ML092710045

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Supplemental Information for the Review of the License Renewal Application - Changes to the Work Control Process Aging Management Program
ML092710045
Person / Time
Site: Kewaunee Dominion icon.png
Issue date: 09/25/2009
From: Hartz L
Dominion Energy Kewaunee
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
09-597, FOIA/PA-2010-0209
Download: ML092710045 (45)
v • d • e


Text

Dominion Energy Kewaunee, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 DOlllinion September 25, 2009 United States Nuclear Regulatory Commission Serial No.: 09-597 Attention: Document Control Desk LR/MWH RO Washington, DC 20555-0001 Docket No.: 50-305 License No.: DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION SUPPLEMENTAL INFORMATION FOR THE REVIEW OF THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION - CHANGES TO THE WORK CONTROL PROCESS AGING MANAGEMENT PROGRAM By letter dated August 12, 2008 (reference 1), Dominion Energy Kewaunee, Inc. (DEK) submitted an application to renew the operating license of Kewaunee Power Station (KPS). During a July 28, 2009 public meeting between NRC and DEK related to the review of the KPS license renewal application (LRA) (reference 2), DEK indicated that the LRA would be amended to provide supplemental information related to revising the Work Control Process aging management program.

Attachment 1 includes a description of the revised Work Control Process program.

Attachment 2 provides additional supplemental information that clarifies or amends the affected areas of the LRA as a result of the revised Work Control Process program.

Should you have any questions regarding this submittal, please contact Mr. Paul C.

Aitken at (804) 273-2818.

Very truly yours, q--Y;ff?r~

Leslie N. Hartz Vice President - Nuclear Support Services COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and State aforesaid, today by Leslie N. Hartz, who is Vice President - Nuclear Support Services of Dominion Energy Kewaunee, Inc.

She has affirmed before me that she is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of her knowledge and belief.

Acknowledged before me this c?~ay of ~mbt..l,-2009. .

My Commission Expires: 4 \W\ \3 ~~Mb/A\\)(I

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Serial No.09-597 Docket No. 50-305 Page 2 of 3

Reference:

1. Letter from D. A. Christian (DEK) to NRC, "Kewaunee Power Station Application for Renewed Operating License," dated August 12, 2008. [ADAMS Accession No.

ML082341020]

2. Letter from Samuel Hernandez (NRC) to Dominion Energy Kewaunee, "Summary of Public Meeting Related to the Review of the Kewaunee Power station License Renewal Application (TAC No. MD9408)," dated August 10, 2009.

Attachments:

1. Description of the Revised Work Control Process Aging Management Program
2. Changes and Clarifications to the Kewaunee License Renewal Application as a Result of the Revised Work Control Process Aging Management Program Commitments made in this letter:
1. The revised Work Control Process program will be developed and implemented prior to the period of extended operation.

Serial No.09-597 Docket No. 50-305 Page 3 of 3 cc:

U.S. Nuclear Regulatory Commission Regional Administrator, Region III 2443 Warrenville Road Suite 210 Lisle, IL 60532-4532 Mr. P. S. Tam, Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint, Mail Stop 08-H4A 11555 Rockville Pike Rockville, MD 20852-2738 Ms. V. Perin Environmental Project Manager U.S. Nuclear Regulatory Commission Mail Stop 0-11 F1 Washington, DC 20555-0001 Mr. Q. S. Hernandez License Renewal Project Manager U.S. Nuclear Regulatory Commission Mail Stop 0-11 F1 Washington, DC 20555-0001 NRC Senior Resident Inspector Kewaunee Power Station N490 Highway 42 Kewaunee, WI 54216 Public Service Commission of Wisconsin Electric Division P.O. Box 7854 Madison, WI 53707 David Hardtke Chairman - Town of Carlton E2334 Lakeshore Road Kewaunee, WI 54216

Serial No.09-597 Docket No. 50-305 ATTACHMENT 1 DESCRIPTION OF THE REVISED WORK CONTROL PROCESS AGING MANAGEMENT PROGRAM KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No.09-597 Docket No.: 50-305 Attachment 1/Page 1 of 2 Introduction The Work Control Process program for Kewaunee, as described in the License Renewal Application (LRA) (Reference 1) Appendix B, Section B2.1.32, has been revised to include the aging management programs (AMPs) identified in NUREG-1801 (Reference 2),Section XI.M32, "One-Time Inspection," and Section XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components." As revised, the Work Control Process program will be consistent with the NUREG;.,1801 programs identified, with one exception to the Section XI.M38 AMP. The Work Control Process program will retain the original program name in order to maintain consistency within the LRA aging management results and application of aging management programs to manage aging effects. The Work Control Process program, as revised, is a new aging management program that is consistent with NUREG-1801.

Description of Revised Work Control Process Program The Work Control Process program has been revised to encompass two new aging management programs: (1) the One-Time Inspection program, consistent with NUREG-1801,Section XI.M32, "One-Time Inspection," and (2) the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (Internal Surfaces Monitoring) program, consistent with NUREG-1801,Section XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components."

The One-Time Inspection program will include measures to verify the effectiveness of system chemistry-related aging management programs and confirm the insignificance of any aging effects. This program will provide confirmation that (a) an aging effect is not expected to occur but the data is insufficient to rule it out with reasonable confidence; (b) an aging effect is expected to progress very slowly in the specified environment, but the local environment may be more adverse than that generally expected; or (c) the characteristics of the aging effect include a long incubation period.

The Internal Surfaces Monitoring program will perform inspections of components fabricated of steel and other materials in air and other environments. This program will include visual inspections to assure that existing environmental conditions are not causing material degradation that could cause loss of component intended functions.

The program inspections will be performed during surveillance and maintenance activities when the surfaces are made available for examination. The scope of the Internal Surfaces Monitoring program will include aging management for materials of construction, environments, and aging effects that are not included in the scope of the NUREG-1801,Section XI.M38 aging management program. This has been identified as an exception to the recommendations of the NUREG-1801 program.

Serial No.09-597 Docket No.: 50-305 Attachment 1/Page 2 of 2 References

1. Letter from D. A. Christian (DEK) to NRC, "Kewaunee Power Station Application for Renewed Operating License," dated August 12, 2008. [ADAMS Accession No.

ML082341020]

2. NUREG-1801, Volume 2, Revision 1, "Generic Aging Lessons Learned (GALL)

Report," U.S. Nuclear Regulatory Commission, September 2005.

Serial No.09-597 Docket No.: 50-305 ATTACHMENT 2 CHANGES AND CLARIFICATIONS TO THE KEWAUNEE LICENSE RENEWAL APPLICATION AS A RESULT OF THE REVISED WORK CONTROL PROCESS AGING MANAGEMENT PROGRAM KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 1 of 38 This attachment provides the changes and clarifications to the Kewaunee License Renewal Application (LRA) as a result of the revision to the Work Control Process program described in Attachment 1. LRA Sections 3.1, 3.2, 3.3, 3.4, and 3.5, and Appendices A and B are amended by this LRA supplement. LRA changes and clarifications are provided as follows:

Part A: LRA Appendix A and B - Revised aging management program information Part B: LRA Section 3 - Text and Tables 3.x.1 and 3.x.2-y changes Part C: LRA Section 3 - Clarification of the Work Control Process program application

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 2 of 38 Part A: LRA Appendix A and B The following page replaces LRA Appendix A, Section A2.1 .32, Work Control Process, in its entirety.

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 3 of 38 A2.1.32 WORK CONTROL PROCESS Program Description The Work Control Process program is a new program that will correspond to NUREG-1801,Section XI.M32, "One-Time Inspection," and Section XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components."

One-time inspections will manage the aging effects of cracking, loss of material, and reduction of heat transfer to verify the effectiveness of the Primary Water Chemistry, Secondary Water Chemistry, Closed-Cycle Cooling Water System, Fuel Oil Chemistry, and Lubricating Oil Analysis programs through inspections implemented in accordance with the work management process. The one-time inspections will be performed using NDE techniques that have been determined to be effective for the identification of potential aging effects. The program will use a representative sampling approach to verify degradation is not occurring. The sample size and location for the one-time inspections will be established to ensure that the number and scope of the inspections are sufficient to provide reasonable assurance that the aging effects will not compromise the intended functions during the period of extended operation.

The inspections of internal surfaces in miscellaneous piping and ducting components will manage the aging effects of change in material properties, cracking, hardening and loss of strength, loss of material, loss of sealing, loss of strength, and reduction of heat transfer for the in-scope structures and components through inspections implemented in accordance with the work management process. The program will perform visual inspections of piping, piping components, ducting and other components fabricated of aluminum, copper alloys, stainless steel, and steel to detect loss of material, reduction of heat transfer, and cracking. Visual inspections will also manage the degradation of the paper filter elements in the Compressed Air System. The program will include physical manipulation of elastomeric components as a supplement to the visual inspections. An enhanced VT-1 NDE examination will be performed to detect cracking of stainless steel diesel exhaust flexible connections.

Commitments

  • Program Implementation The Work Control Process program will be established.

The commitment is identified in Appendix A, Table A6.0-1 License Renewal Commitments, Item 25.

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 4 of 38 The following pages replace LRA Appendix B, Section B2.1 .32, Work Control Process, in its entirety.

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 5 of 38 82.1.32 WORK CONTROL PROCESS Program Description The Work Control Process program will encompass two aging management programs:

(1) the One-Time Inspection program, consistent with NUREG-1801,Section XI.M32, "One-Time Inspection," and (2) the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (Internal Surfaces Monitoring) program, consistent (with the exception noted below) with NUREG-1801,Section XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components."

The One-Time Inspection program will manage the aging effects of cracking, loss of material, and reduction of heat transfer. The program inspections will, through inspections implemented in accordance with the work management process, provide verification of the effectiveness of the Primary Water Chemistry, Secondary Water Chemistry, Closed-Cycle Cooling Water System, Fuel Oil Chemistry, and Lubricating Oil Analysis programs where (a) an aging effect is not expected to occur but the data is insufficient to rule it out with reasonable confidence; (b) an aging effect is expected to progress very slowly in the specified environment, but the local environment may be more adverse than that generally expected; or (c) the characteristics of the aging effect include a long incubation period.

The one-time inspections will be performed using NDE techniques that have been determined to be effective for the identification of potential aging effects. The program will use a representative sampling approach to verify degradation is not occurring. The sample size and location for the one-time inspections will be established to ensure that the number and scope of the inspections are sufficient to provide reasonable assurance that the aging effects will not compromise the intended functions during the period of extended operation. Sample size and location will be based on an assessment of materials, environments, plausible aging effects, and operating experience.

The personnel performing these one-time inspections will be qualified to perform the applicable inspection in accordance with the station training program.

Unacceptable inspection findings identified by the one-time inspections will be documented in the Corrective Action Program. An engineering review will be performed to evaluate the condition and need for corrective actions. Potential corrective actions may include increasing sample size and locations, and additional monitoring of the system, structure, or component during the period of extended operation. The Corrective Action Program provides for monitoring and trending of inspection results.

The Internal Surfaces Monitoring program will manage the aging effects of change in material properties, cracking, hardening and loss of strength, loss of material, loss of sealing, loss of strength, and reduction of heat transfer for the in-scope structures and components through inspections implemented in accordance with the work management process.

The program will perform visual inspections of piping, piping components, ducting and other components fabricated of aluminum, copper alloys, stainless steel, and steel to detect loss of material, reduction of heat transfer, and cracking. Visual inspections will also manage the degradation of the paper filter elements in the Compressed Air

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 6 of 38 System. The program will include physical manipulation of elastomeric components as a supplement to the visual inspection to aid in detecting cracking, loss of sealing, hardening and loss of strength, and change in material properties. An enhanced VT-1 NDE examination will be performed to detect cracking of stainless steel diesel exhaust flexible connections.

Personnel performing maintenance activities on a component will perform the Internal Surfaces Monitoring program inspections of the internal surfaces (and in specific instances, external surfaces) of the component and adjacent surfaces to identify aging.

The maintenance process will require documentation of the inspection results, including when no signs of aging degradation are found, in order to perform meaningful trending of aging effects. The personnel performing the inspections will be trained to identify the effects of aging and provide acceptable documentation.

Degradation identified by the Internal Surfaces Monitoring program inspections will be documented in the Corrective Action Program. An engineering review will be performed to evaluate the condition and need for corrective actions. Potential corrective actions may include expanding the scope of inspections and additional monitoring of the affected structure or component during the period of extended operation.

The Internal Surfaces Monitoring program inspections will provide support for the "Bolting Integrity," "Compressed Air Monitoring," "Fire Protection," and "Open-Cycle Cooling Water System" programs for managing the components and supports within the scope of those programs.

NUREG-1801 Consistency The Work Control Process program is a new program that will be consistent with the recommendations of NUREG-1801,Section XI.M32, "One-Time Inspection," and consistent, with the exception noted below, with NUREG-1801,Section XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components."

Exceptions to NUREG-1801 Exception 1: XI.M38 - Additional Materials, Environments, and Aging Effects The Internal Surfaces Monitoring program will manage additional materials, environments, and aging effects not included in the NUREG-1801,Section XI.M38 program.

Justification The aging management reviews performed for Kewaunee identified additional materials, environments, and aging effects requiring aging management that were not addressed in the NUREG-1801,Section XI.M38, program. The Internal Surfaces Monitoring inspections will adequately manage the additional materials, environments, and aging effects combinations as discussed in Program Elements Affected below.

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 7 of 38 Program Elements Affected

  • Element 1: Scope of Program The NUREG-1801,Section XI.M38, program indicates that the scope of the program consists of steel piping, piping elements, ducting, and components in an internal environment (such as indoor uncontrolled air, condensation, and steam) for loss of material. The Internal Surfaces Monitoring program will also manage material, environment, and aging effect combinations that are not included in the NUREG-1801,Section XI.M38 program.

These additional materials, environments, and aging effects are listed in the table below, "Internal Surfaces Monitoring - Material, Environments, and Aging Effects."

Where indicated by Notes 1, 2, or 3 in the table, the additional material, environment, and aging effect combinations have been previously reviewed and accepted by the NRC for other nuclear plant license renewal applicants as an exception to the NUREG-1801,Section XI.M38 program.

Internal Surfaces Monitoring - Material, Environments, and Agin! Effects MATERIAL ENVIRONMENT AGING EFFECT NOTES Loss of material 1,2 Air-moist Aluminum Reduction of heat transfer 1 Air-outdoor Loss of material 4 Air-indoor Loss of material 2 uncontrolled Reduction of heat transfer 2 Air-moist Loss of material 2 Reduction of heat transfer 2 Copper Alloys Air-outdoor Loss of material 2 Loss of material 2,3 Raw water Reduction of heat transfer 2,3 Treated water-closed Loss of material 4 cycle cooling Air-indoor controlled Hardening and loss of strength 2 Change in material properties 2 Air-indoor Cracking 2 uncontrolled Loss of material 2 Elastomers Loss of sealing 2 Air-moist Hardening and loss of strength 5 Air-outdoor Loss of sealing 5 Raw water Hardening and loss of strength 5 Loss of material 5

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 8 of 38 Internal Surfaces Monitoring - Material, Environments, and Agim Effects MATERIAL ENVIRONMENT AGING EFFECT NOTES Non-Metallic Air-dried Loss of strength 6 (paper filter)

Air-indoor Loss of material 2 uncontrolled Air-moist Loss of material 1,2 Air-outdoor Loss of material 2 Stainless Cracking 3 Steel Diesel exhaust Loss of material 1,2,3 Raw water Loss of material 1,2 Treated water-closed Loss of material 4 cycle cooling Air-indoor Loss of material 4 uncontrolled Air-moist Loss of material 1,2,3 Steel Diesel exhaust Loss of material 1,2,3 Raw water Loss of material 1,2,3 Treated water-closed Loss of material 4 cycle cooling NOTES:

1. This Material, Environment, Aging Effect combination has been previously accepted ("Safety Evaiuation Report Related to the License Renewal of Beaver Vailey Power Station, Units 1 and 2," June 8, 2009, United States Nuclear Regulatory Commission.).
2. This Material, Environment, Aging Effect combination has been previously accepted ("Safety Evaluation Report Related to the License Renewal of Three Mile Island Nuclear Station Unit 1," June 30, 2009, United States Nuclear Regulatory Commission.).
3. This Material, Environment, Aging Effect combination has been previously accepted ("Safety Evaluation Report with Open Items Related to the License Renewai of Prairie Island Nuclear Generating Plant Units 1 and 2," June 4,2009, United States Nuclear Regulatory Commission.).
4. For metailic materials, visual inspection of component surfaces has been determined to be an acceptable method for managing loss of material in aluminum, copper ailoys, stainless steel, and steel exposed to various environments (see Notes 1, 2, and 3).

Loss of material in aluminum, copper ailoys, stainless steel, and steel components exhibit similar indications (i.e., localized discoloration and surface irreguiarities) regardiess of the environment. The visual inspection techniques implemented through the Internal Surfaces Monitoring program are capable of detecting ioss of material in these metals. Therefore, this material, environment, and aging effect combination will be effectively managed with the Internal Surfaces Monitoring program in a manner consistent with NUREG-1801,Section XI.M38.

5. For elastomeric materials, visual inspection of component surfaces, enhanced by physical manipulation where applicable, has been determined to be an acceptable method for managing hardening and loss of strength and loss of material in elastomers in indoor air environments (see Note 2). Elastomer-related aging effects of hardening and loss of strength, loss of material, and loss of sealing in outdoor air, moist air, and raw water environments exhibit similar indications, and can be identified through visual inspections, enhanced by physical manipuiation where applicable, through the Internal Surfaces Monitoring program.

Therefore, this material, environment, and aging effect combination wiil be effectively managed with the Internal Surfaces Monitoring program in a manner consistent with NUREG-1801,Section XI.M38.

6. For paper filter elements, visual inspections implemented through the Internal Surfaces Monitoring program are capabie of detecting loss of strength (e.g., tears, discoloration, loss of form, etc.). Therefore, this material, environment, aging effect combination will be effectively managed with the Internal Surfaces Monitoring program in a manner consistent with NUREG-1801,Section XI.M38.

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 9 of 38

  • Element 3: Parameters Monitored/Inspected The NUREG-1801,Section XI.M38, program states that the parameters monitored or inspected include visible evidence of corrosion to indicate possible loss of materials. As identified in the table "Internal Surfaces Monitoring - Material, Environments, and Aging Effects," the program manages the aging effects of change in material properties, cracking, hardening and loss of strength, loss of sealing, reduction of heat transfer, and loss of strength, in addition to the aging effect of loss of material.

The program monitors parameters directly related to degradation of plant components. The parameters monitored for each aging effect / material include:

Internal Surfaces Monitoring - Parameters Monitored AGING EFFECT / MATERIAL PARAMETER MONITORED Loss of Material Localized discoloration

  • Aluminum Surface irregularities
  • Rust
  • Stainless steel
  • Scale
  • Steel
  • Deposits
  • Surface pitting
  • Discontinuities
  • Coating degradation Reduction of Heat Transfer Fouling
  • . Aluminum Deposits
  • Copper Alloys Scale on tubes Cracking Cracks
  • Stainless steel (Diesel exhaust Discoloration flexible connection) Localized form of corrosion Surface irregularities Cracking, Change in Material Cracking and Crazing Properties, Hardening and Loss of Discoloration Strength and Loss of Sealing and Distortion Loss of Material Swelling
  • Elastomers Tackiness Resiliency Indentation Recovery Tears, Unusual Wear Leaks

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 10 of 38 Internal Surfaces Monitoring - Parameters Monitored AGING EFFECT / MATERIAL PARAMETER MONITORED Loss of Strength Tears

  • Non-Metallic (Paper) Material Degradation Discoloration Unusual Wear Loss of Form
  • Element 4: Detection of Aging Effects The NUREG-1801,Section XI.M38, program detects aging due to loss of material in steel components. As identified in the table "Internal Surfaces Monitoring -

Material, Environments, and Aging Effects," the Internal Surfaces Monitoring program manages the aging effects of change in material properties, cracking, hardening and loss of strength, loss of sealing, reduction of heat transfer, and loss of strength, in addition to loss of material.

The program will perform inspections of various component types and structural elements during surveillance and maintenance activities to provide for the detection of aging effects prior to the loss of intended function. The inspections are implemented in accordance with the work management process. Personnel performing maintenance activities on a component will perform visual inspections of the internal surfaces of the component and adjacent components and piping to identify aging. The external surfaces of selected elastomeric components will be inspected to identify aging. The maintenance process will require that the extent of the inspection and inspection results be documented even when no signs of aging degradation are found in order to allow meaningful trending of aging effects.

The visual inspection techniques are established and capable of detecting loss of material due to corrosion and reduction of heat transfer due to fouling. The presence of corrosion or fouling can be detected by the localized discoloration and surface irregularities such as rust, scale, deposits, surface pitting, surface discontinuities, and coating degradation. The metallic components including aluminum, copper alloys, and stainless steel would exhibit indications of loss of material similar to steel. Though no credit is taken for coatings in the prevention of the aging effects, visual inspections will detect degradation of paint or coatings as a possible indication of degradation of the underlying material.

Loss of strength of non-metallic paper filter elements can be detected by observing tears, material degradation, loss of form, and discoloration.

For elastomers, physical manipulation (Le., scratch, sniff, and stretch) is capable of detecting cracking, change in material properties, hardening, loss of strength, loss of sealing, and loss of material. These aging effects can be detected by the presence of cracking and crazing, discoloration, distortion, swelling, tackiness, or limited resiliency and indentation recovery. Inspection and detection methods that will be used for elastomeric components are identified in the table "Internal Surfaces Monitoring - Application of Physical Manipulation."

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 11 of 38 Internal Surfaces Monitoring - Application of Physical Manipulation PHYSICAL COMPONENTS NOTES MANIPULATION Flexible connections Yes 1 Hoses Yes 1 Flow element liner No 2 Gaskets for electrical boxes No 3 Spent Fuel Pool qate seals and hoses Yes 4 Reactor cavity seal rinq Yes 4 NOTES:

1. Accessible internal surfaces of the flexible connections and hoses will be visually inspected. The physical manipulation will be performed on the external surface.
2. Due to the physical layout of the component, only a visual inspection is possible.
3. Visual inspections will be performed to evaluate the condition of the gasket and to observe evidence of panel moisture intrusion. No physical manipulation will be performed.
4. Spent fuel pool gate seals and hoses and reactor cavity seal ring will be inspected prior to each installation. The physical manipulation will be performed on the external surface.

NDE examinations (enhanced VT-1 or equivalent) will be performed to manage cracking due to stress corrosion cracking of the stainless steel diesel generator exhaust. As indicated in NUREG-1801,Section XI.M32, "One-Time Inspection,"

the enhanced VT-1 examination is an acceptable method of detection for SCC cracking.

The Internal Surfaces Monitoring program inspections will provide equivalent aging management for the additional material/aging effect combinations as the NUREG-1801,Section XI.M38, program does for the steel/loss of material combination.

  • Element 6: Acceptance Criteria The NUREG-1801,Section XI.M38, program identifies acceptance criteria for corrosion mechanisms resulting in loss of material. As identified in the table "Internal Surfaces Monitoring -- Material, Environments, and Aging Effects," the Internal Surfaces Monitoring program manages the aging effects of change in material properties, cracking, hardening and loss of strength, loss of sealing, reduction of heat transfer, and loss of strength, in addition to loss of material.

Indications or relevant conditions of degradation not meeting acceptance criteria (i.e., no unacceptable wear, corrosion, cracking, change in material properties for elastomers, or fouling) are reported and submitted for further evaluation as a part of the Corrective Action Program and these evaluations are performed against acceptance criteria which ensure that the structure or component intended function(s) will be maintained under current licensing basis design conditions during the period of extended operation. The quantitative or qualitative acceptance criteria are contained in design standards, design codes, and manufacturer information or vendor manuals for some individual components. In the event that

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 12 of 38 acceptance criteria information is not available in these sources, an engineering review process is used to establish specific acceptance criteria.

The Internal Surfaces Monitoring program will provide acceptance criteria for the additional material/aging effect combinations equivalent to the acceptance criteria provided by the NUREG-1801,Section XI.M38, program for the steel/loss of material combination.

Enhancements The Work Control Process program is a new program that will be consistent with the recommendations of NUREG-1801,Section XI.M32, "One-Time Inspection," and NUREG-1801,Section XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components."

This commitment is identified in Appendix A, Table A6.0-1 License Renewal Commitments, Item 25.

Operating Experience The Work Control Process program is a new program. Therefore, no programmatic experience is available. As operating experience is obtained, lessons learned will be used to adjust this program as needed.

However, inspections have been performed and documented during the performance of applicable surveillance and preventive maintenance procedures. These inspections represent operating experience, which is applicable to the Internal Surfaces Monitoring program. The following representative examples of this operating experience are based on a review of Corrective Action items identified during the implementation of these procedures:

  • In April 2002, Maintenance personnel were replacing the fire protection jockey pump discharge relief valve and identified the adjacent piping was approximately 90% blocked with rust-like debris. Additionally, it was identified that a nearby pipe nipple was corroded and reqUired replacement. The work order instructions were revised, the piping was cleaned, and the welded nipple was replaced.
  • In April 2008, a detailed inspection of a service water valve revealed that the disc guides in the valve body were eroded. The inspection was performed in response to a work order written in 2006 when poor valve seat contact was visually noted during service water pipe replacement. It was noted in 2006 that the seat conditions would probably cause the valve to weep. Visual inspection of the valve at that time indicated the valve would continue to perform its isolation function. As a result of the 2008 inspection, it was determined that the guides could not be repaired and the valve was replaced.
  • In April 2008, during an overhaul of the 'B' Component Cooling Water pump, the lower pump casing was found to have an area of material loss on the outboard wear ring casing groove land. It was determined that the condition appeared to have developed over a long period of time, most likely since the pump was installed in October 2001. A review of operating experience did not identify any horizontal pumps with similar conditions. As part of the extent of condition review, the historical operating performance of the 'A' and 'B' Component Cooling Water

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 13 of 38 pumps was reviewed. The results indicated that these pumps were operating at or near the reference vibration levels and hydraulic performance values that were established when the pumps were initially installed. Periodic performance testing (vibrations and hydraulic performance) of the 'B' Component Cooling Water pump is being performed to validate the continued operability of the pump.

The Operating Experience Program ensures that additional operating experience is factored into the aging management programs to ensure program effectiveness.

Conclusion The Work Control Process program ensures that the effects of aging associated with the in-scope components will be adequately managed so that there is reasonable assurance that their intended functions will be maintained consistent with the current licensing basis throughout the period of extended operation.

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 14 of 38 The following provides the changes to LRA commitments related to the Work Control Process program in LRA Appendix A, Table A6.0-1, License Renewal Commitments.

Item Commitment Source Schedule 25 The Work Control Process program Work Control Prior to the Period will be established. The program will Process of Extended perform one-time inspections as a Operation verification of the effectiveness of chemistry control programs. The program will also perform visual inspections of component internal surfaces. and external surfaces of selected components. to manage the effects of aging when the surfaces are made available for examination through surveillance and maintenance activities.

enhanced to provide additional guidance for documenting the "As Found" equipment conditions \Nith sufficient detail to support monitoring and trending of aging effects.

26 Deleted. The Work Control Prooess VVork Control Prior to the Period program will be enhanced to Process of Extended perform visual inspections to assess Operation the aging of the items that require

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27 Deleted. The V'lork Control Prooess 'Nork Control Prior to the Period program \,vill be enhanced to Process of Extended provide additional focused training Operation for the personnel performing the program inspections. The training

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Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 15 of 38 Part B: LRA Section 3 changes The following tables provide a summary listing and revision of the aging management review results that initially credited the Work Control Process program in lieu of the NUREG-1801 recommended aging management programs for the selected NUREG-1801, Volume 2 Reference Item.

The revisions to the LRA Section 3 Tables 3.x-1 (Table 1) and Tables 3.x.2-y (Table 2)

(see LRA Section 3.0 for Table Usage terminology and description) are submitted as a result of eliminating the association to a NUREG-1801, Volume 2 Reference Item in Table 2. The affected rows in Table 2 have been determined to be more appropriately identified as plant-specific material and environment aging as indicated by the application of the Industry Standard Footnote "H" in the Notes column of the revised table rows. See LRA Section 3.0, Aging Management Review Results, under the heading Table 2 for additional information related to plant-specific material and environment aging determinations.

As a result of the Table 2 changes, the associated Table 1 Item discussions also required revision to address these changes.

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 16 of 38 Chanqes to LRA Tables 3.x-1 (Table 1)

Aging Further Item Aging Effect I Management Evaluation Number Component Mechanism Program Required Discussion Table 3.2.1 Summary of Aging Management Programs for Engineered Safety Features Evaluated in Chapter V of NUREG-1801 3.2.1-37 Stainless steel piping, Loss of material due to Open-Cycle No Loss of material due to pitting, orevioe, and piping components, and pitting, crevice, and Cooling Water miorobiologioally influenoed oorrosion for the stainless piping elements exposed microbiologically- System steel piping from the Reaoter Containment Vessel sump to raw water influenced corrosion to the safety injeotion pumps that is el<posed to raw water is managed by the 'Norl< Control Prooess program, whioh is a plant speoifio program.

NUREG-1801 item is not applicable.

3.2.1-39 Stainless steel heat Loss of material due to Open-Cycle No Loss of material due to pitting, orevioe, and exchanger components pitting, crevice, and Cooling Water miorobiologioally influenoed oorrosion, and fouling for exposed to raw water microbiologically- System stainless steel heat el<ohangers Q)(posed to ray.' water is influenced corrosion, and managed by the Worl< Control Prooess program, whioh fOUling is a plant speoifio program.

NUREG-1801 item is not applicable.

Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1801 3.3.1-47 Steel piping, piping Loss of material due to No Loss of material due to general, pitting, and crevice components, piping general, pitting, and Closed-Cycle corrosion of steel piping, piping components, piping elements, tanks, and crevice corrosion Cooling Water elements, and tanks exposed to closed cycle cooling heat exchanger System water is managed by the Closed-Cycle Cooling Water components exposed to System program, which takes exception to the NUREG-closed cycle cooling 1801 AMP, and the Work Control Process program, water whioh is a plant speoifio program.

Loss of material due to general, pitting, and crevice corrosion of steel components in the TSC diesel generator cooling water subsystem is managed by the Work Control Process program, whioh is a plant speoifio

~.

3.3.1-50 Stainless steel piping, Loss of material due to Closed-Cycle No Loss of material due to pitting and crevice corrosion of piping components, and pitting and crevice Cooling Water stainless steel piping, piping components, and piping piping elements exposed corrosion System elements exposed to cycle cooling water is managed by to closed cycle cooling the Closed-Cycle Cooling Water System program, which water takes exception to the NUREG-1801 AMP, and the Work Control Process program, whioh is a plant speoifio

~.

Loss of material due to pitting and crevice corrosion of stainless steel components in the TSC diesel generator cooling water subsystem is managed by the Work Control Process program, whioh is a plant speoifio

~.

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 17 of 38 Chan~es to LRA Tables 3.x-1 (Table 1)

Aging Further Item Aging Effect I Management Evaluation Number Component Mechanism Program Required Discussion 3.3.1-51 Copper alloy piping, Loss of material due to Closed-Cycle No Loss of material due to pitting, crevice, and galvanic piping components, pitting, crevice, and Cooling Water corrosion of copper alloy piping, piping components, piping elements, and galvanic corrosion System piping elements, and heat exchanger components heat exchanger exposed to closed cycle cooling water is managed by components exposed to the Closed-Cycle Cooling Water System program, which closed cycle cooling takes exception to the NUREG-1801 AMP, and the water Work Control Process program, '""hioh is a plant speoifio f*e§fflffi.

Loss of material due to pitting, crevice, and galvanic corrosion of copper alloy components in the TSC diesel generator cooling water subsystem is managed by the Work Control Process program, whioh is a plant speoifio f*e§fflffi.

3.3.1-53 Steel compressed air Loss of material due to Compressed Air No Loss of material due to general and pitting corrosion of system piping, piping general and pitting Monitoring steel compressed air system piping, piping components, components, and piping corrosion and piping elements exposed to condensation is elements exposed to managed by the Compressed Air Monitoring program, condensation (internal) which takes exception to the NUREG-1801 AMP.

Loss of material due to general and pitting oorrosion of steel traps in the Station and Instrument Air System is managed by the "Nork Control Prooess program, whioh is a plant speoifio program.

3.3.1-54 Stainless steel Loss of material due to Compressed Air No Loss of material due to pitting and crevice corrosion of compressed air system pitting and crevice Monitoring stainless steel piping, piping components, and piping piping, piping corrosion elements is managed by the Compressed Air Monitoring components, and piping program, which takes exception to the NUREG-1801 elements exposed to AMP.

internal condensation Loss of material due to pitting and oravioe oorrosion of stainless steel piping, piping oomponents, and piping elements exposed to internal oondensation in systems not within the soope of the Compressed Air Monitoring program is managed by the Worl< Control Prooess program, whioh is a plant speoifio program.

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 18 of 38 Chan~es to LRA Tables 3.x-1 (Table 1)

Aging Further Item Aging Effect I Management Evaluation Number Component Mechanism Program Required Discussion 3.3.1-58 Steel external surfaces Loss of material due to External Surfaces No Loss of material due to general corrosion of steel exposed to air - indoor general corrosion Monitoring external surfaces exposed to air - indoor uncontrolled, uncontrolled (external), air - outdoor, and condensation is managed by the air - outdoor (external), External Surfaces Monitoring program.

and condensation Loss of material due to geneFaI eorrosion of the TSC air (external) eonditioning oompressor and the potable "vater nozzles that are exposed to air indoor unoontrolled are managed by the 'Nork Control Prooess program, whioh is a plant speoifio program.

3.3.1-68 Steel piping, piping Loss of material due to Fire Water System No Loss of material due to general, pitting, crevice, and components, and piping general, pitting, crevice, microbiologically influenced corrosion, and fouling of elements exposed to raw and microbiologically steel piping, piping components, and piping elements in water influenced corrosion, and the Fire Protection System exposed to raw water is fouling managed by the Fire Protection program.

The Fire Protection program encompasses the recommendations of NUREG-1801,Section XI.M2, "Fire Protection", with exceptions, and NUREG-1801,Section XI.M27, "Fire Water System".

Loss of material due to general, pitting, crevice, and microbiologically influenced corrosion, and fouling of steel piping, piping oomponents, and piping elements pumps exposed to raw water in systems other than the Fire Protection System is managed by the VVork Centrol Proeess progFam, .....hioh is a plant speeifio progFam, or tRe External Surfaces Monitoring program.

3.3.1-75 Elastomer seals and Hardening and loss of Open-Cycle No Hardening and loss of strength due to elastomer components exposed to strength due to elastomer Cooling Water degFadation; loss of material due to erosion of elastomer raw water degradation; loss of System seals and oomponents exposed to Fa\\! water are material due to erosion managed by the VVorl< Control Prooess program, whioh is a plant speoifio program.

NUREG-1801 item is not applicable.

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 19 of 38 Chanqes to LRA Tables 3.x-1 (Table 1)

Aging Further Item Aging Effect I Management Evaluation Number Component Mechanism Program Required Discussion 3.3.1-76 Steel piping, piping Loss of material due to Open-Cycle No Loss of material due to general, pitting, crevice, and components, and piping general, pitting, crevice, Cooling Water microbiologically influenced corrosion and fouling of elements (without and microbiologically System safety-related steel piping, piping components, and lining/coating or with influenced corrosion, piping elements exposed to raw water is managed by degraded lining/coating) fouling, and lining/coating the Open-Cycle Cooling Water System program, which exposed to raw water degradation takes exception to the NUREG-1801 AMP.

Loss of material due to general, pitting, crevice, and microbiologically influenced corrosion and fouling of non-safety-related steel traps piping, piping oomponents, and piping elements exposed to raw water is managed by the Worl( Control Prooess program, whioh is a plant speoifio program, and the Compressed Air Monitoring program.

3.3.1-77 Steel heat exchanger Loss of material due to Open-Cycle No Loss of material due to general, pitting, crevice, components exposed to general, pitting, crevice, Cooling Water galvanic, and microbiologically influenced corrosion, and raw water galvanic, and System fouling of safety-related steel heat exchanger microbiologically components exposed to raw water is managed by the influenced corrosion, and Open-Cycle Cooling Water System program, which fouling takes exception to the NUREG-1801 AMP.

Loss of material due to general, pitting, orevioe, galvanio, and miorobiologioally influenoed oorrosion, and fouling of non safety related steel heat exohanger oomponents exposed to raw water is managed by the VVorl( Control Prooess program, whioh is a plant speoifio program.

3.3.1-78 Stainless steel, nickel Loss of material due to Open-Cycle No Loss of material due to pitting and crevice corrosion of alloy, and copper alloy pitting and crevice Cooling Water safety-related stainless steel piping, piping components, piping, piping corrosion System and piping elements exposed to raw water is managed components, and piping by the Open-Cycle Cooling Water System program, elements exposed to raw which takes exception to the NUREG-1801 AMP.

water Loss of material due to pitting and orevioe oorrosion of non safety related stainless steel piping, piping oomponents, and piping elements exposed to raw water is managed by the V'lorl( Control Prooess program,

'",hioh is a plant speoifio program.

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 20 of 38 Changes to LRA Tables 3.x-1 (Table 1)

Aging Further Item Aging Effect I Management Evaluation Number Component Mechanism Program Required Discussion 3.3.1-79 Stainless steel piping, Loss of material due to Open-Cycle No Loss of material due to pitting and crevice corrosion, piping components, and pitting and crevice Cooling Water and fouling of safety-related stainless steel piping, piping elements exposed corrosion, and fouling System piping components, and piping elements exposed to raw to raw water water is managed by the Open-Cycle Cooling Water System program, which takes exception to the NUREG-1801 AMP.

and fouling of non s f piping somponents t ~e~ated Loss of material due to itti

lthe~~ln~

.

ng and crevice corrosion stainless steel pipi~g

.....ater is managed by ~Iements exposed to r~.,..

program, which is I n or<.. ontrol Process a p ant speCIfic program.

3.3.1-80 Stainless steel and Loss of material due to Open-Cycle No Loss of material due to pitting, crevice, and copper alloy piping, pitting, crevice, and Cooling Water microbiologically influenced corrosion of stainless steel piping components, and microbiologically System piping, piping components, and piping elements piping elements exposed influenced corrosion exposed to raw water is managed by the VVorl< Control to raw water Prosess program, '....hich is a plant specific program, or the Structures Monitoring Program.

3.3.1-81 Copper alloy piping, Loss of material due to Open-Cycle No Loss of material due to pitting, crevice, and piping components, and pitting, crevice, and Cooling Water microbiologically influenced corrosion, and fouling of piping elements, microbiologically System safety-related copper alloy piping, piping components, exposed to raw water influenced corrosion, and and piping elements, exposed to raw water is managed fouling by the Open-Cycle Cooling Water System program, which takes exception to the NUREG-1801 AMP.

Loss of material due to pitting, crevice, and microbiologically influensed sorrosion, and fouling of non safety related sopper alloy piping, piping components, and piping elements, exposed to raw

'....ster is managed by the 'Norl< Control Prosess program, whish is a plant specific program.

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 21 of 38 Chanaesto LRA Tables 3.x-1 (Table 1)

Aging Further Item Aging Effect I Management Evaluation Number Component Mechanism Program Required Discussion 3.3.1-82 Copper alloy heat Loss of material due to Open-Cycle No Loss of material due to pitting, crevice, galvanic, and exchanger components pitting, crevice, galvanic, Cooling Water microbiologically influenced corrosion, and fouling of exposed to raw water and microbiologically System safety-related copper alloy heat exchanger components influenced corrosion, and exposed to raw water is managed by the Open-Cycle fouling Cooling Water System program, which takes exception to the NUREG-1801 AMP.

Loss of material due to pitting, crevice, galvanic, and microbiologically influenced corrosion, and fouling of non safety related copper alloy heat mmhanger oomponents exposed to ra'.... water is managed by the VVork Control Process program, whioh is a plant speoifio Fn;,I"3T u;rTI.

3.3.1-83 Stainless steel and Reduction of heat transfer Open-Cycle No Reduction of heat transfer due to fouling of safety-copper alloy heat due to fouling Cooling Water related copper alloy heat exchanger tubes exposed to exchanger tubes System raw water is managed by the Open-Cycle Cooling Water exposed to raw water System program, which takes exception to the NUREG-1801 AMP.

Reduotion of heat transfer due to fouling of non safety related oopper alloy heat exohanger tubes exposed to ra'.... '....a ter is managed by the Work Control Prooess program, whioh is a plant speoifio program.

Table 3.4.1 Summary of Aging Management Programs for Steam and Power Conversion System Evaluated in Chapter VIII of NUREG-1801 3.4.1-24 I Steel heat exchanger Loss of material due to Closed-Cycle No Loss of material due to general, pitting, orevice, and components exposed to general, pitting, crevice, Cooling Water galvanio corrosion for applicable oomponents exposed closed cycle cooling and galvanic corrosion System to a olosed cycle cooling water environment is managed water by the 'Piork Control Prooess program, which is a plant specifio program.

NUREG-1801 item is not applicable.

3.4.1-25 Stainless steel piping, Loss of material due to Closed-Cycle No Loss of material due to pitting and orevioe oorrosion for piping components, pitting and crevice Cooling Water applioable oomponents exposed to a olosed oyole piping elements, and corrosion System oooling '....ater environment is managed by the lJIiork heat exchanger Control Prooess program, '....hich is a plant speoifio components exposed to r-'.>Jt:f ......'.,.

closed cycle cooling NUREG-1801 item is not applicable.

water

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 22 of 38 ChanQes to LRA Tables 3.x-1 (Table 1)

Aging Further Item Aging Effect I Management Evaluation Number Component Mechanism Program Required Discussion 3.4.1-26 Copper alloy piping, Loss of material due to Closed-Cycle No Loss of material due to pitting, ereviee, and gal'Janie piping components, and pitting, crevice, and Cooling Water eorrosion for applieable eomponents exposed to a piping elements exposed galvanic corrosion System elosed sysle sooling water environment is managed by to closed cycle cooling the 'l'lorl< Control Prosess program, whieh is a plant water speeifie program.

NUREG-1801 item is not applicable.

3.4.1-31 Steel heat exchanger Loss of material due to Open-Cycle No Loss of material due to general, pitting, Grevise, components exposed to general, pitting, crevice, Cooling Water galvanie, mierobiologisally influeneed eorrosion, and raw water galvanic, and System fouling is managed by the Worl< Control Proeess microbiologically- program, 'Nhish is a plant speeifie program.

influenced corrosion, and NUREG-1801 item is not applicable.

fouling 3.4.1-32 Stainless steel and Loss of material due to Open-Cycle No Loss of material due to pitting, ereviee, and copper alloy piping, pitting, crevice, and Cooling Water mierobiologieally influensed eorrosion is managed by piping components, and microbiologically- System the Worl< Control Proeess program, whieh is a plant piping elements exposed influenced corrosion spesifis program.

to raw water NUREG-1801 item is not applicable.

Table 3.5.1 Summary of Aging Management Programs for Structures and Component Supports Evaluated in Chapters II and III of NUREG-1801 3.5.1-44 I Group 6 elastomer seals, I Loss of sealing due to Structures No Loss of sealing of elastomer seals and gaskets due to gaskets, and moisture deterioration of seals, Monitoring Program deterioration is managed by the Worl< Control Proeess barriers gaskets, and moisture program, '....hish is a plant speeifie program, the barriers (caUlking, Structures Monitoring Program, and Fire Protection flashing, and other programs. The Fire Protection program takes exception sealants) to the NUREG-1801 AMP.

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 23 of 38 ChanQes to LRA Table 3.x.2-v (Table 2)

Component Material Environment Aging Effect I Mechanism Aging NUREG-1801 Table 1 Item Notes LRA Page Type Management Vol. 2 Number Program Reference Table 3.2.2-2: Engineering Safety Features - Safety Injection - Aging Management Evaluation Pipe Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He;2 3-192 Steel microbiologically influenced Process corrosion Table 3.3.2-3: Auxiliary Systems - Spent Fuel Pool Cooling - Aging Management Evaluation I

Spent Fuel Pool Steel Raw water Loss of material/general, pitting, Work Control A-004 ~ He 3-324 Heat Exchanger crevice, galvanic, and Process Shell microbiologically influenced corrosion, and foulina Spent Fuel Pool Stainless Raw water Loss of material/pitting, crevice, and Work Control E-OOG ~ He 3-324 Heat Exchanger Steel microbiologically influenced Process Tubes corrosion, and foulin~

Spent Fuel Pool Stainless Raw water Loss of material/pitting, crevice, and Work Control E-OOG ~ He 3-325 Heat Exchanger Steel microbiologically influenced Process Tubesheet corrosion, and foulin~

Table 3.3.2-6: Auxiliary Systems - Service Water - Aging Management Evaluation Filter Housings Stainless Raw water Loss of material/pitting and crevice Work Control VII.C1 15 ~ He 3-331 SWto Steel corrosion, and fouling Process chlorination pumps Flexible Hoses Stainless Raw water Loss of material/pitting and crevice Work Control VII.C1 15 ~ He 3-332 Steel corrosion, and foulin~ Process Flow Switches Copper Raw water Loss of material/pitting, crevice, and Work Control VII.C1 09 &-&1--8 He;4 3-333 Alloys microbiologically influenced Process corrosion, and foulin~

Orifices Stainless Raw water Loss of material/pitting and crevice Work Control VII.C1 15 ~ He;4 3-333 Steel corrosion, and fouling Process Pipe Copper Raw water Loss of material/pitting, crevice, and Work Control VII.C1 09 &-&1--8 He;3;4 3-334 Alloys microbiologically influenced Process corrosion, and foulin~

Sight Flow Copper Raw water Loss of material/pitting, crevice, and Work Control VII.C109 &-&1--8 He;4 3-337 Indicators Alloys microbiologically influenced Process corrosion, and foulin~

Standpipes Steel Raw water Loss of material/general, pitting, Work Control VII.C1 19 ~ He;4;5 3-338 crevice, and microbiologically Process influenced corrosion, fouling, and linina-coating degradation Strainer Copper Raw water Loss of material/pitting, crevice, and Work Control VII.C1 09 &-&1--8 He;4 3-339 Housings Alloys microbiologically influenced Process corrosion, and foulin~

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 24 of 38 ChanQes to LRA Table 3.x.2-v (Table 2)

Component Material Environment Aging Effect / Mechanism Aging NUREG-1801 Table 1 Item Notes LRA Page Type Management Vol. 2 Number ProQram Reference Strainer Steel Raw water Loss of material/general, pitting, Work Control '1II.C1 19 ~ H;4;5 3-339 Housings crevice, and microbiologically Process influenced corrosion, fouling, and lininq-coatinq deqradation Tubing Copper Raw water Loss of material/pitting, crevice, and Work Control VII.C1 09 ~ H;4 3-340 Alloys microbiologically influenced Process corrosion, and fouling Tubing Stainless Raw water Loss of material/pitting and crevice Work Control '1II.C1 Hi ~ H;4 3-340 Steel corrosion, and foulinq Process Tubing Steel Raw water Loss of material/general, pitting, Work Control '1II.C1 19 ~ H;4;5 3-341 crevice, and microbiologically Process influenced corrosion, fouling, and lininq-coatinq deqradation Valves Copper Raw water Loss of material/pitting, crevice, and Work Control '1II.C1 09 ~ H;4 3-341 Alloys microbiologically influenced Process corrosion, and fouling Valves Stainless Raw water Loss of material/pitting and crevice Work Control '1II.C1 15 ~ H;4 3-342 Steel corrosion, and foulinq Process Valves Steel Raw water Loss of material/general, pitting, Work Control '1II.C1 19 ~ H;4;5 3-342 crevice, and microbiologically Process influenced corrosion, fouling, and lininq-coatinq deqradation Table 3.3.2-8: Auxiliary Systems - Station and Instrument Air - AQinQ ManaQement Evaluation Aftercoolers Steel Raw water Loss of material/general, pitting, Work Control A-004 ~ H 3-356 Shell crevice, galvanic, and Process microbiologically influenced corrosion, and foulinq Aftercoolers Copper Raw water Loss of material/pitting, crevice, Work Control A-W§ ~ H 3-357 Tubes Alloys galvanic, and microbiologically Process influenced corrosion, and foulinq Aftercoolers Copper Raw water Reduction of heat transfer/fouling Work Control A-G7'd ~ H 3-357 Tubes Alloys Process Aftercoolers Steel Raw water Loss of material/general, pitting, Work Control A-004 ~ H 3-357 Tubesheets crevice, galvanic, and Process microbiologically influenced corrosion, and fouling Compressors Steel Raw water Loss of material/general, pitting, Work Control A-Qdg ~ H;3 3-358 Housing crevice, and microbiologically Process influenced corrosion, fouling, and lining-coating degradation Traps Steel Air-moist Loss of material/general and pitting Work Control ~ ~ H 3-366 corrosion Process

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 25 of 38 ChanCies to LRA Table 3.x.2-v (Table 2)

Component Material Environment Aging Effect / Mechanism Aging NUREG*1801 Table 1 Item Notes LRA Page Type Management Vol. 2 Number Proaram Reference Traps Steel Raw water Loss of material/general, pitting, Work Control A-GdS ~ H;3 3-366 crevice, and microbiologically Process influenced corrosion, fouling, and lininq-coatina dearadation Table 3~-9: Auxiliary Systems - Chemical and Volume Control - Aging Manaaement Evaluation Boric Acid Steel Raw water Loss of material/general, pitting, Work Control A-W4 ~ H 3-371 Evaporator crevice, galvanic, and Process Distillate microbiologically influenced Sample Cooler corrosion, and fOUling Shell Boric Acid Stainless Raw water Loss of material/pitting, crevice, and Work Control E-GaG ~ H 3-372 Evaporator Steel microbiologically influenced Process Distillate corrosion, and fouling Sample Cooler Tubinq Table 3.3.2-13: Auxiliary Systems - Auxiliary Buildina Ventilation - AainCi Manaaement Evaluation Fan Coil Units Steel Raw water Loss of material/general, pitting, Work Control A-Gd3 ~ H 3-429 Drip Pans crevice, and microbiologically Process influenced corrosion, and foulina Table 3.3.2-14: Auxiliarv Svstems* Reactor Buildina Ventilation - Aaina Manaaement Evaluation Containment Stainless Raw water Loss of material/pitting and crevice Work Control A-Ged ~ H 3-435 Fan Coil Units Steel corrosion Process Drip Pan Drip Pans Steel Raw water Loss of material/general, pitting, Work Control A-Gd3 ~ H 3-435 Shroud Cooling crevice, and microbiologically Process Coils influenced corrosion, and foulinq Pipe Stainless Raw water Loss of material/pitting and crevice Work Control A-Ged ~ H;3 3-438 Steel corrosion Process Table 3.3.2-15: Auxiliary Systems - Turbine Buildina and Screenhouse Ventilation - Aaina Manaaement Evaluation Fan Coil Units Copper Raw water Loss of material/pitting, crevice, Work Control A-Gee ~ H;4 3-443 Cooling Alloys galvanic, and microbiologically Process Coils/Fins influenced corrosion, and foulina Fan Coil Units Copper Raw water Reduction of heat transfer/fouling Work Control ~ ~ H;4 3-443 Cooling Alloys Process Coils/Fins Fan Coil Units Steel Raw water Loss of material/general, pitting, Work Control A-Gd3 ~ H 3-444 Drip Pans crevice, and microbiologically Process influenced corrosion, and foulina Table 3.3.2-17: Auxiliary Systems - Technical SUDDort Center Ventilation - Aaina Manaaement Evaluation Air Conditioning Steel Air-indoor Loss of material/general corrosion Work Control .IJl.h+.W ~ H 3-451 Units uncontrolled Process Compressor

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 26 of 38 ChanQes to LRA Table 3.x.2-v (Table 2)

Component Material Environment Aging Effect I Mechanism Aging NUREG-1801 Table 1 Item Notes LRA Page Type Management Vol. 2 Number Program Reference Air Conditioning Steel Raw water Loss of material/general, pitting, Work Control A-OOd ~ H 3-451 Units crevice, and microbiologically Process Condenser Drip influenced corrosion, and fouling Pan Air Handling Steel Raw water Loss of material/general, pitting, Work Control A-OOd ~ H 3-452 Units Battery crevice, and microbiologically Process Room Coil Drip influenced corrosion, and fouling Pan Table 3.3.2-18: Auxiliary Systems - Fire Protection - AQinQ ManaQement Evaluation Flexible Hoses Stainless Air-moist Loss of material/pitting and crevice Work Control AJ2..OO.:l- ~ H 3-460 Steel corrosion Process Tubing Stainless Air-moist Loss of material/pitting and crevice Work Control AJ2..OO.:l- ~ H 3-466 Steel corrosion Process Valves Stainless Air-moist Loss of material/pitting and crevice Work Control AJ2..OO.:l- ~ H 3-469 Steel corrosion Process Table 3.3.2-19: Auxiliarv Svstems - Diesel Generator - Aging Management Evaluation Flexible Stainless Treated water- Loss of material/pitting and crevice Work Control ~ ~ H;1;3 3-479 Connections Steel closed cycle corrosion Process includes cooling braided hoses Pipe Steel Raw water Loss of material/general, pitting, Work Control '111.1=1222 ~ H;2;4;8 3-485 crevice, and microbiologically Process influenced corrosion, fOUling, and linina-coatina dearadation Pumps Jacket Steel Treated water- Loss of material/general, pitting, Work Control '11l.1=122d ~ H;1;3;5 3-486 water cooling closed cycle and crevice corrosion Process cooling Radiator Tubes Copper Treated water- Loss of material/pitting, crevice, and Work Control '11l.1=120g ~ H;1;3 3-487 Alloys closed cycle galvanic corrosion Process coolinQ Sight Glass Stainless Treated water- Loss of material/pitting and crevice Work Control ~ ~ H;1;3 3-488 Steel closed cycle corrosion Process coolinQ Table 3.3.2-20: Auxiliary Systems - Circulating Water - Aging Management Evaluation Chlorine Steel Raw water Loss of material/general, pitting, Work Control '11l.Cd 10 ~ H;5 3-499 Monitoring crevice, and microbiologically Process Water Pump influenced corrosion, fouling, and IininQ-coatinQ deQradation Circulating Steel Raw water Loss of material/general, pitting, Work Control '111.Cd 10 ~ H;5 3-499 Water Pumps crevice, and microbiologically Process influenced corrosion, fOUling, and linina-coatina dearadation

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 27 of 38 ChanQes to LRA Table 3.x.2-v (Table 2)

Component Material Environment Aging Effect / Mechanism Aging NUREG-1801 Table 1 Item Notes LRA Page Type Management Vol. 2 Number Program Reference Condensers Steel Raw water Loss of material/general, pitting, Work Control Vll.Cd 10 ~ H;5 3-500 Waterboxes crevice, and microbiologically Process influenced corrosion, fouling, and linina-coatinq deqradation Flow Elements Stainless Raw water Loss of material/pitting and crevice Work Control Vll.Cd 07 ~ H 3-500 Steel corrosion Process Flow Indicators Copper Raw water Loss of material/pitting, crevice, and Work Control A-044 ~ H 3-501 Alloys microbiologically influenced Process corrosion, and foulina Flow Indicators Stainless Raw water Loss of material/pitting and crevice Work Control Vll.Cd 07 ~ H 3-501 Steel corrosion Process Pipe Stainless Raw water Loss of material/pitting and crevice Work Control Vll.Cd 07 ~ H 3-502 Steel corrosion Process Pipe Steel Raw water Loss of material/general, pitting, Work Control Vll.Cd 10 ~ H;4;5 3-503 crevice, and microbiologically Process influenced corrosion, fouling, and Iinina-coatina dearadation Recirculating Steel Raw water Loss of material/general, pitting, Work Control Vll.Cd 10 ~ H;5 3-503 Water Pump crevice, and microbiologically Process influenced corrosion, fouling, and Iining-coatina dearadation Tubing Copper Raw water Loss of material/pitting, crevice, and Work Control A-044 ~ H 3-504 Alloys microbiologically influenced Process corrosion, and foulina Tubing Stainless Raw water Loss of material/pitting and crevice Work Control Vll.Cd 07 ~ H 3-504 Steel corrosion Process Tubing Steel Raw water Loss of material/general, pitting, Work Control Vll.Cd 10 ~ H;5 3-504 crevice, and microbiologically Process influenced corrosion, fouling, and lining-coating degradation Valves Copper Raw water Loss of material/pitting, crevice, and Work Control A-044 ~ H 3-504 Alloys microbiologically influenced Process corrosion, and foulina Valves Stainless Raw water Loss of material/pitting and crevice Work Control Vll.Cd 07 ~ H;4 3-505 Steel corrosion Process Valves Steel Raw water Loss of material/general, pitting, Work Control Vll.Cd 10 ~ H;5 3-505 crevice, and microbiologically Process influenced corrosion, fouling, and Iininq-coating degradation Table 3.3.2-21: Auxiliary Systems - Gaseous Waste Processing and Discharge - Aging Management Evaluation Filter Housings Stainless Air-moist Loss of material/pitting and crevice Work Control Ai2-Q8.1. ~ H 3-507 Steel corrosion Process

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 28 of 38 ChanQes to LRA Table 3.x.2-v (Table 2)

Component Material Environment Aging Effect / Mechanism Aging NUREG-1801 Table 1 Item Notes LRA Page Type Management Vol. 2 Number Program Reference Heat Steel Raw water Loss of material/general, pitting, Work Control A-Qdd ~ HE 3-508 Exchangers crevice, and microbiologically Process Shell influenced corrosion, and foulinq Heat Copper Raw water Loss of material/pitting, crevice, and Work Control A-Q44 ~ HE 3-509 Exchangers Alloys microbiologically influenced Process Tubes corrosion, and foulinq Heat Steel Raw water Loss of material/general, pitting, Work Control A-Qdd ~ HE 3-509 Exchangers crevice, and microbiologically Process Tubesheet influenced corrosion, and fouling Moisture Steel Raw water Loss of material/general, pitting, Work Control A-Qdd ~ HE 3-510 Separators crevice, and microbiologically Process influenced corrosion, and foulinq Orifices Stainless Air-moist Loss of material/pitting and crevice Work Control MLW+ ~ HE 3-510 Steel corrosion Process Orifices Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ HE 3-510 Steel microbiologically influenced Process corrosion Pipe Stainless Air-moist Loss of material/pitting and crevice Work Control MLW+ ~ HE 3-511 Steel corrosion Process Pipe Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ HE 3-511 Steel microbiologically influenced Process corrosion Strainer Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ HE 3-512 Housings Steel microbiologically influenced Process corrosion Tubing Stainless Air-moist Loss of material/pitting and crevice Work Control MLW+ ~ HE 3-512 Steel corrosion Process Valves Copper Raw water Loss of material/pitting, crevice, and Work Control A-Q44 ~ HE 3-513 Alloys microbiologically influenced Process corrosion, and foulinq Valves Stainless Air-moist Loss of material/pitting and crevice Work Control MLW+ ~ HE 3-513 Steel corrosion Process Valves Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ HE 3-513 Steel microbiologically influenced Process corrosion Waste Gas Steel Raw water Loss of material/general, pitting, Work Control A-Qdd ~ HE 3-514 Compressors crevice, and microbiologically Process influenced corrosion, and foulinq ,,

Table 3.3.2-22: Auxiliary Systems - Liquid Waste Processing and Discharge - Aging Management Evaluation Deaerated Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ HE 3-516 Drains Tank Steel microbiologically influenced Process corrosion

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 29 of 38 ChanQes to LRA Table 3.x.2-v (Table 2)

Component Material Environment Aging Effect / Mechanism Aging NUREG-1801 Table 1 Item Notes LRA Page Type Management Vol. 2 Number Program Reference Deaerated Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-516 Drains Tank Steel microbiologically influenced Process Pump corrosion Distillate Cooler Stainless Air-moist Loss of material/pitting and crevice Work Control AJ2-G8+ ~ He;2 3-517 Shell Only Steel corrosion Process Evaporator Stainless Air-moist Loss of material/pitting and crevice Work Control AJ2-G8+ ~ He;2 3-517 Condenser Steel corrosion Process Shell Onlv Filter Housings Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-517 Steel microbiologically influenced Process corrosion Flexible Hoses Elastomers Raw water Hardening and loss of Work Control A!2-Q7e ~ He 3-518 strenqth/elastomer deqradation Process Flexible Hoses Elastomers Raw water Loss of material/erosion Work Control AJ2-.97e ~ He 3-518 Process Flow Elements Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-518 Steel microbiologically influenced Process corrosion Flow Orifices Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-518 Steel microbiologically influenced Process corrosion Flow Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-519 Transmitters Steel microbiologically influenced Process corrosion Laundry and Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-519 Hot Shower Steel microbiologically influenced Process Tanks corrosion Laundry Pump Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-520 Steel microbiologically influenced Process corrosion Level Switches Stainless Air-moist Loss of material/pitting and crevice Work Control AJ2-G8+ ~ He 3-520 Steel corrosion Process Level Switches Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-520 Steel microbiologically influenced Process corrosion Pipe Stainless Air-moist Loss of material/pitting and crevice Work Control AJ2-G8+ ~ He 3-521 Steel corrosion Process Pipe Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-521 Steel microbiologically influenced Process corrosion

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 30 of 38 ChanQes to LRA Table 3.x.2-v (Table 2)

Component Material Environment Aging Effect / Mechanism Aging NUREG-1801 Table 1 Item Notes LRA Page Type Management Vol. 2 Number Program Reference Pipe Steel Raw water Loss of material/general, pitting, Work Control A-OOd ~ H~ 3-521 crevice, and microbiologically Process influenced corrosion, and foulina Sludge Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H~ 3-523 Interceptor Steel microbiologically influenced Process Pump corrosion Sludge Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H~ 3-523 Interceptor Steel microbiologically influenced Process Tank corrosion Standpipes Steel Raw water Loss of material/general, pitting, Work Control A-OOd ~ H~ 3-523 crevice, and microbiologically Process influenced corrosion, and foulina Strainer Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H~ 3-524 Housings Steel microbiologically influenced Process corrosion

. Sump Tank Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H~ 3-524 Pumps Steel microbiologically influenced Process corrosion Sump Tanks Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H~ 3-524 Steel microbiologically influenced Process corrosion Tubing Stainless Air-moist Loss of material/pitting and crevice Work Control A!2-G8+ ~ H~ 3-525 Steel corrosion Process Tubing Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H~ 3-525 Steel microbiologically influenced Process corrosion Valves Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H~ 3-526 Steel microbiologically influenced Process corrosion Valves Steel Raw water Loss of material/general, pitting, Work Control A-OOd ~ H~ 3-526 crevice, and microbiologically Process influenced corrosion, and foulina Waste Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H~ 3-527 Condensate Steel microbiologically influenced Process Pumps corrosion Waste Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H~ 3-527 Condensate Steel microbiologically influenced Process Tanks corrosion Waste Stainless Air-moist Loss of material/pitting and crevice Work Control A!2-G8+ ~ H~;2 3-527 Evaporator Steel corrosion Process Concentrates Sample Cooler Shell Onlv

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 31 of 38 ChanQes to LRA Table 3.x.2-v (Table 2)

Component Material Environment Aging Effect / Mechanism Aging NUREG-1801 Table 1 Item Notes LRA Page Type Management Vol. 2 Number Program Reference Waste Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H 3-528 Evaporator Steel microbiologically influenced Process Feed Pump corrosion Waste Holdup Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H 3-528 Tank Steel microbiologically influenced Process corrosion Table 3.3.2-23: Auxiliary Systems - Radiation Monitorina - Aaina Manaaement Evaluation Radiation Stainless Air-moist Loss of material/pitting and crevice Work Control AP-OO+ ~ H 3-530 Detectors Steel corrosion Process Radiation Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H 3-530 Detectors Steel microbiologically influenced Process corrosion Tubing Stainless Air-moist Loss of material/pitting and crevice Work Control AP-OO+ ~ H 3-531 Steel corrosion Process Valves Stainless Air-moist Loss of material/pitting and crevice Work Control AP-OO+ ~ H 3-531 Steel corrosion Process Table 3.3.2-25: Auxiliary Systems - Service Water Pretreatment - Aging Management Evaluation Filter Housings Steel Raw water Loss of material/general, pitting, Work Control A-OOd ~ H 3-537 crevice, and microbiologically Process influenced corrosion, and foulino Flow Elements Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H 3-537 Steel microbiologically influenced Process corrosion Mixers Static Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H 3-537 Steel microbiologically influenced Process corrosion Pipe Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H 3-538 Steel microbiologically influenced Process corrosion Pipe Steel Raw water Loss of material/general, pitting, Work Control A-OOd ~ H 3-538 crevice, and microbiologically Process influenced corrosion, and foulino Tubing Copper Raw water Loss of material/pitting, crevice, and Work Control A-G44 ~ H 3-539 Alloys microbiologically influenced Process corrosion, and foulino Tubing Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H 3-539 Steel microbiologically influenced Process corrosion Tubing Steel Raw water Loss of material/general, pitting, Work Control A-OOd ~ H 3-539 crevice, and microbiologically Process influenced corrosion, and fouling

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 32 of 38 Chang~~tto LRA Table 3.x.2-v (Tabl~2)

Component Material Environment Aging Effect / Mechanism Aging NUREG-1801 Table 1 Item Notes LRA Page Type Management Vol. 2 Number ProQram Reference Valves Copper Raw water Loss of material/pitting, crevice, and Work Control A-Q44 ~ HE 3-540 Alloys microbiologically influenced Process corrosion, and foulinQ Valves Steel Raw water Loss of material/general, pitting, Work Control ~ ~ HE 3-540 crevice, and microbiologically Process influenced corrosion, and foulinQ Table 3.3.2-26: Auxiliary Systems - Miscellaneous Drains and Sumps - Aging Management Evaluation Annulus Sump Steel Raw water Loss of material/general, pitting, Work Control ~ ~ HE 3-542 Pumps crevice, and microbiologically Process influenced corrosion, and foulina Deaerated Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ HE 3-543 Drains Tank Steel microbiologically influenced Process Emergency corrosion Pumps Flow Elements Elastomers Raw water Hardening and loss of Work Control Af2-G7e ~ HE;1 3-543 strenQth/elastomer deQradation Process Flow Elements Elastomers Raw water Loss of material/erosion Work Control A/2-G7e ~ HE;1 3-543 Process Reactor Steel Raw water Loss of material/general, pitting, Work Control ~ ~ HE 3-543 Containment crevice, and microbiologically Process Vessel Sump influenced corrosion, and fouling Pumps Includes 1A, 1B, and Rx Cavity C Orifices Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ HE 3-544 Steel microbiologically influenced Process corrosion Pipe Stainless Air-moist Loss of material/pitting and crevice Work Control AJ2..G&:l. ~ HE 3-545 Steel corrosion Process Pipe Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ HE 3-545 Steel microbiologically influenced Process corrosion Pipe Steel Raw water Loss of material/general, pitting, Work Control ~ ~ HE 3-545 crevice, and microbiologically Process influenced corrosion, and foulinQ RHR Pump Pit Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ HE 3-546 Sump Pumps Steel microbiologically influenced Process corrosion Safeguards Steel Raw water Loss of material/general, pitting, Work Control ~ ~ HE 3-546 Alley Sump crevice, and microbiologically Process Pumps influenced corrosion, and foulina

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 33 of 38 ChanQes to LRA Table 3.x.2-v (Table 2)

Component Material Environment Aging Effect / Mechanism Aging NUREG-1801 Table 1 Item Notes LRA Page Type Management Vol. 2 Number Program Reference Screen House Steel Raw water Loss of material/general, pitting, Work Control A-OOd ~ H 3-546 Sump Pumps crevice, and microbiologically Process influenced corrosion, and foulinCi Valves Stainless Air-moist Loss of material/pitting and crevice Work Control AJ2..OO+ ~ H 3-547 Steel corrosion Process Valves Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H 3-547 Steel microbiologically influenced Process corrosion Valves Steel Raw water Loss of material/general, pitting, Work Control A-OOd ~ H 3-547 crevice, and microbiologically Process influenced corrosion, and foulinCi Table 3.3.2-27: Auxiliary Systems - Miscellaneous Gas - Aging Management Evaluation Hoses Stainless Air-moist Loss of material/pitting and crevice Work Control AJ2..OO+ ~ H;1 3-551 Steel corrosion Process Table 3.3.2-28: Auxiliarv Systems - Potable Water - Aaina Management Evaluation Nozzles Steel Air-indoor Loss of material/general corrosion Work Control V-IJ.J..OO ~ H;1 3-557 uncontrolled Process Pipe Copper Raw water Loss of material/pitting, crevice, and Work Control A-G44 ~ H 3-558 Alloys microbiologically influenced Process corrosion, and foulinQ Pipe Steel Raw water Loss of material/general, pitting, Work Control A-OOd ~ H 3-558 crevice, and microbiologically Process influenced corrosion, and foulinQ Valves Copper Raw water Loss of material/pitting, crevice, and Work Control A-G44 ~ H 3-559 Alloys microbiologically influenced Process corrosion, and foulinCi Valves Steel Raw water Loss of material/general, pitting, Work Control A-OOd ~ H 3 c559 crevice, and microbiologically Process influenced corrosion, and foulina Table 3.4.2-1: Steam and Power Conversion System - Turbine - Aging Manaaement Evaluation Electro Steel Raw water Loss of material/general, pitting, Work Control ~ ~ H;1 3-611 Hydraulic crevice, galvanic, and Process Control System microbiologically influenced Oil Coolers corrosion, and fouling Bonnets Turbine Oil Steel Raw water Loss of material/general, pitting, Work Control ~ ~ H;1 3-615 Coolers crevice, galvanic, and Process Channel heads microbiologically influenced corrosion, and fouling

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 34 of 38 ChanQes to LRA Table 3.x.2-v (Table 2)

Component Material Environment Aging Effect / Mechanism Aging NUREG-1801 Table 1 Item Notes LRA Page Type Management Vol. 2 Number Program Reference Table 3.4.2-4: Steam and Power Conversion System - Feedwater - Aging Management Evaluation Feedwater Steel Raw water Loss of material/general, pitting, Work Control ~ ~ H 3-633 Pumps Oil crevice, galvanic, and Process Coolers microbiologically influenced Channel Heads corrosion, and fouling Table 3.4.2-9: Steam and Power Conversion System - Heater and Moisture Separator Drains - Aging Management Evaluation Heater Drain Steel Raw water Loss of material/general, pitting, Work Control ~ ~ H;1 3-675 Pumps crevice, galvanic, and Process microbiologically influenced corrosion, and fouling Table 3.4.2-10: Steam and Power Conversion S stem - Heating Steam - Aging Management Evaluation Boric Acid Steel Raw water Loss of material/general, pitting, Work Control ~ ~ H 3-683 Evaporator crevice, galvanic, and Process Cond Return microbiologically influenced Unit Heat corrosion, and fouling Exchanger Bonnet Control Room Steel Raw water Loss of material/general, pitting, Work Control A-003 ~ H 3-685 AlC HW Pump crevice, and microbiologically Process influenced corrosion, and foulinq Heating Coils Copper Raw water Loss of material/pitting, crevice, and Work Control SJ2..Gd.:I. ~ H;2 3-686 Alloys microbiologically influenced Process corrosion Table 3.4.2-11 : Steam and Power Conversion S stem - Main Generator (Mechanical) and Auxiliaries - Aaina Manaaement Evaluation Air Side Seal Steel Raw water Loss of material/general, pitting, Work Control ~ ~ H 3-694 Oil Cooler crevice, galvanic, and Process Channel Heads microbiologically influenced corrosion, and foulina Generator Copper Raw water Loss of material/pitting, crevice, and Work Control SJ2..Gd.:I. ~ H 3-696 Hydrogen Alloys microbiologically influenced Process Coolers Coils corrosion Hydrogen Side Steel Raw water Loss of material/general, pitting, Work Control ~ ~ H 3-696 Seal Oil Cooler crevice, galvanic, and Process Channel Heads microbiologically influenced corrosion, and fouling Table 3.4.2-12: Steam and Power Conversion System - Secondary Sampling - Aging Management Evaluation Cooler Units Steel Raw water Loss of material/general, pitting, Work Control ~ ~ H 3-702 Channel head crevice, galvanic, and Process of first stage microbiologically influenced cooler units corrosion, and fouling

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 35 of 38 Chane:tes to LRA Table 3.x.2-v (Table 2)

Component Material Environment Aging Effect / Mechanism Aging NUREG-1B01 Table 1 Item Notes LRA Page Type Management Vol. 2 Number Proaram Reference Cooler Units Steel Treated water- Loss of material/general, pitting, Work Control ~ ~ HfE 3-702 Shell of first closed cycle crevice, and galvanic corrosion Process stage cooler cooling units Coolers Shell of Stainless Treated water- Loss of material/pitting and crevice Work Control ~ ~ HfE;1 3-703 sample coolers Steel closed cycle corrosion Process coolina Coolers Shell of Steel Treated water- Loss of material/general, pitting, Work Control ~ ~ HfE;1 3-703 sample coolers closed cycle crevice, and galvanic corrosion Process coolinq FW Sample Stainless Treated water- Loss of material/pitting and crevice Work Control ~ ~ HfE 3-704 Line Chiller Steel closed cycle corrosion Process Evaporator tank coolinq FW Sample Stainless Treated water- Loss of material/pitting and crevice Work Control ~ ~ HfE 3-704 Line Chiller Steel closed cycle corrosion Process Recirculating cooling pump Pipe Stainless Treated water- Loss of material/pitting and crevice Work Control ~ ~ HfE 3-705 Steel closed cycle corrosion Process coolina Pipe Steel Treated water- Loss of material/general, pitting, Work Control ~ ~ HfE 3-706 closed cycle crevice, and galvanic corrosion Process coolina Recirculation Steel Treated water- Loss of material/general, pitting, Work Control ~ ~ HfE 3-706 Pumps closed cycle crevice, and galvanic corrosion Process coolinq Refrigeration Steel Raw water Loss of material/general, pitting, Work Control &-G24 ~ HfE 3-707 Unit Chiller crevice, galvanic, and Process Condenser microbiologically influenced Channel head corrosion, and foulinq Refrigeration Steel Treated water- Loss of material/general, pitting, Work Control ~ ~ HfE 3-707 Unit Chiller closed cycle crevice, and galvanic corrosion Process Condenser cooling Shell Refrigeration Steel Treated water- Loss of material/general, pitting, Work Control ~ ~ HfE 3-707 Unit Chiller closed cycle crevice, and galvanic corrosion Process Evaporator cooling Shell Storage Tank Steel Treated water- Loss of material/general, pitting, Work Control ~ ~ HfE 3-708 closed cycle crevice, and galvanic corrosion Process coolinq

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 36 of 38 ChanQes to LRA Table 3.x.2-v (Table 2)

Component Material Environment Aging Effect / Mechanism Aging NUREG-1801 Table 1 Item Notes LRA Page Type Management Vol. 2 Number Pro~ram Reference Tubing Copper Treated water- Loss of material/pitting, crevice, and Work Control SJ2..GOO ~ H 3-709 Alloys closed cycle galvanic corrosion Process cooling Tubing Stainless Treated water- Loss of material/pitting and crevice Work Control ~ ~ H 3-709 Steel closed cycle corrosion Process cooling Tubing Steel Treated water- Loss of material/general, pitting, Work Control ~ ~ H 3-710 closed cycle crevice, and galvanic corrosion Process coolina Valves Copper Treated water- Loss of material/pitting, crevice, and Work Control SJ2..GOO ~ H 3-711 Alloys closed cycle galvanic corrosion Process cooling Valves Stainless Treated water- Loss of material/pitting and crevice Work Control ~ ~ H 3-711 Steel closed cycle corrosion Process cooling Valves Steel Treated water- Loss of material/general, pitting, Work Control ~ ~ H 3-712 closed cycle crevice, and galvanic corrosion Process coolin a Table 3.5.2-1: Structures and Component Supports - Reactor Containment Vessel - A~in~ Mana~ement Evaluation Reactor cavity Elastomers Air-indoor Loss of sealing/deterioration of Work Control +J2..OO7 ~ H;4 3-793 seal ring uncontrolled seals, gaskets, and moisture Process barriers (caulking, flashing, and other sealants)

Table 3.5.2-4: Structures and Component Supports - Auxiliary Buildin~ - A~in~ Mana~ement Evaluation Spent fuel pool Elastomers Air-indoor Loss of sealing/deterioration of Work Control +J2..OO7 ~ H;10 3-819 gate seal uncontrolled seals, gaskets, and moisture Process barriers (caulking, flashing, and other sealants)

Table 3.5.2-14: Structures and Component SUPI orts - Miscellaneous Structural Commodities - Aging Management Evaluation Gaskets/seals Elastomers Air-outdoor Loss of sealing/deterioration of Work Control +J2..OO7 ~ H 3-872 in junction, seals, gaskets, and moisture Process terminal, and barriers (caulking, flashing, and pull boxes other sealants)

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 37 of 38 Additionally, the Work Control Process program is identified in the LRA Section 3 Table 3.x-1 (Table 1's) tables as a plant-specific program. Since the program has been revised to be consistent with NUREG-1801, Sections XI.M32 and XI.M38 AMPs, it is no longer considered a plant-specific program.

In the discussions in LRA Sections 3.x.2.2, Further Evaluation of Aging Management as Recommended by NUREG-1801, related to the confirmation of the effectiveness of chemistry control programs, the Work Control Process program is credited in lieu of the recommended one-time inspection. However, the Work Control Process program has been revised to include the One-Time Inspection program. Therefore, the discussion in these sections is amended as follows:

... In lieu of a one time inspection, The Work Control Process program is used to provide confirmation of the effectiveness of the {chemistry control} program. The Work Control Process program provides the opportunity to visually inspect the internal surfaces of components constructed of typical system materials and exposed to typical system environments, including stagnant locations, through the One-Time Inspection program during preventive and corrective maintenance activities on an ongoing basis....

The affected LRA sections are:

3.2.2.2.3.4 3.2.2.2.4.1 3.2.2.2.4.2 3.2.2.2.8.3 3.3.2.2.7.1 3.3.2.2.9.1 3.3.2.2.9.2 3.3.2.2.10.4 3.3.2.2.12.1 3.3.2.2.12.2 3.4.2.2.2.1 3.4.2.2.2.2 3.4.2.2.4.1 3.4.2.2.4.2 3.4.2.2.5.2 3.4.2.2.6 3.4.2.2.7.1 3.4.2.2.7.3 3.4.2.2.8 Similarly, the discussion in LRA Section 3.1.2.2.7.1 is amended as follows:

...The Work Control Process program is used to provide confirmation of the effectiveness of the Primary Water Chemistry program. The Work Control Process program provides the opportunity to visually inspect the internal surfaces of components constructed of typical system materials and exposed to typical system environments, including stagnant locations, through the One-Time Inspection program during preventive and corrective maintenance activities on an ongoing basis. '"

Serial No.09-597 Docket No.: 50-305 Attachment 2/Page 38 of 38 Part C: Guide to application of Work Control Process program in LRA Section 3 The Work Control Process program has been revised to consist of the One-Time Inspection program and the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (Internal Surfaces Monitoring) program, which are consistent with the NUREG-1801,Section XI.M32, "One-Time Inspection," and Section XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components,"

AMPs, respectively. The following guidance can be used to determine the application of the two programs when only Work Control Process is indicated in the LRA.

The LRA Section 3 Table 3.x.2-y (Table 2's) tables list the Work Control Process program as the AMP for applicable aging management review results line items. In order to determine whether the One-Time Inspection or the Internal Surfaces Monitoring program is credited, the following rule should be applied:

If the Work Control Process program is listed along with a chemistry control program 1 as the AMP for a single line item (defined as a common Component Type, Intended Function, Material, Environment, and Aging Effect/Mechanism), the One-Time Inspection program is the intended AMP and is used to confirm the effectiveness of the listed chemistry control program. If the Work Control Process program is listed as the AMP without a chemistry control program listed for that line item, then the Internal Surfaces Monitoring program is the intended AMP and is used to manage the identified aging effect as a stand-alone program.

1 Chemistry control programs are the Primary Water Chemistry, Secondary Water Chemistry, Closed-Cycle Cooling Water System, Fuel Oil Chemistry, and LubricatingOil Analysis programs.

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