L-2022-143, Subsequent License Renewal Application - Aging Management Requests for Additional Information Set 1A Response

Subsequent License Renewal Application - Aging Management Requests for Additional Information Set 1A Response

ML22251A202
Person / Time
Site:	Saint Lucie
Issue date:	09/08/2022
From:	Maher W Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2022-143
Download: ML22251A202 (45)

Text

September 08, 2022 L-2022-143 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 Renewed Facility Operating Licenses DPR-67 and NPF-16 SUBSEQUENT LICENSE RENEWAL APPLICATION - AGING MANAGEMENT REQUESTS FOR ADDITIONAL INFORMATION (RAI) SET 1A RESPONSE

References:

1. FPL Letter L-2021-192 dated October 12, 2021 - Subsequent License Renewal Application -

Revision 1 (ADAMS Accession No. ML21285A107) 2. FPL Letter L-2022-043 dated April 7, 2022 - Subsequent License Renewal Application Revision 1 - Supplement 1 (ADAMS Accession No. ML22097A202) 3. FPL Letter L-2022-044 dated April 13, 2022 - Subsequent License Renewal Application Revision 1 - Supplement 2 (ADAMS Accession No. ML22103A014) 4. FPL Letter L-2022-071 dated May 19, 2022 - Subsequent License Renewal Application Revision 1 - Supplement 3 (ADAMS Accession No. ML22139A083) 5. NRC Email and Attachment dated July 11, 2022, St. Lucie SLRA RAI Safety Set 3 Final (ADAMS Accession Nos. ML22193A086, ML22193A087) 6. FPL Letter L-2022-108 dated July 11, 2022 - Subsequent License Renewal Application -

Aging Management Requests for Additional Information (RAI) Set 2 Response 7. NRC Email and Attachment dated August 4, 2022, St. Lucie SLRA RAI (Second Round) 1a Florida Power & Light Company (FPL), owner and licensee for St. Lucie Nuclear Plant (PSL) Units 1 and 2, has submitted a revised and supplemented subsequent license renewal application (SLRA) for the Facility Operating Licenses for PSL Units 1 and 2 (References 1-4). Based on the NRCs review of the SLRA, the NRC issued its Set 1a RAIs to FPL (Reference 7). Attachments 1-6 to this letter provide the response to those information requests. In addition, Attachment 6 to this letter provides a response to RAI B.2.3.27-1a that supersedes the previous Set 1a, Attachment 14 response (Reference 6). Attachment 7 to this letter supersedes the previously submitted SLRA Revision 1, Supplement 1, Attachment 18 submittal (Reference 2).

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-2022-143 l Page 2 of 3 Certain attachments include associated revisions to the SLRA (Enclosure 3 Attachment 1 of Reference 1, as supplemented by References 2 - 4) denoted by strikethrough (deletion) and/or bold red underline (insertion) text. Previous SLRA revisions are denoted by bold black text. SLRA table revisions are included as 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.

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

Executed on the 8th day of September 2022.

Sincerely, Digitally signed by William Maher William DN: cn=William Maher, o=Nuclear, ou=Nuclear Licensing Projects, email=william.maher@fpl.com, Maher c=US Date: 2022.09.08 10:30:22 -04'00' William D. Maher Licensing Director - Nuclear Licensing Projects Florida Power & Light Company

Attachment:

PSL Response to NRC RAI No. B.2.3.27-1a 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











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St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 1 of 42 Buried and Underground Piping and Tanks AMP RAI B.2.3.27-1a Regulatory Basis Section 54.21(a)(3) of Title 10 of the Code of Federal Regulations (10 CFR) requires an applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation. One of the findings that the U.S.

Nuclear Regulatory Commission (NRC) staff must make to issue a renewed license (10 CFR 54.29(a)) is that actions have been identified and have been or will be taken with respect to managing the effects of aging during the period of extended operation on the functionality of structures and components that have been identified to require review under 10 CFR 54.21, such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the current licensing basis. In order to complete its review and enable making a finding under 10 CFR 54.29(a), the staff requires additional information in regard to the matters described below.

Background

SLRA Section B.2.3.27, Buried and Underground Piping and Tanks, states [t]he 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.

GALL-SLR Report Table XI.M41-1, Preventive Actions for Buried and Underground Piping and Tanks, recommends that buried stainless steel piping is externally coated in accordance with the preventive actions program element of GALL-SLR Report AMP XI.M41, Buried and Underground Piping and Tanks.

In addition, GALL-SLR Report AMP XI.M41 states the following:

x [a]dditional inspections, beyond those in Table XI.M41-2, Inspection of Buried and Underground Piping and Tanks, may be appropriate if exceptions are taken to program element 2, preventive actions, or in response to plant-specific operating experience.

x [t]here are no recommended preventive actions [e.g., external coatings] for titanium alloy, super austenitic stainless steels, and nickel alloy materials.

By letter dated June 13, 2022 (ADAMS Accession No. ML22164A802), the applicant stated the following in response to RAIs B.2.3.27-1 and B.2.3.21-2 (respectively):

x [a] portion of the Unit 1 auxiliary feedwater (AFW) and condensate system (AFW pump suction) is buried stainless steel piping in sand beneath the turbine building. No coating was identified, however, due to the location beneath the turbine building, this buried piping is not susceptible to wetting.

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 2 of 42 x [t]he table [referring to the soil corrosivity sampling results table] does not include an outlier soil sample associated with a Unit 2 intake cooling water (ICW) line, since that sample had been impacted by local saltwater foaming from the ICW discharge overflow/standpipe. The caulking between the standpipe and the concrete decking was weathered and porous, allowing saltwater foam to permeate into the soil.

In response to RAI B.2.3.21-2, the applicant provided results from seven soil corrosivity samples which included the following parameters: pH, soil resistivity, moisture, chlorides, sulfates, redox potential, and microbiology. Based on its review of this data, the staff noted that the soil can be considered appreciably corrosive (using average values) or severely corrosive (using least conservative values) to stainless steel when scoring in accordance with Table 9-4, Soil Corrosivity Index from BPWORKS, of Electric Power Research Institute (EPRI) Report 3002005294, Soil Sampling and Testing Methods to Evaluate the Corrosivity of the Environment for Buried Piping and Tanks at Nuclear Power Plants.

Issue The basis provided by the applicant for having uncoated buried stainless steel (i.e., an exception to GALL-SLR AMP XI.M41 guidance) is that the piping is not exposed to significant amounts of moisture (i.e., wetting). However, the staff notes that soil parameters beyond moisture (i.e., pH, soil resistivity, chlorides, sulfates, redox potential, and microbiology) impact the susceptibility of buried stainless steel to external corrosion. Based on the soil corrosivity data provided in the response to RAI B.2.3.21-2, the environment at St. Lucie can be considered corrosive to buried stainless steel. In addition, based on its review of the response to RAI B.2.3.21-2, the staff notes that there has been at least one incident of saltwater intrusion into the soil. Based on its review of Table 9-4 of EPRI Report 3002005294, the staff also notes buried stainless is more sensitive to the effects of chlorides than any other material type.

Request

1. State the approximate length of uncoated in-scope buried stainless steel piping.

2. State the basis for why the inspection quantities in GALL-SLR Report Table XI.M41-2 are appropriate for buried stainless steel piping. The technical basis could include (but is not limited to) discussion of the following: results of soil corrosivity testing in the vicinity of the subject piping, results of inspections of buried uncoated stainless steel piping, and type(s) of in-scope stainless steel (e.g., super austenitic) piping utilized in uncoated buried applications, etc.

References.

x EPRI. EPRI 3002005294, Soil Sampling and Testing Methods to Evaluate the Corrosivity of the Environment for Buried Piping and Tanks at Nuclear Power Plants.

Palo Alto, California: Electric Power Research Institute. November 6, 2015.

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 3 of 42 PSL Response:

The only buried stainless steel piping at St. Lucie, which could not be confirmed as coated or encased in concrete, is comprised of the Unit 1 auxiliary feedwater (AFW) pump recirculation piping and condensate system (AFW pump suction) piping. Therefore, this piping is conservatively assumed to be uncoated. This grade 316 stainless steel piping traverses beneath the Unit 1 turbine building and has a total length of approximately 520 ft.

At St. Lucie, the application of external coatings on safety-related piping is a design feature and is controlled by engineering specifications and design drawings, as appropriate. The St. Lucie Unit 1 design specifications and drawings for buried stainless steel piping do not specify the application of a coating material.

NUREG-2191, Table XI.M41-1 identifies coatings and backfill as preventative actions for buried stainless steel piping. The Unit 1 buried grade 316 stainless steel piping meets the backfill preventive action in Table XI.M41-1. The soil environment in contact with this buried stainless steel piping is composed of backfill in accordance with the applicable plant specification, which is available on the ePortal and summarized as follows:

x Material to be used as compacted backfill for Unit 1 shall be a selected sand and be free of muddy material, organic matter, rubbish, debris, or other unsuitable materials. The moisture content of the sand shall be within the limits required to obtain the specified compaction. Dredged material shall be stockpiled so as to facilitate drainage. No limerock shall be used for fill. This meets and exceeds the NACE SP0169-2007 (Reference 1), Section 5.2.3.4 backfill recommendation from NUREG-2191.

x Backfill material designated as Class I material for Unit 1 shall have no more than 12%

silt content (finer than No. 200 sieve), be free of clay balls, and no rock fragments larger than 6 inches shall be used for the fill except in areas where hand compaction is required wherein the maximum rock fragment size shall not exceed 3 inches. Sieve analyses are performed in accordance with ASTM D422 or D1140. Only Class I backfill is used at St. Lucie. This meets and exceeds the ASTM D 448-08 (Reference 2) size recommendation from NUREG-2191.

Although stainless steel is susceptible to attack by chlorides, such attacks are primarily catalyzed when moisture breaks the chloride molecules ionic bonds freeing chlorine ions to attack the stainless steel piping. The concrete floor slab associated with the turbine building shields the piping from rainwater, saltwater, and other moisture or chloride intrusion. Even if moisture intrusion occurred, sand is known to have relatively good drainage properties, so stagnant moisture leading to a continued chloride attack would not occur. Additionally, as identified in the response to Set 1 RAI B.2.3.21-2, the majority of the soil samples listed had chloride and sulfate readings below the threshold of detection. The two exceptions to this were at soil samples near the intake cooling water (ICW) piping on the intake side of the plant, which measured 205 mg/kg dry chlorides and 149 mg/kg dry sulfates, and the outlier sample near the discharge structure where saltwater intrusion had occurred (Reference 3). Neither of the two outlier sample locations are near any of the subject grade 316 stainless steel piping.

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 4 of 42 An operating experience (OE) search of the 10-year action request (AR) database and component database (NAMS) did not identify any aging-related degradation for the Unit 1 stainless steel AFW and condensate system piping buried beneath the Unit 1 turbine building nor was age-related degradation identified for any other buried stainless steel piping at the site.

Due to the low number of chlorides within the soil, the low likelihood of stagnant moisture due to the concrete floor slab shielding, good soil/backfill drainage, and no history of negative OE, an exception to the NUREG-2191 recommendation of coating buried stainless steel piping as a preventive action is reasonable and will be taken with respect to the Unit 1 stainless steel AFW pump recirculation piping and condensate system (AFW pump suction) piping buried beneath the Unit 1 turbine building. Additionally, for the same reasoning, the inspection quantities listed in NUREG-2191 Table XI.M41-2 are adequate for providing reasonable assurance that the uncoated buried stainless piping at St. Lucie will maintain its pressure boundary function throughout the SPEO.

Due to the new exception for buried stainless steel piping coatings, the following SLRA tables and sections are impacted:

x Table 3.3-1, Summary of Aging Management Evaluations for the Auxiliary Systems x Table 3.3.2-4, Diesel Generators and Support Systems - Summary of Aging Management Evaluation x Table 3.3.2-5, Fire Protection / Service Water - Summary of Aging Management Evaluation x Table 3.3.2-8, Intake Cooling Water / Emergency Cooling Canal - Summary of Aging Management Evaluation x Table 3.3.2-9, Primary Makeup Water - Summary of Aging Management Evaluation x Table 3.3.2-12, Ventilation - Summary of Aging Management Evaluation x Table 3.4-1, Summary of Aging Management Evaluations for the Steam and Power Conversion Systems x Table 3.4.2-3, Auxiliary Feedwater and Condensate - Summary of Aging Management Evaluation x Table B-4, PSL Aging Management Program Consistency with NUREG-2191 x Section B.1.1, Overview x Section B.2.3.27, Buried and Underground Piping and Tanks Several of the impacted pages associated with the above tables and sections were also impacted by previous SLRA Supplements and RAI responses (References 3, 4, and 5).

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 5 of 42

References:

1. NACE. Standard Practice SP0169-2007, Control of External Corrosion on Underground or Submerged Metallic Piping Systems. Houston, Texas: NACE International. 2007.

2. ASTM. ASTM D 448-08, Classification for Sizes of Aggregate for Road and Bridge Construction. West Conshohocken, Pennsylvania: ASTM International. 2008.

3. Florida Power and Light Company (FPL) Letter to NRC L-2022-075 dated June 13, 2022, [St. Lucie Units 1 and 2] Subsequent License Renewal Application - Aging Management Requests for Additional Information (RAI) Set 1A Response and Request for Confirmation of Information (RCI) Set 1 Response, ADAMS Accession No. ML22164A802

4. Florida Power and Light Company (FPL) Letter to NRC L-2022-043 dated April 7, 2022,

[St. Lucie Units 1 and 2] Subsequent License Renewal Application Revision 1 -

Supplement 1, ADAMS Accession No. ML22097A202

5. Florida Power and Light Company (FPL) Letter to NRC L-2022-115 dated August 9, 2022, [St. Lucie Units 1 and 2] Subsequent License Renewal Application - Aging Management Requests for Additional Information (RAI) Set 3 Response and Submittal of Superseded Response for One Set 2 RAI and One Supplement 1 Attachment, ADAMS Accession No. ML22221A134

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 6 of 42 Associated SLRA Revisions:

SLRA Table 3.3-1, page 3.3-46, as updated by Supplement 1 Attachment 30 and Set 3 RAI 3.3.2.2.9-1, is updated 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, 107 Stainless steel, Loss of material due to AMP XI.M41, "Buried No Consistent with NUREG-2191 with nickel alloy piping, pitting, crevice corrosion, and Underground Piping exception. The Buried and Underground piping components MIC (soil only) and Tanks" Piping and Tanks AMP is used to manage exposed to soil, loss of material in stainless steel piping, 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 with austenitic, copper general (copper alloy and Underground Piping exception. The Buried and Underground alloy, stainless only), pitting, crevice and Tanks" Piping and Tanks AMP is used to manage steel, nickel alloy corrosion, MIC (super loss of material in stainless steel closure piping, piping austenitic, copper alloy, bolting exposed to soil.

components, tanks, stainless steel, nickel closure bolting alloy; soil environment exposed to soil, only) concrete, underground 3.3-1, 109 Steel piping, piping Loss of material due to AMP XI.M41, "Buried No Consistent with NUREG-2191 with components, general, pitting, crevice and Underground Piping exception. The Buried and Underground closure bolting corrosion, MIC (soil only) and Tanks" Piping and Tanks AMP is used to manage exposed to soil, loss of material in steel piping, piping concrete, components, and closure bolting exposed to underground soil or concrete that are subject to wetting.

3.3-1, 110 This line item only applies to BWRs.

3.3-1, 111 Steel structural Loss of material due to AMP XI.S6, No Not used.

steel exposed to air general, pitting, crevice "Structures Monitoring" Item Number 3.5-1, 077 is used for loss

- indoor corrosion of material of steel structural steel uncontrolled exposed to air - indoor uncontrolled.

3.3-1, 112 Steel piping, piping None None Yes (SRP-SLR Consistent with NUREG-2191.

components Section 3.3.2.2.9) There are no aging effects to be managed for exposed to concrete steel piping and piping components and the Unit 2 DOSTs exposed to concrete that are not subject to wetting.

Further evaluation is documented in Section 3.2.2.2.9.

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 7 of 42 SLRA Table 3.3-1, page 3.3-55, is updated 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, 144 Stainless steel, Cracking due to SCC AMP XI.M41, "Buried No Consistent with NUREG-2191 with steel, aluminum (steel in and Underground Piping exception. The Buried and Underground piping, piping carbonate/bicarbonate and Tanks" Piping and Tanks AMP is used to manage components, tanks environment only) cracking for steel and stainless steel piping, exposed to soil, piping components, and bolting exposed to concrete soil or concrete.

3.3-1, 145 Stainless steel Cracking due to SCC AMP XI.M18, No Consistent with NUREG-2191. The Bolting closure bolting "Bolting Integrity" Integrity AMP is used to manage cracking of exposed to air, soil, stainless steel closure bolting exposed to concrete, indoor uncontrolled air, outdoor air, and soil.

underground, waste water 3.3-1, 146 Stainless steel Cracking due to SCC AMP XI.M32, Yes (SRP-SLR Consistent with NUREG-2191 with underground piping, "One-Time Inspection," Section 3.3.2.2.3) exception for the Buried and piping components, AMP XI.M41, "Buried Underground Piping and Tanks AMP.

tanks and Underground Piping The Buried and Underground Piping and and Tanks," or AMP Tanks AMP is used to manage loss of XI.M42, material of stainless piping exposed to an "Internal underground environment.

Coatings/Linings for Further evaluation is document in In-Scope Piping, Piping Section 3.3.2.2.3.

Components, Heat Exchangers, and Tanks" 3.3-1, 147 Nickel alloy, nickel Loss of material due to AMP XI.M21A, No Not applicable.

alloy cladding pitting, crevice corrosion, "Closed Treated Water There are no nickel alloy or nickel alloy clad piping, piping MIC Systems" piping or piping components exposed to components closed-cycle cooling water in the Auxiliary exposed to Systems.

closed-cycle cooling water 3.3-1, 149 Fiberglass piping, Cracking, blistering, loss AMP XI.M36, No Not applicable.

piping components, of material due to "External Surfaces There are no fiberglass piping and piping ducting, ducting exposure to ultraviolet Monitoring of components in the Auxiliary Systems components light, ozone, radiation, Mechanical exposed to outdoor air that require aging exposed to air - temperature, or moisture Components" management.

outdoor

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 8 of 42 SLRA Table 3.3-1, page 3.3-74, is updated 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, 246 Stainless steel, Loss of material due to AMP XI.M32, Yes (SRP-SLR Consistent with NUREG-2191 with nickel alloy pitting, crevice corrosion "One-Time Inspection," Section 3.3.2.2.4) exception for the Buried and underground piping, AMP XI.M41, "Buried Underground Piping and Tanks AMP.

piping components, and Underground Piping The Buried and Underground Piping and tanks and Tanks," or AMP Tanks AMP is used to manage cracking of XI.M42, stainless steel piping components exposed "Internal to an underground environment.

Coatings/Linings for In-Scope Piping, Piping Further evaluation is documented in Components, Heat Section 3.3.2.2.4.

Exchangers, and Tanks" 3.3-1, 247 Aluminum piping, Loss of material due to AMP XI.M29, Yes (SRP-SLR Not applicable.

piping components, pitting, crevice corrosion "Outdoor and Large Section 3.3.2.2.10) There are no aluminum piping or piping tanks exposed to Atmospheric Metallic components exposed to raw water or waste raw water, waste Storage Tanks," AMP water in the Auxiliary Systems.

water XI.M32, "One-Time Inspection,"

AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components," or AMP XI.M42, "Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks" 3.3-1, 248 Aluminum piping, None None No Not used.

piping components, Boric acid corrosion is not an applicable tanks exposed to air aging effect for aluminum; the associated with borated water NUREG-2191 aging items are not used.

leakage

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 9 of 42 SLRA Table 3.3.2-4, page 3.3-119, is updated 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 Piping Pressure Carbon steel Treated water Loss of material Closed Treated VII.H2.AP-202 3.3-1, 045 A boundary (int) Water Systems (B.2.3.12)

Piping Pressure Carbon steel Underground Loss of material Buried and VII.I.AP-284 3.3-1, 109 AB boundary (ext) Underground Piping and Tanks (B.2.3.27)

Piping Pressure Copper alloy Air - dry (int) Loss of material Compressed Air VII.D.A-764 3.3-1, 235 A boundary Monitoring (B.2.3.14)

Piping Pressure Copper alloy Air - indoor None None VII.J.AP-144 3.3-1, 114 A boundary uncontrolled (ext)

Piping Pressure Copper alloy Fuel oil (int) Loss of material Fuel Oil Chemistry VII.H1.AP-132 3.3-1, 069 B boundary (B.2.3.18) A One-Time Inspection (B.2.3.20)

Piping Pressure Copper alloy Treated water Loss of material Closed Treated VII.H2.AP-199 3.3-1, 046 A boundary (int) Water Systems (B.2.3.12)

Piping Pressure Stainless steel Air - dry (int) Loss of material Compressed Air VII.D.A-764 3.3-1, 235 A boundary Monitoring (B.2.3.14)

Piping Pressure Stainless steel Air - indoor Cracking External Surfaces VII.H1.AP-209b 3.3-1, 004 A boundary uncontrolled (ext) Monitoring of Mechanical Components (B.2.3.23)

Piping Pressure Stainless steel Air - indoor Loss of material External Surfaces VII.H1.AP-221b 3.3-1, 006 A boundary uncontrolled (ext) Monitoring of Mechanical Components (B.2.3.23)

Piping Pressure Stainless steel Air - indoor Cracking Inspection of Internal VII.D.AP-209b 3.3-1, 004 A boundary uncontrolled (int) Surfaces in Miscellaneous Piping and Ducting Components (B.2.3.24)

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 10 of 42 SLRA Table 3.3.2-4, page 3.3-120, as updated by Supplement 1 Attachment 1, is updated 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 Piping Pressure Stainless steel Air - indoor Loss of material Inspection of Internal VII.H1.AP-221c 3.3-1, 006 A boundary uncontrolled (int) Surfaces in Miscellaneous Piping and Ducting Components (B.2.3.24)

Piping Pressure Stainless steel Fuel oil (int) Loss of material Fuel Oil Chemistry VII.H1.AP-136 3.3-1, 071 B boundary (B.2.3.18) A One-Time Inspection (B.2.3.20)

Piping Pressure Stainless steel Lubricating oil Loss of material Lubricating Oil VII.H2.AP-138 3.3-1, 100 A boundary (int) Analysis (B.2.3.25)

One-Time Inspection (B.2.3.20)

Piping Pressure Stainless steel Treated water Loss of material Closed Treated VII.C2.A-52 3.3-1, 049 A boundary (int) Water Systems (B.2.3.12)

Piping Pressure Stainless steel Underground Cracking Buried and VII.I.A-714b 3.3-1, 146 AB boundary (ext) Underground Piping and Tanks (B.2.3.27)

Piping Pressure Stainless steel Underground Loss of material Buried and VII.I.A-775b 3.3-1, 246 AB boundary (ext) Underground Piping and Tanks (B.2.3.27)

Piping (insulated) Pressure Carbon steel Air - indoor Loss of material External Surfaces VII.I.A-405a 3.3-1, 132 A boundary uncontrolled (ext) Monitoring of Mechanical Components (B.2.3.23)

Piping and piping Pressure Carbon steel Diesel exhaust Cumulative TLAA - Section VII.E1.A-34 3.3-1, 002 A components boundary (int) fatigue damage 4.3.2, Metal Fatigue of Non-Class 1 Components Piping and piping Pressure Stainless steel Diesel exhaust Cumulative TLAA - Section VII.E1.A-57 3.3-1, 002 A components boundary (int) fatigue damage 4.3.2, Metal Fatigue of Non-Class 1 Components

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 11 of 42 SLRA Table 3.3.2-5, page 3.3-135 is updated 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 Accumulator Pressure Carbon steel Air - outdoor (ext) Loss of material External Surfaces VII.I.A-77 3.3-1, 078 A boundary Monitoring of Mechanical Components (B.2.3.23)

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

Bolting Mechanical Carbon steel Air - indoor Loss of material Bolting Integrity VII.I.A-03 3.3-1, 012 A closure uncontrolled (ext) (B.2.3.9)

Bolting Mechanical Carbon steel Air - indoor Loss of preload Bolting Integrity VII.I.AP-124 3.3-1, 015 A closure uncontrolled (ext) (B.2.3.9)

Bolting Mechanical Carbon steel Air - outdoor (ext) Loss of material Bolting Integrity VII.I.A-03 3.3-1, 012 A closure (B.2.3.9)

Bolting Mechanical Carbon steel Air - outdoor (ext) Loss of preload Bolting Integrity VII.I.AP-124 3.3-1, 015 A closure (B.2.3.9)

Bolting Mechanical Carbon steel Soil (ext) Cracking Buried and VII.I.A-425 3.3-1, 144 CD closure Underground Piping and Tanks (B.2.3.27)

Bolting Mechanical Carbon steel Soil (ext) Loss of material Buried and VII.I.AP-241 3.3-1, 109 AB closure Underground Piping and Tanks (B.2.3.27)

Bolting Mechanical Carbon steel Soil (ext) Loss of preload Bolting Integrity VII.I.AP-124 3.3-1, 015 A closure (B.2.3.9)

Bolting Mechanical Cast iron Air - indoor Loss of material Bolting Integrity VII.I.A-03 3.3-1, 012 A closure uncontrolled (ext) (B.2.3.9)

Bolting Mechanical Cast iron Air - indoor Loss of preload Bolting Integrity VII.I.AP-124 3.3-1, 015 A closure uncontrolled (ext) (B.2.3.9)

Bolting Mechanical Cast iron Air - outdoor (ext) Loss of material Bolting Integrity VII.I.A-03 3.3-1, 012 A closure (B.2.3.9)

Bolting Mechanical Cast iron Air - outdoor (ext) Loss of preload Bolting Integrity VII.I.AP-124 3.3-1, 015 A closure (B.2.3.9)

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 12 of 42 SLRA Table 3.3.2-5, page 3.3-136 is updated 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 Bolting Mechanical Cast iron Soil (ext) Cracking Buried and VII.I.A-425 3.3-1, CD closure Underground Piping 144 and Tanks (B.2.3.27)

Bolting Mechanical Cast iron Soil (ext) Loss of material Buried and VII.I.AP-241 3.3-1, AB closure Underground Piping 109 and Tanks (B.2.3.27)

Bolting Mechanical Cast iron Soil (ext) Loss of material Selective Leaching VII.G.A-02 3.3-1, C closure (B.2.3.21) 072 Bolting Mechanical Cast iron Soil (ext) Loss of preload Bolting Integrity VII.I.AP-124 3.3-1, A closure (B.2.3.9) 015 Bolting Mechanical Stainless steel Air - indoor Cracking Bolting Integrity VII.I.A-426 3.3-1, A closure uncontrolled (ext) (B.2.3.9) 145 Bolting Mechanical Stainless steel Air - indoor Loss of material Bolting Integrity VII.I.A-03 3.3-1, A closure uncontrolled (ext) (B.2.3.9) 012 Bolting Mechanical Stainless steel Air - indoor Loss of preload Bolting Integrity VII.I.AP-124 3.3-1, A closure uncontrolled (ext) (B.2.3.9) 015 Bolting Mechanical Stainless steel Air - outdoor (ext) Cracking Bolting Integrity VII.I.A-426 3.3-1, A closure (B.2.3.9) 145 Bolting Mechanical Stainless steel Air - outdoor (ext) Loss of material Bolting Integrity VII.I.A-03 3.3-1, A closure (B.2.3.9) 012 Bolting Mechanical Stainless steel Air - outdoor (ext) Loss of preload Bolting Integrity VII.I.AP-124 3.3-1, A closure (B.2.3.9) 015 Bolting Mechanical Stainless steel Soil (ext) Cracking Buried and VII.I.A-425 3.3-1, CD closure Underground Piping 144 and Tanks (B.2.3.27)

Bolting Mechanical Stainless steel Soil (ext) Loss of material Buried and VII.I.AP-243 3.3-1, AB closure Underground Piping 108 and Tanks (B.2.3.27)

Bolting Mechanical Stainless steel Soil (ext) Loss of preload Bolting Integrity VII.I.AP-124 3.3-1, A closure (B.2.3.9) 015 Drip pan Direct flow Stainless steel Air - indoor Cracking External Surfaces VII.G.AP-209b 3.3-1, A uncontrolled (ext) Monitoring of 004 Mechanical Components (B.2.3.23)

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 13 of 42 SLRA Table 3.3.2-5, page 3.3-137 is updated 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 Drip pan Direct flow Stainless steel Air - indoor Loss of material External Surfaces VII.G.AP-221b 3.3-1, A uncontrolled (ext) Monitoring of 006 Mechanical Components (B.2.3.23)

Drip pan Direct flow Stainless steel Air - indoor Cracking Inspection of Internal VII.G.AP-209c 3.3-1, A uncontrolled (int) Surfaces in 004 Miscellaneous Piping and Ducting Components (B.2.3.24)

Drip pan Direct flow Stainless steel Air - indoor Loss of material Inspection of Internal VII.G.AP-221c 3.3-1, A uncontrolled (int) Surfaces in 006 Miscellaneous Piping and Ducting Components (B.2.3.24)

Drip pan Direct flow Stainless steel Lubricating oil (int) Loss of material Lubricating Oil VII.G.AP-138 3.3-1, C Analysis (B.2.3.25) 100 One-Time Inspection (B.2.3.20)

Fire hydrant Pressure Gray cast iron Air - outdoor (ext) Loss of material Fire Water System VII.G.AP-149 3.3-1, A boundary (B.2.3.16) 063 Fire hydrant Pressure Gray cast iron Air - outdoor (int) Loss of material Fire Water System VII.G.AP-149 3.3-1, A boundary (B.2.3.16) 063 Fire hydrant Pressure Gray cast iron Raw water (int) Long-term loss One-Time Inspection VII.G.A-532 3.3-1, A boundary of material (B.2.3.20) 193 Fire hydrant Pressure Gray cast iron Raw water (int) Loss of material Selective Leaching VII.G.A-51 3.3-1, A boundary (B.2.3.21) 072 Fire hydrant Pressure Gray cast iron Raw water (int) Loss of material Fire Water System VII.G.AP-149 3.3-1, A boundary Flow blockage (B.2.3.16) 063 Fire hydrant Pressure Gray cast iron Raw water (int) Wall thinning - Fire Water System VII.C1.A-409 3.3-1, E, 1 boundary erosion (B.2.3.16) 126 Fire hydrant Pressure Gray cast iron Soil (ext) Cracking Buried and VII.I.A-425 3.3-1, AB boundary Underground Piping 144 and Tanks (B.2.3.27)

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 14 of 42 SLRA Table 3.3.2-5, page 3.3-138 is updated 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 Fire hydrant Pressure Gray cast iron Soil (ext) Loss of material Buried and VII.I.AP-198 3.3-1, AB boundary Underground Piping 109 and Tanks (B.2.3.27)

Fire hydrant Pressure Gray cast iron Soil (ext) Loss of material Selective Leaching VII.G.A-02 3.3-1, A boundary (B.2.3.21) 072 Flame arrestor Fire Aluminum Air - indoor Cracking External Surfaces VII.G.A-451b 3.3-1, A prevention uncontrolled (ext) Monitoring of 189 Mechanical Components (B.2.3.23)

Flame arrestor Fire Aluminum Air - indoor Loss of material External Surfaces VII.H2.A-763b 3.3-1, A prevention uncontrolled (ext) Monitoring of 234 Mechanical Components (B.2.3.23)

Flame arrestor Fire Aluminum Air - indoor Cracking Inspection of Internal VII.G.A-451c 3.3-1, A prevention uncontrolled (int) Surfaces in 189 Miscellaneous Piping and Ducting Components (B.2.3.24)

Flame arrestor Fire Aluminum Air - indoor Loss of material Inspection of Internal VII.H2.A-763c 3.3-1, A prevention uncontrolled (int) Surfaces in 234 Miscellaneous Piping and Ducting Components (B.2.3.24)

Flame arrestor Fire Aluminum Lubricating oil (int) Loss of material Lubricating Oil VII.G.AP-162 3.3-1, A prevention Analysis (B.2.3.25) 099 One-Time Inspection (B.2.3.20)

Flame arrestor Fire Stainless steel Air - indoor Cracking External Surfaces VII.G.AP-209b 3.3-1, A prevention uncontrolled (ext) Monitoring of 004 Mechanical Components (B.2.3.23)

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 15 of 42 SLRA Table 3.3.2-5, page 3.3-145 is updated 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 Carbon steel Air - indoor Loss of material External Surfaces VII.I.A-77 3.3-1, A boundary uncontrolled (ext) Monitoring of 078 Mechanical Components (B.2.3.23)

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

Piping Pressure Carbon steel Air - outdoor (ext) Loss of material External Surfaces VII.I.A-77 3.3-1, A boundary Monitoring of 078 Mechanical Components (B.2.3.23)

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

Piping Pressure Carbon steel Concrete (ext) Cracking Buried and VII.I.A-425 3.3-1, AB boundary Underground Piping 144 and Tanks (B.2.3.27)

Piping Pressure Carbon steel Concrete (ext) Loss of material Buried and VII.I.AP-198 3.3-1, AB boundary Underground Piping 109 and Tanks (B.2.3.27)

Piping Pressure Carbon steel Lubricating oil (int) Loss of material Lubricating Oil VII.G.AP-127 3.3-1, A boundary Analysis (B.2.3.25) 097 One-Time Inspection (B.2.3.20)

Piping Pressure Carbon steel Raw water (ext) Loss of material Fire Water System VII.G.A-33 3.3-1, A boundary (B.2.3.16) 064 Piping Pressure Carbon steel Raw water (int) Long-term loss One-Time Inspection VII.G.A-532 3.3-1, A boundary of material (B.2.3.20) 193

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 16 of 42 SLRA Table 3.3.2-5, page 3.3-146 is updated 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 Carbon steel Raw water (int) Loss of material Fire Water System VII.G.A-33 3.3-1, A boundary Flow blockage (B.2.3.16) 064 Piping Pressure Carbon steel Raw water (int) Loss of material Inspection of Internal VII.C1.A-727 3.3-1, A boundary Flow blockage Surfaces in 134 Miscellaneous Piping and Ducting Components (B.2.3.24)

Piping Pressure Carbon steel Raw water (int) Wall thinning - Fire Water System VII.C1.A-409 3.3-1, E, 1 boundary erosion (B.2.3.16) 126 Piping Pressure Carbon 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 Pressure Carbon steel Soil (ext) Cracking Buried and VII.I.A-425 3.3-1, AB boundary Underground Piping 144 and Tanks (B.2.3.27)

Piping Pressure Carbon steel Soil (ext) Loss of material Buried and VII.I.AP-198 3.3-1, AB boundary Underground Piping 109 and Tanks (B.2.3.27)

Piping Pressure Coating Raw water (int) Loss of coating Internal VII.G.A-416 3.3-1, A boundary or lining integrity Coatings/Linings for 138 In-Scope Piping, Piping Components, Heat Exchangers, and Tanks (B.2.3.28)

Piping Pressure Coating Raw water (int) Loss of coating Internal VII.G.A-416 3.3-1, A boundary (cementitious) or lining integrity Coatings/Linings for 138 (cementitious) In-Scope Piping, Piping Components, Heat Exchangers, and Tanks (B.2.3.28)

Piping Pressure Copper alloy Air - indoor None None VII.J.AP-144 3.3-1, A boundary uncontrolled (ext) 114

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 17 of 42 SLRA Table 3.3.2-5, page 3.3-147 is updated 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 Copper alloy Air - outdoor (ext) None None VII.J.AP-144 3.3-1, A boundary 114 Piping Pressure Copper alloy Raw water (int) Loss of material Fire Water System VII.G.AP-197 3.3-1, A boundary Flow blockage (B.2.3.16) 064 Piping Pressure Copper alloy Raw water (int) Wall thinning - Fire Water System VII.C1.A-409 3.3-1, E, 1 boundary erosion (B.2.3.16) 126 Piping Pressure Copper alloy Air - indoor Cracking External Surfaces VIII.H.S-454 3.4-1, A boundary > 15% Zn uncontrolled (ext) Monitoring of 106 Mechanical Components (B.2.3.23)

Piping Pressure Copper alloy Air - indoor None None VII.J.AP-144 3.3-1, A boundary > 15% Zn uncontrolled (int) 114 Piping Pressure Copper alloy Air - outdoor (ext) Cracking External Surfaces VIII.H.S-454 3.4-1, A boundary > 15% Zn Monitoring of 106 Mechanical Components (B.2.3.23)

Piping Pressure Copper alloy Air - outdoor (int) None None VII.J.AP-144 3.3-1, A boundary > 15% Zn 114 Piping Pressure Ductile iron Air - outdoor (ext) Loss of material External Surfaces VII.I.A-77 3.3-1, A boundary Monitoring of 078 Mechanical Components (B.2.3.23)

Piping Pressure Ductile iron Concrete (ext) Loss of material Buried and VII.I.AP-198 3.3-1, AB boundary Underground Piping 109 and Tanks (B.2.3.27)

Piping Pressure Ductile iron Raw water (int) Long-term loss One-Time Inspection VII.G.A-532 3.3-1, A boundary of material (B.2.3.20) 193 Piping Pressure Ductile iron Raw water (int) Loss of material Selective Leaching VII.G.A-51 3.3-1, A boundary (B.2.3.21) 072 Piping Pressure Ductile iron Raw water (int) Loss of material Fire Water System VII.G.A-33 3.3-1, A boundary Flow blockage (B.2.3.16) 064 Piping Pressure Ductile iron Raw water (int) Wall thinning - Fire Water System VII.C1.A-409 3.3-1, E, 1 boundary erosion (B.2.3.16) 126

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 18 of 42 SLRA Table 3.3.2-5, page 3.3-148 is updated 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 Ductile iron Soil (ext) Cracking Buried and VII.I.A-425 3.3-1, AB boundary Underground Piping 144 and Tanks (B.2.3.27)

Piping Pressure Ductile iron Soil (ext) Loss of material Buried and VII.I.AP-198 3.3-1, AB boundary Underground Piping 109 and Tanks (B.2.3.27)

Piping Pressure Ductile iron Soil (ext) Loss of material Selective Leaching VII.G.A-02 3.3-1, A boundary (B.2.3.21) 072 Piping Pressure Galvanized Air - outdoor (ext) Loss of material External Surfaces VII.I.A-77 3.3-1, A boundary steel Monitoring of 078 Mechanical Components (B.2.3.23)

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

Piping Pressure Galvanized Raw water (int) Long-term loss One-Time Inspection VII.G.A-532 3.3-1, A boundary steel of material (B.2.3.20) 193 Piping Pressure Galvanized Raw water (int) Loss of material Fire Water System VII.G.A-33 3.3-1, A boundary steel Flow blockage (B.2.3.16) 064 Piping Pressure Galvanized Raw water (int) Wall thinning - Fire Water System VII.C1.A-409 3.3-1, E, 1 boundary steel erosion (B.2.3.16) 126 Piping Pressure Gray cast iron Air - indoor Loss of material External Surfaces VII.I.A-77 3.3-1, A boundary uncontrolled (ext) Monitoring of 078 Mechanical Components (B.2.3.23)

Piping Pressure Gray cast iron Air - outdoor (ext) Loss of material External Surfaces VII.I.A-77 3.3-1, A boundary Monitoring of 078 Mechanical Components (B.2.3.23)

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 19 of 42 SLRA Table 3.3.2-5, page 3.3-149 is updated 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 Gray cast iron Concrete (ext) Loss of material Buried and VII.I.AP-198 3.3-1, AB boundary Underground Piping 109 and Tanks (B.2.3.27)

Piping Pressure Gray cast iron Raw water (int) Long-term loss One-Time Inspection VII.G.A-532 3.3-1, A boundary of material (B.2.3.20) 193 Piping Pressure Gray cast iron Raw water (int) Loss of material Selective Leaching VII.G.A-51 3.3-1, A boundary (B.2.3.21) 072 Piping Pressure Gray cast iron Raw water (int) Loss of material Fire Water System VII.G.A-33 3.3-1, A boundary Flow blockage (B.2.3.16) 064 Piping Pressure Gray cast iron Raw water (int) Wall thinning - Fire Water System VII.C1.A-409 3.3-1, E, 1 boundary erosion (B.2.3.16) 126 Piping Pressure Gray cast iron Soil (ext) Cracking Buried and VII.I.A-425 3.3-1, AB boundary Underground Piping 144 and Tanks (B.2.3.27)

Piping Pressure Gray cast iron Soil (ext) Loss of material Buried and VII.I.AP-198 3.3-1, AB boundary Underground Piping 109 and Tanks (B.2.3.27)

Piping Pressure Gray cast iron Soil (ext) Loss of material Selective Leaching VII.G.A-02 3.3-1, A boundary (B.2.3.21) 072 Piping Pressure PVC/CPVC Air - indoor None None VII.J.AP-268 3.3-1, A boundary uncontrolled (ext) 119 Piping Pressure PVC/CPVC Air - indoor None None VII.J.AP-268 3.3-1, A boundary uncontrolled (int) 119 Piping Pressure Stainless steel Air - indoor Cracking External Surfaces VII.G.AP-209b 3.3-1, A boundary uncontrolled (ext) Monitoring of 004 Mechanical Components (B.2.3.23)

Piping Pressure Stainless steel Air - indoor Loss of material External Surfaces VII.G.AP-221b 3.3-1, A boundary uncontrolled (ext) Monitoring of 006 Mechanical Components (B.2.3.23)

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 20 of 42 SLRA Table 3.3.2-5, page 3.3-162 is updated 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 Ductile iron Air - outdoor (ext) Loss of material External Surfaces VII.I.A-77 3.3-1, A boundary Monitoring of 078 Mechanical Components (B.2.3.23)

Valve body Pressure Ductile iron Raw water (int) Long-term loss One-Time Inspection VII.G.A-532 3.3-1, A boundary of material (B.2.3.20) 193 Valve body Pressure Ductile iron Raw water (int) Loss of material Selective Leaching VII.G.A-51 3.3-1, A boundary (B.2.3.21) 072 Valve body Pressure Ductile iron Raw water (int) Loss of material Fire Water System VII.G.A-33 3.3-1, A boundary Flow blockage (B.2.3.16) 064 Valve body Pressure Ductile iron Raw water (int) Wall thinning - Fire Water System VII.C1.A-409 3.3-1, E, 1 boundary erosion (B.2.3.16) 126 Valve body Pressure Gray cast iron Air - indoor Loss of material External Surfaces VII.I.A-77 3.3-1, A boundary uncontrolled (ext) Monitoring of 078 Mechanical Components (B.2.3.23)

Valve body Pressure Gray cast iron Air - outdoor (ext) Loss of material External Surfaces VII.I.A-77 3.3-1, A boundary Monitoring of 078 Mechanical Components (B.2.3.23)

Valve body Pressure Gray cast iron Raw water (int) Long-term loss One-Time Inspection VII.G.A-532 3.3-1, A boundary of material (B.2.3.20) 193 Valve body Pressure Gray cast iron Raw water (int) Loss of material Selective Leaching VII.G.A-51 3.3-1, A boundary (B.2.3.21) 072 Valve body Pressure Gray cast iron Raw water (int) Loss of material Fire Water System VII.G.A-33 3.3-1, A boundary Flow blockage (B.2.3.16) 064 Valve body Pressure Gray cast iron Raw water (int) Wall thinning - Fire Water System VII.C1.A-409 3.3-1, E, 1 boundary erosion (B.2.3.16) 126 Valve body Pressure Gray cast iron Soil (ext) Cracking Buried and VII.I.A-425 3.3-1, AB boundary Underground Piping 144 and Tanks (B.2.3.27)

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 21 of 42 SLRA Table 3.3.2-5, page 3.3-163, as updated by Supplement 1 Attachment 21, is updated 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, AB boundary Underground Piping 109 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, A boundary (B.2.3.21) 072 Valve body Pressure Stainless steel Air - outdoor (ext) Cracking External Surfaces VII.G.AP-209b 3.3-1, A boundary Monitoring of 004 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, A boundary Monitoring of 006 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, A boundary Surfaces in 004 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, A boundary Surfaces in 006 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, A boundary Flow blockage (B.2.3.16) 066 Valve body Pressure Stainless steel Raw water (int) Wall thinning - Fire Water System VII.C1.A-409 3.3-1, E, 1 boundary erosion (B.2.3.16) 126 Valve body (halon) Pressure Carbon steel Air - outdoor (ext) Loss of material Fire Protection VII.G.AP-150 3.3-1, A (Unit 1 only) boundary (B.2.3.15) 058

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 22 of 42 SLRA, Section 3.3, page 3.3-165 is updated as follows:

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.

G. Environment not in NUREG-2191 for this component and material.

Plant Specific Notes

1. The Fire Water System AMP is used to manage the wall thinning due to erosion aging effect for fire protection components exposed to raw water.

2. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components AMP is used to manage the wall thinning due to erosion aging effect for service water components exposed to raw water.

3. The Fire Water System AMP is used to manage the cracking aging effect for copper alloy >15% Zn components internally exposed to raw water.

4. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components AMP is used to manage the cracking aging effect for copper alloy

>15% Zn components internally exposed to raw water.

5. The External Surfaces Monitoring of Mechanical Components AMP is used to manage loss of material for the external surfaces of the yard sump pump 2A.

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 23 of 42 SLRA Table 3.3.2-8, page 3.3-184 is updated as follows:

Table 3.3.2-8: Intake Cooling Water / Emergency Cooling Canal - 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 Bolting Mechanical Carbon steel Air - indoor Loss of material Bolting Integrity VII.I.A-03 3.3-1, A closure uncontrolled (B.2.3.9) 012 (ext)

Bolting Mechanical Carbon steel Air - indoor Loss of preload Bolting Integrity VII.I.AP-124 3.3-1, A closure uncontrolled (B.2.3.9) 015 (ext)

Bolting Mechanical Carbon steel Air - outdoor Loss of material Bolting Integrity VII.I.A-03 3.3-1, A closure (ext) (B.2.3.9) 012 Bolting Mechanical Carbon steel Air - outdoor Loss of preload Bolting Integrity VII.I.AP-124 3.3-1, A closure (ext) (B.2.3.9) 015 Bolting Mechanical Carbon steel Raw water (ext) Loss of material Bolting Integrity VII.I.A-423 3.3-1, A closure (B.2.3.9) 142 Bolting Mechanical Carbon steel Raw water (ext) Loss of preload Bolting Integrity VII.I.AP-124 3.3-1, A closure (B.2.3.9) 015 Bolting Mechanical Carbon steel Soil (ext) Loss of material Buried and VII.I.AP-241 3.3-1, AB closure Underground Piping 109 and Tanks (B.2.3.27)

Bolting Mechanical Carbon steel Soil (ext) Loss of preload Bolting Integrity VII.I.AP-124 3.3-1, A closure (B.2.3.9) 015 Bolting Mechanical Copper alloy > Raw water (ext) Loss of material Bolting Integrity VII.I.A-423 3.3-1, A closure 8% Al (B.2.3.9) 142 Bolting Mechanical Copper alloy > Raw water (ext) Loss of preload Bolting Integrity VII.I.AP-124 3.3-1, A closure 8% Al (B.2.3.9) 015 Bolting Mechanical Stainless steel Air - indoor Cracking Bolting Integrity VII.I.A-426 3.3-1, A closure uncontrolled (B.2.3.9) 145 (ext)

Bolting Mechanical Stainless steel Air - indoor Loss of material Bolting Integrity VII.I.A-03 3.3-1, A closure uncontrolled (B.2.3.9) 012 (ext)

Bolting Mechanical Stainless steel Air - indoor Loss of preload Bolting Integrity VII.I.AP-124 3.3-1, A closure uncontrolled (B.2.3.9) 015 (ext)

Bolting (Unit 1 only) Mechanical Stainless steel Air - outdoor Cracking Bolting Integrity VII.I.A-426 3.3-1, A closure (ext) (B.2.3.9) 145

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 24 of 42 SLRA Table 3.3.2-8, page 3.3-188 is updated as follows:

Table 3.3.2-8: Intake Cooling Water / Emergency Cooling Canal - 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 Orifice Throttle Stainless steel Raw water (int) Loss of material Open-Cycle Cooling VII.C1.A-54 3.3-1, A Flow blockage Water System 040 (B.2.3.11)

Orifice Throttle Stainless steel Raw water (int) Wall thinning - Open-Cycle Cooling VII.C1.A-409 3.3-1, E, 1 erosion Water System 126 (B.2.3.11)

Orifice (Unit 2 only) Pressure Stainless steel Air - indoor Cracking External Surfaces VII.C1.AP-209b 3.3-1, A boundary uncontrolled Monitoring of 004 (ext) Mechanical Components (B.2.3.23)

Orifice (Unit 2 only) Pressure Stainless steel Air - indoor Loss of material External Surfaces VII.C1.AP-221b 3.3-1, A boundary uncontrolled Monitoring of 006 (ext) Mechanical Components (B.2.3.23)

Piping Pressure Carbon steel Air - indoor Loss of material External Surfaces VII.I.A-77 3.3-1, A boundary uncontrolled Monitoring of 078 (ext) Mechanical Components (B.2.3.23)

Piping Pressure Carbon steel Air - outdoor Loss of material External Surfaces VII.I.A-77 3.3-1, A boundary (ext) Monitoring of 078 Mechanical Components (B.2.3.23)

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

Piping Pressure Carbon steel Concrete (ext) Cracking Buried and VII.I.A-425 3.3-1, AB boundary Underground Piping 144 and Tanks (B.2.3.27)

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 25 of 42 SLRA Table 3.3.2-8, page 3.3-189 is updated as follows:

Table 3.3.2-8: Intake Cooling Water / Emergency Cooling Canal - 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 Carbon steel Concrete (ext) Loss of material Buried and VII.I.AP-198 3.3-1, AB boundary Underground Piping 109 and Tanks (B.2.3.27)

Piping Pressure Carbon steel Raw water (ext) Long-term loss of One-Time Inspection VII.C1.A-532 3.3-1, A boundary material (B.2.3.20) 193 Piping Pressure Carbon steel Raw water (ext) Loss of material Open-Cycle Cooling VII.C1.A-400a 3.3-1, A boundary Water System 127 (B.2.3.11)

Piping Pressure Carbon steel Raw water (ext) Loss of material Open-Cycle Cooling VII.C1.AP-194 3.3-1, A boundary Water System 037 (B.2.3.11)

Piping Pressure Carbon steel Raw water (int) Long-term loss of One-Time Inspection VII.C1.A-532 3.3-1, A boundary material (B.2.3.20) 193 Piping Pressure Carbon steel Raw water (int) Loss of material Open-Cycle Cooling VII.C1.A-400a 3.3-1, A boundary Water System 127 (B.2.3.11)

Piping Pressure Carbon steel Raw water (int) Loss of material Open-Cycle Cooling VII.C1.AP-194 3.3-1, A boundary Flow blockage Water System 037 (B.2.3.11)

Piping Pressure Carbon steel Raw water (int) Wall thinning - Open-Cycle Cooling VII.C1.A-409 3.3-1, E, 1 boundary erosion Water System 126 (B.2.3.11)

Piping Pressure Carbon steel Soil (ext) Cracking Buried and VII.I.A-425 3.3-1, AB boundary Underground Piping 144 and Tanks (B.2.3.27)

Piping Pressure Carbon steel Soil (ext) Loss of material Buried and VII.I.AP-198 3.3-1, AB boundary Underground Piping 109 and Tanks (B.2.3.27)

Piping Pressure Coating Raw water (int) Loss of coating or Internal VII.C1.A-416 3.3-1, A boundary lining integrity Coatings/Linings for 138 In-Scope Piping, Piping Components, Heat Exchangers, and Tanks (B.2.3.28)

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 26 of 42 SLRA Table 3.3.2-8, page 3.3-193, as updated by Supplement 1 Attachments 24 and 25, is updated as follows:

Table 3.3.2-8: Intake Cooling Water / Emergency Cooling Canal - 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 Air - outdoor Cracking Inspection of Internal VII.C1.AP-209c 3.3-1, A boundary (int) Surfaces in 004 Miscellaneous Piping and Ducting Components (B.2.3.24)

Piping Pressure Stainless steel Air - outdoor Loss of material Inspection of Internal VII.C1.AP-221c 3.3-1, A boundary (int) Surfaces in 006 Miscellaneous Piping and Ducting Components (B.2.3.24)

Piping Pressure Stainless steel Raw water (int) Loss of material Inspection of Internal VII.C1.A-727 3.3-1, A boundary Flow blockage Surfaces in 134 Miscellaneous Piping and Ducting Components (B.2.3.24)

Piping Pressure Stainless steel Raw water (int) Loss of material Open-Cycle Cooling VII.C1.A-54 3.3-1, A boundary Flow blockage Water System 040 (B.2.3.11)

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 Pressure Stainless steel Raw water (int) Wall thinning - Open-Cycle Cooling VII.C1.A-409 3.3-1, E, 1 boundary erosion Water System 126 (B.2.3.11)

Piping (Unit 1 only) Pressure Stainless steel Soil (ext) Cracking Buried and VII.I.A-425 3.3-1, AB boundary Underground Piping 144 and Tanks (B.2.3.27)

Piping (Unit 1 only) Pressure Stainless steel Soil (ext) Loss of material Buried and VII.I.AP-137 3.3-1, AB boundary Underground Piping 107 and Tanks (B.2.3.27)

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 27 of 42 Table 3.3.2-8: Intake Cooling Water / Emergency Cooling Canal - 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 Concrete (ext) Cracking Buried and VII.I.A-425 3.3-1, AB boundary steel Underground 144 Piping and Tanks (B.2.3.27)

Piping Pressure Stainless Concrete (ext) Cracking Buried and VII.I.AP-137 3.3-1, AB boundary steel Underground 107 Piping and Tanks (B.2.3.27)

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 28 of 42 SLRA, Section 3.3, page 3.3-202 is updated 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.

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. The Open-Cycle Cooling Water AMP is used to manage wall thinning due to erosion for the interior surfaces of components within the service water system exposed to raw water within the scope of the GL 89-13 program.

2. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components AMP is used to manage wall thinning due to erosion for the interior surfaces of components within the intake cooling water system exposed to raw water not within the scope of the GL 89-13 program.

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 29 of 42 SLRA Table 3.3.2-9, page 3.3-203 is updated as follows:

Table 3.3.2-9: Primary Makeup 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 Bolting Mechanical Carbon steel Air - indoor Loss of material Bolting Integrity VII.I.A-03 3.3-1, 012 A closure uncontrolled (ext) (B.2.3.9)

Bolting Mechanical Carbon steel Air - indoor Loss of preload Bolting Integrity VII.I.AP-124 3.3-1, 015 A closure uncontrolled (ext) (B.2.3.9)

Bolting Mechanical Carbon steel Air - outdoor Loss of material Bolting Integrity VII.I.A-03 3.3-1, 012 A closure (ext) (B.2.3.9)

Bolting Mechanical Carbon steel Air - outdoor Loss of preload Bolting Integrity VII.I.AP-124 3.3-1, 015 A closure (ext) (B.2.3.9)

Bolting Mechanical Carbon steel Soil (ext) Loss of material Buried and VII.I.AP-241 3.3-1, 109 AB closure Underground Piping and Tanks (B.2.3.27)

Bolting Mechanical Carbon steel Soil (ext) Loss of preload Bolting Integrity VII.I.AP-124 3.3-1, 015 A closure (B.2.3.9)

Bolting Mechanical Stainless steel Air - indoor Cracking Bolting Integrity VII.I.A-426 3.3-1, 145 A closure uncontrolled (ext) (B.2.3.9)

Bolting Mechanical Stainless steel Air - indoor Loss of material Bolting Integrity VII.I.A-03 3.3-1, 012 A closure uncontrolled (ext) (B.2.3.9)

Bolting Mechanical Stainless steel Air - indoor Loss of preload Bolting Integrity VII.I.AP-124 3.3-1, 015 A closure uncontrolled (ext) (B.2.3.9)

Bolting Mechanical Stainless steel Air - outdoor Cracking Bolting Integrity VII.I.A-426 3.3-1, 145 A closure (ext) (B.2.3.9)

Bolting Mechanical Stainless steel Air - outdoor Loss of material Bolting Integrity VII.I.A-03 3.3-1, 012 A closure (ext) (B.2.3.9)

Bolting Mechanical Stainless steel Air - outdoor Loss of preload Bolting Integrity VII.I.AP-124 3.3-1, 015 A closure (ext) (B.2.3.9)

Bolting Mechanical Stainless steel Soil (ext) Cracking Bolting Integrity VII.I.A-426 3.3-1, 145 A closure (B.2.3.9)

Bolting Mechanical Stainless steel Soil (ext) Loss of material Buried and VII.I.AP-243 3.3-1, 108 AB closure Underground Piping and Tanks (B.2.3.27)

Bolting Mechanical Stainless steel Soil (ext) Loss of preload Bolting Integrity VII.I.AP-124 3.3-1, 015 A closure (B.2.3.9)

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 30 of 42 SLRA Table 3.3.2-9, page 3.3-206 is updated as follows:

Table 3.3.2-9: Primary Makeup 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 Nickel alloy Treated water Loss of material Water Chemistry VIII.E.SP-87 3.4-1, 085 A boundary (int) (B.2.3.2)

One-Time Inspection (B.2.3.20)

Piping Pressure Stainless steel Air - indoor Cracking External Surfaces VII.E1.AP-209b 3.3-1, 004 A boundary uncontrolled (ext) Monitoring of Mechanical Components (B.2.3.23)

Piping Pressure Stainless steel Air - indoor Loss of material External Surfaces VII.E1.AP-221b 3.3-1, 006 A boundary uncontrolled (ext) Monitoring of Mechanical Components (B.2.3.23)

Piping Pressure Stainless steel Air - outdoor Cracking External Surfaces VII.E1.AP-209b 3.3-1, 004 A boundary (ext) Monitoring of Mechanical Components (B.2.3.23)

Piping Pressure Stainless steel Air - outdoor Loss of material External Surfaces VII.E1.AP-221b 3.3-1, 006 A boundary (ext) Monitoring of Mechanical Components (B.2.3.23)

Piping Pressure Stainless steel Concrete (ext) Cracking Buried and VII.I.A-425 3.3-1, 144 AB boundary Underground Piping and Tanks (B.2.3.27)

Piping Pressure Stainless steel Concrete (ext) Loss of material Buried and VII.I.AP-137 3.3-1, 107 AB boundary Underground Piping and Tanks (B.2.3.27)

Piping Pressure Stainless steel Soil (ext) Cracking Buried and VII.I.A-425 3.3-1, 144 AB boundary Underground Piping and Tanks (B.2.3.27)

Piping Pressure Stainless steel Soil (ext) Loss of material Buried and VII.I.AP-137 3.3-1, 107 AB boundary Underground Piping and Tanks (B.2.3.27)

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 31 of 42 SLRA Table 3.3.2-12, page 3.3-222 is updated as follows:

Table 3.3.2-12: Ventilation - 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 Bolting Mechanical Carbon steel Air - indoor Loss of material Bolting Integrity VII.I.A-03 3.3-1, 012 A closure uncontrolled (B.2.3.9)

(ext)

Bolting Mechanical Carbon steel Air - indoor Loss of preload Bolting Integrity VII.I.AP-124 3.3-1, 015 A closure uncontrolled (B.2.3.9)

(ext)

Bolting Mechanical Stainless Air - indoor Cracking Bolting Integrity VII.I.A-426 3.3-1, 145 A closure steel uncontrolled (B.2.3.9)

(ext)

Bolting Mechanical Stainless Air - indoor Loss of material Bolting Integrity VII.I.A-03 3.3-1, 012 A closure steel uncontrolled (B.2.3.9)

(ext)

Bolting Mechanical Stainless Air - indoor Loss of preload Bolting Integrity VII.I.AP-124 3.3-1, 015 A closure steel uncontrolled (B.2.3.9)

(ext)

Demister Moisture Stainless Air - indoor Cracking Inspection of Internal VII.F1.AP-209c 3.3-1, 004 A removal steel uncontrolled (int) Surfaces in Miscellaneous Piping and Ducting Components (B.2.3.24)

Demister Moisture Stainless Air - indoor Loss of material Inspection of Internal VII.F1.AP-221c 3.3-1, 006 A removal steel uncontrolled (int) Surfaces in Miscellaneous Piping and Ducting Components (B.2.3.24)

Duct Pressure Ductile iron Air - indoor Loss of material Inspection of Internal VII.F3.A-778 3.3-1, 249 C boundary uncontrolled (int) Surfaces in Miscellaneous Piping and Ducting Components (B.2.3.24)

Duct Pressure Ductile iron Underground Loss of material Buried and VII.I.AP-284 3.3-1, 109 CD boundary (ext) Underground Piping and Tanks (B.2.3.27)

Duct Pressure Galvanized Air - indoor None None VII.J.AP-13 3.3-1, 116 C boundary steel uncontrolled (ext)

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 32 of 42 SLRA, Section 3.3, page 3.3-231 is updated as follows:

Table 3.3.2-12: Ventilation - 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 Stainless Air - indoor Cracking External Surfaces VII.F3.AP-209b 3.3-1, 004 A boundary steel uncontrolled Monitoring of (ext) Mechanical Components (B.2.3.23)

Valve body Pressure Stainless Air - indoor Loss of material External Surfaces VII.F3.AP-221b 3.3-1, 006 A boundary steel uncontrolled Monitoring of (ext) Mechanical Components (B.2.3.23)

Valve body Pressure Stainless Air - indoor Cracking Inspection of Internal VII.F1.AP-209c 3.3-1, 004 A boundary steel uncontrolled (int) Surfaces in Miscellaneous Piping and Ducting Components (B.2.3.24)

Valve body Pressure Stainless Air - indoor Loss of material Inspection of Internal VII.F1.AP-221c 3.3-1, 006 A boundary steel uncontrolled (int) Surfaces in Miscellaneous Piping and Ducting Components (B.2.3.24)

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.

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 None.

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 33 of 42 SLRA Table 3.4-1, page 3.4-23, as updated by Supplement 1 Attachment 25, is updated as follows:

Table 3.4-1: Summary of the 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, Copper alloy piping, Loss of material due to AMP XI.M39, No Not applicable.

043 piping components pitting, crevice "Lubricating Oil There are no copper alloy piping or piping exposed to lubricating corrosion, MIC Analysis," and AMP components exposed to lubricating oil in the oil XI.M32, Steam and Power Conversion Systems.

"One-Time Inspection" 3.4-1, Stainless steel piping, Loss of material due to AMP XI.M39, No Consistent with NUREG-2191. The Lubricating 044 piping components, pitting, crevice "Lubricating Oil Oil Analysis and One-Time Inspection AMPs heat exchanger corrosion, MIC Analysis," and AMP are used to manage the loss of material in components exposed to XI.M32, stainless steel heat exchanger components lubricating oil "One-Time Inspection" exposed to lubricating oil.

3.4-1, Aluminum heat Reduction of heat AMP XI.M39, No Not applicable.

045 exchanger tubes transfer due to fouling "Lubricating Oil There are no aluminum heat exchanger tubes exposed to lubricating Analysis," and AMP in the Steam and Power Conversion Systems.

oil XI.M32, "One-Time Inspection" 3.4-1, Stainless steel, steel, Reduction of heat AMP XI.M39, No Consistent with NUREG-2191. The Lubricating 046 copper alloy heat transfer due to fouling "Lubricating Oil Oil Analysis and One-Time Inspection AMPs exchanger tubes Analysis," and AMP are used to manage reduction of heat transfer exposed to lubricating XI.M32, in steel or stainless steel heat exchanger tubes oil "One-Time Inspection" exposed to lubricating oil.

3.4-1, Stainless steel piping, Loss of material due to AMP XI.M41, "Buried No Consistent with NUREG-2191 with exception.

047 piping components, pitting, crevice and Underground Piping This item is used for components in the tanks, closure bolting corrosion, MIC (soil and Tanks" Auxiliary Systems. The Buried and exposed to soil, only) Underground Piping and Tanks AMP is used to concrete manage loss of material in stainless steel piping exposed to soil or concrete.

3.4-1, Nickel alloy piping, Loss of material due to AMP XI.M41, "Buried No Not applicable.

048 piping components, pitting, crevice and Underground Piping There are no nickel alloy components in the tanks, closure bolting corrosion, MIC (soil and Tanks" Steam and Power Conversion Systems exposed to soil, only) exposed to soil or concrete.

concrete 3.4-1, Steel piping, piping Loss of material due to AMP XI.M41, "Buried No Consistent with NUREG-2191 with 050 components, tanks, general, pitting, crevice and Underground Piping exception. The Buried and Underground closure bolting exposed corrosion, MIC (soil and Tanks" Piping and Tanks AMP is used to manage to soil, concrete, only) loss of material for underground steel underground components.

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 34 of 42 SLRA Table 3.4-1, page 3.4-28, is updated as follows:

Table 3.4-1: Summary of the 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, Stainless steel, steel, Cracking due to SCC AMP XI.M41, "Buried No Consistent with NUREG-2191 with exception.

072 aluminum piping, piping (steel in and Underground Piping This item is used for components in the components, tanks carbonate/bicarbonate and Tanks" Auxiliary Systems. The Buried and exposed to soil, environment only) Underground Piping and Tanks AMP is used to concrete manage cracking of stainless steel piping exposed to concrete or soil.

3.4-1, Stainless steel closure Cracking due to SCC AMP XI.M18, No Consistent with NUREG-2191.

073 bolting exposed to air, "Bolting Integrity" The Bolting Integrity AMP is used to manage soil, concrete, cracking of stainless steel bolting exposed to underground, waste air.

water 3.4-1, Stainless steel Cracking due to SCC AMP XI.M32, Yes (SRP-SLR Not applicable.

074 underground piping, "One-Time Inspection," Section 3.4.2.2.2) There are no stainless steel underground piping components, AMP XI.M41, "Buried components in the Steam and Power tanks and Underground Piping Conversion Systems.

and Tanks," or AMP XI.M42, "Internal Coatings/Linings for In- Scope Piping, Piping Components, Heat Exchangers, and Tanks" 3.4-1, Stainless steel, steel, Reduction of heat AMP XI.M36, No Consistent with NUREG-2191.

075 aluminum, copper alloy, transfer due to fouling "External Surfaces This line item is used for heat exchanger fins in titanium heat exchanger Monitoring of the Auxiliary Systems. The External Surface tubes exposed to air, Mechanical Monitoring of Mechanical Components AMP is condensation Components" used to manage loss of material of copper alloy heat exchanger fins exposed to indoor uncontrolled air.

3.4-1, Elastomer piping, piping Hardening or loss of AMP XI.M36, No Not applicable.

077 components, seals strength due to "External Surfaces There are no elastomer components in the exposed to air, elastomer degradation Monitoring of Steam and Power Conversion Systems.

condensation Mechanical Components"

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 35 of 42 SLRA Table 3.4.2-3, page 3.4-71, as updated by Supplement 1 Attachment 25, is updated as follows:

Table 3.4.2-3: Auxiliary Feedwater and Condensate - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging Management Program NUREG-2191 Table 1 Notes Function Requiring Item Item Management Orifice (Unit 1 only) Leakage Stainless Treated water Wall thinning - Flow-Accelerated Corrosion VIII.G.S-408 3.4-1, A boundary steel (int) erosion (B.2.3.8) 060 (spatial)

Orifice (Unit 1 only) Leakage Stainless Treated water Cracking Water Chemistry (B.2.3.2) VIII.E.SP-88 3.4-1, A boundary steel >140°F (int) One-Time Inspection (B.2.3.20) 011 (spatial)

Piping Pressure Carbon Air - indoor Loss of material External Surfaces Monitoring of VIII.H.S-29 3.4-1, A boundary steel uncontrolled Mechanical Components 034 (ext) (B.2.3.23)

Piping Pressure Carbon Air - outdoor Loss of material External Surfaces Monitoring of VIII.H.S-29 3.4-1, A boundary steel (ext) Mechanical Components 034 (B.2.3.23)

Piping Pressure Carbon Air - outdoor Loss of material Inspection of Internal Surfaces in VIII.G.SP-59 3.4-1, A boundary steel (int) Miscellaneous Piping and 036 Ducting Components (B.2.3.24)

Piping Pressure Carbon Gas (int) None None VIII.I.SP-4 3.4-1, A boundary steel 059 Piping Pressure Carbon Treated water Loss of material Water Chemistry (B.2.3.2) VIII.E.SP-73 3.4-1, A boundary steel (int) One-Time Inspection (B.2.3.20) 014 Piping Pressure Carbon Treated water Wall thinning - Flow-Accelerated Corrosion VIII.G.S-408 3.4-1, A boundary steel (int) erosion (B.2.3.8) 060 Piping Pressure Carbon Treated water Wall thinning - Flow-Accelerated Corrosion VIII.G.S-16 3.4-1, A boundary steel (int) FAC (B.2.3.8) 005 Piping Pressure Stainless Air - indoor Cracking External Surfaces Monitoring of VIII.G.SP- 3.4-1, A boundary steel uncontrolled Mechanical Components 118b 002 (ext) (B.2.3.23)

Piping Pressure Stainless Air - indoor Loss of material External Surfaces Monitoring of VIII.G.SP- 3.4-1, A boundary steel uncontrolled Mechanical Components 127b 003 (ext) (B.2.3.23)

Piping Pressure Stainless Air - outdoor Cracking External Surfaces Monitoring of VIII.G.SP- 3.4-1, A boundary steel (ext) Mechanical Components 118b 002 (B.2.3.23)

Piping Pressure Stainless Air - outdoor Loss of material External Surfaces Monitoring of VIII.G.SP- 3.4-1, A boundary steel (ext) Mechanical Components 127b 003 (B.2.3.23)

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 36 of 42 Table 3.4.2-3: Auxiliary Feedwater and Condensate - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging Management Program NUREG-2191 Table 1 Notes Function Requiring Item Item Management Piping Pressure Carbon Underground Loss of Buried and VIII.H.SP-161 3.4-1, AB boundary steel (ext) material Underground 050 Piping and Tanks (B.2.3.27)

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 37 of 42 SLRA Table 3.4.2-3, page 3.4-72 is updated as follows:

Table 3.4.2-3: Auxiliary Feedwater and Condensate - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging Management Program NUREG-2191 Table 1 Notes Function Requiring Item Item Management Piping Pressure Stainless Concrete (ext) Cracking Buried and Underground Piping VIII.H.S-420 3.4-1, AB boundary steel and Tanks (B.2.3.27) 072 Piping Pressure Stainless Concrete (ext) Loss of material Buried and Underground Piping VIII.H.SP-145 3.4-1, AB boundary steel and Tanks (B.2.3.27) 047 Piping Pressure Stainless Soil (ext) Cracking Buried and Underground Piping VIII.H.S-420 3.4-1, AB boundary steel and Tanks (B.2.3.27) 072 Piping Pressure Stainless Soil (ext) Loss of material Buried and Underground Piping VIII.H.SP-145 3.4-1, AB boundary steel and Tanks (B.2.3.27) 047 Piping Pressure Stainless Treated water Loss of material Water Chemistry (B.2.3.2) VIII.G.SP-87 3.4-1, A boundary steel (int) One-Time Inspection (B.2.3.20) 085 Piping Pressure Stainless Treated water Wall thinning - Flow-Accelerated Corrosion VIII.G.S-408 3.4-1, A boundary steel (int) erosion (B.2.3.8) 060 Piping Pressure Stainless Treated water Cracking Water Chemistry (B.2.3.2) VIII.G.SP-88 3.4-1, A boundary steel >140°F (int) One-Time Inspection (B.2.3.20) 011 Piping (insulated) Pressure Stainless Air - outdoor Cracking External Surfaces Monitoring of VIII.H.S-452c 3.4-1, A boundary steel (ext) Mechanical Components 104 (B.2.3.23)

Piping (insulated) Pressure Stainless Air - outdoor Loss of material External Surfaces Monitoring of VIII.H.S-451c 3.4-1, A boundary steel (ext) Mechanical Components 103 (B.2.3.23)

Piping (insulated) Leakage Carbon Air - outdoor Loss of material External Surfaces Monitoring of VIII.H.S-402a 3.4-1, A (Unit 1 only) boundary steel (ext) Mechanical Components 063 (spatial) (B.2.3.23)

Piping (Unit 1 only) Leakage Carbon Air - outdoor Loss of material External Surfaces Monitoring of VIII.H.S-29 3.4-1, A boundary steel (ext) Mechanical Components 034 (spatial) (B.2.3.23)

Piping (Unit 1 only) Leakage Carbon Treated water Loss of material Water Chemistry (B.2.3.2) VIII.G.SP-74 3.4-1, A boundary steel (int) One-Time Inspection (B.2.3.20) 014 (spatial)

Piping (Unit 1 only) Leakage Carbon Treated water Wall thinning - Flow-Accelerated Corrosion VIII.G.S-408 3.4-1, A boundary steel (int) erosion (B.2.3.8) 060 (spatial)

Piping (Unit 1 only) Leakage Carbon Treated water Wall thinning - Flow-Accelerated Corrosion VIII.G.S-16 3.4-1, A boundary steel (int) FAC (B.2.3.8) 005 (spatial)

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 38 of 42 SLRA Section B.1.1, page B-6, as updated by Supplement 1 Attachments 10 and 18, is updated as follows:

x PSL Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components AMP (Section B.2.3.24),

x PSL Buried and Underground Piping and Tanks AMP (Section B.2.3.27),

x PSL Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks AMP (Section B.2.3.28),

x PSL Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements used in Instrumentation Circuits AMP (Section B.2.3.37),

x PSL Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements AMP (Section B.2.3.38),

x PSL Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements AMP (Section B.2.3.39),

x PSL Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements AMP (Section B.2.3.40),

x PSL Metal Enclosed Bus AMP (Section B.2.3.41),

x PSL Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements AMP (Section B.2.3.42), and x PSL High-Voltage Insulators AMP (Section B.2.3.43).

These new AMPs will be consistent with the 10 elements of their respective NUREG-2191 AMPs.

The following programs each have exception(s) justified by technical data:

x PSL Reactor Head Closure Stud Bolting AMP (Section B.2.3.3),

x Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (Section B.2.3.6),

x PSL Steam Generators AMP (Section B.2.3.10),

x PSL Outdoor and Large Atmospheric Metallic Storage Tank AMP (Section B.2.3.17),

x PSL Fuel Oil Chemistry AMP (Section B.2.3.18),

x PSL Reactor Vessel Material Surveillance AMP (Section B.2.3.19),

x PSL Buried and Underground Piping and Tanks AMP (Section B.2.3.27),

x PSL ASME Section XI, Subsection IWF AMP (Section B.2.3.30), and x PSL Structures Monitoring AMP (Section B.2.3.33)

B.1.2 Method of Discussion For those PSL AMPs that are consistent with the AMP descriptions and assumptions made in Sections X and XI of NUREG-2191, or are consistent with exceptions or enhancements, each AMP discussion is presented in the following format:

x A Program Description abstract of the overall program form and function is provided. This Program Description also includes whether the program is existing (and if it replaces LR programs) or new for SLR.

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 39 of 42 SLRA Table B-4, page B-21 is updated 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 Fire Protection B.2.3.15 No XI.M26 Yes No Fire Water System B.2.3.16 No XI.M27 Yes No Outdoor and Large B.2.3.17 No XI.M29 Yes Yes Atmospheric Metallic Storage Tanks Fuel Oil Chemistry B.2.3.18 No XI.M30 Yes Yes Reactor Vessel B.2.3.19 No XI.M31 No Yes Material Surveillance One-Time Inspection B.2.3.20 No XI.M32 New No Selective Leaching B.2.3.21 No XI.M33 New No ASME Code Class 1 B.2.3.22 No XI.M35 No No Small-Bore Piping External Surfaces B.2.3.23 No XI.M36 Yes No Monitoring of Mechanical Components Inspection of Internal B.2.3.24 No XI.M38 New No Surfaces in Miscellaneous Piping and Ducting Components Lubricating Oil B.2.3.25 No XI.M39 Yes No Analysis Monitoring of B.2.3.26 No XI.M40 Yes No Neutron-Absorbing Materials Other Than Boraflex Buried and B.2.3.27 No XI.M41 New No Underground Piping Yes and Tanks Internal B.2.3.28 No XI.M42 New No Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks ASME Section XI, B.2.3.29 No XI.S1 Yes No Subsection IWE ASME Section XI, B.2.3.30 No XI.S3 Yes Yes Subsection IWF 10 CFR Part 50, B.2.3.31 No XI.S4 No No Appendix J Masonry Walls B.2.3.32 No XI.S5 Yes No Structures B.2.3.33 No XI.S6 Yes Yes Monitoring

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 40 of 42 SLRA Appendix B, Section B.2.3.27, page B-216, as updated by Supplement 1 Attachments 7 and 25, is updated 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 10 years before the 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)

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 41 of 42

• 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.

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. Initial inspections begin 10 years before 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.

Exceptions to NUREG-2191 None. An exception to the NUREG-2191 recommendation of coating buried stainless steel as a preventive action will be taken with respect to the Unit 1 stainless steel AFW pump recirculation piping and condensate system (AFW pump suction) piping buried beneath the Unit 1 turbine building. This exception is justified due to the low number of chlorides within the soil, the low likelihood of stagnant moisture due to the concrete floor slab shielding, good soil/backfill drainage, and no history of negative OE for buried stainless steel piping at St. Lucie.

St. Lucie Units 1 and 2 Dockets 50-335 and 50-389 PSL Response to NRC RAI No. B.2.3.27-1a L-2022-143 Attachment 1 Page 42 of 42 Associated

Enclosures:

None.