ML041900407

Additional Information in Support of Applications for Renewed Operating Licenses

ML041900407
Person / Time
Site:	Millstone
Issue date:	07/07/2004
From:	Grecheck E Dominion Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
04-320
Download: ML041900407 (28)

Text

Dominion Nuclear Connecticut, Inc.

Ltillxoiit Powcr \\ration Ihp 1 crr] Rocid W.ircrford, ( T 06385 J u l y 7, 2004 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Serial No.04-320 LWELA RO Docket Nos.

50-336 License Nos.

DPR-65 50-423 NPF-49 By letter dated January 20, 2004, DNC submitted the applications for renewed operating licenses (LRAs) for Millstone Power Station, Units 2 and 3. The NRC performed on-site audits of the aging management programs and aging management reviews during the following weeks in 2004: March 29, May 3, May 10, and June 7. As a result of these audits, additional information in support of the Millstone Power Station, Units 2 and 3 LRAs is being submitted as Attachment 1.

Should you have any questions regarding this submittal, please contact Mr. William D.

Corbin, Director, Nuclear Projects, Dominion Resources Services, Inc., 5000 Dominion Blvd., Glen Allen, VA, 23060, (804) 273-2365.

Very truly yours, E.S. Grecheck Vice President - Nuclear Support Services Attachments:

1. Additional Information in Support of Applications for Renewed Operating Licenses Commitments made in this letter:

The additional information related to the Licensee Commitments identified in Table A6.0-1 of Appendix A, Final Safety Analysis Report Supplement, are proposed to support approval of the renewed operating licenses and may change during the NRC review period.

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses Page 2 of 4 cc:

US. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406-1 41 5 Mr. V. Nerses Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North 1 1555 Rockville Pike Mail Stop 8C2 Rockville, MD 20852-2738 Mr. S. M. Schneider NRC Senior Resident Inspector Millstone Power Station Honorable Wayne L. Fraser First Selectman P.O. Box 519 Niantic, CT 06357-051 9 Mr. Stephen Page Central VT PSC 77 Grove Street Rutland, VT 06701 Honorable Andrea Stillman CT House of Representatives 5 Coolidge Court Waterford, CT 06385 Mr. Denny Galloway Supervising Radiation Control Physicist State of Connecticut - DEP Division of Radiation 79 Elm Street Hartford, CT 061 06-51 27 Honorable Chris Dodd US Senate 100 Great Meadow Road Wethersfield, CT 06109 Mr. Michael Doyle Governors Eastern Office 171 Salem Turnpike Norwich, CT 06360 Mr. William Meinert MMWEC P.O. Box426 Ludlow, MA 01 056-0426 Honorable Melodie Peters CT State Senate 25 Osceola Trail Old Lyme, CT 06371 Honorable Gary Orefice CT House of Representatives 47 Columbus Avenue Niantic, CT 06357 Honorable Robert Simmons US Congress 2 Courthouse Square Norwich, CT 06360 Mr. Thomas Wagner Town of Waterford Town Planner 15 Rope Ferry Road Waterford, CT 06385 Dr. Edward L. Wilds Director, Division of Radiation State of Connecticut - DEP 79 Elm Street Hartford, CT 061 06-51 27

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses Page 3 of 4 Chairman Donald Downes DPUC 10 Franklin Square New Britain, CT 06051 Honorable Dennis L. Popp Chairman - Council of Governments Municipal Building 295 Meridian Street Groton, CT 06340 Chief Murray J. Pendleton Director of Emergency Management 41 Avery Lane Waterford, CT 06385-2806 Honorable Richard Blumenthal Attorney General 55 Elm Street Hartford, CT 061 06-1 774 Mr. John Markowicz Co-Chairman - NEAC 9 Susan Terrace Waterford, CT 06385 Mr. Evan Woolacott Co-Chairman - NEAC 128 Terry's Plain Road Simsbury, CT 06070 Honorable M. Jodi Rell Governor State Capitol Hartford, CT 061 06 Mr. Mark Powers 4 Round Rock Road Niantic, CT 06357 Mr. Jay Levin 23 Worthington Road New London, CT 06320 Mr. Jim Butler Executive Director - Council of Govern me nts 8 Connecticut Avenue Nowich, CT 06360 Mr. Bill Palomba Executive Director, DPUC 10 Franklin Square New Britain, CT 06051 Honorable Wade Hyslop State Representative, 3gth District 32 Belden Street New London, CT 06320 Honorable Terry Backer CT State Representative Legislative Office Building Room 3902 Hartford, CT 061 06 Honorable Kevin DelGobbo CT State Representative 83 Meadow Street Naugautuck, CT 06770 Honorable Thomas Herlihy CT Senate 12 Riverwalk Simsbury, CT 06089 Honorable Cathy Cook CT Senate, 18'h District 43 Pequot Avenue Mystic, CT 06355 Mr. Edward Mann Office of Senator Dodd Putnam Park 100 Great Meadow Road Wethersfield, CT 06109 Chairperson Pam Katz CT Siting Council 10 Franklin Square New Britain, CT 06051

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses Page 4 of 4 Mr. Ken Decko CBlA 350 Church Street Hartford, CT 061 03 Honorable Paul Eccard First Selectman Town of Waterford 15 Rope Ferry Road Waterford, CT 06385 Mr. Richard Brown City Manager New London City Hall 181 State Street New London, CT 06320 Honorable Gaylord Gaynor Mayor, New London New London City Hall 181 State Street New London, CT 06320

SN: 04-320 Docket Nos.: 50-336/423

Subject:

Additional Information in Support of Renewed Operating Licenses COMMONWEALTH OF VIRGINIA

)

)

COUNTY OF HENRICO

)

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Eugene S. Grecheck, who is Vice President -

Nuclear Support Services, of Dominion Nuclear Connecticut, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this 7th day of July, 2004.

My Commission Expires: March 31, 2008.

c (SEAL)

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses Additional Information in Support of Applications for Renewed Operatinq Licenses Millstone Power Station Units 2 and 3 Dominion Nuclear Connecticut, Inc.

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses /Page 1 of 22 Additional Information in Support of Applications for Renewed Operating Licenses Audit Item 1: The commitment regarding sprinkler head testing or replacement should have the wording The first tests will be completed prior to the sprinkler heads achieving 50 years of service life. The frequency of subsequent tests will not exceed a 10 year interval. inserted after the words Testing a representative sample of fire protection sprinkler heads or replacing those that have been in service for 50 years will be included in the Fire Protection Program. This commitment appears in the Unit 2 LRA and the Unit 3 LRA in the following locations:

0 Unit 2 Appendix A, Section A2.1.10 (page A-1 1) 0 Unit 2 Appendix B, Section B2.1.10 (page B-38) 0 Unit 3 Appendix A, Section A2.1.9 (page A-9) 0 Unit 3 Appendix B, Section B2.1.10 (page B-38)

Additionally, the wording Not to Exceed a 10 Year Interval Thereafter should be inserted in the Schedule column of Appendix A, Table A6.0-1, Commitment 9 in the Unit 2 LRA (page A-35) and the Unit 3 LRA (page A-34).

Audit Item 6: For the commitment regarding lnservice Inspection Program:

Reactor Vessel Internals, the wording The revised program description, including a comparison to the 10 program elements of the NUREG-1801 program, will be submitted to the NRC for approval. should be inserted at the end of the commitment. This commitment appears in the Unit 2 LRA and the Unit 3 LRA in the following locations:

0 Unit 2 Appendix A, Section A2.1.17 (pages A-15, A-16) 0 Unit 2 Appendix A, Table A6.0-1, Commitment 13 (page A-36)

Unit 2 Appendix B, Section B2.1.17 (pages B-70, B-71)

Unit 3 Appendix A, Section A2.1.16 (page A-14) 0 Unit 3 Appendix A, Table A6.0-1, Commitment 13 (page A-35) 0 Unit 3 Appendix B, Section 82.1.17 (pages B-70, B-71)

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses /Page 2 of 22 Audit Item 8: The wording The Westinghouse modified operating procedure (MOP) method and operational recommendations outlined in WCAP-13588, Operating Strategies for Mitigating Pressurizer lnsurge and Outsurge Transients, have been incorporated into the Unit 3 heatup and cooldown procedures. The use of these recommendations ensures thermal shock of the pressurizer surge line nozzle is minimized by establishing conditions that reduce the magnitude of delta-temperature and the frequency of insurge and outsurge transients. should be inserted following The Millstone Unit 3 pressurizer surge line and pressurizer lower head have been evaluated for the effects of thermal stratification. Forced pressurizer spray (e.g., for boron equalization) has been utilized at Millstone Unit 3 since initial operation. in Unit 3 Section 4.3.1 (page 4-13).

Audit Item 9: To clarify how cycle monitoring was performed, the word equivalent should be inserted before full-temperature thermal cycles in Unit 2 Section 4.3.2 (page 4-16) and Unit 3 Section 4.3.2 (page 4-14) and the words equivalent full-temperature should be inserted before thermal cycles in Unit 2 Appendix A, Section A3.2.2 (page A-27) and Unit 3 Appendix A, Section A3.2.2 (page A-25).

Audit Items 11 & 12: To clarify the discussion of environmentally assisted fatigue, the wording increased frequency should be replaced with increased probability in Unit 2 Section 4.3.3 (page 4-17 last paragraph) and Unit 3 Section 4.3.3 (page 4-1 5 second paragraph).

Audit Item 13: To clarify how the environmentally assisted fatigue analysis was performed, the wording in Unit 2 Section 4.3.3 (page 4-18) and Unit 3 Section 4.3.3 (page 4-16) The second activity involved the evaluation of the influence of the reactor water environment on the cumulative usage factor of the following representative components identified in NUREGER-6260 for the period of extended operation, using the most recent laboratory data and methods: should be replaced with The second activity involved evaluating the influence of the reactor water environment on the fatigue life of six representative NUREG/CR-6260 identified components, which are listed below. NUREG-1 801 requires, as a minimum, that these six representative components be evaluated for the period of extended operation employing the most recent laboratory data and methods:.

Audit Item 14: To provide an enhanced commitment for the environmentally assisted fatigue program, the words If the specific locations are not repaired, replaced, or successfully re-analyzed, a modified inspection program description, including a comparison to the 10 program elements of the NUREG-1801 program, will be submitted to the NRC for approval. should be inserted at the end of the commitment in Unit 3 Appendix A, Section A3.2.3, (page A-27) and Unit 3 Appendix A, Table A6.0-1, Commitment 27 (page A-38).

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses /Page 3 of 22 Audit Item 15: To clarify the revision for the referenced ASME Code Case, N-491 should be replaced with -491-1 in Unit 2 and Unit 3 Appendix B, Section B2.1.18 (page B-76).

Audit Items 16 & 43: To document the industry standards that were the basis for the Fuel Oil Chemistry program, the following wording should be inserted after the first paragraph of Unit 2 Appendix A, Section A2.1.12 (page A-11) and Unit 3 Appendix A, Section A2.1.11 (page A-10):

The Fuel Oil Chemistry program uses the following industry standards as the basis for the program:

0 ASTM Standard D 1796, ASTM Standard D 2276 (unmodified), and ASTM Standard D 4057.

Audit Item 20: The following wording provides an additional commitment for monitoring environmentally assisted fatigue:

Millstone will follow industry efforts that will provide specific guidance to license renewal applicants for evaluating the environmental effects of fatigue on applicable locations, other than those identified in NUREG/CR-6260.

Millstone will also implement the appropriate recommendations resulting from this guidance. This commitment is identified in Appendix A, Table A6.0-1 License Renewal Commitments, Item [28 for Unit 21 [29 for Unit 31.

This commitment should be inserted at the end of following sections in the Unit 2 LRA and the Unit 3 LRA:

Unit 2, Section 4.3.3 (page 4.1.8) 0 Unit 2, Appendix A, Section A3.2.3 (page A-26) 0 Unit 3, Section 4.3.3 (page 4.1.7) 0 Unit 3, Appendix A, Section A3.2.3 (page A-27)

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses /Page 4 of 22 Additionally, a new commitment should be added to Appendix A, Table A6.0-1 for each unit as follows:

Item: 28 (Unit 2), 29 (Unit 3)

Commitment: The commitment will be worded as identified above.

Source: Environmentally Assisted Fatigue TLAA Schedule: Prior to the Period of Extended Operation.

Audit Item 42-1 & 19: Note 6 for Unit 2 Tables 3.1.2-1 through 3.1.2-4 (page 3-101) and Unit 3 Tables 3.1.2-1 through 3.1.2-4 (page 3-106), should state the following:

For potentially susceptible CASS materials, either enhanced volumetric examinations or a unit or component specific flaw tolerance evaluation (considering reduced fracture toughness and unit specific geometry and stress information) will be used to demonstrate that the thermally-embrittled material has adequate fracture toughness in accordance with NUREG-1 801 Section XI.Ml2.

Audit Item 42-2 & 19: Loss of Fracture Toughness as an aging effect for component types Pipe (Safe Ends for SI and SDC), Pipe (Surge Line Piping and Fittings), and Pressurizer (Safe End for PZR Surge Nozzle) should be added in Unit 2 Table 3.1.2-3, (pages 3-72, 74, and 77, respectively). The Loss of Fracture Toughness is managed by the Inservice Inspection Program: Systems, Components and Supports and corresponds to GALL item IV.C2.1-f. The Notes for these entries are A, 6 and the Table 1 Item is 3.1.l-24. The material for the pressurizer component (identified above) will designate that it is CASS material. Note that only the Loss of Fracture Toughness entry will have Note 6 listed for the above component types.

Audit Item 42-3 & 19: Loss of Fracture Toughness as an aging effect for component type Pipe (Hot and Cold Leg Piping and Fittings) should be added in Unit 3 Table 3.1.2-3 (page 3-80). The Loss of Fracture Toughness is managed by the lnservice Inspection Program: Systems, Components and Supports and corresponds to NUREG-1801 Item IV.C2.1-f. The Note for this entry is A, 6 and the Table 1 Item is 3.1.1-24. Note that only the Loss of Fracture Toughness entry will have Note 6 listed for the above component type.

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses /Page 5 of 22 Audit Item 42-4 & 19: The Discussion column in Unit 2 Table 3.1.1, Item 24, (page 3-31), and Unit 3 Table 3.1.l, Item 24, (page 3-32), should read as follows:

Consistent with NUREG-1801. Loss of Fracture Toughness is managed with the lnservice Inspection Program: Systems, Components and Supports. This program takes some exception to the NUREG-1801 AMP.

Audit Item 42-5 & 19: For Unit 2 Appendix A, Section A2.1.18 (page A-17) and Unit 3 Appendix A, Section A2.1.17 (page A-l6), the following wording, providing an additional commitment for monitoring the reduction in fracture toughness, should be inserted at the end of the commitments:

Monitoring Fracture Toughness For potentially susceptible CASS materials, either enhanced volumetric examinations or a unit or component specific flaw tolerance evaluation (considering reduced fracture toughness and unit specific geometry and stress information) will be used to demonstrate that the thermally-embrittled material has adequate fracture toughness in accordance with NUREG-1 801 Section XI.Ml2. This commitment is identified in Appendix A, Table A6.0-1 License Renewal Commitments, Item [27 for Unit 21 [28 for Unit 31.

Additionally, a new commitment should be added to Appendix A, Table A6.0-1 for each unit as follows:

Item: 27 (Unit 2), 28 (Unit 3)

Commitment: The commitment will be worded as identified above.

Source: ISI: Systems, Components and Supports Schedule: Prior to the Period of Extended Operation.

To reflect this additional commitment in the Inservice Inspection Program:

Systems, Components and Supports, the wording in Unit 2 Appendix B, Section 82.1.18 (page B-75) and Unit 3 Appendix B, Section B2.1.18 (page B-75) In accordance with NUREG-1 801 Section Xl.Ml2, the potential for thermal aging embrittlement of CASS components is addressed through the performance of plant-specific or component-specific evaluations to assess whether the material has adequate fracture toughness. should be replaced with For potentially susceptible CASS materials, either enhanced volumetric examinations or a unit or component specific flaw tolerance evaluation (considering reduced fracture toughness and unit specific geometry and stress information) will be used to demonstrate that the thermally-embrittled material has adequate fracture

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses /Page 6 of 22 toughness in accordance with NUREG-1 801 Section XI.Ml2. This commitment is identified in Appendix A, Table A6.0-1 License Renewal Commitments, Item [27 for Unit 21 [28 for Unit 31.

For Unit 2 and Unit 3 Appendix B, B2.1.17 (page 8-72), the last sentence of the discussion under XI.Ml2 - Parameters Monitored/lnspected should be replaced with:

For potentially susceptible CASS materials, either enhanced volumetric examinations or a unit or component specific flaw tolerance evaluation (considering reduced fracture toughness and unit specific geometry and stress information) will be used to demonstrate that the thermally-embrittled material has adequate fracture toughness in accordance with NUREG-1 801 Section XI.Ml2. This commitment is captured under the ISI: Systems, Components, and Supports and is identified in Appendix A, Table A6.0-1 License Renewal Commitments, Item [27 for Unit 21 [28 for Unit 31.

Audit Item 44: The following wording should replace the wording in Unit 2 and Unit 3 Appendix B, Section 82.1.7 (page B-31), Enhancements:

Enhancement 1 : Heat Exchanger Baseline Inspection A baseline visual inspection will be performed of the accessible areas of the shell side (including accessible portions of the exterior side of the tubes) of one:

0 Millstone Unit 2 Reactor Building Closed Cooling Water heat exchanger, Millstone Unit 2 Emergency Diesel Generator Jacket Cooling Water heat exchanger, and 0

Millstone Unit 3 Emergency Diesel Generator Jacket Cooling Water heat exchanger.

These inspections will verify that the chemistry control portion of the closed cycle cooling system AMP is adequately maintaining the corrosion control of the closed cycle cooling heat exchangers. The Unit 2 Reactor Building Closed Cooling Water heat exchanger was chosen as a leading indicator because it has been in service for a longer period of time than Unit 3. This commitment is identified in Appendix A, Table A6.0-1 License Renewal Commitments, Item [29 for Unit 21 [30 for Unit 31.

This enhancement will be implemented prior to the period of extended operation.

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses /Page 7 of 22 Proqram Elements Affected Parameters Monitored/l nspected This program element recommends monitoring the effects of corrosion by surveillance testing and inspection to evaluate system and component performance.

The NUREG-1 801 recommended parameters to be monitored for a heat exchanger (i.e., heat exchanger flow, inlet and outlet temperatures, and differential pressure) are not specifically monitored by the program to indicate corrosion buildup. Instead, baseline inspections of the closed cycle cooling water side of a sample of closed-cycle cooling heat exchangers will be performed to verify the corrosion control program is acceptable and heat exchanger performance is maintained.

Detection of Aging Effects This program element recommends performance and functional testing to ensure acceptable functioning of the closed-cycle cooling water system or components serviced by the closed-cycle cooling water system.

Thermal performance testing of the closed-cycle cooling heat exchangers is not performed on most heat exchangers.

Instead, baseline inspections of the closed cycle cooling water side of a sample of closed-cycle cooling heat exchangers will be performed to verify the corrosion control program is acceptable and heat transfer fouling is not occurring.

Monitoring and Trending This program element recommends performing performance and functional tests at least once every 18 months to demonstrate system operability. Tests to evaluate heat removal capability of the system and degradation of system components are performed every five years. Thermal performance testing of the closed-cycle cooling heat exchangers is not performed on most heat exchangers.

Instead, baseline inspections of the closed cycle cooling water side of a sample of closed-cycle cooling heat exchangers will be performed to verify the corrosion control program is acceptable and heat removal capability is maintained.

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses /Page 8 of 22 The following wording should be inserted at the end of Unit 2 Appendix A, Section A2.1.7 (page A-8) and Unit 3 Appendix A, Section A2.1.6 (page A-6):

Commitments The following commitment will be implemented prior to the period of extended operation:

0 Heat Exchanger Baseline Inspection A baseline visual inspection will be performed of the accessible areas of the shell side (including accessible portions of the exterior side of the tubes) of one:

Millstone Unit 2 Reactor Building Closed Cooling Water heat exchanger, Millstone Unit 2 Emergency Diesel Generator Jacket Cooling Water heat exchanger, and Millstone Unit 3 Emergency Diesel Generator Jacket Cooling Water heat exchanger.

This commitment is identified in Appendix A, Table A6.0-1 License Renewal Commitments, Item [29 for Unit 21 [30 for Unit 31.

An additional item should be added to Unit 2 Appendix A, Table A6.0-1 (page A-39) and Unit 3 Appendix A, Table A6.0-1 (page A-38) as follows:

Item: 29 (Unit 2) and 30 (Unit 3)

Commitment:

A baseline visual inspection will be performed of the accessible areas of the shell side (including accessible portions of the exterior side of the tubes) of one:

Millstone Unit 2 Reactor Building Closed Cooling Water heat exchanger, Millstone Unit 2 Emergency Diesel Generator Jacket Cooling Water heat exchanger, and Millstone Unit 3 Emergency Diesel Generator Jacket Cooling Water heat exchanger.

Source: Closed-Cycle Cooling Water System Schedule: Prior to Period of Extended Operation.

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses /Page 9 of 22 Audit Item 47: Unit 2 Appendix A, Section A2.1.16 (page A-14) and Unit 3 Appendix A, Section A2.1.15 (page A-13), the third paragraph should state:

The Containment Appendix J Leakage Rate Test Program implements Type A and B tests to measure the overall primary Containment integrated leakage rate.

For Unit 2 and Unit 3 Appendix B, Section B2.1.16 (page B-63), the fourth paragraph should read:

The Containment Appendix J Leakage Rate Test Program implements Type A tests to measure the overall primary Containment integrated leakage rate (ILRT) and Type B tests to detect and measure local leakage across each pressure-containing or leakage limiting boundary for Containment penetrations, airlock doors and hatches, whose design incorporates a resilient seal, gasket or expansion bellows, and for electrical penetrations.

For Unit 2 and Unit 3 Appendix B, Section 82.1.16, Exception 2: XI.S4 - Leak Rate Testing (page B-67), the exception wording should read:

The NUREG-1801,Section XI.S4 discusses 10CFR50 Appendix J, Type A Integrated Leak Rate Testing (ILRT) as well as Type B and C Local Leak Rate Testing (LLRT). The lnservice Inspection Program: Containment Inspections credits only the Type A ILRT and Type B LLRT to manage the effects of aging identified in the NUREG-1 801 program element, Detection of Aging Effects.

Proqram Elements Affected Scope of Program This program element identifies three types of leak rate testing (Type A, B and C) as defined by 10 CFR50, Appendix J. The Inservice Inspection Program: Containment Inspections utilizes only the Type A integrated leak rate testing and Type B local teak rate tests to manage the effects of aging.

For Unit 2 Table 3.5.2-1 (page 3-443), the AMP listed for 0-Rings should be the lnservice Inspection Program: Containment Inspections, instead of Work Control Process and the Note should be B instead of E. Also, in Table 3.5.1, Item 3.5.1-06 (page 3-427), the Discussion should read:

Not consistent with NUREG-1801. Aging effects for the O-rings and the Containment moisture barrier is managed by the Inservice Inspection

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses /Page 10 of 22 Program: Containment Inspections. This program takes some exceptions to the NUREG-1801 AMP. Aging effects for gaskets are managed by the Work Control Process.

For Unit 3 Table 3.5.2-1 (page 3-516), the AMP listed for O-rings should be the lnservice Inspection Program: Containment Inspections instead of Work Control Process and the Note should be B? instead of E. Also, in Table 3.5.1, Item 3.5.1 -06 (page 3-497), the Discussion should read:

Not consistent with NUREG-1 801. Aging effects for the O-rings and the Containment moisture barrier is managed by the lnservice Inspection Program: Containment Inspections. This program takes some exceptions to the NUREG-1801 AMP. Aging effects for gaskets are managed by the Work Control Process.

Audit Item 54-1: The Note E should be H in Unit 2 Table 3.2.2-5 (page 3-140),

for the Spent Fuel Pool Cooling System component type Tubing and aging effect Loss of Material. Also, entries were inadvertently made in the NUREG-1801 Volume 2 Item and Table 1 Item columns.

Audit Item 54-2: The Note E should be H in Unit 3 Table 3.2.2-5 (page 3-145),

for the Fuel Pool Cooling and Purification component type Tubing and aging effect Loss of Material. Also, entries were inadvertently made in the NUREG-1801 Volume 2 Item and Table 1 Item columns.

Audit Item 58-1: The Note B should be E in Unit 2 Table 3.1.2-3 (page 3-68),

and Unit 3 Table 3.1.2-3 (page 3-77), for the Reactor Coolant System component type Bolting and aging effects Cracking and Loss of Pre-Load.

Audit Item 58-2: Unit 2 Tables 3.2.2-2 (page 3-122), and 3.2.2-4 (page 3-132),

(Safety Injection and Shutdown Cooling systems, respectively) should reflect NUREG-1801 matching to Item IV.CZ.4-g and Note E for the Bolting component type with the aging effect of Loss of Pre-Load.

Audit Item 58-3: The Note B should be El for the component type Bolting in Unit 3 Table 3.2.2-3 (page 3-131), and Unit 3 Table 3.2.2-4 (page 3-137), for Safety Injection and Residual Heat Removal, respectively.

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses /Page 11 of 22 Audit Item 58-4: The Note D should be E for the component type Closure Head Stud Assembly in Unit 2 Table 3.1.2-1 (page 3-43), for the Loss of Pre-Load aging effect.

Also, Note D should be E for the component type Instrument Tube Flange and StudslNutsNVashers in Unit 2 Table 3.1.2-1 (page 3-45), for the Loss of Pre-Load aging effect.

Audit Item 58-5: The Note D should be E for the component type Closure Head Stud Assembly in Unit 3 Table 3.1.2-1 (page 3-44), for the Loss of Pre-Load aging effect.

Audit Item 64: The Pipe component type Note D should be B for the Chemistry Control for Secondary Systems AMP in Unit 2 Table 3.4.2-9 (page 3-384). The same change applies to the Valve component type on page 3-385.

Audit Item 73: The Work Control Process was inadvertently listed as an AMP for managing loss of material in a Treated Water environment for the DC Switchgear A/C Unit Cooling Coils component type in Unit 2 Table 3.3.2-30 (page 3-274).

Audit Item 81-1 : Flow Accelerated Corrosion (FAC) was inadvertently listed as an AMP for the Steam Nozzle and Safe End component type in Unit 2 Table 3.1.2-4 (page 3-94).

Audit Item 81-2: The Flow Accelerated Corrosion AMP should be the Steam Generator Structural Integrity Program AMP for the Steam Nozzle Flow Restrictor component type in Unit 2 Table 3.1.2-4 (page 3-95). Also, the Note ID should be E for the same entry. In addition, the Discussion column in Unit 2 Table 3.1.l, Item 3.1.1 -25 (page 3-31), should replace Flow-Accelerated Corrosion program. with the following:

Flow-Accelerated Corrosion program for all items except the steam nozzle flow restrictor which is managed by the Steam Generator Structural Integrity Program AMP.

Audit Item 82-1: The Flow Accelerated Corrosion AMP should be added for the Feedwater Inlet Ring and Support component type for the Loss of Material for the internal Treated Water environment in Unit 2 Table 3.1.2-4 (page 3-88). The NUREG-1801 item match for this entry should be IV.Dl.3-a with Note B. Also, the Table 1 Item entry should be 3.1.1-21.

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses /Page 12 of 22 Audit Item 82-2: Unit 2 Section 3.1.2.2.14 (page 3-20) and Unit 2 Table 3.1.1, discussion for Item 3.1.1-21 (page 3-30) should state:

Although the Unit 2 steam generators are not CE System 80 steam generators, the feedwater inlet ring is included in the Flow Accelerated Corrosion program.

Audit Item 82-3: The Flow Accelerated Corrosion AMP should be added for the Feedwater Inlet Ring and Support component type for the Loss of Material for the internal Treated Water environment in the Unit 3 Table 3.1.2-4 (page 3-95).

The NUREG-1801 item match for this entry should be IV.Dl.3-a with Note B.

Also, the Table 1 Item entry should be 3.1.1 -21.

Audit Item 82-4: Unit 3 Section 3.1.2.2.14 (page 3-21) and Unit 3 Table 3.1.1, Item 3.1.l-21 (page 3-31), should state:

Although the Unit 3 steam generators are not CE System 80 steam generators, the feedwater inlet ring is included in the Flow Accelerated Corrosion program.

Audit Item 85: The following items clarify the inspection methods for selective I eac hing :

BURIED PIPE INSPECTION PROGRAM For Unit 2 Appendix A, Section A2.1.4 (page A-6) and Unit 3 Appendix A, Section A2.1.3 (page A-4 & A-5);

1. At the end of the Program Description section, the following should be added:

In addition to visual inspections, the field inspections for loss of material due to selective leaching will include mechanical means, such as resonance when struck by another object, scraping, or chipping.

2. Add the following to the first bulleted Commitment after the first sentence:

Inspection for the loss of material due to selective leaching will be performed by visual, and mechanical or other appropriate methods.

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses /Page 13 of 22

3. Add the following to the second bulleted Commitment after the first sentence:

These procedures will include the inspection for the loss of material due to selective leaching which will be performed by visual, and mechanical or other appropriate methods.

0 For Unit 2 and Unit 3, Appendix A, Table A6.0-1, Commitment 3 (page A-34 and A-33 respectively) add the following to the end of the commitment:

Inspection for the loss of material due to selective leaching will be performed by visual, and mechanical or other appropriate methods.

For Unit 2 and Unit 3, Appendix A, Table A6.0-1, Commitment 4 (page A-34 and A-33 respectively) add the following to the end of the commitment:

These procedures will include the inspection for the loss of material due to selective leaching which will be performed by visual, and mechanical or other appropriate methods.

For Unit 2 and Unit 3 Appendix B, Section B2.1.4, Program Description (page B-l9), the following should be inserted at the end of the section:

In addition to visual inspections, the field inspection for loss of material due to selective leaching will include mechanical means, such as resonance when struck by another object, scraping, or chipping.

For Unit 2 and Unit 3 Appendix B, Section B2.1.4 (page B-20), the following should be added to Enhancement 1 after the sentence that ends with...such as NACE Standard RP 0169.:

Inspection for the loss of material due to selective leaching will be performed by visual, and mechanical or other appropriate methods.

For Unit 2 and Unit 3 Appendix B, Section B2.1.4 (page 8-21), the following should be added to Enhancement 2 after the sentence that ends with...or for any other reason.:

These procedures will include the inspection for the loss of material due to selective leaching which will be performed by visual, and mechanical or other appropriate methods.

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses /Page 14 of 22 WORK CONTROL PROCESS For Unit 2 Appendix A, Section A2.1.25 (page A-23) and Unit 3 Appendix A, Section A2.1.24 (page A-22):

1. At the end of the Program Description section, the following should be added:

In addition to visual inspections, the field inspection for loss of material due to selective leaching will include mechanical means, such as resonance when struck by another object, scraping, or chipping.

2. As the second bulleted Commitment, the following should be added:

Selective Leaching Inspection Using the Work Control Process, a baseline inspection for the loss of material due to selective leaching will be performed on a representative sample of locations for susceptible materials by visual, and mechanical or other appropriate methods prior to entering the period of extended operation. This commitment is identified in Appendix A, Table A6.0-1 License Renewal Commitments, Item 30 (Unit 2) and 31 (Unit 3).

The following commitment should be added to Unit 2 Appendix A, Table A6.0-1 (page A-39) and Unit 3 Appendix A, Table A6.0-1 (page A-38):

Item: 30 (Unit 2) and 31 (Unit 3)

Commitment: Using the Work Control Process, a baseline inspection for the loss of material due to selective leaching will be performed on a representative sample of locations for susceptible materials by visual, and mechanical or other appropriate methods prior to entering the period of extended operation.

Source: Work Control Process Schedule: Prior to the Period of Extended Operation.

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses Attachment l/Page 15 of 22 For Unit 2 Appendix B, Section B2.1.25, Program Description (page B-107) and Unit 3 Appendix B, Section B2.1.25, Program Description (page B-108),

the following should be inserted at the end of the first paragraph:

When performing field inspections for loss of material due to selective leaching, visual inspections will include mechanical means, such as resonance when struck by another object, scraping, or chipping.

0 For Unit 2 and Unit 3 Appendix 9, Section B2.1.25, Detection of Aging Effects (page B-log), the following should be inserted after the first sentence:

When performing field inspections for loss of material due to selective leaching, visual inspections will include mechanical means, such as resonance when struck by another object, scraping, or chipping.

0 For Unit 2 and Unit 3 Appendix B, Section 82.1.25, (page B-112), new Enhancement 3 should be added and read as follows:

Enhancement 3: Selective Leaching Inspections Using the Work Control Process, a baseline inspection for the loss of material due to selective leaching will be performed on a representative sample of locations for susceptible materials by visual, and mechanical or other appropriate methods prior to entering the period of extended operation.

This commitment is identified in Appendix A, Table A6.0-1 License Renewal commitments, Item 30 (Unit 2) and 31 (Unit 3).

This enhancement will be implemented prior to the period of extended operation.

Program Elements Affected 0

Detection of Aging Effects The NUREG-1 801 program element identifies that the program should detect aging effects before there is a loss of structure or component intended function.

The baseline inspection for selective leaching will provide reasonable assurance that the loss of material aging effect, due to selective leaching, will be detected before there is a loss of intended function.

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses /Page 16 of 22 Audit Item 89: To clarify the examination techniques used for small bore piping, the wording in Unit 2 and Unit 3 Appendix B, Section B2.1.18 (page B-75) Based on risk significance (determined by an evaluation of the consequence of failure) and on the probability of failure; volumetric, surface, or VT-2 visual examinations may be performed for specific small-bore pipe welds and base metal areas as defined in the respective RI-IS1 Inspection Plans. should read: Based on risk significance (determined by an evaluation of the consequence of failure) and on the probability of failure; a volumetric, surface, or VT-2 visual examination is performed for specific small-bore pipe welds and base metal areas as defined in the respective RI-IS1 Inspection Plans. As a minimum, examples exist where each of the identified examination methods (i.e. volumetric, surface, and VT-2 visual) are identified in the RI-IS1 Plans for small bore locations.

Audit Item 97: Note 6 for Unit 2 Table 3.1.2-3 (page 3-83) for the RCS component type RCP Thermal Barriers and aging effect Loss of Fracture Toughness should be added. The Note for this item is revised by Item 42-1 of this additional information letter and is applicable to this component because it is CASS material.

The lnservice Inspection Program: Systems, Components and Supports should be the Work Control Process for Unit 2 Table 3.1.2-3 (page 3-83), and Unit 3 Table 3.1.2-3 (page 3-90), for the RCS component type RCP Thermal Barriers and aging effect Cracking. The Note for this item should be E in the Unit 2 LRA.

Also, the Discussion column in Unit 2 Table 3.1.1, Item 36 (page 3-33), and Unit 3 Table 3.1.l, item 36 (page 3-34), should read as follows:

Not consistent with NUREG-1 801.

Cracking is managed with the Chemistry Control for Primary Systems program and the Inservice Inspection Program: Systems, Components and Supports except for the RCP Thermal Barriers, which are managed with chemistry, and the Work Control Process. These programs take some exceptions to the NUREG-1801 AMPS.

Audit Item 100: Note C should be Note A for General Condition Monitoring line items in Unit 2 Table 3.5.2-25 (pages 3-532 through 3-538) and Unit 3 Table 3.5.2-36 (pages 3-643 through 3-648) since the General Condition Monitoring AMP performs the same inspections of structural supports as the Structures Monitoring Program AMP and is considered equivalent to the GALL AMP S6 Structures Monitoring Program.

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses /Page 17 of 22 Audit Item 101: Unit 2 Table 3.3.1, Item 3.3.1-17 (page 3-195), first sentence in the discussion should include and Buildup of Deposits after Loss of Material.

This also applies to Unit 3 Table 3.3.1, Item 3.3.1 -1 7 (page 3-21 0).

Audit Item 11 1 : The material Nickel-based Alloy should be Stainless Steel for the Primary Manway Cover and Diaphragm component type in Unit 3 Table 3.1.2-4 (page 3-98).

Audit Item 116: The following information clarifies when inaccessible medium voltage cables will be tested:

0 The commitment for verification testing should read:

ln-scope cable found to be submerged will be subject to an engineering evaluation and corrective action. The evaluation of cables having significant voltage found to be submerged in standing water for an extended period of time will be based on appropriate testing (using available technology consistent with NRC positions) of cables that are determined to be wetted for a significant period of time.

The Engineering evaluation will also address the appropriate testing requirements for the corresponding ten-year intervals during the period of extended operation. The test will use a proven methodology for detecting deterioration of the insulation system due to wetting. Examples of such tests include power factor, partial discharge, or polarization index, as described in EPRl TR-103834-P1-2, Effects of Moisture on the Life of Power Plant Cables, or other appropriate testing.

Testing will have acceptance criteria defined in accordance with the specific test identified. Occurrence of degradation that is adverse to quality is entered into the Corrective Action Program.

This commitment appears in the Unit 2 and Unit 3 LRAs in the following locations:

0 Unit 2 Appendix A, Section A.2.1.14 (page A-13)

Unit 2 Appendix A, Table A6.0-1, Commitment No. 11 (page A-36)

Unit 3 Appendix A, Section A.2.1.13 (page A-12) 0 Unit 3 Appendix A, Table A6.0-1, Commitment No. 11 (page A-35) 0 For the exception for engineering evaluation of submerged cables, the wording in Unit 2 and Unit 3 Appendix B, Section B.2.1.14 (page B-56)

Should evidence of submerged medium voltage cable with significant voltage be identified, the Inaccessible Medium Voltage Cables Not Subject

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses /Page 18 of 22 to 10 CFR 50.49 Environmental Qualification Requirements program requires an engineering evaluation to determine the appropriate actions to fully address the identified condition of the cables, including the identification of testing requirements as necessary. should read Should evidence of medium voltage cable submerged in standing water for an extended period of time and having significant voltage be identified, Engineering will evaluate the acceptability of the cables based on appropriate testing.

The discussion of the program elements affected by the exception for engineering evaluation of submerged cables in Unit 2 and Unit 3 Appendix B, Section B.2.1.14 (pages B-56, B-57) should indicate that for in-scope medium voltage cables with significant voltage that have been submerged in standing water for an extended period of time, Engineering will evaluate the condition of the cable insulation based on appropriate testing.

The enhancement for verification testing in Unit 2 and Unit 3 Appendix B, Section B.2.1.14 (page B-57) should read:

If inspections of underground enclosures performed in accordance with the Structures Monitoring Program identify evidence of cable submergence (for in-scope medium voltage cables), Engineering will be notified of the condition for evaluation and corrective action. The evaluation of cables having significant voltage and submerged in standing water for an extended period of time will be based on appropriate testing (using available technology consistent with NRC positions) of cables that are determined to be wetted for a significant period of time. The Engineering evaluation will also address the appropriate testing requirements for the corresponding ten-year intervals during the period of extended operation. The test will use a proven methodology for detecting deterioration of the insulation system due to wetting. Examples of such tests include power factor, partial discharge, or polarization index, as described in EPRl TR-103834-P1-2, Effects of Moisture on the Life of Power Plant Cables, or other appropriate testing. Testing will have acceptance criteria defined in accordance with the specific test identified. Occurrence of degradation that is adverse to quality is entered into the Corrective Action Program.

The discussion of the program elements affected by the enhancement for verification testing in Unit 2 and Unit 3 Appendix B, Section 8.2.1.14 (page B-58) should indicate that for in-scope medium voltage cables with significant voltage that have been submerged in standing water for an extended period of time, Engineering will evaluate the condition of the cable insulation based on appropriate testing.

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses /Page 19 of 22 Audit Item 122-1: For the Unit 3 Fire Protection System, as presented in Unit 2 Table 3.3.2-32 (page 3-291) and Unit 3 Table 3.3.2-37 (page 3-346), the Work Control Process AMP for the carbon steel Pipe group with an internal air environment should be the Fire Protection Program AMP. The NUREG-1 801 item should be Vll.H2.3-a and the Notes should be C, 2.

Audit Item 122-2: For the Unit 3 Fire Protection System, as presented in Unit 2 Table 3.3.2-32 (page 3-296) and Unit 3 Table 3.3.2-37 (page 3-351), Note 2 should be included with the copper alloy Valves component type with an internal air environment for the Unit 3 Fire Protection System. The aging effect of Loss of Material should be added to this component type. The Fire Protection Program AMP will manage these aging effects.

Audit Item 122-3: For the Unit 2 Fire Protection System, as presented in Unit 2 Table 3.3.2-31 (page 3-282) and Unit 3 Table 3.3.2-36 (page 3-337), Note 2 should be included with the copper alloy Sprinkler Head component type with an internal air environment for the Unit 2 Fire Protection System. The aging effect of Loss of Material should be added to this component type. The Fire Protection Program AMP will manage these aging effects.

Audit Item 136: The Unit 3 Table 3.5.1, Item 28 (page 3-505) Discussion column should have included a statement that loss of material of steel-lined concrete sumps is managed by the Work Control Process AMP.

In addition, a further evaluation recommended discussion should have been included in LRA Section 3.5.2.2 as follows:

There are no in-scope steel-lined concrete tanks at Millstone. Loss of material for steel-lined concrete sumps is managed by the Work Control Process AMP.

Audit Item 137: Unit 3 Table 3.3.2-46 (pages 3-386 to 3-390) inadvertently had entries in the NUREG-1 801 Volume 2 Item and Table 1 Item columns for all line entries associated with the Cracking aging effect. The Note for each Cracking line entry should be H.

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses /Page 20 of 22 Audit Items 138, 139,140 & 59: The following wording should be added to Unit 2 and Unit 3 Appendix B, Section 82.1.25 (page B-112):

Enhancement 2 - Verification of Program Scope A review of the Work Control Process inspection opportunities for each material and environment group, supplemental to the initial review conducted during the development of the LRA, will be performed. Baseline inspections will be performed for the material and environment combinations that have not been inspected as part of the Work Control Process. This commitment is identified in Appendix A, Table A6.0-1 License Renewal Commitments, Items [31 for Unit 21 [32 for Unit 31.

This commitment will be implemented prior to the period of extended operation.

The following should be added to Unit 2 commitments section, Appendix A A2.1.25 (page A-23) and Unit 3 commitments section, Appendix A, A2.1.24 (page A-22):

Verification of Program Scope A review of the Work Control Process inspection opportunities for each material and environment group, supplemental to the initial review conducted during the development of the LRA, will be performed.

Baseline inspections will be performed for the material and environment combinations that have not been inspected as part of the Work control Process. This commitment is identified in Appendix A, Table A6.0-1 License Renewal Commitments, Items [31 for Unit 21 [32 for Unit 31.

The following commitment should be added to Unit 2 Appendix A, Table A6.0-1 (page A-39) and Unit 3 Appendix A, Table A6.0-1 (page A-38):

Item: 31 (Unit 2), 32 (Unit 3)

Commitment: A review of the Work Control Process inspection opportunities for each material and environment group supplemental to the initial review, conducted during the development of the LRA, will be performed. Baseline inspections will be performed for the material and environment combinations that have not been inspected as part of the Work control Process.

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses /Page 21 of 22 Source: Work Control Process Schedule: Prior to Period of Extended Operation.

Audit Item 142: Unit 2 Table 3.3.2-32 (pages 3-286 to 3-297) and the Unit 3 Table 3.3.2-37 (pages 3-341 to 3-352) should state 3.3.1-29 for the second Table 1 Item listed for components with Cast Iron/Raw Water and Copper Alloy/Raw Water materiaVenvironment combinations. The NUREG-1801 Volume 2 Item column for the affected component types should be VII.Cl.2-a except for the Pipe and Tubing component types which should be VII.Cl.l-a.

Audit Item 143: Unit 2 Table 3.3.1, Item 06 (page 3-190) and Unit 3 Table 3.3.1, Item 06 (page 3-205) should include the following words between the second and third sentences:

For the non-tank components, Loss of Material is managed by the Work Control Process.

Additionally, Unit 2 Section 3.3.2.2.6 (page 3-184) and Unit 3 Section 3.3.2.2.6 (page 3-1 98) should include the following words at the end of the first sentence:

For the non-tank components, Loss of Material is managed by the Work Control Process.

Audit Item 145: Unit 2 Table 3.3.2-41 (page 3-333) should have additional information for the component types Pumps (Cast Iron/Raw Water entry) and Valves (Copper Alloys/Raw Water entry). Each component type should have an additional entry for the Aging Management Program, NUREG-1801 Volume 2 Item, Table 1 Item and Notes columns which adds the entries Work Control Process, VII.Cl.5-a for pumps and VII.Cl.2-a for valves, 3.3.1-29, and E, respectively.

Audit Item 146: Unit 3 Table 3.3.2-49 (pages 2-395, 396) should not include entries in the NUREG-1801 Volume 2 Item and Table 1 Item columns for all line entries associated with the Cracking aging effect. The Note for each Cracking line entry should be H.

Audit Item 150: In Unit 3 Table 3.3.2-12 (page 3-250) the oil environment was inadvertently listed for the instrument air compressor.

Serial No.04-320 Docket Nos.: 50-336/423 Additional Information in Support of Applications for Renewed Operating Licenses /Page 22 of 22 Audit Item 152: In Unit 2 Table 3.1.2-3 (page 3-82) the GALL match for the RCP Seal Cooler (Inner Tube) should be None for the Cracking aging effect entry. In addition, Note E should be H and a new Plant Specific Note should be added that states:

Cracking of the component type RCP Seal Cooler (Inner Tube) is managed by Primary Water Chemistry. However, there are additional means for detecting cracking. The additional means consist of monitoring the radiation monitors in the RBCCW System and chemistry sampling of the RBCCW.

Audit Item 161: The Note E should be C in Unit 3 Table 3.5.2-37 (page 3-655) for the rubber material of the Watertight Door Gasket structural member.

Audit Item 163: The Note 5 should be 6 in Unit 3 Table 3.3.2-15 (page 3-273)

CVCS Component Types Thermal Regeneration Chiller Condenser (shell) and Thermal Regeneration Chiller Evaporator (shell) for an internal environment of air.

Audit Item 164: The material listed for the Regenerative Heat Exchanger (Channel Head) and Regenerative Channel Head (Shell) in Unit 3 Table 3.3.2-1 5 (page 3-268) should be Stainless Steel (CASS) rather than just Stainless Steel.