ML19023A015

Supplement No. 2 - Changes to the Subsequent License Renewal Application

ML19023A015
Person / Time
Site:	Peach Bottom
Issue date:	01/23/2019
From:	Gallagher M Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML19023A015 (196)

Text

Exelon Generation ., 200 Exelon Way Kennett Square, PA 19348 www,exeloncorp.com 10 CFR 50 10 CFR 51 10 CFR 54 January 23, 2019 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278

Subject:

Supplement No. 2 - Changes to the Peach Bottom Atomic Power Station, Units 2 and 3, Subsequent License Renewal Application

References:

1. Letter from Michael P. Gallagher, Exelon Generation Company, LLC (Exelon) to NRC Document Control Desk, dated July 10, 2018, "Application for Subsequent Renewed Operating Licenses"

2. Letter from Michael P. Gallagher, Exelon Generation Company, LLC (Exelon) to NRC Document Control Desk, dated September 14, 2018, "Changes to the Peach Bottom Atomic Power Station, Units 2 and 3, Subsequent License Renewal Application" (Supplement No. 1)

In Reference 1, Exelon submitted the Subsequent License Renewal Application (SLRA) for the Peach Bottom Atomic Power Station, Units 2 and 3 (PBAPS). In Reference 2, Exelon submitted Supplement No. 1 to the SLRA for PBAPS. The purpose of this letter is to provide Supplement No. 2 to the SLRA for PBAPS. Supplement No. 2 includes twenty changes to the SLRA which provide additional information and clarifications in the SLRA to address the NRC Safety Review Audit information needs.

Enclosure A to this letter provides a description of each change, and corresponding mark-ups to affected portions of the SLRA, thereby supplementing the PBAPS SLRA.

Enclosure B to this letter provides an update to the License Renewal Commitment List (LRA Appendix A, Section A.5). There are no other new or revised regulatory commitments contained in this letter.

This submittal has been discussed with the NRC License Renewal Senior Project Manager for the PBAPS Subsequent License Renewal project.

January 23, 2019 U.S. Nuclear Regulatory Commission Page 2 If you have any questions, please contact Mr. David Distel, Licensing Lead, Exelon License Renewal Projects, at 610-765-5517.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 23rd day of January 2019.

Respectfully submitted, Vice President - License Renewal and Decommissioning Exelon Generation Company, LLC

Enclosures:

A. Changes to the PBAPS Subsequent License Renewal Application B. PBAPS Subsequent License Renewal Commitment List Update cc: Regional Administrator - NRC Region I NRC Senior Project Manager (Safety Review), NRR-DMLR NRC Project Manager (Environmental Review), NRR-DMLR NRC Project Manager, NRR-DORL - Peach Bottom Atomic Power Station NRC Senior Resident Inspector, Peach Bottom Atomic Power Station R.R. Janati, Pennsylvania Bureau of Radiation Protection D.A. Tancabel, State of Maryland

January 23, 2019 Enclosure A Page 1 of 187 Enclosure A Changes to the PBAPS Subsequent License Renewal Application Introduction This enclosure contains twenty changes that are being made to the Subsequent License Renewal Application (SLRA) that were identified after submittal of the SLRA. For each item, the change is described and the affected page number(s) and portion(s) of the SLRA is provided. For clarity, entire sentences or paragraphs from the SLRA are provided with deleted text highlighted by strikethrm:1ghs and inserted text highlighted by bolded italics. Revisions to SLRA tables are shown by providing excerpts from the affected tables.

January 23, 2019 Enclosure A Page 2 of 187 Change #1 - Addition of Reference to Tanks PBD in Appendix A. Internal Coatings Affected SLRA Sections: Appendix A, Section A.2.1.29 SLRA Page Numbers: A-39 Description of Change:

GALL-SLR Report AMP Xl.M42 states an applicant may elect to manage the aging effects for internal coatings/linings for in-scope piping, piping components, heat exchangers, and tanks in an alternative AMP that is specific to the component or system in which the coatings/linings are installed if the FSAR supplement for this AMP as shown in the GALL-SLR Report Table Xl-01, "FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging Management Programs," is included in the application with a reference to the alternative AMP.

While SLRA Section B.2.1.29 does include reference to the Outdoor and Large Atmospheric Metallic Storage Tanks program, SLRA Section A.2.1.29, "Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks," does not reference the Outdoor and Large Atmospheric Metallic Storage Tanks program.

Accordingly, SLRA Appendix A, Section A.2.1.29 is revised to add reference to the Outdoor and Large Atmospheric Metallic Storage Tanks program.

January 23, 2019 Enclosure A Page 3 of 187 SLRA Section A.2.1.29, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks, page A-39, second paragraph, is revised as shown below:

A.2.1.29 Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks This program manages these aging effects for internal coatings by conducting periodic visual inspections of all coatings/linings applied to the internal surfaces of in scope components where loss of coating or lining integrity could impact the component's or downstream component's current licensing basis intended function(s). The internal surfaces of the Condensate Storage Tanks and Refueling Water Storage Tank are coated; aging management for these tanks is covered under the Outdoor and Large Atmospheric Metallic Storage Tanks (A.2.1.18) program and includes the applicable requirements for coating inspections from the Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks program. Aging management of galvanized piping in the Plant Equipment and Floor Drain System, and internally coated tanks in the Radwaste and Reactor Water Cleanup Systems will be performed under the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (A.2.1.25) program.

January 23, 2019 Enclosure A Page 4 of 187 Change #2 - Applicability of Cracking Aging Effect to Titanium Main Condenser Tubes Affected SLRA Sections: Table 3.4.1, Table 3.4.2-4, Appendix A, Section A.2.1.25, and Appendix B, Section B.2.1.25 SLRA Page Numbers: 3.4-53, 3.4-80, 3.4-84, A-35, and B-144 Description of Change:

The applicability of cracking in titanium components requires updating in the SLRA. SLRA Table 3.4.2-4 currently indicates that cracking is an applicable aging effect for titanium components exposed to raw water in the Main Condenser system, but that it is not an applicable aging effect for titanium components exposed to treated water in the same system. This discrepancy is being corrected to reflect that cracking is an applicable aging effect in both environments. In addition, Sections A.2.1.25 and B.2.1.25 do not discuss cracking of titanium in raw water, and are being updated for completeness.

Accordingly, SLRA Table 3.4.1, Table 3.4.2-4, Appendix A, Section A.2.1.25, and Appendix B, Section B.2.1.25 are revised.

January 23, 2019 Enclosure A Page 5 of 187 SLRA Table 3.4.1, Summary of Aging Management Evaluations for the Steam and Power Conversion Systems, page 3.4-53, is revised as shown below:

Table 3.4.1 Summary of Aging Management Evaluations for the Steam and Power Conversion Systems Further Item Aging Aging Management Component Evaluation Discussion Number Effect/Mechanism Programs Recommended Consistent with NUREG-2191 with exceptions. The One-Time Inspection (B.2.1.21) program and Water Chemistry (B.2.1.2) program will be used to manage cracking of the titanium heat exchanger tubes exposed to treated water in the Main Condenser System.

AMP Xl.M2, "Water Titanium heat exchanger Cracking due to SCC, Chemistry," and Exceptions apply to the NUREG-2191 3.4.1-114 tubes exposed to treated reduction of heat No AMPXl.M32, recommendations for Water Chemistry water transfer due to fouling "One-Time Inspection" (8.2.1.2) program implementation.

Titanium heat exchanger tubes exposed to treated water in the Main Condenser System only have an intended function of holdup, therefore the aging effects of sr-askiRg Elble te SCC aREI reduction of heat transfer due to fouling is ara not managed.

January 23, 2019 Enclosure A Page 6 of 187 SLRA Table 3.4.2-4, Main Condenser System, Summary of Aging Management Evaluation, pages 3.4-80 and 3.4-84, are revised as shown below.

This SLRA markup also includes the changes discussed in Change #11 below to include a plant specific note for grade 2 titanium, and is duplicated here as an aid to the reviewer.

Table 3.4.2-4 Main Condenser System Summary of Aging Management Evaluation Table 3.4.2-4 Main Condenser System Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Management Heat Exchanger - Holdup Titanium Raw Water (Internal) Cracking Inspection of Internal Vlll.E.S-478b 3.4.1-130 A (Main Condenser) Surfaces in Miscellaneous Tube Sheet Piping and Ducting Components (B.2.1.25)

Treated Water None None Vlll.l.S-463 3.4.1-115 A,3 (External)

Heat Exchanger - Holdup Titanium Raw Water (Internal) Cracking Inspection of Internal Vll.C1.A-736 3.3.1-207 A (Main Condenser) Surfaces in Miscellaneous Tubes Piping and Ducting Components (B.2.1.25)

One-Time Inspection Vlll.E.S-462 3.4-1-114 A (B.2.1.21)

Cracking Treated Water Water Chemistry Vlll.E.S-462 3.4-1-114 B (External) (B.2.1.2)

None None Vlll.E.S-462 3.4.1-114 I, 1

January 23, 2019 Enclosure A Page 7 of 187 Table 3.4.2-4 Main Condenser System (Continued)

Notes Definition of Note A Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

B Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

c Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

D Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

E Consistent with NUREG-2191 item for material, environment, and aging effect, but a different aging management program is credited or NUREG-2191 identifies a plant-specific aging management program.

F Material not in NUREG-2191 for this component.

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

H Aging effect not in NUREG-2191 for this component, material, and environment combination.

I Aging effect in NUREG-2191 for this component, material, and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-2191.

Plant Specific Notes:

1. The component performs an intended function of holdup only and therefore, the aging effects of crackina and reduction of heat transfer due to fouling afe is not applicable.

2. The rupture disks are constructed of 3003 aluminum alloy which is not susceptible to stress corrosion cracking.

3. Components are constructed of grade 2 titanium.

January 23, 2019 Enclosure A Page 8 of 187 SLRA Appendix A, Section A.2.1.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, page A-35, first paragraph, is revised as shown below to address managing of cracking for titanium components. This SLRA markup also includes the changes discussed in Change #3 below to address flow blockage, and is duplicated here as an aid to the reviewer.

A.2.1.25 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program is a new condition monitoring program that will manage loss of material and cracking of metallic components, as well as loss of material and hardening and loss of strength of elastomeric materials. Reduction of heat transfer and flow blockage will also be managed. This program will consist of visual inspections of all accessible internal surfaces of piping, piping components, ducting, heat exchanger components, and other mechanical components. Applicable environments include condensation, closed cycle cooling water, diesel exhaust, fuel oil, lube oil, raw water, treated water, and waste water. Visual (VT-1) or surface examinations will be performed to detect cracking of stainless steel components exposed to a diesel exhaust environment. Visual (VT-1), surface, or volumetric examinations will be performed to detect cracking of titanium components exposed to raw water. Except for hardening and loss of strength of elastomers, aging effects associated with components within the scope of the Open Cycle Cooling Water System (A.2.1.11) program, Closed Treated Water Systems

{A.2.1.12) program, and Fire Water System {A.2.1.17) program will not be managed by this program. Loss of material due to recurring internal corrosion on the drain pans of the HPCI, RCIC, Core Spray and AHR pump room unit coolers will be managed by this program.

Additionally, in accordance with NUREG-2191, AMP Xl.M42, "Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks", loss of coating integrity for certain internally coated tanks in the Radwaste and Reactor Water Cleanup Systems will be performed by this program.

January 23, 2019 Enclosure A Page 9of187 SLRA Appendix B, Section B.2.1.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, page B-144, first paragraph, is revised as shown below to address managing of cracking for titanium components. This SLRA markup also includes the changes discussed in Change #3 below to address flow blockage, and is duplicated here as an aid to the reviewer.

B.2.1.25 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program Description The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program is a new condition monitoring program that will manage loss of material and cracking of metallic components, as well as loss of material and hardening and loss of strength of elastomeric materials. Reduction of heat transfer and flow blockage will also be managed. This program will consist of visual inspections of internal surfaces of piping, piping components, ducting, heat exchanger components, polymeric and elastomeric components, and other mechanical components. Applicable environments include condensation, closed cycle cooling water, diesel exhaust, fuel oil, lube oil, raw water, treated water, and waste water. Visual (VT-1) or surface examinations will be performed to detect cracking of stainless steel components exposed to diesel exhaust. Visual (VT-1 ), surface, or volumetric examinations will be performed to detect cracking of titanium components exposed to raw water. Except for hardening and loss of strength of elastomers, aging effects associated with components within the scope of the Open-Cycle Cooling Water System (B.2.1.11) program, Closed Treated Water Systems (B.2.1.12) program, and Fire Water System (B.2.1.17) program will not be managed by this program. Loss of material due to recurring internal corrosion on the drain pans of the HPCI, RCIC, Core Spray and AHR pump room unit coolers will be managed by this program.

January 23, 2019 Enclosure A Page 10 of 187 Change #3 - Addition of Flow Blockage as an Applicable Aging Effect Affected SLRA Sections: Section 3.2.2.1.4, Table 3.2.2-2, Table 3.2.2-4, Table 3.2.2-6, Section 3.3.2.1.19, Section 3.3.2.1.34, Table 3.3.1, Table 3.3.2-12, Table 3.3.2-19, Table 3.3.2-34, Appendix A, Section A.2.1.25, and Appendix B, Section B.2.1.25 SLRAPage Numbers: 3.2-7, 3.2-84, 3.2-117, 3.2-121, 3.2-143, 3.3-26, 3.3-42, 3.3-98, 3.3-101, 3.3-103, 3.3-117, 3.3-157, 3.3-230, 3.3-300 thru 302, 3.3-309, 3.3-310, 3.3-393, 3.3-394, A-35, and B-144 Description of Change:

Flow blockage due to fouling is an applicable aging effect for components in a raw water or waste water environment that perform a pressure boundary or filter intended function. Some instances have been identified where flow blockage was not identified for these conditions, and the applicable SLRA pages are being updated to include this aging effect. In addition, it was identified that the waste water environment is not applicable to valve bodies that perform a pressure boundary function in the Emergency Diesel Generator system, and the SLRA is being updated to delete this environment.

Accordingly, SLRA Section 3.2.2.1.4, Table 3.2.2-2, Table 3.2.2-4, Table 3.2.2-6, Section 3.3.2.1.19, Section 3.3.2.1.34, Table 3.3.1, Table 3.3.2-12, Table 3.3.2-19, Table 3.3.2-34, Appendix A, Section A.2.1.25, and Appendix 8, Section B.2.1.25 are revised.

January 23, 2019 Enclosure A Page 11 of 187 SLRA Section 3.2.2.1.4, Primary Containment Isolation System, Aging Effects Requiring Management, page 3.2-7, is revised as shown below:

3.2.2.1.4 Primary Containment Isolation System Aging Effects Requiring Management The following aging effects associated with the Primary Containment Isolation System components require management:

• Cracking

• Cumulative Fatigue Damage

• Flow Blockage

• Long-Term Loss of Material

• Loss of Fracture Toughness

• Loss of Material

• Loss of Preload

January 23, 2019 Enclosure A Page 12 of 187 SLRA Table 3.2.2-2, Core Spray System, Summary of Aging Management Evaluation, page 3.2-84, is revised as shown below:

Table 3.2.2-2 Core Spray System (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Management Heat Exchanger - Pressure Boundary Galvanized Steel Air- Indoor None None Vll.J.AP-13 3.3.1-116 c (Core Spray Pump Uncontrolled (External)

Room Cooler)

Shell Side Condensation (Internal) Loss of Material Inspection of Internal V.D2.E-27 3.2.1-046 c Surfaces in Miscellaneous Components Piping and Ducting Components (8.2.1.25)

Waste Water (Internal) Flow Blockage Inspection of Internal Vll.ES.AP-281 3.3.1-091 A Surfaces in Miscellaneous Piping and Ducting Comoonents (8.2.1.25J Long-Term Loss of One-Time Inspection Vll.E5.A-785 3.3.1-193 A Material (8.2.1.21)

Loss of Material Inspection of Internal Vll.E5.AP-281 3.3.1-091 A Surfaces in Miscellaneous V.D2.E-400 3.2.1-066 c Piping and Ducting Components (8.2.1 .25)

January 23, 2019 Enclosure A Page 13 of 187 SLRA Table 3.2.2-4, Primary Containment Isolation System, Summary of Aging Management Evaluation, pages 3.2-117 and 3.2-121, are revised as shown below:

Table 3.2.2-4 Primary Containment Isolation System (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Management Piping, piping Pressure Boundary Carbon Steel Waste Water (Internal) Flow Blockage Inspection of Internal VJl.E5.AP-281 3.3.1-091 A components Surfaces in Miscellaneous Piping and Ducting Comoonents (B.2.1.25)

Long-Term Loss of One-Time Inspection Vll.E5.A-785 3.3.1-193 A Material (B.2.1.21)

Loss of Material Inspection of Internal Vll.E5.AP-281 3.3.1-091 A Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25)

January 23, 2019 Enclosure A Page 14 of 187 Table 3.2.2-4 Primary Containment Isolation System (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Manaaement Valve Body Pressure Boundary Carbon Steel Waste Water (Internal) Flow Blockage Inspection of Internal Vll.E5.AP-281 3.3.1-091 A Surfaces in Miscellaneous Piping and Ducting Comoonents (B.2.1.25J Long-Term Loss of One-Time Inspection Vll.E5.A-785 3.3.1-193 A Material (B.2.1.21)

Loss of Material Inspection of Internal VI I. E5.AP-281 3.3.1-091 A Surfaces in Miscellaneous Piping and Ducting Components (B.2.1 .25)

January 23, 2019 Enclosure A Page 15 of 187 SLRA Table 3.2.2-6, Residual Heat Removal System, Summary of Aging Management Evaluation, page 3.2-143, is revised as shown below:

Table 3.2.2-6 Residual Heat Removal System (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Management Heat Exchanger - Pressure Boundary Galvanized Steel Waste Water (Internal) Flow Blockage Inspection of Internal Vll.E5.AP-281 3.3.1-091 A (AHR Pump Room Surfaces in Cooler) Shell Side Miscellaneous Piping Components and Ducting Components (B.2.1.25)

Long-Term Loss of One-Time Inspection Vll.E5.A-785 3.3.1-193 A Material {8.2.1.21)

Loss of Material Inspection of Internal Vll.E5.AP-281 3.3.1-091 A Surfaces in Miscellaneous Piping and Ducting V.02.E-400 3.2.1-066 c Components (B.2.1.25)

January 23, 2019 Enclosure A Page 16 of 187 SLRA Section 3.3.2.1.19, Plant Equipment and Floor Drain System, Aging Effects Requiring Management, page 3.3-26, is revised as shown below:

3.3.2.1.19 Plant Equipment and Floor Drain System Aging Effects Requiring Management The following aging effects associated with the Plant Equipment and Floor Drain System components require management:

• Cracking

• Flow Blockage

• Hardening and Loss of Strength

• Long-Term Loss of Material

• Loss of Coating or Lining Integrity

• Loss of Material

• Loss of Preload

January 23, 2019 Enclosure A Page 17 of 187 SLRA Section 3.3.2.1.34, Traveling Water Screen System, Aging Effects Requiring Management, page 3.3-42, is revised as shown below:

3.3.2.1.34 Traveling Water Screen System Aging Effects Requiring Management The following aging effects associated with the Traveling Water Screen System components require management:

• Cracking

• Flow Blockage

• Hardening and Loss of Strength

• Long-Term Loss of Material

• Loss of Material

• Loss of Preload

• Wall Thinning

January 23, 2019 Enclosure A Page 18 of 187 SLRA Table 3.3.1, Summary of Aging Management Evaluations for the Auxiliary Systems, pages 3.3-98, 3.3-101, 3.3-103, 3.3-117, and 3.3-157, are revised as shown below:

Table 3.3.1 Summary of Aging Management Evaluations for the Auxiliary Systems Item Component Aging Effect/ Aging Management Further Discussion Number Mechanism Programs Evaluation Recommended 3.3.1-085 Elastomer piping, piping Hardening or loss of AMP Xl.M38, "Inspection No Consistent with NUREG-2191. The components, seals strength due to of Internal Surfaces in Inspection of Internal Surfaces in exposed to air, elastomer Miscellaneous Piping and Miscellaneous Piping and Ducting condensation, closed- degradation; flow Ducting Components" Components (B.2.1.25) program will be cycle cooling water, blockage due to used to manage flow blockage and treated borated water, fouling (raw water, hardening and loss of strength of the treated water, raw water, waste water only) elastomer ducting, ducting components, raw water (potable), piping, piping components exposed to waste water, gas, fuel oil, closed cycle cooling water, condensation, lubricating oil fuel oil, lubricating oil, raw water, treated water, and waste water in the Battery and Emergency Switchgear Ventilation System, Control Room Ventilation System, Diesel Generator Building Ventilation System, Emergency Diesel Generator System, Emergency Service Water System, Plant Equipment and Floor Drain System, Pump Structure Ventilation System, Torus Water Storage and Transfer System, Traveling Water Screen System, Core Spray System, and Residual Heat Removal System.

January 23, 2019 Enclosure A Page 19 of 187 Table 3.3.1 Summary of Aging Management Evaluations for the Auxiliary Systems Item Component Aging Effect/ Aging Management Further Discussion Number Mechanism Programs Evaluation Recommended 3.3.1-091 Steel piping, piping Loss of material due AMP Xl.M38, "Inspection No Consistent with NUREG-2191. The components, heat to general, pitting, of Internal Surfaces in Inspection of Internal Surfaces in exchanger components, crevice corrosion, Miscellaneous Piping and Miscellaneous Piping and Ducting tanks exposed to waste MIC; flow blockage Ducting Components" Components (B.2.1.25) program will be water due to fouling used to manage loss of material and flow blockage of the carbon steel, ductile iron, galvanized steel, and gray cast iron heat exchanger components, piping, piping components, and tanks exposed to waste water in the Chilled Water System, Emergency Diesel Generator System, Plant Equipment and Floor Drain System, Process Sampling System, Radwaste System, Standby Liquid Control System, Core Spray System, High Pressure Coolant Injection System, Primary Containment Isolation System, Reactor Core Isolation Cooling System, and Residual Heat Removal System.

The External Surfaces Monitoring of Mechanical Components (B.2.1.24) program has been substituted and will be used to manage loss of material of the carbon steel piping, piping components exposed to waste water in the High Pressure Coolant Injection System and Standby Liquid Control System.

January 23, 2019 Enclosure A Page 20 of 187 Table 3.3.1 Summary of Aging Management Evaluations for the Auxiliary Systems Item Component Aging Effect/ Aging Management Further Discussion Number Mechanism Programs Evaluation Recommended 3.3.1-095 Copper alloy, stainless Loss of material due AMP Xl.M38, "Inspection No Consistent with NUREG-2191. The steel, nickel alloy piping, to general (copper of Internal Surfaces in Inspection of Internal Surfaces in piping components, heat alloy only), pitting, Miscellaneous Piping and Miscellaneous Piping and Ducting exchanger components, crevice corrosion, Ducting Components" Components (B.2.1.25) program will be tanks exposed to waste MIC; flow blockage used to manage loss of material of the water due to fouling copper alloy and stainless steel piping, piping components, and tanks exposed to waste water in the Emer§ensy Diesel Generater System, Plant Equipment and Floor Drain System, Process Sampling System, Radwaste System, and Containment Atmosphere Control and Dilution System.

January 23, 2019 Enclosure A Page 21 of 187 Table 3.3.1 Summary of Aging Management Evaluations for the Auxiliary Systems Item Component Aging Effect/ Aging Management Further Discussion Number Mechanism Programs Evaluation Recommended 3.3.1-134 Steel, stainless steel, Loss of material due AMP Xl.M38, "Inspection No Consistent with NUREG-2191. The copper alloy piping, to general (steel, of Internal Surfaces in Inspection of Internal Surfaces in piping components, and copper alloy only), Miscellaneous Piping and Miscellaneous Piping and Ducting heat exchanger pitting, crevice Ducting Components" Components (B.2.1.25) program will be components exposed to corrosion, MIC; flow used to manage loss of material and flow raw water (for blockage due to blockage of the carbon steel, copper alloy, components not covered fouling and stainless steel piping, piping by NRG GL 89-13) components, and traveling screens exposed to raw water in the Traveling Water Screen System.

January 23, 2019 Enclosure A Page 22 of 187 Table 3.3.1 Summary of Aging Management Evaluations for the Auxiliary Systems Item Component Aging Effect/ Aging Management Further Discussion Number Mechanism Programs Evaluation Recommended 3.3.1-258 Metallic, elastomer, Flow blockage due to AMP Xl.M38, "Inspection No Not Applicable.

fiberglass, HOPE piping, fouling of Internal Surfaces in +l=leFe aFe Re metallis, elastemeF, piping components Miscellaneous Piping and fi9eFJlass, l=lQPe pipiAJ, pipiAJ exposed to waste water Ducting Components" sempeAeAts e*peseEl te *Nasta wateF witl=l a flew Fate EIF l=leat tFaAsfeF f1:1AstieA iA A1:1*ilial)' Systems.

Metallic and elastomer piping, piping components exposed to waste water which are susceptible to flow blockage due to fouling are addressed by line items 3.3.1-085 and 3.3.1-091.

January 23, 2019 Enclosure A Page 23 of 187 SLRA Table 3.3.2-12, Emergency Diesel Generator System, Summary of Aging Management Evaluation, page 3.3-230, is revised as shown below:

Table 3.3.2-12 Emergency Diesel Generator System (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item ManaQement Valve Body Pressure Boundary Copper Alloy with Fuel Oil (Internal) Loss of Material One-Time Inspection Vll.H1.AP-132 3.3.1-069 A 15% Zinc or Less (B.2.1 .21)

Lubricating Oil (Internal) Loss of Material Lubricating Oil Analysis Vll.H2.AP-133 3.3.1-099 A (B.2.1.26)

One-Time Inspection Vll.H2.AP-133 3.3.1-099 A (B.2.1.21 l Waste IA!ateF {IRlSFAal) bess ef MateFial IRspestieR ef IRteFRal IJll.E:§ ..l\12 272 a.:u gg§ A S1:1Ffases iR MissellaRee1:1s PipiR§ aRa Q1:1stiR§ GeFRpeReRts {8.2 . ~ .2§)

January 23, 2019 Enclosure A Page 24 of 187 SLRA Table 3.3.2-19, Plant Equipment and Floor Drain System, Summary of Aging Management Evaluation, pages 3.3-300, 3.3-301, 3.3-302, 3.3-309, and 3.3-310, are revised as shown below:

Table 3.3.2-19 Plant Equipment and Floor Drain System (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Manaaement Piping, piping Pressure Boundary Carbon Steel Waste Water (Internal) Flow Blockage Inspection of Internal Vll.ES.AP-281 3.3.1-091 A components Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25)

Long-Term Loss of One-Time Inspection Vll.ES.A-785 3.3.1-193 A Material (B.2.1.21)

Loss of Material Inspection of Internal VI I. ES.AP-281 3.3.1-091 A Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25)

Elastomer Air - Indoor Hardening and Loss of External Surfaces Vll.l.AP-102 3.3.1-076 A Uncontrolled (External) Strength Monitoring of Mechanical Comoonents (8.2.1.24)

Waste Water (Internal) Flow Blockage Inspection of Internal Vl/.ES.A-728 3.3.1-085 A Surfaces in Miscellaneous Piping and Ducting Comoonents fB.2.1.251 Hardening and Loss of Inspection of Internal Vll.E5.A-728 3.3.1-085 A Strength Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25)

January 23, 2019 Enclosure A Page 25 of 187 Table 3.3.2-19 Plant Equipment and Floor Drain System (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item ManaQement Piping, piping Pressure Boundary Gray Cast Iron Waste Water (Internal) Flow Blockage Inspection of Internal V/l.E5.AP-281 3.3.1-091 A components Surfaces in Miscellaneous Piping and Ducting Comoonents (B.2.1.25J Long-Term Loss of One-Time Inspection Vll.E5.A-785 3.3.1-193 A Material (8.2.1.21)

Loss of Material Inspection of Internal Vll.E5.AP-281 3.3.1-091 A Surfaces in Miscellaneous Piping and Ducting Comoonents (B.2.1.25)

Selective Leaching Vll.E5.A-547 3.3.1-072 A (B.2.1.22)

January 23, 2019 Enclosure A Page 26 of 187 Table 3.3.2-19 Plant Equipment and Floor Drain System (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Management Pump Casing Pressure Boundary Gray Cast Iron Waste Water (Internal) Flow Blockage Inspection of Internal Vl/.ES.AP-281 3.3.1-091 A (Circulating Water Surfaces in Pump Structure Miscellaneous Piping Sump Pump) and Ducting Comoonents (8.2.1.25J Long-Term Loss of One-Time Inspection Vll.E5.A-785 3.3.1-193 A Material (B.2.1.21)

Loss of Material Inspection of Internal Vll.E5.AP-281 3.3.1-091 A Surfaces in Miscellaneous Piping and Ducting Components (B.2.1 .25)

Selective Leaching Vll.ES.A-547 3.3.1-072 A (B.2.1.22)

January 23, 2019 Enclosure A Page 27 of 187 Table 3.3.2-19 Plant Equipment and Floor Drain System (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item ManaQement Valve Body Pressure Boundary Carbon Steel Waste Water (Internal) Flow Blockage Inspection of Internal Vll.ES.AP-281 3.3.1-091 A Surfaces in Miscellaneous Piping and Ducting Comoonents fB.2.1.25J Long-Term Loss of One-Time Inspection Vll.E5.A-785 3.3.1-193 A Material (B.2.1.21)

Loss of Material Inspection of Internal Vll.E5.AP-281 3.3.1-091 A Surfaces in Miscellaneous Piping and Ducting Components (B.2.1 .25)

Gray Cast Iron Air- Indoor Loss of Material External Surfaces Vll.l.A-77 3.3.1-078 A Uncontrolled (External) Monitoring of Mechanical Components (B.2.1.24)

Waste Water (Internal) Flow Blockage Inspection of Internal Vll.ES.AP-281 3.3.1-091 A Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25)

Long-Term Loss of One-Time Inspection Vll.E5.A-785 3.3.1-193 A Material (B.2.1.21)

Loss of Material Inspection of Internal Vll.E5.AP-281 3.3.1-091 A Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25)

Selective Leaching Vll.E5.A-547 3.3.1-072 A (B.2.1.22)

January 23, 2019 Enclosure A Page 28 of 187 SLRA Table 3.3.2-34, Traveling Water Screen System, Summary of Aging Management Evaluation, beginning on page 3.3-393, is revised as shown below:

Table 3.3.2-34 Traveling Water Screen System (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Management Traveling Screen Filter Carbon Steel Raw Water (External) Flow Blockage Inspection of Internal Vll.C1.A-727 3.3.1-134 A Surfaces in Miscellaneous Piping and Ducting Comoonents (B.2.1.25)

Long-Term Loss of One-Time Inspection Vll.C1 .A-532 3.3.1-193 A Material (B.2.1.21)

Loss of Material Inspection of Internal Vll.C1.A-727 3.3.1-134 A Surfaces in Miscellaneous Piping and Ducting Comoonents (B.2.1.25)

Stainless Steel Raw Water (External) Flow Blockage Inspection of Internal Vll.C1.A-727 3.3.1-134 A Surfaces in Miscellaneous Piping and Ducting Comoonents (B.2.1.25)

Loss of Material Inspection of Internal Vll.C1 .A-727 3.3.1-134 A Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25)

January 23, 2019 Enclosure A Page 29 of 187 SLRA Appendix A, Section A.2.1.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, page A-35, first paragraph, is revised as shown below to address flow blockage.

This SLRA markup also includes the changes discussed in Change #2 above to address managing of cracking for titanium components, and is duplicated here as an aid to the reviewer.

A.2.1.25 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program is a new condition monitoring program that will manage loss of material and cracking of metallic components, as well as loss of material and hardening and loss of strength of elastomeric materials. Reduction of heat transfer and flow blockage will also be managed. This program will consist of visual inspections of all accessible internal surfaces of piping, piping components, ducting, heat exchanger components, and other mechanical components. Applicable environments include condensation, closed cycle cooling water, diesel exhaust, fuel oil, lube oil, raw water, treated water, and waste water. Visual (VT-1) or surface examinations will be performed to detect cracking of stainless steel components exposed to a diesel exhaust environment. Visual (VT-1), surface, or volumetric examinations will be performed to detect cracking of titanium components exposed to raw water. Except for hardening and loss of strength of elastomers, aging effects associated with components within the scope of the Open Cycle Cooling Water System (A.2.1.11) program, Closed Treated Water Systems (A.2.1.12) program, and Fire Water System (A.2.1.17) program will not be managed by this program. Loss of material due to recurring internal corrosion on the drain pans of the HPCI, RCIC, Core Spray and AHR pump room unit coolers will be managed by this program.

Additionally, in accordance with NUREG-2191, AMP Xl.M42, "Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks", loss of coating integrity for certain internally coated tanks in the Radwaste and Reactor Water Cleanup Systems will be performed by this program.

January 23, 2019 Enclosure A Page 30 of 187 SLRA Appendix B, Section B.2.1.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, page B-144, first paragraph, is revised as shown below to address flow blockage.

This SLRA markup also includes the changes discussed in Change #2 above to address managing of cracking for titanium components, and is duplicated here as an aid to the reviewer.

B.2.1.25 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program Description The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program is a new condition monitoring program that will manage loss of material and cracking of metallic components, as well as loss of material and hardening and loss of strength of elastomeric materials. Reduction of heat transfer and flow blockage will also be managed. This program will consist of visual inspections of internal surfaces of piping, piping components, ducting, heat exchanger components, polymeric and elastomeric components, and other mechanical components. Applicable environments include condensation, closed cycle cooling water, diesel exhaust, fuel oil, lube oil, raw water, treated water, and waste water. Visual (VT-1) or surface examinations will be performed to detect cracking of stainless steel components exposed to diesel exhaust. Visual (VT-1 ), surface, or volumetric examinations will be performed to detect cracking of titanium c.omponents exposed to raw water. Except for hardening and loss of strength of elastomers, aging effects associated with components within the scope of the Open-Cycle Cooling Water System (B.2.1.11) program, Closed Treated Water Systems (B.2.1.12) program, and Fire Water System (B.2.1.17) program will not be managed by this program. Loss of material due to recurring internal corrosion on the drain pans of the HPCI, RCIC, Core Spray and RHR pump room unit coolers will be managed by this program.

January 23, 2019 Enclosure A Page 31 of 187 Change #4 - Clarification of Treated Water Environment Definition Affected SLRA Sections: Table 3.0-1, Table 3.3.2-24, Table 3.3.2-26 SLRA Page Numbers: 3.0-10, 3.3-333, 3.3-334, 3.3-337, 3.3-354 Description of Change:

The definition for Treated Water in SLRA Table 3.0-1 states that treatments such as corrosion inhibitors and biocides may be used to treat this water. However, treatments such as these are not used for treated water, as treated water is demineralized water which is managed by industry standards such as BWRVIP-190 to maintain purity. Additionally, there is no source for MIC contamination of treated water systems, and a review of Peach Bottom operating experience since 2008 has not revealed evidence of MIC in treated water systems. This is relevant information for tanks identified in SLRA Tables 3.3.2-24 and 3.3.2-26 that are internally coated and being managed under the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components aging management program, instead of the Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks aging management program. This program substitution is only allowed in the absence of MIC. A plant specific note is needed to address the absence of MIC in the internal environment of these tanks.

Accordingly, SLRA Table 3.0-1, Table 3.3.2-24 and Table 3.3.2-26 are revised.

January 23, 2019 Enclosure A Page 32 of 187 SLRA Table 3.0-1, Peach Bottom Service Environments, page 3.0-1 O, is revised as shown below:

Table 3.0-1 Peach Bottom Service Environments Peach Bottom AMR Description Corresponding NUREG-2191 Environment Environments Treated Water Treated water is demineralized water or Treated water chemically purified water and is the base 1 Air - indoor, uncontrolled water for all clean systems. Depending on the system, treated water may require Reactor coolant 1 further processing. Treated water Steam environments are managed by industry standards such as BWRVIP-190 which do not consider MIC, as there are no sources of MIC in treated water. +:feate8 watef Fflay 80 8eaefate8 aA8 iRsh,:180 69ff96i9A iARi8itefS, 8ieGi8es, Bf 69FFl9 GBFFIBiRatieA ef tl=lese tfeatFF10Ats. The treated water environment also includes wet steam. Dry steam, such as main steam up to the high pressure turbine, is addressed as its own environment.

January 23, 2019 Enclosure A Page 33 of 187 SLRA Table 3.3.2-24, Radwaste System, Summary of Aging Management Evaluation, pages 3.3-333, 3.3-334, and 3.3-337, are revised as shown below:

Table 3.3.2-24 Radwaste System (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Management Tanks (Filter Aid Leakage Boundary Carbon Steel Air- Indoor Loss of Material External Surfaces Vll.l.A-77 3.3.1-078 A Tank) (with Internal Uncontrolled (External) Monitoring of Mechanical Coating) Components (B.2.1.24) n-reated Water {Internal) Loss of Coating or Lining Inspection of Internal Vll.E4.A-416 3.3.1-138 E,+2 Integrity Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25)

January 23, 2019 Enclosure A Page 34 of 187 Table 3.3.2-24 Radwaste System (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Management Tanks (Filter Aid Leakage Boundary Carbon Steel Treated Water (Internal) Loss of Material Inspection of Internal Vll.E4.A-414 3.3.1-139 E,+2 Tank) (with Internal Surfaces in Miscellaneous Coating) Piping and Ducting Components (B.2.1.25)

Tanks (Laundry Leakage Boundary Carbon Steel Air- Indoor Loss of Material External Surfaces Vll.l.A-77 3.3.1-078 A Hot Water Heater) Uncontrolled (External) Monitoring of Mechanical Components (B.2.1.24)

Raw Water (Internal) Long-Term Loss of One-Time Inspection Vll.E3.A-439 3.3.1-193 A Material (B.2.1.21)

Loss of Material Inspection of Internal Vll.E5.AP-270 3.3.1-088 c Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25)

Tanks (Mixing Leakage Boundary Stainless Steel Air - Indoor Cracking One-Time Inspection Vll.E4.AP-209a 3.3.1-004 A Tank) Uncontrolled (External) (B.2.1.21)

Loss of Material One-Time Inspection Vll.E4.AP-221 a 3.3.1-006 A (B.2.1.21)

Waste Water (Internal) Loss of Material Inspection of Internal Vll.E5.AP-278 3.3.1-095 A Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25)

Tanks (RWCU Leakage Boundary Carbon Steel Air - Indoor Loss of Material External Surfaces Vll.l.A-77 3.3.1-078 A Filter Demin (with Internal Uncontrolled (External) Monitoring of Mechanical Backwash Coating) Components (B.2.1.24)

Receiving Tank)

Treated Water (Internal) Loss of Coating or Lining Inspection of Internal Vll.E4.A-416 3.3.1-138 E,+2 Integrity Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25)

Loss of Material Inspection of Internal Vll.E4.A-414 3.3.1-139 E,+2 Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25)

January 23, 2019 Enclosure A Page 35 of 187 Table 3.3.2-24 Radwaste System (Continued)

Notes Definition of Note A Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

B Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

c Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

D Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

E Consistent with NUREG-2191 item for material, environment, and aging effect, but a different aging management program is credited or NUREG-2191 identifies a plant-specific aging management program.

F Material not in NUREG-2191 for this component.

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

H Aging effect not in NUREG-2191 for this component, material, and environment combination.

I Aging effect in NUREG-2191 for this component, material, and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-2191.

Plant Specific Notes:

1. Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25) program is substituted to manage the aging effect(s) applicable to this component type, material and environment combination. The environment is Raw Water (Potable) that does not have the potential for microbiologically-induced corrosion.

2. Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25) program is substituted to manage the aging effect(s) applicable to this component type, material and environment combination. The environment is Treated Water that does not have the potential for microbiologically-induced corrosion.

January 23, 2019 Enclosure A Page 36 of 187 SLRA Table 3.3.2-26, Reactor Water Cleanup System, Summary of Aging Management Evaluation, page 3.3-354, is revised as shown below:

Table 3.3.2-26 Reactor Water Cleanup System (Continued)

Notes Definition of Note A Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

B Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

c Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

D Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

E Consistent with NUREG-2191 item for material, environment, and aging effect, but a different aging management program is credited or NUREG-2191 identifies a plant-specific aging management program.

F Material not in NUREG-2191 for this component.

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

H Aging effect not in NUREG-2191 for this component, material, and environment combination.

I Aging effect in NUREG-2191 for this component, material, and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-2191.

Plant Specific Notes:

1. The internal environment of condensation is associated with the air space in the RWCU Filter Demineralizer Precoat Tank. The aging effect on carbon steel (with internal coating) with an internal environment of condensation includes the loss of coating or lining integrity due to blistering, cracking, flaking, peeling, delamination, rusting, physical damage. This aging effect is managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25) program.

2. The internal environment of condensation is associated with the air space in the RWCU Filter Demineralizer Precoat Tank. The aging effect on carbon steel (with internal coating) with an internal environment of condensation includes the loss of material due to general, pitting, and crevice corrosion. This aging effect is managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25) program.

3. The TLAA designation in the Aging Management Program column indicates that fatigue of this component is evaluated in Section 4.3.

4. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25) program is substituted to manage the aging effect(s) applicable to this component type, material, and environment combination. The environment is Treated Water that does not have the potential for microbio/ogically-induced corrosion.

January 23, 2019 Enclosure A Page 37 of 187 Change #5 - Reduction of Heat Transfer as an Applicable Aging Effect for Core Spray and RHR Pump Room Cooler Air Intake Screens Affected SLRA Sections: Table 3.2.1, Table 3.2.2-2, Table 3.2.2-6, Appendix A, Section A.2.1.24, and Appendix B, Section B.2.1.24 SLRA Page Numbers: 3.2-55, 3.2-84, 3.2-92, 3.2-143, 3.2-151, A-34, and B-140 Description of Change:

The Core Spray Pump Room and RHR Pump Room coolers are configured to pass air through the shell side of the heat exchanger and cooling water through the tube side of the heat exchanger. The air intake on the shell side of the units is equipped with debris screens. Although these screens do not perform a pressure boundary function, loss of flow through them due to obstruction could impact the ability of the heat exchangers to perform their heat transfer function. Therefore, reduction of heat transfer is an applicable aging effect for these components that will be managed by the External Surfaces Monitoring of Mechanical Components aging management program.

Accordingly, SLRA Table 3.2.1, Table 3.2.2-2, Table 3.2.2-6, Appendix A, Section A.2.1.24, and Appendix B, Section B.2.1.24 are revised.

January 23, 2019 Enclosure A Page 38 of 187 SLRA Table 3.2.1, Summary of Aging Management Evaluations for the Engineered Safety Features, page 3.2-55, is revised as shown below:

Table 3.2.1 Summary of Aging Management Evaluations for the Engineered Safety Features Item Component Aging Aging Management Further Discussion Number Effect/Mechanism Programs Evaluation Recommended 3.2.1-081 Stainless steel, steel, Reduction of heat AMP Xl.M36, No t>lst Applisaele.

aluminum, copper alloy, transfer due to fouling "External Surfaces

+l=leFe aFe RS staiRless steel, steel, titanium heat exchanger Monitoring of Mechanical al1:1miR1:1m, seppeF alley, eF titaRi1:1m heat tubes exposed to air, Components" condensation e*sl=laRgeF t1:1ees s*psssEI ts aiF sF seREleRsatisR iR ERgiReeFeEI Safety Feat1:1Fes systems.

Consistent with NUREG-2191. The External Surfaces Monitoring of Mechanical Components (B.2.1.24) program will be used to manage reduction of heat transfer of the carbon steel heat exchanger components exposed to air - indoor uncontrolled in the Core Spray System and Residual Heat Removal System.

January 23, 2019 Enclosure A Page 39 of 187 SLRA Table 3.2.2-2, Core Spray System, Summary of Aging Management Evaluation, pages 3.2-84 and 3.2-92, are revised as shown below:

Table 3.2.2-2 Core Spray System (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Management Heat Exchanger - Heat Transfer Carbon Steel Air-Indoor Reduction of Heat External Surfaces V.E.E-424 3.2.1-081 C,6 (Core Spray Pump Uncontrolled Transfer Monitoring of Room Cooler) (External) Mechanical Components Shell Side (B.2.1.24)

Components Pressure Boundary Galvanized Steel Air - Indoor None None Vll.J.AP-13 3.3.1-116 c Uncontrolled (External)

Condensation (Internal) Loss of Material Inspection of Internal V.02.E-27 3.2.1-046 c Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25)

January 23, 2019 Enclosure A Page 40 of 187 Table 3.2.2-2 Core Spray System (Continued)

Notes Definition of Note A Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP is consistent with NUREG- 2191 AMP.

B Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

c Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

D Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

E Consistent with NUREG-2191 item for material, environment, and aging effect, but a different aging management program is credited or NUREG-2191 identifies a plant-specific aging management program.

F Material not in NUREG-2191 for this component.

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

H Aging effect not in NUREG-2191 for this component, material, and environment combination.

I Aging effect in NUREG-2191 for this component, material, and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-2191.

Plant Specific Notes:

1. The TLAA designation in the Aging Management Program column indicates that fatigue of this component is evaluated in Section 4.3.

2. The Heat Transfer intended function applies only to room coolers 2(3)BE057, 2(3)DE057, 2(3)FE057, 2GE057, and 3HE057.

3. The TLAA designation in the Aging Management Program column indicates that fatigue of this component is evaluated in Section 4.6.

4. The room cooler fins are constructed of 3003 aluminum alloy which is not susceptible to stress corrosion cracking.

5. Flow blockage due to fouling in the ECCS suction strainers will be managed by the ASME Section XI, Subsection IWE (B.2.1.30) program which includes periodic inspections for sludge accumulation on the torus floor and ensures that sludge accumulation rate does not exceed the design basis assumptions used for design, fabrication, and testing of the strainers.

6. The portion of the Core Spray Pump Room Cooler shell that serves as the air intake is equipped with debris screens. While these screens do not directly serve a pressure boundary function, they could prevent the coolers from performing their heat transfer function if the air flow through them would become obstructed by debris or other material. Therefore, the external surfaces of the screens are evaluated as having a heat transfer function, and are managed for reduction of heat transfer due to fouling.

January 23, 2019 Enclosure A Page 41 of 187 SLRA Table 3.2.2-6, Residual Heat Removal System, Summary of Aging Management Evaluation, pages 3.2-143 and 3.2-151, are revised as shown below:

Table 3.2.2-6 Residual Heat Removal System (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Management Heat Exchanger - Heat Transfer Carbon Steel Air-Indoor Reduction of Heat External Surfaces V.E.E-424 3.2.1-081 C,6 (AHR Pump Room Uncontrolled Transfer Monitoring of Cooler) Shell Side (External) Mechanical Components Components (B.2.1.24)

Pressure Boundary Galvanized Steel Air- Indoor None None Vll.J.AP-13 3.3.1-116 c Uncontrolled (External)

Condensation (Internal) Loss of Material Inspection of Internal V.02.E-27 3.2.1-046 c Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25)

January 23, 2019 Enclosure A Page 42 of 187 Table 3.2.2-6 Residual Heat Removal System (Continued)

Notes Definition of Note A Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

B Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

c Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

D Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

E Consistent with NUREG-2191 item for material, environment, and aging effect, but a different aging management program is credited or NUREG-2191 identifies a plant-specific aging management program.

F Material not in NUREG-2191 for this component.

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

H Aging effect not in NUREG-2191 for this component, material, and environment combination.

I Aging effect in NUREG-2191 for this component, material, and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-2191.

Plant Specific Notes:

1. The TLAA designation in the Aging Management Programs column indicates that cumulative fatigue damage for this component is evaluated in Section 4.3.

2. The TLAA designation in the Aging Management Programs column indicates that cumulative fatigue damage for this component is evaluated in Section 4.6.

3. The Heat Transfer intended function applies only to room coolers 2(3)AE058, 2(3)DE058, 2(3)FE058, and 2(3)GE058.

4. The room cooler fins are constructed of 3003 aluminum alloy which is not susceptible to stress corrosion cracking.

5. Flow blockage due to fouling in the ECCS suction strainers will be managed by the ASME Section XI, Subsection IWE (B.2.1.30) program which includes periodic inspections for sludge accumulation on the torus floor and ensures that sludge accumulation rate does not exceed the design basis assumptions used for design, fabrication, and testing of the strainers.

6. The portion of the RHR Pump Room Cooler shell that serves as the air intake is equipped with debris screens. While these screens do not directly serve a pressure boundary function, they could prevent the coolers from performing their heat transfer function if the air flow through them would become obstructed by debris or other material. Therefore, the external surfaces of the screens are evaluated as having a heat transfer function, and are managed for reduction of heat transfer due to fouling.

January 23, 2019 Enclosure A Page 43 of 187 SLRA Appendix A, Section A.2.1.24, External Surfaces Monitoring of Mechanical Components, page A-34, first paragraph, is revised as shown below:

A.2.1.24 External Surfaces Monitoring of Mechanical Components The External Surfaces Monitoring of Mechanical Components aging management program is a new condition monitoring program that will manage loss of material and cracking of metallic components, as well as loss of material, cracking, and hardening and loss of strength for elastomeric components, loss of preload for HVAC closure bolting, reduction of heat transfer for heat exchanger external surfaces exposed to air (room cooler air intake screens}, and reduced thermal insulation resistance. Periodic visual inspections, not to exceed a refueling outage interval, of metallic components, elastomers, and insulation jacketing (insulation when not jacketed) will be conducted. There are no cementitious components in the scope of this program. This program does not monitor for reduction of heat transfer due to fouling for heat exchanger internal surfaces exposed to air.r-t1his aging effect will be managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (A.2.1.25) program. This program does not manage cracking due to stress corrosion cracking (SCC) or loss of material in aluminum and SS components exposed to aqueous solutions and air environments containing halides. As discussed in SLRA Sections 3.1.2.2.16, 3.2.2.2.4, 3.3.2.2.3, 3.4.2.2.2, 3.2.2.2.2, 3.3.2.2.4, 3.4.2.2.3, 3.2.2.2.8, 3.3.2.2.8, 3.4.2.2.7, 3.2.2.2.10, 3.3.2.2.10, and 3.4.2.2.9, these aging effects for these materials and environments are managed by the One-Time Inspection (A.2.1.21) program.

January 23, 2019 Enclosure A Page 44 of 187 SLRA Appendix B, Section B.2.1.24, External Surfaces Monitoring of Mechanical Components, page B-140, first paragraph, is revised as shown below:

B.2.1.24 External Surfaces Monitoring of Mechanical Components Program Description The External Surfaces Monitoring of Mechanical Components aging management program is a new condition monitoring program that will consist of visual inspections that are performed during system inspections and walkdowns. The program will consist of periodic visual inspections of metallic and elastomeric components such as piping, piping components, ducting, ducting components, HVAC closure bolting, elastomeric components, and other components within the scope of license renewal. There are no cementitious components in the scope of this program. The program will manage aging effects through visual inspection of external surfaces for evidence of loss of material, and cracking of metallic components, as well as loss of material, cracking, and hardening and loss of strength for elastomers, loss of preload for HVAC closure bolting, reduction of heat transfer for heat exchanger external surfaces exposed to air (room cooler air intake screens), and reduced thermal insulation resistance. Visual inspections will be augmented by physical manipulation to confirm the absence of hardening and loss of strength of elastomers. This program does not manage reduction of heat transfer due to fouling for heat exchanger internal surfaces exposed to air. This aging effect for this component type and environment will be managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25) program.

January 23, 2019 Enclosure A Page 45 of 187 Change #6 - Addition of Enhancement for Preventative Actions for Bolting Integrity Affected SLRA Sections: Appendix A, Section A.2.1.30, Appendix A, Section A.2.1.31, Appendix A, Section A.2.1.34, Appendix A, Section A.2.1 .35, Appendix A, Section A.5, Appendix B, Section B.2.1.30, Appendix B, Section B.2.1.31, Appendix B, Section B.2.1.34, and Appendix 8, Section 8.2.1.35 SLRA Page Numbers: A-40, A-41, A-44, A-46, A-106, A-107, A-110, A-111, 8-174, 8-181, 8-199, and 8-209 Description of Change:

The Preventative Action element for ASME Section XI, Subsection IWE, ASME Section XI, Subsection IWF, Structures Monitoring, and Inspection of Water-Control Structures Associated with Nuclear Power Plants aging management programs provides preventative actions to provide reasonable assurance that bolting integrity is maintained for high-strength bolting. No corresponding enhancements to the above listed aging management programs are provided in the SLRA to incorporate guidance of standards and emphasis of the recommended preventative actions. A new enhancement is being created for the above listed aging management programs to reflect the use of guidance in the Preventative Action element relative to bolting integrity of high-strength bolts.

Accordingly, SLRA Appendix A, Section A.2.1.30, Appendix A, Section A.2.1 .31, Appendix A, Section A.2.1.34, Appendix A, Section A.2.1.35, Appendix A, Section A.5, Appendix 8, Section 8.2.1.30, Appendix 8, Section 8.2.1.31, Appendix 8, Section B.2.1.34, and Appendix 8, Section 8.2.1.35 are revised.

January 23, 2019 Enclosure A Page 46 of 187 SLRA Appendix A, Section A.2.1.30, ASME Section XI, Subsection IWE, page A-40, is revised as shown below to provide an enhancement to address preventative actions for bolting integrity.

This SLRA markup also includes the changes discussed in Change #19 below to address the implementation of a one-time supplemental volumetric examination of the containment metal shell and is duplicated here as an aid to the reviewer.

A.2.1.30 ASME Section XI, Subsection IWE The ASME Section XI, Subsection IWE aging management program is an existing condition monitoring program based on ASME Code and complies with the provisions of 10 CFR 50.55a. The program consists of periodic visual, surface, and volumetric examinations, where applicable, of metallic pressure-retaining components of steel containments for signs of degradation, damage, irregularities, and for coated areas distress of the underlying metal shell, and corrective actions. Acceptability of inaccessible areas of steel containment shell is evaluated when conditions found in accessible areas indicate the presence of, or could result in, flaws or degradation in inaccessible areas.

This program also includes aging management for the potential loss of material due to corrosion in the inaccessible areas of the BWR Mark I steel containment. In addition, the program includes supplemental surface examination to detect cracking for high temperature mechanical penetrations subject to cyclic loading but have no CLB fatigue analysis; and if triggered by plant-specific operating experience, a one-time supplemental volumetric examination by sampling randomly selected as well as focused locations susceptible to loss of thickness due to corrosion of containment shell that is inaccessible from one side. Inspection results are compared with prior recorded results in acceptance of components for continued service.

The ASME Section XI, Subsection IWE aging management program will be enhanced to:

1. Perform surface examinations on accessible portions of high temperature drywell mechanical penetrations, in addition to visual examinations, to detect cracking, once per 10-year interval during the second period of extended operation.

2. Clarify that the recommended guidance for proper selection of bolting material and lubricants, and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting is a requirement at Peach Bottom in accordance with the guidelines provided in EPRI NP-5067 and TR-104213. Clarify that the recommended requirements for storage, lubricant selection, and bolting and coating material selection include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication "Specification for Structural Joints Using High-Strength Bolts," are a requirement at Peach Bottom.

3. Implement a one-time supplemental volumetric examination of the containment metal shell surfaces that are inaccessible from one side, if triggered by plant-specific OE. The trigger for this supplemental examination is plant-specific occurrence or recurrence of measurable metal shell corrosion (base metal material loss exceeding 10 percent of nominal plate thickness) initiated on the inaccessible side or areas, identified since the date of issuance of the first renewed license. This supplemental volumetric examination consists of a sample of one-foot square locations that include both randomly-selected and focused

January 23, 2019 Enclosure A Page 47 of 187 areas most likely to experience degradation based on plant-specific OE and/or other relevant considerations such as environment. The sample size, locations, and any needed scope expansion (based on findings) for this one-time set of volumetric examinations should be determined on a plant-specific basis to demonstrate statistically with 95 percent confidence that 95 percent of the accessible portion of the containment liner is not experiencing corrosion degradation with greater than 1O percent loss of nominal thickness.

This onhansomont These enhancements will be implemented no later than six months prior to the second period of extended operation.

January 23, 2019 Enclosure A Page 48 of 187 SLRA Appendix A, Section A.2.1.31, ASME Section XI, Subsection IWF, page A-41, is revised to include enhancement 4 as shown below.

A.2.1.31 ASME Section XI, Subsection IWF The ASME Section XI, Subsection IWF aging management program will be enhanced to:

1. Perform periodic evaluations of the acceptability of inaccessible areas of supports (e.g., portions of supports encased in concrete, buried underground, or encapsulated by guard pipe), when conditions exist in accessible areas that could indicate the presence of, or result in, degradation to inaccessible areas of supports. Perform these evaluations once every 1O years during the second period of extended operation.

2. Perform a one-time inspection of an additional five percent of the currently inspected sample size specified in Table IWF-2500-1 for Class 1, 2, and 3 piping supports.

Conduct the one-time inspection within the five years prior to entering the second period of extended operation. Select the additional supports from the remaining population of IWF piping supports. Ensure that the sample expansion includes components that are most susceptible to age-related degradation (i.e., based on factors such as time in service, material, and aggressiveness of the environment).

3. Perform VT-3 examinations of all ASTM A-490 bolting materials, used for the reactor vessel support skirts and for the core spray pump supports once per 10-year interval during the second period of extended operation. Perform volumetric examination comparable to that of ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1 , of 12 ASTM A490 bolts at each of the reactor vessel support skirts, once per 10-year interval during the second period of extended operation.

4. Clarify that the recommended guidance for proper selection of bolting material and lubricants, and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting is a requirement at Peach Bottom in accordance with the guidelines provided in EPRI NP-5067 and TR-104213. Clarify that the recommended requirements for storage, lubricant selection, and bolting and coating material selection include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication "Specification for Structural Joints Using High-Strength Bolts," are a requirement at Peach Bottom.

These enhancements will be implemented in accordance with the schedule described within the enhancements. Inspections that are required to be performed in the five-year period prior to the second period of extended operation will be completed no later than six months prior to the second period of extended operation, or no later than the last refueling outage prior to the second period of extended operation.

January 23, 2019 Enclosure A Page 49 of 187 SLRA Appendix A, Section A.2.1 .34, Structures Monitoring, page A-44, is revised to include enhancement 13 as shown below.

A.2.1.34 Structures Monitoring

10. Expand the program to monitor elastomeric vibration isolators and bearing pads for cracking, loss of material, and hardening. Supplement visual inspection of elastomeric elements with tactile inspection to detect hardening, if the intended function is suspect.

Establish acceptance criteria for elastomeric pads and vibration isolation elements as no loss of material, cracking, or hardening that can lead to loss of isolation or support function.

11. Clarify that loose bolts and nuts and cracked bolts are not acceptable unless accepted by engineering evaluations.

12. Expand the program to inspect the fiberglass outer covering of permanent shielding blankets for signs of tears. If a tear is found, enter the condition into the corrective action program for evaluation. Repair or replace the permanent shielding, unless an evaluation determines that the condition is acceptable.

13. Clarify that the recommended guidance for proper selection of bolting material and lubricants, and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting is a requirement at Peach Bottom in accordance with the guidelines provided in EPRI NP-5067 and TR-104213. Clarify that the recommended requirements for storage, lubricant selection, and bolting and coating material selection include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication "Specification for Structural Joints Using High-Strength Bolts," are a requirement at Peach Bottom.

These enhancements will be implemented no later than six months prior to the second period of extended operation. Baseline inspections will be completed no later than six months prior to the second period of extended operation, or no later than the last refueling outage prior to the second period of extended operation.

January 23, 2019 Enclosure A Page 50 of 187 SLRA Appendix A, Section A.2.1.35, Inspection of Water-Control Structures Associated with Nuclear Power Plants, page A-46, is revised to include enhancement 14 as shown below.

A.2.1.35 Inspection of Water-Control Structures Associated with Nuclear Power Plants

8. Evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas.

9. Document the concrete conditions of submerged concrete structures.

10. Specify a six-year frequency for the inspection of the submerged portions of the traveling screen bays to match the inspection frequency of the submerged portions of the Circulating Water Pump Structure bays.

11. Perform inspections under the enhanced program in order to establish quantitative baseline inspection data prior to the second period of extended operation.

12. Provide evaluation criteria for structural concrete using quantitative second tier criteria of Chapter 5 in ACI 349.3R.

13. Clarify that loose bolts and nuts and cracked bolts are not acceptable unless accepted by engineering evaluations.

14. Clarify that the recommended guidance for proper selection of bolting material and lubricants, and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting is a requirement at Peach Bottom in accordance with the guidelines provided in EPRI NP-5067 and TR-104213. Clarify that the recommended requirements for storage, lubricant selection, and bolting and coating material selection include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication "Specification for Structural Joints Using High-Strength Bolts," are a requirement at Peach Bottom.

These enhancements will be implemented no later than six months prior to the second period of extended operation. Baseline inspections will be completed no later than six months prior to the second period of extended operation, or no later than the last refueling outage prior to the second period of extended operation.

January 23, 2019 Enclosure A Page 51 of 187 SLRA Appendix A, Section A.5, Commitments 30, 31, 34, and 35, on pages A-106, A-107, A-110, and A-111 are revised to include enhancements as shown below. This SLRA markup also includes the changes discussed in Change #19 below to address the implementation of a one-time supplemental volumetric examination of the containment metal shell for item no. 30 and is duplicated here as an aid to the reviewer.

A.5 Second License Renewal Commitment List PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

30 ASME Section XI, ASME Section XI, Subsection IWE is an existing program that will be enhanced to: Program will be Section A.2.1.30 Subsection IWE 1. Perform surface examinations on accessible portions of high temperature enhanced no later than drywell mechanical penetrations, in addition to visual examinations, to six months prior to the detect cracking, once per 10-year interval during the second period of second period of extended operation. extended operation.

2. Exelon Letter Clarify that the recommended guidance for proper selection of bolting material and lubricants, and appropriate installation torque PBAPSSLRA or tension to prevent or minimize loss of bolting preload and Supplement cracking of high-strength bolting is a requirement at Peach Bottom No. 2, dated in accordance with the guidelines provided in EPRI NP-5067 and January23, TR-104213. Clarify that the recommended requirements for 2019 storage, lubricant selection, and bolting and coating material selection include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication "Specification for Structural Joints Using High-Strength Bolts," are a requirement at Peach Bottom.

3. Implement a one-time supplemental volumetric examination of the containment metal shell surfaces that are inaccessible from one side, if triggered by plant-specific OE. The trigger for this supplemental examination is plant-specific occurrence or recurrence of measurable metal shell corrosion {base metal material loss exceeding 10 percent of nominal plate thickness) initiated on the inaccessible side or areas, identified since the date of issuance of the first renewed license. This supplemental volumetric examination consists of a sample of one-foot square locations that include both randomly-selected and focused areas most likely to experience degradation based on plant-specific OE and/or other relevant considerations such as environment. The sample size, locations, and any needed scope expansion {based on findings) for this one-time set of volumetric examinations should be determined on a plant-specific basis to demonstrate statistically with 95 percent confidence that 95 percent of the accessible portion of the containment liner is not experiencing corrosion degradation with greater than 1O percent loss of nominal thickness.

January 23, 2019 Enclosure A Page 52 of 187 PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

31 ASME Section XI, ASME Section XI, Subsection IWF is an existing program that will be enhanced to: Program will be enhanced Section A.2.1.31 Subsection IWF 1. Perform periodic evaluations of the acceptability of inaccessible areas of in accordance with the supports (e.g., portions of supports encased in concrete, buried schedule described within underground, or encapsulated by guard pipe), when conditions exist in the enhancements.

accessible areas that could indicate the presence of, or result in, Inspections that are degradation to inaccessible areas of supports. Perform these required to be performed evaluations once every 10 years during the second period of extended in the five-year period operation. prior to the second period of extended operation will

2. Perform a one-time inspection of an additional five percent of the be completed no later currently inspected sample size specified in Table IWF-2500*1 for Class than six months prior to 1, 2, and 3 piping supports. Conduct the one-time inspection within the the second period of five years prior to entering the second period of extended operation. extended operation, or no Select the additional supports from the remaining population of IWF later than the last piping supports. Ensure that the sample expansion includes refueling outage prior to components that are most susceptible to age-related degradation (i.e., the second period of based on factors such as time in service, material, and aggressiveness extended operation.

of the environment).

3. Perform VT-3 examinations of all ASTM A-490 bolting materials, used for the reactor vessel support skirts and for the core spray pump supports once per 10-year interval during the second period of extended operation. Perform volumetric examination comparable to that of ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1, of 12 ASTM A490 bolts at each of the reactor vessel support skirts, once per 10-year interval during the second period of extended operation.

Exelon Letter

4. Clarify that the recommended guidance for proper selection of bolting material and lubricants, and appropriate installation torque PBAPSSLRA or tension to prevent or minimize loss of bolting preload and Supplement cracking of high-strength bolting is a requirement at Peach Bottom No. 2, dated in accordance with the guidelines provided in EPRI NP-5067 and January23, TR-104213. Clarify that the recommended requirements for 2019 storage, lubricant selection, and bolting and coating material selection include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication "Specification for Structural Joints Using High-Strength Bolts," are a requirement at Peach Bottom.

January 23, 2019 Enclosure A Page 53 of 187 PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

34 Structures Monitoring 10. Expand the program to monitor elastomeric vibration isolators and Program will be Section A.2.1.34 bearing pads for cracking, loss of material, and hardening. Supplement enhanced no later than visual inspection of elastomeric elements with tactile inspection to detect six months prior to the hardening, if the intended function is suspect. Establish acceptance second period of criteria for elastomeric pads and vibration isolation elements as no loss extended operation.

of material, cracking, or hardening that can lead to loss of isolation or Baseline inspections will support function. be completed no later

11. Clarify that loose bolts and nuts and cracked bolts are not acceptable than six months prior to unless accepted by engineering evaluations. the second period of extended operation, or

12. Expand the program to inspect the fiberglass outer covering of no later than the last permanent shielding blankets for signs of tears. If a tear is found, enter refueling outage prior to the condition into the corrective action program for evaluation. Repair or the second period of replace the permanent shielding, unless an evaluation determines that extended operation.

the condition is acceptable.

Exelon Letter

13. Clarify that the recommended guidance for proper selection of bolting material and lubricants, and appropriate installation torque PBAPSSLRA or tension to prevent or minimize loss of bolting preload and Supplement cracking of high-strength bolting is a requirement at Peach Bottom No. 2, dated in accordance with the guidelines provided in EPRI NP-5067 and January23, TR-104213. Clarify that the recommended requirements for 2019 storage, lubricant selection, and bolting and coating material selection include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication "Specification for Structural Joints Using High-Strength Bolts," are a requirement at Peach Bottom.

January 23, 2019 Enclosure A Page 54 of 187 PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

35 Inspection of 8. Evaluate the acceptability of inaccessible areas when conditions exist in Program will be Section A.2.1.35 Water-Control accessible areas that could indicate the presence of, or result in, enhanced no later than Structures Associated degradation to such inaccessible areas. six months prior to the with Nuclear Power 9. Document the concrete conditions of submerged concrete structures. second period of Plants extended operation.

10. Specify a six-year frequency for the inspection of the submerged Baseline inspections will portions of the traveling screen bays to match the inspection frequency be completed no later of the submerged portions of the Circulating Water Pump Structure than six months prior to bays.

the second period of

11. Perform inspections under the enhanced program in order to establish extended operation, or quantitative baseline inspection data prior to the second period of no later than the last extended operation. refueling outage prior to

12. Provide evaluation criteria for structural concrete using quantitative the second period of second tier criteria of Chapter 5 in ACI 349.3R. extended operation.

13. Clarify that loose bolts and nuts and cracked bolts are not acceptable unless accepted by engineering evaluations.

14. Clarify that the recommended guidance for proper selection of Exelon Letter bolting material and lubricants, and appropriate installation torque PBAPSSLRA or tension to prevent or minimize loss of bolting preload and Supplement cracking of high-strength bolting is a requirement at Peach Bottom No. 2, dated in accordance with the guidelines provided in EPRI NP-5067 and January23, TR-104213. Clarify that the recommended requirements for 2019 storage, lubricant selection, and bolting and coating material selection include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication "Specification for Structural Joints Using High-Strength Bolts," are a requirement at Peach Bottom.

January 23, 2019 Enclosure A Page 55 of 187 SLRA Appendix B, Section B.2.1.30, ASME Section XI, Subsection IWE, page B-17 4, is revised as shown below to provide an enhancement to address preventative actions for bolting integrity. This SLRA markup also includes the changes discussed in Change #19 below to address the implementation of a one-time supplemental volumetric examination of the containment metal shell and is duplicated here as an aid to the reviewer.

B.2.1.30 ASME Section XI, Subsection IWE Enhancements Prior to the second period of extended operation, the following onhansomont enhancements will be implemented in the following program elements:

1. Perform surface examinations on accessible portions of high temperature drywall mechanical penetrations, in addition to visual examinations, to detect cracking, once per 10-year interval during the second period of extended operation. Program Elements Affected:

Parameters Monitored or Inspected (Element 3) and Detection of Aging Effects (Element 4)

2. Clarify that the recommended guidance for proper selection of bolting material and lubricants, and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting is a requirement at Peach Bottom in accordance with the guidelines provided in EPRI NP-5067 and TR-104213. Clarify that the recommended requirements for storage, lubricant selection, and bolting and coating material selection include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication "Specification for Structural Joints Using High-Strength Bolts," are a requirement at Peach Bottom. Program Elements Affected:

Preventative Action (Element 2)

3. Implement a one-time supplemental volumetric examination of the containment metal shell surfaces that are inaccessible from one side, if triggered by plant-specific OE. The trigger for this supplemental examination is plant-specific occurrence or recurrence of measurable metal shell corrosion (base metal material loss exceeding 1O percent of nominal plate thickness) initiated on the inaccessible side or areas, identified since the date of issuance of the first renewed license. This supplemental volumetric examination consists of a sample of one-foot square locations that include both randomly-selected and focused areas most likely to experience degradation based on plant-specific OE and/or other relevant considerations such as environment. The sample size, locations, and any needed scope expansion (based on findings) for this one-time set of volumetric examinations should be determined on a plant-specific basis to demonstrate statistically with 95 percent confidence that 95 percent of the accessible portion of the containment liner is not experiencing corrosion degradation with greater than 10 percent loss of nominal thickness. Program Elements Affected: Detection of Aging Effects (Element 4)

January 23, 2019 Enclosure A Page 56 of 187 SLRA Appendix B, Section B.2.1.31, ASME Section XI, Subsection IWF, page B-181, is revised to include enhancement 4 as shown below.

B.2.1.31 ASME Section XI, Subsection IWF Enhancements Prior to the second period of extended operation, the following enhancements will be implemented in the following program elements:

1. Perform periodic evaluations of the acceptability of inaccessible areas of supports (e.g.,

portions of supports encased in concrete, buried underground, or encapsulated by guard pipe),

when conditions exist in accessible areas that could indicate the presence of, or result in, degradation to inaccessible areas of supports. Perform these evaluations once every 1O years during the second period of extended operation. Program Element Affected: Scope of Program (Element 1)

2. Perform a one-time inspection of an additional five percent of the currently inspected sample size specified in Table IWF-2500-1 tor Class 1, 2, and 3 piping supports. Conduct the one-time inspection within five years prior to entering the second period of extended operation. Select the additional supports from the remaining population of IWF piping supports. Ensure that the sample expansion includes components that are most susceptible to age-related degradation (i.e., based on factors such as time in service, material, and aggressiveness of the environment). Program Element Affected: Detection of Aging Effects (Element 4)

3. Perform VT-3 examinations of all ASTM A490 bolting materials, used for the reactor vessel support skirts and tor the core spray pump supports once per 10-year interval during the second period of extended operation. Perform volumetric examination comparable to that of ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1, of 12 ASTM A490 bolts at each of the reactor vessel support skirts, once per 10-year interval during the second period of extended operation. Program Element Affected: Detection of Aging Effects (Element 4)

4. Clarify that the recommended guidance for proper selection of bolting material and lubricants, and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting is a requirement at Peach Bottom in accordance with the guidelines provided in EPR/ NP-5067 and TR-104213. Clarify that the recommended requirements for storage, lubricant selection, and bolting and coating material selection include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication "Specification for Structural Joints Using High-Strength Bolts," are a requirement at Peach Bottom. Program Elements Affected:

Preventative Action (Element 2)

January 23, 2019 Enclosure A Page 57 of 187 SLRA Appendix B, Section B.2.1.34, Structures Monitoring, page B-199, is revised to include enhancement 13 as shown below.

B.2.1.34 Structures Monitoring

10. Expand the program to monitor elastomeric vibration isolators and bearing pads for cracking, loss of material, and hardening. Supplement visual inspection of elastomeric elements with tactile inspection to detect hardening, if the intended function is suspect.

Establish acceptance criteria for elastomeric pads and vibration isolation elements as no loss of material, cracking, or hardening that can lead to loss of isolation or support function. Program Elements Affected: Parameters Monitored or Inspected (Element 3), Detection of Aging Effects (Element 4), and Acceptance Criteria (Element 6)

11. Clarify that loose bolts and nuts and cracked bolts are not acceptable unless accepted by engineering evaluations. Program Element Affected: Acceptance Criteria (Element 6)

12. Expand the program to inspect the fiberglass outer covering of permanent shielding blankets for signs of tears. If a tear is found, enter the condition into the corrective action program for evaluation. Repair or replace the permanent shielding, unless an evaluation determines that the condition is acceptable. Program Elements Affected: Parameters Monitored or Inspected (Element 3) and Acceptance Criteria (Element 6)

13. Clarify that the recommended guidance for proper selection of bolting material and lubricants, and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting is a requirement at Peach Bottom in accordance with the guidelines provided in EPRI NP-5067 and TR-104213. Clarify that the recommended requirements for storage, lubricant selection, and bolting and coating material selection include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication "Specification for Structural Joints Using High-Strength Bolts," are a requirement at Peach Bottom. Program Elements Affected:

Preventative Action (Element 2)

January 23, 2019 Enclosure A Page 58 of 187 SLRA Appendix B, Section B.2.1.35, Inspection of Water-Control Structures Associated with Nuclear Power Plants, page B-209, is revised to include enhancement 14 as shown below.

B.2.1.35 Inspection of Water-Control Structures Associated with Nuclear Power Plants

8. Evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas.

Program Element Affected: Detection of Aging Effects (Element 4)

9. Document the concrete conditions of submerged concrete structures. Program Element Affected: Detection of Aging Effects (Element 4)

10. Specify a six-year frequency for the inspection of the submerged portions of the traveling screen bays to match the inspection frequency of the submerged portions of the Circulating Water Pump Structure bays. Program Element Affected: Detection of Aging Effects (Element 4)

11. Perform inspections under the enhanced program in order to establish quantitative baseline inspection data prior to the second period of extended operation. Program Element Affected:

Monitoring or Trending (Element 5)

12. Provide evaluation criteria for structural concrete using quantitative second tier criteria of Chapter 5 in ACI 349.3R. Program Element Affected: Acceptance Criteria (Element 6)

13. Clarify that loose bolts and nuts and cracked bolts are not acceptable unless accepted by engineering evaluations. Program Element Affected: Acceptance Criteria (Element 6)

14. Clarify that the recommended guidance for proper selection of bolting material and lubricants, and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting is a requirement at Peach Bottom in accordance with the guidelines provided in EPRI NP-5067 and TR-104213. Clarify that the recommended requirements for storage, lubricant selection, and bolting and coating material selection include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication "Specification for Structural Joints Using High-Strength Bolts," are a requirement at Peach Bottom. Program Elements Affected:

Preventative Action (Element 2)

January 23, 2019 Enclosure A Page 59 of 187 Change #7 - Revise SLRA Section 3.3.2.2.9 to Delete the Service Water System Affected SLRA Sections: 3.3.2.2.9 SLRA Page Numbers: 3.3-60 Description of Change:

SLRA Section 3.3.2.2.9 addresses the loss of material in steel piping, piping components exposed to concrete and potentially exposed to groundwater. It includes the Service Water System in the list of systems addressed by this material and environment combination. As identified in SLRA Section 3.3.2.1.29 and as shown in SLRA Table 3.3.2-29 for the Service Water System, concrete is not an applicable environment for this system.

Accordingly, SLRA Section 3.3.2.2.9 is revised.

January 23, 2019 Enclosure A Page 60 of 187 SLRA Section 3.3.2.2.9, Loss of Material Due to General, Crevice or Pitting Corrosion and Cracking Due to Stress Corrosion Cracking, fourth paragraph, page 3.3-60, is revised as shown below:

3.3.2.2.9 Loss of Material Due to General, Crevice or Pitting Corrosion and Cracking Due to Stress Corrosion Cracking Carbon steel piping, piping components exposed to concrete in the Emergency Cooling Water System, Emergency Diesel Generator System, Emergency Service Water System, Fire Protection System, and High Pressure Service Water System, and Service '*"later System are potentially exposed to groundwater and loss of material is considered to be an applicable aging effect. Loss of material is addressed by Item Number 3.3.1-109. This aging effect is managed by the Buried and Underground Piping and Tanks (B.2.1.28) program.

January 23, 2019 Enclosure A Page 61 of 187 Change #8 - Additional Maintenance and Operating Experience Information for HVI Affected SLRA Sections: Section 3.6.2.3.2 SLRA Page Numbers: 3.6-17 through 3.6-20 Description of Change:

The SLRA Section 3.6.2.3.2 discussion for high voltage insulators is being updated to address current maintenance practices and operating experience. Additional maintenance and operating experience is being provided to support the evaluation which determined that there are no high voltage insulator aging effects requiring management, and therefore, no necessity for a High Voltage Insulator aging management program at PBAPS.

Accordingly, SLRA Section 3.6.2.3.2 is revised.

January 23, 2019 Enclosure A Page 62 of 187 SLRA Section 3.6.2.3.2, High-Voltage Electrical Insulators, pages 3.6-17 through 3.6-20, is revised as shown below.

3.6.2.3.2 High-Voltage Electrical Insulators Table 3.6.1 Item Numbers 3.6.1-002 and 3.6.1-003 - High-Voltage Electrical Insulators:

The PBAPS in scope high voltage electrical insulators (HVls), which includes in scope medium voltage insulators, were evaluated for aging effects requiring management during aging management reviews. The HVls in scope for license renewal are located in tAe offsite power source circuits and the alternate AC source for the SBO coping period. The in scope insulators include:

500 kV and 220 kV post insulators in offsite source paths 2SU, 343SU, and 3SU.

34.5 kV post insulators and strain insulators for the Susquehanna Substation and transmission connection conductor to the adjacent wooden pole, 13 kV post insulators and strain insulators for the 13 kV portion of offsite source paths, 2SU, 343SU, and 3SU.

The in scope HVls provide electrical insulation for switchyard bus, transmission conductors, switchyard active components, and associated connections that are part of the circuits that supply power from electric utility transmission system to plant buses, including connecting the alternate AC source in the event of a station black out. These circuits provide power to in scope license renewal components used for coping during and recovery from a station blackout event and during post fire safe shutdown, when offsite power is credited.

Airborne Contamination Various airborne materials such as salt, dust, fog, cooling tower plume, foreign debris, or industrial effluents can contaminate insulator surfaces. An excessive buildup of surface contamination enables the conductor voltage to track along the surface more easily and can lead to insulator flashover. The buildup of surface contamination is gradual and in most areas, such contamination is washed away by rain, where the glazed insulator surface aids in contamination removal.

Excessive surface contamination can be a problem in areas where there are greater concentrations of airborne particles such as near the seacoast where salt spray is prevalent, dust, near industrial facilities that discharge airborne pollutants, or at sites where the cooling tower plume may deposit contaminants on switchyard components and transmission lines.

At PBAPS and Susquehanna Substation, the in scope HVls; the 500 kV, 220 kV, 34.5 kV, and 13 kV post insulators and the 34.5 kV and 13 kV strain insulators, were evaluated for susceptibility to airborne surface contamination from salt, dust, fog, cooling tower plume, foreign debris, and industrial effluents. PBAPS and Susquehanna Substation are not located in an environment conducive to accelerated aging. Considering potential airborne salt contamination, the HVls are not located near a seacoast or near a brackish waterway.

PBAPS and Susquehanna Substation are approximately 1O miles away from the nearest seacoast or brackish waterway (Chesapeake Bay). It is located inland, in south central Pennsylvania where there is no source of airborne salt contamination. Considering potential

January 23, 2019 Enclosure A Page 63 of 187 airborne particulate contamination from industrial and agricultural activities (i.e., dust, soot),

the HVls are located in an area where industrial airborne particle concentrations and agricultural airborne particle concentrations are comparatively low, since it is located in a rural area with no heavy industry or agricultural pollution nearby. The nearest industrial facility is a clean air, natural gas fired power plant located approximately 2.5 miles away.

Considering potential cooling tower plume contamination, the cooling towers at PBAPS are mechanical cooling towers located along the river, at the south end of the site. In scope HVls are located upriver, at the north end of the site, in transmission substations atop the cliff adjacent to the plant site, and at the Susquehanna Substation and adjacent wooden pole which are approximately 10 miles downriver. The plume from these cooling towers poses no contamination risk to the in scope HVls because the mechanical cooling towers that are approximately 50 feet in height and are greater than a quarter mile away from the nearest in scope HVls. These plumes quickly dissipate before reaching the nearest in scope HVls. Considering potential foreign debris, the HVls are located in rural area with no heavy industry or urban population centers. The nearest residential community is 3 miles away from PBAPS and 1 mile away from the Susquehanna Substation.

Fog, in and of itself, is not a contaminant for HVls. Therefore, surface contamination from fog is not an aging effect, is not subject to an aging management review, and does not require aging management.

A ten-year search of operating experience for HVls was performed. Cumulative build up HVI contamination has not been experienced at PBAPS. Additionally, there are no existing preventive maintenance or inspection tasks that are precluding an occurrence of excessive HVI surface contamination.

Based on PBAPS and the Susquehanna Substation locations, lack of substantial airborne contaminants, and its corroborating operating experience, excessive HVI surface contamination is not expected to occur. HVI surface contamination is not a significant aging effect for PBAPS as noted by recent visual observations of these HVls in preparation of this application. Therefore, aging effects of surface contamination from salt, dust, fog, cooling tower plume, foreign debris, and industrial effluents are not applicable to PBAPS for the second period of extended operation. No aging management activity is required for the HVls due to airborne contamination.

In addition, an evaluation was performed for cracking of porcelain. Porcelain cracking or breaking is most commonly caused by an object striking the HVI. Porcelain cracking has also occurred when cement that binds the parts together expands excessively. This phenomenon is known as cement growth; it occurs as a result of improper manufacturing that makes the cement more susceptible to moisture penetration. Plant specific OE shows that porcelain cracking due to cement growth has not occurred at PBAPS. Therefore, cracking caused by physical damage is not an aging effect, is not subject to an aging management review, and does not require aging management.

Loss of Material - Mechanical Wear or Corrosion Loss of material of HVls can occur due to oscillating movement of transmission conductors due to significant and sustained winds. Significant wind can result in mechanical wear of metallic parts. Surface corrosion of HVI metallic parts can also occur due to environmental contamination or if galvanized or other protective coatings are worn from significant wind induced movement of transmission conductors.

January 23, 2019 Enclosure A Page 64 of 187 Mechanical wear is an aging effect for strain insulators in that they are subject to movement.

Movement can be caused by wind blowing the supported transmission conductor, causing it to swing. If this swinging is frequent enough, it could cause wear in the metal contact points of the insulator string.

The HVls to be evaluated for aging effects due to movement of transmission conductors due to significant wind are those conductors with strain HVls, which for PBAPS and the Susquehanna Substation, only include medium voltage transmission conductors (in scope 500 kV and 220 kV insulators are limited to post insulators). The in scope strain insulators are for the 34.5 kV transmission connection conductor routed between the Susquehanna Substation and the wooden pole adjacent to the substation and for the 13 kV transmission conductor that traverses the cliff to the west of PBAPS for the 343 startup feed.

The 34.5 kV transmission conductors are a connection span of three 34.5 kV 556 kcmil aluminum conductors, approximately 30 feet in length. The 13 kV transmission conductors have a relatively short, two spans of three 13 kV 1590 MGM 54/19 ACSR conductors with lengths of 760 feet and 410 feet. The PECO Transmission and Distribution design practices follow the National Electrical Safety Code (NESC) methodologies. The NESC sets the maximum tension of a conductor to withstand heavy load requirements which includes consideration of oscillating movement of transmission conductors due to significant wind.

Although this loss of material due to mechanical wear or corrosion of the metallic parts of HVls is possible, experience has shown that the transmission conductors do not normally swing and that when they do, due to significant wind, they do not continue to swing for very long once the wind has subsided. Wind loading, that can cause a transmission line to sway, is considered and minimized during design and installation. In additional, the concerns for transmission conductor to swing is reduced for shorter spans.

In addition, the installed configuration of the strain insulators minimizes movement. This reduces mechanical wear of metallic parts within the strain insulators such that these metallic contact points do not require inspection for mechanical wear. Therefore, aging effects due to loss of material due to mechanical wear is not applicable to PBAPS for the second period of extended operation.

Loss of material due to corrosion of HVls can also occur due to airborne contamination. A large buildup of contamination could result in corrosion of the metallic parts of the HVls, which if significant, could impact its structural intended function. As previously evaluated, based on the HVls' location, lack of airborne contaminants, and its corroborating operating experience, HVI metallic parts are not subject to a large buildup of contamination from airborne contaminants. Therefore, these metallic contact points do not require inspection for corrosion.

HVI metallic part contamination induced corrosion is not a significant aging effect for PBAPS. Therefore, aging effects of surface contamination induced metallic parts corrosion are not applicable to PBAPS for the second period of extended operation.

HVI metallic part aging due to wear from transmission conductor movement, airborne contamination, and surface rust are not significant aging concerns at PBAPS. These conditions have been addressed in design specifications. Visual observations have not identified significant corrosion during routine switchyard inspections, and are further

January 23, 2019 Enclosure A Page 65 of 187 confirmed as not occurring, per a review of operating experience which did not identify these aging effects as the cause or failure mechanism of documented issues with HVls. These aging effects are not significant at PBAPS and will not impact intended function of the HVls during the second period of extended operation. Therefore, aging effects of loss of material due to mechanical wear or corrosion are not applicable to PBAPS tor the second period of extended operation.

Operating Experience and Maintenance The PBAPS substation and transmission components that are in scope for second license renewal have predictive maintenance tasks performed by both PBAPS personnel and PECO Transmission and Distribution (T&D) maintenance crews. Tasks include visual inspection and thermography. There are no preventive measures being implemented (i.e., no routine cleaning of insulators is performed). PBAPS tasks are in place for Maintenance Rule. PECO T&D predictive maintenance tasks are in place as part of routine, normal, good maintenance, utility practices for substation and transmission components and commodities.

When an unacceptable condition or situation is identified, as part of the PBAPS corrective action program, an issue report is created for the abnormal visual inspection or predictive test results. Based on the significance, the corrective action program issue includes an engineering evaluation, an extent of condition review, identification of cause, and corrective actions that may include interim actions until the condition can be repaired.

PBAPS OE issues in the corrective action program were reviewed going back ten years. The OE review also included completion remarks in work orders and industry OE cited in GALL-SLR.

PBAPS corrective action program issues included applicability reviews for industry issues, including an extent of condition review performed to identify if PBAPS had any installed HVls, potentially subject to a manufacturing material defect, a non-aging issue. It was determined that there are no HVls with subject material at PBAPS. The review of this industry OE provides evidence that industry OE is evaluated for applicability at PBAPS, to ensure that HVls are assessed for potential issues, including issues not caused by aging.

PBAPS corrective action program issues also included several occurrences of degradation of 500 kV underhung insulators for circuits that are not in scope of second license renewal. These issues were attributed to the misapplication of hollow core insulators. There are no insulators of this type in the in scope circuits containing HVls at PBAPS.

During the review of plant specific OE, no onsite occurrences of HVI OE were identified that were attributable to aging. There was no PBAPS plant specific, HVI OE, for second license renewal in scope, as well as not in scope insulators, attributable to either loss of material of metallic parts or reduced insulation resistance.

Conclusion The main contributor to determining that no AMP is required for HVls is that there has been no age-related OE for PBAPS high voltage and medium voltage insulators, in scope as well as not in scope, confirming the lack of age degradation that would necessitate an AMP. The operating experience that was reviewed consistently

January 23, 2019 Enclosure A Page 66 of 187 demonstrated that the non-age-related issues were being identified as part of performing on going, routine predictive maintenance, prior to loss of function. Aging management activities for PBAPS high ¥oltage insulatorsHVls are not required for the second period of extended operation; therefore, the GALL-SLR report Xl.E7 "High Voltage Insulators" aging management program is not applicable to PBAPS.

In addition, to support this conclusion, in accordance with NUREG-2192 requirements, the SSC's including the HVI required to cope with, and recover from, the SBO event are included within the scope of second license renewal. These second license renewal boundaries include components credited to cope with, and recover from, the SBO event were established based on PBAPS current licensing basis consistent with the first license renewal application and aligned with the second license renewal scoping methodology. The HVls are included in the scope of second license renewal. In NUREG-1769, Safety Evaluation Report (SER) related to license renewal of PBAPS, Section 2.5.1. SER Section 2.5.3 concludes there is reasonable assurance that the applicant has adequately identified the electrical and instrumentation and control SSC's that were within the scope of license renewal and subject to an AMR in accordance with 10 CFR 54.4 and 10 CFR 54.21 (a)(1).

These HVl's are documented as an electrical commodity that the AMR determined the aging effect to be none al'}d, therefore, no aging management activity is required for the HVls. The evaluations for the first period of extended operation concluded that the HVls did not require aging management activities to continue to perform their intended function during the first period of extended operation. In agreement with the evaluations performed for the first period of extended operation, airborne contamination and loss of material due to mechanical wear or corrosion are not aging effects requiring management in that they would not cause a loss of intended function if left unmanaged for the second period of extended operation.

January 23, 2019 Enclosure A Page 67 of 187 Change #9 - Revise SLRA Section 3.4.2.2.8 to Address Loss of Material in Stainless Steel Piping, Piping Components Exposed to Concrete Affected SLRA Sections: 3.4.2.2.8 SLRA Page Numbers: 3.4-16 Description of Change:

The subject of SLRA Section 3.4.2.2.8 is loss of material and cracking in steel and stainless steel piping, piping components exposed to concrete and potentially exposed to groundwater. The discussion for Table 3.4.1 Item Number 3.4.1-082 refers to Item Number 3.4.1-072 for cracking but does not cite a similar item for loss of material. The discussion for Table 3.4.1 Item Number 3.4.1-082 should also refer to Item Number 3.4.1-047 for the loss of material.

Accordingly, SLRA Section 3.4.2.2.8 is revised.

January 23, 2019 Enclosure A Page 68 of 187 SLRA Section 3.4.2.2.8, Loss of Material Due to General, Crevice or Pitting Corrosion and Cracking Due to Stress Corrosion Cracking, fourth paragraph, page 3.4-16, is revised as shown below:

3.4.2.2.8 Loss of Material Due to General, Crevice or Pitting Corrosion and Cracking Due to Stress Corrosion Cracking Table 3.4.1 Item Number 3.4.1-082: This item evaluates stainless steel piping, piping components exposed to the concrete environment. Cracking due to sec and loss of material are not considered to be applicable aging effects for portions of the stainless steel piping, piping components exposed to concrete that is outdoors and above ground level in the Condensate Storage System since: (a) attributes of the concrete are consistent with American Concrete Institute (ACI) 318 or ACI 349 (low water-to-cement ratio, low permeability, and adequate air entrainment) as cited in NUREG-1557; (b) plant-specific OE indicates no degradation of the concrete that could lead to penetration of water to the metal surface; and (c) the piping is not potentially exposed to groundwater. Portions of the stainless steel piping, piping components in the Condensate Storage System that are exposed to concrete and are outdoors and below ground level are susceptible to cracking due to SCC and loss of material because they are potentially exposed to groundwater, and are addressed by Item Numbers 3.4.1-072 and 3.4.1-047, respectively.

January 23, 2019 Enclosure A Page 69 of 187 Change #10-Addition of Loss of Preload Aging Effect in Bronze Hatch/Plug Bolting in the Circulating Water Pump Structure Affected SLRA Sections: Table 3.5.1, Table 3.5.2-3, and Appendix B, Section B.2.1.34 SLRA Page Numbers: 3.5-102, 3.5-103, 3.5-127, and B-197 Description of Change:

SLRA Table 3.5.2-3, Circulating Water Pump Structure, Summary of Aging Management Evaluation, includes the component type of Hatches/Plugs. These components include bronze bolting in Air - Indoor Uncontrolled and Air - Outdoor environments with no aging effects. The bronze bolting should include the aging effect of loss of preload managed by the Structures Monitoring program.

Accordingly, SLRA Table 3.5.1, Table 3.5.2-3, and Appendix B, Section B.2.1.34 are revised.

January 23, 2019 Enclosure A Page 70 of 187 SLRA Table 3.5.1, Summary of Aging Management Evaluations for the Containments, Structures and Component Supports, pages 3.5-102 and 3.5-103, are revised as shown below:

Table 3.5.1 Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Further Item Aging Aging Management Component Evaluation Discussion Number Effect/Mechanism Programs Recommended 3.5.1-088 Structural bolting Loss of preload due AMP Xl.S6, "Structures No Consistent with NUREG-2191. The to self-loosening Monitoring" Structures Monitoring {B.2.1.34) program will be used to manage loss of preload for structural bolting and anchors made from aluminum, brass, bronze, carbon and low alloy steel, galvanized steel, stainless steel; metal components- cable trays and wireway gutters; panels, racks, frames, cabinets, and other enclosures; roofing; hatches/plugs; spent fuel pool gates; structural miscellaneous - siding and vents; bolted connections for supports for cable trays, conduit, HVAC components and ducts, tube track, instrument tubing, non-ASME piping and components, sliding support bearings and surfaces, emergency diesel generator, and other mechanical equipment; bolted connections for supports for platforms, pipe whip restraints, jet impingement shields, masonry walls, and other structures; bolted connections for supports for racks, panels, cabinets, and enclosures for electrical equipment and instrumentation exposed to air- indoor uncontrolled, air- outdoor, raw water, and treated water in the Administration Building and Shop, Boiler House, Circulating Water Pump Structure, Containment Structure, Dewatering Building, Diesel Generator

January 23, 2019 Enclosure A Page 71 of 187 Table 3.5.1 Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Further Item Aging Aging Management Component Evaluation Discussion Number Effect/Mechanism Programs Recommended Building, Emergency Cooling Tower and Reservoir, Nitrogen Storage Building, Outdoor Electric Switchgear, North Substation, Radwaste Building and Reactor Auxiliary Bay, Reactor Building, Recombiner Building, Stack, Station Blackout Structure and Foundations, Turbine Building and Main Control Room Complex, and Yard Structures, as well as the commodity groups for Component Supports, Electrical and Instrumentation Enclosures and Raceways, Hazard Barriers and Elastomers, and Miscellaneous Steel.

The Inspection of Overhead Heavy Load and Light Load (Related to Refueling)

Handling Systems (B.2.1.13) program has been substituted and will be used to manage loss of preload of the stainless steel structural bolting exposed to air -

indoor uncontrol and treated water in the Fuel Handling System.

January 23, 2019 Enclosure A Page 72 of 187 SLRA Table 3.5.2-3, Circulating Water Pump Structure, Summary of Aging Management Evaluation, page 3.5-127, is revised as shown below:

Table 3.5.2-3 Circulating Water Pump Structure (Continued)

Component Intended Material Environment Aging Effect Requiring Aging Management NUREG-2191 NUREG-2192 Notes Type Function Management Programs Item Table 1 Item Hatches/Plugs Flood Barrier Bronze Bolting Air- Indoor Loss of Preload Structures Monitoring lll.A3. TP-261 3.5.1-088 A Missile Barrier Uncontrolled (B.2.1.34)

Shelter and Protection Structural Support None None IV.E.R-453 3.1.1-137 c Air - Outdoor Loss of Preload Structures Monitoring lll.A3. TP-261 3.5.1-088 A (B.2.1.34)

None None IV.E.R-453 3.1.1-137 c

January 23, 2019 Enclosure A Page 73 of 187 SLRA Appendix B, Section B.2.1.34, Structures Monitoring, Program Description, eighth paragraph, page B-197, is revised as shown below:

B.2.1.34 Structures Monitoring Program Description Applicable metallic materials within the scope of this program include: aluminum, carbon steel, ductile iron, galvanized steel, and stainless steel; applicable bolting materials include: aluminum, brass, bronze, carbon steel, galvanized steel, and stainless steel. Applicable non-metallic materials within the scope of this program include: reinforced concrete, elastomer, fiberglass, grout, and Lubrite.

January 23, 2019 Enclosure A Page 74 of 187 Change #11 - Addition of Plant Specific Notes for Grade 2 Titanium Affected SLRA Sections: Table 3.3.2-13, Table 3.3.2-21, Table 3.4.2-4 SLRA Page Numbers: 3.3-318, 3.3-321, 3.3-244, 3.3-247, 3.3-249, 3.4-80, and 3.4-84 Description of Change:

SLRA Tables 3.3.2-13, 3.3.2-21, and 3.4.2-4 include component types (other than heat exchanger tubes) constructed of titanium and exposed to treated water. There are no aging effects identified tor these titanium components. NUREG-2191 indicates that there are no aging effects tor titanium grades 1, 2, 7, 9, 11, or 12 in treated water; however, the SLRA tables do not identify the grade of titanium. A plant specific note is being added to these tables identifying the titanium as grade 2.

Accordingly, SLRA Table 3.3.2-13, Table 3.3.2-21, and Table 3.4.2-4 are revised.

January 23, 2019 Enclosure A Page 75 of 187 SLRA Table 3.3.2-13, Emergency Service Water System, Summary of Aging Management Evaluation, pages 3.3-244, 3.3-247, and 3.3-249 are revised as shown below:

Table 3.3.2-13 Emergency Service Water System (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Management Piping, piping Leakage Boundary Titanium Air- Indoor None None Vll.J.AP-160 3.3.1-122 A components Uncontrolled (External)

Treated Water (Internal; None None Vll.J.A-766 3.3.1-237 A,2

January 23, 2019 Enclosure A Page 76 of 187 Table 3.3.2-13 Emergency Service Water System (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Management Valve Body Leakage Boundary Titanium Air- Indoor None None Vll.J.AP-160 3.3.1-122 A Uncontrolled (External)

Treated Water (Internal) None None Vll.J.A-766 3.3.1-237 A,2

January 23, 2019 Enclosure A Page 77 of 187 Table 3.3.2-13 Emergency Service Water System (Continued)

Notes Definition of Note A Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

8 Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

c Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

D Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

E Consistent with NUREG-2191 item for material, environment, and aging effect, but a different aging management program is credited or NUREG-2191 identifies a plant-specific aging management program.

F Material not in NUREG-2191 for this component.

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

H Aging effect not in NUREG-2191 for this component, material, and environment combination.

Aging effect in NUREG-2191 for this component, material, and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-2191.

Plant Specific Notes:

1. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25) program is substituted to manage the aging effect(s) applicable to this component type, material and environment combination.

2. Components are constructed of grade 2 titanium.

January 23, 2019 Enclosure A Page 78 of 187 SLRA Table 3.3.2-21, Process Sampling System, Summary of Aging Management Evaluation, pages 3.3-318 and 3.3-321 are revised as shown below:

Table 3.3.2-21 Process Sampling System (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item ManaQement Piping, piping Leakage Boundary Titanium Air - Indoor Uncontrolled None None Vll.J.AP-160 3.3.1-122 A components <External)

Treated Water (Internal) None None Vll.J.A-766 3.3.1-237 A,2

January 23, 2019 Enclosure A Page 79 of 187 Table 3.3.2-21 Process Sampling System (Continued)

Notes Definition of Note A Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

B Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

c Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

D Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

E Consistent with NUREG-2191 item for material, environment, and aging effect, but a different aging management program is credited or NUREG-2191 identifies a plant-specific aging management program.

F Material not in NUREG-2191 for this component.

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

H Aging effect not in NUREG-2191 for this component, material, and environment combination.

I Aging effect in NUREG-2191 for this component, material, and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-2191.

Plant Specific Notes:

1. The TLAA designation in the Aging Management Program column indicates that fatigue of this component is evaluated in Section 4.3.

2. Components are constructed of grade 2 titanium.

January 23, 2019 Enclosure A Page 80 of 187 SLRA Table 3.4.2-4, Main Condenser System, Summary of Aging Management Evaluation, pages 3.4-80 and 3.4-84 are revised as shown below. This SLRA markup also includes the changes discussed in Change #2 above to address applicability of cracking for titanium Heat Exchanger tubes, and is duplicated here as an aid to the reviewer.

Table 3.4.2-4 Main Condenser System Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Management Heat Exchanger - Holdup Titanium Raw Water (Internal) Cracking Inspection of Internal Vlll.E.S-478b 3.4.1-130 A (Main Condenser) Surfaces in Miscellaneous Tube Sheet Piping and Ducting Components (B.2.1.25)

Treated Water None None Vlll.l.S-463 3.4.1-115 A,3 (External)

Heat Exchanger - Holdup Titanium Raw Water (Internal) Cracking Inspection of Internal Vll.C1.A-736 3.3.1-207 A (Main Condenser) Surfaces in Miscellaneous Tubes Piping and Ducting Components (B.2.1.25)

One-Time Inspection Vlll.E.S-462 3.4-1-114 A (B.2.1.21)

Cracking Treated Water Water Chemistry Vlll.E.S-462 3.4-1-114 B (External) (8.2.1.2)

None None Vlll.E.S-462 3.4.1-114 I, 1

January 23, 2019 Enclosure A Page 81 of 187 Table 3.4.2-4 Main Condenser System (Continued)

Notes Definition of Note A Consistent with NUREG-2191 item tor component, material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

B Consistent with NUREG-2191 item tor component, material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

c Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

D Component is different, but consistent with NUREG-2191 item tor material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

E Consistent with NUREG-2191 item tor material, environment, and aging effect, but a different aging management program is credited or NUREG-2191 identifies a plant-specific aging management program.

F Material not in NUREG-2191 tor this component.

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

H Aging effect not in NUREG-2191 tor this component, material, and environment combination.

I Aging effect in NUREG-2191 tor this component, material, and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-2191.

Plant Specific Notes:

1. The component performs an intended function of holdup only and therefore, the aging effects of crackina and reduction of heat transfer due to fouling ara is not applicable.

2. The rupture disks are constructed of 3003 aluminum alloy which is not susceptible to stress corrosion cracking.

3. Components are constructed of grade 2 titanium.

January 23, 2019 Enclosure A Page 82 of 187 Change #12 - Revise SLRA Table 3.5.2-22 to Use Line Items Associated with Steel Tank Foundations Affected SLRA Sections: Table 2.4-22, Section 3.5.2.2.2.1, Table 3.5.1, and Table 3.5.2-22 SLRA Page Numbers: 2.4-70, 3.5-38 to 3.5-40, 3.5-42 to 3.5-44, 3.5-74, 3.5-77, 3.5-88 to 3.5-92, and 3.5-279 to 3.5-285 Description of Change:

Structure elements associated with Group 8 structures (steel tanks and missile barriers) were not separately identified using line items associated with Group 8 structures during the Aging Management Review phase of the PBAPS SLR project. This change involves revising the Table 3.5.2-22 line items for the steel tank foundations (condensate, refueling water, and diesel fuel oil storage tanks) in scope for License Renewal, which are identified under Yard Structures (Manholes, Duct Banks, Valve Pits, etc.) in Table 3.5.2-22. These Table 3.5.2-22 line items are revised from Group 3 structure lines to Group 8 structure lines. In order to allow for the separate identification of all the elements associated with steel tank foundations, additional component types are created just for these components, e.g., Bolting (Structural - Storage Tanks). As part of these changes, editorial revisions are made to improve consistency of the component type names associated with tank foundations. The changes from Group 3 to Group 8 structure lines affected Table 3.5.1 line summaries that are revised accordingly to identify Group 8 structures and make similar changes to applicable further evaluations regarding Group 8 structures. The addition of the component types in Table 3.5.2-22 also affects Table 2.4-22 that is revised to reflect the additional component types.

Accordingly, SLRA Table 2.4-22, Section 3.5.2.2.2.1, Table 3.5.1, and Table 3.5.2-22 are revised.

January 23, 2019 Enclosure A Page 83 of 187 SLRA Table 2.4-22, Yard Structures (Manholes, Duct Banks, Valve Pits, etc.), Components Subject to Aging Management Review, page 2.4-70 is revised as shown below. This SLRA markup to Table 2.4-22 also includes the changes, discussed in Change #15 below to address the aging management of accessible concrete for the aging effect of "Increase in Porosity and Permeability; Loss of Strength/Leaching of Calcium Hydroxide and Carbonation," and is duplicated here as an aid to the reviewer.

Table 2.4-22 Yard Structures (Manholes, Duct Banks, Valve Pits, etc.)

Components Subject to Aging Management Review Component TvDe Intended Function Boltinq (Structural) Structural Suooort Bolting {Structural-Storage Tanks) Structural Suooort Concrete elements: All (Foundation Structural Support Condensate and Refueling Water Stora1=1e Tanks)

Concrete elements: All (Foundation Structural Support Diesel Fuel Oil Storage Tanks)

Concrete elements: Anchors Structural Suooort Concrete elements: Anchors (Storage Structural Support Tanks)

Concrete elements: Curbs Direct Flow Concrete elements: Embedments Structural Suooort Concrete: Above-grade exterior Missile Barrier, Shelter and Protection, (accessible areas) Structural Suooort Concrete: Above-grade exterior Missile Barrier, Shelter and Protection, (inaccessible areas) Structural Suooort Concrete: Basemat, Foundation, Structural Support Subfoundation (accessible areas)

Concrete: Basemat, Foundation, Structural Support Subfoundation (inaccessible areas)

Concrete: Below-grade exterior Missile Barrier, Shelter and Protection, (inaccessible areas) Structural Support Concrete: Exterior above- and below- Structural Support grade; foundation {accessible areas)

Concrete: Interior (accessible areas) Missile Barrier, Shelter and Protection, Structural Support Concrete: Interior (inaccessible areas) Missile Barrier, Shelter and Protection, Structural Support Equipment supports and foundations Structural Support

{Storaae Tanks)

Manholes, Handholes & Duct Banks Shelter and Protection, Structural Supoort Steel components: structural steel Structural Support Steel components: structural steel Structural Support

{Storage Tanks)

January 23, 2019 Enclosure A Page 84 of 187 SLRA Section 3.5.2.2.2.1, Aging Management of Inaccessible Areas, item #1, first paragraph, page 3.5-38; item #2, first and third paragraphs on pages 3.5-39 and 3.5-40; as well as item #4, first, fifth, and last paragraphs on pages 3.5-42 to 3.5-44, are revised as shown below:

3.5.2.2.2.1 Aging Management of Inaccessible Areas

1. Loss of material (spa/ling, scaling) and cracking due to freeze-thaw could occur in be/ow-grade inaccessible concrete areas of Groups 1-3, 5 and 7-9 structures. Further evaluation is recommended of this aging effect for inaccessible areas of these Groups of structures for plants located in moderate to severe weathering conditions.

[First Paragraph]

Table 3.5.1 Item Number 3.5.1-042: This aging effect and mechanism, the loss of material (spalling, scaling) and cracking due to freeze-thaw, is applicable to PBAPS reinforced concrete structures. PBAPS is located in a region where weathering conditions are considered severe as shown in ASTM C33. The Structures Monitoring (B.2.1.34) program will be used to manage loss of material (spalling, scaling) and cracking in both accessible and inaccessible areas of reinforced concrete for the Groups 2, 3, 8, and 9 structures. At PBAPS, the there are no stand-alone Group 1 or 5 structures, which at PBAPS, are part of the Group 2 Reactor Buildings. PBAPS does not have any Group 7 Gf=-8....structures. None of these structures are completely inaccessible, and there are significant portions of the structures that are accessible that provide indications of reinforced concrete conditions in inaccessible areas.

2. Cracking due to expansion and reaction with aggregates could occur in inaccessible concrete areas for Groups 1-5 and 7-9 structures. Further evaluation is recommended of inaccessible areas of these Groups of structures to determine if a plant-specific AMP is required to manage this aging effect.

[First Paragraph]

Table 3.5.1 Item Number 3.5.1-043: This aging effect and mechanism, cracking due to expansion and reaction with aggregates, is considered applicable to PBAPS reinforced concrete structures. The Structures Monitoring (B.2.1.34) program will be used to manage cracking due to expansion and reaction with aggregates in both accessible and inaccessible areas of reinforced concrete for the Groups 2, 3, 4, 8, and 9 structures. At PBAPS, the there are no stand-alone Group 1 or 5 structures, which at PBAPS, are part of the Group 2 Reactor Buildings. PBAPS does not have any Group 7 Gf=-8....structures.

None of these structures are completely inaccessible, and there are significant portions of the structures that are accessible. The accessible portions of the structures provide indications of reinforced concrete conditions in inaccessible areas.

January 23, 2019 Enclosure A Page 85 of 187

[Third Paragraph]

Cracking associated with expansion due to reaction with aggregates has not been observed on PBAPS Group 2, 3, 4, 8, and 9 concrete structures. Nevertheless, the Structures Monitoring (B.2.1.34) program continues to inspect and monitor reinforced concrete structures tor cracking due to any mechanism. The condition of accessible and above grade concrete is used as an indicator tor the condition of the inaccessible and below grade structural components and provides reasonable assurance that degradation of inaccessible structural components will be detected before a loss of an intended function. If cracking due to expansion and reaction with aggregates were significant, pattern cracking would be expected over most of the surfaces at grade level where the moisture level is higher. This has not occurred. The Group 6 structures, Circulating Water Pump Structure and the Emergency Cooling Tower and Reservoir, which have higher exposure to water compared to other reinforced concrete structures at PBAPS, may be used as leading structures to indicate the presence of expansion and reaction with aggregates for the other reinforced concrete structures that are in scope, as described in Subsection 3.5.2.2.2.3.2

4. Increase in porosity and permeability, and loss of strength due to leaching of calcium hydroxide and carbonation could occur in below-grade inaccessible concrete areas of Groups 1-5 and 7-9 structures. Further evaluation is recommended if leaching is observed in accessible areas that impact intended functions.

[First Paragraph]

Table 3.5.1 Item Number 3.5.1-047: This aging effect and mechanism, increase in porosity and permeability and loss of strength due to leaching of calcium hydroxide and carbonation, is considered applicable to PBAPS reinforced concrete structures. The Structures Monitoring (B.2.1.34) program will be used to manage the increase in porosity and permeability and loss of strength due to leaching of calcium hydroxide and carbonation in both accessible and inaccessible areas for the Groups 2, 3, 8, and 9 structures. At PBAPS, the there are no stand-alone Group 1 or 5 structures, which at PBAPS, are part of the Group 2 Reactor Buildings. PBAPS does not have any Group 7 af-8 structures. This Item Number does not apply to the Group 4 structures due to the Mark I containment design. None of these structures are completely inaccessible, and there are significant portions of the structures that are accessible that provide indications of reinforced concrete conditions in inaccessible areas.

[Fifth Paragraph]

Inaccessible below-grade reinforced concrete for Groups 2, 3, 8, and 9 structures is subject to an aggressive environment. Tet results tor groundwater and raw water samples taken between 2016 and 2018 showed pH limits are safely above the threshold limit for pH> 5.5, and sulfates are safely lower than the threshold limit for sulfates <1500 ppm and this would indicate a non- aggressive environment. Chlorides in a minority of groundwater testing wells exceed the threshold limit for chlorides< 500 ppm, which indicates an aggressive environment. All of the raw water tests, e.g., river water, were safely less than the threshold limit tor chlorides < 500 ppm which indicates a non-

January 23, 2019 Enclosure A Page 86 of 187 aggressive environment. Therefore, only the ground water is considered to be aggressive and only for high chloride levels. High chloride levels are a concern as a potential initiator of reinforcing steel corrosion that could be initially detected as cracking and spalling of concrete. The groundwater at PBAPS is not aggressive with respect to pH or sulfates. Therefore, increase in porosity and permeability and loss of strength due to leaching is not expected.

[Last Paragraph]

The Structures Monitoring (B.2.1.34) program will continue to manage the increase in porosity and permeability and loss of strength due to leaching of calcium hydroxide and carbonation in both accessible and inaccessible areas of Groups 2, 3, 8, and 9 structures. In addition, PBAPS will continue will examine exposed portions of the below-grade concrete, when excavated for any reason. Therefore, no additional measures for managing the aging effect of increase in porosity and permeability, and loss of strength for concrete are required for inaccessible areas of Groups 1, 2, 3, 8, and 9 structures.

January 23, 2019 Enclosure A Page 87 of 187 SLRA Table 3.5.1, Summary of Aging Management Evaluations for the Containments, Structures and Component Supports, pages 3.5-7 4, 3.5-77, and 3.5-88 to 3.5-92, are revised as shown below. This SLRA markup to Table 3.5.1, Item 3.5.1-063, also includes the changes, discussed in Change #15 below to address the aging management of accessible concrete for the aging effect of "Increase in Porosity and Permeability; Loss of Strength/Leaching of Calcium Hydroxide and Carbonation," and is duplicated here as an aid to the reviewer.

Table 3.5.1 Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Further Item Aging Aging Management Component Evaluation Discussion Number Effect/Mechanism Programs Recommended 3.5.1-042 Groups 1-3, 5, 7-9: Loss of material Plant-specific aging Yes The Structures Monitoring (B.2.1.34) concrete (inaccessible (spalling, scaling) and management program program will be used to manage loss of areas): foundation cracking due to material (spalling, scaling) and cracking of freeze-thaw the reinforced concrete in inaccessible areas exposed to an air - outdoor environment in Group 2, 3, 8, and 9 structures.

PBAPS used Group 2 Item Numbers instead of Group 1 or 5 Item Numbers.

PBAPS does not have Group 7-a00-8 structures.

See Subsection 3.5.2.2.2.1.1.

January 23, 2019 Enclosure A Page 88 of 187 Table3.5.1 Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Further Item Aging Aging Management Component Evaluation Discussion Number Effect/Mechanism Programs Recommended 3.5.1-047 Groups 1-5, 7-9: concrete Increase in porosity Plant-specific aging Yes The Structures Monitoring (B.2.1.34)

(inaccessible areas): and permeability; loss management program program will be used to manage increase in exterior above- and of strength due to porosity and permeability, loss of strength below-grade; foundation leaching of calcium of the reinforced concrete basemat, hydroxide and foundation, subfoundation, below-grade carbonation exterior concrete (inaccessible areas), duct banks, manholes, and handholes exposed to water- flowing in Groups 2, 3, B, and 9 structures.

PBAPS used Group 2 Item Numbers instead of Group 1 or 5 Item Numbers.

PBAPS does not have Group 7 aRd-8 structures.

This Item Number does not apply to the Group 4 concrete structures because of the Mark I containment design.

See Subsection 3.5.2.2.2.1.4.

January 23, 2019 Enclosure A Page 89 of 187 Table 3.5.1 Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Further Item Aging Aging Management Component Evaluation Discussion Number Effect/Mechanism Programs Recommended 3.5.1-063 Groups 1-3, 5, 7-9: Increase in porosity AMP Xl.S6, "Structures No Consistent with NUREG-2191. The concrete {accessible and permeability; loss Monitoring" Structures Monitoring {B.2.1.34) program areas): exterior above- of strength due to will be used to manage increase in porosity and below-grade; leaching of calcium and permeability, loss of strength of the foundation hydroxide and grout and reinforced concrete exterior carbonation above- and below-grade, basemat, foundation, subfoundation {accessible areas), iAteRaf; equipment supports and foundations, and penetration Seals exposed to water - flowing in Groups 2, 3, B, and 9 structures, and the Hazard Barriers and Elastomers commodity group.

At PBAPS, the there are no stand-alone Group 1 or 5 structures, which are part of the Group 2 Reactor Buildings.

Group 7 aAEl-8-structures are not applicable to PBAPS.

January 23, 2019 Enclosure A Page 90 of 187 Table 3.5.1 Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Further Item Aging Aging Management Component Evaluation Discussion Number Effect/Mechanism Programs Recommended 3.5.1-064 Groups 1-3, 5, 7-9: Loss of material AMP Xl.S6, "Structures No Consistent with NUREG-2191. The concrete (accessible (spalling, scaling) and Monitoring" Structures Monitoring (B.2.1.34) program areas): exterior above- cracking due to will be used to manage cracking and loss of and below-grade; freeze-thaw material of the grout and reinforced foundation concrete elements of the condensate storage tank foundation, curbs, above-grade exterior (accessible areas), basemat, foundation, subfoundation (accessible areas), interior (accessible areas),

equipment supports and foundations, hatches/plugs, manholes, handholes &

duct banks, penetration seals, and precast beams and panels exposed to air- outdoor in the Group 2, 3, 8, and 9 structures, and the Hazard Barriers and Elastomers commodity group.

At PBAPS, the there are no stand-alone Group 1 or 5 structures, which are part of the Group 2 Reactor Buildings.

Group 7 aAG-8 structures are not applicable to PBAPS.

January 23, 2019 Enclosure A Page 91 of 187 Table3.5.1 Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Further Item Aging Aging Management Component Evaluation Discussion Number Effect/Mechanism Programs Recommended 3.5.1-065 Groups 1-3, 5, 7-9: Cracking; loss of AMP Xl.S6, "Structures No Consistent with NUREG-2191. The concrete (inaccessible bond; and loss of Monitoring" Structures Monitoring (B.2.1.34) program areas): below-grade material (spalling, will be used to manage cracking, loss of exterior; foundation, scaling) due to bond, and loss of material at reinforced Groups 1-3, 5, 7-9: corrosion of concrete elements for Groups 2, 3, B, and concrete (accessible embedded steel 9: at inaccessible areas of concrete below-areas): below-grade grade exterior, basemat, foundation, and exterior; foundation, subfoundation; and Group 6 and other Groups 6: concrete concrete for Hazard Barriers and (inaccessible areas): all Component Supports in accessible and inaccessible areas above-grade and below-grade exterior, interior, basemat, foundation, and subfoundation as well tank foundations, curbs, duct banks, equipment supports and foundations, manholes, handholes, and duct banks, penetration seals, and at locations of expansion and grouted anchors and grout pads; exposed to air - indoor uncontrolled, air - outdoor, and groundwater/soil environments.

At PBAPS, the there are no stand-alone Group 1 or 5 structures, which are part of the Group 2 Reactor Buildings.

Group 7 aRG-8 structures are not applicable to PBAPS.

January 23, 2019 Enclosure A Page 92 of 187 Table 3.5.1 Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Further Item Aging Aging Management Component Evaluation Discussion Number Effect/Mechanism Programs Recommended 3.5.1-066 Groups 1-5, 7, 9: Cracking; loss of AMP Xl.S6, "Structures No Consistent with NUREG-2191. The concrete (accessible bond; and loss of Monitoring" Structures Monitoring (B.2.1.34) program areas): interior and material (spalling, will be used to manage cracking, loss of above-grade exterior scaling) due to bond, and loss of material of Groups 2, 3, corrosion of 4, and 9 concrete, grout, and reinforced embedded steel concrete elements: for concrete above-grade exterior (accessible areas and inaccessible areas); concrete: basemat, foundation, and subfoundation (accessible areas and inaccessible areas); concrete:

Interior, (accessible areas and inaccessible areas); and other concrete for curbs, equipment supports and foundations, hatches/plugs, manholes, handholes, and duct banks, and precast concrete- beams and panels; as well as grout for penetration seals for the Hazard Barriers and Elastomers commodity group. These areas are exposed to air - indoor uncontrolled and air - outdoor environments.

At PBAPS, the there are no stand-alone Group 1 or 5 structures, which are part of the Group 2 Reactor Buildings.

Group 7 aAEl-8 structures are not applicable to PBAPS.

January 23, 2019 Enclosure A Page 93 of 187 Table 3.5.1 Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Further Item Aging Aging Management Component Evaluation Discussion Number Effect/Mechanism Programs Recommended 3.5.1-067 Groups 1-5, 7, 9: Increase in porosity AMP Xl.S6, "Structures No Consistent with NUREG~2191. The Concrete: interior; and permeability; Monitoring" Structures Monitoring (B.2.1.34) program above-grade exterior, cracking; loss of will be used to manage increase in porosity Groups 1-3, 5, 7 material (spalling, and permeability, cracking, and loss of concrete (inaccessible scaling) due to material (spalling, scaling) of the reinforced areas): below-grade aggressive chemical concrete components for Groups 2, 3, 8, exterior; foundation, attack and 9: concrete below-grade exterior Group 6: concrete (inaccessible areas), basemat, foundation, (inaccessible areas): all subfoundation (accessible and inaccessible areas); Group 6 inaccessible concrete elements; as well as other concrete such as tank foundations, curbs, equipment supports and foundations, manholes, and handholes, and duct banks exposed to groundwater/soil.

At PBAPS, the there are no stand-alone Group 1 or 5 structures, which are part of the Group 2 Reactor Buildings.

Group 7 aAG-8 structures are not applicable to PBAPS.

This mechanism is only associated with exposure to groundwater at PBAPS so it does not apply to Group 4 concrete components, which are not exposed to groundwater.

January 23, 2019 Enclosure A Page 94 of 187 SLRA Table 3.5.2-22, Yard Structures (Manholes, Duct Banks, Valve Pits, etc.), Summary of Aging Management Evaluation, pages 3.5-279, 3.5-280, 3.5-283, 3.5-284, and 3.5-285, are revised as shown below. This SLRA markup to Table 3.5.2-22 also includes the changes, discussed in Change #15 below to address the aging management of accessible concrete for the aging effect of "Increase in Porosity and Permeability; Loss of Strength/Leaching of Calcium Hydroxide and Carbonation," and is duplicated here as an aid to the reviewer.

Table 3.5.2-22 Yard Structures {Manholes, Duct Banks, Valve Pits, etc.)

Summary of Aging Management Evaluation Table 3.5.2-22 Yard Structures {Manholes, Duct Banks, Valve Pits, etc.)

Component Intended Material Environment Aging Effect Requiring Aging Management NUREG-2191 NUREG-2192 Notes Type Function Management Programs Item Table 1 Item Bolting Structural Galvanized Air - Outdoor Loss of Material Structures Monitoring ///.AB. TP-274 3.5.1-0B2 A (Structural- Support Steel (B.2.1.34)

Storage Tanks) Bolting Loss of Preload Structures Monitoring Ill.AB. TP-261 3.5.1-0BB A (B.2.1.34)

Concrete Structural Reinforced Air - Outdoor Cracking, Loss of Bond, and Loss Structures Monitoring (B.2.1.34) lll.A3.TP-26 3.5.1-066 A elements: All Support concrete of Material (Soallina, Scalina)

(Foundation Cracking Structures MonitorinQ (B.2.1.34) 111.-AaAB. TP-25 3.5.1-054 A Condensate and Refueling Water Loss of Material (Spalling, Scaling) Structures Monitoring (B.2.1.34) 111.-AaAB.TP-23 3.5.1-064 A Storage Tanks) and Cracking Groundwater/Soil CrackinQ and Distortion Structures Monitorino (B.2.1.34) lll.A3AB. TP-30 3.5.1-044 A Cracking, Loss of Bond, and Loss Structures Monitoring (B.2.1.34) Ill.AB. TP-27 3.5.1-065 A of Material (Spalling, Scaling) lll.A3A8.TP-212 3.5.1-065 A Crackina Structures Monitorina (B.2.1.34' lll.A3A8.TP-204 3.5.1-043 A Increase in Porosity and Structures Monitoring (B.2.1.34) 111.-AaAB.TP-29 3.5.1-067 A Permeability, Cracking, Loss of Material (SpallinQ, ScalinQ)

Loss of Material (Spalling, Structures Monitoring Ill.AB. TP-10B 3.5.1-042 A Scaling) and Cracking (B.2.1.34)

Water - Flowing Increase in Porosity and Structures Monitoring Ill.AB. TP-24 3.5.1-063 A, 1 Permeability; Loss of Strength (B.2.1.34)

Ill.AB. TP-67 3.5.1-047 A, 1

January 23, 2019 Enclosure A Page 95 of 187 Table 3.5.2-22 Yard Structures (Manholes, Duct Banks, Valve Pits, etc.) (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Management Concrete elements: Structural Support Reinforced Groundwater/Soil Cracking and Distortion Structures Monitoring 111.-AaAB.TP-30 3.5.1-044 A All (Foundation concrete (B.2.1.34)

Diesel Fuel Oil 3.5.1-065 A Cracking, Loss of Bond, Structures Monitoring Ill.AB. TP-27 Storage Tanks) (B.2.1.34) and Loss of Material 3.5.1-065 A 111.-AaAB.TP-212 (Spalling, Scaling)

Cracking Structures Monitoring 111.-AaAB.TP-204 3.5.1-043 A (B.2.1.34)

Increase in Porosity and Structures Monitoring 111.-AaAB.TP-29 3.5.1-067 A Permeability, Cracking, (B.2.1 .34)

Loss of Material (Spalling, Scalina)

Loss of Material Structures Monitoring Ill.AB. TP-10B 3.5.1-lJ42 A (Spa/ling, Scaling) and (B.2.1.34)

Cracking Water - Flowing Increase in Porosity and Structures Monitoring Ill.AB. TP-24 3.5.1-063 A, 1 Permeability; Loss of (B.2.1.34)

Ill.AB. TP-67 3.5.1-047 A, 1 Strength Concrete elements: Structural Support Carbon and Low Air - Outdoor Loss of Material Structures Monitoring lll.A3.TP-274 3.5.1-082 A Anchors Alloy Steel (B.2.1 .34)

Bolting Loss of Preload Structures Monitoring lll.A3.TP-261 3.5.1-088 A (B.2.1.34)

Concrete Structural Support Carbon and LoMi Air - Outdoor Loss of Material Structures Monitoring Ill.AB. TP-274 3.5.1-0B2 A elements: Alloy Steel (8.2.1.34J Anchors (Storage Bolting Loss of Preload Structures Monitoring /II.AB. TP-261 3.5.1-0BB A Tanks)

(B.2.1.34)

January 23, 2019 Enclosure A Page 96 of 187 Table 3.5.2-22 Yard Structures (Manholes, Duct Banks, Valve Pits, etc.) (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Manaaement Concrete: Structural Support Reinforced Water - Flowing Increase in Porosity and Structures Monitoring /ll.A3. TP-24 3.5.1-063 A, 1 Exterior above- concrete Permeability; Loss of (B.2.1.34) and below-grade; Strength foundation (accessible areas)

Concrete: Interior Missile Barrier Reinforced Air- Indoor Cracking, Loss of Bond, Structures Monitoring lll.A3.TP-26 3.5.1-066 A (accessible areas) Shelter and concrete Uncontrolled and Loss of Material (B.2.1.34)

Protection CSoallina, Scalina)

Structural Support Cracking Structures Monitoring lll.A3.TP-25 3.5.1-054 A (B.2.1.34)

Concrete: Interior Missile Barrier Reinforced Air - Indoor Cracking, Loss of Bond, Structures Monitoring lll.A3.TP-26 3.5.1-066 c (inaccessible Shelter and concrete Uncontrolled and Loss of Material (B.2.1.34) areas) Protection (Spalling, Scaling)

Structural Support Cracking Structures Monitoring lll.A3.TP-204 3.5.1-043 A (B.2.1.34)

Equipment Structural Support Carbon Steel Air - Outdoor Loss of Material Structures Monitoring /II.AB. TP-302 3.5.1-077 A supports and (B.2.1.34) foundations (Storage Tanks)

January 23, 2019 Enclosure A Page 97 of 187 Table 3.5.2-22 Yard Structures (Manholes, Duct Banks, Valve Pits, etc.) (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Management Steel components: Structural Support Galvanized Steel Air - Outdoor Loss of Material Structures Monitoring 111.82.TP-6 3.5.1-093 A structural steel (B.2.1.34)

Steel Structural Support Galvanized Air - Outdoor Loss of Material Structures Monitoring Ill.AB. TP-302 3.5.1-077 A components: Steel (B.2.1.34) structural steel (Storage Tanks)

January 23, 2019 Enclosure A Page 98 of 187 Table 3.5.2-22 Yard Structures (Manholes, Duct Banks, Valve Pits, etc.) (Continued)

Notes Definition of Note A Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

B Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

c Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP is cunsistent with NUREG-2191 AMP.

D Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

E Consistent with NUREG-2191 item for material, environment, and aging effect, but a different aging management program is credited or NUREG-2191 identifies a plant-specific aging management program.

F Material not in NUREG-2191 for this component.

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

H Aging effect not in NUREG-2191 for this component, material, and environment combination.

I Aging effect in NUREG-2191 for this component, material, and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-2191.

Plant Specific Notes:

~

1. The "water - flowing" environment has been added so that the aging effect and mechanism of "Increase in Porosity and Permeability, Loss of Strength/Leaching of Calcium Hydroxide and Carbonation" is addressed under the Structures Monitoring (B.2. 1.34) program.

January 23, 2019 Enclosure A Page 99 of 187 Change #13 - Addition of Exception for Flow Blockage Due to Fouling Affected SLRA Sections: Appendix B, Section B.2.1.30 SLRA Page Numbers: B-173, B-174 Description of Change:

The scope of the Peach Bottom ASME Section XI, Subsection IWE aging management program includes the management of flow blockage due to fouling for the Core Spray System, High Pressure Coolant Injection System, Reactor Core Isolation Cooling System, and Residual Heat Removal System pump suction strainers located in the suppression pool. There are no GALL SLR line items that manage flow blockage due to fouling for these components and as a result, there is no GALL aging management program specified to perform the associated management activities. Therefore, this change creates a second exception to the ASME Section XI, Subsection IWE aging management program to perform the aging management of this function. This program was selected because the station Containment lnservice Inspection requirements described in the Augmented Inspection program plan and procedures will address the aging management actions as part of the containment activities described below. All (100%) of the strainer assemblies shall be visually inspected during each interval for general structural condition, and one strainer module (screen) in the AHR system and one strainer module (screen) in the Core Spray system shall be inspected for debris during every other refueling outage. The HPCI and RCIC strainers shall be inspected for debris during every other refueling outage.

Accordingly, SLRA Appendix B, Section B.2.1.30 is revised.

January 23, 2019 Enclosure A Page 100 of 187 SLRA Appendix B, Section B.2.1.30, ASME Section XI, Subsection IWE, beginning on page B-173, is revised in paragraph 1 and to include exception 2 as shown below.

B.2.1.30 ASME Section XI, Subsection IWE NUREG-2191 Consistency The ASME Section XI, Subsection IWE aging management program will be consistent with the ten elements of aging management program Xl.S1, "ASME Section XI, Subsection IWE" specified in NUREG-2191 with the following exception exceptions.

Exceptions to NUREG-2191

1. NUREG-2191 states that steel, stainless steel, and dissimilar metal weld pressure-retaining components that are subject to cyclic loading but have no CLB fatigue analysis, are monitored for cracking and are supplemented with surface examination (or other applicable technique) in addition to visual examination to detect cracking. Peach Bottom does not monitor for cracking utilizing supplemental surface examinations except at high temperature mechanical penetrations. Program Elements Affected: Parameters Monitored or Inspected (Element 3) and Detection of Aging Effects (Element 4)

Justification for Exception The PBAPS drywell contains stainless steel penetration sleeves, dissimilar metal welds, and steel components that are subject to cyclic loading but have no current licensing basis fatigue analysis. The Peach Bottom primary containment was designed in accordance with ASME Section Ill, 1965 edition and applicable addenda through the Summer 1966 edition. No fatigue analysis or exemption/waiver was required per this code year or original construction specifications as permitted by later code year editions. PBAPS has performed an assessment that has shown that had the drywell been designed to ASME Section Ill, 1974 edition, it would have met the criteria in subsection NE-3222.4(d) 'Vessel not requiring analysis for cyclic operation'. The criteria that were met to address this condition included: 1) atmospheric to operating pressure cycle, 2) normal operation pressure fluctuation, 3) temperature difference -

startup and shutdown, 4) temperature difference - normal operation, 5) temperature difference

- dissimilar metals, and 6) mechanical loads. This drywell fatigue waiver assessment concluded that the components that could be subject to cyclic loading, but have no current licensing basis fatigue analysis, are subjected to an acceptable and negligible amount of fatigue, and therefore no visual or surface examinations will be performed. The assessment did not include drywell penetration bellows which have fatigue analysis and penetration adapters of high temperature drywell mechanical penetrations.

The majority of the surface of these components are not accessible for visual inspection or surface examination for cracking due to the Mark I containment design. The program will be enhanced to perform surface examinations on accessible portions of drywell high temperature mechanical penetrations in addition to visual examinations to detect cracking for penetrations that could be subject to cyclic loading but have no CLB fatigue analysis. Original design and installation specifications for containment penetration components such as bellows, welds, and penetration adapters required initial surface examinations to ensure no flaws existed as part of initial installation. Appropriate integrated and local leak rate testing is conducted for pressure boundary components per the 10 CFR 50 Appendix J aging management program. Through-wall cracking would be detected by the type A integrated leak rate test. Additionally, VT-3

January 23, 2019 Enclosure A Page 101 of 187 examinations are performed on accessible portions of the containment penetrations in accordance with the IWE program. Peach Bottom has not experienced a failure of the above listed containment components and integrated leak rate test results have shown significant margin. Industry operating experience has also shown strong performance of the subject primary containment components. License renewal applications for other similar Mark I containments designed to later code years have credited fatigue waivers. The design of penetrations where fatigue waivers are not credited limit loads from the piping onto the drywall by either using bellows or installation of small bore diameter pipe. Therefore, the existing 10 CFR Part 50 Appendix J leak testing and ASME Section XI, Subsection IWE, are adequate to detect cracking without requiring surface examination of these containment components subjected to low levels of fatigue.

2. The NUREG-2191 Chapter Xl.S1, ASME Section XI, Subsection /WE aging management program does not manage the aging effect of flow blockage due to fouling.

The scope of the ASME Section XI, Subsection /WE aging management program will manage flow blockage due to fouling for the Core Spray System, High Pressure Coolant Injection System, Reactor Core Isolation Cooling System, and Residual Heat Removal System pump suction strainers located in the suppression pool. Program Elements Affected: Scope of Program (Element 1), Parameters Monitored or Inspected (Element 3),

Detection of Aging Effects (Element 4), and Acceptance Criteria (Element 6)

Justification for Exception The scope of the ASME Section XI, Subsection /WE aging management program will include the management of flow blockage due to fouling for the for the Core Spray System, High Pressure Coolant Injection System, Reactor Core Isolation Cooling System, and Residual Heat Removal System pump suction strainers located in the suppression pool. No existing GALL line items exist for the management of flow blockage due to fouling for these components and as a result, there is no GALL aging management program specified to perform the associated management activities. The ASME Section XI, Subsection /WE aging management program was selected because the station Containment /SI program plan and procedures will perform the required aging management actions. The suction strainer inspections are performed as an augmented inspection program requirement, which is an inspection performed by above and beyond the requirements of ASME Section XI.

January 23, 2019 Enclosure A Page 102 of 187 Change #14 - Revise SLRA Table 3.5.2-5 Line Items Associated with Refueling Bellows Affected SLRA Sections: Table 3.5.1, Table 3.5.2-5 SLRA Page Numbers: 3.5-73, 3.5-110, 3.5-166, and 3.5-170 Description of Change:

Aging management of steel elements associated with the stainless steel refueling bellows is updated to be associated with the One-Time Inspection aging management program instead of referring to the Structures Monitoring aging management program. This change involves revising the Table 3.5.2-5 line items for the steel elements associated with the stainless steel refueling bellows in Table 3.5.2-5. These Table 3.5.2-5 line items are revised to conform to the lines used for other stainless steel, structural elements. This revision affects Table 3.5.1. In addition, a plant specific note was revised to specifically address the existing monitoring of the refueling bellows.

Accordingly, SLRA Table 3.5.1 and Table 3.5.2-5 have been revised.

January 23, 2019 Enclosure A Page 103 of 187 SLRA Table 3.5.1, Summary of Aging Management Evaluations for the Containments, Structures and Component Supports, pages 3.5-73 and 3.5-110, are revised as shown below:

Table 3.5.1 Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Further Item Aging Aging Management Component Evaluation Discussion Number Effect/Mechanism Programs Recommended 3.5.1-039 Steel elements: vent line Cracking due to SCC AMP Xl.S1 I "ASME Yes Consistent with NUREG-2191 with bellows Section XI, Subsection exceptions. The 10 CFR Part 50, IWE," and AMP Xl.S4, Appendix J (B.2.1.32) program and ASME "10 CFR Part 50, Section XI, Subsection IWE (B.2.1 .30)

Appendix J" program will be used to manage cracking of the stainless steel elements: vent line, header, and bellows exposed to air - indoor uncontrolled in the Containment Structure.

Exceptions apply to the NUAEG-2191 recommendations for ASME Section XI, Subsection IWE (B.2.1.30) program implementation.

+l=le StFblStblFes MeAiteFiA§ {Q.:U .34) f:lF9§raFR Ras eeeA SblSStitblteEI aAEI will ee blseEI te FRaAa§e sraskiA§ ef tl=le staiAless Steel eleFReAtS Qf tl=le FefbleliA§ eelle>NS asseFRl:llies eMi;ieseEI te aiF iAEl99F blASeAtmlleEI iA tl=le CeAtaiAmeAt StFblSlblFe.

See Subsection 3.5.2.2.1.6.

January 23, 2019 Enclosure A Page 104 of 187 Table 3.5.1 Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Further Item Aging Aging Management Component Evaluation Discussion Number Effect/Mechanism Programs Recommended 3.5.1-100 Aluminum, stainless steel Loss of material due AMP Xl.M32, "One-Time Yes Consistent with NUREG-2191. The One-support members; welds; to pitting and crevice Inspection," AMP Xl.S6, Time Inspection (B.2.1.21) program will be bolted connections; corrosion, cracking "Structures Monitoring," used to manage cracking and loss of support anchorage to due to sec or AMP Xl.M36, "External material of aluminum and stainless steel building structure Surfaces Monitoring of members and bolting, for embedments; Mechanical Components" conduit; equipment storage racks, expansion joints, fuel storage racks, hatches and plugs, hazard barriers, metal components- cable trays, wireway gutters, poles, and outdoor structures; insulation and insulation jacketing; panels, racks, frames, cabinets, and other enclosures; penetration seals; roofing; spent fuel pool gates; steel elements- liner, liner anchors, aAG-integral attachments, and refueling bellows; structural miscellaneous -

shielding, siding, and vents; supports for cable trays, conduit, HVAC ducts, tube track, instrument tubing, and non-ASME piping and components exposed to air-indoor uncontrolled and air- outdoor environments in the Circulating Water Pump Structure, Containment, Outdoor Electric Switchgear, North Substation, Radwaste Building and Reactor Auxiliary Bay, Reactor Building, Recombiner Building, Stack, Station Blackout Structure and Foundations, and Turbine Building and Main Control Room Complex, as well as commodity groups Component Supports, Electrical and Instrumentation Enclosures and Raceways, Hazard Barriers and Elastomers, Insulation, and Miscellaneous Steel.

January 23, 2019 Enclosure A Page 105 of 187 Table 3.5.1 Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Further Item Aging Aging Management Component Evaluation Discussion Number Effect/Mechanism Programs Recommended The Inspection of Overhead Heavy Load and Light Load (Related to Refueling)

Handling Systems (B.2.1.13) program has been substituted and will be used to manage cranes, hoists, and their associated structural bolting for loss of material in aluminum and cracking and loss of material in stainless steel exposed to air

- indoor uncontrolled for the Fuel Handling System.

See Subsection 3.5.2.2.2.4.

January 23, 2019 Enclosure A Page 106 of 187 SLRA Table 3.5.2-5, Containment Structure, Summary of Aging Management Evaluation, pages 3.5-166 and 3.5-170, are revised as shown below:

Table 3.5.2-5 Containment Structure (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Manaqement Steel elements: Water Retaining Stainless Steel Air- Indoor Cracking Str1:1st1:1res Menitering 11.81.1.CP aQ 3.a.1 039 A,4,5 Refueling Bellows Boundary Uncontrolled (B.2.1.34) 111.82. T-37a 3.5.1-100 assemblies One-Time Inspection (8.2.1.21)

Loss of Material One* Time Inspection 111.82. T*37a 3.5.1-100 A, 4, 5 (8.2.1.21)

January 23, 2019 Enclosure A Page 107 of 187 Table 3.5.2-5 Containment Structure (Continued)

Notes Definition of Note A Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

B Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

c Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

D Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

E Consistent with NUREG-2191 item for material, environment, and aging effect, but a different aging management program is credited or NUREG-2191 identifies a plant-specific aging management program.

F Material not in NUREG-2191 for this component.

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

H Aging effect not in NUREG-2191 for this component, material, and environment combination.

Aging effect in NUREG-2191 for this component, material, and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-2191.

Plant Specific Notes:

1. The Structures Monitoring (B.2.1.34) program is used to manage the aging effect of reduction of strength due to irradiation for this component type, material, and environment combination.

2. The TLAA designation in the Aging Management Programs column indicates fatigue of this component is evaluated in Section 4.6.

3. The sliding supports and bearings for drywell steel beams do not use Lubrite or similar material but are instead steel to steel connections. The Structures Monitoring (B.2.1.34) program is substituted to manage the aging effects of this applicable to this component type, material, and environment combination.

4. The normal environment for this component is Air-Indoor, Uncontrolled. The treated water environment exists only on a short term basis during refueling outages, and therefore, it is not addressed separately for aging management.

5. Tho Struoturos Monitoring (B.2.1.a4) program is substituted to manage tho applioable aging effeots for this oomponont typo, material, and environment oombination. This component is not in low-flow or stagnant areas since the area is drained upon completion of the refueling outage and heat from the reactor pressure vessel causes rapid evaporation of any moisture remaining in the bellows. Plant-specific operating experience reviews have not identified any failures or leakage from the refueling bellows as described in SLRA section 3.5.2.2.1.3 Item 1, and any such failures would be detected by monitoring of water level in the spent fuel pool and as well as by reactor cavity and bellows leakage detection instrumentation that alarms in the main control room.

January 23, 2019 Enclosure A Page 108 of 187 Change #15 - Revise SLRA to Include the Aging Effect, "Increase in Porosity and Permeability. and Loss of Strength Due to Leaching of Calcium Hydroxide and Carbonation" for Accessible, Exterior Concrete Affected SLRA Sections:

• Tables 2.4-1, 2.4-2, 2.4-7, 2.4-13, 2.4-14, 2.4-15, 2.4-16, 2.4-17, 2.4-18, 2.4-19, 2.4-20, 2.4-21, 2.4-22

• Section 3.5.2.1.21

• Table 3.5.1

• Tables 3.5.2-1, 3.5.2-2, 3.5.2-7, 3.5.2-13, 3.5.2-14, 3.5.2-15, 3.5.2-16, 3.5.2-17, 3.5.2-18, 3.5.2-19, 3.5.2-20, 3.5.2-21, 3.5.2-22 SLRA Page Numbers:

• 2.4-~. 2.4-6, 2.4-25, 2.4-42, 2.4-45, 2.4-48, 2.4-52, 2.4-56, 2.4-58, 2.4-61, 2.4-65, 2.4-67, 2.4-70

• 3.5-25, 3.5-88, 3.5-114, 3.5-115, 3.5-117, 3.5-120, 3.5-176, 3.5-177, 3.5-217, 3.5-219, 3.5-222, 3.5-225, 3.5-228, 3.5-233, 3.5-237, 3.5-248, 3.5-251, 3.5-255, 3.5-258, 3.5-261, 3.5-264, 3.5-269, 3.5-272, 3.5-276, 3.5-277, 3.5-278, 3.5-279, 3.5-280, 3.5-283, 3.5-284, and 3.5-285 Description of Change:

To demonstrate GALL SLR Table 1 Item Number 3.5.1-063 consistency, and to explicitly identify that the following aging effect, "increase in porosity and permeability, and loss of strength due to leaching of calcium hydroxide and carbonation," is addressed for accessible, exterior concrete, additional lines are added to the tables in SLRA section 3.5.2 for the applicable structures. A component type of "Concrete: Exterior above- and below-grade; foundation (accessible areas)" is added for this aging effect and mechanism for each structure affected by this change. A new plant specific note is added to clarify the environment used for this component type and aging mechanism combination. The addition of these new line items in the 3.5.2 tables affect the corresponding tables in section 2.4 for the affected structures. The Table 3.5.1, Item 3.5.1-063 is revised to reflect these changes.

For consistency, the line for the subject aging effect in Table 3.5.2-19 for the Station Blackout Structure and Foundation, which was applied to interior concrete, is deleted since it is unnecessary.

Accordingly, the following SLRA tables and sections are revised:

• Tables 2.4-1, 2.4-2, 2.4-7, 2.4-13, 2.4-14, 2.4-15, 2.4-16, 2.4-17, 2.4-18, 2.4-19, 2.4-20, 2.4-21, 2.4-22

• Section 3.5.2.1.21

• Table 3.5.1

• Tables 3.5.2-1, 3.5.2-2, 3.5.2-7, 3.5.2-13, 3.5.2-14, 3.5.2-15, 3.5.2-16, 3.5.2-17, 3.5.2-18, 3.5.2-19, 3.5.2-20, 3.5.2-21, 3.5.2-22

January 23, 2019 Enclosure A Page 109 of 187 SLRA Table 2.4-1, Administration Building and Shop, Components Subject to Aging Management Review, page 2.4-3, is revised as shown below:

Table 2.4-1 Administration Building and Shop Components Subject to Aging Management Review Component Type Intended Function Boltinq (Structural) Structural Support Concrete elements: Anchors Structural Support Concrete elements: Embedments Structural Support Concrete: Above-grade exterior Structural Support (accessible areas)

Concrete: Above-grade exterior Structural Support (inaccessible areas)

Concrete: Basemat, Foundation, Structural Support Subfoundation (accessible areas)

Concrete: Basemat, Foundation, Structural Support Subfoundation (inaccessible areas)

Concrete: Below-grade exterior Structural Support (inaccessible areas)

Concrete: Exterior above- and below- Structural Support grade; foundation (accessible areas)

Concrete: Interior (accessible areas) Structural Suooort Concrete: Interior (inaccessible areas) Structural Suooort Masonry walls: Exterior Structural Suooort Masonry walls: Interior Structural Support Piles Structural Suooort Steel components: structural steel Structural Suooort Structural Miscellaneous - Deckinq Structural Suoport

January 23, 2019 Enclosure A Page 110 of 187 SLRA Table 2.4-2, Boiler House, Components Subject to Aging Management Review, page 2.4-6, is revised as shown below:

Table 2.4-2 Boiler House Components Subject to Aging Management Review Component Type Intended Function BoltinQ (Structural) Structural Support Concrete elements: Anchors Structural Support Concrete elements: Embedments Structural Support Concrete: Above-grade exterior Shelter and Protection, Structural Support (accessible areas)

Concrete: Above-grade exterior Shelter and Protection, Structural Support (inaccessible areas)

Concrete: Basemat, Foundation, Shelter and Protection, Structural Support Subfoundation (inaccessible areas)

Concrete: Exterior above- and below- Structural Support arade; foundation (accessible areas)

Concrete: Interior (accessible areas) Structural Suooort Concrete: Interior (inaccessible areas) Structural Support Equipment suooorts and foundations Structural Suooort Metal components Shelter and Protection, Structural Suooort Precast Concrete- Beams and Panels Shelter and Protection Steel components: structural steel Structural Suooort Structural Miscellaneous - Deckina Shelter and Protection Structural Miscellaneous - Sidina Shelter and Protection

January 23, 2019 Enclosure A Page 111 of 187 SLRA Table 2.4-7, Diesel Generator Building, Components Subject to Aging Management Review, page 2.4-25, is revised as shown below:

Table 2.4-7 Diesel Generator Building Components Subject to Aging Management Review Component Type Intended Function Boltina (Structural) Structural Support Concrete elements: Anchors Structural Support Concrete elements: Embedments Structural Support Concrete: Above-grade exterior Flood Barrier, Missile Barrier, Shelter and (accessible areas) Protection, Structural Suooort Concrete: Above-grade exterior Flood Barrier, Missile Barrier, Shelter and (inaccessible areas) Protection, Structural Suooort Concrete: Basemat, Foundation, Flood Barrier, Shelter and Protection, Subfoundation (inaccessible areas) Structural Support Concrete: Below-grade exterior Flood Barrier, Shelter and Protection, (inaccessible areas) Structural Support Concrete: Exterior above- and below- Structural Support grade; foundation (accessible areasJ Concrete: Interior (accessible areas) Flood Barrier, Missile Barrier, Shelter and Protection, Structural Support Equipment supports and foundations Structural Support Metal components Shelter and Protection Structural Support Piles Structural Support Steel components: structural steel Missile Barrier Structural Support Structural Miscellaneous- Decking Structural Support

January 23, 2019 Enclosure A Page 112 of 187 SLRA Table 2.4-13, Nitrogen Storage Building, Components Subject to Aging Management Review, page 2.4-42, is revised as shown below:

Table 2.4-13 Nitrogen Storage Building Components Subject to Aging Management Review Component Type Intended Function BoltinQ (Structural) Structural Support Concrete elements: Anchors Structural Support Concrete elements: Embedments Structural Support Concrete: Above-grade exterior Missile Barrier, Shelter and Protection, (accessible areas} Structural Suooort Concrete: Above-grade exterior Missile Barrier, Shelter and Protection, (inaccessible areas} Structural Support Concrete: Basemat, Foundation, Shelter and Protection, Structural Support Subfoundation (accessible areas)

Concrete: Basemat, Foundation, Shelter and Protection, Structural Support Subfoundation (inaccessible areas)

Concrete: Below-grade exterior Shelter and Protection, Structural Support (inaccessible areas}

Concrete: Exterior above- and below- Structural Support grade; foundation (accessible areas)

Concrete: Interior (accessible areas) Missile Barrier, Shelter and Protection, Structural Support Concrete: Interior (inaccessible areas) Missile Barrier, Shelter and Protection, Structural Suooort Equipment supports and foundations Structural Suooort

January 23, 2019 Enclosure A Page 113 of 187 SLRA Table 2.4-14, Outdoor Electric Switchgear, North Substation, Components Subject to Aging Management Review, page 2.4-45, is revised as shown below:

Table 2.4-14 Outdoor Electric Switchgear, North Substation Components Subject to Aging Management Review Component Type Intended Function Boltinq (Structural) Structural Support Concrete elements: Anchors Structural Suooort Concrete elements: Embedments Structural Suooort Concrete: Above-grade exterior Shelter and Protection, Structural Support (accessible areas)

Concrete: Above-grade exterior Shelter and Protection, Structural Support (inaccessible areas)

Concrete: Basemat, Foundation, Structural Support Subfoundation Concrete: Exterior above- and below- Structural Support grade; foundation (accessible areas)

Concrete: Interior Structural Supoort Manholes, Handholes & Duct Banks Shelter and Protection, Structural Support Metal components (includes poles and Structural Support outdoor structures)

Rootinq Shelter and Protection Steel components: structural steel Structural Support Structural Miscellaneous - Siding Shelter and Protection

January 23, 2019 Enclosure A Page 114 of 187 SLRA Table 2.4-15, Radwaste Building and Reactor Auxiliary Bay, Components Subject to Aging Management Review, page 2.4-48, is revised as shown below:

Table 2.4-15 Radwaste Building and Reactor Auxiliary Bay Components Subject to Aging Management Review Component Type Intended Function Bolting (Structural) Structural Support Concrete elements: Anchors Structural Support Concrete elements: Curbs Direct Flow Concrete elements: Embedments Structural Support Concrete: Above-grade exterior Flood Barrier, Missile Barrier, Shelter and (accessible areas) Protection, Shieldino, Structural Support Concrete: Above-grade exterior Flood Barrier, Missile Barrier, Shelter and (inaccessible areas) Protection, Shieldino, Structural Support Concrete: Basemat, Foundation, Flood Barrier, Shelter and Protection, Subfoundation (inaccessible areas) Structural Support Concrete: Below-grade exterior Flood Barrier, Missile Barrier, Shelter and (inaccessible areas) Protection, Structural Support Concrete: Exterior above- and below- Structural Support grade; foundation (accessible areas)

Concrete: Interior (accessible areas) Flood Barrier, HELB/MELB Shielding, Missile Barrier, Shelter and Protection, Shieldino, Structural Suooort Concrete: Interior (inaccessible areas) Flood Barrier, HELB/MELB Shielding, Missile Barrier, Shelter and Protection, Shieldino, Structural Suooort Doors (special shield doors) Missile Barrier Shelter and Protection Shieldino Equipment suooorts and foundations Structural Support Hatches/Plugs HELB/MELB Shieldino Shelter and Protection, Structural Support Masonry walls: Interior Shielding Structural Support Metal components Shelter and Protection, Structural Support Metal components (missile shield) Missile Barrier Precast Concrete- Beams and Panels Flood Barrier Shelter and Protection, Structural Support Slidino surfaces Expansion/Separation Steel components: structural steel Flood Barrier Structural Support Structural Miscellaneous - Deckino (floor) Structural Support Structural Miscellaneous - Deckinq (roof) Structural Suooort Structural Miscellaneous - Shielding Shielding, Structural Support Structural Miscellaneous - Sidino Shelter and Protection

January 23, 2019 Enclosure A Page 115 of 187 SLRA Table 2.4-16, Reactor Building, Components Subject to Aging Management Review, page 2.4-52, is revised as shown below:

Table 2.4-16 Reactor Building Components Subject to Aging Management Review Component Type Intended Function Boltina (Structural) Structural Support Concrete elements: Anchors Structural Support Concrete elements: Curbs Direct Flow Concrete elements: Embedments Structural Support Concrete: Above-grade exterior Flood Barrier, Missile Barrier, Shelter and (accessible areas) Protection, Shielding, Structural Pressure Barrier, Structural Suooort Concrete: Above-grade exterior Flood Barrier, Missile Barrier, Shelter and (inaccessible areas) Protection, Shielding, Structural Pressure Barrier, Structural Support Concrete: Basemat, Foundation, Flood Barrier, Shelter and Protection, Subfoundation (inaccessible areas) Structural Pressure Barrier, Structural Support Concrete: Below-grade exterior Flood Barrier, Missile Barrier, Shelter and (inaccessible areas) Protection, Structural Pressure Barrier, Structural Suooort Concrete: Exterior above- and below- Structural Support grade; foundation (accessible areas)

Concrete: Interior (accessible areas) Flood Barrier, Missile Barrier, Shelter and Protection, Shielding, Structural Pressure Barrier, Structural Support HELB/MELB Shieldina Concrete: Interior (inaccessible areas) Flood Barrier, Missile Barrier, Shelter and Protection, Shielding, Structural Pressure Barrier, Structural Support HELB/MELB Shielding Equipment Storage Racks (inside spent Structural Support fuel pool and reactor well)

Equipment supports and foundations Structural Support Fuel Storage Racks (New Fuel) Structural Support Fuel Storage Racks (Spent Fuel) Structural Suooort Fuel Storage Racks: neutron absorbing Absorb Neutrons sheets Hatches/Plugs Flood Barrier, Missile Barrier, Shelter and Protection, Shielding, Structural Pressure Barrier, Structural Support Hatches/Plugs (reactor well) Shieldina Water Retainina Boundarv Masonry walls: Interior HELB/MELB Shieldinq Shelter and Protection, Structural Suooort Shielding

January 23, 2019 Enclosure A Page 116 of 187 SLRA Table 2.4-17, Recombiner Building, Components Subject to Aging Management Review, page 2.4-56, is revised as shown below:

Table 2.4-17 Recombiner Building Components Subject to Aging Management Review Component Type Intended Function Boltina (Structural) Structural Suooort Concrete elements: Anchors Structural Support Concrete elements: Curbs Direct Flow Concrete elements: Embedments Structural Suooort Concrete: Above-grade exterior Shelter and Protection, Structural Support (accessible areas)

Concrete: Above-grade exterior Shelter and Protection, Structural Support (inaccessible areas)

Concrete: Basemat, Foundation, Shelter and Protection, Structural Support Subfoundation (inaccessible areas)

Concrete: Below-grade exterior Shelter and Protection, Structural Support (inaccessible areas)

Concrete: Exterior above- and below- Structural Support arade; foundation (accessible areas)

Concrete: Interior (accessible areas) Shelter and Protection, Structural Support Concrete: Interior (inaccessible areas) Shelter and Protection, Structural Suooort Equipment supports and foundations Structural Support Hatches/Plugs Shelter and Protection, Structural Support Masonrv walls: Exterior Shelter and Protection, Structural Suooort Masonrv walls: Interior Shelter and Protection, Structural Support Metal components Structural Support Precast Concrete- Beams and Panels Shelter and Protection, Structural Suooort Steel components: structural steel Structural Support Structural Miscellaneous - Decking (roof) Shelter and Protection, Structural Support Structural Miscellaneous - Sidina Shelter and Protection, Structural Support Structural Miscellaneous - Vents (blowout Pressure Relief, Shelter and Protection panel)

January 23, 2019 Enclosure A Page 117 of 187 SLRA Table 2.4-18, Stack, Components Subject to Aging Management Review, page 2.4-58, is revised as shown below:

Table 2.4-18 Stack Components Subject to Aging Management Review Component Type Intended Function Bolting (Structural) Structural Suooort Concrete elements: Anchors Structural Suooort Concrete elements: Embedments Structural Suooort Concrete: Above-grade exterior Gaseous Release Path (accessible areas} Shelter and Protection, Shielding, Structural Support Concrete: Above-grade exterior Gaseous Release Path (inaccessible areas} Shelter and Protection, Shielding, Structural Support Concrete: Basemat, Foundation, Structural Support Subfoundation (accessible areas) -

Concrete: Basemat, Foundation, Structural Support Subfoundation (inaccessible areas)

Concrete: Exterior above- and below- Structural Support grade; foundation (accessible areas)

Concrete: Interior (accessible areas} Gaseous Release Path Shelter and Protection, Shielding, Structural Support Concrete: Interior (inaccessible areas} Gaseous Release Path Shelter and Protection, Shielding, Structural Support Hatches/Pluos Direct Flow, Shelter and Protection Roofing Shelter and Protection Steel components: structural steel Structural Support Structural Miscellaneous - Sidino Shelter and Protection

January 23, 2019 Enclosure A Page 118 of 187 SLRA Table 2.4-19, Station Blackout Structure and Foundations, Components Subject to Aging Management Review, page 2.4-61, is revised as shown below:

Table 2.4-19 Station Blackout Structure and Foundations Components Subject to Aging Management Review Component TvDe Intended Function Boltinq (Structural) Structural Support Concrete elements: Anchors Structural Support Concrete elements: Embedments Structural Support Concrete: Above-grade exterior Structural Support (accessible areas)

Concrete: Above-grade exterior Structural Support (inaccessible areas)

Concrete: Below-grade exterior Structural Support (inaccessible areas)

Concrete: Exterior above- and below- Structural Support grade; foundation (accessible areas)

Concrete: Interior Structural Support Conowinqo Hydroelectric Plant (Dam) Shelter and Protection, Structural Suooort Duct Banks Shelter and Protection Equipment supports and foundations Structural Support Manholes, Handholes & Duct Banks Shelter and Protection, Structural Suooort Metal components Structural Support Structural Miscellaneous - Deckinq (Roof) Shelter and Protection, Structural Suooort Structural Miscellaneous - Siding Shelter and Protection, Structural Suooort

January 23, 2019 Enclosure A Page 119 of 187 SLRA Table 2.4-20, Turbine Building and Main Control Room Complex, Components Subject to Aging Management Review, page 2.4-65, is revised as shown below:

Table 2.4-20 Turbine Building and Main Control Room Complex Components Subject to Aging Management Review Component Type Intended Function Bolting (Structural) Structural Support Concrete elements: Anchors Structural Support Concrete elements: Curbs Direct Flow Concrete elements: Embedments Structural Support Concrete: Above-grade exterior Flood Barrier, Missile Barrier, Shelter and (accessible areas) Protection, Shielding, Structural Pressure Barrier, Structural Support Concrete: Above-grade exterior Flood Barrier, Missile Barrier, Shelter and (inaccessible areas) Protection, Shielding, Structural Pressure Barrier, Structural Support Concrete: Basemat, Foundation, Shelter and Protection, Structural Support Subfoundation (inaccessible areas)

Concrete: Below-grade exterior Shelter and Protection, Structural Support (inaccessible areas)

Concrete: Exterior above- and below- Structural Support grade; foundation (accessible areas)

Concrete: Interior (accessible areas) HELB/MELB Shielding Missile Barrier, Shelter and Protection, Shielding, Structural Pressure Barrier, Structural Support Concrete: Interior (inaccessible areas) HELB/MELB Shielding Missile Barrier, Shelter and Protection, Shielding, Structural Pressure Barrier, Structural Support Eauipment supports and foundations Structural Support Hatches/Plugs Shelter and Protection, Shielding, Structural Support Masonry walls: Interior Shelter and Protection, Shielding, Structural Support Metal components Structural Support Precast Concrete- Beams and Panels Shelter and Protection, Shielding, Structural Support Sliding surfaces Structural Support Steel components: structural steel Structural Support Structural Miscellaneous - Decking Shelter and Protection, Structural Support Structural Miscellaneous - Missile Barrier Missile Barrier Structural Miscellaneous - Shielding Shielding Structural Miscellaneous - Siding Shelter and Protection

January 23, 2019 Enclosure A Page 120 of 187 SLRA Table 2.4-21, Watertight Dikes, Components Subject to Aging Management Review, page 2.4-67, is revised as shown below:

Table 2.4-21 Watertight Dikes Components Subject to Aging Management Review Component Type Intended Function Concrete: Above-grade exterior Structural Support (accessible areas)

Concrete: Above-grade exterior Structural Support (inaccessible areas)

Concrete: Below-grade exterior Structural Support (inaccessible areas)

Concrete: Exterior above- and below- Structural Support arade; foundation (accessible areas)

January 23, 2019 Enclosure A Page 121 of 187 SLRA Table 2.4-22, Yard Structures (Manholes, Duct Banks, Valve Pits, etc.),

Components Subject to Aging Management Review, page 2.4-70 is revised as shown below.

This SLRA markup to Table 2.4-22 also includes the changes discussed in Change #12 above to separately identify line items associated with Group 8 structures, and is duplicated here as an aid to the reviewer.

Table 2.4-22 Yard Structures (Manholes, Duct Banks, Valve Pits, etc.)

Components Subject to Aging Management Review Component Tvoe Intended Function Boltino (Structural) Structural Support Bolting (Structural-Storage Tanks) Structural Suooort Concrete elements: All (Foundation Structural Support Condensate and Refueling Water Storage Tanks)

Concrete elements: All (Foundation Structural Support Diesel Fuel Oil Storaoe Tanks)

Concrete elements: Anchors Structural Support Concrete elements: Anchors (Storage Structural Support Tanks)

Concrete elements: Curbs Direct Flow Concrete elements: Embedments Structural Support Concrete: Above-grade exterior Missile Barrier, Shelter and Protection, (accessible areas) Structural Support Concrete: Above-grade exterior Missile Barrier, Shelter and Protection, (inaccessible areas) Structural Support Concrete: Basemat, Foundation, Structural Support Subfoundation (accessible areas)

Concrete: Basemat, Foundation, Structural Support Subfoundation (inaccessible areas)

Concrete: Below-grade exterior Missile Barrier, Shelter and Protection, (inaccessible areas) Structural Support Concrete: Exterior above- and below- Structural Support grade; foundation (accessible areas)

Concrete: Interior (accessible areas) Missile Barrier, Shelter and Protection, Structural Support Concrete: Interior (inaccessible areas) Missile Barrier, Shelter and Protection, Structural Support Equipment supports and foundations Structural Support (Storaae Tanks)

Manholes, Handholes & Duct Banks Shelter and Protection, Structural Support Steel components: structural steel Structural Support Steel components: structural steel Structural Support (Storage Tanks)

January 23, 2019 Enclosure A Page 122 of 187 SLRA Section 3.5.2.1.21, Watertight Dikes, Environments section and Aging Effects Requiring Management section, page 3.5-25, is revised as shown below:

3.5.2.1.21 Watertight Dikes Environments The Watertight Dikes components are exposed to the following environments:

• Air - Outdoor

• Groundwater/Soil

• Water - Flowing Aging Effects Requiring Management The following aging effects associated with the Watertight Dikes components require management:

• Cracking

• Cracking and Distortion

• Cracking, Loss of Bond, and Loss of Material (Spalling, Scaling)

• Increase in Porosity and Permeability, Cracking, Loss of Material (Spalling, Scaling)

• Increase in Porosity and Permeability, Loss of Strength

• Loss of Material (Spalling, Scaling) and Cracking

January 23, 2019 Enclosure A Page 123 of 187 SLRA Table 3.5.1, Summary of Aging Management Evaluations for the Containments, Structures and Component Supports, page 3.5-88, Item Number 3.5.1-063, is revised as shown below. This SLRA markup to Table 3.5.1 also includes the changes, discussed in Change #12 above to separately identify line items associated with Group 8 structures, and is duplicated here as an aid to the reviewer.

Table 3.5.1 Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Further Item Aging Component Aging Programs Evaluation Discussion Number Effect/Mechanism Recommended 3.5.1-063 Groups 1-3, 5, 7-9: Increase in porosity AMP Xl.S6, "Structures No Consistent with NUREG-2191. The concrete (accessible and permeability; loss Monitoring" Structures Monitoring (B.2.1.34) program areas): exterior above- of strength due to will be used to manage increase in porosity and below-grade; leaching of calcium and permeability, loss of strength of the foundation hydroxide and grout and reinforced concrete exterior carbonation above- and below-grade, basemat, foundation, subfoundation (accessible areas), ifltef'iGI:, equipment supports and foundations, and penetration Seals exposed to water - flowing in Groups 2, 3, 8, and 9 structures, and the Hazard Barriers and Elastomers commodity group.

At PBAPS, the there are no stand-alone Group 1 or 5 structures, which are part of the Group 2 Reactor Buildings.

Group 7 aAG-8 structures are not applicable to PBAPS.

January 23, 2019 Enclosure A Page 124 of 187 SLRA Table 3.5.2-1, Administration Building and Shop, Summary of Aging Management Evaluation, pages 3.5-114 and 3.5-115, are revised as shown below:

Table 3.5.2-1 Administration Building and Shop (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Management Concrete: Structural Support Reinforced Water - Flowing Increase in Porosity and Structures Monitoring l/l.A3. TP-24 3.5.1-063 A, 1 Exterior above- concrete Permeability; Loss of (B.2.1.34) and be/ow-grade; Strength foundation (accessible areas Concrete: Interior Structural Support Reinforced Air- Indoor Cracking, Loss of Bond, Structures Monitoring lll.A3.TP-26 3.5.1-066 A (accessible areas) concrete Uncontrolled and Loss of Material (B.2.1 .34)

(Soallino, Scalino)

Cracking Structures Monitoring lll.A3.TP-25 3.5.1-054 A (8.2.1 .34)

January 23, 2019 Enclosure A Page 125 of 187 Table 3.5.2-1 Administration Building and Shop (Continued)

Notes Definition of Note A Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

8 Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

c Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

D Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

E Consistent with NUREG-2191 item for material, environment, and aging effect, but a different aging management program is credited or NUREG-2191 identifies a plant-specific aging management program.

F Material not in NUREG-2191 for this component.

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

H Aging effect not in NUREG-2191 for this component, material, and environment combination.

Aging effect in NUREG-2191 for this component, material, and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-2191.

Plant Specific Notes:

~

1. The "water - flowing" environment has been added so that the aging effect and mechanism of "Increase in Porosity and Permeability, Loss of Strength/Leaching of Calcium Hydroxide and Carbonation" is addressed under the Structures Monitoring (B.2.1.34) program.

January 23, 2019 Enclosure A Page 126 of 187 SLRA Table 3.5.2-2, Boiler House, Summary of Aging Management Evaluation, pages 3.5-117 and 3.5-120, are revised as shown below:

Table 3.5.2-2 Boiler House (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Management Concrete: Structural Support Reinforced Water - Flowing Increase in Porosity and Structures Monitoring lll.A3. TP-24 3.5.1-063 A, 1 Exterior above- concrete Permeability; Loss of (B.2.1.34) and below-grade; Strength foundation (accessible areas)

Concrete: Interior Structural Support Reinforced Air- Indoor Cracking, Loss of Bond, Structures Monitoring lll.A3.TP-26 3.5.1-066 A (accessible areas) concrete Uncontrolled and Loss of Material (B.2.1.34)

(SpallinQ, Scalinq)

Cracking Structures Monitoring lll.A3.TP-25 3.5.1-054 A (B.2.1.34)

January 23, 2019 Enclosure A Page 127 of 187 Table 3.5.2-2 Boiler House (Continued)

Notes Definition of Note A Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

B Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

c Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

D Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

E Consistent with NUREG-2191 item for material, environment, and aging effect, but a different aging management program is credited or NUREG-2191 identifies a plant-specific aging management program.

F Material not in NUREG-2191 for this component.

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

H Aging effect not in NUREG-2191 for this component, material, and environment combination.

Aging effect in NUREG-2191 for this component, material, and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-2191.

Plant Specific Notes:

N9A&.-

1. The "water - flowing" environment has been added so that the aging effect and mechanism of "Increase in Porosity and Permeability, Loss of Strength/Leaching of Calcium Hydroxide and Carbonation" is addressed under the Structures Monitoring (B.2.1.34) program.

January 23, 2019 Enclosure A Page 128 of 187 SLRA Table 3.5.2-7, Diesel Generator Building, Summary of Aging Management Evaluation, pages 3.5-176 and 3.5-177, are revised as shown below:

Table 3.5.2-7 Diesel Generator Building (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Management Concrete: Below- Flood Barrier Reinforced Water - Flowing Increase in Porosity and Structures Monitoring lll.A3.TP-67 3.5.1-047 A grade exterior Shelter and concrete Permeability, Loss of (B.2.1.34)

(inaccessible Protection Strength areas)

Structural Suooort Concrete: Structural Support Reinforced Water - Flowing Increase in Porosity and Structures Monitoring lll.A3. TP-24 3.5.1-063 A, 1 Exterior above- concrete Permeability; Loss of (B.2.1.34) and below-grade; Strength foundation (accessible areas

January 23, 2019 Enclosure A Page 129 of 187 Table 3.5.2-7 Diesel Generator Building (Continued)

Notes Definition of Note A Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

B Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

c Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

D Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

E Consistent with NUREG-2191 item for material, environment, and aging effect, but a different aging management program is credited or NUREG-2191 identifies a plant-specific aging management program.

F Material not in NUREG-2191 for this component.

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

H Aging effect not in NUREG-2191 for this component, material, and environment combination.

I Aging effect in NUREG-2191 for this component, material, and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-2191.

Plant Specific Notes:

~

1. The "water - flowing" environment has been added so that the aging effect and mechanism of "Increase in Porosity and Permeability, Loss of Strength/Leaching of Calcium Hydroxide and Carbonation" is addressed under the Structures Monitoring (B.2.1.34) program.

January 23, 2019 Enclosure A Page 130 of 187 SLRA Table 3.5.2-13, Nitrogen Storage Building, Summary of Aging Management Evaluation, pages 3.5-217 and 3.5-219, are revised as shown below:

Table 3.5.2-13 Nitrogen Storage Building (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item ManaQement Concrete: Structural Support Reinforced Water - Flowing Increase in Porosity and Structures Monitoring IJJ.A3. TP-24 3.5.1-063 A, 1 Exterior above- concrete Permeability; Loss of (B.2.1.34) and below-grade; Strength foundation (accessible areas, Concrete: Interior Missile Barrier Reinforced Air- Indoor Cracking, Loss of Bond, Structures Monitoring lll.A3.TP-26 3.5.1-066 A (accessible areas) Shelter and concrete Uncontrolled and Loss of Material (B.2.1 .34)

Protection (Spalling, Scaling)

Structural Support Cracking Structures Monitoring lll.A3.TP-25 3.5.1-054 A (B.2.1.34)

January 23, 2019 Enclosure A Page 131 of 187 Table 3.5.2-13 Nitrogen Storage Building (Continued)

Notes Definition of Note A Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

B Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

c Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

D Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

E Consistent with NUREG-2191 item for material, environment, and aging effect, but a different aging management program is credited or NUREG-2191 identifies a plant-specific aging management program.

F Material not in NUREG-2191 for this component.

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

H Aging effect not in NUREG-2191 for this component, material, and environment combination.

Aging effect in NUREG-2191 for this component, material, and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-2191.

Plant Specific Notes:

NGA&.

1. The "water - flowing" environment has been added so that the aging effect and mechanism of "Increase in Porosity and Permeability, Loss of Strength/Leaching of Calcium Hydroxide and Carbonation" is addressed under the Structures Monitoring (B.2.1.34) program.

January 23, 2019 Enclosure A Page 132 of 187 SLRA Table 3.5.2-14, Outdoor Electric Switchgear, North Substation, Summary of Aging Management Evaluation, pages 3.5-222 and 3.5-225, are revised as shown below:

Table 3.5.2-14 Outdoor Electric Switchgear, North Substation (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Management Concrete: Structural Support Reinforced Water - Flowing Increase in Porosity and Structures Monitoring l/l.A3. TP-24 3.5.1-063 A, 1 Exterior above- concrete Permeability; Loss of (B.2.1.34) and below-grade; Strength foundation (accessible areas Concrete: Interior Structural Support Reinforced Air- Indoor Cracking, Loss of Bond, Structures Monitoring lll.A3.TP-26 3.5.1-066 A concrete Uncontrolled and Loss of Material (B.2.1 .34)

(Soallina, Scalina)

Cracking Structures Monitoring lll.A3.TP-25 3.5.1-054 A (B.2.1.34)

January 23, 2019 Enclosure A Page 133 of 187 Table 3.5.2-14 Outdoor Electric Switchgear, North Substation (Continued)

Notes Definition of Note A Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

B Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP. .

c Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

D Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

E Consistent with NUREG-2191 item for material, environment, and aging effect, but a different aging management program is credited or NUREG-2191 identifies a plant-specific aging management program.

F Material not in NUREG-2191 for this component.

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

H Aging effect not in NUREG-2191 for this component, material, and environment combination.

I Aging effect in NUREG-2191 for this component, material, and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-2191.

Plant Specific Notes:

Nefl&.-

1. The "water - flowing" environment has been added so that the aging effect and mechanism of "Increase in Porosity and Permeability, Loss of Strength/Leaching of Calcium Hydroxide and Carbonation is addressed under the Structures Monitoring (B.2.1.34) program.

January 23, 2019 Enclosure A Page 134 of 187 SLRA Table 3.5.2-15, Radwaste Building and Reactor Auxiliary Bay, Summary of Aging Management Evaluation, pages 3.5-228 and 3.5-233, are revised as shown below:

Table 3.5.2-15 Radwaste Building and Reactor Auxiliary Bay (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Management Concrete: Below- Flood Barrier Reinforced Groundwater/Soil Increase in Porosity and Structures Monitoring lll.A3.TP-29 3.5.1-067 A grade exterior Missile Barrier concrete Permeability, Cracking, (B.2.1.34)

(inaccessible Loss of Material (Spalling, areas) Shelter and Scalina)

Protection Water - Flowing Increase in Porosity and Structures Monitoring lll.A3.TP-67 3.5.1-047 A Structural Support Permeability, Loss of (B.2.1.34)

Strength Concrete: Structural Support Reinforced Water - Flowing Increase in Porosity and Structures Monitoring l/l.A3. TP-24 3.5.1-063 A,2 Exterior above- concrete Permeability; Loss of (B.2.1.34) and below-grade; Strength foundation (accessible areas,

January 23, 2019 Enclosure A Page 135 of 187 Table 3.5.2-15 Radwaste Building and Reactor Auxiliary Bay (Continued)

Notes Definition of Note A Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

B Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

c Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

D Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

E Consistent with NUREG-2191 item for material, environment, and aging effect, but a different aging management program is credited or NUREG-2191 identifies a plant-specific aging management program.

F Material not in NUREG-2191 for this component.

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

H Aging effect not in NUREG-2191 for this component, material, and environment combination.

Aging effect in NUREG-2191 for this component, material, and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-2191.

Plant Specific Notes:

1. Support design allows for movement, but does not use Lubrite or similar material, instead consists of steel to steel sliding connection. The Structures Monitoring (B.2.1.34) program is substituted to manage the aging effects of this applicable to this component type, material, and environment combination.

2. The "water - flowing" environment has been added so that the aging effect and mechanism of "Increase in Porosity and Permeability, Loss of Strength/Leaching of Calcium Hydroxide and Carbonation" is addressed under the Structures Monitoring (B.2.1.34) program.

January 23, 2019 Enclosure A Page 136 of 187 SLRA Table 3.5.2-16, Reactor Building, Summary of Aging Management Evaluation, pages 3.5-237 and 3.5-248, are revised as shown below:

Table 3.5.2-16 Reactor Building (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item ManaQement Concrete: Below- Flood Barrier Reinforced Groundwater/Soil Cracking, Loss of Bond, Structures Monitoring lll.A2.TP-212 3.5.1-065 A grade exterior Missile Barrier concrete and Loss of Material (B.2.1.34)

(inaccessible (Spalling, Scaling) areas) Shelter and Protection Cracking Structures Monitoring lll.A2.TP-204 3.5.1-043 A (B.2.1.34)

Structural Pressure Barrier Increase in Porosity and Structures Monitoring lll.A2.TP-29 3.5.1-067 A Permeability, Cracking, (B.2.1.34)

Structural Support Loss of Material (Spalling, Scalina)

Water - Flowing Increase in Porosity and Structures Monitoring lll.A2.TP-67 3.5.1-047 A Permeability, Loss of (B.2.1.34)

Strenoth Concrete: Structural Support Reinforced Water - Flowing Increase in Porosity and Structures Monitoring lll.A3. TP-24 3.5.1-063 A, 3 Exterior above- concrete Permeability; Loss of (B.2.1.34) and below-grade; Strength foundation (accessible areas)

January 23, 2019 Enclosure A Page 137 of 187 Table 3.5.2-16 Reactor Building (Continued)

Notes Definition of Note A Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

B Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

c Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

D Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

E Consistent with NUREG-2191 item for material, environment, and aging effect, but a different aging management program is credited or NUREG-2191 identifies a plant-specific aging management program.

F Material not in NUREG-2191 for this component.

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

H Aging effect not in NUREG-2191 for this component, material, and environment combination.

Aging effect in NUREG-2191 for this component, material, and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-2191.

Plant Specific Notes:

1. The Structures Monitoring (B.2.1.34) program is substituted to manage the applicable aging effect(s) for this component type, material, and environment combination.

2. Water level of spent fuel pool and leakage from the leak chase channels are monitored. Therefore, the One-Time Inspection (B.2.1.21) program is not required with the Water Chemistry (B.2.1.2) program for this component type.

3. The "water - flowing" environment has been added so that the aging effect and mechanism of "Increase in Porosity and Permeability, Loss of Strength/Leaching of Calcium Hydroxide and Carbonation" is addressed under the Structures Monitoring (B.2.1.34) program.

January 23, 2019 Enclosure A Page 138 of 187 SLRA Table 3.5.2-17, Recombiner Building, Summary of Aging Management Evaluation, pages 3.5-251 and 3.5-255, are revised as shown below:

Table 3.5.2-17 Recombiner Building (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item ManaQement Concrete: Below- Shelter and Reinforced Water - Flowing Increase in Porosity and Structures Monitoring lll.A3.TP-67 3.5.1-047 A grade exterior Protection concrete Permeability, Loss of (B.2.1.34)

(inaccessible Structural Support Strength areas)

Concrete: Structural Support Reinforced Water - Flowing Increase in Porosity and Structures Monitoring lll.A3. TP-24 3.5.1-063 A, 1 Exterior above- concrete Permeability; Loss of (B.2.1.34) and be/ow-grade; Strength foundation (accessible areas)

January 23, 2019 Enclosure A Page 139 of 187 Table 3.5.2-17 Recombiner Building (Continued)

Notes Definition of Note A Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

B Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

c Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

D Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

E Consistent with NUREG-2191 item for material, environment, and aging effect, but a different aging management program is credited or NUREG-2191 identifies a plant-specific aging management program.

F Material not in NUREG-2191 for this component.

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

H Aging effect not in NUREG-2191 tor this component, material, and environment combination.

Aging effect in NUREG-2191 tor this component, material, and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-2191.

Plant Specific Notes:

NGA&.

1. The "water - flowing" environment has been added so that the aging effect and mechanism of "Increase in Porosity and Permeability, Loss of Strength/Leaching of Calcium Hydroxide and Carbonation" is addressed under the Structures Monitoring (B.2.1.34).

January 23, 2019 Enclosure A Page 140 of 187 SLRA Table 3.5.2-18, Stack, Summary of Aging Management Evaluation, pages 3.5-258 and 3.5-261, are revised as shown below:

Table 3.5.2-18 Stack (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Manaoement Concrete: Structural Support Reinforced Groundwater/Soil Cracking Structures Monitoring lll.A9.TP-204 3.5.1-043 A Basemat, concrete (8.2.1.34)

Foundation, Increase in Porosity and Structures Monitoring lll.A9.TP-29 3.5.1-067 A Subfoundation Permeability, Cracking, (B.2.1.34)

(inaccessible Loss of Material (Spalling, areas)

Scalino)

Water - Flowing Increase in Porosity and Structures Monitoring lll.A9.TP-67 3.5.1-047 A Permeability, Loss of (B.2.1.34)

Strenoth Concrete: Structural Support Reinforced Water - Flowing Increase in Porosity and Structures Monitoring lll.A3. TP-24 3.5.1-063 A, 1 Exterior above- concrete Permeability; Loss of (B.2.1.34) and below-grade; Strength foundation (accessible areas,

January 23, 2019 Enclosure A Page 141 of 187 Table 3.5.2-18 Stack {Continued)

Notes Definition of Note A Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

B Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

c Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

D Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

E Consistent with NUREG-2191 item for material, environment, and aging effect, but a different aging management program is credited or NUREG-2191 identifies a plant-specific aging management program.

F Material not in NUREG-2191 for this component.

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

H Aging effect not in NUREG-2191 for this component, material, and environment combination.

Aging effect in NUREG-2191 for this component, material, and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-2191.

Plant Specific Notes:

Noo&.-

1. The "water - flowing" environment has been added so that the aging effect and mechanism of "Increase in Porosity and Permeability, Loss of Strength/Leaching of Calcium Hydroxide and Carbonation" is addressed under the Structures Monitoring (B.2.1.34).

January 23, 2019 Enclosure A Page 142 of 187 SLRA Table 3.5.2-19, Station Blackout Structure and Foundations, Summary of Aging Management Evaluation, pages 3.5-264 and 3.5-269, are revised as shown below:

Table 3.5.2-19 Station Blackout Structure and Foundations (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Manaaement Concrete: Structural Support Reinforced Water - Flowing Increase in Porosity and Structures Monitoring lll.A3. TP-24 3.5.1-063 A, 3 Exterior above- concrete Permeability; Loss of (B.2.1.34) and be/ow-grade; Strength foundation (accessible areas Concrete: Interior Structural Support Reinforced Air - Outdoor Cracking, Loss of Bond, Structures Monitoring lll.A3.TP-26 3.5.1-066 A concrete and Loss of Material (B.2.1 .34) lSoallina, Scalina)

Cracking Structures Monitoring lll.A3.TP-25 3.5.1-054 A (B.2.1.34)

Loss of Material (Spalling, Structures Monitoring lll.A3.TP-23 3.5.1-064 A Scalina) and Crackina (B.2.1.34)

'Nater Flawing lnsrease in Peresity ane Str1:1st1:1res Manitaring 111.Jl.3.TP 24 a.a.1 g0a A Parmeaeility, bass af (B.2.1.34) atrengtt:l

January 23, 2019 Enclosure A Page 143 of 187 Table 3.5.2-19 Station Blackout Structure and Foundations (Continued)

Plant Specific Notes:

1. The FERG Inspections of the Conowingo Hydroelectric Plant (Dam} are the aging management program for the Conowingo Hydroelectric Plant (Dam). The Conowingo Hydroelectric Plant (Dam) is located on the Susquehanna River approximately ten miles above the mouth of the river on the Chesapeake Bay, five miles below the Pennsylvania border, and approximately ten miles south of PBAPS. Conowingo is owned and operated by Exelon Generation. Conowingo is part of the PBAPS SBO electrical system. Conowingo is licensed by the Federal Energy Regulatory Commission (FERG). Screening of Conowingo was performed at the plant (dam} level. Screening and aging management review of the plant (dam) were performed for the second period of extended operation based on current licensing basis established for Peach Bottom in NUREG-1769, Safety Evaluation Report Related to the License Renewal of Peach Bottom Atomic Power Station, Units 2 and 3, Section 3.6.3 "Station Blackout System". The staff concluded as stated in paragraph 3.6.3.2.1 "Aging Management Program", "By virtue of the FERC's authority and responsibility for ensuring that its regulated projects are constructed, operated, and maintained to protect life, health, and property, the staff finds that for earthen embankments, dams, appurtenances, and related structures subject to AMR, continued compliance with FERG requirements during the license renewal period will constitute an acceptable dam aging management program for the purposes of license renewal. Therefore, the staff finds the program acceptable." PBAPS will continue to comply with these FERG requirements during the second period of extended operation.

2. The FERG Inspections of the Conowingo Hydroelectric Plant (Dam) are substituted to manage aging effect(s) applicable to this component type, material, and environment combination.

3. The "water - flowing" environment has been added so that the aging effect and mechanism of "Increase in Porosity and Permeability, Loss of Strength/Leaching of Calcium Hydroxide and Carbonation" is addressed under the Structures Monitoring (B.2.1.34) program.

January 23, 2019 Enclosure A Page 144 of 187 SLRA Table 3.5.2-20, Turbine Building and Main Control Room Complex, Summary of Aging Management Evaluation, pages 3.5-272 and 3.5-276, are revised as shown below:

Table 3.5.2-20 Turbine Building and Main Control Room Complex (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item ManaQement Concrete: Structural Support Reinforced Water - Flowing Increase in Porosity and Structures Monitoring lll.A3. TP-24 3.5.1-063 A,2 Exterior above- concrete Permeability; Loss of (B.2.1.34) and below-grade; Strength foundation (accessible areas, Concrete: Interior HELB/MELB Reinforced Air - Indoor Cracking, Loss of Bond, Structures Monitoring lll.A3.TP-26 3.5.1-066 A (accessible areas) Shielding concrete Uncontrolled and Loss of Material (B.2.1.34)

(SpallinQ, ScalinQ)

Cracking Structures Monitoring lll.A3.TP-25 3.5.1-054 A (B.2.1.34)

January 23, 2019 Enclosure A Page 145 of 187 Table 3.5.2-20 Turbine Building and Main Control Room Complex (Continued)

Notes Definition of Note A Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

B Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

c Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

D Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

E Consistent with NUREG-2191 item for material, environment, and aging effect, but a different aging management program is credited or NUREG-2191 identifies a plant-specific aging management program.

F Material not in NUREG-2191 for this component.

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

H Aging effect not in NUREG-2191 for this component, material, and environment combination.

Aging effect in NUREG-2191 for this component, material, and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-2191.

Plant Specific Notes:

1. The Structures Monitoring (B.2.1.34) program is substituted to manage the aging effects applicable to this component type, material, and environment combination, for the circulating water discharge tunnel.

2. The "water - flowing" environment has been added so that the aging effect and mechanism of "Increase in Porosity and Permeability, Loss of Strength/Leaching of Calcium Hydroxide and Carbonation" is addressed under the Structures Monitoring (B.2.1.34) program.

January 23, 2019 Enclosure A Page 146 of 187 SLRA Table 3.5.2-21, Watertight Dikes, Summary of Aging Management Evaluation, pages 3.5-277 and 3.5-278, are revised as shown below:

Table 3.5.2-21 Watertight Dikes Summary of Aging Management Evaluation Table 3.5.2-21 Watertight Dikes Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Manaaement Concrete: Below- Structural Support Reinforced Groundwater/Soil Cracking and Distortion Structures Monitoring lll.A3.TP-30 3.5.1-044 A grade exterior concrete (B.2.1.34)

(inaccessible areas) Cracking, Loss of Bond, Structures Monitoring lll.A3.TP-212 3.5.1-065 A and Loss of Material (B.2.1.34)

(Spalling, Scaling)

Cracking Structures Monitoring 'lll.A3.TP-204 3.5.1-043 A (B.2.1.34)

Increase in Porosity and Structures Monitoring lll.A3.TP-29 3.5.1-067 A Permeability, Cracking, (B.2.1.34)

Loss of Material (Spalling, Scaling)

Concrete: Structural Support Reinforced Water - Flowing Increase in Porosity and Structures Monitoring //l.A3. TP-24 3.5.1-063 A, 1 Exterior above- concrete Permeability; Loss of (B.2.1.34) and below-grade; Strength foundation (accessible areas)

January 23, 2019 Enclosure A Page 147 of 187 Table 3.5.2-21 Watertight Dikes (Continued)

Notes Definition of Note A Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

B Consistent with NUAEG-2191 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

c Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

D Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

E Consistent with NUREG-2191 item for material, environment, and aging effect, but a different aging management program is credited or NUREG-2191 identifies a plant-specific aging management program.

F Material not in NUREG-2191 for this component.

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

H Aging effect not in NUREG-2191 for this component, material, and environment combination.

Aging effect in NUREG-2191 for this component, material, and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-2191.

Plant Specific Notes:

NeR&.

1. The "water - flowing" environment has been added so that the aging effect and mechanism of "Increase in Porosity and Permeability, Loss of Strength/Leaching of Calcium Hydroxide and Carbonation" is addressed under the Structures Monitoring (B.2.1.34) program.

January 23, 2019 Enclosure A Page 148 of 187 SLRA Table 3.5.2-22, Yard Structures (Manholes, Duct Banks, Valve Pits, etc.), Summary of Aging Management Evaluation, pages 3.5-279, 3.5-280, 3.5-283, 3.5-284, and 3.5-285, are revised as shown below. This SLRA markup to Table 3.5.2-22 also includes the changes, discussed in Change #12 above to separately identify line items associated with Group 8 structures, and is duplicated here as an aid to the reviewer.

Table 3.5.2-22 Yard Structures (Manholes, Duct Banks, Valve Pits, etc.)

Summary of Aging Management Evaluation Table 3.5.2-22 Yard Structures (Manholes, Duct Banks, Valve Pits, etc.)

Component Intended Material Environment Aging Effect Requiring Aging Management NUREG-2191 NUREG-2192 Notes Type Function Manaqement Proqrams Item Table 1 ltem Bolting Structural Galvanized Air - Outdoor Loss of Material Structures Monitoring Ill.AB. TP-274 3.5.1-DB2 A (Structural- Support Steel Bolting (B.2.1.34)

Storage Tanks)

Loss of Preload Structures Monitoring Ill.AB. TP-261 3.5.1-0BB A (B.2.1.34)

Concrete elements: Structural Reinforced Air - Outdoor Cracking, Loss of Bond, and Loss Structures Monitoring lll.A3.TP-26 3.5.1-066 A All (Foundation Support concrete of Material (Spallino, Scalino) (B.2.1.34)

Condensate and 3.5.1-054 A Cracking Structures Monitoring 111.-AdAB.TP-25 Refueling Water (B.2.1.34)

Storage Tanks)

Loss of Material (Spalling, Structures Monitoring 111.-AdAB.TP-23 3.5.1-064 A Scalino) and Crackino (B.2.1.34)

Groundwater/Soil Cracking and Distortion Structures Monitoring 111.AdAB.TP-30 3.5.1-044 A (B.2.1.34)

Cracking, Loss of Bond, and Loss Structures Monitoring Ill.AB. TP-27 3.5.1-065 A of Material (Spalling, Scaling) (B.2.1.34) A lll.AdAB.TP-212 3.5.1-065 Cracking Structures Monitoring lll.AdAB.TP-204 3.5.1-043 A (B.2.1.34)

Increase in Porosity and Structures Monitoring 111.-AdAB.TP-29 3.5.1-067 A Permeability, Cracking, Loss of (B.2.1.34)

Material (Spallina, Scalina)

Loss of Material (Spa/ling, Structures Monitoring Ill.AB. TP-10B 3.5.1-042 A ScalinQ) and Cracking (B.2.1.34)

Water - Flowing Increase in Porosity and Structures Monitoring Ill.AB. TP-24 3.5.1-063 A, 1 Permeability; Loss of Strength (B.2.1.34) Ill.AB. TP-67 3.5.1-047 A, 1

January 23, 2019 Enclosure A Page 149 of 187 Table 3.5.2-22 Yard Structures (Manholes, Duct Banks, Valve Pits, etc.) (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item ManaQement Concrete elements: Structural Support Reinforced Groundwater/Soil Cracking and Distortion Structures Monitoring 111.-AaAB.TP-30 3.5.1-044 A All (Foundation concrete (B.2.1.34)

Diesel Fuel Oil A Cracking, Loss of Bond, Structures Monitoring JJJ.AB. TP*27 3.5.1*065 Storage Tanks) and Loss of Material (B.2.1.34) 111.-AaAB.TP-212 3.5.1-065 A (SpallinQ, ScalinQ)

Cracking Structures Monitoring 111.-AaAB.TP-204 3.5.1-043 A (B.2.1.34)

Increase in Porosity and Structures Monitoring 111.-AaAB.TP-29 3.5.1-067 A Permeability, Cracking, (B.2.1.34)

Loss of Material (Spalling, Scalina)

Loss of Material Structures Monitoring JJJ.AB. TP-108 3.5.1-042 A (Spa/ling, Scaling) and (B.2.1.34)

CrackinCJ Water - Flowing Increase in Porosity and Structures Monitoring JJl.AB. TP*24 3.5.1-063 A,1 Permeability; Loss of (B.2.1.34)

Ill.AB. TP-67 3.5.1-047 A, 1 Strenath Concrete elements: Structural Support Carbon and Low Air - Outdoor Loss of Material Structures Monitoring lll.A3.TP-274 3.5.1-082 A Anchors Alloy Steel (B.2.1.34)

Bolting Loss of Preload Structures Monitoring lll.A3.TP-261 3.5.1-088 A (B.2.1.34)

Concrete Structural Support Carbon and LoMI Air - Outdoor Loss of Material Structures Monitoring JJJ.AB. TP-274 3.5.1-082 A elements: Alloy Steel (B.2.1.34)

Anchors (Storage Bolting Loss of Preload Structures Monitoring JJJ.AB. TP-261 3.5.1-088 A Tanks)

(B.2.1.34)

January 23, 2019 Enclosure A Page 150 of 187 Table 3.5.2-22 Yard Structures (Manholes, Duct Banks, Valve Pits, etc.) (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item ManaQement Concrete: Structural Support Reinforced Water - Flowing Increase in Porosity and Structures Monitoring lll.A3. TP-24 3.5.1-063 A, 1 Exterior above- concrete Permeability; Loss of (B.2.1.34) and below-grade; Strength foundation (accessible areas Concrete: Interior Missile Barrier Reinforced Air- Indoor Cracking, Loss of Bond, Structures Monitoring lll.A3.TP-26 3.5.1-066 A (accessible areas) concrete Uncontrolled and Loss of Material (B.2.1.34)

Shelter and (Spalling, Scaling)

Protection Cracking Structures Monitoring lll.A3.TP-25 3.5.1-054 A Structural Support (B.2.1.34)

Concrete: Interior Missile Barrier Reinforced Air- Indoor Cracking, Loss of Bond, Structures Monitoring lll.A3.TP-26 3.5.1-066 c (inaccessible Shelter and concrete Uncontrolled and Loss of Material (B.2.1.34) areas) Protection (Spalling, Scaling)

Structural Support Cracking Structures Monitoring lll.A3.TP-204 3.5.1-043 A (B.2.1.34)

Equipment Structural Support Carbon Steel Air - Outdoor Loss of Material Structures Monitoring Ill.AB. TP-302 3.5.1-077 A supports and (B.2.1.34) foundations (Storage Tanks)

January 23, 2019 Enclosure A Page 151of187 Table 3.5.2-22 Yard Structures (Manholes, Duct Banks, Valve Pits, etc.) (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-2191 NUREG-2192 Notes Type Function Requiring Programs Item Table 1 Item Manaqement Steel components: Structural Support Galvanized Steel Air - Outdoor Loss of Material Structures Monitoring 111.82.TP-6 3.5.1-093 A structural steel (B.2.1.34)

Steel Structural Support Galvanized Air - Outdoor Loss of Material Structures Monitoring Ill.AB. TP-302 3.5.1-077 A components: Steel (B.2.1.34) structural steel (Storage Tanks)

January 23, 2019 Enclosure A Page 152 of 187 Table 3.5.2-22 Yard Structures (Manholes, Duct Banks, Valve Pits, etc.) (Continued)

Notes Definition of Note A Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

B Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

c Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP.

D Component is different, but consistent with NUREG-2191 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-2191 AMP.

E Consistent with NUREG-2191 item for material, environment, and aging effect, but a different aging management program is credited or NUREG-2191 identifies a plant-specific aging management program.

F Material not in NUREG-2191 for this component.

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

H Aging effect not in NUREG-2191 for this component, material, and environment combination.

I Aging effect in NUREG-2191 for this component, material, and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-2191.

Plant Specific Notes:

NGA&.

1. The "water - flowing" environment has been added so that the aging effect and mechanism of "Increase in Porosity and Permeability, Loss of Strength/Leaching of Calcium Hydroxide and Carbonation" is addressed under the Structures Monitoring (B.2.1.34) program.

January 23, 2019 Enclosure A Page 153 of 187 Change #16 - Revision to Fire Water System Enhancement #6 Affected SLRA Sections: Appendix A, Section A.2.1.17, Appendix A, Section A.5, Appendix B, Section B.2.1.17 SLRA Page Numbers: A-25, A-26, A-95, A-96 and B-103 Description of Change:

The Fire Water System aging management program (Xl.M27), Enhancement #6 is being revised to eliminate extraneous information. The statement, "Follow-up volumetric wall thickness examinations will be performed if internal visual inspections detect age-related degradation in excess of what would be expected accounting for design, previous inspection experience, and inspection interval," is included in the SLRA Enhancement #6.

The statement is being revised to align with GALL wording. The revised statement is, "Follow-up volumetric wall thickness examinations will be performed if internal visual inspections detect an unexpected level of degradation due to corrosion and corrosion product deposition."

Accordingly, SLRA Appendix A, Section A.2.1.17, Appendix A, Section A.5, and Appendix B, Section B.2.1.17 are revised.

January 23, 2019 Enclosure A Page 154 of 187 SLRA Appendix A, Section A.2.1.17, Fire Water System, Enhancement #6, beginning on page A-25 is revised as shown below:

A.2.1.17 Fire Water System

6. Perform internal visual inspections of sprinkler and deluge system piping to identify internal corrosion, foreign material, and obstructions to flow. Follow-up volumetric wall thickness examinations will be performed if internal visual inspections detect ago related degradation an unexpected level of degradation due to corrosion and corrosion product deposition.in excess of what would be expected accounting for design, previous inspection oxporionco, and inspection interval. If organic or foreign material, or internal flow blockage that could result in failure of system function is identified, then an obstruction investigation will be performed within the corrective action program that includes removal of the material, an extent of condition determination, review for increased inspections, extent of follow-up examinations, and a flush in accordance with NFPA 25 Annex D.5, Flushing Procedures. The internal visual inspections will consist of the following:

a. Wet pipe sprinkler systems - 50 percent of the wet pipe sprinkler systems in scope for license renewal will have visual internal inspections of piping by removing a hydraulically remote sprinkler, performed every five years, consistent with NFPA 25, 2011 Edition, Section 14.2.

During the next five-year inspection period, the alternate systems previously not inspected shall be inspected.

b. Pre-action sprinkler systems - pre-action sprinkler systems in scope for license renewal will have visual internal inspections of piping by removing a hydraulically remote nozzle, performed every five years, consistent with NFPA 25, 2011 Edition, Section 14.2.

c. Deluge systems - Yard transformer deluge systems in scope for license renewal will have visual internal inspections of piping by removing a hydraulically remote nozzle, performed every five years, consistent with NFPA 25, 2011 Edition, Section 14.2.

January 23, 2019 Enclosure A Page 155 of 187 SLRA Appendix B, Section B.2.1.17, Fire Water System, Enhancement #6, page 8-103 is revised as shown below:

B.2.1.17 Fire Water System

6. Perform internal visual inspections of sprinkler and deluge system piping to identify internal corrosion, foreign material, and obstructions to flow. Follow-up volumetric wall thickness examinations will be performed if internal visual inspections detect ago related degradation an unexpected level of degradation due to corrosion and corrosion product deposition.in excess of 1Nhat would be oxpoctod accounting for design, previous inspection experience, and inspection intoF\1al. If organic or foreign material, or internal flow blockage that could result in failure of system function is identified, then an obstruction investigation will be performed within the corrective action program that includes removal of the material, an extent of condition determination, review for increased inspections, extent of follow-up examinations, and a flush in accordance with NFPA 25 Annex D.5, Flushing Procedures. The internal visual inspections will consist of the following:

a. Wet pipe sprinkler systems - 50 percent of the wet pipe sprinkler systems in scope for license renewal will have visual internal inspections of piping by removing a hydraulically remote sprinkler, performed every five years, consistent with NFPA 25, 2011 Edition, Section 14.2.

During the next five-year inspection period, the alternate systems previously not inspected shall be inspected.

b. Pre-action sprinkler systems - pre-action sprinkler systems in scope for license renewal will have visual internal inspections of piping by removing a hydraulically remote nozzle, performed every five years, consistent with NFPA 25, 2011 Edition, Section 14.2.

c. Deluge systems - Yard transformer deluge systems in scope for license renewal will have visual internal inspections of piping by removing a hydraulically remote nozzle, performed every five years, consistent with NFPA 25, 2011 Edition, Section 14.2.

January 23, 2019 Enclosure A Page 156 of 187 SLRA Appendix A, Section A.5, Commitment 17, Fire Water System, Item #6, beginning on page A-95 is revised as shown below:

A.5 SECOND LICENSE RENEWAL COMMITMENT LIST PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

17 Fire Water System 6. Perform internal visual inspections of sprinkler and deluge system piping to Program will be Section A.2.1.17 identify internal corrosion, foreign material, and obstructions to flow. enhanced no later than Follow-up volumetric wall thickness examinations will be performed if six months prior to the internal visual inspections detect age relates ae9raaatieA an unexpected second period of level of degradation due to corrosion and corrosion product extended operation.

deposition.iA e*se66 e# ~Yt:lat we~la l:le e*f=1estea asse~AtiA9 #eF Ele6i9A, Inspections that are to be Exelon Letter previe~6 iA6pestieA e*perieAse, ana iA6pestieA interval. If organic or completed prior to the PBAPSSLRA foreign material, or internal flow blockage that could result in failure of second period of Supplement system function is identified, then an obstruction investigation will be extended operation will No.2, dated performed within the corrective action program that includes removal of be completed no later January23, the material, an extent of condition determination, review for increased than six months prior to 2019 inspections, extent of follow-up examinations, and a flush in accordance the second period of with NFPA 25 Appendix D.5, Flushing Procedures. The internal visual extended operation, or inspections will consist of the following: no later than the last

a. Wet pipe sprinkler systems - 50 percent of the wet pipe sprinkler refueling outage prior to systems in scope for license renewal will have visual internal the second period of inspections of piping by removing a hydraulically remote sprinkler, extended operation.

performed every five years, consistent with NFPA 25, 2011 Edition, Section 14.2. During the next five-year inspection period, the alternate systems previously not inspected shall be inspected.

b. Pre-action sprinkler systems - pre-action sprinkler systems in scope for license renewal will have visual internal inspections of piping by removing a hydraulically remote nozzle, performed every five years, consistent with NFPA 25, 2011 Edition, Section 14.2.

c. Deluge systems - Yard transformer deluge systems in scope for license renewal will have visual internal inspections of piping by removing a hydraulically remote nozzle, performed every five years, consistent with NFPA 25, 2011 Edition, Section 14.2.

January 23, 2019 Enclosure A Page 157 of 187 Change #17 - Removal of the Component-Specific Flaw Tolerance Evaluation Option from the Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) Aging Management Program Affected SLRA Sections: Appendix A, Section A.2.1.8 and Appendix B, Section B.2.1.8 SLRA Page Numbers: A-16, B-53 Description of Change:

The Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) aging management program (Xl.M12) is being revised to eliminate the component-specific flaw tolerance evaluation option as an aging management method.

The SLRA Appendix A, Section A.2.1.8 and Appendix B, Section B.2.1.8 contain the following statement, "Components with the potential for significant thermal aging embrittlement will be managed through either, qualified visual inspections, such as enhanced visual examination, qualified ultrasonic testing methodology, or component-specific flaw tolerance evaluation." The aging management option of "component-specific flaw tolerance evaluation" was deemed unnecessary and will be eliminated.

Accordingly, SLRA Appendix A, Section A.2.1.8 and Appendix B, Section B.2.1.8 are revised.

January 23, 2019 Enclosure A Page 158 of 187 SLRA Appendix A, Section A.2.1.8, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS), page A-16, second paragraph, is revised as shown below:

A.2.1.8 Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)

The program will include a screening methodology to determine components for which thermal aging embrittlement is potentially significant based on casting method, molybdenum content, and percent ferrite. Components with the potential for significant thermal aging embrittlement will be managed through either, qualified visual inspections, such as enhanced visual examination, or qualified ultrasonic testing methodology..,.ef component specific flaw tolerance evaluation. For pump casings, as an alternative to screening for significance of thermal aging embrittlement, no further actions are needed if a flaw tolerance evaluation performed as part of Code Case N-481 implementation is bounding for 80 years.

January 23, 2019 Enclosure A Page 159 of 187 SLRA Appendix 8, Section 8.2.1 .8, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS), page 8-53, second and fifth paragraphs, are revised as shown below:

B.2.1.8 Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)

The program will include a screening methodology to determine components for which thermal aging embrittlement is potentially significant based on casting method, molybdenum content, and percent ferrite. Ferrite content is calculated by using the Hull's equivalent factors (described in NUREG/CR-4513, Revision 1). Components with the potential for significant thermal aging embrittlement will be managed through either, qualified visual inspections, such as enhanced visual examination, or qualified ultrasonic testing methodology, or component specific flaw tolerance evaluation in accordance with ASME Code, Section XI. For pump casings, as an alternative to screening for significance of thermal aging embrittlement, no further actions are needed if a flaw tolerance evaluation performed as part of Code Case N-481 implementation is bounding for 80 years.

Inspections or evaluations are not required for components for which thermal aging embrittlement is not significant. In addition, screening for ASME Code Class 1 CASS valve bodies for significance of thermal aging embrittlement is not required, because the existing ASME Section XI inspection requirements are adequate for managing the aging effects of Class 1 valve bodies.

Reactor vessel internal components fabricated from CASS are not within the scope of this aging management program and are managed by the 8WR Vessel Internals (8.2.1.7) program.

The program will provide for either enhanced visual inspections, or qualified ultrasonic testing methodology, or flaw tolerance evaluations of susceptible components; it will not provide guidance on methods to mitigate thermal aging embrittlement. Tho flaw tolerance evaluation will be based on specific geometry and stress information to verify that the thermally embrittled material has adequate to1:1ghness throughout tho second period of e>dendod operation.

Thermal Aging Embrittlement of Cast Austenitic Stainless Steel program inspections, if required, will be based on ASME Code, Section XI, Table IW8-2412-1 and performed during each 10-year ISi interval. There are no ASME Class 2 components within this program, therefore, Table IWC-2412-1 does not apply. The P8APS ASME Section XI program plans direct the inspection schedules and the extent of the inspections in the program planning documents as required to provide timely detection of flaws. Abnormal or unacceptable results identified are entered into the corrective action program for evaluation and resolution.

Flaws detected in reactor coolant pressure boundary ASME Code Class 1 CASS components are entered into the corrective action program and evaluated in accordance with the applicable procedures of ASME Code, Section XI. The ferrite content of the P8APS Unit 2 and Unit 3 recirculation pump casings and covers are less than 20 percent therefore ASME Code, Section XI can be used for flaw evaluations. Repairs and replacements are performed in accordance with the ASME Section XI Code, which specify the requirements in IWA-4000, per the PBAPS ISi program.

January 23, 2019 Enclosure A Page 160 of 187 Change #18 - Addition of Bolting Integrity Program Enhancements 8 and 9 Affected SLRA Sections: Appendix A, Section A.2.1.10, Appendix A, Section A.5 and Appendix B, Section B.2.1.1 o SLRA Page Numbers: A-18, A-19, A-93, 8-63, and 8-66 Description of Change:

SLRA Appendix A.2.1.10, Bolting Integrity and Appendix B.2.1.10, Bolting Integrity state that PBAPS does not have high strength bolting material with actual yield strength of 150 ksi or greater (High Strength Bolting) on pressure-retaining components with bolt diameters greater than 2 inches. Therefore, sampling based volumetric examinations of high strength closure bolting greater than 2 inches in diameter is not applicable. In addition, existing procedures require engineering approval to use high strength bolting material on system components within the scope of license renewal.

However, Appendix A and B do not specify the necessary actions should PBAPS elect to install greater than 2 inches in diameter high strength closure bolting within the scope of license renewal. Enhancement 8 is added to clarify that engineering procedures will be enhanced to require volumetric examination in accordance with ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1, regardless of the code classification, should high strength bolting greater than 2 inches in diameter be installed.

In addition, the Preventative Action element for Bolting Integrity aging management program provides preventative actions to provide reasonable assurance that bolting integrity is maintained for high-strength bolting. No corresponding enhancements to this aging management program is provided in the SLRA to incorporate guidance of standards and emphasis of the recommended preventative actions. Enhancement 9 is added to reflect the use of guidance in the Preventative Action element relative to bolting integrity of high-strength bolts.

Accordingly, Enhancements 8 and 9 are added to SLRA Appendix A, Section A.2.1.10, Appendix A, Section A.5, and Appendix B, Section 8.2.1.10.

January 23, 2019 Enclosure A Page 161of187 SLRA Appendix A, Section A.2.1.10, Bolting Integrity, beginning on page A-17, is revised as shown below.

A.2.1.10 Bolting Integrity The Bolting Integrity aging management program is an existing condition monitoring program. The program manages aging for loss of preload, cracking, and loss of material of safety-related and nonsafety-related closure bolting on pressure-retaining components. The program utilizes recommendations and guidelines delineated in NUREG-1339, EPRI NP-5769, TR-1015336, and TR-1015337 for material selection, use of approved lubricants, proper torqueing, and leakage evaluations which are implemented during plant surveillance and maintenance activities.

In addition, the program manages aging of submerged mechanical bolting on the 2AS008, 2BS008, 3AS008, and 3BS008 Circulating Water Pump Structure intake traveling screens.

The program includes periodic visual inspections of closure bolting on pressure-retaining components for indication of loss of preload, cracking, and loss of material as evidenced by pressure-retaining joint leakage. Closure bolting on pressure-retaining components and mechanical bolting that are submerged or closure bolting on pressure-retaining components located in piping systems that contain air or gas is inspected by alternative means, such as by sample based periodic inspections. The program also includes preventive measures provided in the EPRI guidance documents to preclude or minimize loss of preload and cracking. Engineering procedures will be enhanced to clarify that recommended guidance for selection, storage and installation of bolting per applicable EPRI and Research Council on Structural Connections (RCSC) publications are a requirement.

There is no high strength bolting material with actual yield strength of 150 ksi or greater on pressure-retaining components with bolt diameters greater than 2 inches, or bolts with unknown yield strength within the scope of this program. Therefore, sampling based volumetric examinations of closure bolting to detect indications of cracking is not applicable. Engineering procedures will be enhanced to require volumetric examination in accordance with ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1, regardless of the code classification of the bolting, should high strength bolting greater than 2 inches in diameter be installed.

The program performs periodic sample based inspections on submerged closure bolting on the ESW, HPSW, and fire protection pumps; submerged closure bolting on the Core Spray, HPCI, RHR, and RCIC suction strainers; and submerged mechanical bolts on the 2AS008, 2BS008, 3AS008, and 3BS008 Circulating Water Pump Structure intake traveling screens. The program also performs periodic inspections on submerged closure bolting on the emergency cooling water pump.

The ASME Section XI lnservice Inspection, Subsections IWB, IWC, and IWD (A.2.1.1) program includes inspection of safety-related closure bolting on pressure-retaining components, and supplements this program. Inspection activities for bolting in a buried environment or underground with restricted access are performed in conjunction with buried piping and component inspections performed as part of the Buried and

January 23, 2019 Enclosure A Page 162 of 187 Underground Piping and Tanks (A.2.1.28) program.

The Reactor Head Closure Stud Bolting (A.2.1.3) program manages the aging effects of the bolting components for the reactor vessel closure head. The ASME Section XI, Subsection IWE (A.2.1.30) program, ASME Section XI, Subsection IWF (A.2.1.31) program; Structures Monitoring {A.2.1.34) program; RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants (A.2.1.35) program; Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems

{A.2.1.13) program; manage the aging effects of safety-related and nonsafety-related structural bolting. The External Surfaces Monitoring of Mechanical Components (A.2.1.24) program manages the aging effects of safety-related and nonsafety-related bolting associated with ductwork for heating, ventilation, and air conditioning systems.

The Bolting Integrity aging management program will be enhanced to:

1. Ensure that submerged carbon steel closure bolts on the ESW, HPSW, and fire protection pumps are inspected for loss of material and to confirm that the closure bolting is hand tight. A minimum of 19 bolt inspections shall be performed each 10-year period during the second period of extended operation for each unit. Inspection of closure bolting on these pumps during pump overhaul and replacement activities may be credited during each 10-year period in the second period of extended operation.

2. Ensure that submerged stainless steel mechanical bolts on the 2AS008, 2BS008, 3AS008, and 3BS008 Circulating Water Pump Structure intake traveling screens are inspected for loss of material and to confirm that the mechanical bolting is hand tight. A minimum of 19 bolt inspections shall be performed each 10-year period during the second period of extended operation for each unit. Inspection of mechanical bolting on these screens during overhaul and replacement activities may be credited during each 10-year period in the second period of extended operation.

3. Ensure that closure bolts on pressure-retaining components that contain air or gas are inspected for cracking and loss of material for the carbon steel/ air-indoor uncontrolled and the stainless steel/ air-indoor uncontrolled material and environment combinations. In addition, the inspections will confirm that this closure bolting is leak tight applying inspection techniques, such as soap bubble testing, thermography, acoustic testing, or verifying closure bolting is hand tight. A minimum of 19 bolt inspections shall be performed each 10-year period during the second period of extended operation for each unit. Opportunistic inspections during maintenance activities may be credited during the same 10-year period.

4. Ensure that closure bolts on pressure-retaining components that contain air or gas are inspected for loss of material for the carbon steel/ air-outdoor material and environment combination. In addition, the inspections will confirm that this closure bolting is leak tight applying inspection techniques, such as soap bubble testing, thermography, acoustic testing, or verifying closure bolting is hand tight. A minimum of 25 bolt inspections shall be performed each 10-year period during the second period of extended operation for both Units 2 and 3. Opportunistic inspections during maintenance activities may be credited during the same 10-year period.

5. Revise site walkdown procedures to specify proper lighting and appropriate

January 23, 2019 Enclosure A Page 163 of 187 distances to adequately identify visible component leakage, evidence of past leakage, or other age-related degradation on pressure-retaining bolted joints that contain fluids such as water, oil, or steam. Cameras and video equipment may be used to supplement these inspections.

6. Revise existing repetitive tasks to provide guidance for proper lighting and appropriate inspection distances to adequately identify loss of material in submerged environments. Cameras and video equipment may be used to supplement these inspections.

7. Ensure no fewer than five additional bolts are inspected for each sample based inspection that does not meet acceptance criteria, or 20 percent of the total bolt population of each applicable material, environment, and aging effect combination; whichever is less. If these subsequent inspections do not meet acceptance criteria, an extent of condition and extent of cause analysis are performed to determine the further extent of inspections. These additional inspections will be completed within the inspection interval for which the original sample based inspections are conducted.

8. Revise engineering procedures to require volumetric examination in accordance with ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1, regardless of the code classification of the bolting, should high strength bolting greater than 2 inches in diameter be installed.

9. Clarify that the recommended guidance for proper selection of bolting material and lubricants, and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting is a requirement at Peach Bottom in accordance with the guidelines provided in EPRI NP-5067 and TR-104213. Clarify that the recommended requirements for storage, lubricant selection, and bolting and coating material selection to include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication "Specification for Structural Joints Using High Strength Bolts," are a requirement at Peach Bottom.

These enhancements will be implemented no later than six months prior to the second period of extended operation.

January 23, 2019 Enclosure A Page 164 of 187 SLRA Appendix A, Section A.5, Second License Renewal Commitment List, Commitment 10, Bolting Integrity, beginning on page A-91, is revised as shown below.

10 Bolting Integrity Bolting Integrity is an existing program that will be enhanced to: Program will be Section A.2.1.10

1. Ensure that submerged carbon steel closure bolts on the ESW, HPSW, enhanced no later than and fire protection pumps are inspected for loss of material and to confirm six months prior to the that the closure bolting is hand tight. A minimum of 19 bolt inspections second period of shall be performed each 10-year period during the second period of extended operation extended operation for each unit. Inspection of closure bolting on these pumps during pump overhaul and replacement activities may be credited during each 10-year period in the second period of extended operation.

2. Ensure that submerged stainless steel mechanical bolts on the 2AS008, 28S008, 3AS008, and 38S008 Circulating Water Pump Structure intake traveling screens are inspected for loss of material and to confirm that the mechanical bolting is hand tight. A minimum of 19 bolt inspections shall be performed each 10-year period during the second period of extended operation for each unit. Inspection of mechanical bolting on these screens during overhaul and replacement activities may be credited during each 10-year period in the second period of extended operation.

3. Ensure that closure bolts on pressure-retaining components that contain air or gas are inspected for cracking and loss of material for the carbon steel/ air-indoor uncontrolled and the stainless steel/ air-indoor uncontrolled material and environment combinations. In addition, the inspections will confirm that this closure bolting is leak tight applying inspection techniques, such as soap bubble testing, thermography, acoustic testing, or verifying closure bolting is hand tight. A minimum of 19 bolt inspections shall be performed each 10-year period during the second period of extended operation for each unit. Opportunistic inspections during maintenance activities may be credited during the same 10-year period.

4. Ensure that closure bolts on pressure-retaining components that contain air or gas are inspected for loss of material for the carbon steel/

air-outdoor material and environment combination. In addition, the inspections will confirm that this closure bolting is leak tight applying inspection techniques, such as soap bubble testing, thermography, acoustic testing, or verifying closure bolting is hand tight. A minimum of 25 bolt inspections shall be performed each 10-year period during the second period of extended operation for both Units 2 and 3. Opportunistic

January 23, 2019 Enclosure A Page 165 of 187 inspections during maintenance activities may be credited during the same 10-year period.

5. Revise site walkdown procedures to specify proper lighting and appropriate distances to adequately identify visible component leakage, evidence of past leakage, or other age-related degradation on pressure-retaining bolted joints that contain fluids such as water, oil, or steam. Cameras and video equipment may be used to supplement these inspections.

6. Revise existing repetitive tasks to provide guidance for proper lighting and appropriate inspection distances to adequately identify loss of material in submerged environments. Cameras and video equipment may be used to supplement these inspections.

7. Ensure no fewer than five additional bolts are inspected for each sample based inspection that does not meet acceptance criteria, or 20 percent of the total bolt population of each applicable material, environment, and aging effect combination; whichever is less. If these subsequent inspections do not meet acceptance criteria, an extent of condition and extent of cause analysis are performed to determine the further extent of inspections. These additional inspections will be completed within the inspection interval for which the original sample based inspections are conducted.

8. Revise engineering procedures to require volumetric examination in Exelon Letter accordance with ASME Code Section XI, Table IWB-2500-1, PBAPSSLRA Examination Category B-G-1, regardless of the code classification of Supplement the bolting, should high strength bolting greater than 2 inches in No. 2, dated diameter be installed. January 23, 2019

9. Clarify that the recommended guidance for proper selection of bolting material and lubricants, and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting is a requirement at Peach Bottom in accordance with the guidelines provided in EPRI NP-5067 and TR-104213. Clarify that the recommended requirements for storage, lubricant selection, and bolting and coating material selection to include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication "Specification for Structural Joints Using High Strength Bolts," are a requirement at Peach Bottom.

January 23, 2019 Enclosure A Page 166 of 187 SLRA Appendix B, Section B.2.1.10, Bolting Integrity, beginning on page B-62, is revised as shown below.

B.2.1.1 O Bolting Integrity Program Description The Bolting Integrity aging management program is an existing condition monitoring program which manages aging for loss of preload, cracking, and loss of material of safety-related and nonsafety-related closure bolting on pressure-retaining components. The program utilizes recommendations and guidelines delineated in NUREG-1339, EPRI NP-5769, TR-1015336, and TR-1015337 for material selection, use of approved lubricants, proper torqueing, and leakage evaluations which are implemented during plant surveillance and maintenance activities.

In addition, the program manages aging of submerged mechanical bolting on the 2AS008, 2BS008, 3AS008, and 3BS008 Circulating Water Pump Structure intake traveling screens.

The program activities provide for aging management of closure bolting on pressure-retaining components within the scope of second license renewal. The program includes periodic inspection, at least once per refueling cycle, of closure bolting on pressure-retaining components for indication of loss of preload, cracking, and loss of material due to corrosion.

The program also credits visual inspection of pressure-retaining bolted joints in ASME Class 1, 2, and 3 systems for leakage and age-related degradation during system pressure tests performed in accordance with ASME Section XI. In addition, the Bolting Integrity aging management program credits volumetric, surface, and visual inspections of ASME Section XI Class 1, 2, and 3 bolts, nuts, washers, and other associated bolting components performed in accordance with ASME Section XI, Tables IWB-2500-1, IWC-2500-1, and IWD-2500-1. The integrity of ASME and non-ASME pressure-retaining bolted joints which contain fluids such as water, oil, or steam is assessed by detection of visible leakage, evidence of past leakage, or other age-related degradation during walkdowns and maintenance activities. Conditions such as: degraded bolts, nuts and threads; active leakage; high noise levels; loose or missing bolts and nuts; evidence of past leakage; damaged insulation; discoloration; or other age-related degradation are entered into the corrective action program where the condition is evaluated.

Resulting actions could include: operability evaluation, root cause determination, extent of condition evaluation, additional or more frequent inspections, and replacement. This could include, when practical, projections of identified corrosion or degradation rates until the next scheduled inspection or replacement. Inspections are performed by personnel qualified in accordance with station procedures and programs to perform the specified task. Inspections within the scope of the ASME Code follow procedures consistent with the ASME Code. Non-ASME Code inspections follow station procedures that include inspection parameters for items such as lighting, distance, and offset, which provide an adequate examination.

The program performs periodic sample inspections on closure bolting on pressure-retaining components within the scope of second license renewal that contain air or gas.

January 23, 2019 Enclosure A Page 167 of 187 The program also includes preventive measures, such as, use of EPRI guidance for the installation, makeup, and material selections of bolted joints; prohibiting the use of lubricants containing molybdenum disulfide; and minimizing the use of high strength bolting to preclude or minimize loss of preload and cracking. Engineering procedures will be enhanced to clarify that recommended guidance for selection, storage and installation of bolting per applicable EPRI and Research Council on Structural Connections (RCSC) publications are a requirement.

Aging management reviews have determined that high strength bolting material with actual yield strength of 150 ksi or greater is used for closure bolting on pressure-retaining components within the scope of second license renewal. There are no high strength bolts that are greater than 2 inches in diameter, or bolts with unknown yield strength within the scope of the Bolting Integrity program, therefore sample based volumetric inspection of closure bolting to detect indications of cracking is not applicable. Engineering procedures will be enhanced to require volumetric examination in accordance with ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1, regardless of the code classification of the bolting, should high strength bolting greater than 2 inches in diameter be installed.

The program includes periodic sample inspections on submerged closure bolting on the ESW, HPSW, and fire protection pumps; submerged closure bolting on the Core Spray, HPCI, RHR, and RCIC system suction strainers; and submerged mechanical bolts on the 2AS008, 2BS008, 3AS008, and 3BS008 intake traveling screens. The program also performs periodic inspections on submerged closure bolting on the emergency cooling water pump.

The reduction of the number of minimum inspections to 19 from 25 bolts per unit for the ESW, HPSW and fire protection pumps, and mechanical bolting located on the 2AS008, 2BS008, 3AS008, and 3BS008 intake traveling screens is justified since the raw water environment in each intake bay is the same for Unit 2 and Unit 3. Also, the reduction of the number of minimum inspections to 19 from 25 bolts per unit on pressure-retaining components that contain air or gas in the carbon steel/ air-indoor uncontrolled and the stainless steel/ air-indoor uncontrolled material and environment combinations is justified since the air-indoor uncontrolled environment for Unit 2 and 3 is the same.

For sample based inspections in which acceptance criteria is not met the condition will be entered into the corrective action program. Conditions such as: loss of material; cracking; loss pf preload; degraded threads; active leakage; loose or missing bolts or nuts; and evidence of past leakage will be entered into the corrective action program where the condition will be evaluated. The degraded conditions will be evaluated relative to extent of condition against the total population of bolts under similar service conditions, to confirm the timing and extent of subsequent inspections to maintain the components' intended functions throughout the second period of extended operation. Site procedures will be enhanced so that as a minimum, additional inspection will be conducted where there will be no fewer than five additional inspections for each inspection that did not meet acceptance criteria, or 20 percent of each applicable material, environment, and aging effect combination, whichever is less. The additional inspections will be completed within the inspection interval for which the original sample based inspections are conducted. Inspection frequencies may be adjusted based on projected degradation rates.

The following bolting is not managed by in the Bolting Integrity aging management program.

January 23, 2019 Enclosure A Page 168 of 187

• The bolting components for the reactor vessel closure head are managed by the Reactor Head Closure Stud Bolting (B.2.1.3) program.

• The Primary Containment (MC) pressure-retaining bolting is managed as part of the ASME Section XI, Subsection IWE (B.2.1.30) program.

• ASME Class 1, 2, 3, and MC piping and components support bolting, including NSSS component supports, is managed as part of the ASME Section XI, Subsection IWF (B.2.1.31) program.

• Structural bolting, other than ASME Class 1, 2, 3, and MC piping and component supports bolting is managed as part of the Structures Monitoring (B.2.1.34) program, and the Inspection of Water-Control Structures Associated With Nuclear Power Plants (B.2.1.35) program.

• Crane and hoist bolting is managed by the Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems (B.2.1.13) program.

• Heating and ventilation system bolted joints are managed by the External Surfaces Monitoring of Mechanical Components (B.2.1.24) program.

• Pressure-retaining bolting in a buried environment or underground with restricted access are inspected in conjunction with buried piping and component inspections performed as part of the Buried and Underground Piping and Tanks (B.2.1.28) program.

NUREG-2191 Consistency The Bolting Integrity aging management program will be consistent with the ten elements of aging management program Xl.M18, "Bolting Integrity" specified in NUREG-2191 with the following exception.

Exceptions to NUREG-2191

1. NUREG-2191 recommends that the scope of the Bolting Integrity program manages aging of closure bolting on pressure-retaining components. The scope of the Bolting Integrity aging management program will also include the aging management of mechanical bolting on the 2AS008, 2BS008, 3AS008, and 38S008 Circulating Water Pump Structure intake traveling screens. Program Element Affected: Scope of Program (Element 1)

Justification for Exception Although the submerged mechanical bolts on the 2AS008, 28S008, 3AS008, and 3BS008 Circulating Water Pump Structure intake traveling screens are not closure bolting on pressure-retaining components, the Bolting Integrity aging management program has been determined to address the aging effects of loss of preload and loss of material as recommended in NUREG-2191.

January 23, 2019 Enclosure A Page 169 of 187 The component, material, environment, and aging effects for these submerged mechanical bolts are the same as for submerged pressure-retaining closure bolts that are included within the scope of the NUREG-2191, Xl.M18, Bolting Integrity program. The alternate means of inspection or testing provided within the NUREG-2191, Xl.M18 program for submerged bolting, utilizing sample based visual inspections, has been determined to adequately manage the aging effects of loss of preload and loss of material for these submerged mechanical bolts.

Enhancements Prior to the second period of extended operation, the following enhancements will be implemented in the following program elements:

1. Ensure that submerged carbon steel closure bolts on the ESW, HPSW, and fire protection pumps are inspected for loss of material and to confirm that the closure bolting is hand tight. A minimum of 19 bolt inspections shall be performed each 10-year period during the second period of extended operation for each unit. Inspection of closure bolting on these pumps during pump overhaul and replacement activities may be credited during each 10-year period in the second period of extended operation. Program Elements Affected: Detection of Aging Effects {Element 4) and Acceptance Criteria {Element 6).

2. Ensure that submerged stainless steel mechanical bolts on the 2AS008, 288008, 3AS008, and 388008 Circulating Water Pump Structure intake traveling screens are inspected for loss of material and to confirm that the mechanical bolting is hand tight. A minimum of 19 bolt inspections shall be performed each 10-year period during the second period of extended operation for each unit. Inspection of mechanical bolting on these screens during overhaul and replacement activities may be credited during each 10-year period in the second period of extended operation. Program Elements Affected: Detection of Aging Effects {Element 4) and Acceptance Criteria (Element 6).

3. Ensure that closure bolts on pressure-retaining components that contain air or gas are inspected for cracking and loss of material for the carbon steel/ air-indoor uncontrolled and the stainless steel/ air-indoor uncontrolled material and environment combinations. In addition, the inspections will confirm that this closure bolting is leak tight applying inspection techniques, such as soap bubble testing, thermography, acoustic testing, or verifying closure bolting is hand tight. A minimum of 19 bolt inspections shall be performed each 10-year period during the second period of extended operation for each unit. Opportunistic inspections during maintenance activities may be credited during the same 10-year period. Program Elements Affected: Detection of Aging Effects {Element 4) and Acceptance Criteria {Element 6).

4. Ensure that closure bolts on pressure-retaining components that contain air or gas are inspected for loss of material for the carbon steel/ air-outdoor material and environment combination. In addition, the inspections will confirm that this closure bolting is leak tight applying inspection techniques, such as soap bubble testing, thermography, acoustic testing, or verifying closure bolting is hand tight. A minimum of 25 bolt inspections shall be performed each 10-year period during the second period of extended operation for both Units 2 and 3.

Opportunistic inspections during maintenance activities may be credited during the same 10-year period. Program Elements Affected: Detection of Aging Effects {Element 4) and Acceptance Criteria {Element 6).

January 23, 2019 Enclosure A Page 170 of 187

5. Revise site walkdown procedures to specify proper lighting and appropriate distances to adequately identify visible component leakage, evidence of past leakage, or other age-related degradation on pressure-retaining bolted joints that contain fluids such as water, oil, or steam.

Cameras and video equipment may be used to supplement these inspections. Program Element Affected: Detection of Aging Effects (Element 4).

6. Revise existing repetitive tasks to provide guidance for the proper lighting and appropriate inspection distances to adequately identify loss of material for bolting in submerged environments. Cameras and video equipment may be used to supplement these inspections.

Program Element Affected: Detection of Aging Effects (Element 4).

7. Ensure no fewer than five additional bolts are inspected for each sample based inspection that does not meet acceptance criteria, or 20 percent of the total bolt population of each applicable material, environment, and aging effect combination; whichever is less. If these subsequent inspections do not meet acceptance criteria, an extent of condition and extent of cause analysis are performed to determine the further extent of inspections. These additional inspections will be completed within the inspection interval for which the original sample based inspections are conducted. Program Element Affected: Corrective Actions (Element 7)

8. Revise engineering procedures to require volumetric examination in accordance with ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1, regardless of the code classification of the bolting, should high strength bolting greater than 2 inches in diameter be installed. Program Element Affected: Detection of Aging Effects (Element 4).

9. Clarify that the recommended guidance for proper selection of bolting material and lubricants, and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting is a requirement at Peach Bottom in accordance with the guidelines provided in EPRI NP-5067 and TR-104213. Clarify that the recommended requirements for storage, lubricant selection, and bolting and coating material selection to include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication "Specification for Structural Joints Using High Strength Bolts," are a requirement at Peach Bottom. Program Element Affected:

Preventive Actions (Element 2).

January 23, 2019 Enclosure A Page 171 of 187 Change #19 - Addition of Enhancement for Detection of Aging Effects for One-Time Supplemental Volumetric Examination, if Triggered by Plant-Specific OE, of the Containment Metal Shell Affected SLRA Sections: Appendix A, Section A.2.1.30, Appendix A, Section A.5, and Appendix 8, Section B.2.1.30 SLRA Page Numbers: A-40, A-106, and B-174 Description of Change:

The Detection of Aging Effects element for ASME Section XI, Subsection IWE aging management program states that if triggered by plant-specific operating experience, a one-time supplemental volumetric examination is required of the containment shell inaccessible surfaces. No corresponding enhancements to the ASME Section XI, Subsection IWE aging management program is provided in the SLRA to incorporate the required examination. A new enhancement is being created to reflect the requirement in the Detection of Aging Effects element including the guidance on the trigger for examination, sample size, location, and any required scope expansion.

Accordingly, SLRA Appendix A, Section A.2.1.30, Appendix A, Section A.5, and Appendix 8, Section B.2.1.30 are revised.

January 23, 2019 Enclosure A Page 172 of 187 SLRA Appendix A, Section A.2.1.30, ASME Section XI, Subsection IWE, page A-40, is revised as shown below to provide an enhancement for implementation of a one-time supplemental volumetric examination, if triggered by plant-specific OE, of the containment metal shell. This SLRA markup also includes the changes discussed in Change #6 above to address preventative actions tor bolting integrity and is duplicated here as an aid to the reviewer.

A.2.1.30 ASME Section XI, Subsection IWE The ASME Section XI, Subsection IWE aging management program is an existing condition monitoring program based on ASME Code and complies with the provisions of 10 CFR 50.55a.

The program consists of periodic visual, surface, and volumetric examinations, where applicable, of metallic pressure-retaining components of steel containments for signs of degradation, damage, irregularities, and tor coated areas distress of the underlying metal shell, and corrective actions. Acceptability of inaccessible areas of steel containment shell is evaluated when conditions found in accessible areas indicate the presence of, or could result in, flaws or degradation in inaccessible areas.

This program also includes aging management for the potential loss of material due to corrosion in the inaccessible areas of the BWR Mark I steel containment. In addition, the program includes supplemental surface examination to detect cracking for high temperature mechanical penetrations subject to cyclic loading but have no CLB fatigue analysis; and if triggered by plant-specific operating experience, a one-time supplemental volumetric examination by sampling randomly selected as well as focused locations susceptible to loss of thickness due to corrosion of containment shell that is inaccessible from one side. Inspection results are compared with prior recorded results in acceptance of components for continued service.

The ASME Section XI, Subsection IWE aging management program will be enhanced to:

1. Perform surface examinations on accessible portions of high temperature drywell mechanical penetrations, in addition to visual examinations, to detect cracking, once per 10-year interval during the second period of extended operation.

2. Clarify that the recommended guidance for proper selection of bolting material and lubricants, and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting is a requirement at Peach Bottom in accordance with the guidelines provided in EPRI NP-5067 and TR-104213.

Clarify that the recommended requirements for storage, lubricant selection, and bolting and coating material selection include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication "Specification for Structural Joints Using High-Strength Bolts," are a requirement at Peach Bottom.

3. Implement a one-time supplemental volumetric examination of the containment metal shell surfaces that are inaccessible from one side, if triggered by plant-specific OE.

The trigger for this supplemental examination is plant-specific occurrence or recurrence of measurable metal shell corrosion (base metal material loss exceeding 10 percent of nominal plate thickness) initiated on the inaccessible side or areas, identified since the date of issuance of the first renewed license. This supplemental volumetric examination consists of a sample of one-foot square locations that include both randomly-selected and focused areas most likely to experience degradation

January 23, 2019 Enclosure A Page 173 of 187 based on plant-specific OE and/or other relevant considerations such as environment. The sample size, locations, and any needed scope expansion (based on findings) for this one-time set of volumetric examinations should be determined on a plant-specific basis to demonstrate statistically with 95 percent confidence that 95 percent of the accessible portion of the containment liner is not experiencing corrosion degradation with greater than 1O percent loss of nominal thickness.

This onhanoomont These enhancements will be implemented no later than six months prior to the second period of extended operation.

January 23, 2019 Enclosure A Page 174 of 187 SLRA Appendix A, Section A.5, Commitment 30, on page A-106, is revised as shown below to provide an enhancement for implementation of a one-time supplemental volumetric examination, if triggered by plant-specific OE, of the containment metal shell. This SLRA markup also includes the changes discussed in Change #6 above to address preventative actions for bolting integrity and is duplicated here as an aid to the reviewer.

A.5 Second License Renewal Commitment List *:*

PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

30 ASME Section XI, ASME Section XI, Subsection IWE is an existing program that will be enhanced to: Program will be Section A.2. 1.30 Subsection IWE 1. Perform surface examinations on accessible portions of high temperature enhanced no later than drywell mechanical penetrations, in addition to visual examinations, to six months prior to the detect cracking, once per 10-year interval during the second period of second period of extended operation. extended operation.

2. Clarify that the recommended guidance for proper selection of bolting material and lubricants, and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting is a requirement at Peach Bottom Exelon Letter in accordance with the guidelines provided in EPRI NP-5067 and TR-104213. Clarify that the recommended requirements for storage, PBAPSSLRA lubricant selection, and bolting and coating material selection Supplement include the recommendations in Section 2 of Research Council on No. 2, dated Structural Connections (RCSC) publication "Specification for January23, Structural Joints Using High-Strength Bolts," are a requirement at 2019 Peach Bottom.

3. Implement a one-time supplemental volumetric examination of the containment metal shell surfaces that are inaccessible from one side, if triggered by plant-specific OE. The trigger for this supplemental examination is plant-specific occurrence or recurrence of measurable metal shell corrosion (base metal material loss exceeding 10 percent of nominal plate thickness) initiated on the inaccessible side or areas, identified since the date of issuance of the first renewed license. This supplemental volumetric examination consists of a sample of one-foot square locations that include both randomly-selected and focused areas most likely to experience degradation based on plant-specific OE and/or other relevant considerations such as environment. The sample size, locations, and any needed scope expansion {based on findings) for this one-time set of volumetric examinations should be determined on a plant-specific basis to demonstrate statistically with 95 percent confidence that 95 percent of the accessible portion of the containment liner is not experiencing corrosion degradation with greater than 10 percent loss of nominal thickness.

January 23, 2019 Enclosure A Page 175 of 187 SLRA Appendix B, Section B.2.1.30, ASME Section XI, Subsection IWE, page B-174, is revised as shown below to provide an enhancement for implementalion of a one-time supplemental volumetric examination, if triggered by plant-specific OE, of the containment metal shell. This SLRA markup also includes the changes discussed in Change #6 above to address preventative actions for bolting integrity and is duplicated here as an aid to the reviewer.

B.2.1.30 ASME Section XI, Subsection IWE Enhancements Prior to the second period of extended operation, the following onhanoomont enhancements will be implemented in the following program elements:

1. Perform surface examinations on accessible portions of high temperature drywell mechanical penetrations, in addition to visual examinations, to detect cracking, once per 10-year interval during the second period of extended operation. Program Elements Affected: Parameters Monitored or Inspected (Element 3) and Detection of Aging Effects (Element 4)

2. Clarify that the recommended guidance for proper selection of bolting material and lubricants, and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting is a requirement at Peach Bottom in accordance with the guidelines provided in EPRI NP-5067 and TR-104213. Clarify that the recommended requirements for storage, lubricant selection, and bolting and coating material selection include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication "Specification for Structural Joints Using High-Strength Bolts," are a requirement at Peach Bottom. Program Elements Affected: Preventative Action (Element 2)

3. Implement a one-time supplemental volumetric examination of the containment metal shell surfaces that are inaccessible from one side, if triggered by plant-specific OE. The trigger for this supplemental examination is plant-specific occurrence or recurrence of measurable metal shell corrosion (base metal material loss exceeding 10 percent of nominal plate thickness) initiated on the inaccessible side or areas, identified since the date of issuance of the first renewed license. This supplemental volumetric examination consists of a sample of one-foot square locations that include both randomly-selected and focused areas most likely to experience degradation based on plant-specific OE and/or other relevant considerations such as environment. The sample size, locations, and any needed scope expansion (based on findings) for this one-time set of volumetric examinations should be determined on a plant-specific basis to demonstrate statistically with 95 percent confidence that 95 percent of the accessible portion of the containment liner is not experiencing corrosion degradation with greater than 1O percent loss of nominal thickness. Program Elements Affected: Detection of Aging Effects (Element 4)

January 23, 2019 Enclosure A Page 176 of 187 Change #20 - Addition of Summary of Fatigue Waiver Assessment Affected SLRA Sections: 3.5.2.2.1.5 and 3.5.2.2.1.6 SLRA Page Numbers: 3.5-33, 3.5-34, and 3.5-35 Description of Change:

SLRA Appendix B, Section B.2.1.30 ASME XI, Subsection IWE includes the following exception:

"NUREG-2191 states that steel, stainless steel, dissimilar metal weld pressure-retaining components that are subject to cyclic loading but have no CLB fatigue analysis, are monitored for cracking and are supplemented with surface examination (or other applicable techniques) in addition to visual examination to detect cracking. Peach Bottom does not monitor for cracking utilizing supplemental surface examinations except at high temperature mechanical penetrations."

As part of the justification for the exception, the SLRA states that the PBAPS primary containment was designed per ASME Section Ill, 1965 edition and applicable addenda through the Summer 1966 edition, and that no fatigue analysis or waiver was required per the original construction specifications. The SLRA Section 3.5.2.2.1.6 further states that PBAPS has performed an assessment that has shown that had the drywell been designed to ASME Section Ill, 1974 edition, it would have met the six criteria in Subsection NE-3222.4(d) "Components not requiring analysis for cyclic operation." This drywell fatigue waiver assessment concluded that the components that could be subject to cyclic loading, but have no CLB fatigue analysis, are subject to an acceptable and negligible amount of fatigue, and therefore no visual or surface examinations will be performed on these components. SLRA Section 3.5.2.2.1.5 is being revised to provide a summary of the fatigue waiver to provide additional detail on the actual assessment.

Accordingly, SLRA Sections 3.5.2.2.1.5 and 3.5.2.2.1.6 are being revised to include the additional detail.

January 23, 2019 Enclosure A Page 177 of 187 SLRA Section 3.5.2.2.1.5, page 3.5-33 is revised as shown below.

3.5.2.2.1.5 Cumulative Fatigue Damage Evaluations involving time-dependent fatigue, cyclical loading, or cyclical displacement of metal liner, metal plates, suppression pool steel shells (including welded joints) and penetrations (including personnel airlock, equipment hatch, control rod drive (CRD) hatch, penetration sleeves, dissimilar metal welds, and penetration bellows) for all types of PWR and BWR containments and BWR vent header, vent line bellows, and downcomers may be TLAAs as defined in 10 CFR 54.3.

TLAAs are required to be evaluated in accordance with 10 CFR 54.21(c)(1). The evaluation of this TLAA is addressed in Section 4.6, "Containment Liner Plates, Metal Containments, and Penetrations Fatigue Analysis," and for cases of plant-specific components, in Section 4. 7 "Other Plant-Specific Time-Limited Aging Analyses," of this SRP-SLR. For plant-specific cumulative usage factor calculations, the method used is appropriately defined and discussed in the applicable TLAAs.

Table 3.5.1 Item Number 3.5.1-009: This item evaluates cumulative fatigue damage due to cyclic loading (only for an existing analysis that is part of the CLB) in metal plates, suppression pool steel shells (including welded joints) and penetrations (including personnel airlock, equipment hatch, CRD hatch, penetration sleeves, dissimilar metal welds, and penetration bellows), vent header, vent line bellows, and downcomers of the PBAPS Mark I containment exposed to air-indoor and treated water environments. Components of the primary containment that were analyzed for fatigue and evaluated as a TLAA include the PBAPS torus, torus penetrations, vent header and downcomers, drywell to torus vents, safety relief valve discharge piping externally attached to the torus, other piping attached to the torus, drywell to torus vent bellows, and AHR and Core Spray suction strainers. These components are addressed in Section 4.6.1. In addition, the evaluation of fatigue as a TLAA, for the containment process line penetration bellows, is addressed in Section 4.6.2 and the evaluation of fatigue as a TLAA, for the Unit 3 AHR supply and return line penetrations, is addressed in Section 4.3.2.

The PBAPS Unit 2 and Unit 3 drywell structures, penetrations, and associated components were determined not to have an existing fatigue analysis and therefore have no fatigue TLAAs. These drywell components include the drywell shell, drywell head, drywell personnel airlock, drywell equipment hatches, drywell CAD removal hatch, drywell electrical penetrations, and drywell mechanical penetrations except for bellows and the Unit 3 AHR supply and return line penetrations. The containment analysis was completed in accordance with the original design specifications. Fatigue analysis, or a fatigue waiver, for the drywell shell, drywell head, or drywell penetrations was not required since no cyclical loads were identified for these components in the applicable design specifications per the CLB. As part of license renewal activities, a fatigue waiver analysis was performed that has shown that had the drywell been designed to ASME Section Ill, 1974 edition, it would have met the six criteria in Subsection NE-3222.4{d) "Components not requiring analysis for cyclic operation." This drywel/ fatigue waiver assessment concluded that the components that could be subject to cyclic loading, but have no CLB fatigue analysis, are subject to an acceptable and negligible amount of fatigue. The fatigue waiver assessment is summarized at the end of this section.

Subsequent to the original design, design changes were made to some portions of the containment, which added new requirements for fatigue analyses, which are considered TLAAs, as described below.

During the 1980's, elements of the PBAPS Units 2 and 3 primary containments were reanalyzed in response to discoveries, by General Electric and others, of unevaluated loads due to design basis events and safety relief valve (SRV) discharge. The load definitions include assumed pressure and temperature transient cycles resulting from SRV discharge and design basis loss of coolant accident (LOCA) events. Components of the primary containment that were analyzed

January 23, 2019 Enclosure A Page 178 of 187 included the torus shell, torus penetrations, the drywell-to-torus vent piping, SRV discharge piping, other piping attached to the.torus, and the drywell to torus vent bellows. As such, these components were analyzed for fatigue and are considered TLAAs, which are addressed in Section 4.6.1.

In the 1980s the PBAPS replaced reactor recirculation and the residual heat removal (AHR) system piping on both units. The Unit 3, the drywell flued-head penetrations for the AHR system were also replaced and analyzed for fatigue in accordance with ASME Section Ill, Class 1 requirements. These components were analyzed for fatigue and these analyses are considered TLAAs, which are addressed in Section 4.3.2.

In 1997 and 1998 PBAPS Units 2 and 3 replaced the AHR and Core Spray System suction strainers. These new strainers and their supports were designed to ASME Section Ill, Subsections NC, NE, and NF, 1980 edition up to and including Winter 1981 Addenda. As such, the new strainers and supports were analyzed for fatigue, and these analyses are considered TLAAs, which are addressed in Section 4.6.1.

Drywell Fatigue Waiver Assessment

1. Introduction 1.1 For drywell components that do not have a fatigue analysis performed per the original plant design specifications and construction codes, PBAPS has performed an assessment to show that the drywell would have met the criteria for a fatigue waiver.

2. Summary

2. 1 The PBAPS Unit 2 and Unit 3 drywe/I structures, penetrations, and associated components were determined not to have an existing fatigue analysis and therefore have no fatigue TLAAs. These drywell components include the drywell shell, drywell head, drywell personnel airlock, drywell equipment hatches, drywell CRD removal hatch, drywell electrical penetrations, and drywe/I mechanical penetrations. The containment analysis was completed in accordance with the original design specifications. Fatigue analysis, or a fatigue waiver, for the drywell shell, drywell head, and drywell penetrations as listed above were not required since no cyclical loads were identified for these components in the applicable design specifications per the CLB.

The PBAPS primary containment was designed per ASME Section Ill, 1965 edition through Summer 1966 addenda. There was no fatigue analysis or waiver required per original construction specifications. Nevertheless, as part of the development of the SLRA, PBAPS has performed an assessment that has shown that had the drywell been designed to ASME Section Ill, 1974 edition, it would have met the six criteria in Subsection NE-3222.4(d) "Vessels Not Requiring Analysis for Cyclic Operation." The design values used in the assessment were based on 1974 Code edition. These values were compared to those values in the 1965 edition/1966 addenda code of record and no changes were noted which impacted the conclusions of the fatigue waiver. Therefore, the fatigue waiver assessment (using 1974 code) applies to drywell design based on 1965-66 code of record.

The assessment justified that the drywell structures, penetrations, and associated components meet the fatigue waiver criteria specified in ASME Section Ill, Subparagraph NE-3222.4{d) and that no fatigue analysis was required to be performed

January 23, 2019 Enclosure A Page 179 of 187 for the drywell structures, penetrations, and associated components. The six criteria address the following design inputs:

1. Atmospheric-to-Operating Pressure Cycles

2. Normal Operation Pressure Fluctuations

3. Temperature Difference - Startup and Shutdown

4. Temperature Difference - Normal Operation

5. Temperature Difference - Dissimilar Materials

6. Mechanical Loads 2.2 This assessment excluded any portions of penetrations that are affected by process fluid to the extent that either (a) temperature exceeds the maximum drywel/

temperature of 281°F, and/or (b) has a range in temperature difference between adjacent points greater than 231°F.

Due to the scope restrictions on maximum temperature and maximum temperature difference, portions of the following penetrations are excluded by the fatigue waiver assessment and as a result, accessible portions of these penetrations will have surface examinations performed to detect cracking:

• N-7 A-D: main steam

• N-8: condensate drain, main steam

• N-9 AIB: RPV feedwater

• N-1 O: RCIC steam supply

• N-11: HPCI steam supply

• N-12: RHR supply, Unit 2 only

• N-13 AIB: RHR return, Unit 2 only

• N-14: reactor water cleanup pump supply

• N-41: recirc sample

• N-57: main steam sample 2.3 Portions of these penetrations, remote from the process piping, such as bellows and outer sleeve, are expected to be below 281 degrees F and within the range in temperature difference between adjacent points of 231°F and are therefore included by the assessment. For Unit 3, the penetrations N-12 and N-13 AIB were analyzed for fatigue and are therefore not included within the scope of this assessment.

2.4 The materials used in the drywell and its penetrations are ASME SA-516 Grade 70 (plate) and ASME SA-333 Grade 1 (pipe), both of which are carbon steel. In addition, some penetrations contain stainless steel portions. The material properties for ASME SA-240 Type 304L stainless steel material are used since these include the bounding (low) Sm values. The assessment is simplified to perform an evaluation of the six criteria on a material basis instead of an individual penetration basis.

January 23, 2019 Enclosure A Page 180 of 187 2.5 Conservative, bounding number of cycles for 80 years were used with specific values as follows, with further explanations provided in subsequent sections:

• Number of full pressure cycles: 266 (per SLRA Table 4.3.3-2)

• Number of significant pressure fluctuations: 17 (bounds number of integrated leak rate tests based on original 10-year integrated leak rate test requirement)

• Number of startup/shutdown cycles:197 (per SLRA Table 4.3.3-2)

• Number of significant temperature fluctuations: 700 (bounds SLRA Table 4.3.3-2)

• Number of significant load fluctuations: 7437 (based on torus penetration cycles which bounds values provided in SLRA Section 4.3.4)

3. Evaluation 3.1 From ASME Section Ill, NE-3222.4(d) (1)-Atmospheric to Operating Pressure Cycle The specified number of times (including startup and shutdown) that the pressure will be cycled from atmospheric pressure to operating pressure and back to atmospheric pressure during normal operation does not exceed the number of cycles on the applicable fatigue curve found in Figures 1-9-1and1-9-2 corresponding to an Sa value of 3 times the Sm value for the material at operating temperature.

Evaluation -NE-3222.4(d) (1)

The number of pressure cycles over the full range from zero to normal operating pressure is 266, the value for the reactor pressure vessel exempted components (refer to SLRA Table 4.3.3-2), which is appropriate given that it is reasonable to expect the drywell to be pressurized in most cases when the RPV is pressurized. Sm is the allowable stress intensity value at a given temperature from Tables 1-1.1and1-1.2. Sa corresponds to the allowable amplitude of the alternating stress component and are plotted against the number of cycles on the fatigue curves found in Figures 1-9-1 and 1-9-2.

At 266 cycles and Sm values taken at 281 degrees F, the resulting fatigue curve cycles at 3 times the Sm from Figures 1-9-1 and 1-9-2 are as follows:

• SA-516 Gr. 70 (Sm= 21.4 ksi) = 1983 cycles

• SA-333 Gr. 1 (Sm = 17.8 ksi) = 3560 cycles

• SA-240 Gr. 304L (Sm= 16.6 ksi) = 18331 cycles Therefore, resulting cycles based on the fatigue curve for each material is greater than the expected 266 operating pressure cycles for 80 years and the criterion is met.

January 23, 2019 Enclosure A Page 181 of 187 3.2 From ASME Section Ill, NE-3222.4(d) (2)-Normal Operation Pressure Fluctuation The specified full range of pressure fluctuations during normal operation does not exceed the quantity (113) x design pressure x (Sa !Sm) where Sa is the value obtained from the applicable design fatigue curve for the total specified number of significant pressure fluctuations and Sm is the allowable stress intensity for the material at operating temperature. If the total specified number of significant pressure fluctuations exceeds 106, the Sa value at N= 106may be used. Significant pressure fluctuations are those for which the total excursion exceeds the quantity:

• Design Pressure

• 113

• S!Sm

• where S = the value of Sa obtained from the applicable design fatigue curve for 106 cycles.

Evaluation - NE-3222.4(d) (2)

• Normal pressure range = 2 psi; Design Pressure = 56 psi Per NE-3222.4(d) (2) significant pressure fluctuations are those for which the excursion exceeds the quantity:

• Design Pressure

• 113

• S!Sm,

• where S = the value of Sa obtained from the applicable design fatigue curve for 106cycles.

At 106 cycles, Sa = 12,500 psi for carbon steel.

For SA-516 Gr. 70, Sm = 21,400 psi.

Therefore, for SA-516 Gr. 70, significant pressure fluctuations are those for which the excursion exceeds the quantity:

• 56*12500/(3*21400) = 11 psi For SA-333 Gr. 1, Sm= 17,800 psi.

Therefore, for SA-333 Gr. 1, significant pressure fluctuations are those for which the excursion exceeds the quantity:

• 56*12500/(3*17800) = 13 psi At 106cycles, Sa= 26,000 psi for stainless steel.

For SA-240 Gr. 304L, Sm= 16,600 psi.

Therefore, for SA-240 Gr. 304L, significant pressure fluctuations are those for which the excursion exceeds the quantity:

• 56*26000/(3*16600) = 29 psi These pressure values define what is a significant pressure fluctuation.

January 23, 2019 Enclosure A Page 182 of 187 The expected number of significant pressure fluctuations is less than 17. This is reasonably conservative because the design basis accident is a very rare event, the integrated leak rate test of the entire containment is required no more frequently than 1O years, and there is only one occurrence of the initial structural integrity test.

At 17 pressure fluctuations; from Figure 1-9-1, the corresponding Sa for carbon steel is 445,000 psi (which includes SA-516 and SA-333).

At 17 pressure fluctuations; from Figure 1-9-2, the corresponding Sa for stainless steel is 507,000 psi (which includes SA-240).

The resulting limit on the normal operation pressure range:

• For SA-516 Gr. 70: 56*445000/(3*21400) = 388 psi

• For SA-333 Gr. 1: 56*445000/(3*17800) = 466 psi

• For SA-240 Gr. 304L: 56*507000/(3*16600) = 570 psi These values are significantly greater than the normal operation pressure fluctuation range and as a result the normal operation pressure fluctuation meets the requirements of criterion (2).

3.3 From ASME Section Ill, NE-3222.4(d) (3) - Temperature Difference -Startup and Shutdown The temperature difference in degrees Fahrenheit between any two adjacent points of the vessel during normal operation does not exceed Sa /(2E a), where Sa is the value obtained from the applicable design fatigue curves for the specified number of startup-shutdown cycles, a is the value of the instantaneous coefficient of thermal expansion at the mean value of the temperatures at the two points as given by Table 1-5.0 and Eis taken from Table 1-6.0 at the two points.

Evaluation - NE-3222.4(d) (3)

The expected number of startup-shutdown cycles is 197 in which the drywell and penetrations experience the maximum temperature difference between any two adjacent points occurring during Startup and Shutdowns. This is the bounding value used in SLRA Table 4.3.3-2.

• Maximum Operating Temperature for the vessel steel is 281 °F (from the original specification for the drywell)

• Minimum Operating Temperature is 50 °F

• Maximum operating temperature difference is 281°F - 50 °F = 231 °F

• Mean operating temperature = (281°F + 70 °F)/2 = 175.5 °F (70 °F is used in averaging instead of 50 °F to yield conservatively high E*a)

• a (carbon steel)= 6.56E"6 inlin/°F

• a (stainless steel)= 9.45E-6 inlin/°F

• E (carbon steel)= 27.7E6 psi

• E (stainless steel)= 27.8E6 psi

January 23, 2019 Enclosure A Page 183 of 187 At 197 cycles; from Figure 1-9-1 Sa = 156,000 psi (carbon steel). Therefore, for the carbon steel components, the limit on the temperature difference is

• 156000/(2*27.7E6*6.56E-6) = 429 °F.

At 197 cycles; from Figure 1-9-2 Sa = 186,000 psi (stainless steel). Therefore, for the stainless steel components, the limit on the temperature difference is

• 186000/(2*27.BE6*9.45E-6) = 354 °F These temperature limits are both significantly greater than the maximum expected temperature difference of 231°F considered for startup and shutdowns.

These results indicate that the containment could experience shutdown and startup temperature differences (between any two adjacent points) of 429 °F (carbon steel) and 354 °F (stainless steel}, 197 times over 80 years without exceeding the NE-3222.4(d)(3) threshold. In reality, experiencing the NE-3222.4(d}(3) startup and shutdown temperature difference thresholds stated above for 197 cycles is not credible given that the maximum operating temperature difference of 231 °F.

3.4 From ASME Section Ill, NE-3222.4(d) (4) - Temperature Difference-Normal Operation The temperature difference in degrees Fahrenheit between any two adjacent points does not change during normal operation by more than the quantity Sa /(2E a}, where Sa is the value obtained from the applicable design fatigue curve found in Figures 1 1 and 1-9-2 for the total specified number of significant temperature-difference fluctuations. A temperature-difference fluctuation is considered to be significant if its total algebraic range exceeds the quantity S/2E a, where S is the value of Sa obtained from the applicable design fatigue curve for 106 cycles.

Evaluation- NE-3222.4(d) (4)

The expected number of significant temperature-difference fluctuations in which the drywell and penetrations experience the maximum temperature-difference fluctuations between any two adjacent points is 700, which is reasonably conservative considering that the higher temperature penetrations are excluded from this assessment. This value bounds the values used in SLRA Table 4.3.1-2.

The expected maximum temperature-difference fluctuation equals the difference between maximum operating temperature (281 °F) and the minimum operating temperature 50 °F, which equals 231 °F, and is conservative.

• a (carbon steel)= 6.56 E-6 in/in/°F

• a (stainless steel)= 9.45 E-6 in/in/°F

• E (carbon steel)= 27.7E6 psi

• E (stainless steel)= 27.8E6 psi

January 23, 2019 Enclosure A Page 184 of 187 At 700 cycles, from Figure 1-9-1, s. = 93,700 psi (carbon steel); Therefore, the limit on the temperature-difference for carbon steel is:

• 93700/(2*27.7E6*6.56E-6) = 258 °F.

At 700 cycles, from Figure 1-9-2, s. = 122, 100 psi (stainless steel). Therefore, the limit on the temperature-difference for stainless steel is:

• 122100/(2*27.8E6*9.45E-6) = 233 °F.

These temperature-difference limits between adjacent points are greater than the expected temperature-difference fluctuation of 231°F between adjacent points. These results indicate that the drywel/ and penetrations could experience normal operation temperature differences (between any two adjacent points) of 258°F (carbon steel) and 233°F (stainless steel), 700 times over 80 years without exceeding the NE-3222.4(d)(3) threshold.

3.5 From ASME Section Ill, NE-3222.4(d) (5) - Temperature Difference-Dissimilar Materials For components fabricated from materials of differing moduli of elasticity or coefficients of thermal expansion, the total algebraic range of temperature fluctuation in deg. F experienced by the component during normal operation does not exceed the magnitude s.12(E1*a1 -E2*a2), wheres. is the value obtained from the applicable design fatigue curve for the total specified number of significant temperature fluctuations, E1 and E2 are the moduli of elasticity, and a1 and a2 are the values of the instantaneous coefficients of thermal expansion at the mean temperature involved for the two materials of construction (Tables 1-5.0 and 1-6.0). A temperature fluctuation is considered to be significant if its total excursion exceeds the quantity S/2(E1 *a1 -

E2*a2) where S is the value of s. obtained from the applicable design fatigue curve found in Figures 1-9-1 and 1-9-2 for 106 cycles. If the two materials used have different applicable design fatigue curves, the lower value of s. is used in applying the rules of this paragraph.

Evaluation - NE-3222.4(d) (5)

The expected number of transients in which the drywel/ and penetrations experience the maximum temperature fluctuations between any two adjacent points is 700, consistent with the basis provided in the previous section.

The expected maximum temperature fluctuation equals the difference between maximum operating temperature (281°F) and the minimum operating temperature 50°F, which equals 231 °F, and is conservative.

• a (carbon steel)= 6.56 E-6 in/in/°F

• a (stainless steel)= 9.45 E-6 in/in/°F

• E (carbon steel)= 27.7 E6 psi

• E (stainless steel)= 27.8 E6 psi

• At 700 cycles, from Figure 1-9-1 s. = 93,700 psi (carbon steel)

• At 700 cycles, from Figure 1-9-2 s. = 122, 100 psi (stainless steel)

January 23, 2019 Enclosure A Page 185 of 187 Therefore, the limit on the maximum temperature difference for dissimilar materials for carbon steel is:

• Sa /2(E1 *a1 -E2*a2) = 579.4°F (carbon steel)

Therefore, the limit on the maximum temperature difference for dissimilar materials for stainless steel is:

• Sa /2(E1 *a1 -E2*a2) = 755.5°F (stainless steel)

These temperature-difference limits for dissimilar materials between adjacent points are greater than the expected temperature fluctuation of 231°F. These results indicate that portions of the drywell and penetrations with dissimilar metals could experience maximum temperature fluctuations stated above, 700 times over 80 years without exceeding the NE-3222.4(d)(5) threshold. Realistically, this NE-3222.4(d)(5) threshold is not credible given that the maximum operating temperature differences between adjacent dissimilar materials is only 231 °F.

3.6 From ASME Section Ill, NE-3222.4(d) (6) - Mechanical Loads The specified full range of mechanical loads, excluding pressure, but including pipe reactions, does not result in load stresses whose range exceeds the Sa value obtained from the applicable design fatigue curve found in Figures 1-9-1 and 1-9-2 for the total specified number of significant load fluctuations. If the total specified number of significant load fluctuations exceeds 1<fS, the Sa value at N= 1<fS may be used. A load fluctuation shall be considered to be significant if the total excursion of load stress exceeds the value of Sa obtained from the applicable design fatigue curve for 1<fS cycles.

Evaluation - NE-3222.4(d) (6)

This criterion addresses mechanical reactions on the containment and not thermal or pressure transients. The expected number of significant load fluctuations is 7437, which bounds the number of cycles used for the torus penetrations and the Unit 3 RHR penetrations.

At 1cF cycles, Sa= 12,500 psi for carbon steel and Sa= 26,000 psi for stainless steel.

The mechanical load stress range limits are as follows:

• At 7437 cycles, from Figure 1-9-1, Sa = 42,000 psi (carbon steel)

• At 7437 cycles, from Figure 1-9-2, Sa = 63,500 psi (stainless steel)

The corresponding mechanical load stress is

• SA-516 Gr. 70 carbon steel: 1.5*23,300 psi= 34,950 psi

• SA-333 Gr. 1 carbon steel: 1.5*18,300 psi= 27,450 psi

• SA-240 Gr. 304L stainless steel: 1.5*16,600 psi= 24,900 psi

January 23, 2019 Enclosure A Page 186 of 187 The maximum expected range of mechanical load stress is 1.5Sm at 100 °Ffor the material being analyzed. This value is the maximum permitted primary membrane plus bending stress intensity and one half the maximum permitted primary plus secondary stress intensity range.

Since the mechanical load stress is less than the corresponding Sa for the mechanical load stress range limits, the mechanical load criterion is satisfied.

4. Conclusion

4. 1 The assessment above concludes that the drywel/ structures, penetrations, and associated components meet the fatigue waiver criteria in ASME Section Ill, Subparagraph NE-3222.4(d) criteria (1)-(6) and that no fatigue analysis was required to be performed for the drywel/ structures, penetrations, and associated components.

January 23, 2019 Enclosure A Page 187 of 187 SLRA Section 3.5.2.2.1.6, page 3.5-35, second paragraph, is revised as shown below.

3.5.2.2.1.6 Cracking Due to Stress Corrosion Cracking Cyclical loading of stainless steel penetration sleeves, penetration bellows, vent line bellows, and dissimilar metal welds is not expected to result in sec at PBAPS because of the containment design which limits cyclical loadings to acceptable levels. The design of penetrations, which exhibit significant differences in temperature during plant operations, limit loads from the piping onto the drywell by either using bellows or installation of small bore diameter pipe. The containment analysis was completed in accordance with the original design specifications.

Fatigue analysis, or a fatigue waiver, for the drywell penetrations was not required since no cyclical loads were identified for these components in the applicable design specifications per the CLB. However, PBAPS Units 2 and 3 process lines that penetrate the drywell and experience significant differences in temperature during plant operation were designed with penetration bellows to ensure that fatigue due to thermal loads during plant operation is acceptable, preventing one potential cause of sec at the penetrations. The following process lines were designed with penetration bellows: the main steam lines, the feedwater lines, the HPCI steam line, the RHR supply and return lines, the RWCU pump suction line, the core spray discharge lines, and the vessel head spray line. In addition, during the preparation of this application, PBAPS has performed an assessment to show that the drywall would have met the criteria for a fatigue waiver. License renewal applications for other similar Mark I containments designed to later code years have credited fatigue waivers. The criteria that were met for the fatigue waiver included: 1) atmospheric to operating pressure cycles, 2) normal operation pressure fluctuations,

3) temperature differences between startup and shutdown, 4) temperature differences during normal operation, 5) temperature differences at dissimilar metals, and 6) mechanical loads. The drywall fatigue waiver assessment concluded that the components that could be subject to cyclic loading but have no current licensing basis fatigue analysis are subjected to an acceptable and negligible amount of fatigue. The fatigue waiver assessment did not include drywell high temperature mechanical penetrations, listed above, which have bellows or are limited to small pipe diameters. A summary of the fatigue waiver assessment is provided in section 3.5.2.2.1.5. The containment components with a fatigue analysis that are addressed in Section 3.5.2.2.1.5 and Sections 4.3.2 and 4.6 are representative of the stainless steel penetration sleeves, penetration bellows, vent line bellows, and dissimilar metal welds and can be used as a leading indicator for these components.

January 23, 2019 Enclosure B Page 1 of 7 Enclosure B PBAPS Subsequent License Renewal Commitment List Update Introduction This Enclosure identifies commitments made in this document and is an update to the PBAPS SLRA Appendix A, Section A.5 License Renewal Commitment List. Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.

Changes to the PBAPS SLRA Appendix A, Section A.5 License Renewal Commitment List are as a result of this SLRA Supplement.

These Enclosure 8 pages are the same as the corresponding PBAPS SLRA Appendix A, Section A.5 pages included in Enclosure A.

To facilitate understanding, relevant portions of the previously submitted License Renewal Commitment List have been repeated in this Enclosure, with revisions indicated. Previously submitted information is shown in normal font. Additions due to this submittal are highlighted with balded italics for inserted text, and strikothro1::1ghs for deleted text.

January 23, 2019 Enclosure B Page 2 of 7 SLRA Appendix A, Section A.5, Second License Renewal Commitment List, Commitment 10, Bolting Integrity, beginning on page A-91, is revised as shown below.

NO. PROGRAM COMMITMENT IMPLEMENTATION SOURCE OR TOPIC SCHEDULE*

10 Bolting Integrity Bolting Integrity is an existing program that will be enhanced to: Program will be Section A.2.1.10 enhanced no later than six months prior to the second period of

8. Revise engineering procedures to require volumetric examination in extended operation Exelon Letter accordance with ASME Code Section XI, Table IWB-2500-1, PBAPSSLRA Examination Category B-G-1, regardless of the code classification of Supplement the bolting, should high strength bolting greater than 2 inches in No. 2, dated diameter be installed. January23,

9. Clarify that the recommended guidance for proper selection of 2019 bolting material and lubricants, and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting is a requirement at Peach Bottom in accordance with the guidelines provided in EPRI NP-5067 and TR-104213. Clarify that the recommended requirements for storage, lubricant selection, and bolting and coating material selection to include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication "Specification for Structural Joints Using High Strength Bolts," are a requirement at Peach Bottom.

January 23, 2019 Enclosure B Page 3 of 7 SLRA Appendix A, Section A.5, Second License Renewal Commitment List, Commitment 17, Fire Water System, Item #6, beginning on page A-95 is revised as shown below:

PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

17 Fire Water System 6. Perform internal visual inspections of sprinkler and deluge system piping to Program will be Section A.2.1.17 identify internal corrosion, foreign material, and obstructions to flow. enhanced no later than Follow-up volumetric wall thickness examinations will be performed if six months prior to the internal visual inspections detect age Felaled degFadaUeA an unexpected second period of level of degradation due to corrosion and corrosion product extended operation.

deposition.iA 9*6966 ef wl=lal we1;1ld ee e*pesled asse1;1AUA9 feF de6igA, Inspections that are to be Exelon Letter prnvie1;16 iR6pesUeA B*PBFieAse, aAd iA6pesUeA iAlePt.<al. If organic or completed prior to the PBAPSSLRA foreign material, or internal flow blockage that could result in failure of second period of Supplement system function is identified, then an obstruction investigation will be extended operation will No. 2, dated performed within the corrective action program that includes removal of be completed no later January23, the material, an extent of condition determination, review for increased than six months prior to 2019 inspections, extent of follow-up examinations, and a flush in accordance the second period of with NFPA 25 Appendix D.5, Flushing Procedures. The internal visual extended operation, or inspections will consist of the following: no later than the last

a. Wet pipe sprinkler systems - 50 percent of the wet pipe sprinkler refueling outage prior to systems in scope for license renewal will have visual internal the second period of inspections of piping by removing a hydraulically remote sprinkler, extended operation.

performed every five years, consistent with NFPA 25, 2011 Edition, Section 14.2. During the next five-year inspection period, the alternate systems previously not inspected shall be inspected.

b. Pre-action sprinkler systems - pre-action sprinkler systems in scope for license renewal will have visual internal inspections of piping by removing a hydraulically remote nozzle, performed every five years, consistent with NFPA 25, 2011 Edition, Section 14.2.

c. Deluge systems - Yard transformer deluge systems in scope for license renewal will have visual internal inspections of piping by removing a hydraulically remote nozzle, performed every five years, consistent with NFPA 25, 2011 Edition, Section 14.2.

January 23, 2019 Enclosure B Page 4 of 7 SLRA Appendix A, Section A.5, Second License Renewal Commitment List, Commitment 30 on page A-106 is revised to include added commitments as shown below.

PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

30 ASME Section XI, ASME Section XI, Subsection IWE is an existing program that will be enhanced to: Program will be Section A.2.1.30 Subsection IWE 1. Perform surface examinations on accessible portions of high temperature enhanced no later than drywall mechanical penetrations, in addition to visual examinations, to six months prior to the detect cracking, once per 10-year interval during the second period of second period of extended operation. extended operation.

Exelon Letter

2. Clarify that the recommended guidance for proper selection of bolting material and lubricants, and appropriate installation torque PBAPSSLRA or tension to prevent or minimize loss of bolting preload and Supplement cracking of high-strength bolting is a requirement at Peach Bottom No. 2, dated in accordance with the guidelines provided in EPRI NP-5067 and January23, TR-104213. Clarify that the recommended requirements for 2019 storage, lubricant selection, and bolting and coating material selection include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication "Specification for Structural Joints Using High-Strength Bolts," are a requirement at Peach Bottom.

3. Implement a one-time supplemental volumetric examination of the containment metal shell surfaces that are inaccessible from one side, if triggered by plant-specific OE. The trigger for this supplemental examination is plant-specific occurrence or recurrence of measurable metal shell corrosion (base metal material loss exceeding 10 percent of nominal plate thickness) initiated on the inaccessible side or areas, identified since the date of issuance of the first renewed license. This supplemental volumetric examination consists of a sample of one-foot square locations that include both randomly-selected and focused areas most likely to experience degradation based on plant-specific OE and/or other relevant considerations such as environment. The sample size, locations, and any needed scope expansion (based on findings) for this one-time set of volumetric examinations should be determined on a plant-specific basis to demonstrate statistically with 95 percent confidence that 95 percent of the accessible portion of the containment liner is not experiencing corrosion degradation with greater than 1O percent loss of nominal thickness.

January 23, 2019 Enclosure B Page 5 of 7 SLRA Appendix A, Section A.5, Second License Renewal Commitment List, Commitment 31 on page A-107 is revised to include added commitments as shown below.

PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

31 ASME Section XI, ASME Section XI, Subsection IWF is an existing program that will be enhanced to: Program will be Section A.2.1.31 Subsection IWF 1. Perform periodic evaluations of the acceptability of inaccessible areas of enhanced in accordance supports (e.g., portions of supports encased in concrete, buried with the schedule underground, or encapsulated by guard pipe), when conditions exist in described within the accessible areas that could indicate the presence of, or result in, enhancements.

degradation to inaccessible areas of supports. Perform these Inspections that are evaluations once every 1O years during the second period of extended required to be performed operation. in the five-year period prior to the second

2. Perform a one-time inspection of an additional five percent of the period of extended currently inspected sample size specified in Table IWF-2500-1 for Class operation will be 1, 2, and 3 piping supports. Conduct the one-time inspection within the completed no later than five years prior to entering the second period of extended operation.

six months prior to the Select the additional supports from the remaining population of IWF second period of piping supports. Ensure that the sample expansion includes extended operation, or components that are most susceptible to age-related degradation (i.e.,

no later than the last based on factors such as time in service, material, and aggressiveness refueling outage prior to of the environment).

the second period of

3. Perform VT-3 examinations of all ASTM A-490 bolting materials, used extended operation.

for the reactor vessel support skirts and for the core spray pump supports once per 10-year interval during the second period of extended operation. Perform volumetric examination comparable to that of ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1, of 12 ASTM A490 bolts at each of the reactor vessel support skirts, once per 10-year interval during the second period of extended operation.

Exelon Letter

4. Clarify that the recommended guidance for proper selection of bolting material and lubricants, and appropriate installation torque PBAPSSLRA or tension to prevent or minimize loss of bolting preload and Supplement cracking of high-strength bolting is a requirement at Peach Bottom No. 2, dated in accordance with the guidelines provided in EPRI NP-5067 and January23, TR-104213. Clarify that the recommended requirements for 2019 storage, lubricant selection, and bolting and coating material selection include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication "Specification for Structural Joints Using High-Strength Bolts," are a requirement at Peach Bottom.

January 23, 2019 Enclosure B Page 6 of 7 SLRA Appendix A, Section A.5, Second License Renewal Commitment List, Commitment 34 on page A-110 is revised to include added commitments as shown below.

PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

34 Structures Monitoring 10. Expand the program to monitor elastomeric vibration isolators and Program will be Section A.2.1.34 bearing pads for cracking, loss of material, and hardening. Supplement enhanced no later than visual inspection of elastomeric elements with tactile inspection to detect six months prior to the hardening, if the intended function is suspect. Establish acceptance second period of criteria for elastomeric pads and vibration isolation elements as no loss extended operation.

of material, cracking, or hardening that can lead to loss of isolation or Baseline inspections will support function. be completed no later

11. Clarify that loose bolts and nuts and cracked bolts are not acceptable than six months prior to unless accepted by engineering evaluations. the second period of extended operation, or

12. Expand the program to inspect the fiberglass outer covering of no later than the last permanent shielding blankets for signs of tears. If a tear is found, enter refueling outage prior to the condition into the corrective action program for evaluation. Repair or the second period of replace the permanent shielding, unless an evaluation determines that extended operation.

the condition is acceptable.

Exelon Letter

13. Clarify that the recommended guidance for proper selection of bolting material and lubricants, and appropriate installation torque PBAPSSLRA or tension to prevent or minimize loss of bolting preload and Supplement cracking of high-strength bolting is a requirement at Peach Bottom No. 2, dated in accordance with the guidelines provided in EPRI NP-5067 and January23, TR-104213. Clarify that the recommended requirements for 2019 storage, lubricant selection, and bolting and coating material selection include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication "Specification for Structural Joints Using High-Strength Bolts," are a requirement at Peach Bottom.

January 23, 2019 Enclosure B Page 7 of 7 SLRA Appendix A, Section A.5, Second License Renewal Commitment List, Commitment 35 on page A-111 is revised to include added commitments as shown below.

PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

35 Inspection of 8. Evaluate the acceptability of inaccessible areas when conditions exist in Program will be Section A.2.1 .35 Water-Control accessible areas that could indicate the presence of, or result in, enhanced no later than Structures Associated degradation to such inaccessible areas. six months prior to the with Nuclear Power 9. Document the concrete conditions of submerged concrete structures. second period of Plants extended operation.

10. Specify a six-year frequency for the inspection of the submerged Baseline inspections will portions of the traveling screen bays to match the inspection frequency be completed no later of the submerged portions of the Circulating Water Pump Structure than six months prior to bays. the second period of

11. Perform inspections under the enhanced program in order to establish extended operation, or quantitative baseline inspection data prior to the second period of no later than the last extended operation. refueling outage prior to

12. Provide evaluation criteria for structural concrete using quantitative the second period of second tier criteria of Chapter 5 in ACI 349.3R. extended operation.

13. Clarify that loose bolts and nuts and cracked bolts are not acceptable unless accepted by engineering evaluations.

14. Clarify that the recommended guidance for proper selection of Exelon Letter bolting material and lubricants, and appropriate installation torque PBAPSSLRA or tension to prevent or minimize loss of bolting preload and Supplement cracking of high-strength bolting is a requirement at Peach Bottom No.2, dated in accordance with the guidelines provided in EPRI NP-5067 and January23, TR-104213. Clarify that the recommended requirements for 2019 storage, lubricant selection, and bolting and coating material selection include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication "Specification for Structural Joints Using High-Strength Bolts," are a requirement at Peach Bottom.

• The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 Peach Bottom Atomic Power Station Unit 3: July 2, 2034