L-25-094, License Renewal Application for Revision 0 - Supplement 9
| ML25112A167 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 04/22/2025 |
| From: | Penfield R Vistra Operations Company |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| L-25-094 | |
| Download: ML25112A167 (1) | |
Text
L-25-094 April 22, 2025 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Perry Nuclear Power Plant, Unit No. 1 Docket No. 50-440, License No. NPF-58 Perry Nuclear Power Plant Rod L. Penfield Site Vice President 1 O Center Road Perry, Ohio 44081 10 CFR 54 License Renewal Application for the Perry Nuclear Power Plant Revision 0 - Supplement 9
REFERENCES:
- 1. Letter L-23-146, from Rod L. Penfield to the Nuclear Regulatory Commission, dated July 3, 2023, submitting the Perry Nuclear Power Plant License Renewal Application Revision O (ADAMS Accession No. ML23184A081)
- 2. Nuclear Regulatory Commission issuance of Conforming License Amendment 203 to Facility Operating License NPF-58 (Enclosure 1) for the license transfer for the Perry Nuclear Power Plant (ADAMS Accession Nos. ML24057A075 and ML24057A077)
- 3. Letter L-24-110, from Rod L. Penfield to the Nuclear Regulatory Commission, dated July 3, 2024, submitting 10 CFR 54.21(b) Annual Amendment to the Perry Nuclear Power Plant License Renewal Application (ADAMS Accession No. ML24185A092)
- 4. Letter from Lauren K. Gibson to Rod L. Penfield, Perry Nuclear Power Plant, Unit No. 1 dated September 25, 2023 - Aging Management Audit Plan Regarding the License Renewal Application Review (ADAMS Accession No. ML232618019)
- 5. Letter L-24-189, from Rod L. Penfield to the Nuclear Regulatory Commission, dated August 7, 2024, submitting the Perry Nuclear Power Plant License Renewal Application Revision 0, Supplement 1 (Non-Proprietary) (ADAMS Accession No. ML24220A270) 6555 SIERRA DRIVE IRVING, TEXAS 75039 o 214-812-4600 VISTRACORP.COM
Perry Nuclear Power Plant L-25-094 Page 2 of 4
- 6. Letter L-24-020, from Rod L. Penfield to the Nuclear Regulatory Commission, dated June 27, 2024, submitting the Perry Nuclear Power Plant License Renewal Application Revision 0, Supplement 2 (ADAMS Accession No. ML24180A010)
- 7. Letter L-24-108, from Rod L. Penfield to the Nuclear Regulatory Commission, dated July 24, 2024, submitting the Perry Nuclear Power Plant License Renewal Application Revision 0, Supplement 3 (ADAMS Accession No. ML24206A150)
- 8. Letter L-24-200, from Rod L. Penfield to the Nuclear Regulatory Commission, dated September 5, 2024, submitting the Perry Nuclear Power Plant License Renewal Application Revision 0, Supplement 4 Revision 1 (ADAMS Accession No. ML24249A123)
- 9. Letter L-24-179, from Rod L. Penfield to the Nuclear Regulatory Commission, dated October 21, 2024, submitting the Perry Nuclear Power Plant License Renewal Application Revision 0, Supplement 5 (ADAMS Accession No. ML24295A352)
- 10. Letter L-24-243 from Rod L. Penfield to the Nuclear Regulatory Commission, dated November 7, 2024, submitting the Perry Nuclear Power Plant License Renewal Application Revision 0, Supplement 6 (ADAMS Accession No. ML24312A368)
- 11. Letter L-24-256 from Rod L. Penfield to the Nuclear Regulatory Commission, dated December 19, 2024, submitting the Perry Nuclear Power Plant License Renewal Application Revision 0, Supplement 7 (ADAMS Accession No. ML24354A265)
- 12. Letter L-25-013 from Rod L. Penfield to the Nuclear Regulatory Commission, dated January 27, 2025, submitting the Perry Nuclear Power Plant License Renewal Application Revision 0, Supplement 8 (ADAMS Accession No. ML25027A327)
- 13. Letter L-24-207, from Rod L. Penfield to the Nuclear Regulatory Commission, dated September 16, 2024, submitting the License Renewal Application for the Perry Nuclear Power Plant-Response to Request for Additional Information - Set 1 (ADAMS Accession No. ML24260A266)
- 14. Letter L-24-208, from Rod L. Penfield to the Nuclear Regulatory Commission, dated October 2, 2024, submitting the License Renewal Application for the Perry Nuclear Power Plant -
Response to Request for Additional Information - Set 2 (ADAMS Accession No. ML24276A083)
- 15. Letter L-24-209, from Rod L. Penfield to the Nuclear Regulatory Commission, dated November 19, 2024, submitting the License Renewal Application for the Perry Nuclear Power Plant-Response to Request for Additional Information - Set 3 (ADAMS Accession No.
M L24324A 185)
- 16. Letter L-25-012, from Rod L. Penfield to the Nuclear Regulatory Commission, dated February 5, 2025, submitting the License Renewal Application for the Perry Nuclear Power Plant
- Response to Request for Additional Information - Set 4 (ADAMS Accession No. ML25036A154)
- 17. Letter L-25-042, from Rod L. Penfield to the Nuclear Regulatory Commission, dated March 20, 2025, submitting the License Renewal Application for the Perry Nuclear Power Plant -
Response to Request for Additional Information - Set 5 (ADAMS Accession No. ML25079A062) 6555 SIERRA DRIVE IRVING, TEXAS 75039 o 214-812-4600 VISTRACORP.COM
Perry Nuclear Power Plant L-25-094 Page 3 of 4
- 18. Letter L-24-226, from Rod L. Penfield to the Nuclear Regulatory Commission, dated October 31, 2024, submitting the License Renewal Application for the Perry Nuclear Power Plant
- Response to Requests for Confirmatory Information - Set 1 (ADAMS Accession No. ML24305A134)
- 19. Letter L-24-257, from Rod L. Penfield to the Nuclear Regulatory Commission, dated December 4, 2024, submitting the License Renewal Application for the Perry Nuclear Power Plant - Response to Requests for Confirmatory Information - Set 2 (ADAMS Accession No. ML24339A066)
- 20. Letter L-25-017, from Rod L. Penfield to the Nuclear Regulatory Commission, dated January 30, 2025, submitting the License Renewal Application for the Perry Nuclear Power Plant
- Response to Requests for Confirmatory Information - Set 3 (ADAMS Accession No. ML25030A014)
On July 3, 2023, Energy Harbor Nuclear Corp. submitted a license renewal application (LRA) for the Facility Operating License for the Perry Nuclear Power Plant, Unit No. 1 (PNPP) (Reference 1).
Subsequent to the submittal of the PNPP LRA, the PNPP Facility Operating License has been transferred to Vistra Operations Company LLC (VistraOps) per conforming license Amendment 203 and the license transfer transaction was closed on March 1, 2024 (Reference 2). The license transfer changes impacting the PNPP LRA are documented in the annual amendment required by 10 CFR 54.21 (b), submitted on July 3, 2024 (Reference 3).
During the Nuclear Regulatory Commission (NRC) staff's aging management audit of the PNPP LRA (Reference 4), the PNPP Staff agreed to supplement the LRA with clarifying information which has led to several LRA supplements (References 5 through 12). In addition, as a result of the NRC's review and audit of the PNPP LRA, the NRC Staff has submitted and the PNPP Staff responded to five sets of Requests for Additional Information (RAls) (References 13 through 17) and three sets of Requests for Confirmatory Information (RCls) (References 18 through 20).
Following submittal of Supplement 8 of the PNPP LRA (Reference 12) and following discussions with NRC Staff, PNPP agreed to further supplement the PNPP LRA with additional information related to aging management activities regarding a subset of in-scope stainless steel flexible hoses. The attachments to this letter provide Supplement 9 to the PNPP LRA, which incorporates the applicable updates to the External Surfaces Monitoring of Mechanical Components Program regarding stainless steel flexible hoses to accommodate the NRC Staff's review. In addition, the attached Supplement 9 incorporates recent operating experience identified for the Structures Monitoring Program identified from the current licensing basis (CLB) review pursuant to 10 CFR 54.21 (b) for the PNPP LRA.
An attachments index is provided for ease of reference that lists the supplemented PNPP LRA sections and tables, and a reason for each update.
The commitment provided in the PNPP LRA Appendix A (Table A.3) that is supplemented is indicated in the associated attachment. If there are any questions or if additional information is required, please contact Mr. Mark Bensi, PNPP License Renewal Manager at (440) 280-6179 or via email at Mark.Bensi@vistracorp.com.
6555 SIERRA DRIVE IRVING, TEXAS 75039 o 214-812-4600 VISTRACORP.COM
Perry Nuclear Power Plant L-25-094 Page 4 of 4 I declare under penalty of perjury that the foregoing is true and correct. Executed on April 22, 2025.
Rod L. Penfield Attachments PNPP LRA Supplement 9 cc:
NRC Region Ill Administrator NRC Resident Inspector NRR Project Manager Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)
Utility Radiological Safety Board 6555 SIERRA DRIVE IRVING, TEXAS 75039 o 214-812-4600 VISTRACORP.COM
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachments Index Page 1 of 2 Perry Nuclear Power Plant (PNPP)
License Renewal Application (LRA)
Supplement 9 Attachments Index for Miscellaneous Supplemented LRA Sections and Tables Attachment No.
LRA Section, Table Updated Reason for LRA Update 1
Section 3.3.2.1.4 Table 3.3.2-4 Update to incorporate flexible hose aging management details to accommodate the NRC Staffs review 2
Section 3.3.2.1.15.1 Table 3.3.2-15a Update to incorporate flexible hose aging management details to accommodate the NRC Staffs review 3
Section 3.3.2.1.43 Table 3.3.2-43 Update to incorporate flexible hose aging management details to accommodate the NRC Staffs review 4
Section 3.3.2.1.54 Table 3.3.2-54 Update to incorporate flexible hose aging management details to accommodate the NRC Staffs review 5
Table 3.3.1 Update to incorporate flexible hose aging management details to accommodate the NRC Staffs review 6
Standard Notes for Tables 3.1.2-1 through Table 3.1.2-63 Update to table plant-specific notes to incorporate flexible hose aging management and replacement details to accommodate the NRC Staffs review 7
Appendix A Section A.1.18 External Surfaces Monitoring of Mechanical Components Program update for flexible hose aging management and replacement details to accommodate the NRC Staffs review 8
Appendix A Table A.3 External Surfaces Monitoring of Mechanical Components Program update to incorporate flexible hose periodic replacement to accommodate the NRC Staffs review 9
Appendix B Section B.2.18 External Surfaces Monitoring of Mechanical Components Program update for flexible hose aging management, replacement and operating experience extent of condition details 10 Appendix B Section B.2.43 Structures Monitoring Program operating experience update for diesel generator roof leakage identified from the current licensing basis (CLB) review conducted for the second annual update to the PNPP LRA
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachments Index Page 2 of 2 The attachments incorporate the PNPP LRA changes made via the LRA supplements, the annual update and the Request for Additional Information (RAI) responses, which were submitted via the following Vistra correspondence:
In addition to the above supplements, the annual update and the RAI responses, the following letters provided responses to the two sets of Requests for Confirmatory Information (RCIs) received:
Therefore, the LRA updates depicted in the attachments are made on clean LRA pages that reflect the LRA updates from the previously docketed Vistra correspondence listed above.
Revisions to LRA tables may be shown by providing excerpts from each affected table, i.e., only the affected parts of the table may be included in the attachment.
Consistent with the PNPP LRA updates from the previously docketed Vistra correspondence listed above, changes for the attachments are indicated by red, bolded and underlined text for added text and strikethrough for text to be deleted.
Note that text editing changes to some of the attachments such as spacing, font consistency changes etc., are not indicated via coloring as these are inconsequential.
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 1 Page 1 of 3 LRA Section: Section 3.3.2.1.4 and Table 3.3.2-4 LRA Page Number(s): Pages 3.3-8 and 3.3-158
References:
Attachments 7 and 9 to this LRA supplement Description of Change: The Perry Nuclear Power Plant License Renewal Application (LRA)
Section 3.3.2.1.4 is updated to add Cracking to the list of Aging Effects Requiring Management to reflect the periodic replacement of the applicable stainless steel flexible hoses, subject to the aging effect of Cracking. This update is consistent the latest revision to the Aging Management Program (AMP) External Surfaces Monitoring of Mechanical Components Program (XI.M36) and the update to PNPP LRA Sections A.1.18 and B.2.18, reference Attachments 7 and 9 to this LRA supplement.
In addition, LRA Table 3.3.2-4 Row 13 is updated to replace the aging effect None with Cracking and the AMP, None with External Surfaces Monitoring of Mechanical Components, and the Standard Note is replaced with H and new Plant Specific Note 344.
PNPP Chapter 3, Section 3.3.2.1.4, Page 3.3-8 is revised as follows:
3.3.2.1.4 Combustible Gas Control Materials Combustible Gas Control system components are constructed of the following materials:
CASS Copper alloy <15% Zn Glass Gray cast iron Stainless steel Steel Environments Combustible Gas Control system components are exposed to the following environments:
Air - indoor, uncontrolled Closed-cycle cooling water Gas Lubricating oil Treated water
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 1 Page 2 of 3 Aging Effects Requiring Management The following aging effects associated with the Combustible Gas Control system components require management:
Cracking Loss of material Loss of preload Reduction of heat transfer Aging Management Programs The following aging management programs manage the effects of aging on Combustible Gas Control system components:
Bolting Integrity (B.2.7)
Closed Treated Water Systems (B.2.15)
External Surfaces Monitoring of Mechanical Components (B.2.18)
Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.25)
Lubricating Oil Analysis (B.2.28)
One-Time Inspection (B.2.35)
Water Chemistry (B.2.44)
PNPP Chapter 3, Table 3.3.2-4, Page 3.3-158, is revised as follows on the next page:
Note: Only rows with content changes are provided.
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 1 Page 3 of 3 Table 3.3.2-4 Auxiliary Systems - Combustible Gas Control Summary of Aging Management Evaluation Table3.3.2 Combustible Gas Control System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 13 Flexible hose Pressure boundary Stainless steel Air - indoor, uncontrolled (Ext)
Cracking None External Surfaces Monitoring of Mechanical Components None VII.J.AP-17 3.3.1-120 H, 344 A
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 2 Page 1 of 3 LRA Section: Section 3.3.2.1.15.1 and Table 3.3.2-15a LRA Page Number(s): Page 3.3-18 and 19 and Page 3.3-223
References:
Attachments 7 and 9 to this LRA supplement.
Description of Change: The Perry Nuclear Power Plant License Renewal Application (LRA)
Section 3.3.2.1.15.1 is updated to add Cracking to the list of Aging Effects Requiring Management to reflect the periodic replacement of the applicable stainless steel flexible hoses, subject to the aging effect of Cracking. This update is consistent with the latest revision to the Aging Management Program (AMP) External Surfaces Monitoring of Mechanical Components Program (XI.M36) and the update to PNPP LRA Sections A.1.18 and B.2.18, reference Attachments 7 and 9 to this LRA supplement.
In addition, Table 3.3.2-15a is updated to add new Row 12 to address cracking in the stainless steel flexible hoses and revised new Row 13. In new Row 13 replaced the aging effect and AMP, both listed as None, with Cracking and External Surfaces Monitoring of Mechanical Components, respectively. See new Plant Specific Notes 344 and 345 in Attachment 6 to this LRA supplement. The remaining rows were renumbered by incrementing the existing row number by 1.
PNPP Chapter 3, Section 3.3.2.1.15.1, Page 3.3-18 and 3.3-19 is revised as follows:
3.3.2.1.15 Diesel Generator and Auxiliaries 3.3.2.1.15.1 Starting Air and Control Air Materials Starting Air and Control Air system components are constructed of the following materials:
Copper alloy <15% Zn
Copper alloy >15% Zn
Glass
Stainless steel
Steel
Zinc Environments Starting Air and Control Air system components are exposed to the following environments:
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 2 Page 2 of 3
Air - dry
Air - indoor, uncontrolled
Condensation
Lubricating oil Aging Effects Requiring Management The following aging effects associated with the Starting Air and Control Air system require management:
Cracking
Loss of material
Loss of preload Aging Management Programs The following aging management programs manage the effects of aging on Starting Air and Control Air system components:
Bolting Integrity (B.2.7)
Compressed Air Monitoring (B.2.16)
External Surfaces Monitoring of Mechanical Components (B.2.18)
Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.25)
Lubricating Oil Analysis (B.2.28)
One-Time Inspection (B.2.35)
PNPP Chapter 3, Table 3.3.2-15a, Page 3.3-223, is revised as follows on the next page:
Note: Only rows with content changes are provided. The remaining rows without content changes were renumbered by incrementing the existing row number by 1.
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 2 Page 3 of 3 Table 3.3.2-15a Auxiliary Systems - Diesel Generator and Auxiliaries - Starting Air and Control Air Summary of Aging Management Evaluation Table 3.3.2-15a - Diesel Generator and Auxiliaries - Starting Air and Control Air Systems Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 12 Flexible hose Pressure boundary Stainless steel Air - indoor, uncontrolled (Ext)
Cracking External Surfaces Monitoring of Mechanical Components VII.J.AP-17 3.3.1-120 H, 344 13 12 Flexible hose Pressure boundary Stainless Steel Air - indoor, uncontrolled (Ext)
None None VII.J.AP-17 3.3.1-120 A, 345
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 3 Page 1 of 3 LRA Section: Section 3.3.2.1.43 and Table 3.3.2-43 LRA Page Number(s): Pages 3.3-47, 3.3-48 and 3.3-388
References:
Attachments 7 and 9 to this LRA supplement.
Description of Change: The Perry Nuclear Power Plant License Renewal Application (LRA)
Section 3.3.2.1.43 is updated to add Cracking to the list of Aging Effects Requiring Management to reflect the periodic replacement of the applicable stainless steel flexible hoses, subject to the aging effect of Cracking. This update is consistent with the latest revision to the Aging Management Program (AMP) External Surfaces Monitoring of Mechanical Components Program (XI.M36) and the update to PNPP LRA Sections A.1.18 and B.2.18 (reference Attachments 7 and 9 to this LRA supplement).
In addition, LRA Table 3.3.2-43 Row 6 is updated to replace the aging effect and AMP None with Cracking and External Surfaces Monitoring of Mechanical Components, respectively.
Also, Standard Note A replaced with H and new Plant Specific Note 344 is added (reference to this LRA supplement).
PNPP Chapter 3, Section 3.3.2.1.43, Pages 3.3-47 and 48 are revised as follows:
3.3.2.1.43 Penetration Pressurization Materials Penetration Pressurization system components are constructed of the following materials:
Copper alloy <15% Zn
Copper alloy >15% Zn
Stainless steel
Steel Environments Penetration Pressurization system components are exposed to the following environments:
Air - dry
Air - indoor, uncontrolled Aging Effects Requiring Management The following aging effects associated with the Penetration Pressurization system require management:
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 3 Page 2 of 3
Cracking
Loss of material
Loss of preload Aging Management Programs The following aging management programs manage the effects of aging on Penetration Pressurization system components:
Bolting Integrity (B.2.7)
Compressed Air Monitoring (B.2.16)
External Surfaces Monitoring of Mechanical Components (B.2.18)
PNPP Chapter 3, Table 3.3.2-43, Page 3.3-388, as supplemented by Supplement 2 in in Vistra Letter L-24-020 (pdf page 59) is revised as follows on the next page:
Note: Only rows with content changes are provided.
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 3 Page 3 of 3 Table 3.3.2-43 Auxiliary Systems - Penetration Pressurization Summary of Aging Management Evaluation Table3.3.2 Penetration Pressurization System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 6
Flexible hose Pressure boundary Stainless steel Air - indoor, uncontrolled (Ext)
Cracking None External Surfaces Monitoring of Mechanical Components None VII.J.AP-17 3.3.1-120 H, 344 A
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 4 Page 1 of 3 LRA Section: Section 3.3.2.1.54 and Table 3.3.2-54 LRA Page Number(s): Pages 3.3-57 and 3.3-58 and 3.3-428
References:
Attachments 7 and 9 to this LRA supplement Description of Change: The Perry Nuclear Power Plant License Renewal Application (LRA)
Section 3.3.2.1.54 is updated to add Cracking to the list of Aging Effects Requiring Management to reflect the periodic replacement of the applicable stainless steel flexible hoses, subject to the aging effect of Cracking. This update is consistent with the latest revision to the Aging Management Program (AMP) External Surfaces Monitoring of Mechanical Components Program (XI.M36) and the update to PNPP LRA Sections A.1.18 and B.2.18 (reference Attachments 7 and 9 to this LRA supplement).
In addition, LRA Table 3.3.2-54 Row 10 is updated to replace aging effect and AMP None with Cracking and External Surfaces Monitoring of Mechanical Components, respectively.
Standard Note A replaced with H and new Plant Specific Note 344 is added (reference to this LRA supplement).
PNPP Chapter 3, Section 3.3.2.1.54, Pages 3.3-57 and 3.3-58 is revised as follows:
3.3.2.1.54 Service Air and Instrument Air Materials Service Air and Instrument Air system components are constructed of the following materials:
Aluminum Copper alloy <15% Zn Copper alloy >15% Zn Glass Stainless steel Steel Environments Service Air and Instrument Air system components are exposed to the following environments:
Air - dry Air - indoor, uncontrolled Condensation
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 4 Page 2 of 3
Lubricating oil Aging Effects Requiring Management The following aging effects associated with the Service Air and Instrument Air system require management:
Cracking
Loss of material
Loss of preload Aging Management Programs The following aging management programs manage the effects of aging on Service Air and Instrument Air system components:
Bolting Integrity (B.2.7)
Compressed Air Monitoring (B.2.16)
External Surfaces Monitoring of Mechanical Components (B.2.18)
Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.25)
Lubricating Oil Analysis (B.2.28)
One-Time Inspection (B.2.35)
PNPP Chapter 3, Table 3.3.2-54, Page 3.3-428, is revised as follows on the next page:
Note: Only rows with content changes are provided.
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 4 Page 3 of 3 Table 3.3.2-54 Auxiliary Systems - Service Air and Instrument Air Summary of Aging Management Evaluation Table3.3.2 Service Air and Instrument Air Systems Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 10 Flexible hose Pressure boundary Stainless steel Air - indoor, uncontrolled (Ext)
Cracking None External Surfaces Monitoring of Mechanical Components None VII.J.AP-17 3.3.1-120 H, 344 A
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 5 Page 1 of 3 LRA Section: Table 3.3.1, Item 3.3.1-120 LRA Page Number(s): Page 3.3-135
References:
Attachments 7 and 9 to this LRA supplement.
Description of Change: The Perry Nuclear Power Plant License Renewal Application (LRA)
Table 3.3.1, Item 3.3.1-120 Discussion is updated to reflect the periodic replacement of the applicable stainless steel flexible hoses, subject to the aging effect of Cracking consistent with the latest revision to the Aging Management Program (AMP) External Surfaces Monitoring of Mechanical Components Program (XI.M36) and the update to PNPP LRA Sections A.1.18 and B.2.18 (reference Attachments 7 and 9 to this LRA supplement).
PNPP Chapter 3, Table 3.3.1, Item 3.3.1-120, Page 3.3-135 is revised as follows: (see following pages)
Note: Only the line item that has changed is provided on the next page.
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 5 Page 2 of 3 Table 3.3.1: Summary of Aging Management Evaluations for the Auxiliary Systems Item Number Component Aging Effect/
Mechanism Aging Management Programs Further Evaluation Recommended Discussion 3.3.1-120 Stainless steel Piping, piping components, and piping elements exposed to Air -
indoor, uncontrolled (Internal/External),
Air - indoor, uncontrolled (External), Air with borated water leakage, Concrete, Air - dry, Gas None None NA - No AEM or AMP Consistent with NUREG-1801 for most components with the following clarifications and a different program. For components exposed to dried air downstream of air dryers, the Compressed Air Monitoring program is assigned to ensure that the environment will remain dry and free of contaminants supporting the conclusion that no aging effects are expected. External Surfaces Monitoring of Mechanical Components program will manage cracking due stress corrosion cracking conservatively assigned to Flexible hoses exposed to concentration of chloride contaminants from periodic testing with leak detector solution in the following auxiliary systems: Combustible Gas Control System (M51),
Service Air and Instrument Air Systems (P51/P52),
Penetration Pressurization System (P53), and Division
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 5 Page 3 of 3 Table 3.3.1: Summary of Aging Management Evaluations for the Auxiliary Systems Item Number Component Aging Effect/
Mechanism Aging Management Programs Further Evaluation Recommended Discussion 3 EDG Starting Air System (R44). In addition to the Auxiliary systems, components exposed to internal environments of air-dry and air-indoor, uncontrolled in the Nuclear Boiler system and Reactor Recirculation system are also aligned to this row. In addition to the Auxiliary systems, stainless steel Base Plates1 exposed to concrete in the Bulk Civil Commodities are also aligned with this item. Also see Item 3.4.1-58 for stainless steel piping components in the Auxiliary systems exposed to Air-indoor, uncontrolled.
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 6 Page 1 of 2 LRA Section: Notes for Table 3.3.2-1 through Table 3.3.2-63 LRA Page Number(s): Pages 3.3-464 through 3.3-468
References:
NCSG RAI-10276-R1, Vistra Letter L-24-208, Attachment 2, and Attachments 7 and 9 to this LRA supplement Description of Change: The Perry Nuclear Power Plant License Renewal Application (LRA)
Plant Specific Notes 344 and 345 for Tables 3.3.2-1 through Table 3.3.2-63 is updated to address the aging effect of Cracking for the applicable stainless steel flexible hoses consistent with the latest revision to the Aging Management Program (AMP) External Surfaces Monitoring of Mechanical Components Program (XI.M36) and the update to PNPP LRA Sections A.1.18 and B.2.18 (reference Attachments 7 and 9 to this LRA supplement).
PNPP Chapter 3, Notes for Table 3.3.2-1 through Table 3.3.2-63, Pages 3.3-364 through 3.3-368, as supplemented by Supplement 3, Attachment 18, Vistra Letter L-24-020 (pdf pages 204 through 208) and responses to RAI set 1, Attachment 8, Vistra Letter L-24-207 (pdf pages 56 through 60) is revised as follows: (see following pages)
Note: Only the Plant Specific Notes that are added are provided on the next page.
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 6 Page 2 of 2 Notes for Table 3.3.2-1 through Table 3.3.2-63 Plant-Specific Notes 344 NUREG-1801 provides no aging effects for this component type, material, and environment combination. Due to transportability of operating experience, PNPP conservatively assigns Cracking due to various causes such as installation-initiated cracking exacerbated by chloride induced SCC, chloride induced SCC, and / or cycle fatigue is assigned to this row. This row represents the external surface of the stainless steel flexible hoses supplying compressed air (Air - dry (Int) environment) to equipment that are periodically tested and subjected to the possibility of concentration of chloride contamination from leak detector solution. These flexible hoses will be periodically replaced.
345 These hoses are associated with the HPCS diesel air start motor and are not normally pressurized. The components are not leak tested with leak detector solution.
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 7 Page 1 of 3 LRA Section: A.1.18 LRA Page Number(s): Pages A-20 through A-21
References:
NCSG RAI-10276-R1, Attachment 2 to Vistra Letter L-24-208, and Attachment 9 to this LRA supplement Description of Changes: The Perry Nuclear Power Plant License Renewal Application (LRA) Section A.1.18 is updated to reflect the periodic replacement of the applicable stainless steel flexible hoses, subject to the aging effect of Cracking. This update is consistent with the latest revision to the Aging Management Program (AMP) External Surfaces Monitoring of Mechanical Components Program (XI.M36) and the update to PNPP LRA Section B.2.18 (reference Attachments 9 to this LRA supplement). Also, two editorial fixes are made by replacing contaminates with contaminants and adding a comma after parenthetical wear) in the first paragraph.
PNPP Section A.1.18, Pages A-20 through A-21, as modified by Attachment 41, Vistra Letter L-24-020 (pdf pages 322 through 323), and in accordance with the responses to:
NCSG RAI-10337-R1 in Attachment 15, Vistra Letter L-24-209 (pdf pages 67 through 75) resulting Supplement 7, Attachment 12, Vistra Letter L-24-256 (pdf pages 194 through 195), and NCSG RAI-10276-R1 in Attachment 2, Vistra Letter L-24-208 (pdf pages 15 through
- 23) resulting in Supplement 8, Attachment 4, Vistra Letter L-25-013 (pdf pages 32 and 33) is revised as follows:
A.1.18 EXTERNAL SURFACES MONITORING OF MECHANICAL COMPONENTS PROGRAM The External Surfaces Monitoring of Mechanical Components Program is a new condition monitoring program that will manage aging effects of components fabricated from metallic, elastomeric, and insulating materials through periodic visual inspection of external surfaces during system inspections and walkdowns for evidence of leakage, loss of material (including loss of material due to wear), hardening and loss of strength due to elastomer degradation, and cracking, in mechanical components. Furthermore, in structural commodities these inspections include change in material properties and cracking of elastomer due to elastomer degradation and change in material properties (causing reduction in thermal resistance) in insulating (i.e., Fiberglass/ Alumina silicate/
Calcium silicate/ Mineral fiber) materials and cracking and loss of material in aluminum structural commodities. The visual inspection of elastomers will detect change in material properties such as cracking or crazing, swelling, discoloration and melting.
Physical manipulation (of at least 10% of available surface area), such as touching, pressing, flexing, and bending, will be used to augment visual inspections to confirm the
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 7 Page 2 of 3 absence of hardening and loss of strength in elastomeric materials. The periodic inspections will include visual inspection of insulation jacketing to ensure the integrity of the jacketing is maintained.
PNPP does not have an air environment containing halides. Stainless steel flexible hoses supplying compressed air to the main steam line safety relief valves located in the drywell have experienced cracking on the external surface. These surfaces, typically exposed to air, have been periodically exposed to a local source of chloride contaminates contaminants from a leak detector solution. The external surface of the pressure boundary for these flexible hoses is physically inaccessible. It is enclosed in a stainless steel mesh integral to its structural integrity. Consequently, these components will be managed by periodically replacing them at a frequency that provides reasonable assurance the intended functions will be maintained consistent with the current licensing basis for the period of extended operation. The initial replacement frequency will be every 3 operating cycles for the stainless steel flexible hoses supplying compressed air to the SRV actuators.
A further extent of condition review was performed for other plant systems within the scope of license renewal with the same component type, material, and environment combination (stainless steel flexible hoses supplying compressed air (Air - dry (Int) or Gas (Int) environments) for similar components that are periodically leak tested and susceptible to chloride exposure from accumulated leak detector solution residue. Flexible hoses meeting this criterion will be periodically replaced at an initial 10 year/5 operating cycle frequency. The affected systems include: M51 (Combustible Gas Control System), P51/P52 (Service Air and Instrument Air Systems), P53 (Penetration Pressurization System), and R44 (Division 3 Diesel Generator Starting Air System).
The program is also credited with managing loss of material from internal surfaces of metallic components and with loss of material, cracking, and change in material properties from the internal surfaces of elastomers, for cases in which material and environment combinations are the same for internal and external surfaces such that external surface condition is representative of internal surface condition.
The inspections of external surfaces will be capable of detecting age-related degradation.
Surfaces that are inaccessible or not readily visible during either normal plant operations or refueling outages will be inspected opportunistically and at such intervals that will ensure the components intended function is maintained during the period of extended operation. Surfaces that are accessible will be inspected at an interval not to exceed one operating cycle. Inspections will be performed by personnel qualified through plant-specific programs. Deficiencies will be documented and evaluated under the Corrective Action Program.
Outdoor insulated components, and indoor insulated components exposed to condensation (because the in-scope component is operated below the dew point), will have portions of the insulation inspected or removed, during each 10-year interval of the period of extended operation, to determine whether the exterior surface of the component is degrading or has the potential to degrade.
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 7 Page 3 of 3 The program will be implemented no later than six months prior to the period of extended operation. Visual inspection of external surfaces will be conducted once every refueling cycle. A sample of insulated piping will be inspected every ten years during the period of extended operation. Inspections will commence during the period of extended operation.
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 8 Page 1 of 2 LRA Section: Appendix A. Table A.3 LRA Page Number(s): Pages A-67
References:
Supplement 8 to the PNPP LRA, Attachment 1 (Vistra letter L-25-013), Attachments 7 and 9 to this LRA supplement Description of Change: Appendix A, Commitment Table A.3, Item No. 18 from the Perry Nuclear Power Plant License Renewal Application (LRA) is updated to reflect the periodic replacement of the applicable stainless steel flexible hoses, subject to the aging effect of Cracking. The additional text to the commitment for the new program is consistent with the latest revision to the Aging Management Program (AMP) External Surfaces Monitoring of Mechanical Components Program (XI.M36) and the PNPP LRA Sections A.1.18 and B.2.18 as updated per Attachments 7 and 9 to this supplement.
PNPP LRA Table A.3, Page A-67 is revised as follows: (see next page)
Note: Only the affected table rows are presented on the following pages. No other changes are made to PNPP LRA Table A.3.
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 8 Page 2 of 2 Item No.
AMP Commitment Implementation Schedule Related LRA Sections 18 XI.M36 Implement the new External Surfaces Monitoring of Mechanical Components Program. Additionally, this program will manage cracking by periodically replacing stainless steel flexible hoses subject to aging management. These hoses supply compressed air/gas to various components and are potentially subject to chloride exposure from the accumulation of leak detector solution residue.
May 8, 2026 A.1.18 B.2.18
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 9 Page 1 of 5 LRA Section: B.2.18 LRA Page Number(s): Pages B-63 through B-64
References:
NCSG RAI-10276-R1, Vistra Letter L-24-208, Attachment 2 Description of Changes: The Perry Nuclear Power Plant License Renewal Application (LRA)
Section B.2.18 is updated to reflect the periodic replacement of the applicable stainless steel flexible hoses, subject to the aging effect of Cracking. This update is consistent the latest revision to the Aging Management Program (AMP) External Surfaces Monitoring of Mechanical Components Program (XI.M36). Also aligning the first paragraph in the Program Description in Section B.2.18 with that in Section A.1.18 and replacing contaminates with contaminants in the second paragraph and adding a comma after parenthetical wear) in the first paragraph.
PNPP Section B.2.18, Pages B-63 thru B-64, as modified in accordance with the responses to:
NCSG RAI 10337-R1, Attachment 15, Vistra Letter L-24-209 (pdf pages 74 and 75) which resulted in Supplement 7, Attachment 17, Vistra Letter L-24-256 (pdf pages 214 thru 216), and
NCSG RAI-10276-R1, Attachment 2, Vistra Letter L-24-208 (pdf pages 15 through
- 23) resulting in Supplement 8, Attachment 5, Vistra Letter L-25-013 (pdf pages 34 through 37) is revised as follows:
B.2.18 EXTERNAL SURFACES MONITORING OF MECHANICAL COMPONENTS PROGRAM Program Description The External Surfaces Monitoring of Mechanical Components Program is a new condition monitoring program that will manage aging effects of components fabricated from metallic, elastomeric, and insulating materials through periodic visual inspection of external surfaces during system inspections and walkdowns for evidence of leakage, loss of material (including loss of material due to wear), hardening and loss of strength due to elastomer degradation, and cracking, in mechanical components. Furthermore, in structural commodities these inspections include change in material properties and cracking of elastomer due to elastomer degradation and change in material properties and cracking of elastomer (causing reduction in thermal resistance) in insulating (i.e.,
Fiberglass/ Alumina silicate/ Calcium silicate/ Mineral fiber) materials and cracking and loss of material in aluminum structural commodities. The visual inspection of elastomers will detect change in material properties including cracking or crazing, swelling, discoloration and melting. Physical manipulation (of at least 10% of available surface area), such as touching, pressing, flexing, and bending, will be used to augment visual inspections to confirm the absence of hardening and loss of strength in
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 9 Page 2 of 5 elastomeric materials. The periodic inspections will include visual inspection of insulation jacketing to ensure the integrity of the jacketing is maintained.
PNPP does not have an air environment containing halides. Stainless steel flexible hoses supplying compressed air to the main steam line safety relief valves located in the drywell have experienced cracking on the external surface. These surfaces, typically exposed to air, have been periodically exposed to a local source of chloride contaminants contaminates from a leak detector solution. The external surface of the pressure boundary for these flexible hoses is physically inaccessible. It is enclosed in a stainless steel mesh integral to its structural integrity. Consequently, these components will be managed by periodically replacing them at a frequency that provides reasonable assurance the intended functions will be maintained consistent with the current licensing basis for the period of extended operation. The initial replacement frequency will be every 3 operating cycles for the stainless steel flexible hoses supplying compressed air to the SRV actuators.
A further extent of condition review was performed for other plant systems within the scope of license renewal with the same component type, material, and environment combination (stainless steel flexible hoses supplying compressed air (Air - dry (Int) or Gas (Int) environments) for similar components that are periodically leak tested and susceptible to chloride exposure from accumulated leak detector solution residue. Flexible hoses meeting this criterion will be periodically replaced at an initial 10 year/5 operating cycle frequency. The affected systems include: M51 (Combustible Gas Control System), P51/P52 (Service Air and Instrument Air Systems), P53 (Penetration Pressurization System), and R44 (Division 3 Diesel Generator Starting Air System).
The program is also credited with managing loss of material from internal surfaces of metallic components and with loss of material, cracking, and change in material properties from the internal surfaces of elastomers, for cases in which material and environment combinations are the same for internal and external surfaces such that external surface condition is representative of internal surface condition.
The inspections of external surfaces will be capable of detecting age-related degradation.
Surfaces that are inaccessible or not readily visible during either normal plant operations or refueling outages will be inspected opportunistically and at such intervals that will ensure the components intended function is maintained during the period of extended operation. Surfaces that are accessible will be inspected at an interval not to exceed one operating cycle. Inspections will be performed by personnel qualified through plant-specific programs. Deficiencies will be documented and evaluated under the Corrective Action Program.
Outdoor insulated components, and indoor insulated components exposed to condensation, will have portions of the insulation inspected or removed, during each 10-year interval of the period of extended operation, to determine whether the exterior surface of the component is degrading or has the potential to degrade.
The program will be implemented no later than six months prior to the period of extended operation. Visual inspection of external surfaces will be conducted once every
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 9 Page 3 of 5 operating cycle. A sample of insulated piping will be inspected every ten years during the period of extended operation. Inspections will commence during the period of extended operation.
NUREG-1801 Consistency The External Surfaces Monitoring of Mechanical Components Program is a new program for PNPP that will be consistent with the 10 elements of an effective aging management program as described in NUREG-1801,Section XI.M36, External Surfaces Monitoring of Mechanical Components as revised by LR-ISG-2012-02.
Exceptions to NUREG-1801 None Enhancements None Operating Experience The following operating experience examples provide objective evidence that the External Surfaces Monitoring of Mechanical Components Program will be effective in ensuring that component intended functions are maintained consistent with the current licensing basis during the period of extended operation.
A review of plant-specific operating experience since 2013, through a search of plant Corrective Action Program documents found 138 corrective actions potentially related to XI.M36 or identifying degraded or potentially degraded insulation. A review of the operating experience found:
In September 2016, a Condition Report (CR) documented damaged or missing insulation in the off gas vault refrigeration system.
Numerous instances of component leaks throughout the plant that were obscured by overlying insulation (e.g., in July 2017 a CR documented a leak in the reactor core isolation cooling system from under the insulation). Such leaks could lead to insulation degradation.
In February 2020, a CR documented that a visual inspection found evidence of corrosion of piping or components under insulation in the turbine building chilled water system.
In February 2020, a CR documented corroded piping or components under insulation were found during repairs in the turbine building chilled water system.
All issues were corrected. The operating experience shows that routine walkdowns and inspections do identify degradation of outdoor components and indoor insulation and leaks under insulation that could identify cracks, seal degradation or failed components.
Routine maintenance has shown that rust, flaking and other piping or component
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 9 Page 4 of 5 degradation does occur under insulation. No evidence of failed or leaking joints in jackets have been identified. Implementation of the External Surfaces Monitoring of Mechanical Components Program will assure system inspections and walkdowns inspect all outdoor accessible components and all indoor accessible insulation each operating cycle. Removal of a sampling of insulation to inspect piping and components will assure degradation from condensation occurring under the insulation will be detected.
In 2021, condition reports document leaking stainless steel flexible air supply hoses for safety relief valves 1B21F0041B and 1B21F0051B. The condition reports cite the suspected failure causes as cyclic fatigue or cracking due to stress corrosion cracking. Both condition reports note that the causes of leaks are not yet known and that a failure analysis is needed to definitively determine the cause. In lieu of a failure analysis, PNPP developed an equivalent replacement hose change document with an improved material resistant to stress corrosion cracking. However, this replacement modification was not implemented. Although failure analyses were ultimately not performed on the flex hoses for the leaks identified in 2021, in 2023 new condition reports identified additional leaking stainless steel flexible air hoses for safety relief valves 1B21F0041B (replaced in 2021) and 1B21F0047B (original equipment). PNPPs operating experience review performed for these condition reports identified that previous leaks in the flexible air hoses for the same system had occurred in 2021 (SRV-0041B and -0051B), in 2017 (SRV-0041B), and in 2011 (SRV-0051B). An outside vendor performed a failure analysis for the leaking flex hoses from 2023, and their failure analysis reports determined the cause to be outside diameter chloride induced stress corrosion cracking. In 2024 an additional condition report was initiated to determine the source of the chloride contamination of the flex hoses, and to prescribe corrective actions to ensure component reliability. The source of the chloride contamination was attributed to accumulated residue from leak detector solution in the corrugations of the flex hoses under the stainless steel braided sheathing. The planned corrective actions included a design change to the hose design to reduce the potential for excessive installation stresses, enhanced procedural guidance for hose installation, revised procedural guidance for leakage testing, and the periodic replacement of the hoses. The initial replacement frequency will be every 3 operating cycles.
A further extent of condition review was performed for other plant systems within the scope of license renewal with the same component type, material, and environment combination (stainless steel flexible hoses supplying compressed air (Air - dry (Int) or Gas (Int) environments) for similar components that are periodically leak tested and susceptible to chloride exposure from accumulated leak detector solution residue. Although many of the contributing causal factors of the SRV flexible hose failures are not present for other plant systems (operational vibratory
- effects, elevated ambient temperature conditions, hose design vulnerability, and recurrent bending stresses from periodic re-installation), PNPP has conservatively identified the accumulation of leak detector solution residue as a contributing cause to the aging effect of cracking for stainless steel flexible hoses.
Based on the above operating experience associated with SRV stainless steel flexible hoses, and consistent with the above-described hose replacement strategy, PNPP will periodically replace flexible hoses identified within this extent of condition at an initial replacement frequency of 10 years/5 operating cycles.
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 9 Page 5 of 5 The stainless steel flexible hose population subject to this replacement strategy are those within the following plant systems in the scope of license renewal: M51 (Combustible Gas Control System), P51/P52 (Service Air and Instrument Air Systems),
P53 (Penetration Pressurization System), and R44 (Division 3 Diesel Generator Starting Air System). As these additional flexible hoses do not have operating experience of failures, and are not subject to the other contributing causal factors described above, this longer (relative to SRV flexible hose) initial 10 year/5 operating cycle is deemed appropriate. Also, consistent with aging management approach for the SRV flexible hoses, the External Surfaces Monitoring of Mechanical Components Program will be credited to manage the aging effect of cracking for these flexible hoses until the periodic replacement strategy is fully implemented.
Conclusion The external surfaces monitoring of mechanical components program will provide reasonable assurance that aging effects will be managed such applicable components will continue to perform their intended functions consistent with the current licensing basis during the period of extended operation.
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 10 Page 1 of 9 0
LRA Sections: B.2.43 LRA Page Number(s): Page B-125
Reference:
N/A (incorporation of recent operating experience)
Description of Change: The Structures Monitoring Program (XI.S6) is revised is to incorporate recent operating experience (OE) associated with a roof penetration on the Diesel Generator Building. The recent event involves a June 2024 plant modification that was implemented to install a flood barrier at the entrance of a construction opening. The installed flood barrier replaced the water intrusion prevention function of the seal with that of the permanent barrier.
The PNPP LRA already includes appropriate line items for flooding barriers as structural bulk commodities subject to aging management under the Structures Monitoring Program. Existing programmatic enhancements provided in LRA Table A.3 address the inspection of this bulk commodity type. As such, no changes are necessary to the Structures Monitoring Program, as enhanced, as a result of this plant change. Therefore, only LRA Section B.2.43 is updated to document this recent operating experience event.
PNPP LRA Section B.2.43, Page B-125, as recently modified for the response to NRC Request for Additional Information (RAI) ESEB RAI-10470-R2, RAI Set 4 Response, Vistra Letter L-25-012, Attachment 11 is revised as follows:
B.2.43 STRUCTURES MONITORING PROGRAM Program Description The Structures Monitoring Program is an existing condition monitoring program that manages the effects of aging on structures and structural components within the scope of license renewal. The program was developed to implement the requirements of 10 CFR 50.65 and is based on guidance in Regulatory Guide 1.160 Revision 2, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, and NUMARC 93-01 Revision 2, Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants.
The scope of the Structures Monitoring Program includes structures, structural components, component supports, and structural commodities in the scope of license renewal that are not addressed by other structural aging management programs (AMPs)
(i.e., ASME Section XI, Subsection IWE (AMP XI.S1); ASME Section XI, Subsection IWL (AMP XI.S2); ASME Section XI, Subsection IWF (AMP XI.S3); and RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants (AMP XI.S7)). The scope of Structures Monitoring Program also includes the in scope (non-safety/non-seismic) masonry walls as described in AMP XI.S5.
Aging effects associated with the in-scope masonry walls are managed by the structures
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 10 Page 2 of 9 monitoring program as described in the Masonry Walls Aging Management Program Description. There are no safety related masonry walls that are in close proximity to or having attachments from safety-related systems or components, as such PNPP does not have any safety related masonry walls meeting the criteria of I.E Bulletin 80-11 or IN 87-67. The masonry walls that are within the scope of license renewal at PNPP are limited to isolated non-safety related, non-seismic Category I structures. The scope of the structures monitoring program also includes managing aging effects associated with the plant underdrain system, storm drains that are considered as bulk commodities and porous concrete sub-foundations.
The program consists of periodic inspection, monitoring and trending of the conditions of structures and structural components to ensure that aging degradation leading to loss of intended functions will be detected and that the extent of degradation can be determined. Unacceptable conditions, when found, are evaluated or corrected in accordance with the corrective action program. Change in material properties for concrete, concrete blocks, elastomers, lubrite/sliding plates, porous concrete and unimpregnated and impregnated (with elastomer) fiber glass fabric are included in the monitored aging effects. Concrete structures are inspected for indications of deterioration and distress. Elastomers will be monitored for hardening, shrinkage and loss of sealing. Rock/stone embankment structures will be inspected for loss of material and loss of form. Component supports will be inspected for loss of material and reduction in anchor capacity due to local concrete degradation. Exposed surfaces of bolting are monitored for loss of material and loose or missing nuts and bolts. The aging effects associated with wooden clamps supporting the electrical cables in manholes are managed by this program.
The program also includes provisions for periodic testing and assessment of ground water chemistry and inspection of accessible below grade concrete structures. A de-watering system is not relied upon to control building settlement.
Protective coatings are not relied upon to manage the effects of aging for structures included in the scope of this program.
NUREG-1801 Consistency The Structures Monitoring Program is an existing PNPP program that after enhancements, will be consistent with the 10 elements of an effective aging management program as described in NUREG-1801,Section XI.S6, Structures Monitoring.
Exceptions to NUREG-1801 None Enhancements The following enhancements will be implemented in the identified program elements no later than six months prior to the period of extended operation.
Scope (Element 1)
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 10 Page 3 of 9 The program implementing procedure will be enhanced to include an attachment listing names and/or unique identifiers of structures and structural bulk commodities (including plant systems containing the bulk commodities) within the scope of license renewal that credit the Structures Monitoring Program for aging management.
The program implementing procedure will be enhanced to include an attachment listing the supporting procedures, instructions, and maintenance plans that are credited to manage the aging effects of the structures and structural bulk commodities that are within the scope of the structures monitoring aging management program for license renewal. For example, the list of procedures, instructions, and maintenance plans will cite documents that address: Monitoring for building settlement; groundwater level monitoring; monitoring site groundwater chemistry; monitoring in-scope masonry structures for loss of material and cracking; plant underdrain system inspection and maintenance; monitoring storm drain piping for flow blockage and loss of material; monitoring concrete for damage from freeze-thaw, and all other topics that are credited in the license renewal structures monitoring aging management program.
The program will be enhanced to monitor the aging effects of the porous concrete sub-foundation and the porous concrete pipe associated with the plant underdrain system.
The program implementing procedure will be enhanced to include the monitoring of in-scope nonsafety related/non-seismic masonry walls for aging management.
The program will be enhanced to include the aging management of plant storm drain piping in the scope of the program.
The program implementing procedures will be enhanced to monitor unimpregnated and impregnated (with elastomer) fiberglass fabric for aging effects.
The program will be enhanced to inspect accessible areas of concrete for the signs of alkali silica reaction (ASR).
Preventive Actions (Element 2):
The program will be enhanced to include preventive actions delineated in NUREG-1339 and in EPRI NP-5769, NP-5067, and TR-104213 that emphasize proper selection of bolting material, installation torque or tension, and the use of lubricants and sealants for high strength bolting (actual measured yield strength greater than or equal to 150 ksi).
The program will be enhanced to include preventive actions for storage, lubricants, and stress corrosion cracking potential consistent with the requirements of Section 2 of RCSC (Research Council for Structural Connections) publication Specification for Structural Joints Using ASTM A325 or A490 Bolts. Lubricants that contain molybdenum disulfide (MoS2) shall not be applied to structural high strength bolts within the scope of license renewal.
The program will be enhanced to include a preventive action for cleaning and
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 10 Page 4 of 9 inspection of storm drain piping for a periodicity not to exceed five years.
Parameters Monitored/Inspected (Element 3)
The implementing procedures will be enhanced to monitor the porous concrete sub-foundation for:
Loss of material (erosion of porous concrete sub-foundation).
Change in material properties (leaching of calcium hydroxide).
Increase in porosity and permeability, loss of strength.
Reduction of foundation strength and cracking due to differential settlement and erosion of the porous concrete sub-foundation.
The program will be enhanced to monitor ground water chemistry for pH, chlorides, and sulfates and verify that it remains non-aggressive, or evaluate results exceeding criteria to assess impact, if any, on below grade concrete.
The program will be enhanced to specify that a representative sample of high strength (actual measured yield strength 150 ksi or 1,034 MPa) structural bolts greater than 1 inch (25 mm) in diameter are monitored for stress corrosion cracking (SCC). The visual inspection is supplemented with volumetric or surface examinations to detect cracking.
The program will be enhanced to monitor accessible sliding surfaces to detect significant loss of material due to wear, corrosion, debris, dirt, distortion, or overload that could restrict or prevent sliding of surfaces as required by design.
The program will be enhanced to require inspection of elastomeric components for cracking, loss of material and hardening. Visual inspections of elastomeric components are to be supplemented by feel or manipulation to detect hardening.
Include instructions to enhance the visual examination of elastomeric material with physical manipulation of at least ten percent of available surface area.
The program will be enhanced to require the plant storm drain piping be monitored for:
Unacceptable flow blockage in the storm drain piping irrespective of piping material.
During opportunistic excavations of piping:
Loss of material in steel (corrugated metal), concrete and polymer
- piping, Loss of material, cracking and blistering in polymer piping, Cracking, change in material properties, increase in porosity and permeability; loss of strength, increase in porosity and permeability; cracking; loss of material (spalling, scaling), and loss of material
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 10 Page 5 of 9 (Corrosion of embedded steel reinforcing) in concrete piping, The program will be enhanced to inspect the in-scope concrete structures for loss of material, cracking, change in material properties, increase in porosity and permeability; loss of strength, increase in porosity and permeability; cracking; loss of material (spalling, scaling), and loss of material due to corrosion of embedded steel reinforcing.
The program implementing documents will be enhanced to inspect accessible areas of concrete for the signs of alkali silica reaction (ASR), such as, map or patterned cracking, alkali-silica gel exudations, surface staining, expansion causing structural deformation, relative movement or displacement, or misalignment/distortion of attached components.
The program implementing procedure will be enhanced to include the monitoring of in-scope masonry walls for loss of material (spalling, scaling), change in material properties and cracking due to freeze-thaw.
The program implementing procedures will be enhanced to monitor unimpregnated and impregnated (with elastomer) fiberglass fabric for loss of material, separation, cracking/delamination, and change in material properties and visible deterioration.
The program implementing procedures will be enhanced to monitor the wooden clamps for loss of material and change in material properties.
Detection of Aging Effects (Element 4)
Groundwater chemistry parameters will be monitored on a frequency of at least once every five years.
The program will be enhanced to require that structures and structural components within the program are monitored at a frequency of at least 5 years.
The program will be enhanced to require the plant storm drain piping is inspected:
100% of internal surfaces by either direct visual observation or remote visual (camera) at least every 5 years.
This will be done either all at one time or spread out of various locations over a period of five years. This meets the NUREG-1801 recommendations of inspection once every five years.
External by direct visual observation during opportunistic excavations.
The thickness of steel piping will be measured over a general area and not a point measurement reflective of a local pit or gouge either directly measured or NDE methods utilized.
Additionally, the sites implementing document will include required storm drain system inspections following offsite agency confirmation that an earthquake has occurred in the area of the plant for any sign of ground settlement that could be an indication of storm drain piping collapse to ensure the integrity of the piping.
Internal inspections of the storm drain system for assurance of continued
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 10 Page 6 of 9 functionality immediately (within 30 days) following the occurrence of significant natural phenomena, such as large floods, earthquakes, hurricanes, tornadoes, and intense local rainfalls.
The program implementing procedures will be enhanced to require (a) evaluation of 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 and (b) examination of representative samples of the exposed portions of the below grade concrete, when excavated for any reason. If normally inaccessible areas become accessible due to planned activities, an inspection of these areas shall be conducted.
Acceptance Criteria (Element 6)
Plant procedures will be updated to prescribe quantitative acceptance criteria based on the acceptance criteria of ACI 349.3R-2002, ACI 20.1R-2008, ACI 349-1976, ACI 318-71, ACI 301-72, AISC-1969 and 1978, ANSI N18.1-1971 and ASCE 11-90.
Industry and plant specific operating experience will also be considered in the development of the acceptance criteria.
Plant implementing procedures will be updated to indicate that loose bolts or nuts and cracked high strength bolts will not be acceptable unless accepted by engineering evaluation.
Plant implementing procedures will be updated to indicate that structural sealants will be acceptable if the observed loss of material, cracking, and hardening will not result is loss of sealing.
Plant implementing procedures will be updated to indicate that elastomeric vibration isolation elements will be acceptable if there is no loss of material, cracking, or hardening that could lead to the reduction or loss of isolation function.
Plant implementing procedures will be updated to indicate that acceptance criteria for sliding surfaces will be (a) no indications of excessive loss of material due to corrosion or wear and (b) no debris or dirt that could restrict or prevent sliding of the surfaces as required by design.
The program will be enhanced to require that personnel performing inspections and evaluations meet the qualifications specified within ACI Report 349.3R-2002 with respect to knowledge of inservice inspection of concrete and visual acuity requirements.
Implementing documents will be updated to prescribe the acceptance criterion for flow blockage in storm drain piping is less than a 10% flow capacity reduction based on cross-sectional geometry.
Implementing documents will be updated to prescribe the acceptance criterion for storm drain piping corrugated metal pipe wall thickness in no less than 50% of the original thickness.
The implementing procedures will be updated to reflect when cracking or separation are observed in in-scope masonry walls, a condition report shall be initiated to document an evaluation of the effect of the condition for acceptability
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 10 Page 7 of 9 on the intended function of the masonry wall.
Acceptance criteria for indication of leaching of calcium hydroxide will be as follows:
Groundwater parameters are no longer be considered non-aggressive if they exceed:
pH < 5.5, chlorides > 500 ppm sulfates > 1500 ppm Operating Experience The following operating experience examples provide objective evidence that the Structures Monitoring program will be effective in ensuring that component intended functions are maintained consistent with the current licensing basis during the period of extended operation.
In March 1997, the U.S. Nuclear Regulatory Commission (NRC) issued Information Notice IN 97-11, to alert addressees to information regarding the possible erosion of cement from porous concrete sub-foundations below the reactor building basemats at some reactor sites. It was expected that recipients will review the information for applicability to their facilities and consider actions, as appropriate, to monitor similar phenomena at their plants. PNPP was one of the plants identified in this information notice. The issue of the loss of calcium from the porous concrete and the precipitation of calcium carbonate in the porous concrete, porous concrete pipe, and underdrain manholes had been a subject of investigation since 1983 at PNPP. Engineering evaluations performed concluded that the interior of the porous concrete layer (under the plant buildings) is fairly stagnant and leaching of calcium is localized in the peripheral portions of the porous concrete pad, and not uniformly throughout the pad.
Additionally, building settlement data are collected on a quarterly basis by measuring the elevation of a number of permanent settlement markers installed in the exterior of plant structures. The details of the settlement are reviewed by Design Engineering.
There has been no significant building settlement that has been identified that would indicate that the underdrain basemat is degraded and not performing its function.
Various preventative maintenance procedures/instructions are in place to ensure that the plant underdrain system is performing its design function.
In November 2005, cracks and chipped areas of concrete were identified on the concrete pedestal of the Division I Diesel Generator below the engine. These cracks were considered hairline cracks, which are normal in concrete structures and were/are considered acceptable. These cracks are being monitored as part of maintenance rule walk downs to ensure they will not degrade to an unacceptable level which could impact the structural integrity of the concrete structure.
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 10 Page 8 of 9 In August 2012, the maintenance rule walkdown for the Intermediate Building noted several deficiencies that were acceptable for the current inspection cycle. The acceptable deficiencies were evaluated and assigned corrective actions as necessary to ensure they would not lead to unacceptable deficiencies. Examples of corrective actions included, repair/replacement of conduit, rework/repair of leaking roof, and rework/repair of conduit supports.
In May 2012, the maintenance rule walk down for the Auxiliary Building noted several deficiencies that were acceptable for the current inspection cycle. The acceptable deficiencies were evaluated and assigned corrective actions as necessary to ensure they would not lead to unacceptable deficiencies. Examples of corrective actions included restore pipe insulation, recoat piping as needed, rework/restore floor coating, rework cover holding mounting bolts and clean the roof/remove debris.
In May 2012, the maintenance rule walk down for the Fuel Handling Building noted several deficiencies that were acceptable for the current inspection cycle. The acceptable deficiencies were evaluated and assigned corrective actions as necessary to ensure they would not lead to unacceptable deficiencies. Results of the Fuel Handling Building Maintenance Rule walk down identified three items with a potential Fire Protection significance.
- 1. A tear/crack in the penetration sealant material of the seismic gap between the Shield Building and the Intermediate Building wall near Door IB-209.
- 2. A tear/crack in the penetration sealant material of the seismic gap between the Shield Building and the Intermediate Building wall near Door IB-217.
- 3. An approximately 3/16 gap in sealant material at a floor penetration on the 599 elevation located near the building coordinate of IB-8 and IB-G.
Both Items 1 and 2 above are located in Fire Zone IB-2. Per the PNPP Fire Protection Evaluation Report, sections 9A.4.3.1.1 and 9A.4.3.2.1, the Reactor Building interfaces are unprotected openings. Unprotected openings do not have a fire rating and therefore there cannot be any degradation of a fire barrier as a result of the condition described in items 1 and 2. Item 3 documents a potential degradation of a fire barrier since the condition was noted around a floor penetration located within Fire Zone FH-2a. Floor penetrations in this Fire Zone have a three-hour barrier rating per Section 9A.4.7.2.1.
However, the condition was determined to be insufficiently deep (depth of only an inch or two and not fully penetrating) to challenge the integrity of the fire barrier. The acceptable deficiencies were assigned corrective actions as necessary to ensure they would not lead to unacceptable deficiencies.
Industry Operating Experience concerning laminar cracking of concrete structure subsurfaces is documented in NRC Information Notice 2013-04, Shield Building Concrete Subsurface Laminar Cracking Caused by Moisture Intrusion and Freezing dated March 7, 2013. The review of this condition relative to PNPP has determined the following.
As no protective sealant has been applied to the exterior of the PNPP shield building, the structure is susceptible to the expansive forces in the presence of high internal
Perry Nuclear Power Plant LRA Supplement 9 L-25-094 Attachment 10 Page 9 of 9 moisture content. The event report identifies the potential for laminar cracking to initiate and propagate in areas of closely spaced rebar (6 inches center-to-center).
As the architecture of the shield building in this area is unlikely to produce the initial laminar cracking, propagation of cracking is not expected. In the event that laminar cracking did initiate in this area and then propagated through this area, the crack length would be limited based on the relatively short section of closely spaced rebar.
The shield building does not contain architectural flutes and the majority of the shield building rebar has been shown as sufficient to preclude laminar cracking and crack propagation. Therefore, the conditions susceptible to laminar cracking are minimal over the majority of the structure. As such, no actions are required at PNPP to further prevent laminar cracking due to extreme weather conditions.
In June of 2024 following severe weather, rainwater from the DG building roof leaked through a piping penetration, down the diesel exhaust piping into the Div. 3 DG room. During the peak leakage, water was observed to be flowing onto the engine, the turbocharger, and into the openings of the generator. The same piping penetration had been identified to leak water in 2017. The penetration is designed to keep a fire protection system CO2 discharge contained in the diesel room. The penetration application is unique based on the 800° F diesel exhaust piping temperature. A calcium silicate insulation band circumscribes the piping at the penetration, with an elastomer seal filling the remainder of the penetration annular space. Going forward a design change has been implemented that installs flood barriers on the diesel building roof, limiting further exposure of the calcium silicate insulation band to submergence.
From 2013 through to date, various condition reports were written to document roof leaks in various plant buildings. Corrective actions included either repair of roofs, roof replacements or in planning for planned future repairs. Additionally, the plant procedure Monitoring the Effectiveness of Maintenance Structure Monitoring Program includes periodic inspections of plant buildings which identify any such deficiencies and corrective actions taken accordingly.
The above examples of site operating experience provide evidence that as a result of implementation of the structures monitoring program, conditions continue to be documented, trended, and evaluated. As needed, corrective actions are initiated, tracked and implemented. Any operability concerns are promptly identified and addressed and evaluated.
Conclusion The Structures Monitoring Program, with enhancement, will provide reasonable assurance that aging effects will be managed such that applicable components will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.