 of 70 Visual inspection of at least 10 percent of each type of sealed penetration is performed at a frequency in accordance with the plants NRC-approved fire protection program or at least once every refueling outage. Visual inspections on fire-rated structures (fire barrier walls, ceilings, and floors), combustible liquid spill retaining features (oil collection dikes and curbs), fire-rated assemblies, and on the fire damper housings assemblies are conducted at a frequency in accordance with the plants NRC-approved fire protection program. Periodic visual inspections are performed and functional tests are conducted on fire doors and their closing mechanism and latches are verified functional at a frequency in accordance with the plants NRC-approved fire protection program.

The results of inspections and functional testing of the in-scope fire protection equipment are collected, analyzed, and failed or degraded components are summarized by engineers in health reports. The system and program health reporting procedures identify adverse trends and prescribe preemptive corrective actions to prevent further degradation or future failures. When performance degrades to unacceptable levels, the PSL corrective action program is utilized to drive improvement. During the inspection of penetration seals, if any sign of abnormal degradation is detected within the sample, the inspection sample size is expanded, in accordance with the approved PSL fire protection program, to include an additional 10 percent of each type of sealed penetration.

NUREG-2191 Consistency The PSL Fire Protection AMP, with enhancements, will be consistent without exception to the 10 elements of NUREG-2191,Section XI.M26, Fire Protection.

Exceptions to NUREG-2191 None.

Enhancements The PSL Fire Protection AMP will be enhanced as follows, for alignment with NUREG-2191. The enhancements are to be implemented no later than 6 months prior to entering the SPEO.

Element Affected Enhancement

1. Scope of Program Enhance plant procedures to specify that penetration seals will
3. Parameters Monitored or be inspected for indications of increased hardness and loss of Inspected strength such as cracking, seal separation from walls and
4. Detection of Aging components, separation of layers of material, rupture, and Effects puncture of seals.
5. Monitoring and Trending
6. Acceptance Criteria

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 20 Page 70 of 70 Element Affected Enhancement

1. Scope of Program Enhance plant procedures to specify that subliming,
3. Parameters Monitored or cementitious, and silicate materials used in fireproofing and fire Inspected barriers will be inspected for loss of material, separation,
4. Detection of Aging change in material properties, and cracking/delamination.

Effects

5. Monitoring and Trending
6. Acceptance Criteria
1. Scope of Program Enhance plant procedures to specify that any loss of material
3. Parameters Monitored or (e.g., general, pitting, or crevice corrosion), cracking, or Inspected elastomer degradation (e.g., hardening, loss of strength, or
4. Detection of Aging shrinkage) as applicable to the fire damper housings Effects assembly is unacceptable.
5. Monitoring and Trending
6. Acceptance Criteria
5. Monitoring and Trending Enhance plant procedures to require projection of identified degradation to the next scheduled inspection for all monitored fire protection SSCs, where practical.
5. Monitoring and Trending Enhance plant procedures to require that projections are evaluated against acceptance criteria to confirm that the timing of subsequent inspections will maintain the components intended functions throughout the subsequent period of extended operation based on the projected rate of degradation.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 21 Page 1 of 7 Fire Water System Aging Effects and NFPA Clarifications Affected SLRA Sections: Table 3.3.2-5; 19.2.2.16 (Appendices A1 and A2); B.2.3.16 SLRA Page Numbers: 3.3-151, 3.3-152, 3.3-163, A1-23, A2-23, B-135 Description of Change:

SLRA Table 3.3.2-5, Fire Protection/Service Water - Summary of Aging Management Evaluation, is revised to include the following updates:

  • With respect to domestic water and fire water pump casings with an internal environment of raw water, a clarification is added to state that wall thinning due to erosion is an applicable aging effect.
  • With respect to domestic water pump casings with an internal environment of raw water, a clarification is added to state that flow blockage is an applicable aging effect.
  • With respect to stainless steel valve bodies with an internal environment of raw water, a clarification is added to delete the duplicate wall thinning row which had cross-referenced Note 2.

Appendix A1 and A2 of the PSL SLRA stated that inspections and testing are performed in accordance with the nuclear insurance carrier's fire protection system testing requirements and generally follows the guidance of applicable NFPA Codes and Standards. The phrase generally follows has been removed and any NFPA 25 deviations not already approved by NUREG-2191, which includes the significant corrosion clarifier within Section B.2.3.16 table (NFPA 25 Section 5.2.1.1) have been removed.

SLRA Table 3.3.2-5 is revised to clarify the aging effects associated with the domestic water and fire water pump casings and the stainless steel valve bodies. Appendix A1 and A2, Section 19.2.2.16, and Appendix B Section B.2.3.16 are revised to remove any deviation from the NFPA Codes and Standards.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 21 Page 2 of 7 SLRA Table 3.3.2-5, page 3.3-151 is revised as follows:

Table 3.3.2-5: Fire Protection / Service Water - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging Management NUREG-2191 Table 1 Notes Function Requiring Program Item Item Management Piping Pressure Stainless steel Raw water (int) Wall thinning - Inspection of Internal VII.C1.A-409 3.3-1, E, 2 boundary erosion Surfaces in 126 Miscellaneous Piping and Ducting Components (B.2.3.24)

Piping (halon) (Unit 1 Pressure Galvanized Air - outdoor (ext) Loss of material Fire Protection VII.G.AP-150 3.3-1, A only) boundary steel (B.2.3.15) 058 Piping (halon) (Unit 1 Pressure Galvanized Gas (int) None None VII.J.AP-6 3.3-1, A only) boundary steel 121 Piping (Unit 1 only) Leakage Galvanized Air - indoor None None VII.J.AP-13 3.3-1, A boundary steel uncontrolled (ext) 116 (spatial)

Piping (Unit 1 only) Pressure Copper alloy Gas (int) None None VII.J.AP-9 3.3-1, A boundary > 15% Zn 114 Piping (Unit 1 only) Pressure Galvanized Air - indoor None None VII.J.AP-13 3.3-1, A boundary steel uncontrolled (ext) 116 Piping (Unit 1 only) Pressure Galvanized Air - indoor None None VII.J.AP-13 3.3-1, A boundary steel uncontrolled (int) 116 Pump casing Pressure Ductile iron Air - outdoor (ext) Loss of material External Surfaces VII.I.A-77 3.3-1, A (domestic water boundary Monitoring of 078 pump) Mechanical Components (B.2.3.23)

Pump casing Pressure Ductile iron Raw water (int) Long-term loss One-Time Inspection VII.G.A-532 3.3-1, A (domestic water boundary of material (B.2.3.20) 193 pump)

Pump casing Pressure Ductile iron Raw water (int) Loss of material Fire Water System VII.G.A-33 3.3-1, A (domestic water boundary Flow blockage (B.2.3.16) 064 pump)

Pump casing Pressure Ductile iron Raw water (int) Wall thinning - Inspection of VII.C1.A-409 3.3-1, E, 2 (domestic water boundary erosion Internal Surfaces in 126 pump) Miscellaneous Piping and Ducting Components (B.2.3.24)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 21 Page 3 of 7 SLRA Table 3.3.2-5, page 3.3-152 is revised as follows:

Table 3.3.2-5: Fire Protection / Service Water - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging Management NUREG-2191 Table 1 Notes Function Requiring Program Item Item Management Pump casing Pressure Ductile iron Raw water (int) Loss of material Selective Leaching VII.G.A-51 3.3-1, 072 A (domestic water pump) boundary (B.2.3.21)

Pump casing (fire Pressure Gray cast iron Air - outdoor (ext) Loss of material External Surfaces VII.I.A-77 3.3-1, 078 A water pump) boundary Monitoring of Mechanical Components (B.2.3.23)

Pump casing (fire Pressure Gray cast iron Raw water (int) Long-term loss of One-Time Inspection VII.G.A-532 3.3-1, 193 A water pump) boundary material (B.2.3.20)

Pump casing (fire Pressure Gray cast iron Raw water (int) Loss of material Selective Leaching VII.G.A-51 3.3-1, 072 A water pump) boundary (B.2.3.21)

Pump casing (fire Pressure Gray cast iron Raw water (int) Loss of material Fire Water System VII.G.A-33 3.3-1, 064 A water pump) boundary Flow blockage (B.2.3.16)

Pump casing (fire Pressure Gray cast iron Raw water (int) Wall thinning - Fire Water System VII.C1.A-409 3.3-1, 126 E, 1 water pump) boundary erosion (B.2.3.16)

Pump casing (yard Pressure Stainless steel Air - outdoor (ext) Cracking External Surfaces VII.G.AP-209b 3.3-1, 004 A sump pump 2A) boundary Monitoring of Mechanical Components (B.2.3.23)

Pump casing (yard Pressure Stainless steel Air - outdoor (ext) Loss of material External Surfaces VII.G.AP-221b 3.3-1, 006 A sump pump 2A) boundary Monitoring of Mechanical Components (B.2.3.23)

Pump casing (yard Pressure Stainless steel Raw water (ext) Loss of material External Surfaces VII.E5.A-411 3.3-1, 135 G, 5 sump pump 2A) boundary Monitoring of Mechanical Components (B.2.3.23)

Pump casing (yard Pressure Stainless steel Raw water (ext) Loss of material Inspection of Internal VIII.G.S-436 3.4-1, A sump pump 2A) boundary Flow blockage Surfaces in 089 Miscellaneous Piping and Ducting Components (B.2.3.24)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 21 Page 4 of 7 SLRA Table 3.3.2-5, page 3.3-163 is revised as follows:

Table 3.3.2-5: Fire Protection / Service Water - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging Management NUREG-2191 Table 1 Notes Function Requiring Program Item Item Management Valve body Pressure Gray cast iron Soil (ext) Loss of material Buried and VII.I.AP-198 3.3-1, 109 A boundary Underground Piping and Tanks (B.2.3.27)

Valve body Pressure Gray cast iron Soil (ext) Loss of material Selective Leaching VII.G.A-02 3.3-1, 072 A boundary (B.2.3.21)

Valve body Pressure Stainless steel Air - outdoor (ext) Cracking External Surfaces VII.G.AP-209b 3.3-1, 004 A boundary Monitoring of Mechanical Components (B.2.3.23)

Valve body Pressure Stainless steel Air - outdoor (ext) Loss of material External Surfaces VII.G.AP-221b 3.3-1, 006 A boundary Monitoring of Mechanical Components (B.2.3.23)

Valve body Pressure Stainless steel Air - outdoor (int) Cracking Inspection of Internal VII.G.AP-209c 3.3-1, 004 A boundary Surfaces in Miscellaneous Piping and Ducting Components (B.2.3.24)

Valve body Pressure Stainless steel Air - outdoor (int) Loss of material Inspection of Internal VII.G.AP-221c 3.3-1, 006 A boundary Surfaces in Miscellaneous Piping and Ducting Components (B.2.3.24)

Valve body Pressure Stainless steel Raw water (int) Loss of material Fire Water System VII.G.A-55 3.3-1, 066 A boundary Flow blockage (B.2.3.16)

Valve body Pressure Stainless steel Raw water (int) Wall thinning - Fire Water System VII.C1.A-409 3.3-1, 126 E, 1 boundary erosion (B.2.3.16)

Valve body Pressure Stainless steel Raw water (int) Wall thinning - Fire Water System VII.C1.A-409 3.3-1, 126 E, 2 boundary erosion (B.2.3.16)

Valve body (halon) Pressure Carbon steel Air - outdoor (ext) Loss of material Fire Protection VII.G.AP-150 3.3-1, 058 A (Unit 1 only) boundary (B.2.3.15)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 21 Page 5 of 7 SLRA Appendix A1, Section 19.2.2.16, page A1-23 is revised as follows:

fire protection system components. This AMP manages loss of material, wall thinning, cracking, and flow blockage due to fouling by performing periodic visual inspections, tests, and flushes in accordance with the 2011 Edition of NFPA 25.

Testing or replacement of fast-response and traditional sprinkler heads that have been in service for 20 or 50 years, respectively, is performed in accordance with NFPA 25. In addition to NFPA codes and standards, portions of the water-based fire protection system that are: (1) normally dry but periodically subjected to flow and (2) cannot be drained or allow water to collect are subjected to augmented testing beyond that specified in NFPA 25, including: (a) periodic system full flow tests at the design pressure and flow rate or internal visual inspections and (b) piping volumetric wall-thickness examinations. Preventive actions (i.e., periodic flushes and biocide utilization) as well as periodic maintenance, testing, and inspection activities of the water-based fire protection systems are implemented to provide reasonable assurance that the fire water systems are capable of performing their intended functions. Inspections and testing are performed in accordance with the nuclear insurance carrier's fire protection system testing requirements and generally follows the guidance of applicable NFPA Codes and Standards.

The water-based fire protection system is normally maintained at required operating pressure and is monitored such that loss of system pressure is immediately detected and corrective actions are initiated. Piping wall thickness measurements are conducted when visual inspections detect surface irregularities indicative of unexpected levels of degradation. When the presence of organic or inorganic material sufficient enough to obstruct piping or sprinklers is detected, the material is removed, the source of the material is identified, and the source is corrected.

Inspections and tests follow site procedures that include inspection parameters for items such as lighting, distance, offset, presence of protective coatings, and cleaning processes for an adequate examination.

19.2.2.17 Outdoor and Large Atmospheric Metallic Storage Tanks The PSL Outdoor and Large Atmospheric Metallic Storage Tanks AMP is an existing AMP, previously part of the PSPM Program and Structures Monitoring Program.

This condition monitoring AMP manages aging effects associated with outdoor tanks sited on concrete and indoor large-volume tanks containing water designed with internal pressures approximating atmospheric pressure that are sited on concrete.

The Unit 1 and Common Unit tanks included within the scope of this AMP are as follows:

  • Unit 1 Refueling Water Tank (U1 RWT)
  • Treated Water Storage Tank (TWST)
  • Unit 1 Condensate Storage Tank (U1 CST)
  • Diesel Oil Storage Tank 1A (DOST 1A)
  • Diesel Oil Storage Tank 1B (DOST 1B)

This AMP includes preventive measures to mitigate corrosion by protecting the external surfaces of steel components per standard industry practice. Sealant or caulking is used for outdoor tanks at the tank bottom interface. This AMP manages loss of material and cracking by conducting one-time and periodic internal and external visual and surface examinations. Inspections of caulking or sealant are

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 21 Page 6 of 7 SLRA Appendix A2, Section 19.2.2.16, page A2-23 is revised as follows:

Testing or replacement of fast-response and traditional sprinkler heads that have been in service for 20 or 50 years, respectively, is performed in accordance with NFPA 25. In addition to NFPA codes and standards, portions of the water-based fire protection system that are: (1) normally dry but periodically subjected to flow and (2) cannot be drained or allow water to collect are subjected to augmented testing beyond that specified in NFPA 25, including: (a) periodic system full flow tests at the design pressure and flow rate or internal visual inspections and (b) piping volumetric wall-thickness examinations. Preventive actions (i.e., periodic flushes and biocide utilization) as well as periodic maintenance, testing, and inspection activities of the water-based fire protection systems are implemented to provide reasonable assurance that the fire water systems are capable of performing their intended functions. Inspections and testing are performed in accordance with the nuclear insurance carrier's fire protection system testing requirements and generally follows the guidance of applicable NFPA Codes and Standards.

The water-based fire protection system is normally maintained at required operating pressure and is monitored such that loss of system pressure is immediately detected and corrective actions are initiated. Piping wall thickness measurements are conducted when visual inspections detect surface irregularities indicative of unexpected levels of degradation. When the presence of organic or inorganic material sufficient enough to obstruct piping or sprinklers is detected, the material is removed, the source of the material is identified, and the source is corrected.

Inspections and tests follow site procedures that include inspection parameters for items such as lighting, distance, offset, presence of protective coatings, and cleaning processes for an adequate examination.

19.2.2.17 Outdoor and Large Atmospheric Metallic Storage Tanks The PSL Outdoor and Large Atmospheric Metallic Storage Tanks AMP is an existing AMP, previously part of the PSPM Program and Structures Monitoring Program.

This condition monitoring AMP manages aging effects associated with outdoor tanks sited on concrete and indoor large-volume tanks containing water designed with internal pressures approximating atmospheric pressure that are sited on concrete.

The Unit 2 and Common Unit tanks included within the scope of this AMP are as follows:

  • Unit 2 Refueling Water Tank (U2 RWT)
  • Unit 2 Primary Water Storage Tank (U2 PWST)
  • Unit 2 Condensate Storage Tank (U2 CST)

This AMP includes preventive measures to mitigate corrosion by protecting the external surfaces of steel components per standard industry practice. Sealant or caulking is used for outdoor tanks at the tank bottom interface. This AMP manages loss of material and cracking by conducting one-time and periodic internal and external visual and surface examinations. Inspections of caulking or sealant are supplemented with physical manipulation. Surface exams are conducted to detect cracking for the stainless steel U2 RWT. Thickness measurements of tank bottoms are conducted to detect degradation (e.g., loss of material on the inaccessible external surface). Inspections are conducted in accordance with ASME Code Section XI requirements as applicable or are conducted in accordance with

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 21 Page 7 of 7 SLRA Appendix B, Section B.2.3.16 (NFPA 25 Section 5.2.1.1), page B-135 is revised as follows:

Description NFPA 25 Required Enhancements Section Sprinkler Systems damage, loading, and loss of fluid in glass bulb heat responsive elements.

Additionally, sprinklers shall be installed in the correct orientation (e.g.,

upright, pendent, or sidewall). Any sprinkler that does not meet these criteria shall be replaced.

Note: The acceptance criteria related to glass bulb heat responsive elements only apply to the procedures that inspect closed head sprinklers (wet system and pre-action system), rather than open head nozzles.

The documentation above will be maintained by the AMP owner for comparing and trending inspection/test results.

5.2.1.1* Sprinklers shall be inspected from the floor level annually. [See NUREG-2191 Table XI.M27-1 Note 10.]

5.2.1.1.1* Sprinklers shall not show signs of leakage; shall be free of

[significant] corrosion, foreign materials, paint, and physical damage; and shall be installed in the correct orientation (e.g., upright, pendent, or sidewall).

5.2.1.1.2 Any sprinkler that shows signs of any of the following shall be replaced:

(1) Leakage (2) [Significant] Corrosion (3) Physical damage (4) Loss of fluid in the glass bulb heat responsive element (5)*Loading (6) Painting unless painted by the sprinkler manufacturer 5.2.1.1.3* Any sprinkler that has been installed in the incorrect orientation shall be replaced.

5.2.1.1.4 Any sprinkler shall be replaced that has signs of leakage; is painted, other than by the sprinkler manufacturer, corroded, damaged, or loaded; or is in the improper orientation.

5.2.1.1.5 Glass bulb sprinklers shall be replaced if the bulbs have emptied.

5.2.1.1.6* Sprinklers installed in concealed spaces such as above suspended ceilings shall not require inspection.

5.2.1.1.7 Sprinklers installed in areas that are inaccessible for safety considerations due to process operations shall be inspected during each scheduled shutdown.

Sprinkler 5.3.1 Update relevant preventive maintenance activities to incorporate the following testing sprinkler testing instructions of NFPA 25, Section 5.3.1 subsections. Steps with asterisks have additional clarifying information in NFPA 25, Annex A.

The required steps and information are as follows:

5.3.1.1*: Where required by this section, sample sprinklers shall be submitted to a recognized testing laboratory acceptable to the authority having jurisdiction for field service testing.

5.3.1.1.1: Where sprinklers have been in service for 50 years, they shall be replaced or representative samples from one or more sample areas shall be tested.

5.3.1.1.1.1: Test procedures shall be repeated at 10-year intervals.

5.3.1.1.1.2: Sprinklers manufactured prior to 1920 shall be replaced.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 22 Page 1 of 2 Outdoor and Large Atmospheric Metallic Storage Tanks - Refueling Water Tank Inspection Frequency Clarification Affected SLRA Sections: B.2.3.17 SLRA Page Numbers: B-154, B-155 Description of Change:

The SLRA did not include adequate clarity with respect to interior tank inspection frequency for the Unit 1 refueling water tank (RWT) that was impacted by a recent NRC approved relief request associated with the 10-year ASME Section XI Inservice Inspection (ISI) interval. This supplement adds additional wording to the exception to indicate that full hands-on interior inspections of the Unit 1 RWT will be performed consistent with the methods and frequency prescribed by the NRC approved relief request for each respective ASME Section XI ISI interval.

Accordingly, SLRA Section B.2.3.17 is revised to add the above clarification to the exception.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 22 Page 2 of 2 SLRA Appendix B, Section B.2.3.17 (exception), pages B-154 and B-155, is revised as follows:

Exceptions to NUREG-2191 The PSL Outdoor and Large Atmospheric Metallic Storage Tanks AMP will take the following exception to the NUREG-2191 guidance:

The PSL Outdoor and Large Atmospheric Metallic Storage Tanks AMP will take an exception to performing volumetric examinations of the U1 RWT floor, since it is not feasible. The aluminum floor for the U1 RWT has through-wall holes and this metal floor was not credited for the original License Renewal. Instead the floor is lined with a fiberglass-reinforced vinyl ester epoxy material (Dudick Protecto-Line 800), which is credited for performing the pressure boundary function for SLR. Instead of volumetric examinations, visual inspections will be used to inspect for cracking and loss of material as prescribed in an approved NRC relief request documented in FPL engineering evaluations and preventive maintenance activities. The preventive maintenance activities include diver inspections performed at a refueling outage interval and a full hands-on drained tank interior inspection performed using the methods directed by the relief request at an interval of every 6th refueling outage the frequency prescribed by the NRC approved relief request for each respective ASME Section XI ISI interval. The drained tank inspection will continue to inspect for galvanic corrosion cells between the SS piping, and manway flanges and the aluminum tank.

Enhancements The PSL Outdoor and Large Atmospheric Metallic Storage Tanks AMP will be enhanced as follows, for alignment with NUREG-2191. The enhancements are to be implemented no later than 6 months prior to entering the SPEO.

Element Affected Enhancement

3. Parameters Monitored or Create a new procedure, and/or associated PMs, to:

Inspected;

  • Address the interfaces, handoffs, and overlaps between
4. Detection of Aging the PSL Outdoor and Large Atmospheric Metallic Effects Storage Tanks AMP and the following AMPs:
5. Monitoring and Trending; o PSL Structures Monitoring (Section B.2.3.33) AMP;
6. Acceptance Criteria o PSL External Surfaces Monitoring of Mechanical
7. Corrective Actions Components (Section B.2.3.23) AMP; o PSL Water Chemistry (Section B.2.3.2) AMP; o PSL Fuel Oil Chemistry (Section B.2.3.18) AMP; o PSL One-Time Inspection (Section B.2.3.20) AMP; o PSL Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks (Section B.2.3.28) AMP and; o PSL ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD (Section B.2.3.1)

AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 23 Page 1 of 5 Fuel Oil Chemistry - Diesel Oil Storage Tanks Sampling Clarification Affected SLRA Sections: Table 19-3 (Appendices A1 and A2); B.2.3.18 SLRA Page Numbers: A1-88, A2-88, B-163, B-164 Description of Change:

The SLRA included an exception to performing bottom sampling of the diesel oil storage tanks (DOSTs), since the current practice is to recirculate the fuel oil prior to taking samples. This supplement adds an enhancement to perform bottom sampling of the DOSTs before and after the respective tanks recirculation. Additionally, this supplement removes the exception.

Accordingly, SLRA Appendix A1 and A2 and Section B.2.3.18 are revised to add an enhancement to perform bottom sampling before and after recirculation of the DOSTs.

Additionally, SLRA Section B.2.3.18 is updated to remove the exception related to bottom sampling of the DOSTs.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 23 Page 2 of 5 SLRA Appendix A1, Table 19-3 (Item 21), page A1-88 is revised as follows:

No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) i) Include the following acceptance criteria features in visual and volumetric inspection methodology:

  • Report any degradation of the tank (including all DOSTs and day tanks) internal surfaces and evaluate using the corrective action program.
  • Evaluate thickness measurements of the DOST tank bottom against the design thickness and corrosion allowance.

j) Provide corrective actions, such as addition of a biocide, to be taken should testing detect the presence of microbiological activity in stored diesel fuel.

k) Address performing corrective actions to prevent recurrence when the specified limits for fuel oil standards are exceeded during periodic surveillance.

l) Update procedures/PMRQs to perform bottom sampling of the DOSTs before and after the respective tanks recirculation.

22 Reactor Vessel XI.M31 Continue the existing PSL Reactor Vessel Material Surveillance AMP, No later than 6 months prior to Material Surveillance including an incremental adjustment to the approved capsule the SPEO, or no later than the (19.2.2.19) withdrawal schedule to withdraw and test the surveillance capsules last refueling outage prior to located at 263o and 83o in accordance with the NRC approved the SPEO i.e.:

withdrawal schedule.

PSL1: 09/01/2035

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 23 Page 3 of 5 SLRA Appendix A2, Table 19-3 (Item 21), page A2-88 is revised as follows:

No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) g) Include the following monitoring and trending features in visual and volumetric inspection methodology:

  • Identified degradation is projected until the next scheduled inspection, where practical.
  • Evaluate the results against acceptance criteria to confirm that the timing of subsequent inspections will maintain the components intended functions throughout the SPEO based on the projected rate of degradation.

h) Provide acceptance criteria, consistent with industry standards, for the testing requirement and approach used to detect the presence of water, particulates, and microbiological activity in stored diesel fuel within all DOSTs and day tanks.

i) Include the following acceptance criteria features in visual and volumetric inspection methodology:

  • Report any degradation of the tank (including all DOSTs and day tanks) internal surfaces and evaluate using the corrective action program.
  • Evaluate thickness measurements of the DOST tank bottom against the design thickness and corrosion allowance.

j) Provide corrective actions, such as addition of a biocide, to be taken should testing detect the presence of microbiological activity in stored diesel fuel.

k) Address performing corrective actions to prevent recurrence when the specified limits for fuel oil standards are exceeded during periodic surveillance.

l) Update procedures/PMRQs to perform bottom sampling of the DOSTs before and after the respective tanks recirculation.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 23 Page 4 of 5 SLRA Section B.2.3.18, page B-163 is revised as follows:

Exceptions to NUREG-2191 The PSL Fuel Oil Chemistry AMP includes the following exceptions to the NUREG-2191 guidance:

1. The size and the design of the day tanks make it difficult to perform the required draining, cleaning, internal inspections, or volumetric inspection of the bottom thickness of the day tanks. Accordingly, PSL will take an exception to the cleaning and inspection requirements specified in Element 4 of the NUREG-2191, XI.M30. As an alternate to the GALL-SLR Element 4 requirements, PSL will drain and clean the day tanks to the extent practical.

Visual inspection of accessible locations of the day tank internals will be performed, and volumetric (UT) inspection of accessible portions of the day tank as close to the bottom as possible will be performed.

2. Multilevel sampling or sampling from the lowest point is not used specified in Element 4 of the NUREG-2191, XI.M30. As an alternate to the GALL-SLR Element 4 requirements, the DOSTs are placed on recirculation for 30-minutes prior to sampling. The periodic recirculation of fuel oil also achieves filtering, reducing need for fuel treatments and additives by preventing contaminant build-up.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 23 Page 5 of 5 SLRA Section B.2.3.18, page B-164 is revised as follows:

Element Affected Enhancement

3. Parameters Monitored Require any pressure retaining boundary degradation identified during or Inspected; and visual inspection be supplemented with volumetric (UT) wall thickness
4. Detection of Aging testing including bottom thickness measurements for the DOSTs if Effects warranted.
4. Detection of Aging Prior to the subsequent period of extended operation, a one-time Effects inspection of selected components exposed to diesel fuel oil to be performed in accordance with the PSL One-Time Inspection (Section B.2.3.20) AMP to verify the effectiveness of the PSL Fuel Oil Chemistry AMP.
4. Detection of Aging Update procedures/PMRQs to perform bottom sampling of Effects the DOSTs before and after the respective tanks recirculation.
5. Monitoring and Update procedures/PMRQs to:

Trending o Perform periodic fuel oil sampling of the day tanks.

o Clarify that the sampling specifically monitors the following parameters for trending purposes: water content, sediment content, biological activity, and total particulate concentration for all DOSTs and day tanks.

o Update frequency of ASTM D975 (Reference 1.6.41) analysis to quarterly.

5. Monitoring and All new and existing visual and volumetric inspection procedures Trending for this AMP will include the following monitoring and trending features:

o Identified degradation is projected until the next scheduled inspection, where practical.

o Results are evaluated against acceptance criteria to confirm that the timing of subsequent inspections will maintain the components intended functions throughout the SPEO based on the projected rate of degradation.

6. Acceptance Criteria Provide acceptance criteria, consistent with industry standards, for the testing requirement and approach used to detect the presence of water, particulates, and microbiological activity in stored diesel fuel within all DOSTs and day tanks.
6. Acceptance Criteria All new and existing visual and volumetric inspection procedures for this AMP will include the following acceptance criteria features:

o Any degradation of the tank (including all DOSTs and day tanks) internal surfaces is reported and is evaluated using the corrective action program.

o Thickness measurements of the DOST tank bottom are evaluated against the design thickness and corrosion allowance.

7. Corrective Actions Provide corrective actions, such as addition of a biocide, to be taken should testing detect the presence of microbiological activity in stored diesel fuel.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 24 Page 1 of 5 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Affected SLRA Sections: Table 3.3-1, Table 3.3.2-4, Table 3.3.2-8 SLRA Page Numbers: 3.3-52, 3.3-78, 3.3-112, 3.3-193, 3.3-201 Description of Change:

SLRA Table 3.3.2-8 is being revised to add flow blockage due to fouling for stainless steel piping and valve body components exposed to raw water, with a pressure boundary intended function, under the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components AMP. Line item 3.3-1, 134 in SLRA Table 3.3-1 is also updated to include flow blockage in the discussion.

Internal cracking or blistering due to exposure to ultraviolet light, ozone, radiation, or chemical attack is not applicable to the internals of polyester flexible hoses or plexiglass sight glasses as these components are located indoors and are not exposed to ultraviolet light, ozone, radiation, or chemical attacks. Accordingly, SLRA Table 3.3.-1, Item Number 263, is being revised to explain why some aging effects are not applicable for internal surfaces, or components located indoors.

Additionally, a line is added to SLRA Table 3.3.2-4 to account for loss of material of rubber flexible hose exposed to dry air.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 24 Page 2 of 5 SLRA Table 3.3-1, page 3.3-52 is revised as follows:

Table 3.3-1: Summary of Aging Management Evaluations for the Auxiliary Systems Item Component Aging Effect / Aging Management Further Discussion Number Mechanism Programs Evaluation Recommended 3.3-1, 134 Steel, stainless steel, Loss of material due to XI.M38, No Consistent with NUREG-2191.

copper alloy piping, general (steel, copper alloy "Inspection of Internal The Inspection of Internal piping components, and only), pitting, crevice Surfaces in Miscellaneous Surfaces in Miscellaneous heat exchanger corrosion, MIC; flow Piping and Ducting Piping and Ducting components exposed to blockage due to fouling Components" Components AMP is used to raw water (for manage loss of material and components not covered flow blockage in steel and by NRC GL 89-13) stainless steel piping and piping components exposed to raw water internally.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 24 Page 3 of 5 SLRA Table 3.3-1, page 3.3-78 is revised as follows:

Table 3.3-1: Summary of Aging Management Evaluations for the Auxiliary Systems Item Component Aging Effect / Aging Management Further Discussion Number Mechanism Programs Evaluation Recommended 3.3-1, 263 Polymeric piping, Hardening or loss of AMP XI.M36, No Consistent with NUREG-2191. The piping components, strength due to polymeric "External Surfaces Inspection of Internal Surfaces in ducting, ducting degradation; loss of Monitoring of Mechanical Miscellaneous Piping and Ducting components, seals material due to peeling, Components," or AMP Components and External Surfaces exposed to air, delamination, wear; XI.M38, Monitoring of Mechanical Components condensation, raw cracking or blistering due to "Inspection of Internal AMPs are used to manage hardening or water, raw water exposure to ultraviolet light, Surfaces in Miscellaneous loss of strength, and loss of material, (potable), treated ozone, radiation, or Piping and Ducting and cracking of polyester or plexiglass water, waste water, chemical attack; flow Components" piping components exposed to indoor underground, blockage due to fouling uncontrolled air, dry air, or treated concrete, soil water. The External Surfaces Monitoring of Mechanical Components AMP is used to manage cracking of external surfaces of polyester or plexiglass piping components exposed to indoor uncontrolled air.

Internal cracking or blistering due to exposure to ultraviolet light, ozone, radiation, or chemical attack is not applicable for the internals of polyester flexible hoses or plexiglass sight glasses because they are not exposed to ultraviolet light, ozone, radiation, or chemical attacks.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 24 Page 4 of 5 SLRA Table 3.3.2-4, page 3.3-112 is revised as follows:

Table 3.3.2-4: Diesel Generators and Support Systems - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Type Function Requiring Management Item Item Management Program Flexible hose Pressure Rubber Air - dry (int) Loss of Inspection of VII.F4.AP-103 3.3-1, A boundary material Internal Surfaces 096 in Miscellaneous Piping and Ducting Components (B.2.3.24)

SLRA Table 3.3.2-8, page 3.3-193 is revised as follows:

Table 3.3.2-8: Intake Cooling Water / Emergency Cooling Canal - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Type Function Requiring Management Item Item Management Program Piping Pressure Stainless Raw water (int) Loss of material Inspection of VII.C1.A-727 3.3-1, A boundary steel Flow blockage Internal Surfaces 134 in Miscellaneous Piping and Ducting Components (B.2.3.24)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 24 Page 5 of 5 SLRA Table 3.3.2-8, page 3.3-201 is revised as follows:

Table 3.3.2-8: Intake Cooling Water / Emergency Cooling Canal - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Type Function Requiring Management Item Item Management Program Valve body Pressure Stainless Raw water (int) Loss of material Inspection of VII.C1.A-727 3.3-1, A boundary steel Flow blockage Internal Surfaces 134 in Miscellaneous Piping and Ducting Components (B.2.3.34)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 25 Page 1 of 11 Buried and Underground Piping and Tanks AMP and AMR Updates Affected SLRA Sections: Table 3.3.2-4, Table 3.3.2-8, Table 3.4-1, Table 3.4.2-3, 19.2.2.27 (Appendices A1 and A2), Table 19-3 (Appendices A1 and A2), B.2.3.27 SLRA Page Numbers: 3.3-130, 3.3-193, 3.4-23, 3.4-71, A1-32, A1-98, A2-31, A2-98, B-215, B-216 Description of Change:

SLRA Table 3.3.2-4 listed the Buried and Underground Piping and Tanks AMP for management of loss of material at the carbon steel to external concrete interface of the Unit 2 diesel oil storage tanks (DOSTs). Since this interface is not buried nor underground, the Buried and Underground Piping and Tanks AMP is not appropriate to manage loss of material at this interface. Additionally, unlike the Unit 1 DOSTs, the Unit 2 DOSTs 2A and 2B are excluded from the scope of the Outdoor and Large Atmospheric Metallic Storage Tanks AMP for SLR, since the Unit 2 DOSTs are indoors (within the Unit 2 DOST building) with a capacity of less than 100,000 gallons and no history of moisture at the inaccessible exterior bottom surface.

The Fuel Oil Chemistry AMP performs internal inspections of the Unit 1 and Unit 2 DOSTs. For the Unit 1 DOSTs, which are outdoors, the SLRA includes a commitment to perform LFET examination of the tank bottoms using the Outdoor and Large Atmospheric Metallic Storage Tanks AMP. For the Unit 2 DOSTs, which are indoors, volumetric tank bottom examinations only need to be performed if the internal inspections associated with the Fuel Oil Chemistry AMP determine a need for additional volumetric examinations. Therefore, the respective line from SLRA Table 3.3.2-4 is revised to state that for SLR, loss of material at the carbon steel to external concrete interface will not be managed by any AMP for SLR.

Operating experience has shown that buried stainless steel piping at PSL is typically embedded in concrete. Therefore, SLRA Table 3.3.2-8 is revised to add lines for stainless steel piping exposed to concrete.

Carbon steel underground piping is located in the auxiliary feedwater system. SLRA Table 3.4.2-3 is revised to add carbon steel piping in an underground external environment and Table 3.4-1, item number 3.4-1, 050 is revised, accordingly.

SLRA Section B.2.3.27 stated that opportunistic inspections can be credited for satisfying scheduled inspections but did not include the NUREG-2191 limits for crediting such inspections.

SLRA Section B.2.3.27 is revised to state that opportunistic examinations of nonleaking pipes may only be credited towards scheduled examinations if the GALL-SLR AMP XI.M41 criteria are met.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 25 Page 2 of 11 SLRA Section B.2.3.27 discussed the fuel oil piping that is housed within guard piping. The lengths of the piping are conservatively approximated as follows:

Fuel Line Length (ft)

Unit 1 Line from A DOST to A Emergency Diesel Generator 130 Unit 1 Line from B DOST to B Emergency Diesel Generator 110 Unit 1 to Unit 2 Cross Tie 300 Unit 2 Line from A DOST to A Emergency Diesel Generator 150 Unit 2 Line from B DOST to B Emergency Diesel Generator 200 With respect to cathodic protection, the guard pipe prevents contact of the fuel oil piping with the soil, making such cathodic protection of the fuel oil piping ineffective and unnecessary.

Currently, in lieu of cathodic protection and direct visual examination, the annular volume between the fuel oil piping and guard pipe is periodically pressure tested and blow-out tested (purged) with air or nitrogen to verify no leakage of the guard pipe and no leakage from the fuel oil piping. During the test, any potential leakage from the fuel oil piping gets blown to a collection port to verify the integrity of the piping. SLRA Appendix A1 and A2, Section 19.2.2.27 and Table 19-3 (Item 30), and Appendix B, Section B.2.3.27, are revised to include the commitment to perform the fuel oil guard pipe pressure testing and blow-out testing.

SLRA Table 3.3.2-4 stated that underground stainless steel piping would be managed for loss of material and cracking using the Buried and Underground Piping and Tanks AMP. SLRA Appendix A1 and A2, Section 19.2.2.27 and Table 19-3 (Item 30), and Appendix B, Section B.2.3.27, are revised to state that the underground stainless steel piping will be subject to periodic pressure testing and blow-out testing (purging) with air or nitrogen of the annular volume between the underground stainless steel fuel oil piping and its respective guard piping to verify no leakage of guard pipe and no leakage from the fuel oil piping. This testing will be performed for at least 25 percent of the stainless steel fuel oil piping housed within guard piping at an interval not to exceed 5 years with the first occurrence prior to the SPEO. The annular volume between the fuel oil piping and guard piping will be pressurized to 110 percent of the design pressure of any component within the boundary (not to exceed the maximum allowable test pressure of any non-isolated components) with test pressure being held for a continuous eight hour interval.

SLRA Appendix A1, Appendix A2, and Appendix B were not clear on whether the proposed cathodic protection criterion would continue to be used after five years or if alternative confirmatory tests would later be used. Therefore, SLRA Appendix A1 and A2, Section 19.2.2.27 and Table 19-3 (Item 30), and Appendix B, Section B.2.3.27, are revised to state that the cathodic protection criterion proposed in the SLRA will continue to be used after five years through the end of the SPEO.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 25 Page 3 of 11 SLRA Table 3.3.2-4, page 3.3-130 is revised as follows:

Table 3.3.2-4: Diesel Generators and Support Systems - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging Management NUREG-2191 Table 1 Notes Function Requiring Program Item Item Management Tank (Unit 2 air Pressure Stainless steel Air - indoor Loss of material External Surfaces VII.H2.AP-221b 3.3-1, 006 C start) boundary uncontrolled (ext) Monitoring of Mechanical Components (B.2.3.23)

Tank (Unit 2 diesel Pressure Carbon steel Air - indoor Loss of material Inspection of Internal V.A.E-29 3.2-1, 044 A oil storage) boundary uncontrolled (int) Surfaces in Miscellaneous Piping and Ducting Components (B.2.3.24)

Tank (Unit 2 diesel Pressure Carbon steel Fuel oil (int) Loss of material Fuel Oil Chemistry VII.H1.A-105 3.3-1, 070 B oil storage) boundary (B.2.3.18) A One-Time Inspection (B.2.3.20)

Tank (Unit 2 diesel Pressure Carbon steel Air - indoor Loss of material External Surfaces VII.I.A-77 3.3-1, 078 A oil storage) boundary uncontrolled (ext) Monitoring of Mechanical Components (B.2.3.23)

Tank (Unit 2 diesel Pressure Carbon steel Concrete (ext) None None VII.I.AP-198 3.3-1, 112 A oil storage) boundary Loss of material Buried and 109 Underground Piping and Tanks (B.2.3.27)

Tank (Unit 2 diesel Pressure Coating Air - indoor Loss of coating or Internal VII.D.A-416 3.3-1, 138 A oil storage) boundary uncontrolled (int) lining integrity Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks (B.2.3.28)

Tank (Unit 2 diesel Pressure Coating Fuel oil (int) Loss of coating or Internal VII.H1.A-416 3.3-1, 138 A oil storage) boundary lining integrity Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks (B.2.3.28)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 25 Page 4 of 11 SLRA Table 3.3.2-8, page 3.3-193 is revised to add the following lines:

Table 3.3.2-8: Intake Cooling Water / Emergency Cooling Canal - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Type Function Requiring Management Item Item Management Program Piping Pressure Stainless Concrete (ext) Cracking Buried and VII.I.A-425 3.3-1, A boundary steel Underground 144 Piping and Tanks (B.2.3.27)

Piping Pressure Stainless Concrete (ext) Loss of Buried and VII.I.AP-137 3.3-1, A boundary steel material Underground 107 Piping and Tanks (B.2.3.27)

SLRA Table 3.4-1, page 3.4-23 is revised as follows:

Table 3.4-1: Summary of Aging Management Evaluations for the Steam and Power Conversion Systems Item Component Aging Effect / Aging Management Further Discussion Number Mechanism Programs Evaluation Recommended 3.4-1, 050 Steel piping, piping Loss of material due to AMP XI.M41, "Buried No Not applicable.

components, tanks, general, pitting, crevice and Underground Piping There are no steel piping and closure bolting exposed corrosion, MIC (soil only) and Tanks" piping components exposed to to soil, concrete, soil, concrete, or underground underground in the Steam and Power Conversion Systems.

Consistent with NUREG-2191.

The Buried and Underground Piping and Tanks AMP is used to manage loss of material for underground steel components.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 25 Page 5 of 11 SLRA Table 3.4.2-3, page 3.4-71 is revised to add the following line:

Table 3.4.2-3: Auxiliary Feedwater and Condensate - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG-2191 Table 1 Notes Type Function Requiring Management Item Item Management Program Piping Pressure Carbon Underground Loss of Buried and VIII.H.SP-161 3.4-1, A boundary steel (ext) material Underground 050 Piping and Tanks (B.2.3.27)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 25 Page 6 of 11 SLRA Appendix A1, Section 19.2.2.27, page A1-32 is revised as follows:

Material No. of Inspections Notes Steel (buried) 11* prior to the SPEO Includes 2 additional inspections to (Category F) meet the requirements of NUREG-2191 4 in each 10-year period Section XI.M41, paragraph 4.e.i during the SPEO (Category C) regarding the aging effects associated with fire mains.

Steel 3 (underground)

Stainless steel Pressure testing per note Perform periodic pressure testing (underground) and blow-out testing (purging) with air or nitrogen of the annular volume between the underground stainless steel fuel oil piping and its respective guard piping to verify no leakage of guard pipe and no leakage from the fuel oil piping. This testing will be performed for at least 25 percent of the stainless steel fuel oil piping housed within guard piping at an interval not to exceed 5 years with the first occurrence prior to the SPEO. The annular volume between the fuel oil piping and guard piping will be pressurized to 110 percent of the design pressure of any component within the boundary (not to exceed the maximum allowable test pressure of any non-isolated components) with test pressure being held for a continuous eight hour interval.

Stainless steel 2 (buried)

  • If after five years of operation the cathodic protection system does not meet the effectiveness acceptance criteria defined by NUREG-2191, Tables XI.M41-2 and -3

(-850 mV relative to a copper/copper sulfate reference electrode (CSE), instant off, for at least 80 percent of the time, and in operation for at least 85 percent of the time), FPL commits to performing two additional buried steel piping inspections beyond the number required by Preventive Action Category F resulting in a total of thirteen (13) inspections being completed six months prior to the SPEO. The cathodic protection criterion listed above will continue to be used after five years through the end of the SPEO.

Loss of material is monitored by visual inspection of the exterior and wall thickness measurements of the piping. Wall thickness is determined by an NDE technique such as UT.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 25 Page 7 of 11 SLRA Appendix A1, Table 19-3 (Item 30), page A1-98 is revised as follows:

Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) other considerations. The new Boral panel surveillance acceptance criteria for the obtained inspection, testing, and analysis measurements must ensure that the 5% subcriticality margin for the SFP will be maintained, otherwise corrective actions need to be implemented.

30 Buried and Underground XI.M41 Implement the new PSL Buried and Underground Piping and Tanks AMP. Implement AMP and start Piping and Tanks (19.2.2.27) a) Install cathodic protection systems and perform effectiveness reviews inspections no earlier than 10 in accordance with Table XI.M41-2 in NUREG-2191,Section XI.M41. years prior to the SPEO b) If after five years of operation the cathodic protection system does not (03/01/2026). Install cathodic meet the effectiveness acceptance criteria defined by NUREG-2191, protection systems no later than Tables XI.M41-2 and -3 (-850 mV relative to a CSE, instant off, for at 10 years prior to the SPEO least 80% of the time, and in operation for at least 85% of the time), (03/01/2026). Complete FPL commits to performing two additional buried steel piping pre-SPEO inspections no later inspections beyond the number required by Preventive Action than 6 months or the last RFO Category F resulting in a total of 13 inspections being completed prior to SPEO i.e.:

6 months prior to the SPEO. The cathodic protection criterion PSL1: 09/01/2035 listed above will continue to be used after five years through the end of the SPEO.

c) Perform periodic pressure testing and blow-out testing (purging) with air or nitrogen of the annular volume between the underground stainless steel fuel oil piping and its respective guard piping to verify no leakage of guard pipe and no leakage from the fuel oil piping. This testing will be performed for at least 25 percent of the stainless steel fuel oil piping housed within guard piping at an interval not to exceed 5 years with the first occurrence prior to the SPEO. The annular volume between the fuel oil piping and guard piping will be pressurized to 110 percent of the design pressure of any component within the boundary (not to exceed the maximum allowable test pressure of any non-isolated components) with test pressure being held for a continuous eight hour interval.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 25 Page 8 of 11 SLRA Appendix A2, Section 19.2.2.27, page A2-31 is revised as follows:

The number of inspections for each 10-year inspection period, commencing 10 years prior to the start of SPEO, are based on the inspection quantities noted in NUREG-2191, Table XI.M41-2, adjusted for a 2-Unit plant site.

Material No. of Inspections Notes Steel (buried) 11* prior to the SPEO Includes 2 additional inspections to (Category F) meet the requirements of NUREG-2191 4 in each 10-year period Section XI.M41, paragraph 4.e.i during the SPEO (Category C) regarding the aging effects associated with fire mains.

Steel 3 (underground)

Stainless steel Pressure testing per note Perform periodic pressure testing (underground) and blow-out testing (purging) with air or nitrogen of the annular volume between the underground stainless steel fuel oil piping and its respective guard piping to verify no leakage of guard pipe and no leakage from the fuel oil piping. This testing will be performed for at least 25 percent of the stainless steel fuel oil piping housed within guard piping at an interval not to exceed 5 years with the first occurrence prior to the SPEO. The annular volume between the fuel oil piping and guard piping will be pressurized to 110 percent of the design pressure of any component within the boundary (not to exceed the maximum allowable test pressure of any non-isolated components) with test pressure being held for a continuous eight hour interval.

Stainless steel 2 (buried)

  • If after five years of operation the cathodic protection system does not meet the effectiveness acceptance criteria defined by NUREG-2191, Tables XI.M41-2 and -3

(-850 mV relative to a copper/copper sulfate reference electrode (CSE), instant off, for at least 80 percent of the time, and in operation for at least 85 percent of the time), FPL commits to performing two additional buried steel piping inspections beyond the number required by Preventive Action Category F resulting in a total of thirteen (13) inspections being completed six months prior to the SPEO. The cathodic protection criterion listed above will continue to be used after five years through the end of the SPEO.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 25 Page 9 of 11 SLRA Appendix A2, Table 19-3 (Item 30), page A2-98 is revised as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 30 Buried and Underground XI.M41 Implement the new PSL Buried and Underground Piping and Tanks Implement AMP and start Piping and Tanks (19.2.2.27) AMP. inspections no earlier than 10 years prior to the SPEO a) Install cathodic protection systems and perform effectiveness (04/06/2033). Install cathodic reviews in accordance with Table XI.M41-2 in NUREG-2191, protection systems no later Section XI.M41. than 10 years prior to the b) If after five years of operation the cathodic protection system does SPEO (04/06/2033).

not meet the effectiveness acceptance criteria defined by Complete pre-SPEO NUREG-2191, Tables XI.M41-2 and -3 (-850 mV relative to a inspections no later than 6 CSE, instant off, for at least 80% of the time, and in operation for months or the last RFO prior to at least 85% of the time), FPL commits to performing two SPEO i.e.:

additional buried steel piping inspections beyond the number required by Preventive Action Category F resulting in a total of PSL2: 10/06/2042 thirteen (13) inspections being completed 6 months prior to the SPEO. The cathodic protection criterion listed above will continue to be used after five years through the end of the SPEO.

c) Perform periodic pressure testing and blow-out testing (purging) with air or nitrogen of the annular volume between the underground stainless steel fuel oil piping and its respective guard piping to verify no leakage of guard pipe and no leakage from the fuel oil piping. This testing will be performed for at least 25 percent of the stainless steel fuel oil piping housed within guard piping at an interval not to exceed 5 years with the first occurrence prior to the SPEO.

The annular volume between the fuel oil piping and guard piping will be pressurized to 110 percent of the design pressure of any component within the boundary (not to exceed the maximum allowable test pressure of any non-isolated components) with test pressure being held for a continuous eight hour interval.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 25 Page 10 of 11 SLRA Section B.2.3.27, page B-215 is revised as follows:

B.2.3.27 Buried and Underground Piping and Tanks Program Description The PSL Buried and Underground Piping and Tanks AMP is a new condition monitoring AMP that manages the aging effects associated with the external surfaces of buried and underground piping such as loss of material and cracking. It addresses piping composed of steel (carbon steel, cast iron, and ductile iron) and SS materials that are within the scope of Subsequent License Renewal. There are no buried or underground tanks at PSL.

There are no polymeric, cementitious, or additional metallic materials other than the steel metals stated above for the in-scope systems, therefore, the aging management of these materials is not applicable. The interior surfaces of the coated, cement lined cast iron fire water system piping is managed by the PSL Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks (Section B.2.3.28) AMP.

The objective of this program is accomplished through the use of preventive, mitigative, inspection, and in some cases, performance monitoring activities. The PSL Buried and Underground Piping and Tanks AMP includes (a) preventive measures to mitigate degradation (e.g., external coatings/wrappings), (b) visual inspections of external surfaces of buried components for evidence of coating/wrapping damage, and (c) visual inspections of external surfaces of buried components for evidence of degradation, if the coating or wrapping is damaged or the pipe is uncoated or unwrapped, to manage the effects of aging. The periodicity of these inspections will be based on plant OE and opportunities for inspection such as scheduled maintenance work. These inspections will occur once prior to the SPEO and at least every 10 years during the SPEO. If an opportunity for inspection of nonleaking piping occurs prior to the scheduled inspection, the opportunistic inspection can be credited for satisfying the scheduled inspection if the GALL-SLR AMP XI.M41 criteria are met.

The PSL Buried and Underground Piping and Tanks AMP manages applicable aging effects such as loss of material, cracking, and blistering. Depending on the material, preventive and mitigative techniques may include using external coatings, cathodic protection, and quality backfill. Depending on the material and environment, inspection activities may include electrochemical verification of the effectiveness of cathodic protection, nondestructive evaluation of pipe wall thicknesses, pressure testing and blow-out testing, and visual inspections of the pipe from the exterior.

PSL currently does not have an active cathodic protection system for buried and underground piping. Backfill specifications, average pH of soil samples, the use of guard pipe and coatings was previous justification for not having a need for an active cathodic protection system for buried steel piping. In accordance with the recommendations of NUREG-2191 AMP XI.M41, a cathodic protection system will be installed 10 years prior to SPEO.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 25 Page 11 of 11 SLRA Section B.2.3.27, page B-216 is revised as follows:

selected for buried steel piping after the cathodic protection system has been in service for approximately 10 years and annual effectiveness reviews are performed.

However, if these conditions were to change, the Preventive Action Category would require reevaluation and could potentially change.

The number of inspections for each 10-year inspection period, commencing 10 years prior to the start of SPEO, are based on the inspection quantities noted in NUREG-2191, Table XI.M41-2, adjusted for a 2-Unit plant site.

Material No. of Inspections Notes Steel (buried) 11* prior to the SPEO Includes 2 additional inspections to (Category F) meet the requirements of NUREG-2191 4 in each 10-year period in the Section XI.M41, paragraph 4.e.i SPEO (Category C) regarding the aging effects associated with fire mains.

Steel 3 (underground)

Stainless steel Pressure testing per note Perform periodic pressure testing (underground) and blow-out testing (purging) with air or nitrogen of the annular volume between the underground stainless steel fuel oil piping and its respective guard piping to verify no leakage of guard pipe and no leakage from the fuel oil piping. This testing will be performed for at least 25 percent of the stainless steel fuel oil piping housed within guard piping at an interval not to exceed 5 years with the first occurrence prior to the SPEO. The annular volume between the fuel oil piping and guard piping will be pressurized to 110 percent of the design pressure of any component within the boundary (not to exceed the maximum allowable test pressure of any non-isolated components) with test pressure being held for a continuous eight hour interval.

Stainless steel 2 (buried)

  • If after five years of operation the cathodic protection system does not meet the effectiveness acceptance criteria defined by NUREG-2191, Tables XI.M41-2 and -3 (-850 mV relative to a CSE, instant off, for at least 80 percent of the time, and in operation for at least 85 percent of the time), FPL commits to performing two additional buried steel piping inspections beyond the number required by Preventive Action Category F resulting in a total of thirteen (13) inspections being completed six months prior to the SPEO. The cathodic protection criterion listed above will continue to be used after five years through the end of the SPEO.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 26 Page 1 of 4 Clarification of Internal Coatings Items Affected SLRA Sections: Table 3.2-1; B.2.3.28 SLRA Page Numbers: 3.2-32, B-221 Description of Change:

SLRA Table 3.2.1 is being revised to update item 3.2-1, 073 to say, not used and point to item 3.2-1, 070.

Clarification about the nature of the internal environment for fire water piping is appropriate. The fire water system is supplied by the city water storage tanks (CWSTs), which are supplied by potable water from the Fort Pierce water supply line to the site. While this potable water is classified as raw water within the environments classified by NUREG-2191 and NUREG-2192, it represents a significantly more benign environment for the aging effects of concern when compared with the other raw water source used at the St. Lucie plant (PSL). Specifically, this milder, more benign environment justifies the use of the alternative approach for ensuring the continued functionality of the internally coated fire water piping (i.e., use of fire water system tests and monitoring in place of some of the excavations and inspections that would otherwise be required). This clarification will be added to Section B.2.3.28 of Appendix B of the PSL SLRA.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 26 Page 2 of 4 SLRA Table 3.2-1, page 3.2-32 is revised as follows:

Table 3.2-1: Summary of Aging Management Evaluations for the Engineered Safety Features Item Component Aging Effect / Aging Management Further Discussion Number Mechanism Programs Evaluation Recommended 3.2-1, 073 Any material piping, Loss of material due to AMP XI.M42, "Internal No Not used.

piping components, heat general, pitting, crevice Coatings/Linings for In- Loss of material for the Unit 2 exchangers, tanks with corrosion, MIC Scope Piping, Piping refueling water tank is internal coatings/linings Components, Heat addressed by line item 3.2-1, exposed to closed-cycle Exchangers, and Tanks" 070.

cooling water, raw water, Not applicable. The Engineered treated water, treated Safety Features Systems do not borated water, include any material piping, lubricating oil, piping components, heat condensation exchangers, or tanks with internal coatings/linings exposed to closed-cycle cooling water, raw water, treated water, treated borated water, or condensation.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 26 Page 3 of 4 SLRA Section B.2.3.28 on page B-221, is revised as follows:

  • Minor cracking and spalling of cementitious coatings/linings is acceptable provided there is no evidence that the coating/lining is debonding from the base material.
  • As applicable, wall thickness measurements, projected to the next inspection, meet design minimum wall requirements.
  • Adhesion testing results, when conducted, meet, or exceed the degree of adhesion recommended in plant-specific design requirements specific to the coating/lining and substrate.

For tanks and heat exchangers, all accessible surfaces will be inspected. Piping inspections will be sampling-based. The training and qualification of individuals involved in coating/lining inspections of non-cementitious coatings/linings will be conducted in accordance with ASTM International Standards endorsed in RG 1.54 including guidance from the staff associated with a particular standard. For cementitious coatings/linings inspectors should have a minimum of 5 years of experience inspecting or testing concrete structures or cementitious coatings/linings or a degree in the civil/structural discipline and a minimum of 1 year of experience.

Peeling and delamination will not be acceptable. Blisters will be evaluated by a coatings specialist to confirm the surrounding material is sound and the blister size and frequency is not increasing. Minor cracks in cementitious coatings will be acceptable provided there is no evidence of debonding. All other degraded conditions will be evaluated by a coatings specialist. For coated/lined surfaces determined to not meet the acceptance criteria, physical testing will be performed where physically possible (i.e., sufficient room to conduct testing) in conjunction with repair or replacement of the coating/lining. Additional inspections will be conducted if one of the inspections does not meet acceptance criteria due to current or projected degradation (i.e., trending) unless the cause of the aging effect for each applicable material and environment is corrected by repair or replacement for all components constructed of the same material and exposed to the same environment.

While the air, fuel oil, and treated water environments between the two Units meet the criteria listed in GALL-SLR Chapter XI.M42, the components that are coated and exposed to these environments are tanks. As such, the population sizes are too small to reduce the number of inspections required. Because the fire water and service water systems for both Units are supplied from the same raw water source (city water) and the intake cooling water and emergency cooling canal systems for both Units are supplied by the same raw water source (intake canal water), the coatings inspections for each environment (i.e., city water and intake canal water) could be reduced for the two units.

The fire water system is supplied by the CWSTs, which are supplied by potable water from the Fort Pierce water supply line to the site. Although this is considered a raw water environment, it represents a significantly more benign environment for the aging effects of concern when compared with the other raw water source (brackish water at the intake structure) used at the PSL.

Additionally, the flow rate through the fire water system is much lower than that through the intake cooling water system or the circulating water system.

Because of the milder environment, lower flow rates, and because plant-specific OE does not show any leaks due to age-related degradation of

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 26 Page 4 of 4 the internally coated/lined portions of the fire water system, oOpportunistic inspections, in lieu of periodic inspections, will be performed for the buried concrete lined fire protection piping. PSL will perform flow tests and internal piping inspections at intervals specified by NUREG-2191, Table XI.M27-1, and will be capable of detecting through-wall flaws in the piping through continuous system pressure monitoring (alarm setpoints). In addition, PSL does not have plant-specific OE regarding buried fire main leaks due to age-related degradation in the coated/lined portions of the piping.

The PSL Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks AMP will have new governing and inspection procedures

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 27 Page 1 of 12 ASME Section XI, Subsection IWE AMP: Clarified Discussions for Enhancements and Related Further Evaluations Affected SLRA Sections: 3.5.2.2.1.3, 3.5.2.2.1.6, Table 19-3 (Appendices A1 and A2),

B.2.3.29 SLRA Page Numbers: 3.5-23, 3.5-25, A1-99 through A1-100, A2-99 through A2-100, B-227 through B-229 Description of Change:

The St. Lucie Nuclear Plant (PSL) ASME Section XI, Subsection IWE AMP is credited for evaluating the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas. A brief summary of how existing procedures at PSL mandate these evaluations is added to the background discussion in SLRA Section B.2.3.29. In addition, four conditions are specified by NUREG-2192 Section 3.5.3.2.1.3 that must be satisfied to demonstrate the adequacy of the above approach in lieu of a plant-specific AMP for corrosion. Accordingly, text addressing concrete specification (per ACI 318), aging management of the moisture barrier (per the ASME Section XI, Subsection IWE AMP), monitoring concrete for cracks (per the Structures Monitoring AMP), and control of borated water spills and water ponding (per the Boric Acid Corrosion AMP) is added to SLRA Section 3.5.2.2.1.3.

A holistic review of the PSL Units 1 and 2 metal containments and penetration fatigue analyses was performed as presented in Attachment 8 to this supplement. This review also included a revalidation of dissimilar metal welds associated with containment penetrations.

As a result of this review, a significant number of revisions are made to SLRA Sections 3.5.2.2.1.5, 3.5.2.2.1.6, Table 3.5-1, Table 3.5.2-1, Section 4.6, Section 19.3.5 and Table 19-3 (Appendices A1 and A2), and Section B.2.3.29. For a description of revisions to the ASME Section XI, Subsection IWE AMP as a result of the review of containment fatigue and dissimilar metal welds, refer to Attachment 8 to this supplement.

An enhancement related to supplemental one-time inspections to detect stress corrosion cracking (SCC) was specified for the PSL ASME Section XI, Subsection IWE AMP; however, specific methods for surface examination (magnetic particle, dye penetrant) and enhanced visual examination (EVT-1 or equivalent) were not identified. As noted in to this supplement, the electrical penetrations for PSL Unit 2 incorporate dissimilar metal welds. Per Unit 2 UFSAR Section 8.3.1.2.2, there are a total of 48 electrical penetrations for cables entering the containment; 10 items constitute a representative sample for this population. Clarifying text is added to discussions of this enhancement in SLRA Section 3.5.2.2.1.6 and in SLRA Section B.2.3.29.

Enhancements related to bolting integrity were specified for the PSL ASME Section XI, Subsection IWE AMP. To ensure consistency of preventive actions for bolting across all related PSL AMPs, enhancements in SLRA Section B.2.3.29 are revised to incorporate EPRI reports 1015336 and 1015337 (which superseded EPRI NP-5067 and TR-104213--

cited in NUREG-2191 Section XI.S1) and to specify guidance discussed in Section 2 of Research Council for Structural Connections publication "Specification for Structural Joints Using High-Strength Bolts" regarding the selection of bolting materials, the selection of bolting lubricants, the selection of coating materials, and the appropriate installation torque or tension in addition to storage requirements. Enhancements will also ensure molybdenum

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 27 Page 2 of 12 disulfide and other lubricants containing sulfur will not be used for structural bolting at PSL.

An enhancement related to one-time volumetric examinations triggered by plant-specific OE was specified for the PSL ASME Section XI, Subsection IWE AMP. Text of the enhancement in SLRA Section B.2.3.29 is revised to clarify application to both units at PSL, add characteristics of the locations to be examined, and remove unnecessary reference to code inspections.

As noted in Attachment 8 of this supplement, electrical penetrations for PSL Unit 2 incorporate dissimilar metal welds. An enhancement related to corrective actions upon identification of SCC as a result of supplemental one-time inspections for susceptible items was specified for the PSL ASME Section XI, Subsection IWE AMP. If needed, follow-on inspections will include surface examination (magnetic particle, dye penetrant) and enhanced visual examination (EVT-1 or equivalent). The frequency of inspection will be consistent with the approved IWE interval. Text addressing the type and periodicity of follow-on inspections is added to the subject enhancement in SLRA Section B.2.3.29.

Changes to the enhancements identified above are also reflected in updates to the associated commitments presented in SLRA Table 19-3 (both Appendices A1 and A2).

Note that the markups for SLRA Section 3.5.2.2.1.6, Table 19-3 (Appendices A1 and A2), and Section B.2.3.29 include changes associated with Attachment 8 of this supplement.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 27 Page 3 of 12 SLRA Section 3.5.2.2.1.3, page 3.5-23 (paragraph continued from page 3.2-22), is revised as follows:

Vessel in the Shield Building. The Containment Vessel bottom head is supported by concrete fill, with the void spaces filled. Concrete fill also occupies the operating floor inside the PSL Containment Vessel. Concrete meeting the requirements of ACI 318 was used in these applications at PSL. Moisture barriers are provided between the Containment Vessel and concrete fill on the Shield Building side and inside the Containment Vessel. These moisture barriers are inspected by the Section XI, Subsection IWE Inservice Inspection Program for the current renewed licenses. Inspections performed in accordance with the Stuctures Monitoring (B.2.3.33) AMP monitor concrete for penetrating cracks that could provide a path for water seepage to the surface of the containment vessel; plant-specific OE has revealed no such indications.

As part of the Boric Acid Corrosion (B.2.3.4) AMP, evaluation and extent of condition assessments are initiated when potential leakage from borated water systems is discovered. Any borated water spillage or water ponding on concrete floors is cleaned up or diverted to sumps in a timely manner when detected. The above activities are part of the current licensing basis and will be continued through the SPEO.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 27 Page 4 of 12 SLRA Section 3.5.2.2.1.6, page 3.5-25, is revised as follows:

3.5.2.2.1.6 Cracking Due to Stress Corrosion Cracking Stress corrosion cracking (SCC) of stainless steel (SS) penetration sleeves, penetration bellows, vent line bellows, suppression chamber shell (interior surface), and dissimilar metal welds could occur in PWR and/or BWR containments. The existing program relies on ASME Code Section XI, Subsection IWE and 10 CFR Part 50, Appendix J, to manage this aging effect. Further evaluation, including consideration of SCC susceptibility and applicable operating experience (OE) related to detection, is recommended of additional appropriate examinations/evaluations implemented to detect this aging effect for these SS components and dissimilar metal welds.

Stainless steel mechanical penetration expansion bellows and PSL Unit 2 electrical penetration dissimilar metal welds are exposed to an uncontrolled indoor air environment at PSL. A review of PSL OE confirms halides are potentially present in the indoor environments at PSL.

Additionally, these indoor components, particularly those in standby or periodically operated systems, could conservatively see an accumulation of contaminants. As such, the stainless steel mechanical penetration expansion bellows and PSL Unit 2 electrical penetration dissimilar metal welds exposed to uncontrolled indoor air in the containment buildings are susceptible to SCC and require management via an appropriate program.

Consistent with the recommendation of NUREG-2191, cracking of these components will be managed by the ASME Section XI, Subsection IWE (B.2.3.29) AMP and 10 CFR Part 50, Appendix J (B.2.3.31) AMP. The ASME Section XI, Subsection IWE AMP provides for the management of aging effects through surface examinations (magnetic particle, dye penetrant) or enhanced visual examinations (EVT-1 or equivalent), performed by qualified personnel using methods capable of detecting cracking. Any visual evidence of cracking will be evaluated for acceptability and additional surface examinations or enhanced visual examinations, if required, will be conducted in accordance with the sites corrective action process. The 10 CFR Part 50, Appendix J AMP is a performance monitoring program that monitors the leakage rates through the containment system, its vessel, associated welds, penetrations, isolation valves, fittings, and other access openings to detect degradation of the containment pressure boundary. Adverse conditions will be documented in accordance with the 10 CFR Part 50, Appendix B Corrective Action Program.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 27 Page 5 of 12 SLRA Appendix A1, Section 19.4, commitment No. 32 portion of Table 19-3 beginning on page A1-99, is revised as follows:

Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 32 ASME Section XI, XI.S1 Continue the existing PSL ASME Section XI, Subsection IWE AMP, No later than 6 months prior to Subsection IWE (19.2.2.29) including enhancement to: the SPEO, or no later than the last refueling outage prior to a) Augment existing procedures to reference EPRI Reports the SPEO i.e.:

1015336 and 1015337 and to incorporate guidance for proper selectionspecify that whenever replacement of bolting is PSL1: 09/01/2035 required, bolting material, and lubricants and appropriate installation torque or tension, and use of lubricants and sealants Start the one-time inspections are in accordance with the guidelines of EPRI NP-5769, for cracking due to SCC no Degradation and Failure of Bolting in Nuclear Power Plants and earlier than 5 years prior to the EPRI TR-104213, Bolted Joint Maintenance & Application Guide SPEO (03/01/2031).

to prevent or minimize loss of bolting preload and cracking of high-strength bolting. Additionally, update procedures to explicitly prohibit the use of molybdenum disulfide and other lubricants containing sulfur on structural bolting.

b) Augment existing procedures to specify that for structural bolting consisting of ASTM A325, ASTM A490, and equivalent materials, the use of preventive actions for storage, lubricant selection, and stress corrosion cracking potentialbolting and coating material selection discussed in Section 2 of RCSC (Research Council for Structural Connections) publication Specification for Structural Joints Using High-StrengthASTM A325 or A490 Bolts, will be usedfor structural bolting consisting of ASTM A325, ASTM A490, and equivalent bolts.

c) Augment existing procedures to implement periodic supplemental surface or enhanced visual examinations at intervals no greater than 10 years to detect cracking due to cyclic loading of all non-piping penetrations (hatches, electrical penetrations, etc.)

that are subject to cyclic loading but have no current licensing bases fatigue analysis and are not subject to local leak rate testing.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 27 Page 6 of 12 Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) d) Augment existing procedures to implement supplemental one-time surface or enhanced visual examinations performed by qualified personnel using methods capable of detecting cracking, comprising (a) a representative sample (two) of the stainless steel penetrations or dissimilar metal welds associated with high-temperature (temperatures above 140°F) stainless steel piping systems in frequent use on each unit; and (b) the stainless steel fuel transfer tube on each unit. These inspections are intended to confirm the absence of SCC aging effects. If SCC is identified as a result of the supplemental one-time inspections, additional inspections will be conducted in accordance with the sites corrective action process. This will include one additional penetration with dissimilar metal welds associated with greater than 140°F stainless steel piping systems for each Unit until cracking is no longer detected. Periodic inspection of subject penetrations with dissimilar metal welds for cracking will be added to the PSL ASME Section XI, Subsection IWE AMP if necessary, depending on the inspection results.

ec) Augment existing procedures to implement a one-time supplemental volumetric examinationinspection of containment vesselmetal shell surfaces for both units that samples one-foot squarerandomly selected as well as focused locations including both randomly-selected and focused areas most likely to experience degradation based on OE and/or other relevant considerations such as environmentsusceptible to loss of thickness due to corrosion from the inaccessible side if triggered by plant-specific OE identified through code inspections after the date of issuance of the first renewed license in eitherfor each unit. This sampling is conducted to demonstrate, with 95%

confidence, that 95% of the accessible portion of the containment vesselmetal shell is not experiencing greater than 10% wall loss.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 27 Page 7 of 12 SLRA Appendix A2, Section 19.4, commitment No. 32 portion of Table 19-3 beginning on page A2-99, is revised as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 32 ASME Section XI, XI.S1 Continue the existing PSL ASME Section XI, Subsection IWE AMP, No later than 6 months prior Subsection IWE (19.2.2.29) including enhancement to: to the SPEO, or no later than the last refueling a) Augment existing procedures to reference EPRI Reports outage prior to the SPEO 1015336 and 1015337 and to incorporate guidance for i.e.:

proper selectionspecify that whenever replacement of bolting is required, bolting material, and lubricants and appropriate PSL2: 10/06/2042 installation torque or tension, and use of lubricants and sealants are in accordance with the guidelines of EPRI NP-5769, Start the one-time Degradation and Failure of Bolting in Nuclear Power Plants and inspections for cracking due EPRI TR-104213, Bolted Joint Maintenance & Application Guide to SCC no earlier than 5 to prevent or minimize loss of bolting preload and cracking years prior to the SPEO of high-strength bolting. Additionally, update procedures (04/06/2038).

to explicitly prohibit the use of molybdenum disulfide and other lubricants containing sulfur on structural bolting.

b) Augment existing procedures to specify that for structural bolting consisting of ASTM A325, ASTM A490, and equivalent materials, the use of preventive actions for storage, lubricant selection, and stress corrosion cracking potentialbolting and coating material selection discussed in Section 2 of RCSC (Research Council for Structural Connections) publication Specification for Structural Joints Using High-StrengthASTM A325 or A490 Bolts, will be usedfor structural bolting consisting of ASTM A325, ASTM A490, and equivalent bolts.

c) Augment existing procedures to implement periodic supplemental surface or enhanced visual examinations at intervals no greater than 10 years to detect cracking due to cyclic loading of all non-piping penetrations (hatches, electrical penetrations, etc.) that are subject to cyclic loading but have no current licensing bases fatigue analysis and are not subject to local leak rate testing.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 27 Page 8 of 12 Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) dc) Augment existing procedures to implement supplemental one-time surface examinations (magnetic particle, dye penetrant) or enhanced visual examinations (EVT-1 or equivalent), performed by qualified personnel using methods capable of detecting cracking, comprising (a) a representative sample (tentwo) of the PSL Unit 2 electrical stainless steel penetrations or dissimilar metal welds associated with high-temperature (temperatures above 140°F) stainless steel piping systems in frequent use on each unit; and (b) the stainless steel fuel transfer tube on each unit. These inspections are intended to confirm the absence of SCC aging effects. If SCC is identified as a result of these supplemental one-time inspections, additional surface examinations (magnetic particle, dye penetrant) or enhanced visual examinations (EVT-1 or equivalent)inspections will be conducted in accordance with the sites corrective action process. This will include one additional PSL Unit 2 electrical penetration with dissimilar metal welds associated with greater than 140°F stainless steel piping systems for each Unit until cracking is no longer detected.

Periodic inspection of PSL Unit 2 electrical subject penetrations with dissimilar metal welds for cracking will be added to the PSL ASME Section XI, Subsection IWE AMP if necessary, depending on the inspection results. Frequency of inspections will be consistent with the approved IWE inspection interval.

ed) Augment existing procedures to implement a one-time supplemental volumetric examinationinspection of containment vesselmetal shell surfaces for both units that samples one-foot squarerandomly selected as well as focused locations including both randomly-selected and focused areas most likely to experience degradation based on OE and/or other relevant considerations such as environmentsusceptible to loss of thickness due to corrosion from the inaccessible side if triggered by plant-specific OE identified through code inspections after the date of issuance of the first renewed license in eitherfor each unit. This sampling is conducted to demonstrate, with 95%

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 27 Page 9 of 12 Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) confidence, that 95% of the accessible portion of the containment vesselmetal shell is not experiencing greater than 10% wall loss.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 27 Page 10 of 12 SLRA Appendix B, Section B.2.3.29, beginning with second paragraph in Program Description on page B-227, is revised as follows:

This AMP includes periodic visual, surface, and volumetric examinations, where applicable, for signs of degradation, damage, irregularities, and for coated areas distress of the underlying metal shell, and corrective actions. Implementing procedures require evaluation of relevant indications in accordance with the PSL IWE Program Plan, which mandates documenting and evaluating aAcceptability of inaccessible areas of the steel containment vessel is evaluated when conditions found in accessible areas indicate the presence of, or could result in, flaws or degradation in inaccessible areas.

If site-specific OE identified after the date of issuance of the first renewed license in eitherfor each Unit triggers the requirement to implement a one-time supplemental volumetric examination of containment vessel shell surfaces that are inaccessible from one side, then this inspection is performed for both Units by sampling randomly selected, as well as focused, one-foot square metal shell locations including both randomly-selected and focused areas most likely to experience degradation based on OE and/or other relevant considerations such as environmentsusceptible to corrosion that are inaccessible from one side.

Guidance provided in EPRI TR-107514 will be considered for sampling determinations. The trigger for this one-time examination is site-specific occurrence or recurrence of containment vesselmetal shell corrosion (base metal material loss exceeding 10 percent of nominal plate thickness) that is determined to originate from the inaccessible areasside. Any such instance would be identified through code inspections performed since 10/02/2003. Based on a review of current PSL OE, no such triggers have occurred.

SLRA Appendix B, Section B.2.3.29, continuing paragraph at top of page B-228, is revised as follows:

addressed in the Containment Liner Plate, Metal Containments, and Penetrations Fatigue Analysis TLAA for SLR (Section 4.6). Cracking due to cyclic loading of all non-piping penetrations (equipment hatch, personnel locks, electrical penetrations, etc.) that are subject to cyclic loading but have no current licensing bases fatigue analysis will be managed by the 10 CFR Part 50, Appendix J AMP (Section B.2.3.31) or by periodic supplemental surface or enhanced visual examinations incorporated into and consistent with the frequency of this AMP. This AMP will also include supplemental one-time inspections within 5 years prior to the SPEO for a representative sample of SS PSL Unit 2 electrical penetrations and dissimilar metal welds, including the fuel transfer tubes, that may be susceptible to SCC.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 27 Page 11 of 12 SLRA Appendix B, Section B.2.3.29, Enhancements Table beginning on page B-228, is revised as follows:

Element Affected Enhancement

2. Preventive Actions Procedures will be revised to specify that whenever replacementreference EPRI Reports 1015336 and 1015337 and to incorporate guidance for proper selection of bolting is required, bolting material, and lubricants and appropriate installation torque or tension, and use of lubricants and sealants are in accordance with the guidelines of EPRI NP-5769, Degradation and Failure of Bolting in Nuclear Power Plants and EPRI TR-104213, Bolted Joint Maintenance & Application Guide to prevent or minimize loss of bolting preload and cracking of high-strength bolting.

Additionally, procedures will be updated to explicitly prohibit the use of molybdenum disulfide and other lubricants containing sulfur on structural bolting.

2. Preventive Actions Procedures will be revised to specify that for structural bolting consisting of ASTM A325, ASTM A490, and equivalent materials, the use of preventive actions for storage, lubricant selection, and bolting and coating material selectionstress corrosion cracking potential discussed in Section 2 of RCSC (Research Council for Structural Connections) publication Specification for Structural Joints Using High-StrengthASTM A325 or A490 Bolts, will be usedfor structural bolting consisting of ASTM A325, ASTM A490, and equivalent bolts.
4. Detection of Aging Procedures will be revised to perform periodic supplemental Effects surface or enhanced visual examinations at intervals no greater than 10 years to detect cracking due to cyclic loading of all non-piping penetrations (hatches, electrical penetrations, etc.) that are subject to cyclic loading but have no current licensing bases fatigue analysis and are not subject to local leak rate testing.
4. Detection of Aging Procedures will be revised to implement supplemental Effects one-time surface examinations (magnetic particle, dye penetrant) or enhanced visual examinations (EVT-1 or equivalent), performed by qualified personnel using methods capable of detecting cracking, comprising (a) a representative sample (tentwo) of the SS PSL Unit 2 electrical penetrations or dissimilar metal welds associated with high-temperature (temperatures above 140°F) SS piping systems in frequent use on each unit; and (b) the SS fuel transfer tube on each unit.

These inspections are intended to confirm the absence of SCC aging effects.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 27 Page 12 of 12 Element Affected Enhancement

4. Detection of Aging Procedures will be revised to specify a one-time volumetric Effects examination of containment vesselmetal shell surfaces that are inaccessible from one side if triggered by plant-specific OE identified after the date of issuance of the first renewed license in eitherfor each unit. If triggered, this inspection will be performed for both units by sampling randomly selected, as well as focused, one-foot squaremetal shell locations including both randomly-selected and focused areas most likely to experience degradation based on OE and/or other relevant considerations such as environmentsusceptible to corrosion that are inaccessible from one side. The trigger for this one-time examination is site-specific occurrence or recurrence of containment vesselmetal shell corrosion (base metal material loss exceeding 10% of nominal plate thickness) that is determined to originate from the inaccessible areasside.

Any such instance would be identified through code inspections performed since 10/02/2003. Guidance provided in EPRI TR-107514 will be considered when establishing a sampling plan. This sampling is conducted to demonstrate, with 95% confidence, that 95% of the accessible portion of the containment vesselmetal shell is not experiencing greater than 10% wall loss.

7. Corrective Actions If SCC is identified as a result of the supplemental one-time inspections, additional surface examinations (magnetic particle, dye penetrant) or enhanced visual examinations (EVT-1 or equivalent)inspections will be conducted in accordance with the sites corrective action process. This will include one additional PSL Unit 2 electrical penetration with dissimilar metal welds associated with greater than 140°F SS piping systems for each Unit until cracking is no longer detected. Periodic inspection of subject PSL Unit 2 electrical penetrations with dissimilar metal welds for cracking will be added to the PSL ASME Section XI, Subsection IWE AMP if necessary, depending on the inspection results. Frequency of inspections will be consistent with the approved IWE inspection interval.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 28 Page 1 of 16 ASME Section XI, Subsection IWF AMP: AMR Corrections, Clarified Discussions for Exception, and Enhancement Updates Affected SLRA Sections: Table 3.5-1, Table 3.5.2-10, Table 3.5.2-16, 19.2.2.30 (Appendices A1 and A2), Table 19-3 (Appendices A1 and A2), B.2.3.30 SLRA Page Numbers: 3.5-66, 3.5-67, 3.5-116, 3.5-136, A1-34, A1-100 through A1-102, A2-33, A2-101 through A2-102, B-233 through B-235 Description of Change:

The St. Lucie Nuclear Plant (PSL) has no Class 1, 2, or 3 structural bolting in a treated borated water environment. Accordingly, Not applicable replaces Not used in the Discussion column for the associated AMR line items (i.e., 3.5-1, 085 and 3.5-1, 090) in SLRA Table 3.5-1. Additionally, one entry for structural bolting in Table 3.5.2-10 inaccurately specified 3.5-1, 090 in the Table 1 Item column; this is revised to read 3.5-1, 089the appropriate AMR line item for alignment with NUREG-2191 Item III.B5.T-25.

As stated in the Discussion column for AMR line item 3.5-1, 091 in SLRA Table 3.5-1, the PSL ASME Section XI, Subsection IWF AMP is credited with managing loss of material for ASME Class 1, 2 and 3 support members, welds, bolted connections, and support anchorage. This includes ASME class 1 structural bolting outside containment at PSL, whose entry in Table 3.5.2-16 inaccurately specified III.B1.1.TP-226 and 3.5-1, 081 in the NUREG-2191 Item and Table 1 Item columns (respectively); these are revised to read III.B1.1.T-24 and 3.5-1, 091 (respectively). Accordingly, Not used is added to text in the Discussion column for AMR line item 3.5-1, 081 in SLRA Table 3.5-1.

The UFSAR summary descriptions for the PSL ASME Section XI, Subsection IWF AMP inaccurately stated that examinations described by commitment 33(g) in SLRA Table 19-3 should be performed; this phrasing is corrected in SLRA Section 19.2.2.30 (both Appendices A1 and A2) to indicate that the subject examinations will be performed as described in the corresponding enhancement.

The PSL ASME Section XI, Subsection IWF AMP takes exception to NUREG-2191 with respect to the scope of the program, as ASME Class MC supports are excluded from the ASME Section XI, Subsection IWF AMP scope. The steel containment vessel and its integral attachments provide the support function for Class MC components at PSL; their inspection is included in the scope of the PSL ASME Section XI, Subsection IWE AMP. To clarify this justification for the exception, extraneous text is removed from SLRA Section B.2.3.30.

Additionally, aging management for vibration isolation elements was omitted from discussion of the PSL ASME Section XI, Subsection IWF AMP because there are no vibration elements requiring aging management at PSL. Text is added to the background discussion in SLRA Section B.2.3.30 to address this exclusion.

An enhancement related to storage of high strength bolting was specified for the PSL ASME Section XI, Subsection IWF AMP. To ensure consistency of preventive actions for bolting across all related PSL AMPs, enhancements in SLRA Section B.2.3.30 are revised to incorporate EPRI reports 1015336 and 1015337 (which superseded EPRI NP-5067 and TR-104213--cited in NUREG-2191 Section XI.S3) and to specify guidance discussed in

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 28 Page 2 of 16 Section 2 of Research Council for Structural Connections publication "Specification for Structural Joints Using High-Strength Bolts" regarding the selection of bolting materials, the selection of bolting lubricants, the selection of coating materials, and the appropriate installation torque or tension in addition to storage requirements. Enhancements will also ensure molybdenum disulfide and other lubricants containing sulfur will not be used for structural bolting at PSL. Changes to the enhancements identified above are also reflected in updates to the associated commitments presented in SLRA Table 19-3 (both Appendices A1 and A2).

Note that the markups for SLRA pages A1-102 and A2-102 include changes associated with Attachment 6 of this supplement.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 28 Page 3 of 16 SLRA Table 3.5-1, page 3.5-66, is revised as follows:

Table 3.5-1: Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Item Aging Aging Management Further Evaluation Component Discussion Number Effect/Mechanism Program / TLAA Recommended 3.5-1, 081 Structural bolting Loss of material due to AMP XI.S3, "ASME No Not used.

general, pitting, Section XI, Subsection Consistent with NUREG-2191, bolted crevice corrosion IWF" connections for ASME Class 1, 2, and 3 component supports are addressed with Item 3.5-1, 091.

3.5-1, 082 Structural bolting Loss of material due to AMP XI.S6, "Structures No Consistent with NUREG-2191.

general, pitting, Monitoring" The Structures Monitoring (B.2.3.33) AMP is crevice corrosion credited with managing loss of material for structural bolting exposed to outdoor air.

3.5-1, 083 Structural bolting Loss of material due to AMP XI.S7, "Inspection No Not used general, pitting, of Water-Control Structural bolting exposed to uncontrolled indoor crevice corrosion Structures Associated air and outdoor air is addressed under item with Nuclear Power 3.5-1, 080.

Plants" or the FERC/US Army Corp of Engineers 3.5-1, 084 Item 3.5-1, 084 is deleted in NUREG-2192.

3.5-1, 085 Structural bolting Loss of material due to AMP XI.M2, "Water No Not usedapplicable.

pitting, crevice Chemistry," and AMP PSL has no Class 1, 2, or 3 structural bolting in corrosion XI.S3, "ASME a treated borated water environment.

Section XI, Subsection IWF" 3.5-1, 086 Structural bolting Loss of material due to AMP XI.S3, "ASME No Consistent with NUREG-2191.

pitting, crevice Section XI, Subsection The ASME Section XI, Subsection IWF corrosion IWF" (B.2.3.30) AMP is credited with managing loss of material for bolted connections for ASME Class 1, 2 and 3 component supports.

3.5-1, 087 Structural bolting Loss of preload due to AMP XI.S3, "ASME No Consistent with NUREG-2191.

self-loosening Section XI, Subsection The ASME Section XI, Subsection IWF IWF" (B.2.3.30) AMP is credited with managing loss of preload for structural bolting for ASME Class 1, 2, and 3 supports.

3.5-1, 088 Structural bolting Loss of preload due to AMP XI.S6, "Structures No Consistent with NUREG-2191.

self-loosening Monitoring" The Structures Monitoring (B.2.3.33) AMP is credited with managing loss of preload for structural bolting.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 28 Page 4 of 16 SLRA Table 3.5-1, page 3.5-67, is revised as follows:

Table 3.5-1: Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Item Aging Aging Management Further Evaluation Component Discussion Number Effect/Mechanism Program / TLAA Recommended 3.5-1, 089 Support members; Loss of material due AMP XI.M10, "Boric No Consistent with NUREG-2191.

welds; bolted to boric acid Acid Corrosion" The Boric Acid Corrosion (B.2.3.4) AMP is connections; corrosion credited with managing loss of material for support anchorage structural steel. miscellaneous structural to building structure components, electrical enclosures, conduit, support members, welds, bolted connections, crane/lifting components, and support anchorage in the Containment, Reactor Auxiliary, and Fuel Handling Buildings due to potential for borated water leakage.

3.5-1, 090 Support members; Loss of material due AMP XI.M2, "Water No Not usedapplicable.

welds; bolted to general (steel Chemistry," and AMP PSL has no Class 1, 2, or 3 structural bolting connections; only), pitting, crevice XI.S3, "ASME in a treated borated water environment.

support anchorage corrosion Section XI, Subsection to building structure IWF" 3.5-1, 091 Support members; Loss of material due AMP XI.S3, "ASME No Consistent with NUREG-2191.

welds; bolted to general, pitting Section XI, Subsection The ASME Section XI, Subsection IWF connections; corrosion IWF" (B.2.3.30) AMP is credited with managing loss support anchorage of material for ASME Class 1, 2 and 3 support to building structure members, welds, bolted connections, and support anchorage.

3.5-1, 092 Support members; Loss of material due AMP XI.S6, "Structures No Consistent with NUREG-2191.

welds; bolted to general, pitting Monitoring" The Structures Monitoring (B.2.3.33) AMP will connections; corrosion be used to manage loss of material for support anchorage support members, welds, bolted connections, to building structure and support anchorage exposed to uncontrolled indoor air and outdoor air environments.

3.5-1, 093 Galvanized steel Loss of material due AMP XI.S6, "Structures No Consistent with NUREG-2191.

support members; to pitting, crevice Monitoring" The Structures Monitoring (B.2.3.33) AMP is welds; bolted corrosion credited with managing loss of material of connections; galvanized steel supports in an outdoor air support anchorage environment.

to building structure

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 28 Page 5 of 16 SLRA Table 3.5.2-10, page 3.5-116, is revised as follows:

Table 3.5.2-10: Reactor Auxiliary Buildings - Summary of Aging Management Evaluation Aging Effect Table Aging Management NUREG-2191 Component Type Intended Function Material Environment Requiring 1 Notes Program Item Management Item Concrete: roofs, slabs, Fire barrier Concrete Air - indoor Cracking Structures Monitoring III.A3.TP-26 3.5-1, B walls (accessible) Flood protection (reinforced) uncontrolled Loss of bond (B.2.3.33) 066 Missile barrier Air - outdoor Loss of material Pressure boundary Shelter, protection Structural support HVAC louvers Shelter, protection Steel Air - outdoor Loss of material Structures Monitoring III.A3.TP-302 3.5-1, B Structural support (B.2.3.33) 077 HVAC louvers Shelter, protection Stainless steel Air - outdoor Cracking Structures Monitoring III.B5.T-37b 3.5-1, D Structural support Loss of material (B.2.3.33) 100 HVAC louvers Shelter, protection Galvanized Air - outdoor Loss of material Structures Monitoring III.A3.TP-274 3.5-1, D Structural support steel (B.2.3.33) 082 Miscellaneous Fire barrier Steel Air - indoor Loss of material Structures Monitoring III.A3.TP-302 3.5-1, B steel (i.e., radiation Missile barrier uncontrolled (B.2.3.33) 077 shielding, missile Shelter, protection Air - outdoor barriers, hatch frame Structural support covers, etc.)

Missile protection Missile barrier Steel Air - outdoor Loss of material Structures Monitoring III.A3.TP-302 3.5-1, B doors and barriers (B.2.3.33) 077 Reinforced concrete Fire barrier Concrete block Air - indoor Cracking Masonry Walls III.A3.T-12 3.5-1, A, 3 masonry block walls Pressure boundary (reinforced) uncontrolled (B.2.3.32) 070 Shelter, protection Structural support Structural bolting Structural support Steel Air with borated Loss of material Boric Acid Corrosion III.B5.T-25 3.5-1, A water leakage (B.2.3.4) 0890 Structural bolting Structural support Galvanized Air with borated Loss of material Boric Acid Corrosion III.B5.TP-3 3.5-1, A steel water leakage (B.2.3.4) 089 Structural bolting Structural support Galvanized Air - indoor None None III.B3.TP-8 3.5-1, A steel uncontrolled 095 Structural bolting Structural support Steel Air - indoor Loss of material Structures Monitoring III.A3.TP-248 3.5-1, B uncontrolled (B.2.3.33) 080 Air - outdoor Structural bolting Structural support Steel Air - indoor Loss of preload Structures Monitoring III.A3.TP-261 3.5-1, B uncontrolled (B.2.3.33) 088 Air - outdoor

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 28 Page 6 of 16 SLRA Table 3.5.2-16, page 3.5-136, is revised as follows:

Table 3.5.2-16: Component Support Commodity - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table Component Type Material Environment Requiring Notes Function Program Item 1 Item Management Anchorage / Structural Steel Air with borated Loss of material Boric Acid Corrosion III.B5.T-25 3.5-1, C embedment support water leakage (B.2.3.4) 089 Anchorage / Structural Steel Air - indoor Loss of preload Structures Monitoring III.B3.TP-261 3.5-1, B embedment support uncontrolled (B.2.3.33) 088 Anchorage / Structural Stainless Air - indoor Cracking Structures Monitoring III.B3.T-37b 3.5-1, B embedment support steel uncontrolled Loss of material (B.2.3.33) 100 Anchorage / Structural Steel Air - outdoor Loss of material Structures Monitoring III.B3.TP-248 3.5-1, B embedment support (B.2.3.33) 080 ASME class 1 Structural Steel Air - indoor Loss of material ASME Section XI, III.B1.1.TP- 3.5-1, B, 1 structural bolting support uncontrolled Subsection IWF 2426 0981 (B.2.3.30)

ASME class 1 Structural Steel Air - indoor Loss of preload ASME Section XI, III.B1.1.TP-229 3.5-1, B, 1 structural bolting support uncontrolled Subsection IWF 087 (B.2.3.30)

ASME class 1 Structural High -strength Air Cracking ASME Section XI, III.B1.1.TP-41 3.5-1, B, 1 structural bolting support steel Subsection IWF 068 (B.2.3.30)

ASME class 1 (non- Structural Steel Air - indoor Loss of material ASME Section XI, III.B1.1.T-24 3.5-1, B, 1 RCS) pipe supports support uncontrolled Subsection IWF 091 and component Air - outdoor (B.2.3.30) supports ASME class 1 (non- Structural Steel Air with borated Loss of material Boric Acid Corrosion III.B1.1.T-25 3.5-1, A, 1 RCS) pipe supports support water leakage (B.2.3.4) 089 and component supports ASME class 2 and 3 Structural Galvanized Air - outdoor Loss of material ASME Section XI, III.B1.2.TP-235 3.5-1, B structural bolting support steel Subsection IWF 086 (B.2.3.30)

ASME class 2 and 3 Structural Steel Air - indoor Loss of preload ASME Section XI, III.B1.2.TP-229 3.5-1, B structural bolting support uncontrolled Subsection IWF 087 Air - outdoor (B.2.3.30)

ASME class 2 and 3 Structural Steel Air with borated Loss of material Boric Acid Corrosion III.B1.2.T-25 3.5-1, A structural bolting support water leakage (B.2.3.4) 089

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 28 Page 7 of 16 SLRA Appendix A1, Section 19.2.2.30, second paragraph on page A1-34, is revised as follows:

This AMP consists of periodic visual examination of piping and component supports for signs of degradation, evaluation, and corrective actions. This AMP recommends additional inspections beyond the inspections required by ASME Code Section XI, Subsection IWF. This consists of a one-time inspection of an additional 5 percent of the sample size specified in Table IWF-2500-1 for Class 1, 2, and 3 piping supports.

This one-time inspection is conducted within 5 years prior to entering the subsequent period of extended operation. For high-strength bolting in sizes greater than 1-inch nominal diameter, volumetric examination comparable to that of ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1 willshould be performed to detect cracking in addition to the VT-3 examination.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 28 Page 8 of 16 SLRA Appendix A1, Section 19.4, commitment No. 33 portion of Table 19-3 on pages A1-100, A1-101 and A1-102, is revised as follows:

Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 33 ASME Section XI, XI.S3 Continue the existing PSL ASME Section XI, Subsection IWF AMP, No later than 6 months prior to Subsection IWF (19.2.2.30) including enhancement to: the SPEO, or no later than the last refueling outage prior to a) Identify the population of ASME Class 1, 2, and 3 high-strength the SPEO i.e.:

structural bolting greater than one-inch nominal diameter within the boundaries of IWF-1300. PSL1: 09/01/2035 b) Augment existing procedures to evaluate the acceptability of Start the one-time inspection inaccessible areas (e.g., portions of supports encased in no earlier than 5 years prior to concrete, buried underground, or encapsulated by guard pipe) the SPEO (03/01/2031).

when conditions in accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas.

c) Augment existing procedures to reference EPRI Reports 1015336 and 1015337 and to incorporate guidance for proper selection of bolting material and lubricants and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting.

Additionally, update procedures to explicitly prohibit the use of molybdenum disulfide and other lubricants containing sulfur on structural bolting.

cd) Augment existing procedures to specify the use of high-strength boltpreventive actions for storage, lubricant selection, and bolting and coating material selection requirements discussed in Section 2 of RCSC (Research Council for Structural Connections) publication Specification for Structural Joints Using High-StrengthASTM A325 or A490 Bolts, for structural bolting consisting of ASTM A325, ASTM A490, and equivalent bolts.

de) Augment existing procedures to specify that bolting within the scope of this program is inspected for loss of integrity of bolted connections due to self-loosening.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 28 Page 9 of 16 Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) ef) Augment existing procedures to specify that accessible sliding surfaces are monitored for significant loss of material due to wear and accumulation of debris or dirt.

fg) Perform and document a one-time inspection of an additional 5%

of the sample populations for Class 1, 2, and 3 piping supports.

The additional supports will be selected from the remaining population of IWF piping supports and will include components that are most susceptible to age-related degradation.

gh) Augment existing procedures to specify that, for component supports with high-strength bolting greater than one-inch nominal diameter, volumetric examination comparable to that of ASME Code,Section XI, Table IWB-2500-1, Examination Category B-G-1 will be performed to detect cracking in addition to the VT-3 examination. A representative sample of bolts will be inspected during the inspection interval prior to the start of the SPEO and in each 10-year period during the SPEO. The sample will be 20%

of the population (for a material / environment combination) up to a maximum of 25 bolts.

hi) Augment existing procedures to increase or modify the component support inspection population when a component is repaired to as-new condition by including another support that is representative of the remaining population of supports that were not repaired.

ij) Augment existing procedures to specify that the following conditions are also unacceptable:

  • Loss of material due to corrosion or wear;
  • Debris, dirt, or excessive wear that could prevent or restrict sliding of the sliding surfaces as intended in the design basis of the support; and
  • Cracked or sheared bolts, including high-strength bolts, and anchors; and loss of material, cracking.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 28 Page 10 of 16 Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) k) If necessary based on related Structures Monitoring AMP evaluation results (of stainless steel cracking in the uncontrolled indoor and outdoor air at PSL), develop an augmented examination plan in accordance with IWF-2430 for a representative sample of stainless steel ASME Class 1, 2, or 3 supports as a separate part of the ASME Section XI, Subsection IWF AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 28 Page 11 of 16 SLRA Appendix A2, Section 19.2.2.30, second paragraph on page A2-33, is revised as follows:

This AMP consists of periodic visual examination of piping and component supports for signs of degradation, evaluation, and corrective actions. This AMP recommends additional inspections beyond the inspections required by ASME Code Section XI, Subsection IWF. This consists of a one-time inspection of an additional 5 percent of the sample size specified in Table IWF-2500-1 for Class 1, 2, and 3 piping supports.

This one-time inspection is conducted within 5 years prior to entering the subsequent period of extended operation. For high-strength bolting in sizes greater than 1-inch nominal diameter, volumetric examination comparable to that of ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1 willshould be performed to detect cracking in addition to the VT-3 examination.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 28 Page 12 of 16 SLRA Appendix A2, Section 19.4, commitment No. 33 portion of Table 19-3 beginning on pages A2-101 and A2-102, is revised as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 33 ASME Section XI, XI.S3 Continue the existing PSL ASME Section XI, Subsection IWF AMP, No later than 6 months prior to Subsection IWF (19.2.2.30) including enhancement to: the SPEO, or no later than the last refueling outage prior to a) Identify the population of ASME Class 1, 2, and 3 high-strength the SPEO i.e.:

structural bolting greater than one-inch nominal diameter within the boundaries of IWF-1300. PSL2: 10/06/2042 b) Augment existing procedures to evaluate the acceptability of Start the one-time inspection inaccessible areas (e.g., portions of supports encased in no earlier than 5 years prior to concrete, buried underground, or encapsulated by guard pipe) the SPEO (04/06/2038).

when conditions in accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas.

c) Augment existing procedures to reference EPRI Reports 1015336 and 1015337 and to incorporate guidance for proper selection of bolting material and lubricants and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting.

Additionally, update procedures to explicitly prohibit the use of molybdenum disulfide and other lubricants containing sulfur on structural bolting.

cd) Augment existing procedures to specify the use of high-strength boltpreventive actions for storage, lubricant selection, and bolting and coating material selection requirements discussed in Section 2 of RCSC (Research Council for Structural Connections) publication Specification for Structural Joints Using High-StrengthASTM A325 or A490 Bolts, for structural bolting consisting of ASTM A325, ASTM A490, and equivalent bolts.

de) Augment existing procedures to specify that bolting within the scope of this program is inspected for loss of integrity of bolted connections due to self-loosening.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 28 Page 13 of 16 Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) ef) Augment existing procedures to specify that accessible sliding surfaces are monitored for significant loss of material due to wear and accumulation of debris or dirt.

fg) Perform and document a one-time inspection of an additional 5%

of the sample populations for Class 1, 2, and 3 piping supports.

The additional supports will be selected from the remaining population of IWF piping supports and will include components that are most susceptible to age-related degradation.

gh) Augment existing procedures to specify that, for component supports with high-strength bolting greater than one-inch nominal diameter, volumetric examination comparable to that of ASME Code,Section XI, Table IWB-2500-1, Examination Category B-G-1 will be performed to detect cracking in addition to the VT-3 examination. A representative sample of bolts will be inspected during the inspection interval prior to the start of the SPEO and in each 10-year period during the SPEO. The sample will be 20%

of the population (for a material / environment combination) up to a maximum of 25 bolts.

hi) Augment existing procedures to increase or modify the component support inspection population when a component is repaired to as-new condition by including another support that is representative of the remaining population of supports that were not repaired.

ij) Augment existing procedures to specify that the following conditions are also unacceptable:

  • Loss of material due to corrosion or wear;
  • Debris, dirt, or excessive wear that could prevent or restrict sliding of the sliding surfaces as intended in the design basis of the support; and
  • Cracked or sheared bolts, including high-strength bolts, and anchors; and loss of material, cracking.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 28 Page 14 of 16 Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) k) If necessary based on related Structures Monitoring AMP evaluation results (of stainless steel cracking in the uncontrolled indoor and outdoor air at PSL), develop an augmented examination plan in accordance with IWF-2430 for a representative sample of stainless steel ASME Class 1, 2, or 3 supports as a separate part of the ASME Section XI, Subsection IWF AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 28 Page 15 of 16 SLRA Appendix B, Section B.2.3.30, first paragraph in Program Description on page B-233, is revised as follows:

The PSL ASME Section XI, Subsection IWF AMP is an existing AMP that consists of periodic visual examination of ASME Code Section XI Class 1, 2, and 3 supports for ASME piping and components for signs of degradation such as corrosion; cracking, deformation; misalignment of supports; missing, detached, or loosened support items; loss of integrity of welds; improper clearances of guides and stops; and improper hot or cold settings of spring supports and constant load supports. This AMP is also credited for identifying visible indications of loss of fracture toughness due to irradiation embrittlement of the reactor vessel supports. Bolting for Class 1, 2, and 3 piping and component supports is also included and inspected for corrosion, loss of integrity of bolted connections due to self-loosening, and material conditions that can affect structural integrity. There are no vibration elements requiring aging management at PSL. This AMP will use the edition and addenda of ASME Section XI required by 10 CFR 50.55a, as reviewed and approved by the NRC staff for aging management under 10 CFR 54. Alternatives to these requirements that are aging management related will be evaluated from an aging management point of view in accordance with 10 CFR 50.59 and reviewed/ approved by the NRC staff under 10 CFR 50.55a, if required, before they are implemented.

SLRA Appendix B, Section B.2.3.30, first numbered item in Exceptions to NUREG-2191 discussion on page B-234, is revised as follows:

3. Inspection of supports for Class MC components is not included in theunder ASME Section XI, Subsection IWF AMP foris not required by 10 CFR 50.55a and PSL does not include such inspections in its IWF ISI program. (Note: There are no Class MC component supports at PSL.) This is an exception to the AMP described in Section XI.S3 of NUREG-2191, whose scope of program addresses Class MC supports. Inspection of the steel containment vessel and its integral attachments (which provide the support function for Class MC components at PSL), including penetrations and fuel transfer tube components, is included in the scope of the PSL ASME Section XI, Subsection IWE (Section B.2.3.29) AMP.

Structural supports other than ASME Class 1, 2, and 3 supports and in other areas of the plant outside containment are inspected under the PSL Structures Monitoring (Section B.2.3.33) AMP. Therefore, PSL meets the intent of this NUREG-2191 program element.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 28 Page 16 of 16 SLRA Appendix B, Section B.2.3.30, element 2 portion of Enhancements Table on page B-235, is revised as follows:

Element Affected Enhancement

2. Preventive Actions Procedures will be revised to reference EPRI Reports 1015336 and 1015337 and to incorporate guidance for proper selection of bolting material and lubricants and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting. Additionally, procedures will be updated to explicitly prohibit the use of molybdenum disulfide and other lubricants containing sulfur on structural bolting.
2. Preventive Actions Procedures will be revised to specify the use of high-strength boltpreventive actions for storage, lubricant selection, and bolting and coating material selection requirements discussed in Section 2 of RCSC (Research Council for Structural Connections) publication Specification for Structural Joints Using High-StrengthASTM A325 or A490 Bolts, for structural bolting consisting of ASTM A325, ASTM A490, and equivalent bolts.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 29 Page 1 of 4 Masonry Walls AMP: Clarification to Enhancement Affected SLRA Sections: Table 19-3 (Appendices A1 and A2), B.2.3.32 SLRA Page Numbers: A1-102, A2-103, B-245 Description of Change:

An inconsistency was identified between the enhancement to Element 6 of the PSL Masonry Walls AMP and the AMP description. While the program description references NRC Inspection and Enforcement Bulletin (IEB) 80-11, Masonry Wall Design, and NRC Information Notice (IN) 87-67, Lessons Learned from Regional Inspections of Licensee Actions in Response to IE Bulletin 80-11, the enhancement only refers to IE Bulletin 80-11. The reference to IE Bulletin 80-11 in the enhancement, with the omission of reference to IN 87-67, may lead to the conclusion that the lessons learned in IN 87-67 were not appropriately considered in the design and evaluation of the PSL masonry walls.

IEB 80-11 required (a) the identification of masonry walls in close proximity to or having attachments from safety-related systems or components and (b) the evaluation of design adequacy and construction practice. IN 87-67 recommended plant-specific condition monitoring for masonry walls and administrative controls to ensure that the evaluation basis developed in response to IEB 80-11 is not invalidated by: (a) deterioration of the masonry walls (e.g., new cracks not considered in the reevaluation), (b) physical plant changes such as installation of new safety-related systems or components in close proximity to masonry walls, or (c) reclassification of systems or components from nonsafety-related to safety-related, provided appropriate evaluation is performed to account for such occurrences.

The original evaluation bases for the PSL masonry walls were established in response to IEB 80-11. The lessons learned provided in IN 87-67 were incorporated into the PSL program as industry operating experience. Therefore, the guidance of both IEB 80-11 and IN 87-67 have been considered appropriately.

For consistency, the enhancement to the PSL Masonry Walls AMP is revised to remove the reference to IEB 80-11.

Accordingly, SLRA Table 19-3 (Appendices A1 and A2) and Section B.2.3.32 are revised to remove the reference to IEB 80-11.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 29 Page 2 of 4 SLRA Appendix A1, Section 19.4, commitment No. 35 portion of Table 19-3 beginning on page A1-102, is revised as follows:

Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 35 Masonry Walls (19.2.2.32) XI.S5 Continue the existing PSL Masonry Walls AMP, including No later than 6 months prior to enhancement to: the SPEO, or no later than the last refueling outage prior to the a) Revise the implementing procedure to monitor and inspect for SPEO i.e.:

gaps between the supports and masonry walls that could potentially impact the intended function or potentially invalidate its PSL1: 09/01/2035 evaluation basis.

b) Revise the implementing procedure to include specific monitoring, measurement, and trending of 1) widths and lengths of cracks in masonry walls and mortar joints, and 2) gaps between supports and masonry walls.

c) Revise the implementing procedure to include specific guidance for the assessment of the acceptability of the widths and lengths of cracks in masonry walls and mortar joints and of gaps between supports and masonry walls, using evaluation bases established in response to IE Bulletin 80-11 to confirm that the degradation has not invalidated the original evaluation assumptions or impacted the capability to perform the intended functions.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 29 Page 3 of 4 SLRA Appendix A2, Section 19.4, commitment No. 35 portion of Table 19-3 on page A2-103, is revised as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 35 Masonry Walls (19.2.2.32) XI.S5 Continue the existing PSL Masonry Walls AMP, including No later than 6 months prior to enhancement to: the SPEO, or no later than the last refueling outage prior to the a) Revise the implementing procedure to monitor and inspect for SPEO i.e.:

gaps between the supports and masonry walls that could potentially impact the intended function or potentially invalidate its PSL2: 10/06/2042 evaluation basis.

b) Revise the implementing procedure to include specific monitoring, measurement, and trending of 1) widths and lengths of cracks in masonry walls and mortar joints, and 2) gaps between supports and masonry walls.

c) Revise the implementing procedure to include specific guidance for the assessment of the acceptability of the widths and lengths of cracks in masonry walls and mortar joints and of gaps between supports and masonry walls, using evaluation bases established in response to IE Bulletin 80-11 to confirm that the degradation has not invalidated the original evaluation assumptions or impacted the capability to perform the intended functions.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 29 Page 4 of 4 SLRA Section B.2.3.32, page B-245 is revised as follows:

Element Affected Enhancement

3. Parameters Monitored or Revise the implementing procedure to monitor and inspect for Inspected gaps between the supports and masonry walls that could potentially impact the intended function or potentially invalidate its evaluation basis.
5. Monitoring and Trending Revise the implementing procedure to include specific monitoring, measurement, and trending of 1) widths and lengths of cracks in masonry walls and mortar joints, and 2) gaps between supports and masonry walls.
6. Acceptance Criteria Revise the implementing procedure to include specific guidance for the assessment of the acceptability of the widths and lengths of cracks in masonry walls and mortar joints and of gaps between supports and masonry walls, using evaluation bases established in response to IE Bulletin 80-11 to confirm that the degradation has not invalidated the original evaluation assumptions or impacted the capability to perform the intended functions.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 1 of 26 Structures Monitoring AMP: Clarifications, Enhancements, and Commitments Affected SLRA Sections: 1.2, 2.1.4.2.1, Table 2.4-16, Table 3.3-1, Table 3.5.2-7, Table 3.5.2-16, 19.2.2.33 (Appendices A1 and A2), Table 19-3 (Appendices A1 and A2),

B.2.3.33 SLRA Page Numbers: 1-8, 2.1-14, 2.4-34, 3.3-46, 3.5-53, 3.5-107, 3.5-108, 3.5-138, 3.5-141, A1-35, A1-103, A1-104, A2-34, A2-35, A2-103, A2-104, B-247, B-248, B-249 Description of Change:

1. SLRA Section 2.1.4.2.1 lists jet impingement shields and blowout panels as examples of nonsafety-related components that are designed and installed to protect safety-related equipment from the effects of a high-energy line break (HELB). Neither jet impingement shields nor blowout panels are listed explicitly in the AMR tables in the SLRA.

SLRA Section 2.1.4.2.1 applies to NNS structures and components that are required to function in support of SLR intended functions of SR structures and components.

However, all PSL Unit 1 and 2 structures and components relied upon to protect SR components following a HELB are classified as safety-related. The PSL HELB design does include SR pipe whip restraints, jet deflector plates, and blowout panels that are in the scope of SLR. The jet deflector plates are installed at the end of the main steam and feedwater mechanical penetration guard pipes and are included as part of the Penetrations (mechanical), including bellows component type listed in SLRA Tables 2.4-1 and 3.5.2-1.

The containment cooling system for both units contain blowout panels in the ventilation ductwork. These blowout panels are included as part of the duct component type listed in SLRA Tables 2.3.2-1 and 3.2.2-1.

Accordingly, SLRA Section 2.1.4.2.1 is revised to clarify that there are no nonsafety-related HELB design features at PSL. Clarification is also being added that the jet deflector plates are evaluated as part of the mechanical penetration assemblies and the containment cooling system blowout panels are evaluated as part of the duct component types. Pipe whip restraints are addressed as part of the component support commodity in SLRA Tables 2.4-16 and 3.5.2-16.

2. SLRA Table 19-3 in Appendices A1 and A2, Commitment 36d and SLRA Section B.2.3.33 state that the existing PSL Structures Monitoring AMP will be enhanced to inspect elastomers for loss of material and loss of strength. NUREG-2191 (GALL-SLR)

Section XI.S6 specifies that elastomer components (e.g., vibration isolators, structural sealants, and seismic joint fillers) are to be monitored for cracking, loss of material, and hardening. GALL-SLR Section XI.S6 does not include loss of strength as an aging effect requiring management for elastomeric components managed by the Structures Monitoring AMP. There are no elastomer components within the scope of SLR that credit the PSL Structures Monitoring AMP to manage loss of strength. Therefore, an enhancement is not needed for the inspection of elastomers for loss of strength.

Conversely, the existing PSL Structures Monitoring AMP does not list cracking as an aging mechanism that can cause loss of seal in elastomers, therefore an enhancement to the existing program is necessary to include cracking.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 2 of 26 Accordingly, SLRA Table 19-3 in Appendices A1 and A2 and Section B.2.3.33 are revised to remove loss of strength and add cracking as an aging effect managed by the PSL Structures Monitoring AMP.

3. An inconsistency was identified between SLRA Table 2.4-16 and SLRA Table 3.5-1.

Table 2.4-16 lists Vibration isolation elements as a component type in the component support commodity. Table 3.5-1, Item Number 3.5-1, 094 indicates that there are no vibration isolation elements requiring aging management at PSL. SLRA Table 3.5-1 is correct.

Accordingly, SLRA Table 2.4-16 is revised to remove vibration isolation elements.

4. NUREG-2191 Section XI.S6, Structures Monitoring AMP, states that bolting within the scope of the program should be monitored for loss of material, loose bolts, missing or loose nuts, and other conditions indicative of loss of preload. The existing PSL Structures Monitoring AMP inspects (1) structural steel, electrical panels, and miscellaneous steel for loose or missing anchors/fasteners, deformation or degradation of fasteners, and anchor bolt deficiencies, (2) equipment mounting for missing/loose nuts or bolts, nuts not fully engaged (not meeting minimum thread engagement), and degraded bolts or nuts (cracked, bent, deformed, etc.), and (3) tanks for loose, missing, or damaged anchor bolts. If evidence of the applicable aging effects is identified on bolting during inspections, the condition is evaluated by the responsible-in-charge-engineer, who is qualified in accordance with ACI 349.3R. In order to ensure that the PSL Structures Monitoring AMP fully meets the NUREG-2191 Section XI.S6 guidance, the program will be enhanced to specify that all bolting is monitored for loss of material, loose bolts, missing or loose nuts, and other conditions indicative of loss of preload.

Accordingly, SLRA Table 19-3 in Appendices A1 and A2 and Section B.2.3.33 are revised to include a commitment and enhancement that will ensure that all bolting within the scope of the Structures Monitoring AMP will be monitored for loss of material, loose bolts, missing or loose nuts, and other conditions indicative of loss of preload.

5. Additional details are provided to clarify the plant-specific actions that will be implemented within the Structures Monitoring AMP to ensure and demonstrate that the AMP will adequately manage degradation for inaccessible areas exposed to an aggressive water/soil environment. The PSL Structures Monitoring AMP currently includes an enhancement to manage degradation for inaccessible areas exposed to aggressive groundwater/soil and water-flowing. This enhancement is replaced with a site-specific enhancement to the pertinent elements for management of inaccessible concrete (scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria). The site-specific enhancement includes the following:
a. A baseline inspection of inaccessible concrete will be conducted prior to the SPEO.
i. The baseline inspection locations will consider site-specific OE. OE considered will include known degradation due to chlorides in ambient air and the potential for further degradation due to the aggressive groundwater as well as whether leaching and carbonation is occurring in the water-flowing environment.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 3 of 26 ii. The baseline inspection will include excavation, visual inspection, and physical inspection of the inaccessible concrete through pH analysis and a chloride concentration test at a location close to the coastline/intake and a location in the main plant area for comparison. The baseline inspection of these two locations is a representative sample since the baseline sample is 20 percent of the population of structures most likely to experience degradation associated with groundwater.

b. A baseline evaluation will be performed prior to the SPEO.
i. The baseline evaluation will consider the baseline inspection results to determine the additional actions (if any) that are warranted. Any observed degradation will be entered into the corrective action program.

The baseline inspection results will be evaluated based on acceptance criteria provided in ACI 349.3R and will also consider the correlation between the chloride ion concentration necessary to induce corrosion and alkalinity level of the concrete (Reference 1). The highly alkaline environment of concrete protects the steel reinforcement from corrosion (Reference 2). Additional actions will be based on the baseline inspection results and corrective action program and may include: enhanced inspection techniques and/or frequency, destructive testing, and focused inspections of representative accessible concrete (leading indicator) or below grade, inaccessible concrete structural elements exposed to aggressive groundwater/soil (or to leaching and carbonation in water-flowing if determined to impact intended function).

ii. The baseline inspection and evaluation results will set the subsequent inspection requirements and inspection intervals (not to exceed 5 years) for the SPEO. The minimum inspection interval of every 5 years will be reduced if the observed degradation could adversely affect structural function prior to the next scheduled inspection. The subsequent inspection sample size will include the two baseline inspection locations and may be expanded based on any corrective action program results (as applicable to degradation) to include additional locations. Additional locations may be based on the aging effect (cracking, loss of material (spalling, scaling), increase in porosity and permeability, loss of strength, loss of bond), location (close to the coastline/intake or main plant area),

existing technical information, structure design, material of construction (concrete), environment, operating conditions, and OE. For example, if degradation outside of the acceptance criteria is identified at the coastline/intake location, an additional location at the coastline should be inspected.

c. Periodic inspections (focused) at a frequency determined in the baseline evaluation (not to exceed 5 years) will be performed.
i. Opportunistic inspections may be used to replace or supplement the focused inspections if the inspection location is excavated for other reasons during the periodic inspection interval.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 4 of 26 ii. The locations inspected during the baseline inspection will continue to be monitored during the periodic inspections along with any other locations established after the baseline inspection.

d. Periodic evaluation updates will be performed (not to exceed 5 years) throughout the SPEO.
i. Updates will be based on OE and focused periodic inspection results (and/or opportunistic inspection results, if applicable) during the interval.

ii. The periodic evaluation results will update subsequent inspection requirements and inspection intervals (not to exceed 5 years) for the SPEO as required.

Accordingly, SLRA Sections 19.2.2.33 in Appendices A1 and A2 and B.2.3.33, and Table 19-3 in Appendices A1 and A2 are revised to include this additional detail.

6. SLRA Section 1.2 is revised to document that the outage interval for PSL Unit 1 and PSL Unit 2 is 18 months.
7. An inconsistency was identified in SLRA Table 3.3-1. The discussion for Item Number 3.3-1, 111 states that that this item number is used for structural items in SLRA Section 3.5. Item Number 3.3-1, 111 is not used in any of the AMR tables in the SLRA.

Instead, Item Number 3.5-1, 077 is used for loss of material of steel structural steel exposed to air - indoor uncontrolled.

Item Number 3.3-1, 111 is listed in NUREG-2191 Section VII.A1 in reference to structures and components used for new fuel storage, including steel new fuel storage racks. The new fuel storage racks at PSL are stainless steel, so this line item does not apply. Furthermore, consistent with the first license renewal application, the new fuel storage racks do not perform or support any license renewal system intended function that satisfy the scoping criteria of 10 CFR 54.4 and therefore are not within the scope of license renewal.

Accordingly, SLRA Table 3.3-1 is revised to reflect that 3.3-1, 111 is not used.

8. The Water Chemistry and One-Time Inspection AMPs are credited to manage loss of preload of stainless steel bolting exposed to treated borated water in SLRA Table 3.5.2-7. The bolting in question is located in the fuel transfer canal, which is normally dry but is filled with borated water during refueling operations. The Water Chemistry and One-Time Inspection AMPs do not manage the loss of preload aging effect. Since the fuel transfer canal is normally dry, the Structures Monitoring AMP is credited instead to manage the loss of preload aging effect for these bolts.

Accordingly, SLRA Table 3.5.2-7 is revised to change the aging management program for the bolting in question to the Structures Monitoring AMP.

9. Several NUREG-2191 Items were identified that are not referenced in the SLRA. The NUREG-2191 Items in question all align with one of the following two SRP Items; 3.5-1, 055 or 3.5-1, 093. Both of these SRP Items are referenced only in the component support commodity group in SLRA Table 3.5.2-16.

Since all of the NUREG-2191 Item numbers associated with SRP Item 3.5-1, 055 in NUREG-2191 Section III are identical for the Structure and/or Component, Material,

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 5 of 26 Environment, Aging Effect/Mechanism, and Aging Management Program column headings, listing separate lines for each NUREG-2191 Item number is not necessary.

Similarly, both of the NUREG-2191 Item numbers associated with SRP Item 3.5-1, 093 are identical for Structure and/or Component, Material, Environment, Aging Effect/Mechanism, and Aging Management Program column headings.

Accordingly, SLRA Table 3.5.2-16 is revised to add a plant specific note to clarify the structures and components that are included in the component support commodity for the line in question.

10. SLRA Section 19.2.2.33 in Appendices A1 and A2 are revised to clarify that the PSL Structures Monitoring AMP consists primarily of periodic visual inspection and condition monitoring. This is consistent with the description of the AMP in SLRA Section B.2.3.33.
11. An inconsistency was identified between SLRA Tables 3.5-1 and 3.5.2-1. Item Number 3.5-1, 019 in Table 3.5-1 indicates in the Discussion column that the item is not applicable. However, this Item Number is referenced in Table 3.5.2-1 on page 3.5-84 of the SLRA. The reference in Table 3.5.2-1 is correct. Furthermore, the component description in Table 3.5-1 for Item Number 3.5-1, 019 does not match the component description for ID 019 in Table 3.5-1 of NUREG-2192.

Accordingly, SLRA Table 3.5-1 is revised to update the component description and discussion columns.

Note that the markups for SLRA pages A1-103, A1-104, A2-103 and A2-104 include changes associated with Attachment 6 of this supplement.

References:

1. NUREG/CR-5466 (NISTIR 89-4086), Service Life of Concrete, Published November 1989 (ADAMS Accession No. ML061430380)
2. ACI 222.3R, Design and Construction Practices to Mitigate Corrosion of Reinforcement in Concrete Structures

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 6 of 26 SLRA Section 1.2, page 1-8, is revised as follows:

1.2 PLANT DESCRIPTION PSL is a steam electric generating facility situated on the East Coast of Florida, approximately seven miles southeast of the city of Fort Pierce, Florida. The plant consists of two nuclear power Units designated as PSL Unit 1 and PSL Unit 2.

The PSL Units 1 and 2 reactors are Combustion Engineering designed pressurized light-water moderated and cooled systems. PSL Units 1 and 2 were each originally licensed and operated at 2560 megawatts thermal (MWt). Commercial operation for Unit 1 began on March 01, 1976, and for Unit 2 on April 06, 1983. Both Units' operating licenses were subsequently amended to allow operation at the stretch power limit of 2700 MWt (Unit 1 Amendment #48 dated November 23, 1981 (Reference ML013530273); Unit 2 Amendment #9 dated March 1, 1985 (Reference ML013600080).

In 2012, an extended power uprate (EPU) increased the reactor core thermal power to 3020 MWt for each unit (References ML103560419, ML110730116, and ML12124A224). For each unit, both original steam generators were removed and replacement steam generators designed and manufactured by B&W (Unit 1) and AREVA (Unit 2) were installed. Per the Unit 1 and Unit 2 UFSAR, each steam and power conversion system, including its turbine generator, is designed to permit generation of a gross electrical output of approximately 1026 megawatts-electric (MWe) for Unit 1 and 1045 MWe for Unit 2.

PSL Units 1 and 2 currently operate on an 18-month fuel cycle and therefore have scheduled refueling outages every 18 months.

The major structures for PSL are two reactor containment buildings, two reactor auxiliary buildings, two turbine buildings, and two fuel handling buildings; it is one set of buildings for each unit. Each containment is a steel containment vessel with cylindrical shell surrounded by a reinforced concrete shield building.

FPL also operates an independent spent fuel storage installation (ISFSI) at the site. The ISFSI is operated under a general license issued pursuant to the provisions of 10 CFR 72 (Reference 1.6.11). Therefore, the ISFSI is not in-scope of subsequent license renewal.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 7 of 26 SLRA Section 2.1.4.2.1, page 2.1-14, is revised as follows:

system that could prevent the accomplishment of a SR function, are considered to meet the criteria of 10 CFR 54.4(a)(2) and within the scope of SLR. Additional details for the cranes included in the scope of SLR can be found in Section 2.4.18.

High-Energy Line Break (HELB)

For PSL Unit 1, the definition of high energy piping systems are systems in which operating temperatures exceed 200°F and operating pressures exceed 275 psig.

Piping systems 1 nominal pipe size and smaller are excluded from HELB review.

For PSL Unit 2, the definition of high energy piping systems are described as high energy (i.e., fluid systems which exceed 200°F or 275 psig during normal operating conditions) and moderate energy (i.e., fluid systems which are 200°F or less, and 275 psig or less during normal operating conditions). High energy or moderate energy piping 1 nominal pipe size and smaller are excluded from HELB review.

All HELB design features at PSL are safety-related. Pipe whip restraints are included in the Component Support Commodity in Tables 2.4-16 and 3.5.2-16.

Jet deflector plates installed at the end of the main steam and feedwater mechanical penetration guard pipes are included as part of the Penetrations (mechanical), including bellows component type listed in Tables 2.4-1 and 3.5.2-1. Blowout panels in the containment cooling system are included as part of the duct component type listed in Tables 2.3.2-1 and 3.2.2-1.NNS whip restraints, jet impingement shields, blowout panels, etc. that are designed and installed to protect SR equipment from the effects of a HELB are within the scope of SLR per 10 CFR 54.4(a)(2). Additional details for the HELB structural components included in the scope of SLR can be found in Section 2.4.

Missiles Missiles can be generated from internal events such as failure of rotating equipment or external events. Inherent NNS features that protect SR equipment from internal and external missiles are within the scope of SLR per 10 CFR 54.4(a)(2). Additional details for the structural components that provide protection from missiles included in the scope of SLR can be found in Section 2.4.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 8 of 26 SLRA Table 2.4-16, page 2.4-34, is revised as follows:

Table 2.4-16 Component Support Commodity Subject to Aging Management Review Component Type Component Intended Function(s)

Anchorage / Embedment Structural support ASME class 1 structural bolting Structural support ASME class 1 (non-RCS) pipe supports Structural support and component supports ASME class 2 and 3 structural bolting Structural support ASME class 2 and class 3 pipe supports Structural support and component supports Building concrete at locations of Structural support expansion and grouted anchors; grout pads for support base plates Component supports (NNS) Structural support Conduits and cable trays Structural support Shelter, protection Conduits (non-metallic) Structural support Shelter, protection Constant and variable load spring Structural support hangers; guides; stops Electrical and instrument panel and Structural support enclosure supports Electrical and instrument panels and Structural support enclosures Shelter, protection Non-metallic thermal insulation Insulate (thermal)

Pipe whip restraints Pipe whip restraint Sliding support surfaces (Unit 1 CCW Structural support heat exchangers)

Sliding support surfaces (Unit 2 CCW Structural support heat exchangers)

Structural bolting Structural support Vibration isolation elements Structural support

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 9 of 26 SLRA Table 3.3-1, page 3.3-46, is revised as follows:

Table 3.3-1: Summary of Aging Management Evaluations for the Auxiliary Systems Item Component Aging Effect/Mechanism Aging Management Further Evaluation Discussion Number Program (AMP)/TLAA Recommended 3.3-1, 107 Stainless steel, nickel Loss of material due to AMP XI.M41, "Buried No Consistent with NUREG-2191. The Buried and alloy piping, piping pitting, crevice corrosion, MIC and Underground Piping Underground Piping and Tanks AMP is used to components exposed (soil only) and Tanks" manage loss of material in stainless steel piping, to soil, concrete piping components exposed to soil or concrete 3.3-1, 108 Titanium, super Loss of material due to AMP XI.M41, "Buried No Consistent with NUREG-2191. The Buried and austenitic, copper general (copper alloy only), and Underground Piping Underground Piping and Tanks AMP is used to alloy, stainless steel, pitting, crevice corrosion, MIC and Tanks" manage loss of material in stainless steel closure nickel alloy piping, (super austenitic, copper bolting exposed to soil.

piping components, alloy, stainless steel, nickel tanks, closure bolting alloy; soil environment only) exposed to soil, concrete, underground 3.3-1, 109 Steel piping, piping Loss of material due to AMP XI.M41, "Buried No Consistent with NUREG-2191. The Buried and components, closure general, pitting, crevice and Underground Piping Underground Piping and Tanks AMP is used to bolting exposed to corrosion, MIC (soil only) and Tanks" manage loss of material in steel piping, piping soil, concrete, components, and closure bolting exposed to soil underground or concrete that are subject to wetting.

3.3-1, 110 This line item only applies to BWRs.

3.3-1, 111 Steel structural steel Loss of material due to AMP XI.S6, No Not used.Consistent with NUREG-2191.

exposed to air - general, pitting, crevice "Structures Monitoring" Item Number 3.5-1, 077 is used for loss of indoor uncontrolled corrosion material of steel structural steel exposed to air - indoor uncontrolled. The Structures Monitoring (B.2.3.33) AMP is used to manage loss of material in structural steel exposed to uncontrolled indoor air. This line item is used to evaluate structural items in Section 3.5.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 10 of 26 SLRA Table 3.5-1, page 3.5-53, is revised as follows:

Table 3.5-1: Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Item Aging Aging Management Further Evaluation Component Discussion Number Effect/Mechanism Program / TLAA Recommended 3.5-1, 019 Concrete Cracking due to AMP XI.S2, "ASME No Consistent with NUREG-2191.

(accessible expansion from Section XI, Subsection The Structures Monitoring (B.2.3.33) AMP areas): dome; reaction with IWL" and/or AMP manages cracking of accessible Shield wall; aggregates XI.S6, "Structures Building foundation/base mat exposed to basemat; ring Monitoring" an outdoor air environment.

girders; Not applicable.

buttresses, PSL does not have a reinforced concrete containment; containment.

concrete fill-in The Structures Monitoring (B.2.3.33) AMP annulus manages cracking of accessible Shield Reinforced Building concrete exposed to an outdoor concrete environment as addressed for item 3.5-1, 054.

containment structure (accessible)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 11 of 26 SLRA Table 3.5.2-7, page 3.5-107, is revised as follows:

Table 3.5.2-7: Fuel Handling Buildings - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Pool liner plates Pressure Stainless steel Treated borated Cracking Water Chemistry III.A5.T-14 3.5-1, A boundary water Loss of material (B.2.3.2) and 078 monitoring of the pool water level and leakage from the leak chase channels Spent fuel pool storage Structural Stainless steel Air - indoor Cracking Structures Monitoring III.B5.T-37b 3.5-1, D brackets support uncontrolled Loss of material (B.2.3.33) 100 Spent fuel pool storage Structural Stainless steel Treated borated Loss of material One-Time Inspection VII.A2.A-99 3.3-1, C brackets support water (B.2.3.20) 125 Water Chemistry (B.2.3.2)

Spent fuel storage Shelter, Stainless steel Treated borated Loss of material One-Time Inspection VII.A2.A-99 3.3-1, A racks protection water (B.2.3.20) 125 Structural Water Chemistry support (B.2.3.2)

Structural bolting Structural Steel Air with borated Loss of material Boric Acid Corrosion III.B5.T-25 3.5-1, A support water leakage (B.2.3.4) 089 Structural bolting Structural Galvanized steel Air with borated Loss of material Boric Acid Corrosion III.B5.TP-3 3.5-1, A support water leakage (B.2.3.4) 089 Structural bolting Structural Galvanized steel Air - indoor None None III.B3.TP-8 3.5-1, A support uncontrolled 095 Structural bolting Structural Galvanized steel Air - outdoor Loss of material Structures Monitoring III.A5.TP-274 3.5-1, B support (B.2.3.33) 082 Structural bolting/ Structural Steel Air - indoor Loss of material Structures Monitoring III.A5.TP-248 3.5-1, B connections support uncontrolled (B.2.3.33) 080 Air - outdoor Structural bolting/ Structural Steel Air - indoor Loss of preload Structures Monitoring III.A5.TP-261 3.5-1, B connections support uncontrolled (B.2.3.33) 088 Air - outdoor Structural bolting/ Structural Stainless steel Treated borated Loss of preload Structures Monitoring III.A5.TP-261 3.5-1, BE, 5 connections support water (B.2.3.33)One-Time 088 Inspection (B.2.3.20)

Water Chemistry (B.2.3.2)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 12 of 26 SLRA Table 3.5.2-7, page 3.5-108, is revised as follows:

Table 3.5.2-7: Fuel Handling Buildings - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Structural steel Structural Steel Air with borated Loss of material Boric Acid Corrosion III.B1.2.T-25 3.5-1, C framing (beams, support water leakage (B.2.3.4) 089 columns, connections, etc.)

Structural steel Structural Steel Air - indoor Loss of material Structures Monitoring III.A5.TP-302 3.5-1, B framing (beams, support uncontrolled (B.2.3.33) 077 columns, connections, etc.)

Weatherproofing Shelter, Caulking and Air - outdoor Loss of sealing Structures Monitoring III.A6.TP-7 3.5-1, B protection sealants (B.2.3.33) 072 General Notes A. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

B. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

C. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

D. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

E. Consistent with NUREG-2191 material, environment, and aging effect but a different AMP is credited or NUREG-2191 identifies a plant-specific AMP.

Plant Specific Notes

1. Whereas the NUREG-2191/2192 item calls for a plant-specific AMP, PSL credits an existing AMP based on SLR-ISG-2021-03-STRUCTURE, Updated Aging Management Criteria for Structures Portions of Subsequent License Renewal Guidance.
2. Groundwater is considered to be water-flowing.
3. Conservatively, spent fuel pool leakage is identified as water-flowing.
4. There are no leak chase channels to monitor for the fuel pool gates.
5. Structural bolting/connection associated with the spent fuel pool will be managed under the Water Chemistry and One-Time Inspection AMP's.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 13 of 26 SLRA Table 3.5.2-16, page 3.5-138, is revised as follows:

Table 3.5.2-16: Component Support Commodity - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Component supports Structural Steel Air - indoor Loss of material Structures Monitoring III.B2.TP-43 3.5-1, B (nonsafety-related) support uncontrolled (B.2.3.33) 092 Air - outdoor Component supports Structural Galvanized Air - outdoor Loss of material Structures Monitoring III.B2.TP-6 3.5-1, B, 4 (nonsafety-related) support steel (B.2.3.33) 093 Conduits and cable trays Shelter, Steel Air with borated Loss of material Boric Acid Corrosion III.B2.T-25 3.5-1, C protection water leakage (B.2.3.4) 089 Structural support Conduits and cable trays Shelter, Galvanized Air with borated Loss of material Boric Acid Corrosion III.B2.TP-3 3.5-1, C protection steel water leakage (B.2.3.4) 089 Structural support Conduits and cable trays Shelter, Galvanized Air - indoor None None III.B2.TP-8 3.5-1, A protection steel uncontrolled 095 Structural support Conduits and cable trays Shelter, Aluminum Air - indoor Cracking Structures Monitoring III.B2.T-37b 3.5-1, D protection uncontrolled Loss of material (B.2.3.33) 100 Structural support Conduits and cable trays Shelter, Stainless steel Air - indoor Cracking Structures Monitoring III.B2.T-37b 3.5-1, D protection uncontrolled Loss of material (B.2.3.33) 100 Structural Air - outdoor support Conduits and cable trays Shelter, Steel Air - indoor Loss of material Structures Monitoring III.B2.TP-43 3.5-1, D protection uncontrolled (B.2.3.33) 092 Structural support Conduits and cable trays Shelter, Steel; Air - outdoor Loss of material Structures Monitoring III.B2.TP-274 3.5-1, D protection galvanized (B.2.3.33) 082 Structural steel support

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 14 of 26 SLRA Table 3.5.2-16, page 3.5-141, is revised as follows:

Table 3.5.2-16: Component Support Commodity - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Sliding support surfaces Structural Graphite Air - indoor Loss of mechanical ASME Section XI, III.B1.2.TP-45 3.5-1, B, 2 (Unit 2 CCW heat support lubricated steel uncontrolled function Subsection IWF (B.2.3.30) 075 exchangers)

Structural bolting Structural Steel Air - indoor Loss of material Structures Monitoring III.B5.TP-248 3.5-1, B, 3 support uncontrolled (B.2.3.33) 080 Air - outdoor Structural bolting Structural Steel Air Loss of preload Structures Monitoring III.B5.TP-261 3.5-1, B, 3 support (B.2.3.33) 088 Structural bolting Structural Galvanized Air - outdoor Loss of material Structures Monitoring III.B5.TP-274 3.5-1, B, 3 support steel (B.2.3.33) 082 General Notes A. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

B. Consistent with component, material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

C. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

D. Component is different, but consistent with material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

Plant Specific Notes

1. RCS Class 1 supports (inside containment) are addressed in Table 3.5.2-1.
2. Sliding support surfaces for the Unit 1 and Unit 2 CCW heat exchangers will be managed by the ASME Section XI, Subsection IWF AMP.
3. Structural bolting for non-ASME and nonsafety-related supports will be managed under the Structure Monitoring AMP.
4. Includes all galvanized steel support members, welds, bolted connections, and support anchorages within the scope of the component support commodity (as defined in Section 2.4.16) exposed to air-outdoor.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 15 of 26 SLRA Appendix A1, Section 19.2.2.33, page A1-35, is revised as follows:

19.2.2.33 Structures Monitoring The PSL Structures Monitoring AMP is an existing AMP that consists primarily of periodic visual inspection and monitoring of the condition of concrete and steel structures, structural components, components supports, and structural commodities to ensure that aging degradation (such as those described in ACI 349.3R, ACI 201.1R, SEI/ASCE 11, and other documents) will be detected, the extent of degradation determined and evaluated, and corrective actions taken prior to loss of intended functions. Structures are monitored on an interval not to exceed 5 years.

Inspections also include seismic joint fillers, elastomeric materials; steel edge supports and bracings associated with masonry walls; and opportunistic inspections for the condition of below grade concrete. Quantitative results (measurements) and qualitative information from periodic inspections are trended with sufficient detail, such as photographs and surveys for the type, severity, extent, and progression of degradation, to ensure that corrective actions can be taken prior to a loss of intended function. The acceptance criteria are derived from applicable consensus codes and standards. For concrete structures, the program includes personnel qualifications and quantitative evaluation criteria of ACI 349.3R. Due to aggressive groundwater chemistry (Chlorides > 500 parts per million), the AMP includes a site-specific enhancement to conduct a baseline visual inspection, pH analysis, a chloride concentration test, and evaluation to address the potential degradation of concrete due to exposure of aggressive chemical attack in groundwater/soil or leaching and carbonation in the water-flowing environment. The baseline evaluation will consider site-specific OE and the baseline inspection results and will determine the additional actions (if any) that are warranted. Periodic inspections (focused) and evaluation updates (not to exceed 5 years) will be performed throughout the SPEO to ensure aging of inaccessible concrete is adequately managed. Opportunistic inspections may be used to replace or supplement the focused inspections if the inspection location is excavated for other reasons during the periodic inspection interval.will be enhanced prior to the SPEO to include site-specific evaluations, destructive testing, if warranted, and/or focused inspections of representative accessible (leading indicator) or below-grade inaccessible concrete structural elements exposed to aggressive groundwater/soil, on an interval not to exceed 5 years.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 16 of 26 SLRA Appendix A1, Section 19.4, commitment No. 36 portion of Table 19-3 on pages A1-103 and A1-104, is revised as follows:

Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management Program NUREG-2191 Commitment Implementation Schedule or Activity (Section) Section 36 Structures Monitoring XI.S6 Continue the existing PSL Structures Monitoring AMP, including No later than 6 months prior to the (19.2.2.33) enhancement to: SPEO, or no later than the last refueling outage prior to the SPEO a) Monitor and inspect steel edge supports on masonry walls. i.e.:

b) Specify the use of high-strength bolt storage requirements PSL1: 09/01/2035 discussed in Section 2 of the Research Council for Structural Connections publication, Specification for Structural Joints Using High-Strength Bolts, for structural bolting consisting of ASTM A325, ASTM A490, and equivalent bolts.

c) Inspect concrete structures for increase in porosity and permeability, loss of strength, and reduction in concrete anchor capacity due to local concrete degradation.

d) Inspect elastomers for loss of material and crackingloss of strength.

e) Inspect stainless steel and aluminum components for pitting and crevice corrosion, and evidence of cracking due to SCC.

f) Include monitoring and trending of leakage volumes and chemistry for signs of concrete or steel reinforcement degradation if active through-wall leakage or groundwater infiltration is identified.

g) Specify that all bolting is monitored for loss of material, loose bolts, missing or loose nuts, and other conditions indicative of loss of preload.

hg) Include tactile inspection in addition to visual inspection of elastomeric elements to detect hardening.

ih) Include evidence of water in-leakage as a finding requiring further evaluation. This may include engineering evaluation, more frequent inspections, or destructive testing of affected concrete to validate existing concrete properties, including concrete pH

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 17 of 26 Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management Program NUREG-2191 Commitment Implementation Schedule or Activity (Section) Section levels. When leakage volumes allow, assessment may include analysis of the leakage pH, along with mineral, chloride, sulfate, and iron content in the water.

ji) Develop a new implementing procedure or attachment to an existing implementing procedure to address aging management of inaccessible areas exposed to groundwater/soil and water-flowing. The document will include guidance to conduct a baseline visual inspection, pH analysis, and a chloride concentration test prior to the SPEO at a location close to the coastline/intake and a location in the main plant area for comparison. The baseline inspection results will be used to conduct a baseline evaluation that will determine the additional actions (if any) that are warranted.

Additionally, the baseline evaluation results will set the subsequent inspection requirements and inspection intervals (not to exceed 5 years). Periodic inspections (focused) and evaluation updates (not to exceed 5 years) will be performed throughout the SPEO to ensure aging of inaccessible concrete is adequately managed. Opportunistic inspections may be used to replace or supplement the focused inspections if the inspection location is excavated for other reasons during the periodic inspection interval.Address the aggressive groundwater/soil environment to account for the extent of the degradation experienced. Specific requirements include evaluations, destructive testing, and/or focused inspections of representative accessible (leading indicator) or below-grade, inaccessible concrete structural elements exposed to aggressive groundwater/soil, on an interval not to exceed 5 years.

kj) Require inspections of the Condensate Storage Tank (CST) and Auxiliary Feedwater (AFW) Structures and Piping Inspections in the Trenches every third refueling outage, which will ensure that these inspections are performed at least once per 5 years.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 18 of 26 Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management Program NUREG-2191 Commitment Implementation Schedule or Activity (Section) Section il) Include stainless steel ASME Class 1, 2, or 3 support members, welds, bolted connections, or anchorage in the engineering evaluation of acceptance criteria, expansion criteria, and examination frequency if cracking due to SCC in the uncontrolled indoor and outdoor air at PSL is detected for stainless steel mechanical or non-ASME structural components.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 19 of 26 SLRA Appendix A2, Section 19.2.2.33, page A2-34, is revised as follows:

19.2.2.33 Structures Monitoring The PSL Structures Monitoring AMP is an existing AMP that consists primarily of periodic visual inspection and monitoring of the condition of concrete and steel structures, structural components, components supports, and structural commodities to ensure that aging degradation (such as those described in ACI 349.3R, ACI 201.1R, SEI/ASCE 11, and other documents) will be detected, the extent of degradation determined and evaluated, and corrective actions taken prior to loss of intended functions. Structures are monitored on an interval not to exceed 5 years.

Inspections also include seismic joint fillers, elastomeric materials; steel edge supports and bracings associated with masonry walls; and opportunistic inspections for the condition of below grade concrete. Quantitative results (measurements) and qualitative information from periodic inspections are trended with sufficient detail, such as photographs and surveys for the type, severity, extent, and progression of

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 20 of 26 SLRA Appendix A2, Section 19.2.2.33, page A2-35, is revised as follows:

degradation, to ensure that corrective actions can be taken prior to a loss of intended function. The acceptance criteria are derived from applicable consensus codes and standards. For concrete structures, the program includes personnel qualifications and quantitative evaluation criteria of ACI 349.3R. Due to aggressive groundwater chemistry (Chlorides > 500 parts per million), the AMP includes a site-specific enhancement to conduct a baseline visual inspection, pH analysis, a chloride concentration test, and evaluation to address the potential degradation of concrete due to exposure of aggressive chemical attack in groundwater/soil or leaching and carbonation in the water-flowing environment. The baseline evaluation will consider site-specific OE and the baseline inspection results and will determine the additional actions (if any) that are warranted. Periodic inspections (focused) and evaluation updates (not to exceed 5 years) will be performed throughout the SPEO to ensure aging of inaccessible concrete is adequately managed. Opportunistic inspections may be used to replace or supplement the focused inspections if the inspection location is excavated for other reasons during the periodic inspection interval.will be enhanced prior to the SPEO to include site specific evaluations, destructive testing, if warranted, and/or focused inspections of representative accessible (leading indicator) or below grade inaccessible concrete structural elements exposed to aggressive groundwater/soil, on an interval not to exceed 5 years.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 21 of 26 SLRA Appendix A2, Section 19.4, commitment No. 36 portion of Table 19-3 on pages A2-103 and A2-104, is revised as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Program or Activity Section Schedule (Section) 36 Structures Monitoring XI.S6 Continue the existing PSL Structures Monitoring AMP, including enhancement to: No later than 6 (19.2.2.33) months prior to the a) Monitor and inspect steel edge supports on masonry walls.

SPEO, or no later b) Specify the use of high-strength bolt storage requirements discussed in Section 2 of than the last the Research Council for Structural Connections publication, Specification for refueling outage Structural Joints Using High-Strength Bolts, for structural bolting consisting of prior to the SPEO ASTM A325, ASTM A490, and equivalent bolts. i.e.:

c) Inspect concrete structures for increase in porosity and permeability, loss of PSL2: 10/06/2042 strength, and reduction in concrete anchor capacity due to local concrete degradation.

d) Inspect elastomers for loss of material and crackingloss of strength.

e) Inspect stainless steel and aluminum components for pitting and crevice corrosion, and evidence of cracking due to SCC.

f) Include monitoring and trending of leakage volumes and chemistry for signs of concrete or steel reinforcement degradation if active through-wall leakage or groundwater infiltration is identified.

g) Specify that all bolting is monitored for loss of material, loose bolts, missing or loose nuts, and other conditions indicative of loss of preload.

hg) Include tactile inspection in addition to visual inspection of elastomeric elements to detect hardening.

ih) Include evidence of water in-leakage as a finding requiring further evaluation. This may include engineering evaluation, more frequent inspections, or destructive testing of affected concrete to validate existing concrete properties, including concrete pH levels. When leakage volumes allow, assessment may include analysis of the leakage pH, along with mineral, chloride, sulfate, and iron content in the water.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 22 of 26 Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Program or Activity Section Schedule (Section) ji) Develop a new implementing procedure or attachment to an existing implementing procedure to address aging management of inaccessible areas exposed to groundwater/soil and water-flowing. The document will include guidance to conduct a baseline visual inspection, pH analysis, and a chloride concentration test prior to the SPEO at a location close to the coastline/intake and a location in the main plant area for comparison. The baseline inspection results will be used to conduct a baseline evaluation that will determine the additional actions (if any) that are warranted. Additionally, the baseline evaluation results will set the subsequent inspection requirements and inspection intervals (not to exceed 5 years). Periodic inspections (focused) and evaluation updates (not to exceed 5 years) will be performed throughout the SPEO to ensure aging of inaccessible concrete is adequately managed.

Opportunistic inspections may be used to replace or supplement the focused inspections if the inspection location is excavated for other reasons during the periodic inspection interval. Address the aggressive groundwater/soil environment to account for the extent of the degradation experienced. Specific requirements include evaluations, destructive testing, and/or focused inspections of representative accessible (leading indicator) or below-grade, inaccessible concrete structural elements exposed to aggressive groundwater/soil, on an interval not to exceed 5 years.

kj) Require inspections of the Condensate Storage Tank (CST) and Auxiliary Feedwater (AFW) Structures and Piping Inspections in the Trenches every third refueling outage, which will ensure that these inspections are performed at least once per 5 years.

l) Include stainless steel ASME Class 1, 2, or 3 support members, welds, bolted connections, or anchorage in the engineering evaluation of acceptance criteria, expansion criteria, and examination frequency if cracking due to SCC in the uncontrolled indoor and outdoor air at PSL is detected for stainless steel mechanical or non ASME structural components.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 23 of 26 SLRA Section B.2.3.33, page B-247, is revised as follows:

B.2.3.33 Structures Monitoring Program Description The PSL Structures Monitoring AMP is an existing AMP that was previously evaluated as part of the PSL Systems and Structures Monitoring AMP in the initial license renewal application.

The PSL Structures Monitoring AMP is a condition monitoring AMP that is based on the requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.65 (the Maintenance Rule), U.S. Nuclear Regulatory Commission (NRC) Regulatory Guide (RG) 1.160, and Nuclear Management and Resources Council (NUMARC) 93-01. These documents provide guidance for development of site/fleet-specific programs to monitor the condition of structures and structural components within the scope of the SLR rule, such that there is no loss of structure or structural component intended function.

The PSL Structures Monitoring AMP consists primarily of periodic visual inspections of plant structures and SCs for evidence of deterioration or degradation, such as described in the American Concrete Institute (ACI) Standards 349.3R, ACI 201.1R, and Structural Engineering Institute/American Society of Civil Engineers Standard (SEI/ASCE) 11. Quantitative acceptance criteria for concrete inspections are based on ACI 349.3R. The condition of steel is compared to design standards and evaluated.

Inspections and evaluations are performed by qualified personnel using criteria derived from industry codes and standards contained in the plant CLB, including ACI 349.3R. Inspections and evaluations are performed at no interval greater than 5 years with identified degraded conditions receiving more frequent inspection, as warranted, until repaired. The AMP includes preventive actions to provide reasonable assurance of structural bolting integrity.

The groundwater/soil at PSL is judged to be aggressive (chlorides > 500 ppm). Since the chloride levels for seawater are much greater than 500 ppm, there is reasonable certainty that any groundwater/soil chemistry tests will consistently result in chloride level readings that are greater than 500 ppm, which indicates an aggressive groundwater/soil classification, and periodic sampling and testing of groundwater is not necessary. Due to the presence of high chloride levels in the groundwater, a site-specific enhancement to manage the concrete aging during the SPEO will include a baseline visual inspection, pH analysis, and a chloride concentration test prior to the SPEO. The inspection will include a location close to the coastline/intake and a location in the main plant area for comparison and consider site-specific OE. The baseline inspection results will be used to conduct a baseline evaluation that will determine if additional actions are warranted. Additionally, the baseline evaluation results will set the subsequent inspection requirements and inspection intervals (not to exceed 5 years). Functionality throughout the period of the next scheduled inspection will be monitored. Periodic inspections (focused) and evaluation updates (not to exceed 5 years) will be performed throughout the SPEO to ensure aging of inaccessible concrete is adequately managed. Opportunistic inspections may be used to replace or supplement the focused inspections if the inspection location is excavated for other reasons during the periodic inspection interval.

Included in the program is: inspection of structures, including SR buildings and the internal structures within containment; inspection of NNS structures; inspection of structural steel elements; inspection of elastomers; and inspection of the component supports commodity group and architectural items.

Coatings minimize corrosion by limiting exposure to the environment. However, coatings are not credited in the determination of aging effects requiring management. Coatings are not credited for license renewal but are used to indicate aging effects of the base material.

Service Level I coatings in containment are managed by the Protective Coating Monitoring and Maintenance AMP (Section B.2.3.35).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 24 of 26 SLRA Section B.2.3.33, pages B-248, is revised as follows:

NUREG-2191 Consistency The PSL Structures Monitoring AMP with enhancements will be consistent with exception to the 10 elements of NUREG-2191,Section XI.S6, Structures Monitoring.

Exceptions to NUREG-2191 The PSL Structures Monitoring AMP includes the following exception to the NUREG-2191 guidance:

1. The groundwater/soil at PSL is considered aggressive and is expected to be consistently aggressive throughout SPEO due to the plants proximity to the Atlantic Ocean. Since periodic sampling and testing of the groundwater will not impact the groundwater/soil classification, periodic sampling and testing of the groundwater/soil is unnecessary for the PSL Structures Monitoring AMP.

Enhancements The PSL Structures Monitoring AMP will be enhanced as follows, for alignment with NUREG-2191. The enhancements are to be implemented no later than 6 months prior to entering the SPEO.

Element Affected Enhancement

1. Scope Update the governing AMP procedure and other applicable procedures to monitor and inspect steel edge supports on masonry walls.
1. Scope Inaccessible concrete/foundations exposed to groundwater/soil and water-flowing.
2. Preventive Actions Update the governing AMP procedure and other applicable procedures to specify the use of high-strength bolt storage requirements discussed in Section 2 of the Research Council for Structural Connections publication, Specification for Structural Joints Using High-Strength Bolts, for structural bolting consisting of ASTM A325, ASTM A490, and equivalent bolts.
3. Parameters Monitored or Update the governing AMP procedure and other applicable Inspected procedures to inspect concrete structures for increase in porosity and permeability, loss of strength, and reduction in concrete anchor capacity due to local concrete degradation.
3. Parameters Monitored or Update the governing AMP procedure and other applicable Inspected procedures to inspect elastomers for loss of material and crackingloss of strength.
3. Parameters Monitored or Update the governing AMP procedure and other applicable Inspected procedures to inspect SS and aluminum components for pitting and crevice corrosion, and evidence of cracking due to SCC.
3. Parameters Monitored or Update the governing AMP procedure and other applicable Inspected procedures to include monitoring and trending of leakage volumes and chemistry for signs of concrete or steel reinforcement degradation if active through-wall leakage or groundwater infiltration is identified.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 25 of 26 SLRA Section B.2.3.33, page B-249, is revised as follows:

Element Affected Enhancement

3. Parameters Monitored or Update the governing AMP procedure or other applicable Inspected procedures to specify that all bolting is monitored for loss of material, loose bolts, missing or loose nuts, and other conditions indicative of loss of preload.
3. Parameters Monitored or Monitoring of the condition of inaccessible concrete, Inspected including pH and chloride concentration, of concrete exposed to groundwater/soil and water-flowing environment for evidence of aggressive chemical attack or leaching and carbonation.
4. Detection of Aging Effects Update the governing AMP procedure and other applicable procedures to include tactile inspection in addition to visual inspection of elastomeric elements to detect hardening.
4. Detection of Aging Effects Update the governing AMP procedure and other applicable procedures to include evidence of water in-leakage as a finding requiring further evaluation. This may include engineering evaluation, more frequent inspections, or destructive testing of affected concrete to validate existing concrete properties, including concrete pH levels. When leakage volumes allow, assessment may include analysis of the leakage pH, along with mineral, chloride, sulfate, and iron content in the water.
4. Detection of Aging Effects Update the governing AMP procedure and other applicable procedures to address the aggressive groundwater/soil environment to account for the extent of the degradation experienced. Specific requirements include evaluations, destructive testing, and/or focused inspections of representative accessible (leading indicator) or below-grade, inaccessible concrete structural elements exposed to aggressive groundwater/soil, on an interval not to exceed 5 years.
4. Detection of Aging Effects Update the governing AMP procedure and other applicable procedures to require inspections of the Condensate Storage Tank (CST) and Auxiliary Feedwater (AFW) Structures and Piping Inspections in the Trenches every third refueling outage, which will ensure that these inspections are performed at least once per 5 years.
4. Detection of Aging Guidance on baseline inspection with excavation, visual Effects inspection, and physical inspection of the inaccessible concrete through pH analysis and a chloride concentration test of concrete exposed to groundwater/soil and water-flowing at a location near the coastline and a location in the main plant area for comparison prior to the SPEO. Include periodic inspections (focused) at a frequency determined in the baseline evaluation (not to exceed 5 years). Opportunistic inspections may be used to replace or supplement the focused inspections if the inspection location is excavated for other reasons during the periodic inspection interval. The locations inspected during the

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 30 Page 26 of 26 SLRA Section B.2.3.33, page B-249, revision continued:

Element Affected Enhancement baseline inspection will continue to be monitored during the periodic inspections along with any other locations established after the baseline inspection.

Degradation of accessible areas due to aging mechanisms such as chemical attack, leaching of calcium hydroxide, and carbonation can be used as an indicator for reinforced concrete conditions in inaccessible areas. Carbonation test results from accessible areas may be used as an indicator to determine the extent of condition of inaccessible reinforced concrete that is exposed to similar environmental conditions and of similar age.

5. Monitoring and Guidance for the evaluation of the baseline inspection Trending results and related OE, with concrete exposed to ambient air and to groundwater/soil, for concrete susceptible to aging effects related to an aggressive environment prior to the SPEO to determine subsequent inspection/evaluation requirements and intervals (not to exceed 5 years), with periodic updates based on periodic inspections and OE.

Guidance for the evaluation of baseline inspection results and related OE of concrete exposed to water-flowing for evidence of leaching of calcium hydroxide and carbonation will be developed prior to the SPEO.

The baseline evaluation will determine whether leaching and carbonation are occurring or causing adverse effects.

Subsequent inspection/evaluation requirements and intervals (not to exceed 5 years), with periodic updates based on periodic inspections and OE, will be developed if leaching or carbonation is occurring in accessible or inaccessible areas that impacts intended function.

The locations inspected during the baseline inspection will continue to be monitored during the periodic inspections along with any other locations established after the baseline inspection.

6. Acceptance Criteria Acceptance criteria for concrete inspections will be consistent with ACI 349.3R and consider the correlation between the chloride ion concentration within the concrete cover necessary to induce corrosion and alkalinity level of the concrete covering the rebar for inaccessible concrete exposed to groundwater/soil and water-flowing environments.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 31 Page 1 of 16 Inspection of Water-Control Structures Associated with Nuclear Power Plants AMP:

Clarified Discussions for Enhancements and Exceptions Affected SLRA Sections: 2.4.8, 3.5.2.1.8, 3.5.2.2.2.3, Table 3.5-1, Table 3.5.2-8, Table 19-3 (Appendices A1 and A2), B.2.3.34 SLRA Page Numbers: 2.4-18, 2.4-19, 3.5-9, 3.5-10, 3.5-30, 3.5-59, 3.5-62, 3.5-68, 3.5-109, 3.5-110, A1-104, A1-105, A2-105, B-254 Description of Change:

1. Each PSL Unit 1 and 2 intake structure includes four (4) intake wells. The four intake wells for each unit are inspected on a rotating basis, one intake well per refueling outage. Therefore, all four intake wells for each unit (100%) are inspected within a 6-year interval. This inspection interval is an exception to Element 4 of NUREG-2191 Section XI.S7 guidance, which states that inspections are to be performed on 100% of submerged structural elements at least once every 5 years. Therefore, an exception is added to SLRA Section B.2.3.34, as described below.
2. Enhancements related to bolting integrity were specified for the PSL Inspection of Water-Control Structures Associated with Nuclear Power Plants AMP. To ensure consistency of preventive actions for bolting across all related PSL AMPs, enhancements in SLRA Section B.2.3.34 are revised to incorporate EPRI reports 1015336 and 1015337 (which superseded EPRI NP-5067 and TR-104213 cited in NUREG-2191 Section XI.S7) and to specify guidance discussed in Section 2 of Research Council for Structural Connections publication "Specification for Structural Joints Using High-Strength Bolts" regarding the selection of bolting materials, the selection of bolting lubricants, the selection of coating materials, and the appropriate installation torque or tension in addition to storage requirements. Enhancements will also ensure molybdenum disulfide and other lubricants containing sulfur will not be used for structural bolting at PSL.

Changes to the enhancements identified above are also reflected in updates to the associated commitments presented in SLRA Table 19-3 (both Appendices A1 and A2).

3. The structures that are within the scope of the PSL Inspection of Water-Control Structures Associated with Nuclear Power Plants AMP include the emergency cooling canal (located between Big Mud Creek and the intake cooling water canal), the intake cooling water canal (the portion between the emergency cooling canal and the intake structure), Unit 1 and Unit 2 intake structures, and ultimate heat sink dam.

The intended functions performed by the structures within the scope of the PSL Inspection of Water-Control Structures Associated with Nuclear Power Plants AMP are listed in SLRA Sections 2.4.8, 2.4.9, and 2.4.14. The discharge canal, and the portion of the intake canal not located between the emergency cooling canal and the Unit 1 and Unit 2 intake structures do not perform a license renewal intended function. Similarly, the trash racks located at the intake structures and the sluice gates located at the intake headwalls do not perform a license renewal intended function. As such, these structures are not within the scope of SLR.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 31 Page 2 of 16 Section 2.4.8 of the SLRA is titled Intake, Discharge, and Emergency Cooling Canals and contains a description of structures that are not within the scope of license renewal, including the discharge canal and portions of the intake canal.

Accordingly, SLRA Section 2.4.8, Table 3.5-1, and Table 3.5.2-8 are revised to clarify the structures that are within the scope of SLR and managed by the PSL Inspection of Water-Control Structures Associated with Nuclear Power Plants AMP.

4. The concrete compaction piles located in the underlying soil beneath the ultimate heat sink dam are design features of the soil, and thus do not require screening as unique components. There are no sliding surfaces requiring aging management within the scope of the PSL Inspection of Water-Control Structures Associated with Nuclear Power Plants AMP.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 31 Page 3 of 16 SLRA Section 2.4.8, page 2.4-18 is revised as follows:

2.4.8 Intake, Discharge, and Emergency Cooling Canals Description The intake canal, which takes water directly from the Atlantic Ocean through subaqueous intake water pipes that run under the beach and terminate at the intake canal headwalls, serves as the plant heat sink during normal plant operation. In the unlikely event of blockage of the intake canal or pipes, emergency cooling water will be taken from Big Mud Creek through the ultimate heat sink dam and emergency cooling canal. This emergency source of water is designed to withstand design basis seismic, tornado, and hurricane conditions. Regardless of the source, cooling water is discharged into the discharge canal, and then flows to the Atlantic Ocean through discharge pipes.

The intake and discharge canal headwalls are reinforced concrete structures. The intake canal headwalls provide the termination point for the intake pipes from the Atlantic Ocean. The discharge canal headwalls provide the origination point for the discharge pipes to the Atlantic Ocean.

The emergency cooling canal is seismic category 1 in the area of the intake structure.

Erosion protection in the area of the intake structure is provided by a concrete retaining wall and concrete embankments.

Boundary The evaluation boundary of the intake cooling canal system on the intake side consists of the intake canal headwalls, the earthen dikes up to the intake structure and the emergency cooling canal (located between the intake canal and Big Mud Creek) and the portion of the intake canal located between the emergency cooling canal and the Unit 1 and Unit 2 intake structures. On the discharge side, the discharge canal extends from the seal wells to the two discharge canal headwalls. There are no significant differences between the current boundaries and those identified as part of the original PSL license renewal effort.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 31 Page 4 of 16 SLRA Section 2.4.8, page 2.4-19 is revised as follows:

Components Subject to AMR Table 2.4-8 lists the intake, discharge, and emergency cooling canal component types that require AMR and their associated component intended functions.

Table 3.5.2-8 provides the results of the AMR.

Table 2.4-8 Intake, Discharge, and Emergency Cooling Canal Components Subject to Aging Management Review Component Type Component Intended Function(s)

Concrete erosion protection; concrete Structural support paving and grout filled fabric (between Emergency cooling water source intake structures and ultimate heat sink dam)

Earthen canal dikes Structural support Emergency cooling water source

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 31 Page 5 of 16 SLRA Section 3.5.2.1.8, page 3.5-9 is revised as follows:

3.5.2.1.8 Intake, Discharge, and Emergency Cooling Canals Materials The materials of construction for the intake, discharge, and emergency cooling canal components are:

  • Concrete (reinforced)
  • Earthen fill Environments The intake, discharge, and emergency cooling canal components are exposed to the following environments:
  • Air - outdoor
  • Groundwater / soil
  • Raw water
  • Soil
  • Water - flowing
  • Water - standing

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 31 Page 6 of 16 SLRA Section 3.5.2.1.8, page 3.5-10 is revised as follows:

Aging Effects Requiring Management The following aging effects associated with the intake, discharge, and emergency cooling canals require management:

  • Cracking
  • Distortion
  • Increase in porosity and permeability
  • Loss of bond
  • Loss of form
  • Loss of material
  • Loss of preload Aging Management Programs The following AMPs manage the aging effects for the intake, discharge, and emergency cooling canal components:
  • Inspection of Water-Control Structures Associated with Nuclear Power Plants (B.2.3.34)
  • Structures Monitoring (B.2.3.33)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 31 Page 7 of 16 SLRA Section 3.5.2.2.2.3, page 3.5-30 is revised as follows:

3.5.2.2.2.3 Aging Management of Inaccessible Areas for Group 6 Structures Further evaluation is recommended for inaccessible areas of certain Group 6 structure/aging effect combinations as identified below, whether or not they are covered by inspections in accordance with the GALL-SLR Report, AMP XI.S7, Inspection of Water-Control Structures Associated with Nuclear Power Plants, or Federal Energy Regulatory Commission (FERC)/U.S. Army Corp of Engineers dam inspection and maintenance procedures.

1. Loss of material (spalling, scaling) and cracking due to freeze-thaw could occur in below-grade inaccessible concrete areas of Group 6 structures. Further evaluation is recommended of this aging effect for inaccessible areas for plants located in moderate to severe weathering conditions.
2. Cracking due to expansion and reaction with aggregates could occur in inaccessible concrete areas of Group 6 structures. Further evaluation is recommended to determine if a plant-specific AMP is required to manage this aging effect. Acceptance criteria are described in BTP RLSB-1 (Appendix A.1 of this SRP-SLR).
3. Increase in porosity and permeability and loss of strength due to leaching of calcium hydroxide and carbonation could occur in inaccessible areas of concrete elements of Group 6 structures.

Further evaluation is recommended if leaching is observed in accessible areas that impact intended functions. Acceptance criteria are described in BTP RLSB-1 (Appendix A.1 of this SRP-SLR).

Further evaluation for Inaccessible Areas for Group 6 Structures is provided below:

Note that structures and components submerged underwater are considered accessible [NUREG-2191, Table IX.B].

1. Group 6 Structures at PSL; intake, discharge, and emergency cooling canals, ultimate heat sink (UHS) dam, and intake structures are located in a subtropical climate with long warm summers accompanied by abundant rainfall and mild dry winters, and therefore, freeze-thaw is not an

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 31 Page 8 of 16 SLRA Table 3.5-1, page 3.5-59 is revised as follows:

Table 3.5-1: Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Item Aging Aging Management Further Evaluation Component Discussion Number Effect/Mechanism Program / TLAA Recommended 3.5 1, 049 Group 6 concrete Loss of material Plant specific AMP or Yes (SRP SLR Section Not Applicable. Structures at PSL are not exposed (inaccessible areas): (spalling, scaling) and AMP XI.S6, "Structures 3.5.2.2.2.3.1) to freezing temperatures for sufficient durations to exterior above and cracking due to freeze Monitoring" enhanced as cause freeze thaw aging effects.

below grade; thaw necessary foundation; interior slab 3.5-1, 050 Groups 6: concrete Cracking due to Plant-specific AMP or Yes (SRP-SLR A plant-specific AMP is not required for the (inaccessible areas): expansion from reaction AMP XI.S6, "Structures Section 3.5.2.2.2.3.2) inaccessible areas of the PSL Intake Structures, all with aggregates Monitoring" enhanced as Intake, Discharge, and Emergency Cooling Canals, necessary and Ultimate Heat Sink Dam (Barrier Wall)

The Structures Monitoring (B.2.3.33) AMP (which includes opportunistic inspection of inaccessible concrete when excavated for other reasons and frequent dewatering of the intake structure bays) is credited with managing cracking in inaccessible areas of PSL structures, including the Intake Structures; Intake, Discharge, and Emergency Cooling Canals; and Ultimate Heat Sink Dam (Barrier Wall).

Further evaluation is documented in Section 3.5.2.2.2.3, Item 2.

3.5-1, 051 Groups 6: concrete Increase in porosity and Plant-specific AMP or Yes (SRP-SLR A plant-specific AMP is not required for the (inaccessible areas): permeability; loss of AMP XI.S6, "Structures Section 3.5.2.2.2.3.3) inaccessible areas of the PSL Intake Structures; exterior above-and strength due to leaching Monitoring" enhanced as Intake, Discharge, and Emergency Cooling Canals; below-grade; of calcium hydroxide necessary and Ultimate Heat Sink Dam (Barrier Wall).

foundation; interior and carbonation The Structures Monitoring (B.2.3.33) AMP is slab credited with managing the inaccessible areas of plant structures including the Intake Structures; Intake, Discharge, and Emergency Cooling Canals; and Ultimate Heat Sink Dam (Barrier Wall).

Further evaluation is documented in Section 3.5.2.2.2.3, Item 3.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 31 Page 9 of 16 SLRA Table 3.5-1, page 3.5-62 is revised as follows:

Table 3.5-1: Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Item Aging Aging Management Further Evaluation Component Discussion Number Effect/Mechanism Program / TLAA Recommended 3.5-1, 060 Group 6: concrete Loss of material None No Not Applicable (accessible areas): (spalling, scaling) and Structures at PSL are not exposed to freezing exterior above-and cracking due to temperatures for sufficient durations to cause below-grade; freeze-thaw freeze-thaw aging effects.

foundation 3.5-1, 061 Group 6: concrete Increase in porosity AMP XI.S7, "Inspection No Consistent with NUREG-2191.

(accessible areas): and permeability; loss of Water-Control The Inspection of Water-Control Structures exterior above-and of strength due to Structures Associated Associated with Nuclear Power Plants below-grade; leaching of calcium with Nuclear Power (B.2.3.34) AMP is credited with managing an foundation; interior hydroxide and Plants" or the increase in porosity and permeability and loss slab carbonation FERC/US Army Corp of of strength for accessible concrete exposed to Engineers outdoor air, and water-flowing or standing.

3.5-1, 062 Group 6: Wooden Loss of material; AMP XI.S7, "Inspection No Not applicable Piles; sheeting change in material of Water-Control There are no wooden piles or sheeting used properties due to Structures Associated in the PSL Intake Structures, Intake, weathering, chemical with Nuclear Power Discharge, and Emergency Cooling Canals, degradation, and Plants" or the or the Ultimate Heat Sink Dam (Barrier Wall).

insect infestation FERC/US Army Corp of repeated wetting and Engineers drying, fungal decay 3.5-1, 063 Groups 1-3, 5, 7-9: Increase in porosity AMP XI.S6, "Structures No Consistent with NUREG-2191.

concrete and permeability; loss Monitoring" The Structures Monitoring (B.2.3.33) AMP is (accessible areas): of strength due to credited with managing leaching or exterior above-and leaching of calcium carbonation of exterior plant structure below-grade; hydroxide and concrete and foundations where groundwater foundation carbonation or precipitation run-off forms a flowing water environment.

3.5-1, 064 Groups 1-3, 5, 7-9: Loss of material AMP XI.S6, "Structures No Not Applicable.

concrete (spalling, scaling) and Monitoring" Structures at PSL are not exposed to freezing (accessible areas): cracking due to temperatures for sufficient durations to cause exterior above-and freeze-thaw freeze-thaw aging effects.

below-grade; foundation

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 31 Page 10 of 16 SLRA Table 3.5-1, page 3.5-68 is revised as follows:

Table 3.5-1: Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Item Aging Aging Management Further Evaluation Component Discussion Number Effect/Mechanism Program / TLAA Recommended 3.5-1, 094 Vibration isolation Reduction or loss of AMP XI.S3, "ASME No Not Applicable.

elements isolation function due Section XI, Subsection There are no vibration isolation elements to radiation IWF," and/or AMP requiring aging management at PSL.

hardening, XI.S6, "Structures temperature, Monitoring" humidity, sustained vibratory loading 3.5-1, 095 Galvanized steel None None No Consistent with NUREG 2191 support members; Galvanized steel in components and welds; bolted commodities in an indoor air environment connections; have no aging effect/mechanism and support anchorage therefore do not require aging management.

to building structure 3.5-1, 096 Groups 6: concrete Cracking due to AMP XI.S7, "Inspection No Consistent with NUREG-2191.

(accessible areas): expansion from of Water-Control The Inspection of Water-Control Structures all reaction with Structures Associated Associated with Nuclear Power Plants aggregates with Nuclear Power (B.2.3.34) AMP is credited with managing Plants" or the cracking for accessible concrete in the Intake FERC/US Army Corp of Structures; Intake, Discharge, and Emergency Engineers Cooling Canals; and the Ultimate Heat Sink Dam (Barrier Wall).

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 31 Page 11 of 16 SLRA Table 3.5.2-8, page 3.5-109 is revised as follows:

Table 3.5.2-8: Intake, Discharge, and Emergency Cooling Canals - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Concrete, erosion Structural Concrete Water - flowing Loss of material Inspection of Water- III.A6.T-20 3.5-1, A protection; concrete support (reinforced); Control 056 paving and grout filled Emergency Grout Structures Associated fabric (between intake cooling water with Nuclear Power structures and source Plants (B.2.3.34) ultimate heat sink dam)

Concrete, erosion Structural Concrete Soil Cracking and Structures Monitoring III.A6.TP-30 3.5-1, B protection; concrete support (reinforced); distortion (B.2.3.33) 044 paving and grout filled Emergency Grout fabric (between intake cooling water structures and source ultimate heat sink dam)

Concrete, erosion Structural Concrete Air - outdoor Cracking Inspection of Water- III.A6.T-34 3.5-1, A protection; concrete support (reinforced); Raw water Control 096 paving and grout filled Emergency Grout Structures Associated fabric (accessible) cooling water with Nuclear Power (between intake source Plants (B.2.3.34) structures and ultimate heat sink dam)

Concrete, erosion Structural Concrete Air - outdoor Increase in porosity Inspection of Water- III.A6.TP-37 3.5-1, A protection; concrete support (reinforced); Raw water and permeability Control 061 paving and grout filled Emergency Grout Loss of strength Structures Associated fabric (accessible) cooling water with Nuclear Power (between intake source Plants (B.2.3.34) structures and ultimate heat sink dam)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 31 Page 12 of 16 SLRA Table 3.5.2-8, page 3.5-109 revision continued:

Table 3.5.2-8: Intake, Discharge, and Emergency Cooling Canals - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Concrete, erosion Structural Concrete Air - outdoor Cracking Inspection of Water- III.A6.TP-38 3.5-1, A protection; concrete support (reinforced); Raw water Loss of bond Control 059 paving and grout filled Emergency Grout Loss of material Structures Associated fabric (accessible) cooling water with Nuclear Power (between intake source Plants (B.2.3.34) structures and ultimate heat sink dam)

Concrete, erosion Structural Concrete Soil Cracking Structures Monitoring III.A6.TP-220 3.5-1, B protection; concrete support (reinforced); (B.2.3.33) 050 paving and grout filled Emergency Grout fabric (inaccessible) cooling water (between intake source structures and ultimate heat sink dam)

Concrete, erosion Structural Concrete Groundwater/soil Cracking Structures Monitoring III.A6.TP-104 3.5-1, B protection; concrete support (reinforced); Loss of bond (B.2.3.33) 065 paving and grout filled Emergency Grout Loss of material fabric (inaccessible) cooling water (between intake structures and source ultimate heat sink dam)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 31 Page 13 of 16 SLRA Table 3.5.2-8, page 3.5-110 is revised as follows:

Table 3.5.2-8: Intake, Discharge, and Emergency Cooling Canals - Summary of Aging Management Evaluation Aging Effect Intended Aging Management NUREG-2191 Table 1 Component Type Material Environment Requiring Notes Function Program Item Item Management Concrete, erosion Structural Concrete Groundwater/soil Cracking Structures Monitoring III.A6.TP-107 3.5-1, B protection; concrete support (reinforced); Increase in (B.2.3.33) 067 paving and grout filled Emergency Grout porosity and fabric (inaccessible) cooling water permeability (between intake structures and source Loss of strength ultimate heat sink dam)

Concrete, erosion Structural Concrete Water - flowing Increase in Structures Monitoring III.A6.TP-109 3.5-1, B protection; concrete support (reinforced); porosity and (B.2.3.33) 051 paving and grout filled Emergency Grout permeability fabric (inaccessible) cooling water Loss of strength (between intake structures and source ultimate heat sink dam)

Earthen canal dikes Structural Earthen fill Air - outdoor Loss of form Inspection of Water- III.A6.T-22 3.5-1, A support Water - flowing or Loss of material Control 058 Emergency standing Structures Associated cooling water with Nuclear Power source Plants (B.2.3.34)

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 31 Page 14 of 16 SLRA Appendix A1, Section 19.4, commitment No. 37 portion of Table 19-3 beginning on page A1-104, is revised as follows:

Table 19-3 List of Unit 1 SLR Commitments and Implementation Schedule No. Aging Management NUREG-2191 Commitment Implementation Schedule Program or Activity Section (Section) 37 Inspection of Water-Control XI.S7 Continue the existing PSL Inspection of Water-Control Structures No later than 6 months prior to Structures Associated with Associated with Nuclear Power Plants AMP, including enhancement the SPEO, or no later than the Nuclear Power Plants to: last refueling outage prior to the (19.2.2.34) SPEO i.e.:

a) Revise the implementing procedure to reference EPRI Reports 1015336 and 1015337 and to incorporate guidance PSL1: 09/01/2035 for proper selection of bolting material and lubricants and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high strength bolting. Additionally, procedures will be updated to explicitly prohibit the use of molybdenum disulfide and other lubricants containing sulfur on structural bolting.

ba) Revise the implementing procedure to specify the use of preventive actions for storage, lubricant selection, and bolting and coating material selectionhigh-strength bolt storage requirements discussed in Section 2 of the Research Council for Structural Connections publication, Specification for Structural Joints Using High-Strength Bolts, for structural bolting consisting of ASTM A325, ASTM A490, and equivalent bolts.

cb) Revise the implementing procedure to state that further evaluation of evidence of groundwater infiltration or through-concrete leakage may also include destructive testing of affected concrete to validate existing concrete properties, including concrete pH levels, and that assessments may include analysis of the leakage pH, along with mineral, chloride, sulfate, and iron content in the leakage water if leakage volumes allow.

dc) Revise the severe weather implementing procedure to include performance of structural inspections after major unusual events such as hurricanes, floods, or seismic events.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 31 Page 15 of 16 SLRA Appendix A2, Section 19.4, commitment No. 37 portion of Table 19-3 on page A2-105 is revised as follows:

Table 19-3 List of Unit 2 SLR Commitments and Implementation Schedule No. Aging Management Program NUREG-2191 Commitment Implementation Schedule or Activity (Section) Section 37 Inspection of Water-Control XI.S7 Continue the existing PSL Inspection of Water-Control Structures Associated No later than 6 months prior to the Structures Associated with with Nuclear Power Plants AMP, including enhancement to: SPEO, or no later than the last Nuclear Power Plants refueling outage prior to the SPEO (19.2.2.34) a) Revise the implementing procedure to reference EPRI Reports i.e.:

1015336 and 1015337 and to incorporate guidance for proper selection of bolting material and lubricants and appropriate PSL2: 10/06/2042 installation torque or tension to prevent or minimize loss of bolting preload and cracking of high strength bolting. Additionally, procedures will be updated to explicitly prohibit the use of molybdenum disulfide and other lubricants containing sulfur on structural bolting.

ba) Revise the implementing procedure to specify the use of preventive actions for storage, lubricant selection, and bolting and coating material selectionhigh-strength bolt storage requirements discussed in Section 2 of the Research Council for Structural Connections publication, Specification for Structural Joints Using High-Strength Bolts, for structural bolting consisting of ASTM A325, ASTM A490, and equivalent bolts.

cb) Revise the implementing procedure to state that further evaluation of evidence of groundwater infiltration or through-concrete leakage may also include destructive testing of affected concrete to validate existing concrete properties, including concrete pH levels, and that assessments may include analysis of the leakage pH, along with mineral, chloride, sulfate, and iron content in the leakage water if leakage volumes allow.

dc) Revise the severe weather implementing procedure to include performance of structural inspections after major unusual events such as hurricanes, floods, or seismic events.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-2022-043 Attachment 31 Page 16 of 16 SLRA Section B.2.3.34, page B-254 is revised as follows:

Exceptions to NUREG-2191 Each PSL Unit 1 and Unit 2 intake structure includes four (4) intake wells. The four intake wells for each unit are dewatered and inspected on a rotating basis.

All four intake wells for each unit (100%) are inspected within a 6-year interval.

This is an exception to the NUREG-2191 guidance that 100% of submerged structural elements should be inspected every 5 years. None.

Enhancements The PSL Inspection of Water-Control Structures Associated with Nuclear Power Plants AMP will be enhanced as follows, for alignment with NUREG-2191. The enhancements are to be implemented no later than 6 months prior to entering the SPEO.

Element Affected Enhancement

2. Preventive Actions Revise the implementing procedure to reference EPRI Reports 1015336 and 1015337 and to incorporate guidance for proper selection of bolting material and lubricants and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high strength bolting. Additionally, procedures will be updated to explicitly prohibit the use of molybdenum disulfide and other lubricants containing sulfur on structural bolting.
2. Preventive Actions Revise the implementing procedure to specify the use of preventive actions for storage, lubricant selection, and bolting and coating material selectionhigh-strength bolt storage requirements discussed in Section 2 of the Research Council for Structural Connections publication, Specification for Structural Joints Using High-Strength Bolts, for structural bolting consisting of ASTM A325, ASTM A490, and equivalent bolts.
4. Detection of Aging Revise the implementing procedure to state that further Effects evaluation of evidence of groundwater infiltration or through-concrete leakage may also include destructive testing of affected concrete to validate existing concrete properties, including concrete pH levels, and that assessments may include analysis of the leakage pH, along with mineral, chloride, sulfate, and iron content in the leakage water if leakage volumes allow.
4. Detection of Aging Revise the severe weather implementing procedure to include Effects performance of structural inspections after major unusual events such as hurricanes, floods, or seismic events.
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