L-MT-06-018, License Renewal Application Annual Update

License Renewal Application Annual Update

ML060800360
Person / Time
Site:	Monticello
Issue date:	03/15/2006
From:	Conway J Nuclear Management Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
FOIA/PA-2010-0209, L-MT-06-018, TAC MC6440
Download: ML060800360 (151)

Text

NMC Monticello Nuclear Generating Plant Committed to NudcearExcel Operated by Nuclear Management Company, LLC March 15, 2006 L-MT-06-018 10 CFR Part 54 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Monticello Nuclear Generating Plant Docket 50-263 License No. DPR-22 Monticello Nuclear Generating Plant -License Renewal Application Annual Update (TAC No. MC6440)By letter dated March 16, 2005, Nuclear Management Company, LLC (NMC), submitted the Monticello Nuclear Generating Plant (MNGP) License Renewal Application (LRA).In accordance with 10 CFR 54.21(b), NMC is submitting an update to the LRA, including the Updated Safety Analysis Report (USAR) supplement which reflects the changes made to the MNGP current licensing basis since the LRA was submitted.

These changes are required to be submitted each year and at least 3 months prior to the scheduled completion of the LRA review by the NRC.NMC has completed the annual review and concluded that there are changes that materially affect the content of the MNGP LRA. Enclosure 1 provides the details of the changes and the effect on the content of the MNGP LRA including the revisions to the MNGP USAR supplement.

This submittal does not change the NMC determination in the original March 16, 2005, submittal that the measures described in the MNGP LRA provide assurance that the effects of aging will be adequately managed, consistent with the current licensing basis, for the requested period of extended operation.

This letter contains the following new commitments:

New Commitments:

NMC has inspected the in-core monitoring dry tubes on an every-other refueling outage periodicity and will continue to perform this inspection during the period of extended operation, per the guidance provided in GE SIL- 409.2807 West County Road 75

• Monticello, Minnesota 55362-9637 A113 Telephone:

763.295.5151 USNRC Page 2* The NMC is an active member of the BWRVIP [Boiling Water Reactor Vessels Internal Program] and will continue to follow applicable inspection guidelines and recommendations, which have been reviewed and approved by the executive committee of the BWRVIP, throughout the period of extended operation for MNGP.* NMC will follow the guidance provided in BWRVIP-139, Steam Dryer Inspection and Flaw Evaluation Guidelines (April 2005), for the MNGP steam dryer inspections during the period of extended operation.

NMC will add inspection requirements for the P1, P2, and P3 Core Spray piping welds, at MNGP, in accordance with guidance provided in BWRVIP-18, or subsequent revisions, prior to the period of extended operation.

I declare under penalty of perjury that the foregoing is true and correct.Executed on March 14 .,2006.I' I-pynn T. Conwy/ )Lbite Vice President, Monti ear Generating Plant Nuclear Management Company, LLC Enclosure cc: Administrator, Region IlIl, USNRC Project Manager, Monticello, USNRC License Renewal Project Manager, Monticello, USNRC Resident Inspector, Monticello, USNRC Minnesota Department of Commerce Pillsbury, Winthrop, Shaw, Pittman; LLP (David Lewis)

ENCLOSURE 1 Monticello Nuclear Generating Plant -License Renewal Application Annual Update In accordance with the requirements of 10 CFR 54.21(b), Nuclear Management Company, LLC (NMC) is submitting the first annual update to the Monticello Nuclear Generating Plant (MNGP) License Renewal Application (LRA).The enclosure is divided into three sections: (I) Methodology, (II) Current Licensing Basis Changes, and (Ill) Clarifying Changes to the MNGP LRA.I. METHODOLOGY Plant changes made between January 6, 2005, and March 1, 2006, were reviewed in preparation for this first annual update to the MNGP LRA. NMC evaluated the changes to the current licensing basis and determined those that materially affected the contents of the LRA.These reviews focused specifically on plant changes that would require new information or revisions to existing information in the MNGP LRA. These LRA changes are detailed later in this submittal.

In some cases, plant changes occurred that had no effect on information contained in the LRA; therefore, these changes are not discussed in this submittal.

This MNGP LRA Annual Update incorporates changes from the equipment database and current licensing basis that reflect the plant as it existed on March 1, 2006.II. CURENT LICENSING BASIS CHANGES NMC is required, by 10 CFR 54.21 (b), to provide an annual report of changes to the MNGP current licensing basis (CLB) that materially affect the contents of the MNGP LRA, including the Updated Safety Analysis Report Supplement.

The following CLB changes have been made since the initial submittal of the MNGP LRA:* NMC has consolidated the various site-specific Quality Assurance (QA)programs into a common fleet QA program. Various sections in the USAR have been revised due to the replacement of the Xcel Energy, Inc., Operational Quality Assurance Plan (OQAP) with the Nuclear Management Company NMC-1,"Quality Assurance Topical Report," which superseded the OQAP. This QA program change was approved by NRC safety evaluation reports dated January 13 and March 24, 2005.* NMC has received NRC approval, License Amendment 138, to eliminate the requirements for hydrogen recombiners and relax the requirements for hydrogen and oxygen monitoring.

Page 1 of 149 ENCLOSURE 1 11. CLARIFYING CHANGES TO THE LRA LRA Section 1 -ADMINISTRATIVE INFORMATION Table 1.5-01 Abbreviations During review of the MNGP LRA, NMC determined that Section 1.5-01, Abbreviation Table, should be clarified.

System "DGN" is not listed. System "CWT" was incorrectly listed as "CW." The word"system" is not used consistently. "HPC" is defined as "High Pressure Coolant" when it should be "High Pressure Coolant Injection System." "RCI" is defined as "Reactor Core Isolation" and.it should be "Reactor Core Isolation Cooling System." DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold text in brackets; deletions are strikethrough)

Table 1.5-01, on LRA pages 1-15, 1-16 and 1-22, is revised as follows: Table 1.5-01' Abbreviations CV Control Valve[IW CWT] Circulating Water [System]DBA Design Basis Accident DG Diesel Generator DGB Diesel Generator Building[DGN Emergency Diesel Generator System]HPB HPCI Building_ HPC lHigh Pressure Coolant Injection System]HPCI High Pressure Coolant Injection RBM Rod Block Monitor[RCI Reactor Core Isolation Cooling System]RCIC Reactor Core Isolation Cooling Page 2 of 149 ENCLOSURE 1 LRA Section 2.1 -SCOPING AND SCREENING METHODOLOGY Table 2.1-1 Intended Function Definitions BACKGROUND (2.3.1-2)During discussions with the NRC staff, NMC determined that LRA Table 2.3.1-3, Reactor Pressure Vessel Internals, should be revised to include the intended function of"Spray Pattern" for the Core Spray Lines, Spargers and Spray Nozzles.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table 2.1-1 Intended Function Definitions Component Intended Functions Definition Mechanical Pressure Boundary/Fission Product Provide pressure boundary or essentially Barrier leak tight barrier to protect public health and safety in the event of any postulated design basis events.[Spray Pattern To provide adequate flow in a specified distribution spray pattern.]Structural Support Provide structural support to safety related components.

Page 3 of 149 ENCLOSURE 1 LRA Section 2.1 -SCOPING AND SCREENING METHODOLOGY 2.1.4 Scoping Methodology 2.1.4.2.2 Scoping Criterion 2 -Non-Safety Related Affecting Safety Related BACKGROUND (2.1-2a)During discussions with the NRC staff, NMC determined that for the purposes of clarification, using the ground as an equivalent anchor required that the below grade piping be included in-scope for license renewal. Therefore, a review of the additional in-scope piping was performed to determine the changes/additions required to material, environment, aging effects and aging management programs.

The following clarifications were made: DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

1. LRA Section 2.1.4.2.2, Scoping Criterion 2 -Non-Safety Related Affecting Safety Related, Part b was revised to state: b. NSR SSCs Directly Connected to Scoping Criterion I SSCs For NSR SSCs directly connected to Scoping Criterion I SSCs, the in-scope boundary for license renewal extends into the NSR portion of the piping and supports up to and including the first equivalent anchor beyond the safety/non-safety interface.

For Monticello, the first equivalent anchor is that point beyond which failure of the piping system will not prevent the satisfactory accomplishment of the Scoping Criterion 1 function of the connected SSCs. Examples that constitute the first equivalent anchor include: a true anchor; a large piece of plant equipment; a building penetration;

[buried piping;] and, two levels of support in each orthogonal direction.

In general, equivalent anchors were selected consistent with the pipe analyses of record that demonstrate seismic adequacy of the various configurations.

The piping components and supports up to and including the first equivalent anchor [and buried piping used as an equivalent anchor] are in-scope for license renewal. Moreover, when further evaluated, NSR piping components and supports attached to Scoping Criterion 1 piping were found to be in-scope for license renewal for other reasons in most cases.Page 4 of 149 ENCLOSURE I LRA Section 2.1 -SCOPING AND SCREENING METHODOLOGY 2.1.4 Scoping Methodology 2.1.4.2.2 Scoping Criterion 2 -Non-Safety Related Affecting Safety Related BACKGROUND (Rill-B2.1

.12-3)LRA Section 2.1.4.2.2 identifies that the steam dryer assembly is in the scope of license renewal under Scoping Criterion 2, Non-Safety-Related Affecting Safety-Related.

Although BWRVIP guidance had not been issued at the time of preparation of the MNGP LRA, it was expected that BWRVIP guidance would be forthcoming and that the MNGP would follow this guidance.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough) 2.1.4.2.2 Scoping Criterion 2 -Non-Safety Related Affecting Safety Related c. NSR SSCs in Spatial Proximity of Scoping Criterion I SSCs* Steam Dryer Assembly.

Industry operating experience has shown that steam dryer assembly structural failures can occur. In some cases, operating at higher power levels was a contributing factor. In 1998, the thermal power of Monticello was increased from 1670 MWt to 1775 MWt.MNGP has not experienced any steam dryer failures during the period of increased power operation and dryer failures in the industry have typically been attributed to design, not aging, concerns.

During evaluation of the Dresden/Quad Cities Station LRA, the NRC recommended the steam dryers be categorized as Scoping Criterion 2 items. Consistent with this recommendation, the MNGP has included the steam dryer assembly as in-scope for license renewal. [NMC will follow the guidance provided in BWRVIP-139, Steam Dryer Inspection and Flaw Evaluation Guidelines (April 2005), for the MNGP steam dryer inspections.]

Page 5 of 149 ENCLOSURE I LRA Section 2.1 -SCOPING AND SCREENING METHODOLOGY 2.1.4 Scoping Methodology 2.1.4.3.2 Unresolved ISGs BACKGROUND (2.1.4.3.2-01i)

Upon further review subsequent to submitting the LRA to identify inspection locations, it was determined that all piping in this inspection group is of actual diameter 2 inches and less. In accordance with the plant piping specification, only socket weld connections are used in such applications and no butt welds. Therefore, inspections of this piping for the One-Time Inspection Program will consist of VT-2 examinations during pressure testing for system leaks upon return to service from outages and destructive examination of any socket welds removed from service prior to the period of extended operation.

DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough) 2.1.4.3.2 Unresolved ISGs Cracking of Class I Small-Bore Piping The MNGP One-Time Inspection Program for small-bore piping will be representative of all Class I piping, including

[1 inch and lcss, with full penetration butt welds 2-inch and less with socket weld connections].

Page 6 of 149 ENCLOSURE I LRA Section 2.2 -Plant Level Scoping Results BACKGROUND (CLB Change)NRC approved License Amendment 138 for MNGP, which eliminated the requirements for hydrogen recombiners and relax the requirements for hydrogen and oxygen monitoring.

DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table 2.2-1 Plant Level Scoping Results Description System or Within Scope Comments Structure of License Code Renewal?SRP Evaluation Group: Engineered Safety Features Combustible Gas Control CGC [Yes Deleted] [Deleted NRC approval granted to[(Seetien 2.3.2.2) Deleted] remove system. System to be isolated and capped during 2005 refueling outage-]Page 7 of 149 ENCLOSURE 1 LRA Section 2.3 -Scoping and Screening Results: Mechanical Systems 2.3.1.3 Reactor Pressure Vessel Internals BACKGROUND (2.3.1-2)During discussions with the NRC staff, NMC determined that LRA Table 2.3.1-3, Reactor Pressure Vessel Internals, should be revised to include the intended function of"Spray Pattern" for the Core Spray Lines, Spargers and Spray Nozzles. The revision to Table 2.3.1-3 is as follows: DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table 2.3.1-3 Reactor Pressure Vessel Internals Subcomponent Intended Function CORE SPRAY LINES AND SPARGERS PIPING SUPPORTS CLAMP MODIFICATION CORE SPRAY LINES (HEADERS)

PRESSURE BOUNDARY SPRAY RINGS.SPRAY NOZZLES THERMAL SLEEVES[CORE SPRAY LINES, SPARGERS AND SPRAY PATTERN]SPRAY NOZZLES Page 8 of 149 ENCLOSURE 1 LRA Section 2.3 -Scoping and Screening Results: Mechanical Systems 2.3.2.2 Combustible Gas Control System BACKGROUND (CLB Change)NRC approved License Amendment 138 for MNGP, which eliminated the requirements for hydrogen recombiners and relax the requirements for hydrogen and oxygen monitoring.

DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough) 2.3.2.2 Combustible Gas Control System[System Deseription Deleted][Thc Combustible Gas Control (CGC) System is designed to maintain primary containmcnt oxygen concentratio%

rcsulting from long-tcrm radiolytic deeempesition of coolant and corrosion of metals belew thc flammability limit of oxygen/hydrogen mixtures following a los of coolant accident.

The system aeeomplishes this by utilizing hydrogenloxygen recombincrs, which causc the H2 and 02 to combinc to form watcr, thereby redueing their concentration within containmcnt.

This standby system consists of two trains. Thc bulk of the CGC cquipmcnt resides on two scparatc skids in thc Reactor Building.

Upon activation the CGC System draws f4tw~li atnephW i .^+nte ^ -;F~D Feeernbinton of hydF;gn and ox= ygen, and then mixes thc hot cxhaust gas with watcr supplied by the Residual Heat Reemoval (RHR) System beforc discharging the mixturc- to thc supprcssion pool. Thc CCC Syste prmrycntainmclnt isolation valves arc supplied pncumatic peweF by thc RHR Scrvicc Watcr (ESW Syste) auxiliary omprssors.

Amendmant No.138 to Facility Operating Weense No. DPR 22 for the MNGP climinates requiremants for hydrOgen rFcombiners.

ThcCGC System, and thc rclated plant procedurcs for controlling 02 concentrations in the primary---.+_ --+- A _ .:, -.- .P .---I- +o r c t > A- :e -+. .- -., -. ." : coniainmcni, arc avalable Tcer usc unff inc Me k ystcm Is OacOSvatea Dy cutting and capping process lincs conncsting to intcrfacing systems during thc 2005 Fefueling outagc.Each CGC skid contains a fan bloweF, heater, Feaete chamber, Spray eeoleF, water straincr, and associated valvas and piping. A rFecriulation linc from the watcr scparator to thc fan bloer intakc allo ws for controlling the rats of rcaction if cxcess ive tcm perature builds in the Feaater chamber. Sk(id piping is stainless steel whilc thc influent and effluent piping, and much of thc .atcr supply piping, is carbon steel.Under the amended epcrafing liacnse, the in scopc peortion of the CCC Systc consists of the piping from thc drywell and from the supprcssion pool up to, and including, thaei r raspetiv isolation Yalves. Alse, the piping intfaeaaing with the Page 9 of 149 ENCLOSURE 1 Residual Heat Rcemoval (RHR) system up to, and including, the first valve isolating the two systems.The deoceriptie n above Fesults in same S~s in this system bin in copcin aeOeordanee with 10 CFR 54.4(a)(1).

In addition, some SCs are in scope due to Environmental Qualification in acordance with 10 CFR 64.(a)(3).

The portions of the CGC System eontaining eomponents subject to an AMR extend from the drywell atmosphere intake header, the return header terminating at the ouprocionpool, and the lines proyiding coolant frm the RHR system, to their roopcctivo points of isolation.

System Function Listing A eomprehensive listing of funetions associated with the Combustible Gas Control System, oer _pccifie ccmponent contained in the systeno, ic proyidAd in the osummrna belew.dc: CGCG4 Gf12 GCi3 Thc Combustible Gas Control System maintains F thc concentration of oxygen in the pest accident containmcnt to non combustible level-Commcnt: Amcndmcnt No.138 to Facility Operating License No. DPR 22 for the Monticcilo Nucicar Gcncrating Plant climinatco rcguiremcnts for hydrogen recombincrS.

Howevcr, th.CGC System and the Felated plant pro--ccdurcs for controlling 02 con entrations in the primnary containmcnt using the system will be etained until the CGC System is abandoned in placc during the 2005 refueling outagc.Codc: CGC 02 Ci4 Gfi-2 C P.rimary Containment

.oslation.

Preo/ide&-primafy containment ioelatien fFr theos periso S of. t_ o v v system that intcrfacc with the primary eentainment X (val':es and pi ping), Cemment: None Code: CGC EQ GCri GpI3 Thc system contains components-vhihperrerm functions credited in the currcnt lic g singbasis for EnrOnntal Qualifieationv r.Commcnt: N~no.USAR Refcrcnce Additional Combustible Gas Contr^l Sysetcm details arc provided in SCction 5.2.1.5 and Seotion 5.2.2.9 of the USA.R.License Renewal Dra.ng Thc licco renewal drawings for the Cmnbustible Gao Control System aro listed belew: I D '2nIA^I D ^An^Ct hl- .> '{ --l 'J --'I D Q A'o7 I D fAOQ{7 LR-36258 Page 10 of 149 ENCLOSURE 1 CnmnvnnvntR-hoppi in nn ALM vlXXJJwgxir

---J--. .- -- -, -.-------I- ------- .---- .1 -._. A. .. A. ..I nnmnnnrni T'lr lflI¶ iniT rjIrw 1m .I.--..-... .,- .- .S --... .1-- ....- -. --I. 1 ...- ..- .. .-I-Arl -rv t Io -IN Is 1% _l wr -. -- rv l r r r 4 -re -g -; --& rtelr-I S- 1_ArArrinoin :i[1It: ::::;i U: *.-:ari

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function(s).

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--I- -.Table 2.3.2 2 Combustiblc Gas Control System Component Group intended-Funetien FASTENERS!BOLTING PRESSURE BOUNDARY PIPING AND FITTINGS PRESSURE BOUNDARY VALVE BODIES PRESSURE BOUNDARY Page 11 of 149 ENCLOSURE 1 LRA Section 2.3 -Scoping and Screening Results: Mechanical Systems 2.3.3.1 Alternate Nitrogen System BACKGROUND (2.3.3.1-1)

The nitrogen supply bottles shown on LR boundary drawing LR-36049-10 at location B-8 and C-8 are periodically replaced and therefore are not long-lived and not subject to aging management review per the requirements of 10 CFR 54.21(a).

Consequently, these nitrogen supply bottles are not listed in LRA Table 2.3.3-1.The text description of the AN2 components subject to AMR in the last paragraph of LRA Section 2.3.3.1 (System Description) is therefore clarified to state that the bottles are not subject to AMR.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough) 2.3.3.1 Alternate Nitrogen System System Description The portions of the AN2 System containing components subject to an AMR extend from the above mentioned pneumatically served components in the drywell and at the primary containment boundary, back to the nitrogen [supply battles distribution rack]in the Turbine Building.

[The nitrogen supply bottles connected to the distribution rack are not long-lived components and not subject to an AMR.]Page 12 of 149 ENCLOSURE 1 LRA Section 2.3 -Scoping and Screening Results: Mechanical Systems 2.3.3.4 Control Rod Drive System BACKGROUND (2.3.3.4-01)

During review of the MNGP LRA it was determined that LR-36042 drawing should be added to LRA Section 2.3.3.4, CRD System, License Renewal Drawings).

DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough) 2.3.3.4 Control Rod Drive System License Renewal Drawings The license renewal drawings for the Control Rod Drive System are listed below: LR-36036 LR-36039[LR-360421 LR-36043 LR-36044 LR-36242 LR-36242-1 LR-36242-2 LR-36244 LR-36245 LR-36254 Page 13 of 149 ENCLOSURE 1 LRA Section 2.3 -Scoping and Screening Results: Mechanical Systems 2.3.3.13 Radwaste Solid and Liquid System BACKGROUND (RiII-2.3-01)

During discussions with the NRC Staff, NMC determined that the text description for the Radwaste System boundary in the LRA Section 2.3.3.13 needed to be revised.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough) 2.3.3.13 Radwaste Solid and Liquid System System Description

...AII Radwaste Solid and Liquid System components existing in either the Turbine[Building]

or [ReaetoF Buildigs, and-constituting within the Secondary Containment boundary which constitute]

a liquid pressure boundary, are in-scope. This includes piping, valve bodies, tanks, pump casings, orifices, drains, heat exchangers and fasteners.

[The entire Reactor Building is considered Secondary Containment with the following exceptions:

Elevation Description 962'6 Recirc Pump MG Set Room 962'6 Cleanup Phase Separators and Waste Sludge Tank Area 962'6 Pump Room 962'6 Condensate Phase Separator and Tank Area 985'6 Standby Gas Treatment System Rooms 985'6 Main Exhaust Plenum 985'6 Filter and Fan Room above MG Sets 985'6 Cleanup Filter Demin Holding Pump Room 985'6 Radwaste Pump Area 985'6 Chemical Waste Filter Demin Collection and Waste Collection Tank Room 1001' Seven Filter Demin Vessel Vaults (when the vault hatches are in place)]Page 14 of 149 ENCLOSURE 1 LRA Section 2.3 -Scoping and Screening Results: Mechanical Systems 2.3.3.16 Service and Seal Water System BACKGROUND (2.1-2a)During discussions with the NRC staff, NMC determined that for the purposes of clarification, using the ground as an equivalent anchor required that the below grade piping be included in-scope for license renewal. Therefore, a review of the additional in-scope piping was performed to determine the changes/additions required to material, environment, aging effects and aging management programs.

The following clarifications were made: For the Service and Seal Water (SSW) system, Drawing LR-36489 is added to LRA Section 2.3.3.16, Service and Seal Water System, License Renewal Drawings.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough) 2.3.3.16 Service and Seal Water System License Renewal Drawings The license renewal drawings for the Service and Seal Water System are listed below: LR-36041 LR-36665 LR-36041-2 LR-36665-2 LR-36048 LR-36666[LR-36489]

LR-36807 LR-36664 LR-1 55483-1 Page 15 of 149 ENCLOSURE 1 LRA Section 2.3 -Scoping and Screening Results: Mechanical Systems 2.3.3.18 Wells and Domestic Water System BACKGROUND (RilI-2.3.3.1 8-01)A modification replaced the original PVC piping drains with C-276 (Hastelloy) in 2005 to remove intervening combustibles between redundant divisions of safe shutdown equipment in the Intake Structure.

Per the modification, the new piping and supports are Seismic Il/I.Therefore, these drains meet scoping criterion (a)(2) and are required to be within the scope of license renewal.The drains fall within the Wells and Domestic Water System (WDW). The associated LRA sections will be revised to address these drain lines being within scope.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough) 2.3.3.18 Wells and Domestic Water System System Description The Wells and Domestic Water (WDW) System includes the Domestic Water, Sanitary Sewer, Acid Drain, Storm Drain, and Turbine Building Normal Drain subsystems as described below. [Also included is the Sodium Hypochlorite (SHC) Building floor drain piping.] ...The Turbine Building Normal Drain Subsystem removes water from areas in the Turbine Building where there is no potential for radioactive contamination and transports it to the river.[The SHC Building is located on top of the Intake Structure.

The SHC Building floor drain piping penetrates the ceiling of the Intake Structure and transports any leakage to a polyethylene drum located in the Intake Structure.]

[One reason why T-the WDW System is in-scope for LR is] because of check valves and connected piping located in the floor drain lines of both EDG rooms. The valves are located below the surface of the floor and are accessible through bolted access covers located at floor level in the 11 EDG room....Included in this category are roof drains and clean (non-radioactive) floor drains not buried in concrete or ground [and the SHC Building floor drain piping]. Potentially radioactive floor drains are included in the Radwaste Solid and Liquid (RAD) System.The portions of the Wells and Domestic Water System containing components subject to an AMR include the check valves and connected floor drain piping located in the EDG rooms, domestic water piping located in the Turbine Building, EFT Building and main control room[,yend l roof drains and clean (non-radioactive) floor drains not buried in concrete or ground, located throughout the plant [and the SHC Building floor drain piping].Page 16 of 149 ENCLOSURE 1 LRA Section 2.4 -Scoping and Screening Results: Containments, Structures, and Component Supports 2.4.8 Intake Structure BACKGROUND (2.1-01)During discussions with the NRC staff regarding equipment stored onsite that is required by station procedures to be installed during emergency or abnormal conditions in accordance with the current licensing basis, NMC concluded that; the description of the steel plates in the Current License Basis (CLB) and their dedicated use for external flood protection to serve as flood barriers for specific Class I structure openings and penetrations warranted their inclusion in License Renewal scope per 10 CFR 54.4 (a)(2). Similarly, the Intake Structure original floor steel hatch covers, staged to provide external flood protection as described in the MNGP Operations Manual A.6 (Acts of Nature), warranted their inclusion in License Renewal scope.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Components/Commodities Subject to an AMR The component groups for the Intake Structure that require aging management review are addressed in Table 2.4.8-1 along with each component group's intended function(s).

Table 2.4.8-1 Intake Structure Component Group Intended Function CARBON STEEL, LOW ALLOY COOLING WATER SOURCE STEEL IN ATMOSPHERE/

FLOOD BARRIER WEATHER NON-SAFETY SUPPORT SAFETY RELATED SUPPORT (STRUCTURAL STEEL, SHEET SHELTER/PROTECTION PILES, VENTILATION ASSEMBLIES, [STORED STEEL HATCH COVERS AND STEEL PLATES FOR EXTERNAL FLOOD PROTECTION])

Page 17 of 149 ENCLOSURE 1 LRA Section 3.0 -AGING MANAGEMENT REVIEW RESULTS 3.0.7 Review of NUREG-0933 BACKGROUND (Commitment No. 2)In accordance with the guidance of Appendix A.3.2.1.2 of NUREG-1800, Appendix B of the latest issued supplement to NUREG-0933 will be reviewed for new GSIs designated as USI-, HIGH-, or MEDIUM- priority.

Any identified that involve TLAAs or aging effects for structures and components subject to an aging management review will be included in the annual update of the LRA.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough) 3.0.7 Review of NUREG-0933 NUREG-0933 (Reference 9), contains listings of industry experience in the form of NRC Unreviewed Safety Issues (USls) and Generic Safety Issues (GSIs) along with their current status. NUREG-0933 (through Supplement

[28 29]) was reviewed in accordance with the guidance provided in Appendix A.3 of NUREG-1 800 (Reference

3) to identify those USIs and GSIs related to both aging effects of structures and components and TLAAs within the scope of License Renewal....

In accordance with the guidance of Appendix A.3.2.1.2 of NUREG-1 800, Appendix B of the latest issued supplement to NUREG-0933

[will-be was] reviewed for new GSIs designated as USI-, HIGH-, or MEDIUM- priority.

[AMy Supplement 29 of NUREG-0933 was reviewed as part of the first annual update of the LRA. No issues were]identified that involve TLAAs or aging effects for structures and components subject to an aging management review [will be included in the annual update of the LR'\].Page 18 of 149 ENCLOSURE 1 LRA Section 3.1 -Aging Management of Reactor Coolant System 3.1.1 Introduction BACKGROUND (3.1-18)During discussions with the NRC staff, NMC determined that LRA Table 3.1.1, Item Number 3.1.1-23, should be revised to read, "CASS components in the ESF systems subject to an environment that supports loss of fracture toughness due to thermal aging embrittlement were assigned the ASME Section XI In-Service Inspection, Subsections IWB, IWC, and IWD Program. Those CASS components that are subject to this aging effect/mechanism are valves." DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table 3.1.1 Summary of Aging Management Evaluations In Chapter IV of NUREG-1801 for Reactor Coolant System Aging Further Item Aging Management Evaluation Number Component EffectlMechanism Programs Recommended Discussion 3.1.1-23 CASS pump Loss of fracture In-service No This line item is not used at MNGP. The casing and valve toughness due to inspection rcaetor coolant systems comprnents of CASS body thermal aging material arc portions of the Jct Pump, Fucl embrittlement Support, and CRD assemblies.

Sce items 3.1.1 31 and 3.1.1 33 for these components.

4n addition, CASS valve bodies in the ESF systems are discussed in item 3.2.1 11 of Table -.2.1. CASS components in the ESF systems subject to an environment that supports loss of fracture toughness due to thermal aging embrittlement were assigned the ASME Section XI In-Service Inspection, Subsections IWB, IWC and IWD Program.Those CASS components that are subject to this aging effect/mechanism are valves.]Page 19 of 149 ENCLOSURE 1 LRA Section 3.0 -AGING MANAGEMENT REVIEW RESULTS BACKGROUND (B2.1 .2-15)During discussions with the NRC staff, NMC determined that AMP B2.1.4, "Bolting Integrity," (NUREG-1801, XI.M18) should be revised. Based on the revision to the AMP, NMC also determined that the Notes for the LRA 3.X.2 Tables, which reference the Bolting Integrity AMP, should also be changed from-Note A to Note B to reflect the change in the status of the AMP from "AMP is consistent with NUREG-1 801 AMP" to "AMP takes some exceptions to NUREG-1 801 AMP".DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

--l .. a, I DAA e_6..__~_

AAP ^_l \* ._~ _^.- __. As A__. __-A! ._._*I aDle .1. .Z- I eavcor Codola oyStem -reactoru feu ven oystem -oummary vo A ing Managemeni -Valuaton Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Primary Loss of Material -Bolting V.E.2-a 3.2.1-18 [A B], 101, Bolting Boundary Steel Containment Galvanic Corrosion Integrity 106, Air(Ext) 112,126 Loss of Material -Bolting V.E.2-a 3.2.1-18 [A B], 101, General Corrosion Integrity 106, 126 Table 3.1.24 Reactor Coolant System -Reactor Recirculation System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table 1 Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners!

Pressure Carbon Plant IndoorAir Loss of Material -Bolting V.E.2-a 3.2.1-18 [A B], 101, Bolting Boundary Steel (Ext) Galvanic Corrosion Integrity 106, 112,126 Loss of Material -Bolting V.E.2-a 3.2.1-18 [A B], 101, General Corrosion Integrity 106, 126 Primary Loss of Material -Bolting V.E.2-a 3.2.1-18 [A B], 101, Containment Air Galvanic Corrosion Integrity 106, (Ext) 112,126 Loss of Material -Bolting V.E.2-a 3.2.1-18 [A B], 101, General Corrosion Integrity 106, 126 Page 20 of 149 ENCLOSURE 1 Table 3.1.2-5 Reactor Coolant System -Reactor Vessel Instrumentation

-Summary of Aaing Manaaement Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table 1 Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Plant Indoor Air Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 101, Bolting Boundary Steel (Ext) Galvanic Corrosion 106, 112,126 Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 101, General Corrosion 106,126 Primary Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 101, Containment Air Galvanic Corrosion 106, (Ext) 112,126 Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 101, General Corrosion 106, 126 Table 3.2.2-1 Eng ineered Safety Features -Automatic Pressure Relief System -Summry of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table 1 Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Plant Indoor Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, Bolting Boundary Steel Air (Ext) Galvanic Corrosion 206, 212 Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, General Corrosion 206 Primary Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, Containment Galvanic Corrosion 206, 212 Air ( Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, General Corrosion 206 Table 3.2.2-2 Engin ered Safety Features -Combustible Gas Control System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table 1 Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Plant Indoor Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, Bolting Boundary Steel Air (Ext) Galvanic Corrosion 206, 212 Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, General Corrosion 206 Table 3.2.2.3 Engineered Safety Features -Core Spray System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Plant Indoor Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, Bolting Boundary Steel Air (Ext) Galvanic Corrosion 206, 212 Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, General Corrosion 206 Primary Loss of Material-Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, Containment Galvanic Corrosion 206,212l l l ~~Air (Ext) l lIlI A lElt) Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201.General Corrosion I 206 l Page 21 of 149 ENCLOSURE 1 Table 3.2.2-4 Engineered Safety Features -High Pressure Coolant Injection System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Plant Indoor Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, Bolting Boundary Steel Air (Ext) Galvanic Corrosion 206, 212 Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, General Corrosion 206 Primary Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, Containment Galvanic Corrosion 206, 212 Air (Ext)Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, General Corrosion 206 Table 3.2.2-5 Engineered Safety Features -Primary Containment Mechanical System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Plant Indoor Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, Bolting Boundary Steel Air (Ext) Galvanic Corrosion 206, 212 Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, General Corrosion

.206 Primary Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, Containment Galvanic Corrosion 206, 212 Air (Ext)II Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, General Corrosion 206 Table 3.2.2-6 Engineered Safety Features -Reactor Core Isolation Cooling System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Plant Indoor Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, Bolting Boundary Steel Air (Ext) Galvanic Corrosion 206, 212 Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, General Corrosion 206 Primary Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, Containment Galvanic Corrosion 206, 212 Air (Ext) Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, General Corrosion 206 Page 22 of 149 ENCLOSURE I Table 3.2.2-7 Engineered Safety Features -Residual Heat Removal System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table 1 Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Plant Indoor Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, Bolting Boundary Steel Air (Ext) Galvanic Corrosion 206, 212 Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, General Corrosion 206 Primary Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, Containment Galvanic Corrosion 206, 212 Air (Ext) Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, General Corrosion 206 Table 3.2.2-8 Engineered Safety Features -Secondary Containment System -Summa of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table 1 Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Plant Indoor Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, Bolting Boundary Steel Air (Ext) Galvanic Corrosion 206, 212 Loss of Material -Bolting Integrity V.E.2-a 3.2.1-18 [A B], 201, General Corrosion 206 Table 3.3.2-1 Auxiliary Systems -Alternate Nitrogen System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Plant Indoor Loss of Material -Bolting Integrity VI1.1.2-a 3.3.1-24 [A B], 301, Bolting Boundary Steel Air (Ext) Galvanic Corrosion 306, 312 Loss of Material -Bolting Integrity VI1.1.2-a 3.3.1-24 [A B], 301, General Corrosion 306 Primary Loss of Material -Bolting Integrity VII.1.2-a 3.3.1-24 [A B], 301, Containment Galvanik Corrosion 306, 312 Air (Ext) Loss of Material -Bolting Integrity VII.1.2-a 3.3.1-24 [A B], 301, General Corrosion 306 Table 3.3.2-2 Auxiliary Systems- Chemistry Sampling System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table 1 Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Plant Indoor Loss of Material -Bolting Integrity VI1.1.2-a 3.3.1-24 [A B], 301, Bolting Boundary Steel Air (Ext) Galvanic Corrosion 306, 312 Loss of Material -Bolting Integrity VI1.1.2-a 3.3.1-24 [A B], 301, General Corrosion 306 Page 23 of 149 ENCLOSURE 1 Table 3.3.2-3 Auxiliary Systems- Circulating Water System -Summary of Aging Mana ement Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table i Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Plant Indoor Loss of Material -Bolting Integrity VII.1.2-a 3.3.1-24 [A B], 301, Bolting Boundary Steel Air (Ext) Galvanic Corrosion 306, 312 Loss of Material -Bolting Integrity V11.1.2-a 3.3.1-24 [A B], 301, General Corrosion 306 Table 3.3.24 Auxiliary Systems- Control Rod Drive System -Summary of Aging Mana ement Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners Pressure Carbon Plant Indoor Loss of Material -Bolting Integrity VII.1.2-a 3.3.1-24 [A B], 301, Bolting Boundary Steel Air (Ext) Galvanic Corrosion 306, 312 Loss of Material -Bolting Integrity V11.1.2-a 3.3.1-24 [A B], 301, General Corrosion 306 Primary Loss of Material -Bolting Integrity V11.1.2-a 3.3.1-24 [A B], 301, Containment Galvanic Corrosion 306, 312 Air (Ext) Loss of Material -Bolting Integrity V11.1.2-a 3.3.1-24 [A B], 301, General Corrosion 306 Table 3.3.2-5 Auxiliary Systems- Demineralized Water System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners!

Pressure Carbon Plant Indoor Loss of Material -Bolting Integrity VII.1.2-a 3.3.1-24 [A B], 301, Bolting Boundary Steel Air (Ext) Galvanic Corrosion 306, 312 Loss of Material -Bolting Integrity V11.1.2-a 3.3.1-24 [A B], 301, General Corrosion 306 Table 3.3.2-6 Auxiliry Systems- Emergency Diesel Generators System -Summary of Aging Mana ement Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners!

Pressure Carbon Exposed to Loss of Material -Bolting Integrity V11.1.2-a 3.3.1-24 [A B], 301, Bolting Boundary Ste-el Weather Galvanic Corrosion 306, 312 (Ext)Loss of Material -Bolting Integrity V11.1.2-a 3.3.1-24 [A B], 301, General Corrosion 306 Plant Indoor Loss of Material -Bolting Integrity V11.1.2-a 3.3.1-24 [A BI, 301, Air (Ext) Galvanic Corrosion 306, 312 Loss of Material -Bolting Integrity V11.1.2-a 3.3.1-24 [A B],301,lGeneral Corrosion I I 1 306 Page 24 of 149 ENCLOSURE 1 Table 3.3.2-8 Auxiliary Systems- Emergency Service Water System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table 1 Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Plant Indoor Loss of Material -Bolting Integrity VII.1.2-a 3.3.1-24 [A B], 301, Bolting Boundary Steel Air (Ext) Galvanic Corrosion 306, 312 Loss of Material -Bolting Integrity VII.1.2-a 3.3.1-24 [A B], 301, General Corrosion 306 Table 3.3.2-9 Auxiliary Systems- Fire System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Exposed to Loss of Material -Bolting Integrity VII.1.2-a 3.3.1-24 [A B], 301, Bolting Boundary Steel Weather Galvanic Corrosion 306, 312 Loss of Material -Bolting Integrity VII.1.2-a 3.3.1-24 [A B], 301, General Corrosion 306 Plant Indoor Loss of Material -Bolting Integrity VII.1.2-a 3.3.1-24 [A B], 301, Air (Ext) Galvanic Corrosion 306, 312 Loss of Material -Bolting Integrity VII.1.2-a 3.3.1-24 [A B], 301, General Corrosion 306 Table 3.3.2-10 Auxiliary Systems -Fuel Pool Cooling and Cleanup -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Plant Indoor Loss of Material -Bolting Integrity VII.I.2-a 3.3.1-24 [A B], 301, Bolting Boundary Steel Air (Ext) Galvanic Corrosion 306, 312 Loss of Material -Bolting Integrity VII.1.2-a 3.3.1-24 [A B], 301, General Corrosion 306 Table 3.3.2-11 Auxiliry Systems -Heating and Ventilation

-Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Plant Indoor Loss of Material -Bolting Integrity VII.I.2-a 3.3.1-24 [A B], 301, Bolting Boundary Steel Air (Ext) Galvanic Corrosion 306, 312 Loss of Material -Bolting Integrity VII.1.2-a 3.3.1-24 [A B], 301, General Corrosion I 1 306 Table 3.3.2-12 Auxiliary Systems- Instrument and Service Air System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table 1 Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Plant Indoor Loss of Material -Bolting Integrity VII.1.2-a 3.3.1-24 [A B], 301, Bolting Boundary Steel Air (Ext) Galvanic Corrosion 306, 312 Loss of Material -Bolting Integrity VII.1.2-a

] 3.3.1-24 l [A B],301,lGeneral Corrosion l 306 Page 25 of 149 ENCLOSURE 1 Table 3.3.2-13 Auxil ary Syste s- Radwaste Solid and Liquid Syste m -Summary of Agi ng Managem nt Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Exposed to Loss of Material -Bolting Integrity VII.1.2-a 3.3.1-24 [A B], 301, Bolting Boundary Steel Weather Galvanic Corrosion 306, 312 (Ext)Loss of Material -Bolting Integrity VII.I.2-a 3.3.1-24 [A B], 301, General Corrosion 306 Plant Indoor Loss of Material -Bolting Integrity VI1.1.2-a 3.3.1-24 [A BI, 301, Air (Ext) Galvanic Corrosion 306, 312 Loss of Material -Bolting Integrity VI1.1.2-a 3.3.1-24 [A B], 301, General Corrosion 306 Table 3.3.2-14 Auxiliary Systems -Reactor Building Closed Cooling Water System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Exposed to Loss of Material -Bolting Integrity V11.1.2-a 3.3.1-24 [A B], 301, Bolting Boundary Steel Weather Galvanic Corrosion 306, 312 (Ext)Loss of Material -Bolting Integrity Vl1.1.2-a 3.3.1-24 [A B], 301, General Corrosion 306 Plant Indoor Loss of Material -Bolting Integrity V11.1.2-a 3.3.1-24 [A B], 301, Air (Ext) Galvanic Corrosion 306, 312 Loss of Material -Bolting Integrity V11.1.2-a 3.3.1-24 [A B1, 301, General Corrosion 306 Table 3.3.2-15 Auxili ry System -Reactor Wa er Cleanup System Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Exposed to Loss of Material -Bolting Integrity VI1.1.2-a 3.3.1-24 [A B], 301, Bolting Boundary Steel Weather Galvanic Corrosion 306, 312 (Ext)Loss of Material -Bolting Integrity V11.1.2-a 3.3.1-24 [A B], 301, General Corrosion 306 Plant Indoor Loss of Material -Bolting Integrity V11.1.2-a 3.3.1-24 [A B], 301, Air (Ext) Galvanic Corrosion 306, 312 Loss of Material -Bolting Integrity VI1.1.2-a 3.3.1-24 [A B], 301, General Corrosion 306 Table 3.3.2-16 Auxiliary Systems -Service and Seal Water System -Summa of A in Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table 1 Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Plant Indoor Loss of Material -Bolting Integrity Vl1.1.2-a 3.3.1-24 [A B], 301, Bolting Boundary Steel Air (Ext) Galvanic Corrosion 306, 312 Loss of Material -Bolting Integrity Vl1.1.2-a 3.3.1-24 [A B], 301, General Corrosion I 1 306 Page 26 of 149 ENCLOSURE I Table 3.3.2-17 Auxiliary Systems -Standby Liquid Control System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Exposed to Loss of Material -Bolting Integrity VI1.1.2-a 3.3.1-24 [A B], 301, Bolting Boundary Steel Weather Galvanic Corrosion 306, 312 (Ext)Loss of Material -Bolting Integrity V1.1.2-a 3.3.1-24 [A B], 301, General Corrosion 306 Plant Indoor Loss of Material -Bolting Integrity VI1.1.2-a 3.3.1-24 [A B], 301, Air (Ext) Galvanic Corrosion 306, 312 Loss of Material -Bolting Integrity V1.1.2-a 3.3.1-24 [A B], 301, General Corrosion 306 Table 3.3.2-18 Auxiliary Systems -Wells and Domestic Water System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Plant Indoor Loss of Material -Bolting Integrity V11.1.2-a 3.3.1-24 [A B], 301, Bolting Boundary Steel Air (Ext) Galvanic Corrosion 306, 312 Loss of Material -Bolting Integrity VI1.1.2-a 3.3.1-24 [A B], 301, General Corrosion 306 Table 3.4.2-1 Steam and Power Conversion System -Condensate Storage System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Plant Indoor Loss of Material -Bolting Integrity VIII.H.2-a 3.4.1-08 [A B], 401, Bolting Boundary Steel Air (Ext) Galvanic Corrosion 406, 412 Loss of Material -Bolting Integrity V1II.H.2-a 3.4.1-08 [A B], 401, General Corrosion 406 Table 3.4.2-2 Steam and Power Conversion System -Condensate and Feedwater System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Plant Indoor Loss of Material -Bolting Integrity V1II.H.2-a 3.4.1-08 [A B], 401, Bolting Boundary Steel Air (Ext) Galvanic Corrosion 406, 412 Loss of Material -Bolting Integrity V1II.H.2-a 3.4.1-08 [A B], 401, General Corrosion 406 Primary Loss of Material -Bolting Integrity VIII.H.2-a 3.4.1-08 [A B], 401, Containment Galvanic Corrosion 406.412 Air (t) Loss of Material -Bolting Integrity VIII.H.2-a 3.4.1-08 [A B], 401, General Corrosion 406 Page 27 of 149 ENCLOSURE I Table 3.4.2-3 Steam and Power Conversion S stem -Main Condenser System -Sum ary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table 1 Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Plant Indoor Loss of Material -Bolting Integrity VIII.H.2-a 3.4.1-08 [A B], 401, Bolting Boundary Steel Air (Ext) Galvanic Corrosion 406, 412 Loss of Material -Bolting Integrity VIII.H.2-a 3.4.1-08 [A B], 401, General Corrosion 406 Table 3.4.2-4 Steam and Power Conversion S fstem -Main Steam System -Summary of Aging Man gement Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Plant Indoor Loss of Material -Bolting Integrity VIII.H.2-a 3.4.1-08 [A B], 401, Bolting Boundary Steel Air (Ext) Galvanic Corrosion 406, 412 Loss of Material -Bolting Integrity VIII.H.2-a 3.4.1-08 [A B], 401, General Corrosion 406 Primary Loss of Material -Bolting Integrity VIII.H.2-a 3.4.1-08 [A B], 401, Containment Galvanic Corrosion 406, 412 Air (Ext) Loss of Material -Bolting Integrity VIII.H.2-a 3.4.1-08 [A B], 401, General Corrosion 406 Table 3.4.2-5 Steam and Power Conversion System -Turbine Generator System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table 1 Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fasteners/

Pressure Carbon Plant Indoor Loss of Material -Bolting Integrity VIII.H.2-a 3.4.1-08 [A B], 401, Bolting Boundary Steel Air (Ext) Galvanic Corrosion 406, 412 Loss of Material -Bolting Integrity VIII.H.2-a 3.4.1-08 [A B], 401, General Corrosion 406 Page 28 of 149 ENCLOSURE I LRA Section 3.1 -Aging Management of Reactor Coolant System 3.1.2 Results BACKGROUND (3.1.2-1)As described in the NMC letter dated October 28, 2005, these components were conservatively included in LRA Table 3.1.2-2 for the Stress Corrosion Cracking (SCC) and Intergranular Stress Corrosion Cracking (IGSCC) aging mechanisms due to industry experience with SCC and IGSCC in the cladding of these components.

NMC agrees with the NRC staff that this is not an aging mechanism for the low alloy base material.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table 3.1.2-2 Reactor Coolant System -Reactor Pressure Vessel -Summary of Aging Mana ement Evaluation Component Environment Aging Effect Aging Management NUREG -Type Function Requiring Programs 1801 Item ent Volume 2 Line Itern Top Head Pressure A533-65 288 0 C (550 0 F) [CGfa-h(itiation ASME Seetmzn Xi Enclosure

-Boundary GrB Cl 1, Steam endsGFewth in Gervioe Inspeeton,* Top Head 308/309 Stress Gorrfosien Subsectiens IWB, Dollar Plate Clad Cradeingg, IWG a indIWD.tefgralaf Plant GhernistFy H]&resGO~ffe~t FPegfam Cumulative TLAA evaluated in IV.A1.1-b 3.1.1-01 Fatigue accordance with 10 Damage/Fatigue CFR 54.21 (c)Top Head Pressure A508 Cl 2, 288 0 C (550 0 F) [Gfaek-l.ifiaAGeAt ASM Section Xli H Enclosure

-Boundary 308/309 Steam and Growth, In Scrvicc Inspegtion,* Top Head Clad Stress olrrosion Subsections-IWB, Flange rad4WD e Plant Chemistry H]Stress-Gerreslbn Prora Gfododem Cumulative TLAA evaluated in IV.A1.1-b 3.1.1-01 Fatigue accordance with 10 Damage/Fatigue CFR 54.21 (c)Top Head Pressure A533-65 288 0 C (5501F) [Greek-fitiaien ASME Scetien Xl H Enclosure

-Boundary GrB Cl 1, Steam and Growth, in Service inspeetion,-Top Head 308/309 Stress Corrosion Subseetions

!"G, Torus Clad Grackinn IWWG-c-o WD __A)_ter_ _r__fof Plant Ghemistry H]Stress Colrrcsien P~~Cumulative TLAA evaluated In IV.A1.1-b 3.1.1.01 Fatigue accordance with 10 Damage/Fatigue CFR 54.21 (c)Page 29 of 149 ENCLOSURE 1 LRA Section 3.1 -Aging Management of Reactor Coolant System 3.1.2 Results BACKGROUND (B2.1 .2-15)During discussions with the NRC staff, NMC determined that AMP B2.1.8, "BWR Feedwater Nozzle," (NUREG-1 801, X1.M5) should be revised to include an exception to the GALL. Based on the revision to the AMP, NMC also determined that the Notes for the LRA 3.X.2 Tables, which reference the BWR Feedwater Nozzle AMP, should also be changed from Note A to Note B to reflect the change in the status of the AMP from "AMP is consistent with NUREG-1 801 AMP" to "AMP takes some exceptions to NUREG-1 801 AMP".DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table 3.1.2-2 Reactor Coolant System -Reactor Pressure Vessel -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Nozzles -Pressure SA508 Cl 2, Up to 288 0 C Crack Initiation BWR Feedwater IVA1 .3-b 3.1.1-27 [A B], Feedwater Boundary 308/309 (550 0 F) and Nozzle 129 Clad Reactor Growth/Cyclic Coolant Water Loading Page 30 of 149 ENCLOSURE I LRA Section 3.1 -Aging Management of Reactor Coolant System 3.1.2 Results BACKGROUND (B2.1 .2-15)During discussions with the NRC staff, NMC determined that AMP B2.1.28, "Reactor Head Closure Studs," (NUREG-1 801, X1.M3) should be revised to include an exception to the GALL. Based on the revision to the AMP, NMC also determined that the Notes for the LRA 3.X.2 Tables, which reference the Reactor Head Closure Studs AMP, should also be changed from Note A to Note B to reflect the change in the status of the AMP from "AMP is consistent with NUREG-1 801 AMP" to "AMP takes some exceptions to NUREG-1 801 AMP".DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table 3.1.2-2 Reactor Coolant ystem -Reactor Pressure Vessel -Summary of Aging Mana gement Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Top Head Pressure SA540 Gr Air, Leaking Crack Initiation and Reactor Head IV.A1.1-c 3.1.1-22 [A B]Enclosure

-Boundary B23/24 Reactor Coolant Growth, Stress Closure Studs-Closure Water and/or Corrosion Studs Steam at 288 0 C Cracking,& Nuts (550 0 F) Intergranular Stress Corrosion Cracking Page 31 of 149 ENCLOSURE 1 LRA Section 3.1 -Aging Management of Reactor Coolant System 2.3.3 Results BACKGROUND (2.3.1-2 and Rill-B2.1.12-3)

During discussions with the NRC staff, NMC determined that LRA Table 3.1.2-3, Reactor Coolant System -Reactor Pressure Vessel Internals

-Summary of Aging Management Evaluation, should be revised to include the intended function of "Spray Pattern" for the Core Spray Lines and Spargers.In addition, NMC has determined that although BWRVIP-139 guidance was not approved by the NRC at the time of preparation of the MNGP LRA, it was expected that MNGP would follow the BWRVIP-1 39 guidance for the steam dryer inspection and flaw evaluations.

DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table 3.1.2-3 Reactor Coolant System -Reactor Pressure Vessel Internals

-Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG- Table 1 Notes Type Function Requiring Management 1801 Item Management Programs Volume 2 Line Item Core Spray Pressure Stainless 288 0 C (5501F) Cumulative Fatigue TLAA evaluated IV.B1.3-a 3.1.1-31 D Lines and Boundary Steel High Purity Damage/Fatigue in accordance Spargers Water with 10 CFR Piping 54.21 (c)Supports Clamp Modification

[Core Spray Stainless 2881C (550 0 F) Crack initiation and BWR Vessel IV.B1.3-a 3.1.1-31 B Spray Pattern Steel High Purity Growth/ Stress Internals Lines and Water Corrosion Cracking, Spargers Intergranular Stress Corrosion Cracking, Plant Chemistry IV.BI1.3-a 3.1 .1.31 B]Spray Irradiation-Assisted Program Nozzles Stress Corrosion Cracking Steam Structural Stainless 288 0 C (550 0 F) Crack initiation and BWR Vessel J. 136 Dryer Support Steel High Purity Growth/Cyclic Intemals Water Loading Crack initiation and BWR Vessel IV.B1.1-a 3.1.1-31 D, 136 Growth/ Stress Intemals Corrosion Cracking, Intergranular Stress Corrosion Cracking 136 The inspection of the steam dryer is to be accomplished using the guidelines in the approved BWRVIP[-139, Steam Dryer Inspection and Flaw Evaluation Guidelines, tepieal repeor(s)]

for steam dryer inspection.

In the event a new steam dryer is installed, NMC will reevaluate the inspection requirements.

Page 32 of 149 ENCLOSURE 1 LRA Section 3.1 -Aging Management of Reactor Coolant System 3.1.2 Results BACKGROUND (B2.1 .2-15)During discussions with the NRC staff, NMC determined that AMP B2.1.33, "Thermal Aging& Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS)," (NUREG-1 801, XL.M13) should be revised to include an exception to the GALL. Based on the revision to the AMP, NMC also determined that the Notes for the LRA 3.X.2 Tables, which reference the Thermal Aging & Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS)AMP, should also be changed from Note A to Note B to reflect the change in the status of the AMP from "AMP is consistent with NUREG-1.801 AMP" to "AMP takes some exceptions to NUREG-1801 AMP".DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table 3.1.2-3 Reactor Coolant System -Reactor Pressure Vessel Internals

-Summary of A ing Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table 1 Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Jet Pump Pressure Cast 288 0 C (550 0 F) Loss of Fracture Thermal Aging IV.B1.4-c 3.1 .1-33 [A B]Assemblies Boundary Austenitic High Purity Toughness/

& Neutron Stainless Water Thermal Aging and Irradiation C Castings:

Steel Neutron Irradiation Embrittlement Elbow, Embrittlement of Cast Collar. Austenitic Flare, Stainless Flange, Steel (CASS)Transition Piece Orificed Structural Cast 288 0 C (550 0 F) Loss of Fracture Thermal Aging IV.B1.5-a 3.1.1-33 [A B]Fuel Support Austenitic High Purity Toughness/

& Neutron Support Stainless Water Thermal Aging and Irradiation Steel Neutron Irradiation Embrittlement Embrittlement of Cast Austenitic Stainless Steel (CASS).Page 33 of 149 ENCLOSURE 1 LRA Section 3.1 -Aging Management of Reactor Coolant System 3.1 -Aging Management of Reactor Coolant System BACKGROUND (3.1-10)NUREG-1 801, Item V.E.1-b requires a "plant specific aging management program" to manage loss of material on the external surfaces of carbon steel components.

The System Condition Monitoring Program is a plant specific aging management program and the methodology employed by MNGP required assigning a Note A (Consistent with NUREG-1801 item for component, material, environment and aging effect. AMP is consistent with NUREG-1 801 AMP). However, since NUREG-1 801 states that further evaluation of these line items is required, then Note E (Consistent with NUREG-1 801 for material, environment and aging effect, but a different aging management program is credited.)

should be used in order to address the evaluation required for this line item.Therefore, in each instance where the LRA 3.X.2 Tables credit the System Condition Monitoring Program for aging management and the NUREG-1801 line item referenced a plant specific aging management program with further evaluation required, Note E should be assigned.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table 3.1.2-1 Reactor Coolant System -Reactor Head Vent System -Summary of Agin Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table 1 Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Piping and Pressure Carbon Primary Loss of Material -System Condition V.E.1-b 3.2.1-10 [A- E,] 112, Fittings Boundary Steel Containment Galvanic Corrosion Monitoring Program 126 Air (Ext) Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; Ej 126 General Corrosion Monitoring Program Valve Pressure Carbon Primary Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,] 112, Bodies Boundary Steel Containment Galvanic Corrosion Monitoring Program 126 Air (Ext) Loss of Material -System Condition V.E.1-b 3.2.1-10 [A E,] 126_ General Corrosion Monitoring Program I Page 34 of 149 ENCLOSURE 1 Table 3.1.2-4 Reactor Coolant System -Reactor Recirculation System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Filters / Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A-E,] 112, Strainers Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program 126 Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,] 126 General Corrosion Monitoring Program Heat Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; Ej 112, Exchangers Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program 126 Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej 126 General Corrosion Monitoring Program Manifolds Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A, E,] 112, Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program 126 Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,] 126 General Corrosion Monitoring Program Piping and Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej 112, Fittings Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program 126 Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej 126 General Corrosion Monitoring Program Primary Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej 112, Containment Galvanic Corrosion Monitoring Program 126 Air (Ext) Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej 126 General Corrosion Monitoring Program Pump Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,] 112, Casings Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program 126 Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,] 126 General Corrosion Monitoring Program Restricting Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,] 112, Orifices Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program 126 Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej 126 General Corrosion Monitoring Program Tanks Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,] 112, Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program 126 Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej 126 General Corrosion Monitoring Program Thermowells Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,] 112, Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program 126 Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,] 126 General Corrosion Monitoring Program Primary Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej 112, Containment Galvanic Corrosion Monitoring Program 126 Air (Ext) Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; Ej 126 General Corrosion Monitoring Program Page 35 of 149 ENCLOSURE 1 Table 3.1.2-4 Reactor Coolant System -Reactor Recirculation System -Summary of Aging Management Evaluation (Cont'd)Component Intended Material Environment Aging Effect Aging NUREG Table 1 Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Valve Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,] 112, Bodies Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program 126 Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej 126 General Corrosion Monitoring Program Primary Loss of Material -System Condition V.E.1-b 3.2.1-10 [A;E,] 112, Containment Galvanic Corrosion Monitoring Program 126 Air (Ext) Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,] 126 General Corrosion Monitoring Program Table 3.1.2-5 Reactor Coolant System -Reactor Vessel Instrumentation

-Summary of Aging Manag ement Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table 1 Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Manifolds Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; Ej 112, Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program 126 Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; Ej 126 General Corrosion Monitoring Program Piping and Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,] 112, Fittings Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program 126 Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,] 126 Genera! Corrosion Monitoring Program Primary Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,] 112, Containment Galvanic Corrosion Monitoring Program 126 Air (Ext) Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; Ej 126 General Corrosion Monitoring Program Thermowells Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,] 112, Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program 126 Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,] 126 General Corrosion Monitoring Program Valve Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; Ej 112, Bodies Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program 126 Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,] 126 General Corrosion Monitoring Program Primary Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,] 112, Containment Galvanic Corrosion Monitoring Program 126 Air ( Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,] 126 General Corrosion Monitoring Program Page 36 of 149 ENCLOSURE 1 Table 3.2.2-1 Engineered Safety Features -Automatic Pressure Relief System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Manifolds Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A, E,] 212 Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,]General Corrosion Monitoring Program Piping and Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej 212 Fittings Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej General Corrosion Monitoring Program Primary Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,] 212 Containment Galvanic Corrosion Monitoring Program Air (Ext) Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,]General Corrosion Monitoring Program Thermowells Pressure Carbon Primary Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,] 212 Boundary Steel Containment Galvanic Corrosion Monitoring Program Air (Ext) Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej General Corrosion Monitoring Program Valve Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,] 212 Bodies Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E, General Corrosion Monitoring Program Primary Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej 212 Containment Galvanic Corrosion Monitoring Program Air (Ext) Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,]General Corrosion Monitoring Program Table 3.2.2-2 Engineerd Safety Features -Combustible Gas Control System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging 'NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Piping and Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,] 212, Fittings Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [A E,]General Corrosion Monitoring Program Valve Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,] 212 Bodies Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,]General Corrosion Monitoring Program Heat Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej 212 Exchangers Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,]General Corrosion Monitoring Program Manifolds Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,] 212 Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,]General Corrosion Monitoring Program Page 37 of 149 ENCLOSURE 1 Table 3.2.2-3 Engineered Safety Features -Core Spray System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Piping and Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E, 212, Fittings Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [A, EJ General Corrosion Monitoring Program Primary Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; EJ 212, Containment Galvanic Corrosion Monitoring Program Air (Ext) Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,]General Corrosion Monitoring Program Pump Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,] 212, Casings Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program_Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; EJ General Corrosion Monitoring Program Thermowells Pressure Carbon Primary Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,] 212 Boundary Steel Containment Galvanic Corrosion Monitoring Program Air (Ext) Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; EJ General Corrosion Monitoring Program Valve Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT EJ 212 Bodies Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,]General Corrosion Monitoring Program Primary Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,] 212 Containment Galvanic Corrosion Monitoring Program Air (Ext) Loss of Material -System Conditon V.E.1-b 3.2.1-10 [A; E,]l General Corrosion Monitoring Program Table 3.2.2-4 Engineered Safety Features -High Pressure Coolant Injection System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Fan/Blower/

Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,] 212, Housings Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [A, E,]General Corrosion Monitoring Program Filters / Filtration Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,] 212 Housings Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; EJ General Corrosion Monitoring Program Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,] 212, Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; EJ General Corrosion Monitoring Program Heat Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; EJ 212 Exchangers Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,]General Corrosion Monitoring Program Page 38 of 149 ENCLOSURE I Table 3.2.24 Engineered Safety Features -High Pressure Coolant Injection System -Summary of Aging Management (Cont'd) Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Manifolds Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E, 212 Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,]General Corrosion Monitoring Program Piping and Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A, EJ 212, Fittings Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT EJ General Corrosion Monitoring Program Primary Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT EJ 212, Containment Galvanic Corrosion Monitoring Program Air (Ext) Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT EJ General Corrosion Monitoring Program Pump Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,] 212, Casings Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT EJ General Corrosion Monitoring Program Restricting Flow Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,] 212, Orifices Restriction Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT EJ1 General Corrosion Monitoring Program Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,] 212, Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program_Loss of Material -System Condition V.E.1-b 3.2.1-10 [A- E, General Corrosion Monitoring Program Steam Traps Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,] 212, Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E, General Corrosion Monitoring Program Tanks Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E.] 212, Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT EJ General Corrosion Monitoring Program Thernowells Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT EJ 212 Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT EJ General Corrosion Monitoring Program Turbines Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT EJ 212 Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E.]General Corrosion Monitoring Program Page 39 of 149 ENCLOSURE I Table 3.2.2-4 Engineered Safety Features -High Pressure Coolant Injection System -Summary of Aging Management (Cont'd) Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table 1 Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Valve Pressure Carbon Plant Indoor Loss of Material System Condition V.E.1-b 3.2.1-10 [A; E,] 212 Bodies Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [Av EJ General Corrosion Monitoring Program Primary Loss of Materiar -System Condition V.E.1-b 3.2.1-10 [A; E,] 212 Containment Galvanic Corrosion Monitoring Program Air (Ext) Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,]General Corrosion Monitoring Program Table 3.2.2-5 Engineered Safety Features -Primary Containment Mechanical System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Accumulators Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,] 212 Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT EJ General Corrosion Monitoring Program Filters / Filtration Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,] 212 Strainers Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,]General Corrosion Monitoring Program Flow Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; EJ 212 Element Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,]General Corrosion Monitoring Program Manifolds Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,] 212 Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.lb 3.2.1-10 [AT E,]General Corrosion Monitoring Program Piping and Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1 -b 3.2.1-10 [A; E,] 212 Fittings Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,]General Corrosion Monitoring Program Primary Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; EJ 212 Containment Galvanic Corrosion Monitoring Program Air (Ext) Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; EJ General Corrosion Monitoring Program Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A, E,] 212 Boundary!

Steel Air (Ext) Galvanic Corrosion Monitoring Program Fission__

_ _ _ _Product Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT EJ Retention General Corrosion Monitoring Program Thermowells Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,] 212 Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,]General Corrosion Monitoring Program Page 40 of 149 ENCLOSURE I Table 3.2.2-5 Engineered Safety Features -Primary Containment Mechanical System -Summary of Aging Management (Cont'd) Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Valve Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A-; E] 212 Bodies Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [A 7 E]General Corrosion Monitoring Program Primary Loss of Material -System Condition V.E.1-b 3.2.1-10 [A 7 E,] 212 Containment Galvanic Corrosion Monitoring Program Air ( Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,]General Corrosion Monitoring Program I Table 3.2.2-6 Engineered Safety Features -Reactor Core Isolation Cooling System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table 1 Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Filters / Filtration Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A Ej] 212 Strainers Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E.]General Corrosion Monitoring Program Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,] 212 Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; Ej General Corrosion Monitoring Program Heat Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; Ej] 212 Exchangers Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej]General Corrosion Monitoring Program Manifolds Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej 212 Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E.]General Corrosion Monitoring Program Piping and Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,] 212 Fittings Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E]General Corrosion Monitoring Program Primary Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E] 212 Containment Galvanic Corrosion Monitoring Program Air (Ext) Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E]General Corrosion Monitoring Program Pump Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E] 212, Casings Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [A-T E,]General Corrosion Monitoring Program Steam Traps Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej 212, Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E]General Corrosion Monitoring Program Page 41 of 149 ENCLOSURE I Table 3.2.2-6 Engineered Safety Features -Reactor Core Isolation Cooling System -Summary of Aging Management (Cont'd) Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table 1 Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Tanks Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; EJ 212, Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1 -10 [AT Ej General Corrosion Monitoring Program Thermowells Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; EJ] 212 Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej General Corrosion Monitoring Program Turbines Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej 212 Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej General Corrosion Monitoring Program Valve Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A, Ej 212 Bodies Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej General Corrosion Monitoring Program Primary Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; Ej 212 Containment Galvanic Corrosion Monitoring Program Air (Ext)Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,]General Corrosion Monitoring Program Table 3.2.2-7 Engineered Safety Features -Residual Heat Removal System -Summary of Aging Ma agement Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Accumulators Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej 212 Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E, General Corrosion Monitoring Program Heat Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej 212 Exchangers Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej]General Corrosion Monitoring Program Manifolds Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,1 212 Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej General Corrosion Monitoring Program Piping and Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej 212 Fittings Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; Ej General Corrosion Monitoring Program Primary Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,. 212 Containment Galvanic Corrosion Monitoring Program Air (Ext)Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej General Corrosion Monitoring Program Page 42 of 149 ENCLOSURE I Table 3.2.2-7 Engineered Safety Features -Residual Heat Removal System -Summary of Aging Management Evaluation (Cont'd)Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Pump Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej 212, Casings Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [A E, General Corrosion Monitoring Program Thermowells Pressure Carbon Plant Indoor Loss of Material -. System Condition V.E.1-b 3.2.1-10 [A; Ej 212 Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,]General Corrosion Monitoring Program Valve Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A, Ej 212 Bodies Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT Ej Genera! Corrosion Monitoring Program Primary Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; Ej 212 Containment Galvanic Corrosion Monitoring Program Air (Ext) Loss of Material -System Condition V.E.1-b 3.2.1-10 [A 7 Ej General Corrosion Monitoring Program Table 3.2.2-8 Engineered Safety Features -S condary Containme t System -Summa of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Damper Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,1 212, Housings Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [A, Ej General Corrosion Monitoring Program Flow Flow Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; Ej 212, Element Restriction Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; El General Corrosion Monitoring Program Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,] 212, Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2:1-10 [A; E, General Corrosion Monitoring Program Manifolds Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E,] 212 Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E, General Corrosion Monitoring Program Piping and Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; Ej 212 Fitings Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; E, General Corrosion Monitoring Program Page 43 of 149 ENCLOSURE I Table 3.2.2-8 Engin ered Safe ty Features -Se condary Containme t System -Summa of Aging M nagement Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Restricting Flow Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A 7 E,] 212, Orifices Restriction Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; Ed General Corrosion Monitoring Program Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT EJ 212, Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,]General Corrosion Monitoring Program Thermowells Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; EJ 212 Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [AT E,]General Corrosion Monitoring Program Valve Pressure Carbon Plant Indoor Loss of Material -System Condition V.E.1-b 3.2.1-10 [A7 EJ 212 Bodies Boundary Steel Air (Ext) Galvanic Corrosion Monitoring Program Loss of Material -System Condition V.E.1-b 3.2.1-10 [A; EJ General Corrosion Monitoring Program Page 44 of 149 ENCLOSURE 1 LRA Section 3.2 -Aging Management of Engineered Safety Features 3.2.1 Introduction BACKGROUND (CLB Change)NRC approved License Amendment 138 for MNGP, which eliminated the requirements for hydrogen recombiners and relax the requirements for hydrogen and oxygen monitoring.

DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough) 3.2.1 Introduction This section provides the results of the aging management review for those components identified in Section 2.3.2, Engineered Safety Features, as being subject to aging management review. The systems, or portions of systems, which are addressed in this section, are described in the indicated sections.* Automatic Pressure Relief System (Section 2.3.2.1)* Combustible Gas Control System [(Seetien 2.3.2.2) Deleted]* Core Spray System (Section 2.3.2.3)* High Pressure Coolant Injection System (Section 2.3.2.4)* Primary Containment Mechanical System (Section 2.3.2.5)* Reactor Core Isolation Cooling System (Section 2.3.2.6)* Residual Heat Removal System (Section 2.3.2.7)* Secondary Containment System (Section 2.3.2.8)3.2.2 Results The materials that specific components are fabricated from, the environments to which components are exposed, the potential aging effects requiring management, and the aging management programs used to manage these aging effects are provided for each of the above systems in the following subsections of Section 3.2.2.1, Materials, Environment, Aging Effects Requiring Management and Aging Management Programs: Section 3.2.2.1.1, Automatic Pressure Relief System[Scetion 3.2.2.1.2,]Combustible Gas Control System [Deleted]Section 3.2.2.1.3, Core Spray System Section 3.2.2.1.4, High Pressure Coolant Injection System Section 3.2.2.1.5, Primary Containment Mechanical System Page 45 of 149 ENCLOSURE 1 3.2.2.1.2 Combustible Gas Control System [Deleted]Materias r_ _I h mawcials et eonStruction

!Er the r~emiustIDle Uas GentreI System eempenents arc: C-Garben-Steel

• -Staine Stl Thc Combsilc a Control Systrom opocts +arr cxoscd tr tho~ following cnvironmcnts:-Plant Indoor Air (Ext)-PFrimary Gentainmnet Air (Int)'-Trcated Watcr (Int)Aging Effets FRequiring Management The follewing aging effects, asseciated with the Conbustible Gas Contro Systcm, rcgircmaagement:

,-Loss of Matcrial Crevicc Corrosion'-Loss of Matcrial Galvanic Corresie 4-Loss of Matcrial Gcncral Corrosion*-Loss of Matcrial MIC'-Loss of Matcrial Pitting Corrosie Aging Managemcnt Programs Thc following aging managemcnt programs ma CombustiblE Ga Control System componrnts:

--lftintegfty

'-Onc-Timc Inzpccticn

,"--Plant Chemry. Program r Systm Condition Monitoring PFE gFaM]naec thc aging cffcts for thc Page 46 of 149 ENCLOSURE I LRA Section 3.2 -Aging Management of Engineered Safety Features 3.2.1 Introduction BACKGROUND (3.2-10)NUREG-1 801 Chapter V does not contain a line item which covers ECCS piping in treated water susceptible to FAC; therefore, Table 3.2.1 line item 3.2.1-14 was not used. Instead ECCS piping and fittings, exposed to treated water, susceptible to FAC, used Table 3.1.1 line item 3.1.1-25, and GALL line item IV.C1 .1-c for a better match.LRA Table 3.2.1 line item 3.2.1-14 was revised from "Aging effect is managed by the Flow-Accelerated Corrosion Program." to "This line item is not used at MNGP." DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table 3.2.1 Summary of Aging Management Evaluations in Cha ter V of NUREG 1801 for Engineered Safety Features Aging Further Item Aging Management Evaluation Number Component Effect/Mechanism Programs Recommended Discussion 3.2.1-14 Emergency Wall thinning due Flow- No [This line Item Is not used at MNGP. Agfl8 core cooling to flow-accelerated accelerated effzt is managed by the Flow Ace.erated system valves corrosion corrosion ePfgraf.]

Consistent with NUREG-and lines to 1801, some sections of the High Pressure and from HPC Coolant Injection (HPC) and Reactor Core and RCI pump Isolation Cooling (RCI) systems are susceptible turbines to flow-accelerated corrosion (FAC) and the Flow-Accelerated Corrosion Program is credited to manage the aging effect. The predominate sections of the HPC and RCI systems were evaluated as not susceptible to FAC based on material type or the components have no flow or operate less than 2% of plant operating time.The components that fall in the latter category do not require aging management for FAC in accordance with EPRI, NSAC-202L, R2 and NUREG-1557.

'Summary of Technical Information and Agreements from Nuclear Management and Resources Council Industry Reports Addressing License Renewal.'Page 47 of 149 ENCLOSURE I LRA Section 3.2 -Aging Management of Engineered Safety Features 3.2.2 Results BACKGROUND (3.3.2.3-8)

Elastomers in Table 3.2.2-8 (ventilation seals in the Secondary Containment System) are presently being managed utilizing the One-Time Inspection Program for the internal surfaces and the System Condition Monitoring Program for the external surfaces.

These AMPs were initially credited to manage change in material properties and cracking due to thermal exposure, since a temperature threshold of greater than 95 0 F was assigned to these components.

Consequently, these same AMPs will also manage change in material properties due to ozone exposure which shall be assigned to these components.

DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table 3.2.2-8 Engineered Safety Features -Secondary Containment System -Summary of Aging Ma agement Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table 1 Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item Ventilation Pressure Neoprene Plant Indoor Change in Material System Condition V.B.1-b 3.2.1-07 A Seal Boundary Air (Ext) Properties

-Monitoring Thermal Exposure Program[Ozone Exposure]Cracking -Thermal System Condition V.B.1-b 3.2.1-07 A Exposure Monitoring Program Plant Indoor Change in Material One-Time V.B.1-b 3.2.1-07 E, 203 Air (Int) Properties

-Inspection Thermal Exposure[Ozone Exposure]Cracking -Thermal One-Time V.B.1-b 3.2.1-07 E, 203 Exposure Inspection Page 48 of 149-ENCLOSURE I LRA Section 3.3 -Aging Management of Auxiliary Systems 3.3.2.2 Further Evaluation of Aging Management as Recommended by NUREG-1 801 BACKGROUND (3.5.2.1.15-1 a)NMC has evaluated when to remove the remaining set of three Boral coupons (two clad in stainless steel and one bare coupon) for sampling and determined that minimal benefit would be provided by testing the coupons prior to the period of extended operation.

As discussed with the NRC staff, NMC will remove the remaining Boral coupons from the MNGP Spent Fuel Pool during the period of extended operation for surveillance testing.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough) 3.3.2.2.10 Reduction of Neutron-Absorbing Capacity and Loss of Material due to General Corrosion This subsection discusses various aging effects for Boral. This subsection specifically discusses the plant specific programs used to manage the aging effects for Boral.The Plant Chemistry Program is used to manage the aging effects loss of material and reduction of neutron-absorbing capacity of Boral in treated water environment due to crevice, galvanic, MIC and pitting corrosion and the aging effect cracking due to stress corrosion cracking by ensuring that corrosive ion concentrations do not exceed acceptable limits and by limiting the amount of impurities in the water. General corrosion is not applicable since boral/aluminum develops a strongly bonded oxide film with excellent corrosion resistance.

The One-Time Inspection Program will verify the effectiveness of the Plant Chemistry Program by confirming the absence of aging effects on Boral coupon samples stored in the spent fuel pool. Aging effects that could affect rack integrity or neutron absorption characteristics are not expected since none have been observed during coupon sample evaluations conducted over the past 20 years. [NMC will visually examine the unclad boral coupon sample prior to extended operation.

The coupon will be removed from the spent fuel pool for a brief period of time, visually examined, and then immediately returned to the spent fuel pool.]Exceptions apply to NUREG-1801 recommendations for the Plant Chemistry Program implementation.

Implementation of the One-Time Inspection Program in conjunction with the Plant Chemistry Program to manage the aging effects for Boral provides added assurance that the aging effects are not occurring; or that the aging effects are progressing very slowly such that the component's intended function will be maintained during the period of extended operation.

Page 49 of 149 ENCLOSURE 1 LRA Section 3.3 -Aging Management of Auxiliary Systems 3.3.2.1.18 Wells and Domestic Water System BACKGROUND (RilI-2.3.3.1 8-01)A modification replaced the original PVC piping drains with C-276 (Hastelloy) in 2005 to remove intervening combustibles between redundant divisions of safe shutdown equipment in the Intake Structure.

Per the modification, the new piping and supports are Seismic 11/1.Therefore, these drains meet scoping criterion (a)(2) and are required to be within the scope of license renewal.The drains fall within the Wells and Domestic Water System (WDW). The associated LRA sections will be revised to address these drain lines being within scope.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough) 3.3.2.1.18 Wells and Domestic Water System Materials The materials of construction for the Wells and Domestic Water System components are:* Carbon Steel* Cast Iron* Copper Alloy* Stainless Steel* [Hasteloy) (C-276)]Page 50 of 149 ENCLOSURE 1 LRA Section 3.3 -Aging Management of Auxiliary Systems 3.3.2 Results BACKGROUND (3.1-03)To resolve the conflict between the AMP description and the LRA table, NMC determined that LRA Table 3.3.2-2, Page 3-296, should be revised to remove the line item for the Chemistry Sampling System carbon steel valve. In addition the LRA Appendix B2.1.19 (Flow Accelerated Corrosion)

Program will be revised to remove the Chemistry Sampling System from the list of systems which it manages.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table 3.3.2-2 Auxiliary Systems- Chemistry Sampling System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging Management NUREG Table 1 Notes Type Function Requiring Programs -1801 Item Management Volume 2 Line Item Valve Bodies Pressure Carbon Treated Water Loss of Material -One-Time VlIl.E.2-b 3.4.1-02 A, 312, Boundary Steel (Int) Pitting Corrosion Inspection 326 Plant Chemistry V\II.E.2-b 3.4.1-02 B, 312, Program 326 Treated Water Loss of Material -One-Time VlII.C.2-b 3.4.1-02 A, 326 or Steam (Int) Crevice Inspection Corrosion Plant Chemistry VII.C.2-b 3.4.1-02 B. 326 Program[Loss ef Mateial Flow Aeeeierated VI.G.2 b a-0 Ag26]FAG Corrosin Page 51 of 149 ENCLOSURE 1 LRA Section 3.3 -Aging Management of Auxiliary Systems 3.3.2 Results BACKGROUND (2.1-2a)During discussions with the NRC staff NMC determined that for the purposes of clarification, using the ground as an equivalent anchor required that the below grade piping be included in-scope for license renewal. Therefore, a review of the additional in-scope piping was performed to determine the changes/additions required to material, environment, aging effects and aging management programs.

The following clarifications were made: DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

For the Circulating Water System (CWT) from the Service Seal Water (SSW) system, lines SW8-14"-JF on Drawing LR-36041 (D4) and SW6-24"-JF on Drawing LR-36664 (B8) were extended underground to the circulating water piping. The underground portion of the circulating water piping from the SW6-24"-JF connection point on Drawing LR-36489 (B2) to the Turbine Building on Drawing LR-36489 (C2) is considered part of the buried piping equivalent anchor and, therefore, is also included in-scope.

This line is carbon steel. Therefore, the following information was added to the CWT system, LRA Table 3.3.2-3 Auxiliary Systems- Circulating Water System -Summary of Aging Management Evaluation:

Table 3.3.2-3 Auxiliary 5ystems- Circulating Water Sys tem -Summary Ot Agi g Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG- Table 1 Notes Type Function Requiring Management 1801 Item Management Programs Volume 2 Line Item[Piping and Pressure Carbon Buried in Loss of Material -Buried Piping & VII.CI.1-b 3.3.1-18 A, 315 Fittings Boundary Steel Ground (Ext) Crevice Corrosion Tanks Inspection Loss of Material -Buried Piping & VII.C1.1-b 3.3.1-18 A, 312, Galvanic Corrosion Tanks 315 Inspection Loss of Material -Buried Piping & VIL.C.1.-b 3.3.1-18 A, 315 General Corrosion Tanks Inspection Loss of Material -Buried Piping & VII.C1.1-b 3.3.1-18 A, 315 MIC Tanks Inspection Loss of Material -Buried Piping & VII.C1.1-b 3.3.1-18 A, 315]Pitting Corrosion Tanks Inspection Page 52 of 149 ENCLOSURE I LRA Section 3.3 -Aging Management of Auxiliary Systems 3.3.2 Results BACKGROUND (3.3.2.3-8)

After further evaluation of this issue, NMC has taken the conservative approach of managing change in material properties due to ozone exposure for elastomers in an air environment, specifically for natural rubber.As a result, elastomers in an external air environment in LRA Table 3.3.2-3 (expansion joints in the Circulating Water System), Table 3.3.2-5 (piping and fittings in the Demineralized Water System), Table 3.3.2-6 (piping and fittings in the Emergency Diesel Generators System), Table 3.3.2-7 (ventilation seals in the Emergency Filtration Train System), Table 3.3.2-16 (expansion joints in the Service and Seal Water System), and Table 3.4.2-2 (expansion joints in the Condensate and Feedwater System which were not previously managed externally), will utilize the System Condition Monitoring Program to manage the potential aging effect of change in material properties due to ozone exposure which shall be assigned to these components.

DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table 3 ?.2-Anvii~inrv u tam rirr-,iftinn Watpr Sc~v-ttm -Riummarv nf Aninn Manaripment Fvahuiafinn Aging Effect Aging Management NUREG Component Intended Material Environment Requiring Programs -1801 Table I Notes Type Function Management Volume 2 Item Line Item Expansion Pressure Rubber Plant Indoor [None-Change In [None System [J, a44 Joints Boundary Air (Ext) Material Properties Condition

.27]-Ozone Exposure]

Monitoring Program]Raw Water None None J. 314, (Int) 327 Table 3.3.2-5 Auxiliary Systems- Demineralized Water System -Summary of Aging Mana ement Evaluation Aging Effect Aging Management NUREG Component Intended Material Environment Requiring Programs -1801 Table I Notes Type Function Management Volume 2 Item Line Item Piping and Pressure Rubber Plant Indoor [None Change in [None System [J, &4.Fittings Boundary Air (Ext) Material Properties Condition am-Ozone Exposure]

Monitoring Program]Treated None None J. 314, Water (Int) 327 Page 53 of 149 ENCLOSURE 1 Table 3.3.2-5 Auxiliar r Systems- Emergency D esel Generators Syst em -Summary ot Aging Management Evaluation Aging Effect Aging Management NUREG Component Intended Material Environment Requiring Programs -1801 Table 1 Notes Type Function Management Volume 2 Item Line Item Piping and Pressure Rubber Gas -[Nene Change in [Nenve One-Time [J. 44;Fittings Boundary Instrument Material Properties Inspection Program] am Air (Int) -Ozone Exposure]Plant Indoor [None Change in [None System VlI.F4.1-b 3.3.1-02 [I, 844 Air (Ext) Material Properties Condition 32?-Ozone Exposure]

Monitoring Program]Table 3.3.2-7 Auxilia.y Systems -Emergency Filtration Train System -Summary of Aging Management Evaluation Aging Effect Aging Management NUREG Component Intended Material Environment Requiring Programs -1801 Table I Notes Type Function Management Volume 2 Item Line Item Ventilation Pressure Elastomers Air/Gas (Int) [None Change In [None One-Time V\ I.F1.1-b 3.3.1-02 [I, 344T Seal Boundary (Rubber, Material Properties Inspection Program] 32?]Neoprene, -Ozone Exposure]Silicone, etc) Plant Indoor [None-Change In [Nene System VII.F1.1-b 3.3.1-02 [1. A44 Air (Ext) Material Properties Condition 327]-Ozone Exposure]

Monitoring Program]Table 3.3.2-16 Auxiliar tSystems -Service and Seal Water System -Summary of Aging Mana ement Evaluation Aging Effect Aging Management NUREG Component Intended Material Environment Requiring Programs -1801 Table I Notes Type Function Management Volume 2 Item Line Item Expansion Pressure Rubber Plant Indoor [None- Change in [None System [J, 344;Joints Boundary Air (Ext) Material Properties Condition 32a]-Ozone Exposure]

Monitoring Program]Raw Water None None J, 314, (Int) 327 Table 3.4.2-2 Steam and Power Conversion System -Condensate and Feedwater System -Summary of Aging Management Evaluation Aging Effect Aging Management NUREG Component Intended Material Environment Requiring Programs -1801 Table I Notes Type Function Management Volume 2 Item Line Item Expansion Pressure Rubber Plant Indoor [None- Change In [None System [J,444;lJoints Boundary Air (Ext) Material Properties Condition 42?q]-Ozone Exposure]

Monitoring Program]Treated Change in Material One-Time Inspection J, 404, Water (Int) Properties

-Thermal Exposure Cracking -Thermal One-Time Inspection J, 404 Exposure Page 54 of 149 ENCLOSURE I LRA Section 3.3 -Aging Management of Auxiliary Systems 3.3.2 Results BACKGROUND (3.3.2.3-8)

After further evaluation of this issue, NMC has taken the conservative approach of managing change in material properties due to ozone exposure for elastomers in an air environment, specifically for natural rubber.Elastomers in an internal air environment in Table 3.3.2-6 (piping and fittings in the Emergency Diesel Generators System) and Table 3.3.2-7 (ventilation seals in the Emergency Filtration Train System) will utilize the One-Time Inspection Program to manage the potential aging effect of change in material properties due to ozone exposure which shall be assigned to these components.

DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

---

en I able 3.3.-o Auxiiar yystems- Emergency uDeset Generators oys em -summary oT Aging management Evaluation Aging Effect Aging Management NUREG Component Intended Material Environment Requiring Programs -1801 Table I Notes Type Function Management Volume 2 Item Line Item Piping and Pressure Rubber Gas -[None Change In [None One-Time [J. 344;Fittings Boundary Instrument Material Properties Inspection Program] am Air (Int) -Ozone Exposure]Plant Indoor [Neft- Change In [None System VII.F4.1-b 3.3.1-02 [I, 344, Air (Ext) Material Properties Condition am-Ozone Exposure]

Monitoring Program]Table 3.3.2-7 Auxii ary Systems -E ergency Filtration Train System -Su mmary of Aging Man gement Evaluation Aging Effect Aging Management NUREG Component Intended Material Environment Requiring Programs -1801 Table 1 Notes Type Function Management Volume 2 Item Line Item Ventilation Pressure Elastomers Air/Gas (Int) [None Change in [None One-Time VIL.F1.1-b 3.3.1-02 [I. 4-1 Seal Boundary (Rubber, Material Properties

-Inspection 3a Neoprene, Ozone Exposure]

Program]Silicone, etc) -Plant Indoor [None Change in [None System VII.F1.1-b 3.3.1-02 [I, 3414 Air (Ext) Material Properties

-Condition Ozone Exposure]

Monitoring I Program]Page 55 of 149 ENCLOSURE I LRA Section 3.3 -Aging Management of Auxiliary Systems 3.3.2 Results BACKGROUND (3.3.2.1 .9-2)Table 3.3.2-9, Auxiliary Systems-Fire System-Summary of Aging Management Evaluation, identifies stainless steel fasteners/bolting "exposed to weather" and "plant indoor air" external environments.

For conservatism during the IPA process, the stainless steel fastener/bolting component was added as a "global" asset in both an "exposed to weather" and "plant indoor air" external environment to assure no components, materials or environments were inadvertently omitted from the evaluations.

However, recent walkdowns of the Fire System revealed that there were no stainless steel fasteners/bolting"exposed to weather".Consequently, the Fire System's stainless steel fasteners/bolting "exposed to weather" asset is removed from Table 3.3.2-9.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table 3.3.2-9 Aux liary Syst ems- Fire Sy tem -Summary of Aging Manageme t Evaluation Aging Effect Aging NUREG Component Intended Material Environment Requiring Management

-1801 Table 1 Notes Type Function Management Programs Volume 2 Item Line Item Fasteners/

Pressure Stainless

[Expesedto eRe .Bolting Boundary Steel Weather-(Ext) 306,-32 Plant Indoor None None J, 301 Air (Ext) I 306 327 Page 56 of 149 ENCLOSURE 1 LRA Section 3.3 -Aging Management of Auxiliary Systems 3.3.2 Results BACKGROUND (3.3.2.1.9-3)

Although the Fire Water System AMP is credited in the license renewal database for managing the aging effect of loss of material for copper alloy filters and strainers in a raw water environment, it was inadvertently omitted from Table 3.3.2-9 of the LRA and is, in fact, credited for managing these components in the water-based portion of the Fire System. Therefore, NMC is updating MNGP LRA Table 3.3.2-9 to state that the Fire Water System AMP is credited for managing the aging effect of loss of material for copper alloy filters and strainers in a raw water environment.

DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table 3.3.2-9 Auxiliarv Svstems- Fire Svstem -Summarv of Aoina Mananement Evaluation Componen Environment Aging Effect Aging Management NUREG -Type Function Requiring Programs 1801 Item Notes nent Volume 2 Line Item Filters / Filtration Copper Plant Indoor Air None .None J. 327 Strainers Alloy (Ext)Raw Water Loss of Material -Fire Protection Vll.G.6-b 3.3.1-21 E. 319 (Int) Crevice Corrosion.[Fire Water.System VII.G.6-b 3.3.1-21 A, 312]Loss of Material -Fire Protection VlI.G.6-b 3.3.1-21 E, 319 MIC[Fire Water System VII.G.6-b 3.3.1-21 A, 312]Loss of Material -Fire Protection VII.G.6-b 3.3.1-21 E, 319 Pitting Corrosion

[Fire Water System VII.G.6-b 3.3.1-21 A, 312]Loss of Material -Fire Protection VlI.G.6-b 3.3.1-21 E, 312, Selective 319 Leaching [Fire Water System VII.G.6-b 3.3.1-21 A, 312]Page 57 of 149 ENCLOSURE 1 LRA Section 3.3 -Aging Management of Auxiliary Systems 3.3.2 Results BACKGROUND (3.3-04)The selective leaching aging mechanism was listed in error in (FIR) Table 3.3.1 item 3.3.1-5. The Table 3.3.2-9 line item for Pump Casings/Gray Cast Iron/Plant Indoor Air identifies an Aging Effect Requiring Management of Loss of Material -Selective Leaching.The line item is deleted.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table 3.3.2-9 Auxiliary S stems- Fire System -Summary of Aging Mana ement Evaluation Aging Effect Aging NUREG Component Intended Material Environment Requiring Management

-1801 Table I Notes Type Function Management Programs Volume 2 Item Line Item Pump Pressure Gray Plant Indoor Loss of Material -Fire Water System V1.1.1-b 3.3.1-05 E, 303, Casings Boundary Cast Air (Ext) Galvanic Corrosion 312, 317 Iron Loss of Material -Fire Water System V11.I.1.-b 3.3.1-05 E, 303, General Corrosion 312, 317[Loss of Material -Fire Water System Vihi -b 3.3A-05 E , 303, Sewetve 6ee I__ _ _ _ _3173 Page 58 of 149 ENCLOSURE 1 LRA Section 3.3 -Aging Management of Auxiliary Systems 3.3.2 Results BACKGROUND (2.1-2a)During discussions with the NRC staff NMC determined that for the purposes of clarification, using the ground as an equivalent anchor required that the below grade piping be included in-scope for license renewal.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

A review of the additional in-scope piping was performed to determine the changes/additions required to material, environment, aging effects and aging management programs.

The following clarifications were made: For the Heating and Ventilation (HTV) system, the in-scope portion of the ducting (below grade portion is piping) from the Off-Gas Storage and Compressor Building (OGSB) fan room was extended underground to the point where it exits the ground on Drawing LR-51142-1 (B6). This line is carbon steel and contains flanged connections with bolts. Therefore, the following information is added to the HTV system, LRA Table 3.3.2-11 Auxiliary Systems -Heating and Ventilation

-Summary of Aging Management Evaluation:

Table 3.3.2-11 Auxiliary Systems -Hea ing and Ventilation

-Summary of Aginq Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG- Table 1 Notes Type Function Requiring Management 1801 Item Management Programs Volume 2 Line Item[Piping and Pressure Carbon Buried In Loss of Material -Buried Piping & VII.C1.1-b 3.3.1-18 A, 315 Fittings Boundary Steel Ground (Ext) Crevice Corrosion Tanks Inspection Loss of Material -Buried Piping & VII.C1.1-b 3.3.1-18 A, 312, Galvanic Corrosion Tanks 315 Inspection Loss of Material -Buried Piping & VILcl.1.-b 3.3.1-18 A, 315 General Corrosion Tanks Inspection Loss of Material -Buried Piping & VII.C1.1-b 3.3.1-18 A, 315 MIC Tanks Inspection Loss of Material -Buried Piping & VIL.CI.1-b 3.3.1-18 A, 315]Pitting Corrosion Tanks Inspection Page 59 of 149 ENCLOSURE 1 Table 3.3.2-11 Auxiliary Systems -Heating and Ventilation

-Summary of Aging Management Evaluation (Cont'd)Component Intended Material Environment Aging Effect Aging NUREG- Table I Notes Type Function Requiring Management 1801 Item Management Programs Volume 2 Line Item[Fasteners/

Pressure Carbon Buried In Loss of Material -Bolting Vll.C1.1-b 3.3.1-18 E, 301, 306, Bolting Boundary Steel Ground (Ext) Crevice Corrosion Integrity 309, 315 Loss of Material -Bolting Vll.C1.1-b 3.3.1-18 E, 301, 306, Galvanic Corrosion Integrity 309, 312, 315 Loss of Material -Bolting Vll.C1.1-b 3.3.1-18 E, 301, 306, General Corrosion Integrity 309, 315 Loss of Material -Bolting VII.C1.1-b 3.3.1-18 E, 301, 306, MIC Integrity 309, 315 Loss of Material -Bolting Vll.C1.1-b 3.3.1-18 E, 301, 306, Pitting Corrosion Integrity 309, 315]Page 60 of 149 ENCLOSURE 1 LRA Section 3.3 -Aging Management of Auxiliary Systems 3.3.2 Results BACKGROUND (3.3.2.3-8)

After further evaluation of this issue, NMC has taken the conservative approach of managing change in material properties due to ozone exposure for elastomers in an air environment, specifically for natural rubber.Elastomers in both an internal and external air environment in Table 3.3.2-11 (ventilation seals in the Heating and Ventilation System) were inadvertently omitted from this table.These components will be managed for the potential aging effect of change in material properties due to ozone exposure utilizing the One-Time Inspection Program for the internal surfaces and the System Condition Monitoring Program for the external surfaces which shall be assigned to these components.

DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table 3.3.2-11 Auxiliary Syste s -Heating and Ventilation

-Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table I Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item[Ventilation Pressure Neoprene Plant Indoor Change In Material System V.B.1-b 3.2.1-07 A Seal Boundary Air (Ext) Properties

-Condition Ozone Exposure Monitoring Program Plant Indoor Change in Material One-Time V.B.1-b 3.2.1-07 E, 303]Air (Int) Properties

-Inspection Ozone Exposure Page 61 of 149 ENCLOSURE 1 LRA Section 3.3 -Aging Management of Auxiliary Systems 3.3.2 Results BACKGROUND (2.1-2a)During discussions with the NRC staff, NMC determined that for the purposes of clarification, using the ground as an equivalent anchor required that the below grade piping be included in-scope for license renewal.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

A review of the additional in-scope piping was performed to determine the changes/additions required to material, environment, aging effects and aging management programs.

The following clarifications were made: For the Service and Seal Water (SSW) system the in-scope portion of line SW8-14"-JF was extended underground to the point where it connects to the 78" diameter circulating water line on Drawings LR-36041 (D4) and LR-36489 (B1). This line is carbon steel.The in-scope portion of line SW6-24"-JF was extended underground to the point where it connects to the 108" diameter circulating water line on Drawings LR-36664 (B8) and LR-36489 (B2). This line is carbon steel.Therefore, the following information was added to the SSW system, LRA Table 3.3.2-16 Auxiliary Systems -Service and Seal Water System -Summary of Aging Management Evaluation:

Table 3.3.2-16 Auxiliaiy Systems -Service and Seal Water System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging Management NUREG- Table 1 Notes Type Function Requiring Programs 1801 Item Management Volume 2 Line Item[Piping and Pressure Carbon Buried In Loss of Material -Buried Piping & Tanks VII.C1.1-b 3.3.1-18 A, 315 Fittings Boundary Steel Ground (Ext) Crevice Corrosion Inspection Loss of Material -Buried Piping & Tanks VIl.C1.1-b 3.3.1-18 A, 312, Galvanic Corrosion Inspection 315 Loss of Material -Buried Piping & Tanks Vll.C1.1-b 3.3.1-18 A, 315 General Corrosion Inspection Loss of Material -Buried Piping & Tanks VIL.CI.1-b 3.3.1-18 A, 315 MIC Inspection Loss of Material -Buried Piping & Tanks VII.C1.1-b 3.3.1-18 A, 315]Pitting Corrosion Inspection Page 62 of 149 ENCLOSURE 1 LRA Section 3.3 -Aging Management of Auxiliary Systems 3.3.2 Results BACKGROUND (B2.1 .2-14)After further review of these systems, it was determined that a stainless steel piping segment in a treated water environment in the Standby Liquid Control System has the potential for cracking due to its proximity to the RPV. LRA Table 3.3.2-17 Auxiliary Systems -Standby Liquid Control System, Page 3-487, is revised to include the aging effect of cracking for this stainless steel piping with an internal treated water environment, crediting the ASME Section Xl In-Service Inspection, Subsections IWB, IWC, and IWD, Plant Chemistry and One-Time Inspection Programs.

This will be NUREG-1 801, Volume 2 Line Item IV.C1.1-i and Table 1 Item 3.1.1-7.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table 3.3.2-17 Auxiliarv Svstems -Standbv Licuid Control Svstam -Summarv of Aaina Mananament fEvaluation Aging Effect Aging Management NUREG Component Intended Material Environment Requiring Programs -1801 Table I Notes Type Function Management Volume 2 Item Line Item Piping and Pressure Stainless Treated Water Loss of Material -One-Time Inspection V1I.E4.1-a 3.3.1-08 A Fittings Boundary Steel (Int) Crevice Corrosion Plant Chemistry V\l.E4.1-a 3.3.1-08 B Program[Cracking One-Time Inspection IV.C1.1-i 3.1.1-07 A Plant Chemistry IV.C1.1-i 3.1.1-07 B Program ASME Section XI IV.C1.1.i 3.1.1-07 B]In-Service Inspection, Subsections IWB, IWC, and IWD Page 63 of 149 ENCLOSURE I LRA Section 3.3 -Aging Management of Auxiliary Systems 3.3.2 Results BACKGROUND (RiII-2.3.3.1 8-01)A modification replaced the original PVC piping drains with C-276 (Hastelloy) in 2005 to remove intervening combustibles between redundant divisions of safe shutdown equipment in the Intake Structure.

Per the modification, the new piping and supports are Seismic 11/1.Therefore, these drains meet scoping criterion (a)(2) and are required to be within the scope of license renewal.The drains fall within the Wells and Domestic Water System (WDW). The associated LRA sections are revised to address these drain lines being within scope.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table 3.3.2-18 Auxiliay Systems -Wells and Domestic Water System -ummary of Aging Management Evaluation Aging Effect Aging Management NUREG Component Intended Material Environment Requiring Programs -1801 Table I Notes Type Function Management Volume 2 Item Line Item Piping and Pressure [Hasteloy)

Concrete None None F]Fittings Boundary (C-276) (Ext)[Plant Indoor None None F]Air (Ext)[Raw Water Loss of Material -One-Time Inspection F](Int) Crevice Corrosion Loss of Material -One-Time Inspection F]MIC Loss of Material -One-Time Inspection F]Pitting Corrosion Page 64 of 149 ENCLOSURE I LRA Section 3.4 -Aging Management of Steam and Power Conversion System 3.4.2.2.4 General Corrosion BACKGROUND (1.5-01)During review of the MNGP LRA, NMC discovered and corrected a minor typographical error in Section 3.4.2.2.4, "General Corrosion." DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough) 3.4.2.2.4 General Corrosion This subsection discusses loss of material due to general corrosion on the external surfaces of carbon steel and cast iron components of the steam and power conversion system in air/gas environments.

Aging effect is managed by the System Condition Monitoring Program. The System Condition Monitoring Program is used to manage the aging effect on the external surfaces of carbon steel and cast iron components in air/gas environments.

Management of the aging effect associated with certain components of the Main Condenser with the intended function, 'plateout and holdup of radioactive material," is not applicable since the Main Condenser structural integrity is continuously demonstrated during normal plant operation.

The System Condition Monitoring Program is [an existing new] plant-specific program.This program manages aging effects for normally accessible, external surfaces of piping, tanks, and other components and equipment within the scope of License Renewal.These aging effects are managed through visual inspection and monitoring of external surfaces for leakage and evidence of material degradation (refer to Appendix B, Section B2.1 .32).Implementation of the System Condition Monitoring Program to manage corrosion provides added assurance that corrosion is not occurring; or that the aging effect is progressing very slowly such that the component's intended function will be maintained during the period of extended operation.

Page 65 of 149 ENCLOSURE I LRA Section 3.4 -Aging Management of Steam and Power Conversion System 3.4.1 Introduction BACKGROUND (3.3-06)NMC has revised the last column of LRA Table 3.4.1 item 3.4.1-12, to read: "Emergency Diesel Generators System Oil Storage Tank external surface is managed by the Buried Piping & Tanks Inspection Program." DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table 3.4.1 Summary of Aging Management Evaluations In Chapter Vill of NUREG-1801 for Steam and Power Conversion System Item Component Aging Aging Further Discussion Number EffectlMechanlsm Management Evaluation Programs Recommended 3.4.1-12 External surface of Loss of material Buried piping and No [Not applicablc.

The buried condensate due to general, tanks surveillance ) _ndensat storage tank and pitting, and crevice storage tanks arc -not AFW piping corrosion and MIC or with in the scope of Buried piping and Yes, detection of license renewal-end-arc tanks inspection aging effects and located above ground.operating experience Emergency Diesel are to be further Generators System Oil evaluated (see Storage Tank external[SRP] subsection surface Is managed by 3.4.2.2.5.2) the Buried Piping &Tanks Inspection Program.]Page 66 of 149 ENCLOSURE I LRA Section 3.4 -Aging Management of Steam and Power Conversion System 3.4.2 Results The following tables summarize the results of the aging management review for systems in the Steam and Power Conversion Systems group: BACKGROUND (2.1-2a)During discussions with the NRC staff, NMC determined that for the purposes of clarification, using the ground as an equivalent anchor required that the below grade piping be included in-scope for license renewal. Therefore, a review of the additional in-scope piping was performed to determine the changes/additions required to material, environment, aging effects and aging management programs.

The following clarifications are made: DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

For the Condensate Storage (CST) system the in-scope portion of lines C1 1-20"-HK, SC1 6-1 0"-HK, C22-4"-HK and C23-4"-HK was extended underground to the point where they exit the ground on Drawing LR-36039 (B4, B5). These lines are stainless steel. Therefore, the following information was added to the CST System, LRA Table 3.4.2-1 Steam and Power Conversion System -Condensate Storage System -Summary of Aging Management Evaluation:

Table 3.4.2-1 Steam and Power Conversion System -Iondensate Storage System -Summary Aging Manage ent Evaluation Component Intended Material Environment Aging Effect Aging NUREG-1801 Table I Notes Type Function Requiring Management Volume 2 Item Management Programs Line Item[Piping and Pressure Stainless Buried in Loss of Material -Buried Piping & VIII.E.5.1-d J, 404, Fittings Boundary Steel Ground (Ext) Crevice Corrosion Tanks 415 Inspection Loss of Material -Buried Piping & VlIl.E.5.1-d J, 404, MIC Tanks 415 Inspection Loss of Material -Buried Piping & VIII.E.5.1-d J. 404, Pitting Corrosion Tanks 415]Inspection Page 67 of 149 ENCLOSURE 1 LRA Section 3.4 -Aging Management of Steam and Power Conversion System 3.4.2 Results BACKGROUND (3.4-10)NMC determined, during a review of the MNGP LRA, that Table 3.4.2-2 of the MNGP LRA be revised to include FAC for the CFW heat exchangers.

No change to the FAC AMP description in the LRA is needed as the CFW System is already included in the FAC Program for aging management.

DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table 3.4.2-2 Steam and Power Conversion System -Condensate and Feedwater System -Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG Table 1 Notes Type Function Requiring Management

-1801 Item Management Programs Volume 2 Line Item[Heat Pressure Carbon Treated Loss of Material -Flow-Accelerated VIII.E.4-d 3.4.1-02 H, 404]Exchangers Boundary Steel Water (Int) FAC Corrosion Page 68 of 149 ENCLOSURE 1 LRA Section 3 -AGING MANAGEMENT REVIEW RESULTS 3.5.Aging Management of Containments, Structures, and Component Supports BACKGROUND (2.1-01)During discussions with the NRC staff regarding equipment stored onsite that is required by station procedures to be installed during emergency or abnormal conditions in accordance with the current licensing basis NMC concluded that the description of the steel plates in the Current License Basis (CLB) and their dedicated use for external flood protection to serve as flood barriers for specific Class I structure openings and penetrations warranted their inclusion in License Renewal scope per 10 CFR 54.4 (a)(2). Similarly, the Intake Structure original floor steel hatch covers, staged to provide external flood protection as described in the MNGP Operations Manual A.6 (Acts of Nature), warranted their inclusion in License Renewal scope.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough) lable 3.5.2-8 Structures and lComponent Supports -Intake Structure

-Summary o0 Aging Management Evaluation Aging Effect Aging NUREG- Table Component Intended Material Environment Requiring Management Volume 2 I Notes Type Function Management Programs Vline Ite Item Carbon Steel, Cooling Carbon Atmosphere/

Loss of material Structures IlI.A6.2-a 3.5.1-22 E, 51 1.Low Alloy Water Steel Weather Corrosion Monitoring 512, [572]Steel in Source .Program Atmosphere/

Flood Weather Barrier (Structural Non-Safety Steel, Sheet Support Piles, Safety Ventilation Related Assemblies, Support[Stored Shelter/Steel Hatch Protection Covers and Steel Plates for External Flood Protection)]

[572 The Intake Structure original floor steel hatch covers are stored on site for external flood protection to serve as flood barriers.

Similarly, steel plates are stored to provide external flood protection for specific safety related structure openings and penetrations.

These components are not installed, but rather dedicated for use.]Page 69 of 149 ENCLOSURE I LRA Section 3.5 -Aging Management of Containments, Structures, and Component Supports 3.5.2 Results BACKGROUND (3.5-02)During discussions with the NRC staff, NMC determined that the following items listed in LRA Table 3.5.2-13, structural steel components in treated water that were included under line item l.B13.1.1-a, should be revised: LRA line lI.B13.1.1 -a for the component structural steel in a treated water environment for the AMP Plant Chemistry Program is revised to list note "E" and not note "D".LRA line ll.B1.1.1-a for the component structural steel in a treated water environment for the AMP Primary Containment In-Service Inspection Program is revised to list note"C" and not note "D".DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table 3.5.2-13 Structures and Corn onent Supports -Primary Containment-Summary of Aging Management Evaluation Aging Effect Aging Management NUREG Component Intended Material Environment Requiring Programs -1801 Table 1 Notes Type Function Management Volume 2 Item Line Item Carbon Steel, Non-Safety Carbon Treated Water Loss of material / Plant Chemistry l 1.B1.1.1-a 3.5.1-12, [D E.]Low Alloy Support steel General, crevice, Program 3.5.1-14 555, 561.Steel in galvanic, MIC and 563, 568 Treated Wate Safety pitting corrosion Related Primary Containment lI.B13.1.1-a 3.5.1-12, f9 Cj (Structural Support In-Service Inspection 3.5.1-14 555, 561.Steel) Program 566, 568 Page 70 of 149 ENCLOSURE I LRA Section 3.5 -Aging Management of Containments, Structures, and Component Supports 3.5.2 Results BACKGROUND (3.5-02)During discussions with the NRC staff, NMC determined that the following items listed in LRA Table 3.5.2-13, components including support members, welds, bolted connections, torus internal catwalk support columns in treated water were included under line item II.1B1.1.1-a:

LRA line ll.BI.1.1 -a for the components support members, welds, bolted connections, torus internal catwalk support columns in a treated water environment for the AMP Primary Containment In-Service Inspection Program is revised to list note "C" and not note "D".LRA line II.BI3.1.1 -a for the components support members, welds, bolted connections, torus internal catwalk support columns in a treated water environment for the AMP Plant Chemistry Program is revised to list note "E" and not note "D".DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table 3.5.2-13 Structures and Corn onent Supports -Primary Containment

-Summary of A ing Management Evaluation Aging Effect Aging Management NUREG Component Intended Material Environment Requiring Programs -1801 Table I Notes Type Function Management Volume 2 Item Line Item Carbon Steel, Non-Safety Carbon Treated Water Loss of material / Plant Chemistry l 1.B1.1.1-a 3.5.1-12, ID Ej Low Alloy Support steel General, crevice, Program 3.5.1-14 555, 561, Steel in galvanic, MIC 563, 568 Treated Water Safety and (Support Related pitting corrosion Primary Containment ll.B1.1.1-a 3.5.1-12, ID Cj members, In-Service Inspection 3.5.1-14 555, 561, welds, bolted Program 563, 568 connections, i.e. Torus Internal Catwalk Support C o lu m n s) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _Page 71 of 149 ENCLOSURE I LRA Section 3.5 -Aging Management of Containments, Structures, and Component Supports 3.5.2 Results BACKGROUND (3.5-03)Following discussions with the NRC staff, NMC revised LRA Table 3.5.2-13, LRA line lI.B1.1.1-a, for the components structural steel inside torus, torus internal catwalk in an air/gas environment for the AMP Primary Containment In-Service Inspection Program to list note "C" and not note "D".DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table 3.5.2-13 Structures and Comr onent Supports -Primary Contai ment -Summary of Al ing Management Evaluation Aging Effect Aging Management NUREG Component Intended Material Environment Requiring Programs -1801 Table I Notes Type Function Management Volume 2 Item Line Item Carbon Steel, Non-Safety Carbon Air/Gas Loss of material Primary Containment lII.B1.1.1-a 3.5.1-12, [D Cj Low Alloy Support steel Corrosion In-Service Inspection 3.5.1-14 566 Steel In Safety Program Air/Gas Related (Structural Support Steel Inside Torus, i.e.Torus Internal Catwalk, etc.)Page 72 of 149 ENCLOSURE 1 LRA Section 3.6 -Aging Management of Electrical and Instrumentation and Controls 3.6.2.1.1 Electrical Penetrations Commodity Group BACKGROUND (B2.1 .6-1 a)NMC will implement a program at MNGP which is consistent with the NUREG-1 801, Revision 1, XI.E6, "Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements" program. The details of this program will be consistent with the program description and the ten elements described in the NUREG-1801, Revision 1, XI.E6 program.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough) 3.6 Aging Management of Electrical and Instrumentation and Controls 3.6.2.1.1 Electrical Penetrations Commodity Group Aging Management Programs The following aging management programs manage the aging effects for the Electrical Penetrations Commodity Group components:

• Electrical Cables & Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program* Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits* [Electrical Cable Connections Not Subject To 10 CFR 50.49 Environmental Qualification Requirements]

3.6.2.1.3 Non-EQ Cables and Connections Commodity Group Aging Management Programs The following aging management programs manage the aging effects for the Non-EQ Cables and Connections Commodity Group components:

• Electrical Cables & Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program* Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits* Inaccessible Medium Voltage (2kV to 34.5kV) Cables Not Subject to 10 CFR 50.49 EQ Requirements

• [Electrical Cable Connections Not Subject To 10 CFR 50.49 Environmental Qualification Requirements]

Page 73 of 149 ENCLOSURE 1 3.6.2.1.4 Off Site Power/SBO Recovery Path Commodity Group Aging Management Programs The following aging management programs manage the aging effects for the Off Site Power/SBO Recovery Path Commodity Group components:

• Electrical Cables & Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program* Bus Duct Inspection Program* Inaccessible Medium Voltage (2kV to 34.5kV) Cables Not Subject to 10 CFR 50.49 EQ Requirements

• [Electrical Cable Connections Not Subject To 10 CFR 50.49 Environmental Qualification Requirements]

Table 3.6.2-3 Electrical Components

-Non-EQ Cables and Connections Commodity Group -Summary of Aging Management Evaluation NUJREG-Aging Effect Aging 1801 Component Intended Requiring Management Volume 2 Table I Type Function Material Environment Management Programs Line Item Item Notes Electrical Provide Various Adverse Embrittlement, Electrical Cables VM.A.1-a 3.6.1-02 A cables and electrical organic localized cracking, & Connections connections connections polymers environment melting, Not Subject to not subject to specified caused by heat, discoloration, 10 CFR 50.49 to 10 CFR sections of radiation, or swelling, or loss Environmental 50.49 EQ an electrical moisture in the of dielectric Qualification requirements circuit to presence of strength Requirements deliver oxygen leading to Program voltage, reduced current, or Insulation signals. resistance, electrical failure Various Adverse [None [None Electrical J, 609 metals localized Loosening of Cable environment connection]

Connections caused by Not Subject to thermal cyciing, 10 CFR 50.49 ohmic heating, Environmental electrical Qualification transients, Requirements]

vibration, chemical contamination, corrosion, and oxidation.

Page 74 of 149 ENCLOSURE 1 Table 3.6.24 Electrical Components

-Off Site PowerISBO Recovery Path Commodity Group -Summary of Aging Management Evaluation NUREG-Aging Effect Aging 1801 Component Intended Requiring Management Volume 2 Table 1 Type Function Material Environment Management Programs Line Item Item Notes Electrical Provide Various Adverse Embrittlement, Electrical Cables VI.A.1-a 3.6.1-02 A cables and electrical organic localized cracking, & Connections connections connections polymers environment melting, Not Subject to not subject to specified caused by discoloration, 10 CFR 50.49 to 10 CFR sections of heat, and swelling, or loss Environmental 50.49 EQ an electrical radiation in the of dielectric Qualification requirements circuit to presence of strength Requirements deliver oxygen leading to Program voltage, reduced current, or insulation signals. resistance, electrical failure Various Adverse [Nene [None Electrical J. 609 metals localized Loosening of Cable environment connection]

Connections caused by Not Subject to thermal cyciing, 10 CFR 50.49 ohmic heating, Environmental electrical Qualification transients, Requirements]

vibration, chemical contamination, corrosion, and oxidation.

Notes for Tables 3.6.2-1 through 3.6.2-4 Plant-specific notes: 609 As supported by the DOE Cable AMG (SAND96-0344) and MNGP operating experience, the likelihood of substantially increased effects or failure rates resulting from the aging mechanisms of thermal cycling, ohmic heating, electrical transients, mechanical stress (vibration), chemical contamination, corrosion, oxidation, and cable subject to frequent manipulation (at connections and terminal blocks) as applied to the metallic components of electrical cables and connections is considered low. [Therefore, the aboey listed mFchanisms arc not considered aging cffcctz requiring managemcnt.

Page 75 of 149'.

ENCLOSURE 1 LRA Section 4.0 -TIME-LIMITED AGING ANALYSES 4.2 Neutron Embrittlement of the Reactor Pressure Vessel and Internals BACKGROUND (4.2.3)During discussions with the NRC staff, NMC has determined that LRA Sections 4.2.3 and 4.2.4 are revised to state the appropriate 1 0 CFR 54.21 subsection.

10 CFR 54.21 (c)(1 )(i), is changed to 10 CFR 54.21 (c)(1 )(ii).DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough) 4.2.3 Reflood Thermal Shock Analysis of the RPV Disposition:

Validation, 10 CFR 54.21(c)(1)

[(@ (ii)]The current analysis (Reference

7) assumes end-of-life material toughness, which in turn depends on end-of-life ART. The critical location for fracture mechanics analysis is at 1/4 of the vessel thickness (from the inside, 1/4T). For this event, the peak stress intensity occurs at approximately 300 seconds after the LOCA....4.2.4 Reflood Thermal Shock Analysis of the RPV Core Shroud Disposition:

Validation, 10 CFR 54.21(c)(1)

[(@ (ii)]As discussed above, core shroud components were evaluated for a reflood thermal shock event, considering the embrittlement effects of lifetime radiation exposure.

The analysis includes the most irradiated point on the inner surface of the shroud where the calculated value of fluence for 40-year operating period is below the threshold (3.0 x 1020 n/cm 2) for material property changes due to irradiation.

However, using the approved fluence methodology discussed in Section 4.2.2, the 54 EFPY fluence at the most irradiated point on the core shroud was calculated to be 3.84 x 1021 n/cm 2.Page 76 of 149 ENCLOSURE I LRA Section 4.0 -TIME-LIMITED AGING ANALYSES 4.4 Irradiation Assisted Stress Corrosion Cracking (IASCC)BACKGROUND (B2.1 .12-06)In respons6 to the NRC Staffs request concerning the need to augment the Top Guide inspections NMC has determined that top guide grid inspections, of the high fluence locations, are prudent for the license renewal period of extended operation.

This determination was reached in consideration of the NRC Staffs current position with respect to the conclusions contained in BWRVIP-26, "BWR Top Guide Inspection and Flaw Evaluation Guidelines." It is worthy to note, however, that MNGP has performed an inspection of the high fluence areas. These inspections were performed on approximately a twenty-five percent sampling of the high fluence locations of the top guide grid. Fifteen (15) cells were inspected and no evidence of cracking was noted.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough) 4.4 Irradiation Assisted Stress Corrosion Cracking (IASCC)Disposition:

Aging Management, 10 CFR 54.21(c)(1)(iii)

The top guide, shroud, and incore instrumentation dry tubes and guide tubes are susceptible to IASCC. The aging effect associated with IASCC (crack initiation and growth) will require aging management.

All three components (top guide, shroud, and incore instrumentation dry tubes and guide tubes) have been evaluated by the BWRVIP, as described in the Inspection and Evaluation Guidelines for each component:

BWRVIP-26 (Top Guide), BWRVIP-76 (Shroud), and BWRVIP-47 (incore instrumentation dry tubes and guide tubes). BWRVIP recommendations are implemented at M NGP by the Water Chemistry and the In-Service Inspection Programs.[NMC will perform top guide grid inspections, during the period of extended operation, using the EVT-1 method of examination, for the high fluence locations (grid beam and beam-to-beam crevice slot locations with fluence exceeding 5.0 x 1020 nlcm 2). Ten percent (10%) of the total population will be inspected within 12 years with a minimum of 5% inspected within the first 6 years.NMC has inspected the in-core monitoring dry tubes on an every-other refueling outage periodicity and will continue to perform this inspection during the period of extended operation, per the guidance provided in GE SIL- 409.]Page 77 of 149 ENCLOSURE I LRA Section 4.0 -TIME-LIMITED AGING ANALYSES 4.5 Effects of Reactor Coolant Environment BACKGROUND (4.5-01)Recently, industry implementation of Fen temperature input parameter (T) has been questioned for carbon and low-alloy steel locations.

Specifically, it has been noted that the service temperature as opposed to 25C which is required for a fatigue life correction factor that is defined relative to air (e.g., the "0.00124T" term in equations 6.5a and 6.5b of NUREG/CR-6583) has been used. We have completed a review of calculations that support the LRA, found that this error is applicable to MNGP and revised the calculations accordingly.

All affected locations continue to meet acceptance criteria for fatigue. The following revised environmental fatigue usages are provided.

For comparison, original values reported in LRA Section 4.5 are also included.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough) 4.5 Effects of Reactor Coolant Environment Analysis For each location, detailed environmental fatigue calculations have been performed using Fen relationships for carbon and low-alloy steel locations (NUREG/CR-6583) and stainless steel locations (NUREG/CR-5704).

The calculations incorporate Fen methodology to determine a multiplier on the cumulative usage factor (CUF) so that e nvironmental effects can be assessed.

As can be seen in the following table, all locations are acceptable through the extended term of operation due to the fact that all CUF's remain below the acceptance criteria of 1.0.Usage Factor Location Component Material (60 year Uenv)Reactor Vessel Shell Carbon Steel [G.W9 0.748]Feedwater Nozzle Safe End Carbon steel [098 0.872']Recirculation Inlet Safe End Stainless Steel 0.749 Nozzle Core Spray Nozzle Safe End Carbon Steel [9494 0.268]Recirculation.

Piping RHR Tee Stainless Steel 0.864 Feedwater Piping FWTR/RCIC Tee Carbon Steel [0.653 0.673][Note: 1. Reduction due to removal in conservative treatment of T* in calculation of Fen (originally 549 "F as opposed to transient maximum of 391 6F).]Page 78 of 149 ENCLOSURE I LRA Section 4.0 -TIME-LIMITED AGING ANALYSES 4.7 Environmental Qualification of Electrical Equipment (EQ)BACKGROUND (4.7-1)Following discussions with the NRC staff, NMC expanded Section 4.7 of the MNGP application as described below: DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough) 4.7 Environmental Qualification of Electrical Equipment (EQ)Analysis* Analytical Methods -The MNGP EQ Program generally uses the same analytical models in the reanalysis of an aging evaluation as those previously applied for the current evaluation.

The Arrhenius methodology is used for performing thermal aging evaluation.

[MNGP has implemented temperature monitoring by using temperature recorders in areas of the plant in which EQ equipment is located. The plant's GOTHIC model provides temperature and pressure input for accident scenarios.]

The analytical method used for a radiation aging evaluation is to demonstrate qualification for the total integrated dose (that is, normal radiation dose for the projected installed life plus accident radiation dose). For license renewal, MNGP established the 60 year normal radiation dose by multiplying the 40 year normal radiation dose by 1.5 or used the actual calculated value for 60 years. That result is added to the accident radiation dose to obtain the total integrated dose for the component.

In some cases, the normal radiation dose is insignificant when compared to the accident dose. In such cases the total integrated dose may be valid for both the 40 year and 60 year dose. [For cyclical aging, the 40 year value was multiplied by 1.5 to obtain the 60 year value or an estimated 60 year value was used.]* Data Collection and Reduction Methods -Reducing excess conservatism in the component service conditions (for example, temperature, radiation, cycles) used in the prior aging evaluation is the primary method used for a reanalysis per the EQ Program.Temperature data used in aging evaluations is typically conservative and based on plant design temperature.

Actual plant temperature data is obtained in several ways including monitors used for technical specification compliance, other installed monitors, measurements made by plant operators during rounds, temperature sensors on large motors (while the motor is not running) [and the newly implemented temperature monitoring devices installed in areas where EQ equipment is located.]

A representative number of temperature measurements are conservatively evaluated to establish the temperature used in an aging evaluation.

Plant temperature data may be used in an aging evaluation in different ways, such as (a) directly applying the plant temperature data in the evaluation or (b) using the plant temperature data to demonstrate conservatism when using plant design temperatures for an evaluation.

Any Page 79 of 149 ENCLOSURE 1 changes to the material activation energy values as part of a reanalysis are justified on a plant specific basis. Similar methods of reducing excess conservatism in the component service conditions used in prior aging evaluations are used for radiation and cyclical aging. [Radiation surveys are routinely monitored and incorporated into EQ bases calculations on an as needed basis.]* Underlying Assumptions

-EQ component aging evaluations contain sufficient conservatism to account for most environmental changes occurring due to plant modifications and events. When unexpected adverse conditions are identified during operational or maintenance activities that affect the normal operating environment of a qualified component, the affected EQ component is evaluated and appropriate corrective actions are taken, which may include changes to the qualification bases and conclusions.

• Acceptance Criteria and Corrective Action -The reanalysis of an aging evaluation can extend the qualification of the component.

If the qualification cannot be extended by reanalysis, the component is maintained, replaced, or re-qualified prior to exceeding the period for which the current qualification remains valid. A reanalysis is performed in a timely manner (that is, sufficient time is available to maintain, replace, or re -qualify the component if the reanalysis is unsuccessful).

[Parameters (temperature, radiation, pressure, cycles, etc.) evaluated and found to be outside the current bases are documented in the Corrective Action Program, per 10 CFR 50 Appendix B requirements.

Corrective actions are then implemented to bring the calculation or associated equipment up to current requirements.]

Page 80 of 149 ENCLOSURE 1 LRA Section A2 -PROGRAMS THAT MANAGE THE EFFECTS OF AGING A2.1 Aging Management Programs BACKGROUND (2.1-02(a))

The Buried Piping and Tanks Inspection Program is used to manage the aging effects for these new in-scope buried components.

The following clarifications were made to LRA Section A2.1.5 The program is updated to reflect that it will be used to manage stainless steel for loss of material due to crevice corrosion, microbiologically influenced corrosion (MIC) and pitting corrosion.

DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

A2.1.5 Buried Piping & Tanks Inspection The buried piping and tanks inspection program consists of preventive and condition monitoring measures to manage the aging effects for buried piping, conduit and tanks in scope for license renewal. Buried components in scope for license renewal include carbon steel piping, bolting, conduit and tanks (loss of material due to general, crevice, galvanic, MIC and pitting corrosion)

[,stainless steel (loss of material due to crevice, MIC and pitting corrosion)]

and cast iron piping (loss of material due to general, crevice, galvanic, MIC and pitting corrosion and selective leaching).

Preventive measures consist of protective coatings and/or wraps on buried components.

Condition monitoring consists of periodic inspections of buried components.

In addition, buried components are not routinely uncovered during maintenance activities.

Therefore, other system monitoring and functional testing activities are relied upon to provide effective degradation aging management of buried piping and tanks. Some of these activities are neither preventive nor mitigative in nature, but they do provide indication of a leak. However, the potential problem is detected at an early stage, i.e. small leak, such that repairs can be made prior to loss of component intended function.Page 81 of 149 ENCLOSURE 1 LRA Section A2 -PROGRAMS THAT MANAGE THE EFFECTS OF AGING A2.1 Aging Management Programs BACKGROUND (B2.1 .2-15)As discussed in NMC letter to NRC, "Documentation of Responses to Aging Management Program and Aging Management Review Audits for the Monticello License Renewal Application (TAC No. MC6440)," dated August 11, 2005, Appendix A, Section A2.1, Aging Management Programs, has been revised as fallows: DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

A2.1.9 BWR Penetrations The MNGP BWR Penetrations Program is part of the MNGP AS ME Section Xi In-Service Inspection Program. The BWR Penetrations Program is in accordance with ASME Section Xi 1995 Edition through the 1996 Addenda [(with approved ISI Relief Requests)]

and provides for condition monitoring of the BWR penetrations.

A2.1.10 BWR Stress Corrosion Cracking The Monticello Nuclear Generating Plant BWR Stress Corrosion Cracking Program is an existing program and is part of the MNGP ASME Section XI In-Service Inspection Program. ASME Section XI is being implemented with ultrasonic (UT) volumetric, surface, and visual inspections

[and the Risk Informcd ISI Program].

NUREG-0313, Technical Report on Material Selection and Processing Guidelines for BWR Coolant Pressure Boundary Piping, and Nuclear Regulatory Commission (NRC) Generic Letter (GL) 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping, and its Supplement 1 are part of the MNGP BWR Stress Corrosion Cracking Program. All IGSCC susceptible materials have been replaced or protected with a cladding of resistant weld material.A2.1.11 BWR Vessel ID Attachment Welds The MNGP BWR Vessel ID Attachment Welds Program is part of the MNGP ASME Section Xl In-Service Inspection Aging Management Program. The BWR Vessel ID Attachment Weld Program is in accordance with ASME Section XI 1995 Edition through the 1996 Addenda [and approved ISI Rclief Rcqucsts].

The program provides for condition monitoring of the BWR vessel ID attachment welds. The program includes inspection and flaw evaluation in accordance with BWRVIP-48, Vessel ID Attachment Weld and Inspection and Flaw Guidelines (EPRI TR-108724).

Page 82 of 149 ENCLOSURE 1 A2.1.12 BWR Vessel Internals The MNGP BWR Vessel Internals Program is part of the MNGP ASME Section Xl In-Service Inspection Program. The BWR Vessel Internals Program is in accordance with ASME Section Xl 1995 Edition through the 1996 Addenda [and approved ISI Rclief Requests].

The program provides for condition monitoring of the BWR vessel internals for crack initiation and growth....

Commitments Prior to the period of extended operation, the repair/replacement guidelines in BWRVIP-16, 19, 44, 45, 50, 51, 52, 57, and 58 will be added, as applicable, to the MNGP BWR Vessel Internals Program.During the period of extended operation, NMC will perform top guide grid inspections using the EVT-1 method of examination, for the high fluence locations (grid beam and beam-to-beam crevice slot locations with fluence exceeding 5.0 x 1020 n/cm2). Ten percent (10%) of the total population will be inspected within 12 years with a minimum of 5% inspected within the first 6 years.[NMC has inspected the in-core monitoring dry tubes on an every-other refueling outage periodicity and will continue to perform this inspection during the period of extended operation, per the guidance provided in GE SIL- 409.The NMC is an active member of the BWRVIP and will continue to follow applicable inspection guidelines and recommendations, which have been reviewed and approved by the executive committee of the BWRVIP, throughout the period of extended operation for MNGP.NMC will follow the guidance provided in BWRVIP -1 39, Steam Dryer Inspection and Flaw Evaluation Guidelines (April 2005), for the MNGP steam dryer inspections.

NMC will add inspection requirements for the P1, P2, and P3 welds, at MNGP, in accordance with guidance provided in BWRVIP-18, or subsequent revisions.]

Page 83 of 149 ENCLOSURE 1 LRA Section A2 -PROGRAMS THAT MANAGE THE EFFECTS OF AGING A2.1 Aging Management Programs BACKGROUND (A2.1.13-01)

During review of the LRA by NMC it was discovered that on pages A-8 and A-9, EPRI document "TR-1 007820" is incorrectly described as "TR-1 008720." These pages are corrected as described below.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

LRA Pages A-8 and A-9 A2.1.13 Closed-Cycle Cooling Water System Corrosion inhibitor concentrations are maintained within limits based on a combination of EPRI TR-[4008720 1007820] guidelines, vendor recommendations, and plant experience.

System and component performance test results are evaluated in accordance with the guidelines of EPRI TR-[400872,0 1007820] and used as a basis for evaluating the effectiveness of actions to mitigate cracking, corrosion, and heat exchanger fouling.Acceptance criteria and tolerances are also based on system design parameters and functions.

For chemical parameters monitored, many are based on ranges identical to or more restrictive than noted in both EPRI TR-[4008720 1007820] and EPRI TR-107396.

Others are based on vendor recommendations and plant experience.

Frequency of performance and functional tests are consistent with EPRI TR-[4008720 1007820] and are based on plant operating experience, trends and equipment performance.

System and component operability tests are typically performed on a more frequent basis than once per cycle whereas more intrusive inspections (disassembly, eddy current testing, etc.) are performed less frequently but at sufficient intervals to detect the impact of aging effects on component function.Page 84 of 149 ENCLOSURE 1 LRA Section A2 -PROGRAMS THAT MANAGE THE EFFECTS OF AGING A2.1 Aging Management Programs BACKGROUND (B3.2-04A)

For 2006 LRA Supplement, augment Appendices A & B with descriptions of commitments to enhance supporting programs.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

A2.1.19 Flow-Accelerated Corrosion The MNGP Flow-Accelerated Corrosion Program includes the response made to GL 89-08, Erosion/Corrosion Induced Pipe Wall Thinning.[The NMC Fleet Procedure for the Flow Accelerated Corrosion Inspection Program will be revised to include the accepted 87.5% of nominal pipe wall thickness for non-safety related piping as a trigger point for engineering analysis.]

Page 85 of 149 ENCLOSURE I LRA Section A2 -PROGRAMS THAT MANAGE THE EFFECTS OF AGING A2.1 Aging Management Programs BACKGROUND (B3.2-04A)

For 2006 LRA Supplement, augment Appendices A & B with descriptions of commitments to enhance supporting programs.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

A2.1.27 Protective Coating Monitoring

& Maintenance Program Description Commitments Prior to the period of extended operation, the MNGP Protective Coating Maintenance and Monitoring Program: 1) Procedures will be updated to include Inspection of all accessible painted surfaces inside containment;

2) Will be revised to include a pre-inspection review of the previous two inspection reports so that trends can be identified;

[and]3) Implementation procedures will be revised to include provisions for analysis of suspected reasons for coating failure[.

and 4) The MNGP Protective Coating Maintenance and Monitoring Program will be revised to include the requirement that personnel performing the inspection shall meet the requirements of ANSI N45.2.6.]Page 86 of 149 ENCLOSURE I LRA Section A2 -PROGRAMS THAT MANAGE THE EFFECTS OF AGING A2.1 Aging Management Programs BACKGROUND (3.6-2a)During discussions with the NRC staff, NMC determined that the MNGP LRA should include a program which is consistent with the NUREG-1801, Revision 1, Xl.E6, "Electrical Cable Connections Not subject to 10 CFR 50.49 Environmental Qualification Requirements." This program has been added to the LRA as follows

DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

[A2.1.34 Electrical Cable Connections Not subject to 10 CFR 50.49 Environmental Qualification Requirements Cable connections are used to connect cable conductors to other cables or electrical devices. Connections associated with cables within the scope of license renewal are part of this program. The most common types of connections used in nuclear power plants are splices (butt or bolted), crimp-type ring lugs, connectors, and terminal blocks. Most connections involve insulating material and metallic parts. This aging management program for electrical cable connections (metallic parts) account for the following aging stressors:

thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation.

GALL XI.EI, "Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements," manages the aging of insulating material but not the metallic parts of the electrical connections.

GALL Xl.E1 is based on only a visual inspection of accessible cables and connections.

Visual inspection is not sufficient to detect the aging effects from thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation on the metallic parts of cable connections.

Circuits exposed to appreciable ohmic or ambient heating during operation may experience loosening related to repeated cycling of connected loads or of the ambient temperature environment.

Different materials used in various cable system components can produce situations where stresses existing between these components change with repeated thermal cycling. For example, under loaded conditions, appreciable ohmic heating may raise the temperature of a compression termination and cable conductor well above the ambient temperature, thereby causing thermal expansion of both components.

Different thermal expansion coefficients may alter mechanical stresses between the components so that the termination may tighten on the conductor.

When the load or current is reduced, the affected components cool and contract.

Repeated cycling in this fashion can produce loosening of the termination under ambient Page 87 of 149 ENCLOSURE I conditions, and may lead to high electrical resistance joints or eventual separation to compression-type terminations.

Threaded connectors, splices, and terminal blocks may loosen if subjected to significant thermally induced stress and cycling.Cable connections within the scope of license renewal are tested to provide an indication of the integrity of the cable connections.

The specific type of test performed will be determined prior to the initial test, and will be a proven test for detecting loose connections, such as thermography, contact resistance testing, or other appropriate testing.This program, as described, can be thought of as a sampling program. The following factors are considered for sampling:

application (high, medium and low voltage), circuit loading, and location (high temperature, high humidity, vibration, etc.). The technical basis for the sample selections is documented.

If an unacceptable condition or situation is identified in the selected sample, a determination is made as to whether the same condition or situation is applicable to other connections not tested.SAND 96-0344, "Aging Management Guidelines for Electrical Cable and Terminations," indicated loose terminations were identified by several plants. The major concern is that failures of a deteriorated cable system (cables, connections including fuse holders, and penetrations) might be induced during accident conditions.

Since the connections are not subject to the environmental qualification requirements of 10 CFR 50.49, an aging management program is required to manage the aging effects. This program will ensure that electrical cable connections will perform their intended function for the period of extended operation.]

Page 88 of 149 ENCLOSURE I LRA Section A4 -TLAA SUPPORTING ACTIVITIES A4.2 Metal Fatigue of Reactor Coolant Pressure Boundary BACKGROUND (B3.2-04)A revised USAR Supplement, transmitted by NMC letter No. L-MT-05-052 on June 10, 2005, was in response to an NRC Staff request. This RAI requested a list of commitments that were provided in the LRA transmittal letter as well as a schedule for implementation.

The MNGP response specifically addressed Appendix A Section A2 AMPs only. In retrospect, inclusion of commitments from TLAA supporting activities (Section A4) would have provided a more comprehensive reply to the RAI. The LRA has been amended to include the following addition: DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

A4.2 Metal Fatigue of Reactor Coolant Pressure Boundary The MNGP Metal Fatigue of the Reactor Coolant Pressure Boundary aging management program is part of the MNGP Thermal Fatigue Monitoring Program. The MNGP Thermal Fatigue Monitoring Program provides for the periodic review of plant transients for impact on selected components.

In addition, MNGP has evaluated environmental effects in accordance with NUREG/CR-6260, "Application of NUREG/CR-5999 Interim Fatigue Curves for Selected Nuclear Power Plant Components." Selected components were evaluated using material specific guidance presented in NUREG/CR-6583 for carbon and low alloy steels and in NUREG/CR-5704 for austenitic stainless steels. The MNGP program ensures that limiting components remain within the acceptance criteria for cumulative fatigue usage throughout the licensed term and, that if trends indicate otherwise, appropriate corrective action can be implemented.

[NMC will also incorporate requirements for inclusion of NUREG/CR-6260 locations in implementing procedures for the MNGP Thermal Fatigue Monitoring Program.]Page 89 of 149 ENCLOSURE 1 LRA Section A.5 -COMMITMENTS BACKGROUND (A2.1-1)NMC letter of June 10, 2005, provided a revised Appendix A to the LRA. The revision added a new Section A.5, "Commitments," that provided a table summarizing the actions committed to by NMC in the LRA for the MNGP. This table is updated as follows: DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

A r%CnARMITMfi:KTQ ITEM COMMITMENT SOURCE SCHEDULE 52. Incorporate requirements for inclusion of NUREG/CR-6260 LRA Section Prior to Period locations in implementing procedures for the MNGP B3.2 [and LRA of Extended Thermal Fatigue Monitoring Program. Section A4.2] Operation[53. The NMC Fleet Procedure for the Flow Accelerated LRA Sections Prior to Period Corrosion Inspection Program will be revised to include A2.1.19 and of Extended the accepted 87.5% of nominal pipe wall thickness for B2.1.19 Operation]

non-safety related piping as a trigger point for engineering analysis.[54. Prior to the period of extended operation, coating LRA Section Prior to Period inspectors will meet the requirements of ANSI N45.2.6. A2.1.27 and of Extended B2.1.27 Operation]

[55. NMC will implement a program at MNGP which is LRA Sections Prior to Period consistent with the NUREG-1801, Rev. 1, XI.E6 3.6, A2.1.34 of Extended"Electrical Cable Connections Not subject to 10 CFR and B2.1.34 Operation]

50.49 Environmental Qualification Requirements."[56. NMC has inspected the in-core monitoring dry tubes on LRA Sections During the Period an every-other refueling outage periodicity and will 4.4, A2.1.12 of Extended continue to perform this inspection during the period of and B2.1.12 Operation]

extended operation, per the guidance provided in GE SIL- 409.[57. The NMC is an active member of the BWRVIP and will LRA Section During the.Period continue to follow applicable inspection guidelines and B1.6, A2.1.12. of Extended recommendations, which have been reviewed and and B2.1.12 Operation]

approved by the executive committee of the BWRVIP, throughout the period of extended operation for MNGP.[58. NMC will follow the guidance provided in BWRVIP-139, LRA Section During the Period Steam Dryer Inspection and Flaw Evaluation Guidelines 2.1.4.2.2, Table of Extended (April 2005), for the MNGP steam dryer inspections.

3.1.2-3 Note Operation]

136, A2.1.12 and B2.1.12 Page 90 of 149 ENCLOSURE 1[59. NMC will add inspection requirements for the P1, P2, LRA Section Prior to the Period and P3 Core Spray piping welds, at MNGP, in B1.6, A2.1.12 of Extended accordance with guidance provided in BWRVIP-18, or and B2.1.12 Operation]

subsequent revisions.

Page 91 of 149 ENCLOSURE 1 LRA APPENDIX B -Aging Management Programs B1.3 Quality Assurance Program and Administrative Controls BACKGROUND (B1 .3-01)The LRA has been revised to reference the new NMC Quality Assurance Topical Report (QATR), implemented in September, 2005 which replaces the previously referenced Xcel Energy, Inc., Operational Quality Assurance Plan (OQAP).DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B1.3 Quality Assurance Program and Administrative Controls The elements of corrective action, confirmation process, and administrative controls in the Quality Assurance Program will be applicable to safety related and non-safety related systems, structures, and components subject to an AMR consistent with the summary in Appendix A.2 of NUREG-1 800.These three elements will be applicable as follows: Corrective Actions MNGP has a single corrective action process regardless of the safety classification of the structure or component.

The corrective action process includes the work control process.Corrective action requirements are established in accordance with the requirements of 10 CFR 50, Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" (Reference 4). Implementation is further described in the [Operational NMC-1 "Quality Assurance Topical Report" Plaff-(XeeI Energy, Inc.)]. This plan is applicable to MNGP.The corrective action process at MNGP is implemented via [Fleet procedures and]site-specific administrative work instructions.

These [*M] procedures require the initiation of an Action Request (AR) for actual or potential problems, including failures, malfunctions, discrepancies, deviations, defective material and equipment, nonconformances, and administrative control discrepancies.

Equipment deficiencies are corrected through the initiation of a Work Order (WO) in accordance with plant procedures.

Although a WO may initially document equipment deficiencies, the corrective action process specifies that an AR also be initiated as discussed above.[NMC Fleet Procedures and] MNGP site-specific administrative work instructions will be applicable to both safety and non-safety related systems, structures and components that are subject to an aging management review consistent with the current licensing basis during the period of extended operation.

Page 92 of 149 ENCLOSURE 1 Confirmation Process The confirmation process is part of the corrective action program (described above). The focus of the confirmation process is on the follow-up actions that must be taken to verify effective implementation of corrective actions. The measure of effectiveness is in terms of correcting the adverse condition and precluding repetition of significant conditions adverse to quality. Plant procedures include provisions for timely evaluation of adverse conditions and implementation of any corrective actions required, including root cause determinations and prevention of recurrence where appropriate (e.g., significant conditions adverse to quality).

These procedures provide for tracking, coordinating, monitoring, reviewing, verifying, validating, and approving corrective actions, to ensure effective corrective actions are taken. The AR process is also monitored for potentially adverse trends. The existence of an adverse trend due to recurring or repetitive adverse conditions would result in the initiation of an AR. The aging management activities required for license renewal would also uncover any unsatisfactory condition due to ineffective corrective action.Since the same 10 CFR 50, Appendix B corrective actions and confirmation process is applied for nonconforming safety related and non-safety related structures and components subject to an AMR for license renewal, the MNGP corrective action program is currently consistent with these NUREG-1 801 and NUREG-1 800 elements.Site documents that implement aging management activities for license renewal will be enhanced to ensure that an Action Request is prepared in accordance with [Fleet and] plant procedures whenever non-conforming conditions are found (i.e., the acceptance criteria is not met).Administrative Controls The MNGP document control process applies to all MNGP generated documents, procedures, and instructions regardless of safety classification of the associated structure or component.

Document Control processes are implemented in accordance with the requirements of 10 CFR 50, Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants." Implementation is further defined in the [Gperatienal NMC-1 "Quality Assurance Topical Report" (QATR) Plan, (Xccl Encrgy, Inc.)] Section 8.0,'Document Control." The [Operatienal Quality Assuranec Plan QATR] is applicable to MNGP and the MNGP administrative work instructions.

The document control requirements will apply to aging management programs.Enhancements to license renewal related procedures and other document types will be made to include a purpose section discussing management of the effects of aging for structures, systems, and components within the scope of license renewal with applicable references.

Page 93 of 149 ENCLOSURE I LRA APPENDIX B -Aging Management Programs B1.6 BWRVIP Applicant Action Items BACKGROUND (Rill-B2.1

.12-4)The NMC is an active member of the BWRVIP and will continue to follow applicable inspection guidelines and recommendations, which have been reviewed and approved by the executive committee of the BWRVIP, throughout the period of extended operation for MNGP. This commitment is added to the MNGP LRA.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B13.6 BWRVIP Applicant Action Items[The NMC is an active member of the BWRVIP and will continue to follow applicable inspection guidelines and recommendations, which have been reviewed and approved by the executive committee of the BWRVIP, throughout the period of extended operation for MNGP.] The aging management programs identified above contain references to applicable Boiling Water Reactor Vessel Internals Project (BWRVIP)documents, several of which have received a License Renewal Safety Evaluation Report (LR SER) from the NRC. Each LR SER contains License Renewal Applicant Action Items (AAls) that are to be addressed in the plant specific LR application.

For MNGP, the following BWRVIP documents contain AAls: Page 94 of 149 ENCLOSURE 1 LRA APPENDIX B -Aging Management Programs B1.6 BWRVIP Applicant Action Items BACKGROUND (Rill-B2.1

.12-2)The installation of the T-box bracket repair to the MNGP core spray spargers was performed in 1994. The guidance provided in BWRVIP-94 (BWR Vessel and Internals Project Program Implementation Guide), Section 2.3 states that "Repairs implemented prior to the issuance of BWRVIP guidelines do not need to be evaluated for compliance with the BWRVIP guidelines." The Core Spray Piping and Sparger Repair Design Criteria (BWRVIP-19) was issued after implementation of the T-box modification.

Consequently, the T-box modification was designed and evaluated in accordance with codes and standards in effect at the time of the repair. However, the NMC will add inspection requirements for the P1, P2, and P3 welds, at MNGP, in accordance with guidance provided in BWRVIP-18, or subsequent revisions, as if no structural repair were installed, to ensure that analysis assumptions remain bounding.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

Table B1.6-11 Responses to BWRVIP-74-A for the MNGP, Table 4-1 Inspection Items BWRVIP-74-A MNGP LRA Reference Table 4-1 Item AMP Description Section / Comments (see notes')core Spray Attachments Section A2.1.11 and Section B2.1.11 / MNGP manages the aging effects of the Core Spray Attachments in accordance with BWRVIP-48 (Vessel ID Attachment Weld Inspection and Flaw Evaluation Guidelines), BWRVIP-18 (Core Spray Internals Inspection and Flaw Evaluation Guidelines) and the ASME Code, Section Xl, Subsection IWB, Table lwB-2500-1.

The P1,2 & 3 welds arc not inspected in accordance with BWRVIP 18 guidance.]

MNGP has installed mechanical clamps to insure the structural integrity of the sparger T-box.MNGP performs a visual inspection each outage to confirm that T-box integrity is maintained.

Page 95 of 149 ENCLOSURE I LRA APPENDIX B -Aging Management Programs B2.1.2 ASME Section Xl In-Service Inspection, Subsections IWB, IWC and IWD BACKGROUND (B2.1.2-15) (B2.1.26-01) (Rill-B2.1.2-01)

NMC letter to NRC, dated August 11, 2005, described changes necessary to the LRA description of the MNGP ASME Section XI, In-Service Inspection, Subsections IWB, IWC, and IWD (NUREG-1 801, XI.M1) Program. Enclosure 1 contained a table of Section XI alternatives used at MNGP along with a discussion of why the alternative was acceptable from an aging management standpoint.

DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.2 ASME Section Xl In-Service Inspection, Subsections IWB, IWC and IWD NUREG-1801 Consistency The Monticello Nuclear Generating Plant ASME Section XI In-Service Inspection, Subsections IWB, IWC, and IWD Program is an existing program. With exceptions, it is consistent with the recommendations of NUREG-1801, Chapter Xl, Program Xl.M1.[Exceptions to ASME Codc requirements that have been granted by approved Code Cases or relief requests, or modifications by 10 CFR 50.55(a) arc not considered to be exoeptiens to NUREG 1801 rite*ia.-]

Exceptions to NUREG-1 801 See the following element discussion(s) on the exceptions to NUREG-1801 aging management program elements: Scope Per 10 CFR 50.55a(b)(2)(xi), the requirements of IWB-1220 in the 1989 Edition of ASME Section XI, "Components Exempt from Examination," are used for Class 1 piping instead of the 1995 Edition of ASME Section Xl with the 1996 Addenda.Per 10 CFR 50.55a(b)(2)(xxi)(B), reused CRD bolting must meet examination requirements for Table IWB-2500-1, Category B-G-2, Item 67.80 of ASME Section Xl 1995 Edition [with 1995 Addenda].[The MNGP Risk Informed Inservice Inspection (RI-ISI) Program for Class 1 and Class 2 piping welds provides an alternative to the ASME Section XI, ISI requirements with regards to (1) the number of locations, (2) the locations of inspections, and (3) the method of inspection.

The RI-ISI program maintains an acceptable level of quality and safety pursuant to IOCFR 50.55a(a)3.

Page 96 of 149 ENCLOSURE 1 Therefore, the aging effect cracking continues to be adequately managed for the piping welds.MNGP performs a surface examination on the reactor pressure vessel stabilizer brackets if local Get reaction forces) or seismic design loads are experienced.

A release from the surface examination should have no effect on aging management of the reactor pressure vessel stabilizer brackets welds.The stabilizers brackets are not subject to general corrosion or stress corrosion cracking, nor are they loaded so they are subject to cumulative fatigue.MNGP uses the 2001 Edition of Section Xl in lieu of the 1995 Edition with the 1996 Addenda for repair/replacement activities.

This alternative has already been generically reviewed and approved by the NRC staff for aging management of systems and components within the scope of license renewal.MNGP uses the ASME Section Xl Code Case N-613-1 in lieu of the ASME Section Xl Table IWB-2500-1 Examination Category B-D, Item No. B3.90 requirements.

This activity alters the examination volume boundary for the reactor vessel pressure retaining nozzle-to-vessel welds; however, the aging effect continues to be managed and inspected.

MNGP utilizes Code Case N-307-2 -Revised Ultrasonic Examination Volume for Class I Bolting, Table IWB-2500-1, Examination Category B-G-1, When the examinations are conducted from the end of the bolt or stud, or from the center-drilled hole.MNGP utilizes Code Case N-526 -Alternative Requirements for Successive Inspections of Class 1 and 2 Vessels when areas of the vessel are found, by volumetric examinations, to contain subsurface flaws. The successive inspections may be waived when the flaw is found to be acceptable for continued service in accordance with IWB-3600.

The vessel aging effects continue to be managed and therefore, there is no impact on aging management of the vessel.]Aging Management Program Elements Scope of Program The following program exceptions to NUREG-1801 regarding scope are being implemented in accordance with 10 CFR 50.55a:* Per 10 CFR 50.55a(b)(2)(xi), the requirements of IWB-1220 in the 1989 Edition of ASME Section Xl, "Components Exempt from Examination," are used for Class 1 piping instead of the 1995 Edition of ASME Section Xl with the 1996 Addenda.* Additionally, per 10 CFR 50.55a(b)(2)(xxi)(B), reused CRD bolting must meet examination requirements for Table IWB-2500-1, Category B-G-2, Item B7.80 of ASME Section Xl 1995 Edition [with 1995 Addenda].* [The MNGP Risk Informed Inservice Inspection (RI-ISI) Program for Class I and Class 2 piping welds provides an alternative to the ASME Section Xl, ISI requirements with regards to (1) the number of locations, (2) the locations of inspections, and (3) the method of inspection.

The RI-ISI Page 97 of 149 ENCLOSURE 1 program maintains an acceptable level of quality and safety pursuant to 1OCFR 50.55a(a)3.

Therefore, the aging effect cracking continues to be adequately managed for the piping welds.* MNGP performs a surface examination on the reactor pressure vessel stabilizer brackets if local get reaction forces) or seismic design loads are experienced.

A release from the surface examination should have no effect on aging management of the reactor pressure vessel stabilizer brackets welds. The stabilizers brackets are not subject to general corrosion or stress corrosion cracking, nor are they loaded so they are subject to cumulative fatigue.* MNGP uses the 2001 Edition of Section Xl in lieu of the 1995 Edition with the 1996 Addenda for repairlreplacement activities.

This alternative has already been generically reviewed and approved by the NRC staff for aging management of systems and components within the scope of license renewal.* MNGP uses the ASME Section Xl Code Case N-613-1 in lieu of the ASME Section Xl Table IWB-2500-1 Examination Category B-D, Item No. B3.90 requirements.

This activity alters the examination volume boundary for the reactor vessel pressure retaining nozzle-to-vessel welds; however, the aging effect continues to be managed and inspected.

• MNGP utilizes Code Case N-307-2 -Revised Ultrasonic Examination Volume for Class I Bolting, Table IWB-2500-1, Examination Category B-G-1, When the examinations are conducted from the end of the bolt or stud, or from the center-drilled hole.* MNGP utilizes Code Case N-526 -Alternative Requirements for Successive Inspections of Class I and 2 Vessels when areas of the vessel are found, by volumetric examinations, to contain subsurface flaws. The successive inspections may be waived when the flaw is found to be acceptable for continued service in accordance with IWB-3600.

The vessel aging effects continue to be managed and therefore, there is no impact on aging management of the vessel.]Corrective Actions For Class 1, 2, and 3, respectively, repair and replacements are in conformance with IWA-4000 [and approved NRC relief requests].

Approved BWRVIP-44 and BWRVIP-45 documents, respectively, provide guidelines for weld repair of nickel alloys and for weldability of irradiated structural components.

Page 98 of 149 ENCLOSURE I LRA APPENDIX B -Aging Management Programs B2.1.3 ASME Section Xi, Subsection IWF BACKGROUND (B2.1 .2-15)NMC letter to NRC, "Documentation of Responses to Aging Management Program and Aging Management Review Audits for the Monticello License Renewal Application (TAC No. MC6440)," dated August 11, 2005, described changes necessary to the LRA description of the MNGP ASME Section Xl, Subsection IWF, (NUREG-1801, XI.S3)Program.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.3 ASME Section Xl, Subsection IWF Program Description The program is updated periodically as required by 10 CFR 50.55a.[Prior to the period of extended operation, the MNGP ASME Section Xl, Subsection IWF Program will be enhanced to provide inspections of Class MC components supports consistent with NUREG-1 801, Chapter III Section B1.3.]NUREG-1801 Consistency The ASME Section Xl, Subsection IWF Program is an existing program. It will be enhanced [, with certain exceptions,]

to be consistent with the NUREG-1 801, Chapter Xl, Program XI.S3 and ASME Section Xl, Subsection IWF.Exceptions to NUREG-1801

[None. MNGP uses Code Case N-491-2 -Rules for Examination of Class 1, 2, 3, and MC Component Supports of Light-Water Cooled Power Plants, Section Xl, Division I which allows for corrective measures to be performed on a component support to return the support to its design condition after acceptance by evaluation or test, without requiring additional examinations.

This alternative involves corrective actions of component supports and has no impact on the aging management of the supports.]

Page 99 of 149 ENCLOSURE 1 LRA APPENDIX B -Aging Management Programs B2.1.4 Bolting Integrity BACKGROUND (B2.1.2-15) (B2.1.4-1 (a))NMC letter to NRC, dated August 11, 2005, described changes necessary to the LRA description of the MNGP Bolting Integrity Program (NUREG-1 801, XI.M18).In addition, subsequent to a phone conversation with the NRC on November 4, 2005, and upon further investigation by NMC, it was determined that closure bolting of the EFT System is included in the Bolting Integrity Program for loss of preload. Section B.2.1.4, Scope of Program, of the LRA for the Bolting Integrity Program is revised to include the EFT System.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.4 Bolting Integrity Program Description The program credits other MNGP Aging Management Programs for the inspection of installed bolts. These other programs are:* 10 CFR 50, Appendix J, ...* System Condition Monitoring, and* Structures Monitoring.

[Prior to the period of extended operation, the guidance for performing visual bolting inspections contained in EPRI TR-104213, Bolted Joint Maintenance

&Application Guide, and the Good Bolting Practices Handbook (EPRI NP-5067 Volumes I and 2) will be included in the Inspection of Overhead Heavy Load and Light Load (Related to Refueling)

Handling Systems Program, Structures Monitoring Program and the System Condition Monitoring Program.]NUREG-1801 Consistency The MNGP Bolting Integrity Program is an existing program. It will be enhanced [, with certain exceptions,]

to be consistent with the recommendations of NUREG-1 801, Chapter Xl, Program XI.M1 8.Exceptions to NUREG-1801

[Nenei MNGP uses the ASME Code 2001 Edition for Repair/ Replacement Program.]Page 100 of 149 ENCLOSURE I Aging Management Program Elements Scope of Program Diesel Fuel Oil Transfer House Miscellaneous SBO Yard Structures Emergency Diesel Generator Building Reactor Head Vent System Emergency Diesel Generators Reactor Pressure Vessel Emergency Filtration Treatment Building Reactor Pressure Vessel Internals[Emergency Filtration Train] Reactor Recirculation Emergency Service Water Reactor Vessel Instrumentation Fire Reactor Water Cleanup Fuel Pool Cooling & Cleanup Residual Heat Removal Hangers and Supports Secondary Containment Heating & Ventilation Service & Seal Water High Pressure Coolant Injection Standby Liquid Control HPCI Building Structures Affecting Safety Instrument and Service Air Turbine Building Intake Structure Turbine Generator System Main Condenser Underground Bus Duct Main Steam Wells and Domestic Water Detection of Aging Effects Inspection of bolting for ASME Section Xl, Class 1, 2, 3, and MC components is performed in accordance with the requirements of American Society of Mechanica I Engineers (ASME) Section Xi, Tables IWB 2500-1, IWC 2500-1, IWD-2500-1, and IWE-2500-1, respectively

[except as allowed by code cases, relief requests, or interpretations].

Requirements of IWF-2500-1 for Class 1, 2, and 3 structural bolting inspections apply in a similar manner. 1W sections for performing inspections are based on the 1995 code edition through the 1996 addenda. The ASME Section Xl program uses three types of examination:

surface, volumetric, and visual. Surface examinations indicate the presence of surface discontinuities and may be conducted by magnetic particle, liquid penetrant, or an Eddy Current test method.Monitoring and Trending The ASME Section Xl examination schedule was developed from ASME Code requirements, [risk informed methodology-]

individual component examination history, and plant scheduling needs such as optimizing insulation removal and scaffolding needs. The examination schedule is submitted to the NRC as part of the In-Service Inspection Examination Plan.Page 101 of 149 ENCLOSURE 1 Corrective Actions Repair and replacement of bolting is performed in accordance with: (1) corrective actions developed through application of the site Corrective Action Program, (2)IWA-4000, and (3) with plant procedures on bolting practices that include consideration of EPRI NP-5067 Volumes 1 and 2 (Good Bolting Practices), EPRI NP-5769, and EPRI TR-104213.

ASME Section Xl repairs and replacements are based on the 2001 Edition of Section Xl [pIr a previously approved ISI Relief Request].Page 102 of 149 ENCLOSURE 1 LRA APPENDIX B -Aging Management Programs B2.1.5 Buried Piping & Tanks Inspection BACKGROUND (2.1.02a)

(3.3.2.3.5-1) and (Rill B2.1.5-01)

During discussions with the NRC staff, NMC determined that the Buried Piping and Tanks Inspection Program will be used to manage the aging effects for the new in-scope buried components and although not specifically stated, credit the Selective Leaching of Materials Program for managing loss of material due to selective leaching.

The following clarifications are made to LRA Section B2.1.5, Buried Piping & Tanks Inspection: (a) The Program Description is updated to reflect that it will be used to manage stainless steel for loss of material due to crevice corrosion, microbiologically influenced corrosion (MIC) and pitting corrosion; (b) The Scope of Program is updated to include the following additional systems; Circulating Water (CWT), Condensate Storage (CST), Heating and Ventilating (HTV) and Service and Seal Water (SSW) and credit the Selective Leaching of Materials Program for managing loss of material due to selective leaching; and (c) An enhancement to the scope of the program is updated to clearly identify buried conduit for loss of material due to corrosion.

DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.5 Buried Piping & Tanks Inspection Program Description The buried piping and tanks inspection program consists of preventive and condition monitoring measures to manage the aging effects for buried pipi ng, conduit and tanks in scope for license renewal. Buried components in scope for license renewal include carbon steel piping, bolting, conduit and tanks (loss of material due to general, crevice, galvanic, MIC and pitting corrosion)

[and,] cast iron piping (loss of material due to general, crevice, galvanic, MIC and pitting corrosion and selective leaching)[and stainless steel (loss of material due to crevice corrosion, MIC and pitting corrosion)].

Preventive measures consist of protective coatings and/or wraps on buried components.

Condition monitoring consists of periodic inspections of buried components.

In addition, buried components are not routinely uncovered during maintenance activities.

Therefore, other system monitoring and functional testing activities are relied upon to provide effective degradation aging management of buried piping and tanks. Some of these activities are neither preventive nor mitigative in nature, but they do provide indication of a leak. However, the potential problem is detected at an early stage, i.e. small leak, such that repairs can be made prior to loss of component intended function.[Prior to the period of extended operation:

Page 103 of 149 ENCLOSURE 1 1) The Buried Piping and Tanks Inspection Program will update the implementing procedures to include inspections of buried components, including conduit, when they are uncovered.

2) The Diesel Fuel Oil Storage Tank, T-44, internal inspection will be added to the list of scheduled inspections in the Buried Piping and Tanks Inspection Program.3) The Buried Piping and Tanks Inspection Program will be revised to include a provision that if evaluations of pipe wall thickness show a susceptibility to corrosion, further evaluation as to the extent of susceptibility will be performed.

4) The Buried Piping and Tanks Inspection Program will be revised to specify a 10-year buried pipe inspection frequency.

5) The Buried Piping and Tanks Inspection Program will be revised to specify a 10-year inspection frequency for Diesel Fuel Oil Storage Tank T-44.6) The Buried Piping and Tanks Inspection Program will be revised to include a review of previous buried piping issues to determine possible susceptible locations.

Enhancements Scope of Program The Buried Piping and Tanks Inspection Program implementing procedures will be updated to include inspections of buried components

[, including conduitj when they are uncovered.

Aging Management Program Elements Scope of Program Since buried components are not routinely uncovered, internal tank inspections and several systems monitoring and functional testing activities are relied upon to provide an early warning of leaking such that repairs can be made and loss of component intended function is prevented.

[The Buried Piping and Tanks Inspection Program also provides for managing loss of material due to selective leaching by crediting the Selective Leaching of Materials Program.]The Buried Piping and Tanks Inspection Buried Services Monitoring Program manages the aging effects for components in the following systems and structures:

Emergency Service Water Secondary Containment Fire [Circulating Water][Condensate Storage] [Heating and Ventilation]

[Service and Seal Water]Page 104 of 149 ENCLOSURE I LRA APPENDIX B -Aging Management Programs B2.1.6 Bus Duct Inspection Program BACKGROUND (B2.1.6-1, B2.1.6-1a and B2.1.6-2)NMC stated in a December 7, 2005 (ADAMS Accession No. ML0534602420) response to NRC RAI 2.1.6-1, that the "Detection of Aging Effects" program element would be replaced.In an NMC letter dated February 24, 2006, in response to NRC RAI B2.1.6-1, B2.1.6-1a and B2.1.6-2, NMC described the following changes to the MNGP Bus Duct Inspection Program: DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.6 Bus Duct Inspection Program Program Description The primary objective of the aging management program is to provide an inspection of bus ducts. Non-segregated bus duct insulation aging degradation from ingress of moisture or contaminants (dust and debris), or heat or radiation in the presence of oxygen causes insulation surface anomalies.

In managing this aspect of the aging management program, visual inspection of interior portions of bus ducts will be performed to identify aging degradation of insulating and metallic components and water/debris intrusion.

The external portions of bus ducts and structural supports will be inspected in accordance with a plant specific structural monitoring program.Additionally, bus ducts exposed to appreciable ohmic heating during operation may experience loosening of bolted connections.

In managing this aspect of the aging management program, bolted connections at sample sections of the buses in the [metal enclosed bus (MEB) ducts will be checked for preper toque, or loose connections by using thermography or by measuring the bolted joints will b checked to cnsur loew connection resistance using a low range ohmmeter.

As an alternative to thermography or measuring connection resistance of bolted connections, for the accessible bolted connections that are covered with heat shrink tape, sleeving, insulating boots, etc., NMC will use visual inspection of insulation material to detect surface anomalies, such as discoloration, cracking, chipping or surface contamination.]

The purpose of the aging management program is to provide reasonable assurance that the intended functions of nonsegregated bus ducts that are not subject to the environmental qualification requirements of 10 CFR 50.49 and are exposed to adverse localized environments caused by the ingress of moisture, contaminants (dust and debris), insulation degradation caused by heat or radiation in the presence of oxygen, and bolt relaxation caused by thermal cycling will be maintained consistent with the current licensing basis through the period of extended operation.

This program considers the technical information provided in Information Notice No. 89-64.Page 105 of 149 ENCLOSURE I[Prior to the period of extended operation, the Bus Duct Inspection Program will be implemented consistent with the appropriate ten elements described in Appendix A of NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants.]Aging Management Program Elements Detection of Aging Effects[Visual inspcetion of internal portions of bus ducts detects cracks, corrosion, debris, dust and moisture.

Visual inspection of the bus insulating system detects embrittlement, craeking, mElti ng, swellin g and discoloration.

Visual inspectien of bus supports detects cracking and lack of structural integrity.

internal portions of bus ducts, the bus insulating system, and the bus supports arc visually inspected at Icast one. every 10 years.A torque test or a resistancc test of a sample of acecssiblc bolted conncetions is pFe..rmcd at lcast onc cvry 10 yarS. This program will bc complctcd bcforc thc cnd of the initial 40 year licensc term and eyery 10 years thereafter.

This is an adequate period to prcclude failures of the bus ducts sine cxpcricnc.

has shown that aging degradation is a sloW process. A 10 year inspcetion frequency will provide two data points during a 20 year period, which can be used to characterize the ddegiraedn rarte A sample of accessible bolted connections will be checked for loose connection by using thermography or by measuring connection resistance using a low range ohmmeter.

Metal enclosed bus (MEB) internal surfaces will be visually inspected for aging degradation of insulating material and for foreign debris and excessive dust buildup, and evidence of moisture intrusion.

Bus insulation will be visually inspected for signs of embrittlement, cracking, melting, swelling, or discoloration, which may indicate overheating or aging degradation.

Internal bus supports will be visually inspected for structural integrity and signs of cracks. This program will be completed before the period of extended operation and every 10 years thereafter provided visual inspection is not used to check bolted connections.

A 10 year inspection interval will provide two data points during a 20-year period, which can be used to characterize the degradation rate. This is an adequate period to preclude failures of the MEBs since experience has shown that aging degradation is a slow process.As an alternative to thermography or measuring connection resistance of bolted connections, for the accessible bolted connections that are covered with heat shrink tape, sleeving, insulating boots, etc., N MC will use visual inspection of insulation material to detect surface anomalies, such as discoloration, cracking, chipping or surface contamination.

When this alternative visual inspection is used to check bolted connections, the first inspection will be completed before the period of extended operation and every five years thereafter.]

Existing plant preventive maintenance procedures require the bus duct located outside of the Turbine Building (between the Turbine Building wall and the 2R transformer and between the Turbine Building wall and the 1 R transformer) to be inspected.

These inspections require the removal of all outside bus support damage Page 106 of 149 ENCLOSURE 1 and loose connections.

The inspections have a QC witness point to ensure Quality Assurance.

These procedures require a micro-ohm test and a power factor test once maintenance activities have been completed.

These preventive maintenance procedures will be revised to include license renewal requirements.

Acceptance Criteria Bolted connections

[must meet the manufacturcr's minimum torque specificaticns -ef the rFsistance of bolted joints must meet required spceifications need to be below the maximum allowed temperature for the application when thermography is used or a low resistance value appropriate for the application when resistance measurement is used. MEBs Bus duets] are to be free from [unacceptable visual indications of any surface anomalies, which tat] suggest that conductor insulation degradation exists. [In An additional aeeeptanee criterion includes no indication ef unacceptable indication of corrosion, cracking, foreign debris, excessive dust buildup, or evidence of moisture intrusion is to exist. Any condition or situation that, if not corrected, An unacceptable indication is defined as a noted condition or situation that, if left unmanaged,]

could lead to a loss of intended function[.

is eensidered uncceptable.]

[When the visual inspection alternative for bolted connections is used, the absence of discoloration, cracking, chipping or surface contamination will provide positive indication that the bolted connections are not loose.]Corrective Actions[Further investigation and evaluation are performed when the acceptance criteria are not met. Corrective actions may include but are not limited to cleaning, drying, increased inspection frequency, replacement, or repair of the affected metal enclosed bus components.

If an unacceptable condition or situation is identified, a determination is made as to whether the same condition or situation is applicable to other accessible or inaccessible metal enclosed bus.Also refer to Section B1 .3.]Page 107 of 149 ENCLOSURE I LRA APPENDIX B -Aging Management Programs B2.1.7 BWR Control Rod Drive Return Line Nozzle BACKGROUND (B2.1 .2-15)NMC letter to NRC, dated August 11, 2005, described changes necessary to the LRA description of the MNGP BWR Control Rod Drive Return Line Nozzle, (NUREG-1801, XI.M6) Program.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.7 BWR Control Rod Drive Return Line Nozzle Aging Management Program Elements Scope of Program The scope of the MNGP BWR Control Rod Drive Return Line Nozzle Program is part of the MNGP ASME Section Xl In-Service Inspection Program and provides for condition monitoring of the BWR CRDRL nozzle in accordance with ASME Section XI, Table IWB-2500-1, Examination Category B-D.[MNGP uses the ASME Code 2001 Edition for Repair/ Replacement Program.]MNGP cut and capped its CRDRL nozzle in 1977. This modification (and the attendant operational changes) has mitigated the aging effects such that no augmented inspections are required.The BWR Control Rod Drive Return Line Nozzle Program consists of MNGP activities that manage the aging effects for the components in the following systems and structures:

IReactor Pressure Vessel Page 108 of 149 ENCLOSURE 1 LRA APPENDIX B -Aging Management Programs B2.1.8 BWR Feedwater Nozzle BACKGROUND (B2.1.2-15)

NMC letter to NRC, "Documentation of Responses to Aging Management Program and Aging Management Review Audits for the Monticello License Renewal Application (TAC No. MC6440)," dated August 11, 2005, described changes necessary to the LRA description of the MNGP BWR Feedwater Nozzle, (NUREG-1801, XI.M5) Program.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.8 BWR Feedwater Nozzle Program Description The BWR Feedwater Nozzle Program is not currently augmented by the recommendations of General Electric (GE) NE-523-A71-0594, Alternate BWR Feedwater Nozzle Inspection Requirement.

The program will be enhanced by including.the recommendations of the GE NE-523-A71-0594-A, Revision 1.The Program is updated periodically as required by 10 CFR 50.55a.[Prior to the period of extended operation, the BWR Feedwater Nozzle Program will be enhanced so: 1) The parameters monitored and inspected are consistent with the recommendations of GE NE-523-A71-0594-A, Revision 1.2) The regions being inspected, examination techniques, personnel qualifications, and inspection schedule are consistent with the recommendations of GE NE-523-A71-0594-A, Revision 1.3) That inspections will be scheduled per recommendations of GE NE-523-A71-0594-A, Revision 1.]NUREG-1801 Consistency The BWR Feedwater Nozzle Program is an existing program. It will be enhanced [l with certain exceptions,]

to be consistent with the recommendations of NUREG-1 801, Chapter XI, Program XLI.M5, "BWR Feedwater Nozzle." Exceptions to NUREG-1801

[Nloe. MNGP uses the ASME Code 2001 Edition for Repair/ Replacement Program.]Page 109 of 149 ENCLOSURE 1 LRA APPENDIX B -Aging Management Programs B2.1.9 BWR Penetrations BACKGROUND (B2.1 .2-1 5)NMC letter to NRC, dated August 11, 2005, described changes necessary to the LRA description of the MNGP BWR Penetrations, (NUREG-1 801, XI.M9) Program.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.9 BWR Penetrations Program Description The MNGP BWR Penetrations Program is part of the MNGP ASME Section Xi In-Service Inspection Program. The BWR Penetrations Program is in accordance with ASME Section XI 1995 Edition through the 1996 Addenda [(with approv6d IS Relief Requests)]

and provides for condition monitoring of the BWR penetrations.

Exceptions to NUREG-1801 This subsection identifies the elements of the MNGP AMP that are not consistent with the corresponding NUREG-1 801 AMP elements.For further details, see the following element discussion(s) on the exceptions to NUREG -1801 aging management program elements:* [Scope of Program The MNGP Risk Informed Inservice Inspection (RI-ISI) Program for Class I and Class 2 piping welds provides an alternative to the ASME Section Xl, ISI requirements with regards to (1) the number of locations, (2) the locations of inspections, and (3) the method of inspection.

The RI-ISI program maintains an acceptable level of quality and safety pursuant to IOCFR 50.55a(a)3.

Therefore, the aging effect cracking continues to be adequately managed for the piping welds.MNGP uses the ASME Section Xl Code Case N-613-1 in lieu of the ASME Section Xl Table IWB-2500-1 Examination Category B-D, Item No. B3.90 requirements.

This activity alters the examination volume boundary for the reactor vessel pressure retaining nozzle-to-vessel welds; however, the aging effect continues to be managed and inspected.]

Page 1100 of 149 ENCLOSURE I Aging Management Program Elements Detection of Aging Effects The detection of aging effects is prescribed by the MNGP BWR Penetrations Program in accordance with the requirements of ASME Section Xl, Table IWB-2500-1 for Examination Categories

[B-l] B-O, and B-P[, ASME Code Case N-613-1 in lieu of the ASME Section Xl Table IWB-2500-1 for Examination Category B-D, Item B3.90] and NRC approved alternatives for Categories B-F and B-J (Risk-informed ISI (RI-ISI)).

The material susceptible to the aging effect of crack initiation and growth is within the scope of the MNGP BWR Penetrations Program and is being periodically examined using the ultrasonic (UT) volumetric, surface, and visual nondestructive examination methods as applicable.

Page 111 of 149 ENCLOSURE 1 LRA APPENDIX B -Aging Management Programs B2.1.10 BWR Stress Corrosion Cracking BACKGROUND (B2.1 .2-1 5)NMC letter to NRC, "Documentation of Responses to Aging Management Program and Aging Management Review Audits for the Monticello License Renewal Application (TAC No. MC6440)," dated August 11, 2005, described changes necessary to the LRA description of the MNGP BWR Stress Corrosion Cracking, (NUREG-1 801, XI.M7) Program.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.10 BWR Stress Corrosion Cracking Program Description The Monticello Nuclear Generating Plant BWR Stress Corrosion Cracking Program is an existing program and is part of the MNGP ASME Section Xi In-Service Inspection Program. ASME Section XI is being implemented with ultrasonic (UT) volumetric, surface, and visual inspections

[and the Risk lnformcd ISI PFrogram].

Exceptions to NUREG-1801 For further details, see the following element discussion(s) on the exceptions to NUREG-1801 aging management program elements:[Scope of Program MNGP uses the ASME Code 2001 Edition for Repair I Replacement Program.]Aging Management Program Elements Detection of Aging Effects The detection of aging effects is prescribed by the MNGP BWR Stress Corrosion Cracking Program in accordance with the requirements of ASME Section Xi, [and]NRC GL 88-01[, and RI ISI] to ensure that aging effects will be discovered and repaired before the loss of intended function.Monitoring and Trending...The program requirements for inspection schedule, extent, frequency, sequence of examinations, re-examinations, and additional examinations are in accordance with ASME Section Xl, Article IWB-2000 and IWC-2000, [and the RI ISI Program]with the incorporation of NRC GL-88-01.Page 112 of 149 ENCLOSURE I LRA APPENDIX B -Aging Management Programs B2.1.11 BWR Vessel ID Attachment Welds BACKGROUND (B2.1 .2-15)NMC letter to NRC, dated August 11, 2005, described changes necessary to the LRA description of the MNGP BWR Vessel ID Attachment Welds, (NUREG-1 801, XI.M4)Program.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.11 BWR Vessel ID Attachment Welds Program Description The MNGP BWR Vessel ID Attachment Welds Program is part of the MNGP ASME Section XI In-Service Inspection Aging Management Program. The BWR Vessel ID Attachment Weld Program is in accordance with ASME Section Xl 1995 Edition through the 1996 Addenda [and approved ISI Relief Requests].

Exceptions to NUREG-1801 This subsection identifies the elements of the MNGP AMP that are not consistent with the corresponding NUREG-1801 AMP elements.For further details, see the following element discussion(s) on the exceptions to NUREG -1801 aging management program elements:* [Scope of Program[MNGP uses the ASME Code 2001 Edition for Repair / Replacement Program.]Page 113 of 149 ENCLOSURE 1 LRA APPENDIX B -Aging Management Programs B2.1.12 BWR Vessel Internals BACKGROUND (B2.1 .2-15)NMC letter to NRC, dated August 11, 2005, described changes necessary to the LRA description of the MNGP BWR Vessel Internals, (NUREG-1801, XI.M9) Program.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.12 BWR Vessel Internals Program Description The BWR Vessel Internals Program is in accordance with ASME Section Xl 1995 Edition through the 1996 Addenda [and appreved ISI Relief Requests].

The program provides for condition monitoring of the BWR vessel internals for crack initiation and growth....

The Program is updated periodically as required by 10 CFR 50.55a and the BWRVIP Program.[Prior to the period of extended operation, the repair/replacement guidelines in BWRVIP-16, 19, 44, 45, 50, 51, 52, 57, and 58 will be added, as applicable, to the MNGP BWR Vessel Internals Program. (Also see Commitment No. 56)During the period of extended operation, NMC will perform top guide grid inspections using the EVT-1 method of examination, for the high fluence locations (grid beam and beam-to-beam crevice slot locations with fluence exceeding 5.0 x 1020 n/cm 2). Ten percent (10%) of the total population will be inspected within 12 years with a minimum of 5% inspected within the first 6 years. (Also see Commitments Nos. 53 and 58)NMC has inspected the in-core monitoring dry tubes on an every-other refueling outage periodicity and will continue to perform this inspection during the period of extended operation, per the guidance provided in GE SIL- 409.The NMC is an active member of the BWRVIP and will continue to follow applicable inspection guidelines and recommendations, which have been reviewed and approved by the executive committee of the BWRVIP, throughout the period of extended operation for MNGP.NMC will follow the guidance provided in BWRVIP-139, Steam Dryer Inspection and Flaw Evaluation Guidelines (April 2005), for the MNGP steam dryer inspections.

NMC will add inspection requirements for the P1, P2, and P3 welds, at MNGP, in accordance with guidance provided in BWRVIP-18, or subsequent revisions.]

Page 114 of 149 ENCLOSURE I LRA APPENDIX B -Aging Management Programs B2.1.13 Closed-Cycle Cooling Water BACKGROUND (A2.1.13-01)

During review of the LRA by NMC it was discovered that on pages A-8, A-9, B-1 07, B-1 08, and B-109, EPRI document "TR- 007820" is incorrectly described as "TR- 008720." DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

LRA Pages B-107, B-108, and B-109 B2.1.13 Closed-Cycle Cooling Water Program Description The MNGP Closed-Cycle Cooling Water System Program includes:

(1) preventive measures to minimize corrosion, and (2) periodic system and component performance testing and inspection to monitor the effects of corrosion and confirm intended functions are met. Preventive measures include the monitoring and control of corrosion inhibitors and other chemical parameters, such as pH, in accordance with the guidelines of Electric Power Research Institute (EPRI) TR-1007820, Closed Cooling Water Chemistry Guideline (Reference 6), vendor recommendations, and plant operating experience.

EPRI TR-1 007820 is the current revision (Revision

1) of EPRI-107396.

As only minor changes were made to the MNGP Closed-Cycle Cooling Water System Program to implement EPRI TR-1007820, the program is also still in accordance with the EPRI Revision 0 guidelines identified in NUREG-1801, Chapter Xl, Program M21, i.e., EPRI TR-107396, Closed Cooling Water Chemistry Guidelines.

Periodic inspection and testing to confirm function and monitor corrosion is also performed in accordance with EPRI TR-1007820, vendor recommendations, and industry and plant operating experience.

A review of plant operating experience demonstrates these measures ensure closed-cycle cooling water (CCCW) systems are performing their intended functions.

The MNGP has four systems in License Renewal Scope that meet the definition for consideration as closed-cycle cooling water systems and portions of three additional systems (heat exchangers or coolers) that are serviced directly by these cooling water systems. These systems and portions of systems are not subject to significant sources of contamination, in which water chemistry is controlled and in which heat is not directly rejected to a heat sink. The adequacy of chemistry control is confirmed on a routine basis by sampling and monitoring to within established limits and by equipment performance monitoring to identify aging effects.Corrosion inhibitor concentrations are maintained within limits based on a combination of EPRI TR-[1-008720 1007820] guidelines, vendor recommendations, and plant experience.

System and component performance test results are evaluated in accordance with the guidelines of EPRI TR-[4008720 1007820] and used as a basis for evaluating the effectiveness of actions to mitigate cracking, corrosion, and heat exchanger fouling.Page 115 of 149 ENCLOSURE I Acceptance criteria and tolerances are also based on system design parameters and functions.

For chemical parameters monitored, many are based on ranges identical to or more restrictive than noted in both EPRI TR-[I008720 1007820] and EPRI TR-1 07396.Others are based on vendor recommendations and plant experience.

Frequency of performance and functional tests are consistent with EPRI TR-[1-008720 1007820] and are based on plant operating experience, trends and equipment performance.

System and component operability tests are typically performed on a more frequent basis than once per cycle whereas more intrusive inspections (disassembly, eddy current testing, etc.) are performed less frequently but at sufficient intervals to detect the impact of aging effects on component function.[Prior to the period of extended operation, a one time inspection will be performed to monitor the effects of corrosion on select portions of closed-cycle cooling water systems that perform a pressure-integrity intended function.]

Exceptions to NUREG-1801

• Scope of Program The MNGP Closed-Cycle Cooling Water System Program uses EPRI TR-[4008720 1007820], Closed Cooling Water Chemistry Guideline, (not the NUREG-1801 EPRI TR-1 07396, Closed Cooling Water Chemistry Guideline).

EPRI TR-[4008720 1007820] is the current revision (Revision

1) of TR-107396.

In a similar situation with regard to the EPRI BWR Water Chemistry Guidelines the NRC found the provisions in the updated EPRI BWR Water Chemistry Guidelines to be acceptable.

... Further, implementing EPRI TR-[4008720 1007820] resulted in only minor program changes and the MNGP program generally meets the criteria of both revisions of the Closed Cooling Water Chemistry Guideline as described below.* Preventive Actions Some of the chemical parameters recommended for routine monitoring by EPRI TR-[4008720 1007820] and EPRI TR-1 07396 are not included in the Closed-Cycle Cooling Water System Program. Chosen parameters are deemed adequate and based on a combination of system design features (which preclude the need for monitoring some chemicals), make-up water source requirements, EPRI TR-[1-008720 1007820] guidelines, vendor recommendations, and plant operating experience.

Page 116 of 149 ENCLOSURE I LRA APPENDIX B -Aging Management Programs B2.1.14 Compressed Air Monitoring BACKGROUND (B3.2-04A)

For 2006 LRA Supplement, augment Appendices A & B with descriptions of commitments to enhance supporting programs.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.14 Compressed Air Monitoring Program Description The MNGP Compressed Air Monitoring Program consists of inspection, monitoring, and testing of the Instrument and Service Air System to provide reasonable assurance that they will perform their intended function for the duration of extended operation.

[Prior to the period of extended operation, the Compressed Air Monitoring Program procedures will be revised to include corrective action requirements if the acceptance limits for water vapor, oil content, or particulate are not met. Also, the acceptance criteria for oil content testing will be clarified and the basis for the acceptance limits for the water vapor, oil content, and particulate tests will be provided.Prior to the period of extended operation, the Compressed Air Monitoring Program will be revised to include inspection of air distribution piping based on the recommendations of EPRI TR-108147.]

Page 117 of 149 ENCLOSURE 1 LRA APPENDIX B -Aging Management Programs B2.1.15 Electrical Cables & Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program BACKGROUND (B3.2-04A)

For 2006 LRA Supplement, augment Appendices A & B with descriptions of commitments to enhance supporting programs.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.15 Electrical Cables & Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program Program Description The MNGP Electrical Cables & Connections Not Subject To 10 CFR 50.49 Environmental Qualification Requirements Program will be implemented as a new program consistent with the recommendations of NUREG-1801, Chapter Xl, Program XL.E1. The program will manages the aging of conductor insulation material on cables, connectors, and other electrical insulation materials that are installed in an adverse localized environment caused by heat, radiation, or moisture....

The program addresses cables and connections whose configuration is such that most cables and connections installed in adverse localized environments are accessible.

This program is a sampling program in which selected cables and connections from accessible areas are inspected and represent, with reasonable assurance, all cables and connections in the adverse localized environments.

If an unacceptable condition or situation is identified for a cable or connection in the inspection sample, a determination is made as to whether the same condition or situation is applicable to other accessible or inaccessible cables or connections.

[Prior to the period of extended operation, the MNGP Electrical Cables &Connections Not Subject To 10 CFR 50.49 Environmental Qualification Requirements Program will be implemented as a new program consistent with the recommendations of NUREG-1801 Chapter Xi Program XI.Ei.]Page 118 of 149 ENCLOSURE 1 LRA APPENDIX B -Aging Management Programs B2.1.16 Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits BACKGROUND (B3.2-04A)

For 2006 LRA Supplement, augment Appendices A & B with descriptions of commitments to enhance supporting programs.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.16 Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Program Description The Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Program will be implemented as a new program. With exceptions, it will be consistent with the recommendations of NUREG-1801 Chapter Xl, Program XI.E2....As stated in NUREG/CR-5643, "The major concern with cables is the performance of aged cable when it is exposed to accident conditions." The statement of considerations for the final license renewal rule (60 Fed. Reg. 22477) states, "The major concern is that failures of deteriorated cable systems (cables, connections, and penetrations) might be induced during accident conditions." Since they are not subject to the environmental qualification requirements of 10 CFR 50.49, the electrical cables covered by this aging management program are either not exposed to harsh accident conditions or are not required to remain functional during or following an accident to which they are exposed.[Prior to the period of extended operation, the Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Program will be implemented as a new program. With exceptions, it will be consistent with the recommendations of NUREG-1801 Chapter Xl, Program XL.E2.]Page 119 of 149 ENCLOSURE I LRA APPENDIX B -Aging Management Programs B2.1.17 Fire Protection BACKGROUND (3.3.2.3.5-1 and B3.2-04A)For 2006 LRA Supplement, augment Appendices A & B with descriptions of commitments to enhance supporting programs.

The Fire Protection Program, under "Scope of Program" in Appendix B of the LRA, although not specifically stated, credits the Selective Leaching of Materials Program for managing loss of material due to selective leaching and is intended to be included in these sections.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.17 Fire Protection Program Description The halon fire suppression system inspection included periodic inspection and testing of the cable spreading room halon fire suppression system.[The Fire Protection AMP will adequately manage the effect of loss of material due to crevice, galvanic, general and pitting corrosion for these components in the Fire System by invoking the Fire Water System AMP for the water initiated aging effects related to the diesel fire pump water-based subsystem.

Prior to the period of extended operation:

1) The MNGP Fire Protection Program will be revised to include a visual inspection of the halon fire suppression system to detect any signs of degradation, such as corrosion and mechanical damage. This visual inspection will provide aging management for external surfaces of the halon fire suppression system; and 2) The MNGP Fire Protection Program will be revised to include qualification criteria for individuals performing visual inspections of penetration seals, fire barriers, and fire doors. The qualification criteria will be in accordance with VT-1 or equivalent and VT-3 or equivalent, as applicable.]

Aging Management Program Elements Scope of Program The Fire Protection Program is credited for detecting and managing age-related degradation of fire barrier walls, ceilings, and floors, penetration seals, fire doors, and halon fire suppression system components.

It also manages the aging effects on the intended function of the fuel supply line for the diesel fire pump [and the loss of material due to selective leaching by crediting the Selective Leaching of Materials Program.]Page 120 of 149 ENCLOSURE 1 LRA APPENDIX B -Aging Management Programs B2.1.18 Fire Water System BACKGROUND (B3.2-04A)

For 2006 LRA Supplement, augment Appendices A & B with descriptions of commitments to enhance supporting programs.

The Fire Water System Program under "Scope of Program" in Appendix B of the LRA, although not specifically stated, credits the Selective Leaching of Materials Program for managing loss of material due to selective leaching and is intended to be included in this section.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.18 Fire Water System Program Description The Fire Water System aging management program relies on testing of water based fire protection system piping and components in accordance with applicable NFPA recommendations....

The system is also normally maintained at required operating pressure and is monitored such that loss of system pressure is immediately detected and corrective actions initiated.

[Prior to the period of extended operation, the Fire Water System Program implementing procedures will be revised to include the extrapolation of inspection results to below grade fire water piping with similar conditions that exist within the above grade fire water piping, and sprinkler heads will be inspected and tested per NFPA requirements or replaced before the end of the 50-year sprinkler head service life and at 10-year intervals thereafter during the extended period of operation to ensure that signs of degradation, such as corrosion, are detected in a timely manner.The program will also verify that the procedures, used for aging management activities of the Fire Water System, will be revised as appropriate and will apply testing in accordance with applicable NFPA codes and standards.]

Aging Management Program Elements Scope of Program The MNGP Fire Water System Program focuses on managing loss of material due to corrosion of carbon steel, cast-iron, stainless steel, and copper alloys in fire protection system components exposed to water. Hose stations and standpipes are considered as piping in this AMP. [The program also manages loss of material due to selective leaching of material by crediting the Selective Leaching of Materials Program.]Page 121 of 149 ENCLOSURE I LRA APPENDIX B -Aging Management Programs B2.1.19 Flow-Accelerated Corrosion BACKGROUND (3.1-03 and B2.1.19-05)

During discussions with the NRC staff, NMC determined that the fleet procedure for Flow Accelerated Corrosion is revised to include the accepted 87.5% of nominal pipe wall thickness for non safety-related piping as a trigger point for engineering analysis.

This action is entered and being tracked in the NMC corrective action process.In addition the FAC Program is revised to remove the Chemistry Sampling System from the list of systems which it manages.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.19 Flow-Accelerated Corrosion Aging Management Program Elements Scope of Program The Flow-Accelerated Corrosion Program manages the aging effects for susceptible components of the following systems and/or structures:

[Chemistr~y Sampling]

Reactor Head Vent Condensate

& Feedwater Reactor Recirculation High Pressure Coolant Injection Reactor Water Cleanup Main Steam Turbine Generator Reactor Core Isolation Cooling Detection of Aging Effects MNGP conducts an inspection program in accordance with NSAC-202L-R2.

Ultrasonic and radiographic testing is used to detect wall thinning.

The extent and frequency of inspections assure detection of wall thinning prior to the loss of intended function.

[The NMC Fleet Procedure for the Flow Accelerated Corrosion Inspection Program will be revised to include the accepted 87.5% of nominal pipe wall thickness for non-safety related piping as a trigger point for engineering analysis.]

Page 122 of 149 ENCLOSURE I LRA APPENDIX B -Aging Management Programs B2.1.20 Fuel Oil Chemistry BACKGROUND (B3.2-04A)

For 2006 LRA Supplement, augment Appendices A & B with descriptions of commitments to enhance supporting programs.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.20 Fuel Oil Chemistry Program Description The Monticello Nuclear Generating Plant (MNGP) Fuel Oil Chemistry Program is an existing program using existing diesel fuel oil system procedures that encompass the NUREG-1801 program recommendations.

The Fuel Oil Chemistry Program mitigates and manages aging effects on the internal surfaces of diesel fuel oil storage tanks and associated components in systems that contain diesel fuel oil. The program includes (a)surveillance and monitoring procedures for maintaining diesel fuel oil quality by controlling contaminants in accordance with applicable ASTM Standards; (b) periodic draining of water from diesel fuel oil tanks, if water is present, (c) periodic or conditional visual inspection of internal surfaces or wall thickness measurements (e.g., by UT) from external surfaces of diesel fuel oil tanks; and (d) one-time inspections of a representative sample of components in systems that contain diesel fuel oil.[Prior to the period of extended operation:

1) The MNGP procedures related to the Diesel Fuel Oil System will be revised to include requirements to check for general, pitting, crevice, galvanic, microbiological influenced corrosion (MIC), and cracking.2) The MNGP Fuel Oil Chemistry Program procedures will be revised to require tank draining, cleaning, and inspection if deemed necessary based on the trends indicated by the results of the diesel fuel oil analysis, or as recommended by the system engineer based on equipment operating experience.

Develop or revise existing procedures in the MNGP Fuel Oil Chemistry Program to require periodic tank inspections of the diesel fuel oil tanks.]NUREG-1801 Consistency The MNGP Fuel Oil Chemistry Program is an existing program. It will be enhanced to be consistent, with certain exceptions, with the recommendations of NUREG-1801 Chapter Xl, Program XI.M30.Page 123 of 149 ENCLOSURE 1 Exceptions to NUREG-1801 For further details, see the following element discussion(s) on the exceptions to NUREG -1801 aging management program elements:* Parameters Monitored or Inspected ASTM D 2709 and ASTM D 2276 are not utilized at the MNGP. NUREG-1 801, Section XL.M30, recommends the use of ASTM Standards D 1796 and D 2709 to test for water and sediment in diesel fuel oils. MNGP uses only ASTM D 1796 for verification that water and sediment are within specified limits. This standard is applicable to the grade of diesel fuel oil used at MNGP.NUREG-1801, Section XL.M30, also recommends the use of a modified ASTM D 2276 for sampling of particulate contaminants.

MNGP uses ASTM Standard D 6217 as a laboratory test to sample diesel fuel oil for suspended particulates.

This standard is applicable to the grade of diesel fuel oil used at MNGP. This standard utilizes the more conservative filter pore size of 0.8 [{wI pm] versus the recommended 3.0 [mm Mm].* Acceptance Criteria ASTM D 2709 and ASTM D 2276 are not utilized at MNGP. NUREG-1801, Section XL.M30, recommends the use of ASTM Standards D 1796 and D 2709 to test for water and sediment in diesel fuel oils. MNGP uses only ASTM D 1796 for verification that water and sediment are within specified limits. This standard is applicable to the grade of diesel fuel oil used at MNGP.NUREG-1801, Section XL.M30, also recommends the use of a modified ASTM D 2276 for sampling of particulate contaminants.

MNGP uses ASTM Standard D 6217 as a laboratory test to sample diesel fuel oil for suspended particulate.

This standard is applicable to the grade of diesel fuel oil used at MNGP. This standard utilizes the more conservative filter pore size of 0.8 [mm pm] versus the recommended 3.0 [amm pm.].Aging Management Program Elements Parameters Monitored or Inspected...This standard is applicable to the grade of diesel fuel oil used at MNGP. This standard utilizes the more conservative filter pore size of 0.8 [mmn pm]versus the recommended 3.0 [mm pm].The ASTM Standards used at MNGP, combined with the MNGP diesel fuel oil management activities, provide equivalent testing methods to those specified in NUREG-1801, Section XL.M30.Acceptance Criteria...This standard is applicable to the grade of diesel fuel oil used at MNGP. This standard utilizes the more conservative filter pore size of 0.8 [mm pm] versus the recommended 3.0 [mm pm].Page 124 of 149 ENCLOSURE I LRA APPENDIX B -Aging Management Programs B2.1.21 Inaccessible Medium Voltage (2kV to 34.5kV) Cables Not Subject to 10 CFR 50.49 EQ Requirements BACKGROUND (B3.2-04A and B2.1.21-1)

During discussions with the NRC staff, NMC determine that Appendix B Section B2.1.21 needed to be revised for clarification and to augment Appendices A & B with descriptions of commitments to enhance supporting programs.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.21 Inaccessible Medium Voltage (2kV to 34.5kV) Cables Not Subject to 10 CFR 50.49 EQ Requirements Program Description In this aging management program, periodic actions are taken to prevent cables from being exposed to significant moisture, such as inspecting for water collection in cable manholes and conduit, and draining water, as needed. In-scope, medium-voltage cables exposed to significant moisture and significant voltage are tested to provide an indication of the condition of the conductor insulation.

The specific type of test performed will be determined prior to the initial test, and is to be a proven test for detecting deterioration of the insulation system due to wetting, such as power factor, partial discharge, polarization index, or other testing that is state-of-the-art at the time the test is performed.

[Prior to the period of extended operation, the MNGP Inaccessible Medium Voltage (2 kV to 34.5 kV) Cables Not Subject to 10 CFR 50.49 EQ Requirements Program will be implemented as a new program consistent with the recommendations of NUREG-1801 Chapter Xl Program XL.E3.]Aging Management Program Elements Preventive Actions Periodic actions are taken to prevent medium voltage cables not designed for submergence from being subject to prolonged exposure to significant moisture, such as inspecting for water collection in cable manholes and conduit, and draining water, as needed. [Medium veltage eables, fOr which sueh aetiens ar, taken, arc net required to be tested sinee operating cxpcricnlc indicates that prolonged exposure to significant moisture and being energized for significant periods of time arc rFeuirzd to induec this aging effect.]Page 125 of 149 ENCLOSURE I Detection of Aging Effects The MNGP program will test inaccessible non-EQ medium-voltage cables (2 kV to 34.5 kV) within the scope of License Renewal, which are exposed to moisture (direct buried or in underground conduit) and energized more than 25% of the time at least once every 10 years. As stated in NUREG-1801, this is an adequate period to preclude failures of the conductor insulation since experience has shown that aging degradation is a slow process. This testing frequency provides an indication of insulation condition and the ability of the cable to perform its intended function.

The first tests for license renewal are to be completed before the period of extended operation.

[In addition, the underground electrical vaults (manholes, handholes, etc.)containing cable at MNGP are designed and installed without a concrete bottom. The electrical vaults are set on natural soil which is porous river sand.Historically, water accumulation in electrical vaults has not been an issue due to the natural draining due to the porous soil. The inspection frequency for water collection will be based on actual plant experience.

For those electrical vaults within the scope of License Renewal, the initial inspection frequency for water accumulation will be at least once every two years. The first inspection for license renewal is to be completed before the period of extended operation.]

Page 126 of 149 ENCLOSURE 1 LRA APPENDIX B -Aging Management Programs B2.1.22 Inspection of Overhead Heavy Load and Light Load (Related to Refueling)

Handling Systems BACKGROUND (B3.2-04A)

For 2006 LRA Supplement, augment Appendices A & B with descriptions of commitments to enhance supporting programs.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.22 Inspection of Overhead Heavy Load and Light Load (Related to Refueling)

Handling Systems Program Description The Inspection Of Overhead Heavy Load & Light Load (Related To Refueling)

Handling Systems program, which is implemented through plant procedures and preventive maintenance, manages loss of material of structural components for heavy load and fuel handling components within the scope of license renewal. The Inspection Of Overhead Heavy Load & Light Load (Related To Refueling)

Handling Systems program provides for visual and NDE inspections of in-scope load handling components.

Functional tests are also performed to assure their integrity.

The cranes also comply with the maintenance rule requirements provided in 10 CFR 50.65.[Prior to the period of extended operation, the Inspection of Overhead Heavy Load& Light Load (Related to Refueling)

Handling Systems Program will be enhanced to specify a five-year inspection frequency for the fuel preparation machines.]

Page 127 of 149 ENCLOSURE I LRA APPENDIX B -Aging Management Programs B2.1.23 One-Time Inspection BACKGROUND (B3.2-04A)

For 2006 LRA Supplement, augment Appendices with descriptions of commitments to enhance supporting programs.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.23 One-Time Inspection' Program Description The MNGP One-Time Inspection Program will be implemented as a new program consistent with the recommendations of NUREG-1801 Chapter XI, Program M32, "One-Time Inspection." This program will include measures to verify the effectiveness of the following aging management programs:* Plant Chemistry Program* Fuel Oil Chemistry Program This program will also confirm the absence of age degradation in selected components (e.g., flow restrictors, venturis, and small bore piping) within License Renewal scope....The program will manage the aging effects due to corrosion, cracking, erosion, fouling, fretting, or thermal exposure.

The program will also verify the absence of reduction of neutron absorption capacity of boral in the spent fuel pool.[Prior to the period of extended operation, the MNGP One-Time Inspection Program will be implemented as a new program consistent with the recommendations of NUREG-1801 Chapter Xl Program XI.M32, "One-Time Inspection." This program will include measures to verify the effectiveness of the following aging management programs:

Plant Chemistry Program and Fuel Oil Chemistry Program. This program will also confirm the absence of age related degradation in selected components (e.g., flow restrictors, venturis) within License Renewal scope.]Page 128 of 149 ENCLOSURE 1 LRA APPENDIX B -Aging Management Programs B2.1.26 Primary Containment In-Service Inspection Program BACKGROUND (B2.1.2-15) (B2.1.26-O1)

NMC letter to NRC, "Documentation of Responses to Aging Management Program and Aging Management Review Audits for the Monticello License Renewal Application (TAC No. MC6440)," dated August 11, 2005, determined that Primary Containment In-Service Inspection Program, (NUREG-1801, Xl.S1) should be revised.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.26 Primary Containment In-Service Inspection Program NUREG-1801 Consistency The Primary Containment In-Service Inspection Program is an existing program. It is consistent with NUREG-1 801, Chapter Xl, Program XI.SO1 and ASME Section XI, Subsection IWE.LExeeptions to ASME Codc requiremcnts that have been granted by approved CodG Cases or relief requests arc not considered to be cxeeptions to NUREG 1801 criteria.]

Aging Management Program Elements Scope of Program The current MNGP program does not require the examination of seals & gaskets, the measurement of residual bolt torque, the pre-service examination of new coatings or the pre-removal examination of existing coatings.

LThese aFe not rnsid;reod exceptions sinec the IINGIP progr-am has ben rc wd by tho teNRC and is in accordanoe with 1 OCFR50.55a with NRC approed relief requests.Parameters Monitored or Inspected The MNGP program doesn't include residual bolt torque measurement and penetration seal / gasket examination.

[Thesc arc not considered exceptions sineo thc MNGP pgrgram has boon rz band is in acoordanco withv 10GCFR65.55a with NRC approved relief roqucsts.Detection of Aging Effects The program requires a General Visual examination of all accessible surfaces, except submerged surfaces, once during each period. It requires a VT-3 visual examination of all accessible surfaces, including submerged surfaces, once during each interval.

Sub-Section IWE requires the VT-3 examination to be done at the end of the interval.

The MNGP program allows a part of this exam to be done during each period. [This is not considered an exeeption sinee the MNGP program Page 129 of 149 ENCLOSURE 1 has been reviewed by the NRC and is in acOordance with IOCFR5O.55a with NRC approved Felief rFquests-.]

Monitoring and Trending The MNGP Program allows the need for augmented examination of repaired areas to be based on engineering evaluation rather than on the prescriptive requirements of Sub-Section IWE. [Thisis not considered an exception sincc the MNGP program has been reviewed by the NRC and is in acoerdance with I OCFF5O.55a with NRG approved Frclief guests.]Corrective Actions Per plant administrative procedures, repairs/replacements and re-examinations comply with IWA-4000.

The MNGP Program for the 4th 10 year In-service Inspection Interval allows the 2001 Edition of Section Xl to be used for IWA-4000.[This is not considered an cxeeption sinec the MNGP program has been reviewed byteNRG and is in accordanee with !OGFR-GO5.65a with NRC approved relief r equests_.]

Confirmation Process Per plant administrative procedures, repairs/replacements and re-examinations comply with IWA-4000.

The MNGP Program for the 4th 10 year In-service Inspection Interval allows the 2001 Edition of Section Xl to be used for IWA-4000.[This is not considered an exceptien sinoe the MNGP program has been reviewed by the NRC and is in acoardance with 100GFR5O.55a with NRC approved reliefi Fequests.]

Page 130 of 149 ENCLOSURE 1 LRA APPENDIX B -Aging Management Programs B2.1.27 Protective Coating Monitoring

& Maintenance Program BACKGROUND (B2.1 .27-04)During discussions with the NRC staff, NMC determined that the inspectors who perform the periodic inspections are qualified to plant procedures and acceptance criteria.However, they are not necessarily qualified to ASTM Guide D4537 or ANSI N45.2.6. Prior to the period of extended operation, all coating inspectors will meet the requirements of ANSI N45.2.6.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.27 Protective Coating Monitoring

& Maintenance Program Program Description The MNGP Protective Coating Monitoring and Maintenance Program applies to Service Level 1 protective coatings inside containment to address the concerns of NRC GL 98-04, Potential for Degradation of the Emergency Core Cooling System and the Containment Spray System after a Loss-of-Cooling Accident because of Construction and Protective Coating Deficiencies and Foreign Material in Containment.

The Protective Coating Monitoring and Maintenance Program prevents the degradation of coatings that could lead to the clogging of ECCS suppression pool suction strainers.

MNGP does not credit the Protective Coating Monitoring and Maintenance Program for the prevention of corrosion of carbon steel components.

As outlined in MNGP's response to GL 98-04, the Protective Coating Monitoring and Maintenance Program is a comparable program for monitoring and maintaining protective coatings inside the primary containment and subject to the requirements of ANSI N101.4-1972, to the extent specified in ANSI N18.7-1976 and as modified by Regulatory Guide 1.54, June 1973.[Prior to the period of extended operation, the MNGP Protective Coating Maintenance and Monitoring Program: 1) Procedures will be updated to include Inspection of all accessible painted surfaces inside containment;

2) Procedures will be revised to include a pre-inspection review of the previous two inspection reports so that trends can be identified; and 3) Implementation procedures will be revised to include provisions for analysis of suspected reasons for coating failure.4) The program will be revised to include the requirement that personnel performing the inspection shall meet the requirements of ANSI N45.2.6.]Page 131 of 149 ENCLOSURE I Enhancements The following enhancement(s) are required to satisfy the NUREG-1801 aging management program recommendations.

Details of the enhancements are included in the appropriate element descriptions below. Enhancements will be completed prior to the period of extended operation.

[

• Detection of Aging Effects The MNGP Protective Coating Maintenance and Monitoring Program will be revised, prior to the period of extended operation, to include the requirement that personnel performing the inspection shall meet the requirements of ANSI N45.2.6.]Aging Management Program Elements Detection of Aging Effects The Protective Coating Monitoring and Maintenance Program requires inspections to be performed each operating cycle for the torus above water line and drywell-coated surfaces.

The below water line painted surfaces, including the areas near the ECCS suction strainers, are inspected at intervals not exceeding five years. Knowledgeable coatings personnel perform the inspections using appropriate equipment as necessary.

[The program will be revised to include the requirement that personnel performing the inspection shall meet the requirements of ANSI N45.2.6.]

A VT-3 exam is performed for all coatings degradation identified by the inspector.

All unacceptable areas are required to be repaired or evaluated.

Page 132 of 149 ENCLOSURE 1 LRA APPENDIX B -Aging Management Programs B2.1.28 Reactor Head Closure Studs BACKGROUND (B2.1 .2-15)NMC letter to NRC, "Documentation of Responses to Aging Management Program and Aging Management Review Audits for the Monticello License Renewal Application (TAC No. MC6440)," dated August 11, 2005, determined that Reactor Head Closure Studs (NUREG-1801, X1.M3) should be revised.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.28 Reactor Head Closure Studs NUREG-1801 Consistency The Reactor Head Closure Studs Program is an existing program. It is consistent with the recommendations of NUREG-1 801, Chapter XI, Program XI.M3, "Reactor Head Closure Studs.' [AEeepties to-ASME reqUirements that have been grantEd by approved Code Cases or relief requests arc not considered to be cxeeptions to NU REC 18 Q eritre 1-.Exceptions to NUREG-1801

• [Nem-e NMC uses the ASME Code 2001 Edition for Repair / Replacement

-Program at MNGP.* NMC utilizes Code Case N-307-2 -Revised Ultrasonic Examination Volume for Class I Bolting, Table IWB-2500-1, Examination Category B-G-1, When the examinations are conducted from the end of the bolt or stud, or from the center-drilled hole at MNGP.* The Reactor Head Closure Studs Program does not incorporate the ultimate tensile strength requirement of NRC Regulatory Guide 1.65 for the existing reactor head closure studs. NMC considers this an acceptable exception to NUREG-1801, since these studs are considered susceptible to cracking at MNGP and NMC continues to manage them through the preventative measures recommended by Regulatory Guide 1.65 regardless of the tensile strength.]

Page 133 of 149 ENCLOSURE I LRA APPENDIX B -Aging Management Programs B2.1.29 Reactor Vessel Surveillance BACKGROUND (B3.2-04A)

For 2006 LRA Supplement, augment Appendices with descriptions of commitments to enhance supporting programs.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.29 Reactor Vessel Surveillance Program Description The MNGP Reactor Vessel Surveillance Program is part of the Boiling Water Reactor's Vessel Internals Project (BWRVIP) Integrated Surveillance Program (ISP) that uses data from BWR member surveillance programs to select the "best' representative material to monitor radiation embrittlement for a particular plant. The BWRVIP ISP monitors capsule test results from various member plants. This is consistent with the methodology allowed by NUREG-1 801.The MNGP Reactor Vessel Surveillance Program is required by 10 CFR 50, Appendix H. The scope of the Reactor Vessel Surveillance Program is described by the BWRVIP ISP guidance.

The ISP capsule removal schedule is included in BWRVIP-86-A and its technical basis is described in BWRVIP-78.

The NRC in a Safety Evaluation (SE) to the BWRVIP, dated February 1, 2002, approved the ISP. This Safety Evaluation concluded that the ISP, if implemented in accordance with the conditions in the SE, is an acceptable alternative to all existing BWR plant-specific RPV surveillance programs for the purpose of maintaining compliance with the requirements of Appendix H to 10 CFR Part 50 through the end of current facility 40 year operating licenses.[NMC intends to use the Integrated Surveillance Program during the period of extended operation by implementing the requirements of BWRVIP-116, which is currently being reviewed by the NRC.Prior to and during the period of extended operation, NMC will retain the capsules removed from the MNGP reactor vessel as part of the Reactor Vessel Surveillance Program.]Page 134 of 149 ENCLOSURE 1 LRA APPENDIX B -Aging Management Programs B2.1.30 Selective Leaching of Materials BACKGROUND (3.3.2.3.5-1)

The Fire Protection Program, the Fire Water System Program and the Buried Piping and Tanks Inspection Program are credited for managing the effects of loss of material due to selective leaching for certain Fire System components (copper alloy and gray cast iron materials in a raw water or buried in ground environment) in Table 3.3.2-9. These AMPs, in turn, credit (invoke) the Selective Leaching of Materials Program for the actual management of loss of material due to selective leaching.

However, the Fire System was inadvertently omitted from the applicable MNGP systems table in B2.1.30 (under "Scope of Program")

for the Selective Leaching of Materials Program in Appendix B of the LRA and is included in this table.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.30 Selective Leaching of Materials Aging Management Program Elements Scope of Program The Selective Leaching of Materials Program consists of activities that manage the aging effects for components of the following MNGP systems and/or structures:

Circulating Water High Pressure Coolant Injection Condensate Storage Instrument and Service Air Core Spray Radwaste Solid & Liquid Demineralized Water Reactor Building Closed Cooling Water Emergency Diesel Generators Residual Heat Removal Emergency Filtration Train Reactor Core Isolation Cooling Emergency Service Water Service & Seal Water Fuel Pool Cooling and Turbine Generator Cleanup Heating & Ventilation Wells and Domestic Water[Fire System]Page 135 of 149 ENCLOSURE I LRA APPENDIX B -Aging Management Programs B2.1.31 Structures Monitoring Program BACKGROUND (B3.2-04A)

For 2006 LRA Supplement, augment Appendices with descriptions of commitments to enhance supporting programs.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.31 Structures Monitoring Program Program Description The Structures Monitoring Program does not rely upon protective coatings to manage the effects of aging.[Prior to the period of extended operation, the MNGP Structures Monitoring Program: 1) Will be expanded, as necessary, to include inspections of structures and structural elements in scope for License Renewal that are not inspected as part of another aging management program.2) Implementing procedures will be enhanced to ensure that structural inspections are performed on submerged portions of the intake structure from the service water bays to the wing walls;3) Implementing procedures will be revised to include the monitoringlinspection parameters for structural components within the scope of License Renewal;4) Will be enhanced to include a requirement to sample ground water for pH, chloride concentration and sulfate concentration;

5) Will be enhanced to include concrete evaluations of inaccessible areas if degradation of accessible areas is detected; and 6) Implementing procedures will be enhanced to include acceptance criteria for structural inspections of submerged portions of the Intake Structure.]

Page 136 of 149 ENCLOSURE 1 LRA APPENDIX B -Aging Management Programs B2.1.32 System Condition Monitoring Program BACKGROUND (B3.2-04A)

For 2006 LRA Supplement, augment Appendices with descriptions of commitments to enhance supporting programs.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.32 System Condition Monitoring Program Program Description The System Condition Monitoring Program is an existing plant-specific program that is based on system engineer monitoring.

Although many monitoring activities are being performed at MNGP, this AMP brings aging management into the scope of the monitoring activities.

Other groups augment this program by identifying and reporting adverse material conditions via the corrective action process or work control process.This monitoring consists of system-level performance monitoring, inspections and walkdowns, health and status reporting, and preventive maintenance.

This program will be enhanced to include specific activities and criteria for managing age related degradation for SSCs within License Renewal scope. This program manages aging effects for normally accessible external surfaces of piping, tanks, hangers/supports, racks, panels, and other components and equipment within the scope of License Renewal. These aging effects are managed through visual inspection and monitoring of external surfaces for leakage and evidence of material degradation.

[Prior to the period of extended operation, the implementing instructions and procedures for the MNGP System Condition Monitoring Program will be revised to describe specific age degradation parameters to be monitored and inspected.

Acceptance criteria will also be included.]

Page 137 of 149 ENCLOSURE I LRA APPENDIX B -Aging Management Programs B2.1.33 Thermal Aging & Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS)BACKGROUND (B2.1 .2-15)NMC letter to NRC, "Documentation of Responses to Aging Management Program and Aging Management Review Audits for the Monticello License Renewal Application (TAC No. MC6440)," dated August 11, 2005, determined that Thermal Aging & Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) (NUREG-1 801, XI.M1 3)should be revised.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B2.1.33 Thermal Aging & Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS)Exceptions to NUREG-1801

[None. MNGP uses the ASME Code 2001 Edition for Repair / Replacement Program.]Page 138 of 149 ENCLOSURE 1 LRA APPENDIX B -Aging Management Programs B2.1.34 Electrical Cable Connections Not subject to 10 CFR 50.49 Environmental Qualification Requirements BACKGROUND (3.6-2a)During discussions with the NRC staff, NMC determined that the MNGP LRA should include a program which is consistent with the NUREG-1 801, Revision 1, XI.E6, "Electrical Cable Connections Not subject to 10 CFR 50.49 Environmental Qualification Requirements." DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

[B2.1.34 Electrical Cable Connections Not subject to 10 CFR 50.49 Environmental Qualification Requirements Program Description Cable connections are used to connect cable conductors to other cables or electrical devices. Connections associated with cables with in the scope of license renewal are part of this program. The most common types of connections used in nuclear power plants are splices (butt or bolted), crimp-type ring lugs, connectors, and terminal blocks. Most connections involve insulating material and metallic parts. This aging management program for electrical cable connections (metallic parts) account for the following aging stressors:

thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation.

GALL XI.EI, "Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements," manages the aging of insulating material but not the metallic parts of the electrical connections.

GALL XL.EI is based on only a visual inspection of accessible cables and connections.

Visual inspection is not sufficient to detect the aging effects from thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation on the metallic parts of cable connections.

Circuits exposed to appreciable ohmic or ambient heating during operation may experience loosening related to repeated cycling of connected loads or of the ambient temperature environment.

Different materials used in various cable system components can produce situations where stresses existing between these components change with repeated thermal cycling. For example, under loaded conditions, appreciable ohmic heating may raise the temperature of a compression termination and cable conductor well above the ambient temperature, thereby causing thermal expansion of both components.

Different thermal expansion coefficients may alter mechanical stresses between the components so that the termination may tighten on the conductor.

When the load Page 139 of 149 ENCLOSURE I or current is reduced, the affected components cool and contract.

Repeated cycling in this fashion can produce loosening of the termination under ambient conditions, and may lead to high electrical resistance joints or eventual separation to compression-type terminations.

Threaded connectors, splices, and terminal blocks may loosen if subjected to significant thermally induced stress and cycling.Cable connections within the scope of license renewal are tested to provide an indication of the integrity of the cable connections.

The specific type of test performed will be determined prior to the initial test, and will be a proven test for detecting loose connections, such as thermography, contact resistance testing, or other appropriate testing.This program, as described, can be thought of as a sampling program. The following factors are considered for sampling:

application (high, medium and low voltage), circuit loading, and location (high temperature, high humidity, vibration, etc.). The technical basis for the sample selections is documented.

If an unacceptable condition or situation is identified in the selected sample, a determination is made as to whether the same condition or situation is applicable to other connections not tested.SAND 96-0344, "Aging Management Guidelines for Electrical Cable and Terminations," indicated loose terminations were identified by several plants. The major concern is that failures of a deteriorated cable system (cables, connections including fuse holders, and penetrations) might be induced during accident conditions.

Since the connections are not subject to the environmental qualification requirements of 10 CFR 50.49, an aging management program is required to manage the aging effects. This program will ensure that electrical cable connections will perform their intended function for the period of extended operation.

NUREG-1801 Consistency The Electrical Cable Connections Not Subject To 10 CFR 50.49 Environmental Qualification Requirements Program is a new program. It is consistent with the recommendations of NUREG-1801 Rev. 1, Chapter Xi, Program XL.E6.Exceptions to NUREG-1801 None Enhancements None Aging Management Program Elements The program elements, which are part of the Electrical Cable Connections Not Subject To 10 CFR 50.49 Environmental Qualification Requirements Program, are described below. The results of an evaluation of each element against NUREG-1801, Generic Aging Lessons Learned (GALL) Report, Chapter Xl Program XI.E6, Electrical Cable Connections Not Subject To 10 CFR 50.49 Environmental Qualification Requirements is provided.Page 140 of 149 ENCLOSURE 1 Scope of Program The Electrical Cables Connections Not Subject To 10 CFR 50.49 Environmental Qualification Requirements Program consists of MNGP activities that manage the aging effects of connections associated with cables that have been identified as within scope of License Renewal activities, regardless of their association with active or passive components.

Preventive Actions This is a testing program and no actions are taken as part of this program to prevent or mitigate aging degradation.

Parameters Monitored or Inspected This program will focus on the metallic parts of the connection.

The monitoring includes loosening of bolted connections due to thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation.

A representative sample of electrical cable connections will be tested. The following factors will be considered for sampling:

application (high, medium and low voltage), circuit loading, and location (high temperature, high humidity, vibration, etc.). The technical basis for the sample selected will be documented in the site work instruction document.Detection of Aging Effects Electrical connections within the scope of license renewal will be tested at least once every 10 years. Testing may include thermography, contact resistance testing, or other appropriate testing methods. This is an adequate period to preclude failures of the electrical connections since experience has shown that aging degradation is a slow process. A 10-year testing interval will provide two data points during a 20-year period, which can be used to characterize the degradation rate. The first tests for license renewal will be completed before the period of extended operation.

Monitoring and Trending Trending actions are not included as part of this program because the ability to trend test results is dependent on the specific type of test chosen.However, if tests selected produce results that are trendable, then these results will be used to provide additional information on the rate of degradation.

Acceptance Criteria The acceptance criteria for each test will be defined by the specific type of test performed and the specific type of cable connections tested.Corrective Actions An engineering evaluation is performed when the test acceptance criteria are not met in order to ensure that the intended functions of the cable Page 141 of 149 ENCLOSURE 1 connections can be maintained consistent with the current licensing basis.Such an evaluation is to consider the significance of the test results, the operability of the component, the reportability of the event, the extent of the concern, the potential root causes for not meeting the test acceptance criteria, the corrective action necessary, and the likelihood of recurrence.

When an unacceptable condition or situation is identified, a determination is made on whether the same condition or situation is applicable to other in-scope cable connections not tested.[Insert TR-013, Element 7, Corrective Actions, discussion here.]Confirmation Process[Insert TR-013, Element 8, Confirmation Process, discussion here.]Administrative Controls[Insert TR-013, Element 9, Administrative Controls, discussion here.]Operating Experience The Electrical Cable Connections Not Subject To 10 CFR 50.49 Environmental Qualification Requirements Program is a new site-specific program and therefore does not have any operating experience.

However, industry operating experience has shown that loosening of connections and corrosion of connections are aging mechanisms that, if left unmanaged, could lead to a loss of electrical continuity and potential arcing or fire.Conclusion Implementation of the MNGP Electrical Cable Connections Not Subject To 10 CFR 50.49 Environmental Qualification Requirements Program will provide reasonable assurance that the aging effects will be managed so that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis through the period of extended operation.]

Page 142 of 149 ENCLOSURE I LRA Section B3 -TLAA SUPPORT ACTIVITIES B3.1 Environmental Qualification (EQ) of Electrical Components BACKGROUND (B3.1 -3)During discussions with the NRC staff NMC has determined that in accordance with the Generic Aging Lessons Learned (GALL) Report -NUREG-1 801, Vol. 2, Rev .1, GALL X.E1, elaboration of the corrective action element is necessary DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

B3.1 Environmental Qualification (EQ) of Electrical Components Aging Management Program Elements Corrective Actions[If an EQ component is found to be outside the bounds of its qualification basis, corrective actions are implemented in accordance with the station's corrective action program. When unexpected adverse conditions are identified during operational or maintenance activities that affect the environment of a qualified component, the affected EQ component is evaluated and appropriate corrective actions are taken, which may include changes to the qualification bases and conclusions.

When an emerging industry aging issue is identified that affects the qualification of an EQ component, the affected component is evaluated and appropriate corrective actions are taken, which may include changes to the qualification bases and conclusions.

Also refer to Section B1.3.]Page 143 of 149 ENCLOSURE I CLARIFYING DRAWING CHANGES TO SUPPORT THE LRA During review of the MNGP LRA and discussions with the NRC staff, NMC has made several clarifications to the License Renewal Boundary Drawings that were submitted in support of the MNGP LRA.Page 144 of 149 ENCLOSURE 1 APPENDIX E CLARIFYING CHANGES TO THE ENVIRONMENTAL REPORT Applicant's Environmental Report, Operating License Renewal Stage SECTIONS 2.8.1 and 3.1.

3.5 BACKGROUND

(2.8.1 and 3.1.3.5)During the NRC audit of the Environmental Report associated with the License Renewal Application, the plant staff noted that only 4 of the 5 on-site wells were mentioned in Sections 2.8.1 and 3.1.3.5.The LRA discussed the two domestic wells located west of the reactor building, the well associated with the SAB and the well associated with Warehouse

1. 5; however the LRA failed to mention the new well at the security training facility (firing range) that was installed in 2004.A further review of plant documents noted that the Ops Manual and other plant references failed to mention the existence of the 5th well. The LRA was written, in part, based on information contained in the Operation Manual and other plant references, thus the most likely reason the fifth well was not mentioned in LRA.The discrepancy was addressed through the site Corrective Action Process and the Operation Manual was revised to include the update (Operation Manual B.08.06-01 Rev. 6 page 4 of 9).DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough) 2.8.1 Public Water Supply"NMC operates one of these regulated systems, providing potable water from [fewu five]groundwater wells in support of MNGP operations." 3.1.3.5 Domestic Water Supply and Sanitary Wastewater Treatment"NMC operates [foof five] groundwater wells to meet the domestic water needs of the MNGP site.. .[The ether twoTwo wells] serviced by 45-gpm pumps[-] provide domestic water on an as-needed basis to a warehouse and the Site Administration Building.

[The final well was installed in 2004 at the Security Training Facility for potable water use]. Annual usage of these wells is less than one million gallons per year or less than 1.9 gpm; therefore, water appropriations permits are not required by MNDNR (MN 2003).Page 145 of 149 ENCLOSURE I SECTION 2.3.

1.1 BACKGROUND

(2.3.1.1) page 2-16 NMC staff were contacted by the NRC during the information review process and asked to provide a more recent freshwater mussel study than that provided at the site audit. NMC staff located a study published in 2002 by Kelner and Davis which provided new insight to the Mississippi River mussel communities near the MNGP site.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough) 2.3.1.1 Aquatic Ecological Communities (Amish et al. 1978, page 51). [ The 2000-2001 study by Kelner and Davis surveyed mussel species in the Coon Rapids Pool, located near the M ississippi River RM 867. This is the closest study site to the MNGP site. A total of 587 mussels representing six species were collected at 19 sites (Kelner & Davis 2002, p. 11). Species collected consisted of Lampsilis cardium, Lampsilis siliquoidea, Lasmigona complanata, Lasmigona compressa, Ligumia recta and Pyganodon grandis (Kelner & Davis, Appendix II). Two of these species, Ligumia recta and Pyganodon grandis (or Anodonta grandis) were also observed in the Upper Mississippi River in the 1940 survey by J.B. Moyle.]Additional reference provided: Kelner, Dan & Mike Davis. (Minnesota Department of Natural Resources).

2002. Final Report: Mussel (Bivalvia:

Unionidae) survey of the Mississippi National River and Recreation Area Corridor, 2000-01. Ecological Services Division.

July.Page 146 of 149 ENCLOSURE 1 SECTIONS 2.3.1.2, 2.3.3.1, 7.

7.1 BACKGROUND

(2.3.1.2) page 2-19 (2.3.3.1) page 2-25 (7.7.1) page 7-5 During the MNGP site audit, members of the review team from NRC and Lawrence Livermore National Laboratory observed the presence of a bald eagle on top of a nest on Beaver Island, directly across the Mississippi River from the MNGP site. During the information review, NRC staff noted that the island was incorrectly identified in the Environmental Report as 'Cedar Island ." NMC reviewed maps of the Mississippi River islands and concurred with the Staffs findings.

Review of the Environmental Report found that Beaver Island was also omitted in the discussion of Riparian Habitats (Section 2.3.1.2).DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough) 2.3.1.2 Riparian Habitats River islands in the immediate MNGP site area consists of Cedar Island, [Beaver Island]and Oxbow Island (see Figure 2.1-3). [Both ef] These islands..." 2.3.3.1 Fauna"One nest is known to exist on [Gedaf Beaver] Island, upstream from the power block..." 7.1.1 Terminating Operations and Decommissioning

"- Bald Eagles (federal-threatened) have been observed to nest on [Gedaf Beaver] Island, portions of which are as close as 600 feet from the power block (Figure 2.1-3 of this ER).Page 147 of 149 ENCLOSURE 1 SECTION 3.

1.2 BACKGROUND

(3.1.2) page 2-16 Based on the information provided in the GEIS, the Commission found that, "the impacts of transporting spent fuel enriched up to 5 percent uranium-235 with average burnup for the peak rod to current levels approved by NRC up to 62,000 MWd/MTU and the cumulative impacts of transporting high-level waste to a single repository, such as Yucca Mountain, Nevada, are found to be consistent with the impact values contained in 10 CFR 51.52(c), Summary Table S-4-Environmental Impact of Transportation of Fuel and Waste to and from one Light-Water-Cooled Nuclear Power Reactor. If fuel enrichment or burnup conditions are not met, the applicant must submit an assessment of the implications for the environmental impact values reported in 10 CFR 51.52." The MNGP Environmental Report presents fuel burn-up levels per pellet instead of per rod. The correction seeks to more closely align with the GEIS requirements (per-rod instead of per-pellet).

DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough) 3.1.2 NUCLEAR FUEL"MNGP is licensed for low-enriched uranium-dioxide fuel with enrichments below 5.0 percent by weight Uranium-235 and fuel burn-up levels for the peak pellet less than 70,000 megawatt days per metric ton uranium. [MNGP fuel rod release fractions have been determined to be acceptable for use with currently approved light water reactor fuel with a peak fuel rod burnup of up to 62,000 MWd/MTU provided that the maximum linear heat generation rate does not exceed 6.3 kwlft peak rod average power for burnups exceeding 54 GWd/MTU.]Additional reference provided: Monticello Nuclear Generating Plant, Alternate Source Term Submittal (ML052640368).

Page 148 of 149 ENCLOSURE I TABLE 9.1-1 Background (Table 9.1-1) page 9-5 through 9-8 Table 9.1-1, Environmental Authorizations for Current Operations, has been updated to reflect changes and updates to permits held by NMC or Xcel Energy.DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are bold in brackets; deletions are strikethrough)

The MNDNR Division of Fish and Wildlife Special Permit was reissued on 11/21/2005.

Authorization information is as follows: Agency: Minnesota Department of Natural Resources Authority:

Minnesota Statutes Chapter 97A.401 Requirement:

Division of Fish and Wildlife Special Permit Number: 13315 Expiration Date: 12/31/06 Renewal Frequency:

Yearly Renewal Page 149 of 149