ML20181A381

SLR-ISG-2021-03-Structures - Updated Aging Management Criteria for Structures Portions of Subsequent License Renewal Guidance

ML20181A381
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Issue date:	02/18/2021
From:	David Drucker, Jeffrey Mitchell NRC/NRR/DNRL/NLRP
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Mitchell J
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ML20343A164	List: ML20181A381 ML20181A395
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SLR-ISG-2021-03
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SLR-ISG-2021-03-STRUCTURES Updated Aging Management Criteria for Structures Portions of Subsequent License Renewal Guidance Interim Staff Guidance February 2021

ML20181A381 CAC: TM3021 OFFICE PM:DNRL:NLRP LA:DRO:IRSB PM:DRO:IRSB QTE NAME JMitchell BCurran TGovan JDoughery DATE 09/4/2020 09/18/2020 09/18/2020 09/17/2020 OFFICE STA:DNLR BC:DNRL:NLRP OGC D:NRR:DEX NAME AHiser OTabatabai STurk JMarshall DATE 09/21/2020 09/15/2020 11/10/2020 12/4/2020 OFFICE D:NRR:DSS D:NRR:DRO D:DNRL NAME JDonoghue GSuber for CMiller ABradford DATE 11/25/2020 01/28/2021 02/16/2021 INTERIM STAFF GUIDANCE UPDATED AGING MANAGEMENT CRITERIA FOR STRUCTURES PORTIONS OF SUBSEQUENT LICENSE RENEWAL GUIDANCE SLR-ISG-2021-03-STRUCTURES PURPOSE The U.S. Nuclear Regulatory Commission (NRC) staff is providing this subsequent license renewal (SLR) interim staff guidance (ISG) to clarify existing guidance to facilitate staff and industry understanding of the aging management of systems, structures, and components required in Title 10 of the Code of Federal Regulations (10 CFR) Part 54, Requirements for renewal of operating licenses for nuclear power plants.

This SLR-ISG identifies revisions to the structures portions of NUREG-2191, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, issued July 2017, and NUREG-2192, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants, issued July 2017 (SRP-SLR).

BACKGROUND The NRC staff has reviewed three applications to extend plant operations to 80 years (i.e., for SLR) for Turkey Point Nuclear Generating Units 3 and 4 (Turkey Point); Peach Bottom Atomic Power Station, Units 2 and 3 (Peach Bottom); and Surry Power Station, Units 1 and 2 (Surry).

During these reviews, the staff and applicants have identified ways to prepare and review future SLR applications more effectively and efficiently.

RATIONALE The NRC held public meetings on March 28, 2019; December 12, 2019; February 20, 2020; March 25, 2020; April 3, 2020; and April 7, 2020, with industry representatives to discuss staff and industry experience in the preparation and review of the initial license renewal application for River Bend Station, Unit 1, which piloted the optimized 18-month review process for SLR applications, as well as the reviews of the first three SLR applications from Turkey Point, Peach Bottom, and Surry.

This SLR-ISG includes revisions to the following GALL SLR Report and SRP-SLR sections:

• SRP-SLR Section 3.5.2.2.1.5, Cumulative Fatigue Damage, SRP-SLR Section 3.5.3.2.1.5, Cumulative Fatigue Damage, SRP-SLR Section 3.5.6, References, GALL-SLR Report Chapter II, and aging management review (AMR) items associated with cracking due to cyclic loading in SRP-SLR Table 3.5-1, Summary of Aging Management Programs for Containments, Structures and Component Supports Evaluated in Chapters II and III of the GALL-SLR Report

• GALL-SLR Report Aging Management Program (AMP) XI.S8, Protective Coating Monitoring and Maintenance

SLR-ISG-2021-03-STRUCTURES Page 2 of 4

• GALL-SLR Report Chapter II to Allow Plant-Specific Aging Management Options

• GALL-SLR Report Chapter III to Allow Plant-Specific Aging Management Options

• SRP-SLR Section 3.5 and Table 3.5-1 to Allow Plant-Specific Aging Management Options and Provide Option to Perform Further Evaluation Related to Fatigue Waiver Analyses APPLICABILITY All holders of operating licenses for nuclear power reactors, under 10 CFR Part 50, Domestic licensing of production and utilization facilities, except those that have permanently ceased operations and have certified that fuel has been permanently removed from the reactor vessel.

GUIDANCE In 10 CFR Part 54, the NRC provides requirements for the submission and review of applications to extend plant operations beyond the initial 40-year operating period.

The GALL-SLR Report and SRP-SLR provide guidance to licensees that wish to extend their plant operating licenses from 60 years to 80 years, and to the NRC staff who will review the SLR applications.

The staff and nuclear industry have identified several areas for which future SLR applications and staff reviews can be completed more effectively and efficiently. A series of SLR-ISGs will capture these areas, known as lessons learned.

The NRC staff considers the information in this ISG to provide an acceptable approach for managing aging in structures and structural components within the scope of 10 CFR Part 54. It will improve the quality, uniformity, effectiveness, and efficiency of NRC staff reviews of future SLR applications.

IMPLEMENTATION The staff will use the information discussed in this ISG to determine whether, pursuant to 10 CFR 54.21(a)(3), a license renewal application demonstrates that the effects of aging on structures and components subject to an AMR are adequately managed so that their intended functions will be maintained consistent with the current licensing basis for the subsequent period of extended operation. This ISG contains an update in redline/strikeout of the existing guidance identified in the Rationale section above. An applicant may reference this ISG in an SLR application to demonstrate that the AMPs at the applicants facility correspond to those described in the GALL-SLR. If an applicant credits an AMP as updated by this ISG, it is incumbent upon the applicant to ensure that the conditions and operating experience at the plant are bounded by the conditions and operating experience for which this ISG was evaluated.

If these bounding conditions are not met, it is incumbent upon the applicant to address any additional aging effects and augment its AMPs. For AMPs that are based on this ISG, the NRC staff will review and verify whether the applicants AMPs are consistent with those described in this ISG, including applicable plant conditions and operating experience.

SLR-ISG-2021-03-STRUCTURES Page 3 of 4 BACKFITTING AND ISSUE FINALITY DISCUSSION Issuance of this ISG does not constitute a backfit as defined in 10 CFR 50.109(a)(1) and is not otherwise inconsistent with the issue finality provisions in 10 CFR Part 52, Licenses, certifications, and approvals for nuclear power plants. Thus, the NRC staff did not prepare a backfit analysis for the issuance of this ISG.

The NRC staffs position is based upon the following considerations:

• The ISG positions do not constitute backfitting, inasmuch as the ISG is guidance directed to the NRC staff with respect to its regulatory responsibilities. The ISG provides interim guidance to the staff on how to review certain requests. Changes in guidance intended for use by only the staff are not matters that constitute backfitting as that term is defined in 10 CFR 50.109, Backfitting, or that involve the issue finality provisions of 10 CFR Part 52.

• Backfitting and issue finalitywith certain exceptions discussed in this sectiondo not apply to current or future applicants. Applicants and potential applicants are not, with certain exceptions, the subject of either the Backfit Rule or any issue finality provisions under 10 CFR Part 52. This is because neither the Backfit Rule nor the issue finality provisions of 10 CFR Part 52 were intended to apply to every NRC action that substantially changes the expectations of current and future applicants. The exceptions to the general principle are applicable whenever a 10 CFR Part 50 operating license applicant references a construction permit or a 10 CFR Part 52 combined license applicant references a license (e.g., an early site permit) or an NRC regulatory approval (e.g., a design certification rule) (or both) for which specified issue finality provisions apply. The NRC staff does not currently intend to impose the positions represented in this ISG in a manner that constitutes backfitting or is inconsistent with any issue finality provision of 10 CFR Part 52. If in the future the NRC staff seeks to impose positions stated in this ISG in a manner that would constitute backfitting or be inconsistent with these issue finality provisions, the NRC staff must make the requisite showing as set forth in the Backfit Rule or address the regulatory criteria set forth in the applicable issue finality provision, as applicable, that would allow the staff to impose the position.

• The NRC staff has no intention to impose the ISG positions on existing nuclear power plant licensees either now or in the future (absent a voluntary request for a change from the licensee). The staff does not intend to impose or apply the positions described in the ISG to existing (i.e., already issued) licenses (e.g., operating licenses and combined licenses). Hence, the issuance of this ISGeven if considered guidance subject to the Backfit Rule or the issue finality provisions in 10 CFR Part 52 would not need to be evaluated as if it were a backfit or as being inconsistent with issue finality provisions. If, in the future, the NRC staff seeks to impose a position in the ISG on holders of already issued licenses in a manner that would constitute backfitting or does not provide issue finality as described in the applicable issue finality provision, then the staff must make a showing as set forth in the Backfit Rule or address the criteria set forth in the applicable issue finality provision that would allow the staff to impose the position.

SLR-ISG-2021-03-STRUCTURES Page 4 of 4 CONGRESSIONAL REVIEW ACT This ISG is a rule as defined in the Congressional Review Act (5 U.S.C. 801-808). However, the Office of Management and Budget has not found it to be a major rule as defined in the Congressional Review Act.

FINAL RESOLUTION By July 1, 2027, the staff will transition this information into GALL-SLR and SRP-SLR.

Following the transition of this guidance to GALL-SLR and SRP-SLR, this ISG will be closed.

APPENDICES A. Revisions to SRP-SLR Section 3.5 and GALL-SRP Report Chapter II to Provide Option to Perform Further Evaluation Based on Fatigue Waiver Analyses to Address AMR of Cracking due to Cyclic Loading B. Revisions to GALL-SLR Report AMP XI.S8, Protective Coating Monitoring and Maintenance C. Revisions to GALL-SRP Report Chapter II to Allow Plant-Specific Aging Management Options D. Revisions to GALL-SLR Report Chapter III to Allow Plant-Specific Aging Management Options E. Revisions to SRP-SLR Section 3.5 to Allow Plant-Specific Aging Management Options and Provide Option to Perform Further Evaluation Related to Fatigue Waiver Analyses F. Disposition of Public Comments

APPENDIX A REVISIONS TO SRP-SLR SECTION 3.5 AND GALL-SLR REPORT CHAPTER II TO PROVIDE OPTION TO PERFORM FURTHER EVALUATION BASED ON FATIGUE WAIVER ANALYSES TO ADDRESS AMR OF CRACKING DUE TO CYCLIC LOADING Summary of Revisions This appendix modifies NUREG-2192, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants, issued July 2017 (SRP-SLR), further evaluation Section 3.5.2.2.1.5, Cumulative Fatigue Damage, and Section 3.5.3.2.1.5, Cumulative Fatigue Damage; SRP-SLR Table 3.5-1, Summary of Aging Management Programs for Containments, Structures and Component Supports Evaluated in Chapters II and III of the GALL-SLR Report, Items 027 and 040 (revisions are provided in Appendix E below);

and corresponding aging management review (AMR) items evaluated in Chapter II of NUREG-2191, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR)

Report, (revisions are provided in Appendix C below). The changes provide the option to perform a further evaluation based on the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section III, Division 1, Subsection NE, fatigue waiver analysis for containment metallic pressure-retaining boundary components that are subject to cyclic loading but have no current licensing basis (CLB) fatigue analysis.

Basis for Revisions ASME Code,Section III, Division 1, includes provisions to analytically address cumulative fatigue damage (cracking due to cyclic loading) through detailed fatigue analysis or fatigue waiver analysis. If the code criteria for a fatigue waiver are satisfied, then a detailed fatigue analysis is not required. SRP-SLR Section 4.6.1, Areas of Review, states that ASME Code fatigue analyses and fatigue waiver analyses that are in the CLB may be time-limited aging analyses (TLAAs).

The fatigue waiver analysis described in this change is a TLAA, except that it will not be in the CLB at the time of a subsequent license renewal application (SLRA) submittal. It therefore does not meet the sixth criterion of Title 10 of the Code of Federal Regulations (10 CFR) 54.3, Definitions, for TLAA, which states that the analysis [is] contained or incorporated by reference in the CLB. Nevertheless, as indicated above, performing a fatigue waiver analysis in accordance with the ASME Code is a technically acceptable approach to analytically address the effects of cyclic loading (fatigue aging effects) for containment metallic pressure-retaining boundary components. Therefore, satisfying the six conditions for fatigue waiver analysis in the ASME Code for applicable component materials provides an acceptable technical basis to demonstrate that a detailed fatigue analysis is not required, and cracking due to cyclic loading is not an aging effect requiring management.

Therefore, the revised further evaluation section and modified AMR line items in this change provide one acceptable approach to address the aging effect of cracking due to cyclic loading for specific containment metallic pressure-retaining boundary components in lieu of supplemental surface examinations or performing or crediting an appropriate leak-rate test pursuant to Appendix J, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors, to 10 CFR Part 50, Domestic licensing of production and utilization facilities, as discussed in GALL-SLR Report Aging Management Program (AMP) XI.S1, ASME

SLR-ISG-2021-03-STRUCTURES: Appendix A Page 2 of 5 Section XI, Subsection IWE, for which no CLB fatigue analysis exists at the time of SLRA submittal.

AMP Revisions None Revisions to FSAR Supplement None Revisions to SRP-SLR Section 3.5 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.

For the above-stated containment pressure-retaining components (corresponding to Table 3.5-1, Items 027 and 040) subject to cyclic loading for which no CLB fatigue analysis exists at the time of an SLRA submittal, a plant-specific further evaluation may be performed to demonstrate that cracking due to cyclic loading is an aging effect that does not require aging management for the component. As one acceptable approach, the aging effect does not require aging management actions if the further evaluation demonstrates that the six criteria for cyclic loading in paragraph NE-3222.4(d) (NE-3221.5(d) in 1980 and later code editions), Analysis for Cyclic Operation, Vessels Not Requiring Analysis for Cyclic Service, of ASME Code,Section III, Division 1 (1974 edition or later edition incorporated by reference in 10 CFR 50.55a(a)(i)), that provide for a waiver from detailed fatigue analysis are satisfied for applicable component materials through the end of the subsequent period of extended operation. The option to perform a fatigue waiver analysis to address the aging effect of cracking due to cyclic loading, for specific containment metallic components, is in lieu of performing supplemental surface examinations or performing or crediting an appropriate 10 CFR Part 50, Appendix J, leak-rate test discussed in GALL-SLR Report AMP XI.S1, ASME Section XI, Subsection IWE.

3.5.3.2.1.5 Cumulative Fatigue Damage Evaluations involving time-dependent fatigue, cyclical loading, or cyclical displacement included in the CLB for the metal liner, 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) for all types of PWR and BWR containments and BWR vent header, vent line bellows, and downcomers are

SLR-ISG-2021-03-STRUCTURES: Appendix A Page 3 of 5 TLAAs as defined in 10 CFR 54.3. TLAAs are required to be evaluated in accordance with 10 CFR 54.21(c). The evaluation of this TLAA is addressed in Section 4.6, Containment Liner Plate, 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.

The staff reviews the information on a case-by-case basis consistent with the review procedures in SRP-SLR Sections 4.6 or 4.7 (as applicable) to determine whether the applicant has provided a sufficient basis for dispositioning the TLAAs in accordance with the acceptance criteria in 10 CFR 54.21(c)(1)(i), (ii), or (iii). This includes staffs review of those cumulative usage factor analyses that qualify as TLAAs based on plant-specific calculation methods.

For specific containment metallic components (corresponding to Table 3.5-1, Items 027 and 040) for which no CLB fatigue analysis exists at the time of SLRA submittal, the applicant may perform a fatigue waiver analysis in accordance with the ASME Code to demonstrate that the fatigue aging effect does not require aging management. The reviewer verifies that the number of cycles for applicable cyclic loads has been adequately accounted for, the appropriate environment and material property inputs are used, and the acceptance criteria in paragraph NE-3222.4(d) (NE-3221.5(d) in 1980 and later code editions) of ASME Code,Section III, Division 1 (1974 edition or later edition incorporated by reference in 10 CFR 50.55a(a)(i)), that provide for a waiver of detailed fatigue analysis are satisfied through the end of the subsequent period of extended operation. The staff reviews any other justification provided on a case-by-case basis.

Revisions to SRP-SLR Section 3.5.6, References

1. 10 CFR Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants. Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

2. 10 CFR 50.55a, Codes and Standards. Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

3. 10 CFR 50.59, Changes, Tests, and Experiments. Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

4. 10 CFR Part 50, Appendix J, Primary Reactor Containment Leakage Testing for Water Cooled Power Reactors. Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

5. 10 CFR 50.71, Maintenance of Record, Making of Reports. Washington, DC: U.S.

Nuclear Regulatory Commission. 2016.

6. 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. Washington, DC: U.S. Nuclear Regulatory Commission.

2016.

7. 10 CFR 54.4, Scope. Washington, DC: U.S. Nuclear Regulatory Commission.

2016.

SLR-ISG-2021-03-STRUCTURES: Appendix A Page 4 of 5

8. NRC. Regulatory Guide 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants. Revision 1. Agencywide Documents Access and Management System (ADAMS) Accession No. ML003739392. Washington, DC:

U.S. Nuclear Regulatory Commission. March 1978.

9. NEI. NEI 95-10, Industry Guideline for Implementing the Requirements of 10 CFR Part 54-The License Renewal Rule. Revision 6. ADAMS Accession No. ML051860406. Washington, DC: Nuclear Energy Institute. June 2005.

10. ASME. ASME Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, Subsection IWL, Requirements for Class CC Concrete Components of Light-Water Cooled Power Plants. New York, New York: The American Society of Mechanical Engineers. 2008.

11. ______ASME. ASME Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, Subsection IWE, Requirements for Class MC and Metallic Liners of Class CC Components of Light-Water Cooled Power Plants. New York, New York: The American Society of Mechanical Engineers. 2008.

12. ______ASME. ASME Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, Subsection IWF, Requirements for Class 1, 2, 3, and MC Component Supports of Light-Water Cooled Power Plants. New York, New York: The American Society of Mechanical Engineers. 2008.

13. NEI. NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. Revision 2. ADAMS Accession No. ML11116A198. Washington, DC: Nuclear Energy Institute. April 1996.

14. NRC. Regulatory Guide 1.160, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. Revision 2. Agencywide Documents Access and Management System (ADAMS) Accession No. ML003761662. Washington, DC:

U.S. Nuclear Regulatory Commission. March 31, 1997.

15. ______NRC. NUREG-1557, Summary of Technical Information and Agreements from Nuclear Management and Resources Council Industry Report addressing License Renewal. Washington, DC: U.S. Nuclear Regulatory Commission.

October 1996.

16. ACI. ACI Standard 318, Building Code Requirements for Reinforced Concrete and Commentary. Farmington Hills, Michigan: American Concrete Institute. 1995.

17. Hilsdorf, H.K., J. Kropp, and H.J. Koch. The Effects of Nuclear Radiation on the Mechanical Properties of Concrete. ACI SP 55-10. pp 223-251. Farmington Hills, Michigan: American Concrete Institute. 1978.

18. NRC. NUREG/CR-7171, A Review of the Effects of Radiation on Microstructure and Properties of Concretes Used in Nuclear Power Plants. ADAMS Accession No. ML13325B077. Washington, DC: U.S. Nuclear Regulatory Commission.

November 2013.

SLR-ISG-2021-03-STRUCTURES: Appendix A Page 5 of 5

19. Field, K.G., Y. Le Pape, and I. Remec. Perspectives on Radiation Effects in Concrete for Nuclear Power Plants-Part I: Quantification of Radiation Exposure and Radiation Effects. Nuclear Engineering and Design. Vol 285. pp 126-143.

February 2015.

20. ACI. ACI Standard 349 85, Code Requirements for Nuclear Safety-Related Concrete Structures. Farmington Hills, Michigan: American Concrete Institute.

1985.

21. ASME. ASME Code,Section III, Rules for Construction of Nuclear Facility Components, Division 1 - Subsection NE, Class MC Components. New York, New York: The American Society of Mechanical Engineers. 1974 edition or later edition incorporated by reference in 10 CFR 50.55a(a)(i) as applicable Revisions to GALL-SLR Report Chapter II See Appendix C to this ISG. Revisions in this appendix only impact Item numbers II.A3.CP-37, II.B1.1.CP-49, II.B2.1.CP-107, II.B2.1.CP-142, II.B2.2.CP-64, and II.B4.CP-37.

Revisions to SRP-SLR Table 3.5-1 See Appendix E to this ISG. Revisions in this appendix only impact Item numbers 027 and 040 in SRP-SLR Table 3.5-1.

APPENDIX B REVISIONS TO GALL-SLR REPORT AMP XI.S8, PROTECTIVE COATING MONITORING AND MAINTENANCE Summary of Revisions This appendix:

(1) Revises the frequency of inservice coating inspection monitoring to allow the inspection of coatings meeting NUREG-2191, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, Aging Management Program (AMP) XI.S8 Element 6, Acceptance Criteria, to be performed on a frequency not to exceed 6 years, based on trending of the total amount of permitted degraded coatings.

(2) Updates GALL-SLR Report AMP XI.S8 to reference Regulatory Guide (RG) 1.54, Service Level I, II, III, and In-Scope License Renewal Protective Coatings Applied to Nuclear Power Plants, Revision 3, issued April 2017, as it is the most current revision at the time of this change.

(3) Revises AMP XI.S8 Element 5, Monitoring and Trending, to provide detail on extended inspection intervals.

(4) Revises AMP XI.S8 Element 10, Operating Experience, to provide detail on extended inspection intervals-, and reference Revision 3 of RG 1.54.

Basis for Revisions The revisions are based on the following items:

(1) ASTM International (formerly American Society for Testing and Materials)

Specification D5163-08, Standard Guide for Establishing a Program for Condition Assessment of Coating Service Level I Coating Systems in Nuclear Power Plants. West Conshohocken, Pennsylvania. ASTM International, 2008, paragraph 6, notes that the licensee shall determine the frequency of inservice coating inspections. ASTM D5163-08, paragraph 6, also notes that it is a good practice to perform inspections during each refueling outage. An interval not to exceed 6 years based on station operating experience may be justified if coatings meet the acceptance criteria (AMP XI.S8 Element 6) and trending activities for the total amount of degraded coatings in containment indicate a margin will be maintained (AMP XI.S8 Element 5). A qualified nuclear coating specialist performs a coating condition assessment report to determine the priority of repairs to be conducted during the current outage and repairs that can be postponed to a future date (ASTM D5163-08, paragraph 11.1.2). Trending of the total amount of degraded coatings allowed in containment is also performed.

(2) RG 1.54, Revision 3, contains the most up-to-date NRC guidance on the selection, application, qualification, inspection, and maintenance of protective coatings applicable under GALL-SLR Report AMP XI.S8.

(3) For an applicant to extend the inspection interval stated in the GALL-SLR Report (each refueling outage), an applicant must demonstrate that margin to the ECCS suction strainer operability limits for coating debris will be maintained during the subsequent

SLR-ISG-2021-03-STRUCTURES: Appendix B Page 2 of 6 period of extended operation based on operating experience and trending of degraded/unqualified coatings.

If plant-specific operating experience identifies coating degradation mechanisms that indicate the potential to exceed the ECCS suction strainer debris margin, an applicant may not be able to extend the inspection intervals beyond each refueling outage.

Applicants that extend the inspection interval to longer than each refueling outage may need to provide trending of degraded and unqualified coatings and review operating experience for more than the previous two coating monitoring reports. This is because an extension of the inspection interval may result in periods of time without inspections that are longer than the time period covered by the previous two refueling outages.

Additionally, an applicant may need to consider covering a time period greater than the proposed interval to provide margin for trending of coatings and to account for variations in degraded coatings recorded during a typical inspection.

(4) RG 1.54, Revision 3, contains the most up-to-date NRC guidance on the selection, application, qualification, inspection, and maintenance of protective coatings applicable under GALL-SLR Report AMP XI.S8.

For an applicant to demonstrate that an inspection interval of longer than every refueling outage is appropriate, it is necessary to identify aging effects such as blistering, cracking, flaking, peeling, rusting, and physical damage and to demonstrate acceptable historical coating performance. This is because coating degradation mechanisms can cause large amounts of coatings to become degraded/unqualified in time periods of less than 6 years (the maximum interval). The applicant will need to account for aging effects such as blistering, cracking, flaking, peeling, rusting, and physical damage for the containment coatings to demonstrate that the coating will be able to perform its safety function during all inspection intervals through the subsequent period of extended operation.

AMP Revisions Program Description Proper maintenance of protective coatings inside containment (defined as Service Level I in the U.S. Nuclear Regulatory Commission (NRC) Regulatory Guide (RG) 1.54, Revision 1, or latest version) is essential to the operability of post-accident safety systems that rely on water recycled through the containment sump/drain system. Degradation of coatings can lead to clogging of Emergency Core Cooling System (ECCS) suction strainers, which reduces flow through the system and could cause unacceptable head loss for the pumps.

Maintenance of Service Level I coatings applied to carbon steel and concrete surfaces inside containment (e.g., steel liner, steel containment shell, structural steel, supports, penetrations, and concrete walls and floors) also serve to prevent or minimize loss of material due to corrosion of carbon steel components and aids in decontamination. Regulatory Position C4 in NRC RG 1.54, Revision 23, describes an acceptable technical basis for a Service Level I coatings monitoring and maintenance program that can be credited for managing the effects of corrosion for carbon steel elements inside containment. ASTM International (formerly American Society for Testing and Materials) standard (ASTM) D5163-08 and endorsed years of the standard in NRC RG 1.54 are acceptable and considered consistent with

SLR-ISG-2021-03-STRUCTURES: Appendix B Page 3 of 6 NUREG--2191the Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report. In addition, Electric Power Research Institute Report 1019157, Guideline on Nuclear Safety-Related Coatings, (December 2009) provides additional information on the ASTM standard guidelines.

A comparable program for monitoring and maintaining protective coatings inside containment, developed in accordance with NRC RG 1.54, Revision 23, is acceptable as an aging management program (AMP) for subsequent license renewal (SLR).

Service Level I coatings credited for preventing corrosion of steel containments and steel liners for concrete containments are subject to requirements specified by the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, Subsection IWE (GALL-SLR Report AMP XI.S1). However, this program (GALL-SLR Report AMP XI.S8) reviews Service Level I coatings to ensure that the protective coating monitoring and maintenance program is adequate for SLR.

Evaluation and Technical Basis

1. Scope of Program: The minimum scope of the program is Service Level I coatings applied to steel and concrete surfaces inside containment (e.g., steel liner, steel containment shell, structural steel, supports, penetrations, and concrete walls and floors), defined in NRC RG 1.54, Revision 23, as follows: Service Level I coatings are used in areas inside the reactor containment where the coating failure could adversely affect the operation of post-accident fluid systems and thereby impair safe shutdown.

The scope of the program also should include any Service Level I coatings that are credited by the licensee for preventing loss of material due to corrosion in accordance with GALL-SLR Report AMP XI.S1.

2. Preventive Action: The program is a condition monitoring program and does not recommend any preventive actions. However, for plants that credit coatings to minimize loss of material, this program is a preventive action.

3. Parameters Monitored or Inspected: ASTM D-5163-08 provides guidelines that are acceptable to the NRC staff for establishing an inservice coatings monitoring program for Service Level I coating systems in operating nuclear power plants, and identifies the parameters monitored or inspected to be any visible defects, such as blistering, cracking, flaking, peeling, rusting, and physical damage.

4. Detection of Aging Effects: ASTM D 5163-08, paragraph 6, defines the inspection frequency to be each refueling outage or during other major maintenance outages, as needed. General visual inspections, as per ASTM D5163-08, will be performed on an interval not to exceed six years. The inspection interval will be based on station operating experience and trending of the total amount of degraded and unqualified coatings allowed in containment that demonstrates acceptable coating performance with respect to the ECCS sump strainer debris limits. ASTM D5163-08, paragraph 9, discusses the qualifications for inspection personnel, the inspection coordinator, and the inspection results evaluator. ASTM D 5163-08, subparagraph 10.1, discusses development of the inspection plan and the inspection methods to be used. It states that a general visual inspection shall be conducted on all readily accessible coated surfaces during a walk-through. After a walk-through, or during the general visual inspection, thorough visual inspections shall be carried out on

SLR-ISG-2021-03-STRUCTURES: Appendix B Page 4 of 6 previously designated areas and on areas noted as deficient during the walk-through.

A thorough visual inspection shall also be carried out on all coatings near sumps or screens associated with the ECCS. This subparagraph also addresses field documentation of inspection results. ASTM D 5163-08, subparagraph 10.5, identifies instruments and equipment needed for inspection.

5. Monitoring and Trending: ASTM D 5163-08 identifies monitoring and trending activities in subparagraph 7.2, which specifies a pre-inspection review of the previous two monitoring reports, and in subparagraph 11.1.2, which specifies that the inspection report should prioritize repair areas as either needing repair during the same outage or as postponed to future outages, but under surveillance in the interim period. The assessment from periodic inspections and analysis of total amount of degraded coatings in the containment is compared with the total amount of permitted degraded coatings to provide reasonable assurance of post-accident operability of the ECCS.

An applicant that proposes to extend the inspection interval to greater than every refueling outage as discussed in Element 4, will need to provide information regarding the available margin for its ECCS suction strainers to accommodate coatings debris. The applicant will also demonstrate the ECCS suction strainer debris margin will be maintained for the length of the inspection intervals during the subsequent license renewal period given trending of degraded and unqualified coatings. Trending of degraded and unqualified coatings will be commensurate with the inspection interval (if greater than every refueling outage). This may result in trending of inspection reports from more than the two previous monitoring reports noted above.

6. Acceptance Criteria: ASTM D 5163-08, subparagraphs 10.2.1 through 10.2.6, 10.3, and 10.4, contains one acceptable method for the characterization, documentation, and testing of defective or deficient coating surfaces. Additional ASTM and other recognized test methods are available for use in characterizing the severity of observed defects and deficiencies. The evaluation covers blistering, cracking, flaking, peeling, delamination, and rusting. ASTM D 5163-08, paragraph 11, addresses evaluation. It specifies that the inspection report is to be evaluated by the responsible evaluation personnel, who prepare a summary of findings and recommendations for future surveillance or repair, and prioritization of repairs.

7. Corrective Actions: Results that do not meet the acceptance criteria are addressed in the applicants corrective action program under those specific portions of the quality assurance (QA) program that are used to meet Criterion XVI, Corrective Action, of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B.

Appendix A of the GALL-SLR Report describes how an applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the corrective actions element of this AMP for both safety-related and nonsafety-related structures and components (SCs) within the scope of this program.

A recommended corrective action plan is required for major defective areas so that these areas can be repaired during the same outage, if appropriate.

8. Confirmation Process: The confirmation process is addressed through those specific portions of the QA program that are used to meet Criterion XVI, Corrective Action, of 10 CFR Part 50, Appendix B. Appendix A of the GALL-SLR Report

SLR-ISG-2021-03-STRUCTURES: Appendix B Page 5 of 6 describes how an applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the confirmation process element of this AMP for both safety-related and nonsafety-related SCs within the scope of this program.

9. Administrative Controls: Administrative controls are addressed through the QA program that is used to meet the requirements of 10 CFR Part 50, Appendix B, associated with managing the effects of aging. Appendix A of the GALL-SLR Report describes how an applicant may apply its 10 CFR Part 50, Appendix B, QA program to fulfill the administrative controls element of this AMP for both safety-related and nonsafety-related SCs within the scope of this program.

10. Operating Experience: NRC Information Notice 88-82, NRC Bulletin 96-03, NRC Generic Letter (GL) 04-02, and NRC GL 98-04 describe industry experience pertaining to coatings degradation inside containment and the consequential clogging of sump strainers. NRC RG 1.54, Revision 13, was issued in July 2000 April 2017. Monitoring and maintenance of Service Level I coatings conducted in accordance with Regulatory Position C4 is expected to be an effective program for managing degradation of Service Level I coatings and, consequently, an effective means to manage loss of material due to corrosion of carbon steel structural elements inside containment.

The program is informed and enhanced when necessary through the systematic and ongoing review of both plant-specific and industry operating experience including research and development such that the effectiveness of the AMP is evaluated consistent with the discussion in Appendix B of the GALL-SLR Report.

References 10 CFR Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants. Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

ASTM. ASTM D5163-05, Guide for Establishing Procedures to Monitor the Performance of Coating Service Level I Coating Systems in an Operating Nuclear Power Plant.

West Conshohocken, Pennsylvania: American Society for Testing and Materials. 2005.

_____. ASTM D5163-08, Standard Guide for Establishing a Program for Condition Assessment of Coating Service Level I Coating Systems in Nuclear Power Plants.

West Conshohocken, Pennsylvania: American Society for Testing and Materials. 2008.

_____. ASTM D5163-96, Standard Guide for Establishing Procedures to Monitor the Performance of Safety Related Coatings in an Operating Nuclear Power Plant.

West Conshohocken, Pennsylvania: American Society for Testing and Materials. 1996.

EPRI. EPRI 1003102, Guideline on Nuclear Safety-Related Coatings. Revision 1.

(Formerly TR-109937). Palo Alto, California: Electric Power Research Institute.

November 2001.

_____. EPRI 1019157, Guideline on Nuclear Safety-Related Coatings. Revision 2.

(Formerly TR-109937and 1003102). Palo Alto, California: Electric Power Research Institute.

December 2009.

SLR-ISG-2021-03-STRUCTURES: Appendix B Page 6 of 6 NRC. Bulletin 96-03, Potential Plugging of Emergency Core Cooling Suction Strainers by Debris in Boiling-Water Reactors. Washington, DC: U.S. Nuclear Regulatory Commission.

May 1996.

_____. Generic Letter 04-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors. Washington, DC: U.S. Nuclear Regulatory Commission. September 2004.

_____. Generic Letter 98-04, Potential for Degradation of the Emergency Core Cooling System and the Containment Spray System After a Loss-Of-Coolant Accident Because of Construction and Protective Coating Deficiencies and Foreign Material in Containment.

Washington, DC: U.S. Nuclear Regulatory Commission. July 1998.

_____. Information Notice 88-82, Torus Shells with Corrosion and Degraded Coatings in BWR Containments. Washington, DC: U.S. Nuclear Regulatory Commission.

November 1988.

_____. Information Notice 97-13, Deficient Conditions Associated With Protective Coatings at Nuclear Power Plants. Washington, DC: U.S. Nuclear Regulatory Commission.

March 1997.

_____. Regulatory Guide 1.54, Quality Assurance Requirements for Protective Coatings Applied to Water-Cooled Nuclear Power Plants. Revision 0. Washington, DC: U.S. Nuclear Regulatory Commission. June 1973.

_____. Regulatory Guide 1.54, Service Level I, II, and III Protective Coatings Applied to Nuclear Power Plants. Revision 1. Washington, DC: U.S. Nuclear Regulatory Commission.

July 2000.

_____. Regulatory Guide 1.54, Service Level I, II, and III Protective Coatings Applied to Nuclear Power Plants. Revision 2. Washington, DC: U.S. Nuclear Regulatory Commission.

October 2010.

_____. Regulatory Guide 1.54, Service Level I, II, III, and In-Scope License Renewal Protective Coatings Applied to Nuclear Power Plants, Revision 3: Washington, DC:

U.S. Nuclear Regulatory Commission. April 2017. ADAMS Accession No. ML17031A288.

Revisions to FSAR Supplement None Revisions to AMR Items None

APPENDIX C REVISIONS TO GALL-SLR REPORT CHAPTER II TO ALLOW PLANT-SPECIFIC AGING MANAGEMENT OPTIONS Summary of Revisions This appendix modifies NUREG-2191, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, relevant aging management review (AMR) items to reflect the option of using, in lieu of recommended plant-specific aging management programs (AMPs), plant-specific enhancements to GALL-SLR Report AMPs (with modified inspection activities when required) essential to manage the effects of aging in concrete for the following:

• Reduction of strength and modulus of elasticity due to elevated temperature (greater than 66 degrees Celsius (150 degrees Fahrenheit) general; greater than 93 degrees Celsius (200 degrees Fahrenheit) local)

• loss of material (spalling, scaling) and cracking due to freeze-thaw

• cracking due to expansion from reaction with aggregates

• increase in porosity and permeability; loss of strength due to leaching of calcium hydroxide and carbonation As discussed in Appendix A to this ISG, modify SRP-SLR Table 3.5-1 and the GALL-SLR Report AMR tables to provide the option to perform a further evaluation based on American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section III, Division 1, Subsection NE, fatigue waiver analysis for containment metallic pressure-retaining boundary components that are subject to cyclic loading but have no current licensing basis (CLB) fatigue analysis.

Basis for Revisions Modifications to the GALL-SLR Report AMR items and SRP-SLR Table 3.5-1 line items (see Appendix E) with associated further evaluations provide the option to use plant-specific enhancements to GALL-SLR Report AMP XI.S2, ASME Section XI, Subsection IWL, and/or GALL-SLR Report AMP XI.S6, Structures Monitoring, in lieu of a plant-specific AMP. The option to use plant-specific enhancements increases the efficiency of subsequent license renewal application reviews by limiting the use of AMR Note E designations for plant-specific aging management activities when aging effects are managed through a plant-specific AMP.

Appendix A to this ISG provides the basis for revisions with regard to fatigue analysis.

AMP Revisions None Revisions to FSAR Supplement None

Revisions to AMR Items SLR-ISG-2021-03-STRUCTURES: Appendix C II CONTAINMENT STRUCTURES Table A1 Concrete Containments (Reinforced and Prestressed)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation II.A1.CP-87 3.5-1, 016 Concrete Concrete Air - indoor Increase in porosity AMP XI.S2, No (accessible areas): uncontrolled, air - and permeability; "ASME Section dome; wall; outdoor cracking; loss of XI, Subsection basemat; ring material (spalling, IWL" girders; buttresses scaling) due to aggressive chemical attack II.A1.CP-31 3.5-1, 018 Concrete Concrete Air - outdoor Loss of material AMP XI.S2, No (accessible areas): (spalling, scaling) "ASME Section dome; wall; and cracking due to XI, Subsection basemat; ring freeze-thaw IWL" girders; buttresses M II.A1.CP-33 3.5-1, 019 Concrete Concrete Any Cracking due to AMP XI.S2, No (accessible areas): expansion from "ASME Section dome; wall; reaction with XI, Subsection basemat; ring aggregates IWL" girders; buttresses II.A1.CP-32 3.5-1, 020 Concrete Concrete Water - flowing Increase in porosity AMP XI.S2, No (accessible areas): and permeability; "ASME Section dome; wall; loss of strength due XI, Subsection basemat; ring to leaching of IWL" girders; buttresses calcium hydroxide and carbonation M II.A1.CP-68 3.5-1, 021 Concrete Concrete Air - indoor Cracking; loss of AMP XI.S2, No (accessible areas): uncontrolled, air - bond; and loss of "ASME Section dome; wall; outdoor material (spalling, XI, Subsection basemat; ring scaling) due to IWL" girders; buttresses; corrosion of reinforcing steel embedded steel Page 2 of 34

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table A1 Concrete Containments (Reinforced and Prestressed)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation II.A1.CP-100 3.5-1, 024 Concrete Concrete Air - indoor Increase in porosity AMP XI.S2, No (inaccessible uncontrolled, air - and permeability; "ASME Section areas): dome; wall; outdoor, cracking; loss of XI, Subsection basemat; ring groundwater/soil material (spalling, IWL," and girders; buttresses scaling) due to supplemented, aggressive chemical as necessary, attack by AMP XI.S6, "Structures Monitoring" EM II.A1.CP-147 3.5-1, 011 Concrete Concrete Air - outdoor, Loss of material Plant-specific Yes (inaccessible groundwater/soil (spalling, scaling) aging areas): dome; wall; and cracking due to management basemat; ring freeze-thaw program to be girders; buttresses evaluated for plants in moderate to severe weathering conditions, or AMP XI.S2, ASME Section XI, Subsection IWL, and/or AMP XI.S6, Structures Monitoring, enhanced as necessary Page 3 of 34

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table A1 Concrete Containments (Reinforced and Prestressed)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M II.A1.CP-67 3.5-1, 012 Concrete Concrete Any Cracking due to Plant-specific Yes (inaccessible expansion from aging areas): dome; wall; reaction with management basemat; ring aggregates program, or girders; buttresses AMP XI.S2, ASME Section XI, Subsection IWL, and/or AMP XI.S6, Structures Monitoring, enhanced as necessary M II.A1.CP-102 3.5-1, 014 Concrete Concrete Water - flowing Increase in porosity Plant-specific Yes (inaccessible and permeability; aging areas): dome; wall; loss of strength due management basemat; ring to leaching of program, or girders; buttresses calcium hydroxide AMP XI.S2, and carbonation ASME Section XI, Subsection IWL, and/or AMP XI.S6, Structures Monitoring, enhanced as necessary M II.A1.CP-97 3.5-1, 023 Concrete Concrete Any Cracking; loss of AMP XI.S2, No (inaccessible bond; and loss of "ASME Section areas): dome; wall; material (spalling, XI, Subsection basemat; ring scaling) due to IWL," and Page 4 of 34 girders; buttresses; corrosion of supplemented, reinforcing steel embedded steel as necessary, by AMP XI.S6, "Structures Monitoring"

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table A1 Concrete Containments (Reinforced and Prestressed)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation EM II.A1.CP-34 3.5-1, 003 Concrete: dome; Concrete Air - indoor Reduction of strength Plant-specific Yes wall; basemat; ring uncontrolled, air - and modulus due to aging girders; buttresses outdoor elevated temperature management

(>150°F general; program to be

>200°F local) evaluated if temperature limits exceeded, or AMP XI.S2, ASME Section XI, Subsection IWL, and/or AMP XI.S6, Structures Monitoring, enhanced as necessary E II.A1.CP-101 3.5-1, 001 Concrete: dome; Concrete Soil Cracking and AMP XI.S2, Yes wall; basemat; ring distortion due to "ASME Section girders; buttresses increased stress XI, Subsection levels from IWL," and settlement supplemented, as necessary, by AMP XI.S6, "Structures Monitoring" E II.A1.C-07 3.5-1, 002 Concrete: Concrete; Water - flowing Reduction of AMP XI.S6, Yes foundation; porous foundation strength "Structures subfoundation concrete and cracking due to Monitoring" differential settlement and erosion of porous concrete Page 5 of 34 subfoundation

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table A1 Concrete Containments (Reinforced and Prestressed)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M II.A1.C-11 3.5-1, 008 Prestressing Steel Air - indoor Loss of prestress due TLAA, SRP- Yes system: tendons uncontrolled, air - to relaxation; SLR Section outdoor shrinkage; creep; 4.5, "Concrete elevated temperature Containment Tendon Prestress,"

and/or SRP-SLR Section 4.7, "Other Plant-Specific Time-Limited Aging Analyses" II.A1.C-10 3.5-1, 032 Prestressing Steel Air - indoor Loss of material due AMP XI.S2, No system: tendons; uncontrolled, air - to corrosion "ASME Section anchorage outdoor XI, Subsection components IWL" M II.A1.CP-35 3.5-1, 035 Steel elements Steel Air - indoor Loss of material due AMP XI.S1, Yes (accessible areas): uncontrolled to general, pitting, "ASME Section liner; liner anchors; crevice corrosion XI, Subsection integral IWE," and AMP attachments XI.S4, "10 CFR Part 50, Appendix J" E II.A1.CP-98 3.5-1, 005 Steel elements Steel Air - indoor Loss of material due AMP XI.S1, Yes (inaccessible uncontrolled to general, pitting, "ASME Section areas): liner; liner crevice corrosion XI, Subsection anchors; integral IWE," and AMP attachments XI.S4, "10 CFR Part 50, Appendix J" Page 6 of 34

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table A2 Steel Containments New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation II.A2.CP-51 3.5-1, 018 Concrete Concrete Air - outdoor Loss of material AMP XI.S2, No (accessible areas): (spalling, scaling) "ASME basemat and cracking due to Section XI, freeze-thaw Subsection IWL," or AMP XI.S6, "Structures Monitoring" M II.A2.CP-58 3.5-1, 019 Concrete Concrete Any Cracking due to AMP XI.S2, No (accessible areas): expansion from "ASME basemat reaction with Section XI, aggregates Subsection IWL," or AMP XI.S6, "Structures Monitoring" II.A2.CP-72 3.5-1, 016 Concrete Concrete Groundwater/soil Increase in porosity AMP XI.S2, No (accessible areas): and permeability; "ASME basemat cracking; loss of Section XI, material (spalling, Subsection scaling) due to IWL," or AMP aggressive chemical XI.S6, attack "Structures Monitoring" II.A2.CP-155 3.5-1, 020 Concrete Concrete Water - flowing Increase in porosity AMP XI.S2, No (accessible areas): and permeability; "ASME basemat loss of strength due Section XI, to leaching of Subsection calcium hydroxide IWL," or AMP and carbonation XI.S6, "Structures Monitoring" Page 7 of 34

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table A2 Steel Containments New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M II.A2.CP-74 3.5-1, 021 Concrete Concrete Air - indoor Cracking; loss of AMP XI.S2, No (accessible areas): uncontrolled, air - bond; and loss of "ASME basemat; outdoor material (spalling, Section XI, reinforcing steel scaling) due to Subsection corrosion of IWL," or AMP embedded steel XI.S6, "Structures Monitoring" EM II.A2.CP-70 3.5-1, 011 Concrete Concrete Air - outdoor, Loss of material Plant-specific Yes (inaccessible groundwater/soil (spalling, scaling) aging areas): basemat and cracking due to management freeze-thaw program to be evaluated for plants in moderate to severe weathering conditions, or AMP XI.S2, ASME Section XI, Subsection IWL, and/or AMP XI.S6, Structures Monitoring, enhanced as necessary Page 8 of 34

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table A2 Steel Containments New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M II.A2.CP-104 3.5-1, 012 Concrete Concrete Any Cracking due to Plant-specific Yes (inaccessible expansion from aging areas): basemat reaction with management aggregates program, or AMP XI.S2, ASME Section XI, Subsection IWL, and/or AMP XI.S6, Structures Monitoring, enhanced as necessary II.A2.CP-71 3.5-1, 024 Concrete Concrete Groundwater/soil Increase in porosity AMP XI.S2, No (inaccessible and permeability; "ASME areas): basemat cracking; loss of Section XI, material (spalling, Subsection scaling) due to IWL," or AMP aggressive chemical XI.S6, attack "Structures Monitoring" M II.A2.CP-53 3.5-1, 014 Concrete Concrete Water - flowing Increase in porosity Plant-specific Yes (inaccessible and permeability; aging areas): basemat loss of strength due management to leaching of program, or calcium hydroxide AMP XI.S2, and carbonation ASME Section XI, Subsection IWL, and/or AMP XI.S6, Page 9 of 34 Structures Monitoring, enhanced as necessary

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table A2 Steel Containments New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M II.A2.CP-75 3.5-1, 023 Concrete Concrete Any Cracking; loss of AMP XI.S2, No (inaccessible bond; and loss of "ASME areas): basemat; material (spalling, Section XI, reinforcing steel scaling) due to Subsection corrosion of IWL," or AMP embedded steel XI.S6, "Structures Monitoring" E II.A2.CP-69 3.5-1, 001 Concrete: basemat Concrete Soil Cracking and AMP XI.S2, Yes distortion due to "ASME increased stress Section XI, levels from Subsection settlement IWL," or AMP XI.S6, "Structures Monitoring" E II.A2.C-07 3.5-1, 002 Concrete: Concrete; Water - flowing Reduction of AMP XI.S6, Yes foundation; porous concrete foundation strength "Structures subfoundation and cracking due to Monitoring" differential settlement and erosion of porous concrete subfoundation M II.A2.CP-35 3.5-1, 035 Steel elements Steel Air - indoor Loss of material due AMP XI.S1, Yes (accessible areas): uncontrolled to general, pitting, "ASME liner; liner anchors; crevice corrosion Section XI, integral Subsection attachments IWE," and AMP XI.S4, "10 CFR Page 10 of 34 Part 50, Appendix J"

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table A2 Steel Containments New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation E II.A2.CP-98 3.5-1, 005 Steel elements Steel Air - indoor Loss of material due AMP XI.S1, Yes (inaccessible uncontrolled to general, pitting, "ASME areas): liner; liner crevice corrosion Section XI, anchors; integral Subsection attachments IWE," and AMP XI.S4, "10 CFR Part 50, Appendix J" II CONTAINMENT STRUCTURES Table A3 Common Components New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M II.A3.CP-37 3.5-1, 027 Metal liner, metal plate, Steel; stainless Air - indoor Cracking due to AMP XI.S1, NoYes airlock, equipment hatch, steel; uncontrolled, cyclic loading (CLB "ASME Section CRD hatch; penetration dissimilar air - outdoor fatigue analysis does XI, Subsection sleeves; penetration metal welds not exist) IWE," and AMP bellows XI.S4, "10 CFR Part 50, Appendix J" M II.A3.C-13 3.5-1, 009 Metal liner, metal plate, Steel; stainless Air - indoor Cumulative fatigue TLAA, SRP-SLR Yes personnel airlock, steel; uncontrolled, damage due to Section 4.6, Page 11 of 34 equipment hatch, CRD dissimilar air - outdoor fatigue (Only if CLB "Containment hatch, penetration metal welds fatigue analysis Liner Plate and sleeves; penetration exists) Penetration bellows Fatigue Analysis"

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table A3 Common Components New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation II.A3.CP-40 3.5-1, 026 Moisture barriers Elastomer, Air - indoor Loss of sealing due AMP XI.S1, No (caulking, flashing, other rubber and uncontrolled to wear, damage, "ASME Section sealants) other similar erosion, tear, surface XI, Subsection materials cracks, other defects IWE" M II.A3.CP-36 3.5-1, 035 Penetration sleeves Steel; Air - indoor Loss of material due AMP XI.S1, Yes dissimilar uncontrolled, to general, pitting, "ASME Section metal welds air - outdoor crevice corrosion XI, Subsection IWE," and AMP XI.S4, "10 CFR Part 50, Appendix J" E II.A3.CP-38 3.5-1, 010 Penetration sleeves; Stainless steel; Air - indoor Cracking due to SCC AMP XI.S1, Yes penetration bellows dissimilar uncontrolled, "ASME Section metal welds air - outdoor XI, Subsection IWE," and AMP XI.S4, "10 CFR Part 50, Appendix J" II.A3.C-16 3.5-1, 028 Personnel airlock, Steel Air - indoor Loss of material due AMP XI.S1, No equipment hatch, CRD uncontrolled, to general, pitting, "ASME Section hatch air - outdoor crevice corrosion XI, Subsection IWE," and AMP XI.S4, "10 CFR Part 50, Appendix J" M II.A3.CP-39 3.5-1, 029 Personnel airlock, Steel Air - indoor Loss of leak AMP XI.S1, No equipment hatch, CRD uncontrolled, tightness due to "ASME Section hatch: locks, hinges, air - outdoor mechanical wear XI, Subsection closure mechanisms IWE," and AMP XI.S4, "10 CFR Part 50, Page 12 of 34 Appendix J" II.A3.CP-148 3.5-1, 031 Pressure-retaining Steel Air - indoor Loss of material due AMP XI.S1, No bolting uncontrolled, to general, pitting, "ASME Section air - outdoor crevice corrosion XI, Subsection IWE"

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table A3 Common Components New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M II.A3.CP-150 3.5-1, 030 Pressure-retaining Steel Any Loss of preload due AMP XI.S1, No bolting to self-loosening "ASME Section XI, Subsection IWE," and AMP XI.S4, "10 CFR Part 50, Appendix J" II.A3.CP-41 3.5-1, 033 Seals and gaskets Elastomer, Air - indoor Loss of sealing due AMP XI.S4, "10 No rubber and uncontrolled, to wear, damage, CFR Part 50, other similar air - outdoor erosion, tear, surface Appendix J" materials cracks, other defects M II.A3.CP-152 3.5-1, 034 Service Level I coatings Coatings Air - indoor Loss of coating or AMP XI.S8, No uncontrolled, lining integrity due to "Protective treated water blistering, cracking, Coating flaking, peeling, Monitoring and delamination, rusting, Maintenance" physical damage II CONTAINMENT STRUCTURES Table B1.1 Mark I Steel Containments New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M II.B1.1.CP-43 3.5-1, 035 Steel elements Steel Air - indoor Loss of material due AMP XI.S1, "ASME Yes Page 13 of 34 (accessible areas): uncontrolled to general, pitting, Section XI, drywell shell; crevice corrosion Subsection IWE,"

drywell head; and AMP XI.S4, drywell shell in "10 CFR Part 50, sand pocket Appendix J" regions

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table B1.1 Mark I Steel Containments New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation E II.B1.1.C-23 3.5-1, 036 Steel elements: Steel Air - indoor Loss of material due AMP XI.S1, "ASME No drywell head; uncontrolled to mechanical wear, Section XI, downcomers including fretting Subsection IWE" II.B1.1.CP-44 3.5-1, 041 Steel elements: Steel Concrete None None No drywell support skirt E II.B1.1.CP-109 3.5-1, 007 Steel elements: Steel Air - indoor Loss of material due AMP XI.S1, "ASME Yes torus ring girders; uncontrolled, to general, pitting, Section XI, downcomers; treated water crevice corrosion Subsection IWE" M II.B1.1.CP-48 3.5-1, 006 Steel elements: Steel Air - indoor Loss of material due AMP XI.S1, "ASME Yes torus shell uncontrolled, to general, pitting, Section XI, treated water crevice corrosion Subsection IWE,"

and AMP XI.S4, "10 CFR Part 50, Appendix J" M II.B1.1.CP-49 3.5-1, 027 Steel elements: Steel; stainless Air - indoor Cracking due to AMP XI.S1, "ASME NoYes torus; vent line; steel uncontrolled cyclic loading (CLB Section XI, vent header; vent fatigue analysis does Subsection IWE,"

line bellows; not exist) and AMP XI.S4, downcomers "10 CFR Part 50, Appendix J" E II.B1.1.C-21 3.5-1, 009 Steel elements: Steel; stainless Air - indoor Cumulative fatigue TLAA, SRP-SLR Yes torus; vent line; steel uncontrolled damage due to Section 4.6, vent header; vent fatigue (Only if CLB "Containment Liner line bellows; fatigue analysis Plate and downcomers exists) Penetration Fatigue Analysis" M II.B1.1.CP-50 3.5-1, 039 Steel elements: Stainless steel Air - indoor Cracking due to SCC AMP XI.S1, "ASME Yes vent line bellows uncontrolled Section XI, Subsection IWE,"

and AMP XI.S4, Page 14 of 34 "10 CFR Part 50, Appendix J"

SLR-ISG-2021-03-STRUCTURES: Appendix C II CONTAINMENT STRUCTURES Table B1.2 Mark I Concrete Containments New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M II.B1.2.CP-79 3.5-1, 021 Concrete Concrete Air - indoor Cracking; loss of AMP XI.S2, No (accessible areas): uncontrolled, air - bond; and loss of "ASME Section XI, basemat; outdoor material (spalling, Subsection IWL" reinforcing steel scaling) due to corrosion of embedded steel E II.B1.2.CP-59 3.5-1, 019 Concrete Concrete Any Cracking due to AMP XI.S2, No (accessible areas): expansion from "ASME Section XI, containment; wall; reaction with Subsection IWL" basemat aggregates II.B1.2.CP-54 3.5-1, 020 Concrete Concrete Water - flowing Increase in porosity AMP XI.S2, No (accessible areas): and permeability; "ASME Section XI, containment; wall; loss of strength due Subsection IWL" basemat to leaching of calcium hydroxide and carbonation M II.B1.2.CP-80 3.5-1, 023 Concrete Concrete Any Cracking; loss of AMP XI.S2, No (inaccessible bond; and loss of "ASME Section XI, areas): basemat; material (spalling, Subsection IWL,"

reinforcing steel scaling) due to and supplemented, corrosion of as necessary, by embedded steel AMP XI.S6, "Structures Monitoring" M II.B1.2.CP-99 3.5-1, 012 Concrete Concrete Any Cracking due to Plant-specific Yes (inaccessible expansion from aging management areas): reaction with program, or AMP containment; wall; aggregates XI.S2, ASME basemat Section XI, Page 15 of 34 Subsection IWL,"

and/or AMP XI.S6, Structures Monitoring, enhanced as necessary

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table B1.2 Mark I Concrete Containments New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M II.B1.2.CP-110 3.5-1, 014 Concrete Concrete Water - flowing Increase in porosity Plant-specific Yes (inaccessible and permeability; aging management areas): loss of strength due program, or AMP containment; wall; to leaching of XI.S2, ASME basemat calcium hydroxide Section XI, and carbonation Subsection IWL, and/or AMP XI.S6, Structures Monitoring, enhanced as necessary E II.B1.2.CP-105 3.5-1, 001 Concrete Concrete Soil Cracking and AMP XI.S2, Yes elements: all distortion due to "ASME Section XI, increased stress Subsection IWL,"

levels from and supplemented, settlement as necessary, by AMP XI.S6, "Structures Monitoring" EM II.B1.2.CP-57 3.5-1, 003 Concrete: Concrete Air - indoor Reduction of Plant-specific Yes containment; wall; uncontrolled, air - strength and aging management basemat outdoor modulus due to program to be elevated evaluated if temperature (>150°F temperature limits general; >200°F exceeded, or AMP local) XI.S2, ASME Section XI, Subsection IWL, and/or AMP XI.S6, Structures Monitoring, Page 16 of 34 enhanced as necessary

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table B1.2 Mark I Concrete Containments New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M II.B1.2.CP-106 3.5-1, 016 Concrete: Concrete Air - indoor Increase in porosity AMP XI.S2, No containment; wall; uncontrolled, air - and permeability; "ASME Section XI, basemat outdoor, cracking; loss of Subsection IWL,"

groundwater/soil material (spalling, or AMP XI.S6, scaling) due to "Structures aggressive chemical Monitoring" attack E II.B1.2.C-07 3.5-1, 002 Concrete: Concrete; Water - flowing Reduction of AMP XI.S6, Yes foundation; porous foundation strength "Structures subfoundation concrete and cracking due to Monitoring" differential settlement and erosion of porous concrete subfoundation M II.B1.2.CP-46 3.5-1, 035 Steel elements Steel Air - indoor Loss of material due AMP XI.S1, Yes (accessible areas): uncontrolled, to general, pitting, "ASME Section XI, suppression treated water crevice corrosion Subsection IWE,"

chamber; drywell; and AMP XI.S4, drywell head; "10 CFR Part 50, embedded shell; Appendix J" region shielded by diaphragm floor (as applicable)

II.B1.2.CP-114 3.5-1, 041 Steel elements Steel Concrete None None No (inaccessible areas): support skirt Page 17 of 34

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table B1.2 Mark I Concrete Containments New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation E II.B1.2.CP-63 3.5-1, 005 Steel elements Steel Air - indoor Loss of material due AMP XI.S1, Yes (inaccessible uncontrolled, to general, pitting, "ASME Section XI, areas): treated water crevice corrosion Subsection IWE,"

suppression and AMP XI.S4, chamber; drywell; "10 CFR Part 50, drywell head; Appendix J" embedded shell; region shielded by diaphragm floor (as applicable)

II.B1.2.CP-117 3.5-1, 031 Steel elements: Steel Air - indoor Loss of material due AMP XI.S1, No downcomer pipes uncontrolled, to general, pitting, "ASME Section XI, treated water crevice corrosion Subsection IWE" E II.B1.2.C-23 3.5-1, 036 Steel elements: Steel Air - indoor Loss of material due AMP XI.S1, No drywell head; uncontrolled to mechanical wear, "ASME Section XI, downcomers including fretting Subsection IWE" II.B1.2.C-49 3.5-1, 037 Steel elements: Steel; Air - indoor Loss of material due AMP XI.S1, No suppression stainless uncontrolled, to general (steel "ASME Section XI, chamber (torus) steel treated water only), pitting, crevice Subsection IWE,"

liner (interior corrosion and AMP XI.S4, surface) "10 CFR Part 50, Appendix J" Page 18 of 34

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table B2.1 Mark II Steel Containments New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M II.B2.1.CP-46 3.5-1, 035 Steel elements Steel Air - indoor Loss of material due AMP XI.S1, "ASME Yes (accessible areas): uncontrolled, to general, pitting, Section XI, suppression treated water crevice corrosion Subsection IWE,"

chamber; drywell; and AMP XI.S4, drywell head; "10 CFR Part 50, embedded shell; Appendix J" region shielded by diaphragm floor (as applicable)

II.B2.1.CP-114 3.5-1, 041 Steel elements Steel Concrete None None No (inaccessible areas): support skirt E II.B2.1.CP-63 3.5-1, 005 Steel elements Steel Air - indoor Loss of material due AMP XI.S1, "ASME Yes (inaccessible uncontrolled, to general, pitting, Section XI, areas): suppression treated water crevice corrosion Subsection IWE,"

chamber; drywell; and AMP XI.S4, drywell head; "10 CFR Part 50, embedded shell; Appendix J" region shielded by diaphragm floor (as applicable)

II.B2.1.CP-117 3.5-1, 031 Steel elements: Steel Air - indoor Loss of material due AMP XI.S1, "ASME No downcomer pipes uncontrolled, to general, pitting, Section XI, treated water crevice corrosion Subsection IWE" E II.B2.1.C-23 3.5-1, 036 Steel elements: Steel Air - indoor Loss of material due AMP XI.S1, "ASME No drywell head; uncontrolled to mechanical wear, Section XI, downcomers including fretting Subsection IWE" M II.B2.1.CP-107 3.5-1, 027 Suppression pool Steel; Air - indoor Cracking due to AMP XI.S1, "ASME NoYes shell stainless uncontrolled, cyclic loading (CLB Section XI, steel; treated water fatigue analysis Subsection IWE,"

dissimilar does not exist) and AMP XI.S4, Page 19 of 34 metal welds "10 CFR Part 50, Appendix J"

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table B2.1 Mark II Steel Containments New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M II.B2.1.C-45 3.5-1, 009 Suppression pool Steel; Air - indoor Cumulative fatigue TLAA, SRP-SLR Yes shell; unbraced stainless uncontrolled, damage due to Section 4.6, downcomers steel; treated water fatigue (Only if CLB "Containment Liner dissimilar fatigue analysis Plate and metal welds exists) Penetration Fatigue Analysis" M II.B2.1.CP-142 3.5-1, 040 Unbraced Steel; Air - indoor Cracking due to AMP XI.S1, "ASME NoYes downcomers stainless uncontrolled, cyclic loading (CLB Section XI, steel; treated water fatigue analysis Subsection IWE" dissimilar does not exist) metal welds II CONTAINMENT STRUCTURES Table B2.2 Mark II Concrete Containments New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M II.B2.2.CP-79 3.5-1, 021 Concrete Concrete Air - indoor Cracking; loss of AMP XI.S2, "ASME No (accessible uncontrolled, air - bond; and loss of Section XI, areas): outdoor material (spalling, Subsection IWL" basemat; scaling) due to reinforcing steel corrosion of embedded steel E II.B2.2.CP-59 3.5-1, 019 Concrete Concrete Any Cracking due to AMP XI.S2, "ASME No Page 20 of 34 (accessible expansion from Section XI, areas): reaction with Subsection IWL" containment; aggregates wall; basemat

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table B2.2 Mark II Concrete Containments New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation II.B2.2.CP-54 3.5-1, 020 Concrete Concrete Water - flowing Increase in porosity AMP XI.S2, "ASME No (accessible and permeability; Section XI, areas): loss of strength due Subsection IWL" containment; to leaching of calcium wall; basemat hydroxide and carbonation M II.B2.2.CP-80 3.5-1, 023 Concrete Concrete Any Cracking; loss of AMP XI.S2, "ASME No (inaccessible bond; and loss of Section XI, areas): material (spalling, Subsection IWL,"

basemat; scaling) due to and supplemented, reinforcing steel corrosion of as necessary, by embedded steel AMP XI.S6, "Structures Monitoring" M II.B2.2.CP-99 3.5-1, 012 Concrete Concrete Any Cracking due to Plant-specific aging Yes (inaccessible expansion from management areas): reaction with program, or AMP containment; aggregates XI.S2, ASME wall; basemat Section XI, Subsection IWL, and/or AMP XI.S6, Structures Monitoring, enhanced as necessary M II.B2.2.CP-110 3.5-1, 014 Concrete Concrete Water - flowing Increase in porosity Plant-specific aging Yes (inaccessible and permeability; management areas): loss of strength due program, or AMP containment; to leaching of calcium XI.S2, ASME wall; basemat hydroxide and Section XI, carbonation Subsection IWL, Page 21 of 34 and/or AMP XI.S6, Structures Monitoring, enhanced as necessary

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table B2.2 Mark II Concrete Containments New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation E II.B2.2.CP-105 3.5-1, 001 Concrete Concrete Soil Cracking and AMP XI.S2, "ASME Yes elements: all distortion due to Section XI, increased stress Subsection IWL,"

levels from and supplemented, settlement as necessary, by AMP XI.S6, "Structures Monitoring" EM II.B2.2.CP-57 3.5-1, 003 Concrete: Concrete Air - indoor Reduction of strength Plant-specific aging Yes containment; uncontrolled, air - and modulus due to management wall; basemat outdoor elevated temperature program to be

(>150°F general; evaluated if

>200°F local) temperature limits exceeded, or AMP XI.S2, ASME Section XI, Subsection IWL, and/or AMP XI.S6, Structures Monitoring, enhanced as necessary M II.B2.2.CP-106 3.5-1, 016 Concrete: Concrete Air - indoor Increase in porosity AMP XI.S2, "ASME No containment; uncontrolled, air - and permeability; Section XI, wall; basemat outdoor, cracking; loss of Subsection IWL,"

groundwater/soil material (spalling, and supplemented, scaling) due to as necessary, by aggressive chemical AMP XI.S6, attack "Structures Monitoring" E II.B2.2.C-07 3.5-1, 002 Concrete: Concrete; Water - flowing Reduction of AMP XI.S6, Yes Page 22 of 34 foundation; porous foundation strength "Structures subfoundation concrete and cracking due to Monitoring" differential settlement and erosion of porous concrete subfoundation

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table B2.2 Mark II Concrete Containments New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M II.B2.2.C-11 3.5-1, 008 Prestressing Steel Air - indoor Loss of prestress due TLAA, SRP-SLR Yes system: uncontrolled, air - to relaxation; Section 4.5, tendons outdoor shrinkage; creep; "Concrete elevated temperature Containment Tendon Prestress,"

and/or SRP-SLR Section 4.7, "Other Plant-Specific Time-Limited Aging Analyses" II.B2.2.C-10 3.5-1, 032 Prestressing Steel Air - indoor Loss of material due AMP XI.S2, "ASME No system: uncontrolled, air - to corrosion Section XI, tendons; outdoor Subsection IWL" anchorage components M II.B2.2.CP-46 3.5-1, 035 Steel elements Steel Air - indoor Loss of material due AMP XI.S1, "ASME Yes (accessible uncontrolled, to general, pitting, Section XI, areas): treated water crevice corrosion Subsection IWE,"

suppression and AMP XI.S4, chamber; "10 CFR Part 50, drywell; drywell Appendix J" head; embedded shell; region shielded by diaphragm floor (as applicable)

II.B2.2.CP-114 3.5-1, 041 Steel elements Steel Concrete None None No (inaccessible areas): support skirt Page 23 of 34

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table B2.2 Mark II Concrete Containments New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation E II.B2.2.CP-63 3.5-1, 005 Steel elements Steel Air - indoor Loss of material due AMP XI.S1, "ASME Yes (inaccessible uncontrolled, to general, pitting, Section XI, areas): treated water crevice corrosion Subsection IWE,"

suppression and AMP XI.S4, chamber; "10 CFR Part 50, drywell; drywell Appendix J" head; embedded shell; region shielded by diaphragm floor (as applicable)

II.B2.2.CP-117 3.5-1, 031 Steel elements: Steel Air - indoor Loss of material due AMP XI.S1, "ASME No downcomer uncontrolled, to general, pitting, Section XI, pipes treated water crevice corrosion Subsection IWE" E II.B2.2.C-23 3.5-1, 036 Steel elements: Steel Air - indoor Loss of material due AMP XI.S1, "ASME No drywell head; uncontrolled to mechanical wear, Section XI, downcomers including fretting Subsection IWE" II.B2.2.C-49 3.5-1, 037 Steel elements: Steel; Air - indoor Loss of material due AMP XI.S1, "ASME No suppression stainless steel uncontrolled, to general (steel Section XI, chamber (torus) treated water only), pitting, crevice Subsection IWE,"

liner (interior corrosion and AMP XI.S4, surface) "10 CFR Part 50, Appendix J" EM II.B2.2.CP-64 3.5-1, 040 Steel elements: Steel; Air - indoor Cracking due to AMP XI.S1, "ASME NoYes vent header; stainless steel uncontrolled, cyclic loading (CLB Section XI, downcomers treated water fatigue analysis does Subsection IWE" not exist)

E II.B2.2.C-48 3.5-1, 009 Steel elements: Steel; Air - indoor Cumulative fatigue TLAA, SRP-SLR Yes vent header; stainless steel uncontrolled, damage due to Section 4.6, downcomers treated water fatigue (Only if CLB "Containment Liner Page 24 of 34 fatigue analysis Plate and exists) Penetration Fatigue Analysis"

SLR-ISG-2021-03-STRUCTURES: Appendix C II CONTAINMENT STRUCTURES Table B3.1 Mark III Steel Containments New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation II.B3.1.CP-72 3.5-1, 016 Concrete Concrete Groundwater/soil Increase in porosity AMP XI.S2, No (accessible and permeability; "ASME Section areas): cracking; loss of XI, Subsection basemat material (spalling, IWL," or AMP scaling) due to XI.S6, aggressive chemical "Structures attack Monitoring" II.B3.1.CP-156 3.5-1, 020 Concrete Concrete Water - flowing Increase in porosity AMP XI.S2, No (accessible and permeability; "ASME Section areas): loss of strength due XI, Subsection basemat to leaching of IWL," or AMP calcium hydroxide XI.S6, and carbonation "Structures Monitoring" E II.B3.1.CP-66 3.5-1, 019 Concrete Concrete Any Cracking due to AMP XI.S2, No (accessible expansion from "ASME Section areas): reaction with XI, Subsection basemat, aggregates IWL," or AMP concrete fill-in XI.S6, annulus "Structures Monitoring" M II.B3.1.CP-74 3.5-1, 021 Concrete Concrete Air - indoor Cracking; loss of AMP XI.S2, No (accessible uncontrolled, air - bond; and loss of "ASME Section areas): outdoor material (spalling, XI, Subsection basemat; scaling) due to IWL," or AMP reinforcing steel corrosion of XI.S6, embedded steel "Structures Monitoring" II.B3.1.CP-71 3.5-1, 024 Concrete Concrete Groundwater/soil Increase in porosity AMP XI.S2, No Page 25 of 34 (inaccessible and permeability; "ASME Section areas): cracking; loss of XI, Subsection basemat material (spalling, IWL," or AMP scaling) due to XI.S6, aggressive chemical "Structures attack Monitoring"

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table B3.1 Mark III Steel Containments New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M II.B3.1.CP-53 3.5-1, 014 Concrete Concrete Water - flowing Increase in porosity Plant-specific Yes (inaccessible and permeability; aging areas): loss of strength due management basemat to leaching of program, or AMP calcium hydroxide XI.S2, ASME and carbonation Section XI, Subsection IWL, and/or AMP XI.S6, Structures Monitoring, enhanced as necessary M II.B3.1.CP-83 3.5-1, 012 Concrete Concrete Any Cracking due to Plant-specific Yes (inaccessible expansion from aging areas): reaction with management basemat, aggregates program, or AMP concrete fill-in XI.S2, ASME annulus Section XI, Subsection IWL, and/or AMP XI.S6, Structures Monitoring, enhanced as necessary M II.B3.1.CP-75 3.5-1, 023 Concrete Concrete Any Cracking; loss of AMP XI.S2, No (inaccessible bond; and loss of "ASME Section areas): material (spalling, XI, Subsection basemat; scaling) due to IWL," or AMP reinforcing steel corrosion of XI.S6, embedded steel "Structures Monitoring" Page 26 of 34

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table B3.1 Mark III Steel Containments New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation E II.B3.1.CP-69 3.5-1, 001 Concrete: Concrete Soil Cracking and AMP XI.S2, Yes basemat distortion due to "ASME Section increased stress XI, Subsection levels from IWL," or AMP settlement XI.S6, "Structures Monitoring" EM II.B3.1.CP-65 3.5-1, 003 Concrete: Concrete Air - indoor Reduction of strength Plant-specific Yes basemat, uncontrolled, air - and modulus due to aging concrete fill-in outdoor elevated temperature management annulus (>150°F general; program to be

>200°F local) evaluated if temperature limits exceeded, or AMP XI.S2, ASME Section XI, Subsection IWL, and/or AMP XI.S6, Structures Monitoring, enhanced as necessary E II.B3.1.C-07 3.5-1, 002 Concrete: Concrete; Water - flowing Reduction of AMP XI.S6, Yes foundation; porous foundation strength "Structures subfoundation concrete and cracking due to Monitoring" differential settlement and erosion of porous concrete subfoundation M II.B3.1.CP-43 3.5-1, 035 Steel elements Steel Air - indoor Loss of material due AMP XI.S1, Yes Page 27 of 34 (accessible uncontrolled to general, pitting, "ASME Section areas): drywell crevice corrosion XI, Subsection shell; drywell IWE," and AMP head XI.S4, "10 CFR Part 50, Appendix J"

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table B3.1 Mark III Steel Containments New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation E II.B3.1.CP-113 3.5-1, 004 Steel elements Steel Air - indoor Loss of material due AMP XI.S1, Yes (inaccessible uncontrolled, to general, pitting, "ASME Section areas): drywell concrete crevice corrosion XI, Subsection shell; drywell IWE," and AMP head XI.S4, "10 CFR Part 50, Appendix J" M II.B3.1.C-24 3.5-1, 038 Steel elements: Stainless Air - indoor Cracking due to SCC AMP XI.S1, Yes suppression steel uncontrolled "ASME Section chamber shell XI, Subsection (interior IWE," and AMP surface) XI.S4, "10 CFR Part 50, Appendix J" E II.B3.1.CP-158 3.5-1, 007 Steel elements: Steel Air - indoor Loss of material due AMP XI.S1, Yes suppression uncontrolled, to general, pitting, "ASME Section chamber shell treated water crevice corrosion XI, Subsection (interior IWE" surface)

Page 28 of 34

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table B3.2 Mark III Concrete Containments New,

Modified, Deleted, Structure Edited SRP Item and/or Aging Aging Management Further Item Item (Table, ID) Component Material Environment Effect/Mechanism Program (AMP)/TLAA Evaluation II.B3.2.CP-84 3.5-1, 024 Concrete Concrete Air - indoor Increase in porosity AMP XI.S2, "ASME No (accessible uncontrolled, air and permeability; Section XI, Subsection areas): dome; - outdoor, cracking; loss of IWL," and wall; basemat groundwater/soil material (spalling, supplemented, as scaling) due to necessary, by AMP aggressive chemical XI.S6, "Structures attack Monitoring" II.B3.2.CP-52 3.5-1, 018 Concrete Concrete Air - outdoor, Loss of material AMP XI.S2, "ASME No (accessible groundwater/soil (spalling, scaling) and Section XI, Subsection areas): dome; cracking due to IWL" wall; basemat freeze-thaw E II.B3.2.CP-60 3.5-1, 019 Concrete Concrete Any Cracking due to AMP XI.S2, "ASME No (accessible expansion from Section XI, Subsection areas): dome; reaction with IWL" wall; basemat aggregates II.B3.2.CP-55 3.5-1, 020 Concrete Concrete Water - flowing Increase in porosity AMP XI.S2, "ASME No (accessible and permeability; loss Section XI, Subsection areas): dome; of strength due to IWL" wall; basemat leaching of calcium hydroxide and carbonation M II.B3.2.CP-88 3.5-1, 021 Concrete Concrete Air - indoor Cracking; loss of AMP XI.S2, "ASME No (accessible uncontrolled, air bond; and loss of Section XI, Subsection areas): dome; - outdoor material (spalling, IWL" wall; basemat; scaling) due to reinforcing steel corrosion of embedded steel II.B3.2.CP-73 3.5-1, 024 Concrete Concrete Air - indoor Increase in porosity AMP XI.S2, "ASME No (inaccessible uncontrolled, air and permeability; Section XI, Subsection areas): dome; - outdoor, cracking; loss of IWL," and wall; basemat groundwater/soil material (spalling, supplemented, as Page 29 of 34 scaling) due to necessary, by AMP aggressive chemical XI.S6, "Structures attack Monitoring"

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table B3.2 Mark III Concrete Containments New,

Modified, Deleted, Structure Edited SRP Item and/or Aging Aging Management Further Item Item (Table, ID) Component Material Environment Effect/Mechanism Program (AMP)/TLAA Evaluation EM II.B3.2.CP-135 3.5-1, 011 Concrete Concrete Air - outdoor, Loss of material Plant-specific aging Yes (inaccessible groundwater/soil (spalling, scaling) and management program areas): dome; cracking due to to be evaluated for wall; basemat freeze-thaw plants in moderate to severe weathering conditions, or AMP XI.S2, ASME Section XI, Subsection IWL, and/or AMP XI.S6, Structures Monitoring, enhanced as necessary M II.B3.2.CP-121 3.5-1, 012 Concrete Concrete Any Cracking due to Plant-specific aging Yes (inaccessible expansion from management program areas): dome; reaction with significant if it is wall; basemat aggregates demonstrated that the in-place concrete can perform its intended function, or AMP XI.S2, ASME Section XI, Subsection IWL, and/or AMP XI.S6, Structures Monitoring, enhanced as necessary M II.B3.2.CP-122 3.5-1, 014 Concrete Concrete Water - flowing Increase in porosity Plant-specific aging Yes (inaccessible and permeability; loss management program, areas): dome; of strength due to or AMP XI.S2, ASME wall; basemat leaching of calcium Section XI, Subsection hydroxide and IWL, and/or AMP Page 30 of 34 carbonation XI.S6, Structures Monitoring, enhanced as necessary

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table B3.2 Mark III Concrete Containments New,

Modified, Deleted, Structure Edited SRP Item and/or Aging Aging Management Further Item Item (Table, ID) Component Material Environment Effect/Mechanism Program (AMP)/TLAA Evaluation M II.B3.2.CP-89 3.5-1, 023 Concrete Concrete Any Cracking; loss of AMP XI.S2, "ASME No (inaccessible bond; and loss of Section XI, Subsection areas): dome; material (spalling, IWL," and wall; basemat; scaling) due to supplemented, as reinforcing steel corrosion of necessary, by AMP embedded steel XI.S6, "Structures Monitoring" E II.B3.2.CP-105 3.5-1, 001 Concrete Concrete Soil Cracking and AMP XI.S2, "ASME Yes elements: all distortion due to Section XI, Subsection increased stress IWL," and levels from settlement supplemented, as necessary, by AMP XI.S6, "Structures Monitoring" EM II.B3.2.CP-108 3.5-1, 003 Concrete: Concrete Air - indoor Reduction of strength Plant-specific aging Yes dome; wall; uncontrolled, air and modulus due to management program basemat - outdoor elevated temperature to be evaluated if

(>150°F general; temperature limits

>200°F local) exceeded, or AMP XI.S2, ASME Section XI, Subsection IWL, and/or AMP XI.S6, Structures Monitoring, enhanced as necessary E II.B3.2.C-07 3.5-1, 002 Concrete: Concrete; Water - flowing Reduction of AMP XI.S6, "Structures Yes foundation; porous foundation strength Monitoring" subfoundation concrete and cracking due to differential settlement and erosion of porous concrete Page 31 of 34 subfoundation

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table B3.2 Mark III Concrete Containments New,

Modified, Deleted, Structure Edited SRP Item and/or Aging Aging Management Further Item Item (Table, ID) Component Material Environment Effect/Mechanism Program (AMP)/TLAA Evaluation M II.B3.2.CP-35 3.5-1, 035 Steel elements Steel Air - indoor Loss of material due AMP XI.S1, "ASME Yes (accessible uncontrolled to general, pitting, Section XI, Subsection areas): liner; crevice corrosion IWE," and AMP XI.S4, liner anchors; "10 CFR Part 50, integral Appendix J" attachments E II.B3.2.CP-98 3.5-1, 005 Steel elements Steel Air - indoor Loss of material due AMP XI.S1, "ASME Yes (inaccessible uncontrolled to general, pitting, Section XI, Subsection areas): liner; crevice corrosion IWE," and AMP XI.S4, liner anchors; "10 CFR Part 50, integral Appendix J" attachments M II.B3.2.C-24 3.5-1, 038 Steel elements: Stainless Air - indoor Cracking due to SCC AMP XI.S1, "ASME Yes suppression steel uncontrolled Section XI, Subsection chamber shell IWE," and AMP XI.S4, (interior "10 CFR Part 50, surface) Appendix J" II CONTAINMENT STRUCTURES Table B4 Common Components New,

Modified, Deleted, Structure Aging Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M II.B4.CP-37 3.5-1, 027 Metal liner, Steel; Air - indoor Cracking due to cyclic AMP XI.S1, "ASME NoYes metal plate, stainless uncontrolled, air loading (CLB fatigue Section XI, airlock, steel; - outdoor analysis does not exist) Subsection IWE," and equipment dissimilar AMP XI.S4, "10 CFR Page 32 of 34 hatch, CRD metal Part 50, Appendix J" hatch; welds penetration sleeves; penetration bellows

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table B4 Common Components New,

Modified, Deleted, Structure Aging Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M II.B4.C-13 3.5-1, 009 Metal liner, Steel; Air - indoor Cumulative fatigue TLAA, SRP-SLR Yes metal plate, stainless uncontrolled, air damage due to fatigue Section 4.6, personnel steel; - outdoor (Only if CLB fatigue "Containment Liner airlock, dissimilar analysis exists) Plate and Penetration equipment metal Fatigue Analysis" hatch, CRD welds hatch, penetration sleeves; penetration bellows II.B4.CP-40 3.5-1, 026 Moisture Elastomer, Air - indoor Loss of sealing due to AMP XI.S1, "ASME No barriers rubber and uncontrolled wear, damage, erosion, Section XI, (caulking, other tear, surface cracks, Subsection IWE" flashing, other similar other defects sealants) materials M II.B4.CP-36 3.5-1, 035 Penetration Steel; Air - indoor Loss of material due to AMP XI.S1, "ASME Yes sleeves dissimilar uncontrolled, air general, pitting, crevice Section XI, metal - outdoor corrosion Subsection IWE," and welds AMP XI.S4, "10 CFR Part 50, Appendix J" E II.B4.CP-38 3.5-1, 010 Penetration Stainless Air - indoor Cracking due to SCC AMP XI.S1, "ASME Yes sleeves; steel; uncontrolled, air Section XI, penetration dissimilar - outdoor Subsection IWE," and bellows metal AMP XI.S4, "10 CFR welds Part 50, Appendix J" II.B4.C-16 3.5-1, 028 Personnel Steel Air - indoor Loss of material due to AMP XI.S1, "ASME No airlock, uncontrolled, air general, pitting, crevice Section XI, equipment - outdoor corrosion Subsection IWE," and hatch, CRD AMP XI.S4, "10 CFR hatch Part 50, Appendix J" Page 33 of 34

II CONTAINMENT STRUCTURES SLR-ISG-2021-03-STRUCTURES: Appendix C Table B4 Common Components New,

Modified, Deleted, Structure Aging Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M II.B4.CP-39 3.5-1, 029 Personnel Steel Air - indoor Loss of leak tightness AMP XI.S1, "ASME No airlock, uncontrolled, air due to mechanical wear Section XI, equipment - outdoor Subsection IWE," and hatch, CRD AMP XI.S4, "10 CFR hatch: locks, Part 50, Appendix J" hinges, closure mechanisms II.B4.CP-148 3.5-1, 031 Pressure- Steel Air - indoor Loss of material due to AMP XI.S1, "ASME No retaining bolting uncontrolled, air general, pitting, crevice Section XI,

- outdoor corrosion Subsection IWE" M II.B4.CP-150 3.5-1, 030 Pressure- Steel Any Loss of preload due to AMP XI.S1, "ASME No retaining bolting self-loosening Section XI, Subsection IWE," and AMP XI.S4, "10 CFR Part 50, Appendix J" II.B4.CP-41 3.5-1, 033 Seals and Elastomer, Air - indoor Loss of sealing due to AMP XI.S4, "10 CFR No gaskets rubber and uncontrolled, air wear, damage, erosion, Part 50, Appendix J" other - outdoor tear, surface cracks, similar other defects materials M II.B4.CP-152 3.5-1, 034 Service Level I Coatings Air - indoor Loss of coating or lining AMP XI.S8, No coatings uncontrolled, integrity due to blistering, "Protective Coating treated water cracking, flaking, peeling, Monitoring and delamination, rusting, Maintenance" physical damage Page 34 of 34

APPENDIX D REVISIONS TO GALL-SLR REPORT CHAPTER III TO ALLOW PLANT-SPECIFIC AGING MANAGEMENT OPTIONS Summary of Revisions This appendix modifies NUREG-2191, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, relevant aging management review (AMR) items to reflect the option of using, in lieu of recommended plant-specific aging management programs (AMPs), plant-specific enhancements to GALL-SLR Report AMPs (with modified inspection activities when required) to manage the effects of aging in concrete for the following:

• reduction of strength and modulus of elasticity due to elevated temperature (greater than 66 degrees Celsius (150 degrees Fahrenheit) general: greater than 93 degrees Celsius (200 degrees Fahrenheit) local)

• loss of material (spalling, scaling) and cracking due to freeze-thaw

• cracking due to expansion from reaction with aggregates

• increase in porosity and permeability; loss of strength due to leaching of calcium hydroxide and carbonation

• reduction of strength; loss of mechanical properties due to irradiation (i.e., radiation interactions with material and radiation-induced heating) for boiling-water reactor (BWR) and pressurized-water reactor (PWR) components in question, including those located in inaccessible areas Basis for Revisions Modifications to GALL-SLR Report AMR items and SRP-SLR Table 3.5-1 line items (see Appendix E) with associated further evaluations provide the option to use, in lieu of a plant-specific AMP, plant-specific enhancements to GALL-SLR Report AMP XI.S6, Structures Monitoring, or other selected AMPs. The option to use plant-specific enhancements increases the efficiency of subsequent license renewal applications reviews by limiting the use of AMR Note E to plant-specific aging management activities when aging effects are managed through a plant-specific AMP.

AMP Revisions None Revisions to FSAR Supplement None

Revisions to AMR Items SLR-ISG-2021-03-STRUCTURES: Appendix D III STRUCTURES AND COMPONENT SUPPORTS Table A1 Group 1 Structures (BWR Reactor Bldg., PWR Shield Bldg., Control Room/Bldg.)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation E III.A1.TP-25 3.5-1, 054 Concrete Concrete Any Cracking due to AMP XI.S6, No (accessible expansion from "Structures areas): all reaction with Monitoring" aggregates III.A1.TP-27 3.5-1, 065 Concrete Concrete Groundwater/soil Cracking; loss of AMP XI.S6, No (accessible bond; and loss of "Structures areas): below- material (spalling, Monitoring" grade exterior; scaling) due to foundation corrosion of embedded steel III.A1.TP-23 3.5-1, 064 Concrete Concrete Air - outdoor Loss of material AMP XI.S6, No (accessible (spalling, scaling) and "Structures areas): exterior cracking due to Monitoring" above- and freeze-thaw below-grade; foundation III.A1.TP-24 3.5-1, 063 Concrete Concrete Water - flowing Increase in porosity AMP XI.S6, No (accessible and permeability; loss "Structures areas): exterior of strength due to Monitoring" above- and leaching of calcium below-grade; hydroxide and foundation carbonation III.A1.TP-26 3.5-1, 066 Concrete Concrete Air - indoor Cracking; loss of AMP XI.S6, No (accessible uncontrolled, air - bond; and loss of "Structures areas): interior outdoor material (spalling, Monitoring" and above- scaling) due to grade exterior corrosion of embedded steel M III.A1.TP-204 3.5-1, 043 Concrete Concrete Any Cracking due to Plant-specific aging Yes (inaccessible expansion from management Page 2 of 33 areas): all reaction with program or AMP aggregates XI.S6, Structures Monitoring, enhanced as necessary

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A1 Group 1 Structures (BWR Reactor Bldg., PWR Shield Bldg., Control Room/Bldg.)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation III.A1.TP-212 3.5-1, 065 Concrete Concrete Groundwater/soil Cracking; loss of AMP XI.S6, No (inaccessible bond; and loss of "Structures areas): below- material (spalling, Monitoring" grade exterior; scaling) due to foundation corrosion of embedded steel III.A1.TP-29 3.5-1, 067 Concrete Concrete Groundwater/soil Increase in porosity AMP XI.S6, No (inaccessible and permeability; "Structures areas): below- cracking; loss of Monitoring" grade exterior; material (spalling, foundation scaling) due to aggressive chemical attack M III.A1.TP-67 3.5-1, 047 Concrete Concrete Water - flowing Increase in porosity Plant-specific aging Yes (inaccessible and permeability; loss management areas): exterior of strength due to program or AMP above- and leaching of calcium XI.S6, Structures below-grade; hydroxide and Monitoring, foundation carbonation enhanced as necessary M III.A1.TP-108 3.5-1, 042 Concrete Concrete Air - outdoor, Loss of material Plant-specific aging Yes (inaccessible groundwater/soil (spalling, scaling) and management areas): cracking due to program to be foundation freeze-thaw evaluated for plants in moderate to severe weathering conditions or AMP XI.S6, Structures Monitoring, enhanced as necessary Page 3 of 33

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A1 Group 1 Structures (BWR Reactor Bldg., PWR Shield Bldg., Control Room/Bldg.)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation EM III.A1.TP-114 3.5-1, 048 Concrete: all Concrete Air - indoor Reduction of strength Plant-specific aging Yes uncontrolled and modulus due to management elevated temperature program to be

(>150°F general; evaluated if

>200°F local) temperature limits exceeded or AMP XI.S6, Structures Monitoring, enhanced as necessary E III.A1.TP-30 3.5-1, 044 Concrete: all Concrete Soil Cracking and AMP XI.S6, Yes distortion due to "Structures increased stress Monitoring" levels from settlement E III.A1.TP-31 3.5-1, 046 Concrete: Concrete; Water - flowing Reduction of AMP XI.S6, Yes foundation; porous foundation strength "Structures subfoundation concrete and cracking due to Monitoring" differential settlement and erosion of porous concrete subfoundation III.A1.TP-28 3.5-1, 067 Concrete: Concrete Air - indoor Increase in porosity AMP XI.S6, No interior; above- uncontrolled, air - and permeability; "Structures grade exterior outdoor cracking; loss of Monitoring" material (spalling, scaling) due to aggressive chemical attack III.A1.T-12 3.5-1, 070 Masonry walls: Concrete Air - indoor Cracking due to AMP XI.S5, No all block uncontrolled, air - restraint shrinkage, "Masonry Walls" outdoor creep, and aggressive Page 4 of 33 environment N III.A1.TP-34 3.5-1, 071 Masonry walls: Concrete Air - outdoor Loss of material AMP XI.S5, No all block (spalling, scaling) and "Masonry Walls" cracking due to freeze-thaw

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A1 Group 1 Structures (BWR Reactor Bldg., PWR Shield Bldg., Control Room/Bldg.)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation E III.A1.TP-302 3.5-1, 077 Steel Steel Air - indoor Loss of material due AMP XI.S6, No components: all uncontrolled, air - to corrosion "Structures structural steel outdoor Monitoring" E III.A1.TP-261 3.5-1, 088 Structural Any Any Loss of preload due AMP XI.S6, No bolting to self-loosening "Structures Monitoring" M III.A1.TP-248 3.5-1, 080 Structural Steel Air - indoor Loss of material due AMP XI.S6, No bolting uncontrolled, air - to general, pitting, "Structures outdoor crevice corrosion Monitoring" III.A1.TP-274 3.5-1, 082 Structural Steel; Air - outdoor Loss of material due AMP XI.S6, No bolting galvanized to general, pitting, "Structures steel crevice corrosion Monitoring" D III.A1.TP-300 III STRUCTURES AND COMPONENT SUPPORTS Table A2 Group 2 Structures (BWR Reactor Bldg. With Steel Superstructure)

New,

Modified, Deleted, Structure Aging Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation E III.A2.TP-25 3.5-1, 054 Concrete Concrete Any Cracking due to AMP XI.S6, No (accessible expansion from "Structures areas): all reaction with Monitoring" aggregates III.A2.TP-27 3.5-1, 065 Concrete Concrete Groundwater/soil Cracking; loss of AMP XI.S6, No (accessible bond; and loss of "Structures Page 5 of 33 areas): below- material (spalling, Monitoring" grade exterior; scaling) due to foundation corrosion of embedded steel

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A2 Group 2 Structures (BWR Reactor Bldg. With Steel Superstructure)

New,

Modified, Deleted, Structure Aging Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation III.A2.TP-23 3.5-1, 064 Concrete Concrete Air - outdoor Loss of material AMP XI.S6, No (accessible (spalling, scaling) and "Structures areas): exterior cracking due to Monitoring" above- and freeze-thaw below-grade; foundation III.A2.TP-24 3.5-1, 063 Concrete Concrete Water - flowing Increase in porosity AMP XI.S6, No (accessible and permeability; loss "Structures areas): exterior of strength due to Monitoring" above- and leaching of calcium below-grade; hydroxide and foundation carbonation III.A2.TP-26 3.5-1, 066 Concrete Concrete Air - indoor Cracking; loss of AMP XI.S6, No (accessible uncontrolled, air - bond; and loss of "Structures areas): interior outdoor material (spalling, Monitoring" and above- scaling) due to grade exterior corrosion of embedded steel M III.A2.TP-204 3.5-1, 043 Concrete Concrete Any Cracking due to Plant-specific aging Yes (inaccessible expansion from management program areas): all reaction with or AMP XI.S6, aggregates Structures Monitoring, enhanced as necessary III.A2.TP-212 3.5-1, 065 Concrete Concrete Groundwater/soil Cracking; loss of AMP XI.S6, No (inaccessible bond; and loss of "Structures areas): below- material (spalling, Monitoring" grade exterior; scaling) due to foundation corrosion of embedded steel Page 6 of 33

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A2 Group 2 Structures (BWR Reactor Bldg. With Steel Superstructure)

New,

Modified, Deleted, Structure Aging Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation III.A2.TP-29 3.5-1, 067 Concrete Concrete Groundwater/soil Increase in porosity AMP XI.S6, No (inaccessible and permeability; "Structures areas): below- cracking; loss of Monitoring" grade exterior; material (spalling, foundation scaling) due to aggressive chemical attack M III.A2.TP-67 3.5-1, 047 Concrete Concrete Water - flowing Increase in porosity Plant-specific aging Yes (inaccessible and permeability; loss management program areas): exterior of strength due to or AMP XI.S6, above- and leaching of calcium Structures below-grade; hydroxide and Monitoring, foundation carbonation enhanced as necessary M III.A2.TP-108 3.5-1, 042 Concrete Concrete Air - outdoor, Loss of material Plant-specific aging Yes (inaccessible groundwater/soil (spalling, scaling) and management program areas): cracking due to to be evaluated for foundation freeze-thaw plants in moderate to severe weathering conditions or AMP XI.S6, Structures Monitoring, enhanced as necessary EM III.A2.TP-114 3.5-1, 048 Concrete: all Concrete Air - indoor Reduction of strength Plant-specific aging Yes uncontrolled and modulus due to management program elevated temperature to be evaluated if

(>150°F general; temperature limits

>200°F local) exceeded or AMP XI.S6, Structures Monitoring, enhanced as Page 7 of 33 necessary E III.A2.TP-30 3.5-1, 044 Concrete: all Concrete Soil Cracking and AMP XI.S6, Yes distortion due to "Structures increased stress Monitoring" levels from settlement

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A2 Group 2 Structures (BWR Reactor Bldg. With Steel Superstructure)

New,

Modified, Deleted, Structure Aging Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation E III.A2.TP-31 3.5-1, 046 Concrete: Concrete; Water - flowing Reduction of AMP XI.S6, Yes foundation; porous foundation strength "Structures subfoundation concrete and cracking due to Monitoring" differential settlement and erosion of porous concrete subfoundation III.A2.TP-28 3.5-1, 067 Concrete: Concrete Air - indoor Increase in porosity AMP XI.S6, No interior; above- uncontrolled, air - and permeability; "Structures grade exterior outdoor cracking; loss of Monitoring" material (spalling, scaling) due to aggressive chemical attack III.A2.T-12 3.5-1, 070 Masonry walls: Concrete Air - indoor Cracking due to AMP XI.S5, "Masonry No all block uncontrolled, air - restraint shrinkage, Walls" outdoor creep, and aggressive environment N III.A2.TP-34 3.5-1, 071 Masonry walls: Concrete Air - outdoor Loss of material AMP XI.S5, "Masonry No all block (spalling, scaling) and Walls" cracking due to freeze-thaw E III.A2.TP-302 3.5-1, 077 Steel Steel Air - indoor Loss of material due AMP XI.S6, No components: all uncontrolled, air - to corrosion "Structures structural steel outdoor Monitoring" E III.A2.TP-261 3.5-1, 088 Structural Any Any Loss of preload due AMP XI.S6, No bolting to self-loosening "Structures Monitoring" M III.A2.TP-248 3.5-1, 080 Structural Steel Air - indoor Loss of material due AMP XI.S6, No bolting uncontrolled, air - to general, pitting, "Structures outdoor crevice corrosion Monitoring" Page 8 of 33 III.A2.TP-274 3.5-1, 082 Structural Steel; Air - outdoor Loss of material due AMP XI.S6, No bolting galvanized to general, pitting, "Structures steel crevice corrosion Monitoring" D III.A2.TP-300

SLR-ISG-2021-03-STRUCTURES: Appendix D III STRUCTURES AND COMPONENT SUPPORTS Table A3 Group 3 Structures (Auxiliary Bldg., Diesel Generator Bldg., Radwaste Bldg., Turbine Bldg., Switchgear Rm., Yard Structures Such As AFW Pumphouse, Utility/Piping Tunnels, Security/Lighting Poles, Manholes, Duct Banks; SBO Structures Such As Transmission Towers, Startup Tower Circuit Breaker Foundation, Electrical Enclosure)

New,

Modified, Deleted, Structure Edited SRP Item and/or Aging Aging Management Further Item Item (Table, ID) Component Material Environment Effect/Mechanism Program (AMP)/TLAA Evaluation E III.A3.TP-25 3.5-1, 054 Concrete Concrete Any Cracking due to AMP XI.S6, "Structures No (accessible expansion from Monitoring" areas): all reaction with aggregates III.A3.TP-27 3.5-1, 065 Concrete Concrete Groundwater/soil Cracking; loss of AMP XI.S6, "Structures No (accessible bond; and loss of Monitoring" areas): below- material (spalling, grade exterior; scaling) due to foundation corrosion of embedded steel III.A3.TP-23 3.5-1, 064 Concrete Concrete Air - outdoor Loss of material AMP XI.S6, "Structures No (accessible (spalling, scaling) Monitoring" areas): exterior and cracking due to above- and freeze-thaw below-grade; foundation III.A3.TP-24 3.5-1, 063 Concrete Concrete Water - flowing Increase in porosity AMP XI.S6, "Structures No (accessible and permeability; Monitoring" areas): exterior loss of strength due above- and to leaching of below-grade; calcium hydroxide foundation and carbonation III.A3.TP-26 3.5-1, 066 Concrete Concrete Air - indoor Cracking; loss of AMP XI.S6, "Structures No (accessible uncontrolled, air - bond; and loss of Monitoring" areas): interior outdoor material (spalling, Page 9 of 33 and above- scaling) due to grade exterior corrosion of embedded steel

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A3 Group 3 Structures (Auxiliary Bldg., Diesel Generator Bldg., Radwaste Bldg., Turbine Bldg., Switchgear Rm., Yard Structures Such As AFW Pumphouse, Utility/Piping Tunnels, Security/Lighting Poles, Manholes, Duct Banks; SBO Structures Such As Transmission Towers, Startup Tower Circuit Breaker Foundation, Electrical Enclosure)

New,

Modified, Deleted, Structure Edited SRP Item and/or Aging Aging Management Further Item Item (Table, ID) Component Material Environment Effect/Mechanism Program (AMP)/TLAA Evaluation M III.A3.TP-204 3.5-1, 043 Concrete Concrete Any Cracking due to Plant-specific aging Yes (inaccessible expansion from management program areas): all reaction with or AMP XI.S6, aggregates Structures Monitoring, enhanced as necessary III.A3.TP-212 3.5-1, 065 Concrete Concrete Groundwater/soil Cracking; loss of AMP XI.S6, "Structures No (inaccessible bond; and loss of Monitoring" areas): below- material (spalling, grade exterior; scaling) due to foundation corrosion of embedded steel III.A3.TP-29 3.5-1, 067 Concrete Concrete Groundwater/soil Increase in porosity AMP XI.S6, "Structures No (inaccessible and permeability; Monitoring" areas): below- cracking; loss of grade exterior; material (spalling, foundation scaling) due to aggressive chemical attack M III.A3.TP-67 3.5-1, 047 Concrete Concrete Water - flowing Increase in porosity Plant-specific aging Yes (inaccessible and permeability; management program areas): exterior loss of strength due or AMP XI.S6, above- and to leaching of Structures Monitoring, below-grade; calcium hydroxide enhanced as necessary foundation and carbonation M III.A3.TP-108 3.5-1, 042 Concrete Concrete Air - outdoor, Loss of material Plant-specific aging Yes (inaccessible groundwater/soil (spalling, scaling) management program areas): and cracking due to to be evaluated for foundation freeze-thaw plants in moderate to severe weathering Page 10 of 33 conditions or AMP XI.S6, Structures Monitoring, enhanced as necessary

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A3 Group 3 Structures (Auxiliary Bldg., Diesel Generator Bldg., Radwaste Bldg., Turbine Bldg., Switchgear Rm., Yard Structures Such As AFW Pumphouse, Utility/Piping Tunnels, Security/Lighting Poles, Manholes, Duct Banks; SBO Structures Such As Transmission Towers, Startup Tower Circuit Breaker Foundation, Electrical Enclosure)

New,

Modified, Deleted, Structure Edited SRP Item and/or Aging Aging Management Further Item Item (Table, ID) Component Material Environment Effect/Mechanism Program (AMP)/TLAA Evaluation EM III.A3.TP-114 3.5-1, 048 Concrete: all Concrete Air - indoor Reduction of Plant-specific aging Yes uncontrolled strength and management program modulus due to to be evaluated if elevated temperature limits temperature (>150°F exceeded or AMP general; >200°F XI.S6, Structures local) Monitoring, enhanced as necessary E III.A3.TP-30 3.5-1, 044 Concrete: all Concrete Soil Cracking and AMP XI.S6, "Structures Yes distortion due to Monitoring" increased stress levels from settlement E III.A3.TP-31 3.5-1, 046 Concrete: Concrete; Water - flowing Reduction of AMP XI.S6, "Structures Yes foundation; porous foundation strength Monitoring" subfoundation concrete and cracking due to differential settlement and erosion of porous concrete subfoundation III.A3.TP-28 3.5-1, 067 Concrete: Concrete Air - indoor Increase in porosity AMP XI.S6, "Structures No interior; above- uncontrolled, air - and permeability; Monitoring" grade exterior outdoor cracking; loss of material (spalling, scaling) due to aggressive chemical attack III.A3.T-12 3.5-1, 070 Masonry walls: Concrete Air - indoor Cracking due to AMP XI.S5, "Masonry No Page 11 of 33 all block uncontrolled, air - restraint shrinkage, Walls" outdoor creep, and aggressive environment

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A3 Group 3 Structures (Auxiliary Bldg., Diesel Generator Bldg., Radwaste Bldg., Turbine Bldg., Switchgear Rm., Yard Structures Such As AFW Pumphouse, Utility/Piping Tunnels, Security/Lighting Poles, Manholes, Duct Banks; SBO Structures Such As Transmission Towers, Startup Tower Circuit Breaker Foundation, Electrical Enclosure)

New,

Modified, Deleted, Structure Edited SRP Item and/or Aging Aging Management Further Item Item (Table, ID) Component Material Environment Effect/Mechanism Program (AMP)/TLAA Evaluation N III.A3.TP-34 3.5-1, 071 Masonry walls: Concrete Air - outdoor Loss of material AMP XI.S5, "Masonry No all block (spalling, scaling) Walls" and cracking due to freeze-thaw E III.A3.TP-302 3.5-1, 077 Steel Steel Air - indoor Loss of material due AMP XI.S6, "Structures No components: uncontrolled, air - to corrosion Monitoring" all structural outdoor steel III.A3.TP-219 3.5-1, 079 Steel Steel Soil, groundwater Loss of material due AMP XI.S6, "Structures No components: to corrosion Monitoring" piles E III.A3.TP-261 3.5-1, 088 Structural Any Any Loss of preload due AMP XI.S6, "Structures No bolting to self-loosening Monitoring" M III.A3.TP-248 3.5-1, 080 Structural Steel Air - indoor Loss of material due AMP XI.S6, "Structures No bolting uncontrolled, air - to general, pitting, Monitoring" outdoor crevice corrosion III.A3.TP-274 3.5-1, 082 Structural Steel; Air - outdoor Loss of material due AMP XI.S6, "Structures No bolting galvanized to general, pitting, Monitoring" steel crevice corrosion D III.A3.TP-300 Page 12 of 33

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A4 Group Structures (Containment Internal Structures, Excluding Refueling Canal)

New,

Modified, Deleted, Structure Edited SRP Item and/or Aging Aging Management Further Item Item (Table, ID) Component Material Environment Effect/Mechanism Program (AMP)/TLAA Evaluation E III.A4.TP-25 3.5-1, 054 Concrete Concrete Any Cracking due to AMP XI.S6, "Structures No (accessible areas): expansion from Monitoring" all reaction with aggregates III.A4.TP-26 3.5-1, 066 Concrete Concrete Air - indoor Cracking; loss of AMP XI.S6, "Structures No (accessible areas): uncontrolled, bond; and loss of Monitoring" interior and above- air - outdoor material (spalling, grade exterior scaling) due to corrosion of embedded steel M III.A4.TP-204 3.5-1, 043 Concrete Concrete Any Cracking due to Plant-specific aging Yes (inaccessible expansion from management program or areas): all reaction with AMP XI.S6, Structures aggregates Monitoring, enhanced as necessary M III.A4.TP-305 3.5-1, 047 Concrete Concrete Water - Increase in porosity Plant-specific aging Yes (inaccessible flowing and permeability; loss management program or areas): exterior of strength due to AMP XI.S6, Structures above- and below- leaching of calcium Monitoring, enhanced grade; foundation hydroxide and as necessary carbonation EM III.A4.TP-114 3.5-1, 048 Concrete: all Concrete Air - indoor Reduction of strength Plant-specific aging Yes uncontrolled and modulus due to management program to elevated temperature be evaluated if

(>150°F general; temperature limits

>200°F local) exceeded or AMP XI.S6, Structures Monitoring, enhanced as necessary E III.A4.TP-30 3.5-1, 044 Concrete: all Concrete Soil Cracking and AMP XI.S6, "Structures Yes distortion due to Monitoring" increased stress Page 13 of 33 levels from settlement

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A4 Group Structures (Containment Internal Structures, Excluding Refueling Canal)

New,

Modified, Deleted, Structure Edited SRP Item and/or Aging Aging Management Further Item Item (Table, ID) Component Material Environment Effect/Mechanism Program (AMP)/TLAA Evaluation III.A4.TP-28 3.5-1, 067 Concrete: interior; Concrete Air - indoor Increase in porosity AMP XI.S6, "Structures No above-grade uncontrolled, and permeability; Monitoring" exterior air - outdoor cracking; loss of material (spalling, scaling) due to aggressive chemical attack N III.A4.T-35 3.5-1, 097 Group 4: Concrete Concrete Air - indoor Reduction of Plant-specific aging Yes (reactor cavity area uncontrolled strength; loss of management program, proximate to the mechanical or other selected AMPs, reactor vessel): properties due to enhanced as necessary reactor irradiation (i.e.,

(primary/biological) radiation interactions shield wall; with material and sacrificial shield radiation-induced wall; reactor vessel heating) support/pedestal structure M III.A4.TP-301 3.5-1, 073 Service Level I Coatings Air - indoor Loss of coating or AMP XI.S8, "Protective No coatings uncontrolled, lining integrity due to Coating Monitoring and treated water blistering, cracking, Maintenance" flaking, peeling, delamination, rusting, physical damage M III.A4.TP-35 3.5-1, 076 Sliding surfaces: Lubrite; Air - indoor Loss of mechanical AMP XI.S6, "Structures No radial beam seats Fluorogold; uncontrolled function due to Monitoring" in BWR drywell Lubrofluor corrosion, distortion, dirt or debris accumulation, overload, wear E III.A4.TP-302 3.5-1, 077 Steel components: Steel Air - indoor Loss of material due AMP XI.S6, "Structures No Page 14 of 33 all structural steel uncontrolled, to corrosion Monitoring" air - outdoor E III.A4.TP-261 3.5-1, 088 Structural bolting Any Any Loss of preload due AMP XI.S6, "Structures No to self-loosening Monitoring"

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A4 Group Structures (Containment Internal Structures, Excluding Refueling Canal)

New,

Modified, Deleted, Structure Edited SRP Item and/or Aging Aging Management Further Item Item (Table, ID) Component Material Environment Effect/Mechanism Program (AMP)/TLAA Evaluation M III.A4.TP-248 3.5-1, 080 Structural bolting Steel Air - indoor Loss of material due AMP XI.S6, "Structures No uncontrolled, to general, pitting, Monitoring" air - outdoor crevice corrosion III.A4.TP-274 3.5-1, 082 Structural bolting Steel; Air - outdoor Loss of material due AMP XI.S6, "Structures No galvanized to general, pitting, Monitoring" steel crevice corrosion D III.A4.TP-300 III STRUCTURES AND COMPONENT SUPPORTS Table A5 Group 5 Structures (Fuel Storage Facility, Refueling Canal)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation E III.A5.TP-25 3.5-1, 054 Concrete Concrete Any Cracking due to AMP XI.S6, No (accessible expansion from "Structures areas): all reaction with Monitoring" aggregates III.A5.TP-27 3.5-1, 065 Concrete Concrete Groundwater/soil Cracking; loss of AMP XI.S6, No (accessible bond; and loss of "Structures areas): below- material (spalling, Monitoring" grade exterior; scaling) due to foundation corrosion of embedded steel III.A5.TP-23 3.5-1, 064 Concrete Concrete Air - outdoor Loss of material AMP XI.S6, No Page 15 of 33 (accessible (spalling, scaling) and "Structures areas): exterior cracking due to Monitoring" above- and freeze-thaw below-grade; foundation

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A5 Group 5 Structures (Fuel Storage Facility, Refueling Canal)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation III.A5.TP-24 3.5-1, 063 Concrete Concrete Water - flowing Increase in porosity AMP XI.S6, No (accessible and permeability; loss "Structures areas): exterior of strength due to Monitoring" above- and leaching of calcium below-grade; hydroxide and foundation carbonation III.A5.TP-26 3.5-1, 066 Concrete Concrete Air - indoor Cracking; loss of AMP XI.S6, No (accessible uncontrolled, air bond; and loss of "Structures areas): interior - outdoor material (spalling, Monitoring" and above- scaling) due to grade exterior corrosion of embedded steel M III.A5.TP-204 3.5-1, 043 Concrete Concrete Any Cracking due to Plant-specific Yes (inaccessible expansion from aging management areas): all reaction with program or AMP aggregates XI.S6, Structures Monitoring, enhanced as necessary III.A5.TP-212 3.5-1, 065 Concrete Concrete Groundwater/soil Cracking; loss of AMP XI.S6, No (inaccessible bond; and loss of "Structures areas): below- material (spalling, Monitoring" grade exterior; scaling) due to foundation corrosion of embedded steel III.A5.TP-29 3.5-1, 067 Concrete Concrete Groundwater/soil Increase in porosity AMP XI.S6, No (inaccessible and permeability; "Structures areas): below- cracking; loss of Monitoring" grade exterior; material (spalling, foundation scaling) due to aggressive chemical Page 16 of 33 attack

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A5 Group 5 Structures (Fuel Storage Facility, Refueling Canal)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M III.A5.TP-67 3.5-1, 047 Concrete Concrete Water - flowing Increase in porosity Plant-specific Yes (inaccessible and permeability; loss aging management areas): exterior of strength due to program or AMP above- and leaching of calcium XI.S6, Structures below-grade; hydroxide and Monitoring, foundation carbonation enhanced as necessary M III.A5.TP-108 3.5-1, 042 Concrete Concrete Air - outdoor, Loss of material Plant-specific Yes (inaccessible groundwater/soil (spalling, scaling) and aging management areas): cracking due to program to be foundation freeze-thaw evaluated for plants in moderate to severe weathering conditions or AMP XI.S6, Structures Monitoring, enhanced as necessary EM III.A5.TP-114 3.5-1, 048 Concrete: all Concrete Air - indoor Reduction of strength Plant-specific Yes uncontrolled and modulus due to aging management elevated temperature program to be

(>150°F general; evaluated if

>200°F local) temperature limits exceeded or AMP XI.S6, Structures Monitoring, enhanced as necessary E III.A5.TP-30 3.5-1, 044 Concrete: all Concrete Soil Cracking and AMP XI.S6, Yes distortion due to "Structures Page 17 of 33 increased stress Monitoring" levels from settlement

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A5 Group 5 Structures (Fuel Storage Facility, Refueling Canal)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation E III.A5.TP-31 3.5-1, 046 Concrete: Concrete; Water - flowing Reduction of AMP XI.S6, Yes foundation; porous foundation strength "Structures subfoundation concrete and cracking due to Monitoring" differential settlement and erosion of porous concrete subfoundation III.A5.TP-28 3.5-1, 067 Concrete: Concrete Air - indoor Increase in porosity AMP XI.S6, No interior; above- uncontrolled, air and permeability; "Structures grade exterior - outdoor cracking; loss of Monitoring" material (spalling, scaling) due to aggressive chemical attack III.A5.T-12 3.5-1, 070 Masonry walls: Concrete block Air - indoor Cracking due to AMP XI.S5, No all uncontrolled, air restraint shrinkage, "Masonry Walls"

- outdoor creep, and aggressive environment III.A5.TP-34 3.5-1, 071 Masonry walls: Concrete block Air - outdoor Loss of material AMP XI.S5, No all (spalling, scaling) and "Masonry Walls" cracking due to freeze-thaw M III.A5.T-14 3.5-1, 078 Stainless steel Stainless steel Treated water, Cracking due to SCC; AMP XI.M2, No fuel pool liner treated borated loss of material due "Water Chemistry,"

water to pitting and crevice and monitoring of corrosion the spent fuel pool water level and leakage from the leak chase channels.

Page 18 of 33 E III.A5.TP-302 3.5-1, 077 Steel Steel Air - indoor Loss of material due AMP XI.S6, No components: all uncontrolled, air to corrosion "Structures structural steel - outdoor Monitoring" E III.A5.TP-261 3.5-1, 088 Structural Any Any Loss of preload due AMP XI.S6, No bolting to self-loosening "Structures Monitoring"

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A5 Group 5 Structures (Fuel Storage Facility, Refueling Canal)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M III.A5.TP-248 3.5-1, 080 Structural Steel Air - indoor Loss of material due AMP XI.S6, No bolting uncontrolled, air to general, pitting, "Structures

- outdoor crevice corrosion Monitoring" III.A5.TP-274 3.5-1, 082 Structural Steel; Air - outdoor Loss of material due AMP XI.S6, No bolting galvanized to general, pitting, "Structures steel crevice corrosion Monitoring" D III.A5.TP-300 III STRUCTURES AND COMPONENT SUPPORTS Table A6 Group 6 Structures (Water-Control Structures)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation N III.A6.T-34 3.5-1, 096 Concrete Concrete Any Cracking due to AMP XI.S7, No (accessible areas): expansion from "Inspection of all reaction with Water-Control aggregates Structures Associated with Nuclear Power Plants" N III.A6.TP-25 3.5-1, 054 Concrete Concrete Any Cracking due to AMP XI.S6, No (accessible areas): expansion from "Structures all reaction with Monitoring" aggregates Page 19 of 33

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A6 Group 6 Structures (Water-Control Structures)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation E III.A6.TP-38 3.5-1, 059 Concrete Concrete Any Cracking; loss of AMP XI.S7, No (accessible areas): bond; and loss of "Inspection of all material (spalling, Water-Control scaling) due to Structures corrosion of Associated with embedded steel Nuclear Power Plants" or the FERC / US Army Corp of Engineers dam inspections and maintenance programs.

M III.A6.TP-36 3.5-1, 060 Concrete Concrete Any Loss of material AMP XI.S7, No (accessible areas): (spalling, scaling) "Inspection of exterior above- and cracking due to Water-Control and below-grade; freeze-thaw Structures foundation Associated with Nuclear Power Plants" or the FERC / US Army Corp of Engineers dam inspections and maintenance programs.

M III.A6.TP-37 3.5-1, 061 Concrete Concrete Any Increase in porosity AMP XI.S7, No (accessible areas): and permeability; "Inspection of exterior above- loss of strength due Water-Control and below-grade; to leaching of Structures foundation; interior calcium hydroxide Associated with slab and carbonation Nuclear Power Plants" or the Page 20 of 33 FERC / US Army Corp of Engineers dam inspections and maintenance programs.

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A6 Group 6 Structures (Water-Control Structures)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation III.A6.TP-104 3.5-1, 065 Concrete Concrete Air - indoor Cracking; loss of AMP XI.S6, No (inaccessible uncontrolled, air bond; and loss of "Structures areas): all - outdoor, material (spalling, Monitoring" groundwater/soil scaling) due to corrosion of embedded steel M III.A6.TP-220 3.5-1, 050 Concrete Concrete Any Cracking due to Plant-specific Yes (inaccessible expansion from aging management areas): all reaction with program or AMP aggregates XI.S6, Structures Monitoring, enhanced as necessary III.A6.TP-107 3.5-1, 067 Concrete Concrete Groundwater/soil Increase in porosity AMP XI.S6, No (inaccessible and permeability; "Structures areas): all cracking; loss of Monitoring" material (spalling, scaling) due to aggressive chemical attack M III.A6.TP-110 3.5-1, 049 Concrete Concrete Air - outdoor, Loss of material Plant-specific Yes (inaccessible groundwater/soil (spalling, scaling) aging management areas): exterior and cracking due to program to be above- and below- freeze-thaw evaluated for grade; foundation; plants in moderate interior slab to severe weathering conditions or AMP XI.S6, Structures Monitoring, enhanced as Page 21 of 33 necessary

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A6 Group 6 Structures (Water-Control Structures)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M III.A6.TP-109 3.5-1, 051 Concrete Concrete Water - flowing Increase in porosity Plant-specific Yes (inaccessible and permeability; aging management areas): exterior loss of strength due program or AMP above- and below- to leaching of XI.S6, Structures grade; foundation; calcium hydroxide Monitoring, interior slab and carbonation enhanced as necessary E III.A6.TP-30 3.5-1, 044 Concrete: all Concrete Soil Cracking and AMP XI.S6, Yes distortion due to "Structures increased stress Monitoring" levels from settlement E III.A6.T-20 3.5-1, 056 Concrete: exterior Concrete Water - flowing Loss of material due AMP XI.S7, No above- and below- to abrasion; "Inspection of grade; foundation; cavitation Water-Control interior slab Structures Associated with Nuclear Power Plants" or the FERC / US Army Corp of Engineers dam inspections and maintenance programs.

E III.A6.TP-31 3.5-1, 046 Concrete: Concrete; Water - flowing Reduction of AMP XI.S6, Yes foundation; porous foundation strength "Structures subfoundation concrete and cracking due to Monitoring" differential settlement and erosion of porous concrete subfoundation Page 22 of 33

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A6 Group 6 Structures (Water-Control Structures)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M III.A6.T-22 3.5-1, 058 Earthen water- Various Air - outdoor, Loss of material; loss AMP XI.S7, No control structures: water - flowing of form due to "Inspection of dams; or standing erosion, settlement, Water-Control embankments; sedimentation, frost Structures reservoirs; action, waves, Associated with channels; canals; currents, surface Nuclear Power ponds runoff, seepage Plants" or the FERC / US Army Corp of Engineers dam inspections and maintenance programs.

E III.A6.TP-223 3.5-1, 062 Group 6: Wooden Wood Air - outdoor, Loss of material; AMP XI.S7, No Piles; sheeting water - flowing change in material "Inspection of or standing, properties due to Water-Control groundwater/soil weathering, chemical Structures degradation, and Associated with insect infestation Nuclear Power repeated wetting and Plants" or the drying, fungal decay FERC / US Army Corp of Engineers dam inspections and maintenance programs.

III.A6.T-12 3.5-1, 070 Masonry walls: all Concrete Air - indoor Cracking due to AMP XI.S5, No block uncontrolled, air restraint shrinkage, "Masonry Walls"

- outdoor creep, and aggressive environment N III.A6.TP-34 3.5-1, 071 Masonry walls: all Concrete Air - outdoor Loss of material AMP XI.S5, No block (spalling, scaling) "Masonry Walls" Page 23 of 33 and cracking due to freeze-thaw

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A6 Group 6 Structures (Water-Control Structures)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M III.A6.TP-7 3.5-1, 072 Seals; gaskets; Elastomer, Any Loss of sealing due AMP XI.S6, No moisture barriers rubber and to wear, damage, "Structures (caulking, flashing, other similar erosion, tear, surface Monitoring" and other materials cracks, other defects sealants)

E III.A6.TP-261 3.5-1, 088 Structural bolting Any Any Loss of preload due AMP XI.S6, No to self-loosening "Structures Monitoring" M III.A6.TP-248 3.5-1, 080 Structural bolting Steel Air - indoor Loss of material due AMP XI.S6, No uncontrolled, air to general, pitting, "Structures

- outdoor crevice corrosion Monitoring" E III.A6.TP-221 3.5-1, 083 Structural bolting Steel Air - indoor Loss of material due AMP XI.S7, No uncontrolled, air to general, pitting, "Inspection of

- outdoor, water crevice corrosion Water-Control

- flowing or Structures standing Associated with Nuclear Power Plants" or the FERC / US Army Corp of Engineers dam inspections and maintenance programs.

Page 24 of 33

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A7 Group 7 Structures (Concrete Tanks and Missile Barriers)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation E III.A7.TP-25 3.5-1, 054 Concrete Concrete Any Cracking due to AMP XI.S6, No (accessible expansion from "Structures areas): all reaction with Monitoring" aggregates III.A7.TP-27 3.5-1, 065 Concrete Concrete Groundwater/soil Cracking; loss of AMP XI.S6, No (accessible bond; and loss of "Structures areas): below- material (spalling, Monitoring" grade exterior; scaling) due to foundation corrosion of embedded steel III.A7.TP-23 3.5-1, 064 Concrete Concrete Air - outdoor Loss of material AMP XI.S6, No (accessible (spalling, scaling) "Structures areas): exterior and cracking due to Monitoring" above- and freeze-thaw below-grade; foundation III.A7.TP-24 3.5-1, 063 Concrete Concrete Water - flowing Increase in porosity AMP XI.S6, No (accessible and permeability; "Structures areas): exterior loss of strength due Monitoring" above- and to leaching of calcium below-grade; hydroxide and foundation carbonation III.A7.TP-26 3.5-1, 066 Concrete Concrete Air - indoor Cracking; loss of AMP XI.S6, No (accessible uncontrolled, air bond; and loss of "Structures areas): interior - outdoor material (spalling, Monitoring" and above- scaling) due to grade exterior corrosion of embedded steel M III.A7.TP-204 3.5-1, 043 Concrete Concrete Any Cracking due to Plant-specific Yes (inaccessible expansion from aging management areas): all reaction with program or AMP Page 25 of 33 aggregates XI.S6, Structures Monitoring, enhanced as necessary

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A7 Group 7 Structures (Concrete Tanks and Missile Barriers)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation III.A7.TP-212 3.5-1, 065 Concrete Concrete Groundwater/soil Cracking; loss of AMP XI.S6, No (inaccessible bond; and loss of "Structures areas): below- material (spalling, Monitoring" grade exterior; scaling) due to foundation corrosion of embedded steel III.A7.TP-29 3.5-1, 067 Concrete Concrete Groundwater/soil Increase in porosity AMP XI.S6, No (inaccessible and permeability; "Structures areas): below- cracking; loss of Monitoring" grade exterior; material (spalling, foundation scaling) due to aggressive chemical attack M III.A7.TP-67 3.5-1, 047 Concrete Concrete Water - flowing Increase in porosity Plant-specific Yes (inaccessible and permeability; aging management areas): exterior loss of strength due program or AMP above- and to leaching of calcium XI.S6, Structures below-grade; hydroxide and Monitoring, foundation carbonation enhanced as necessary M III.A7.TP-108 3.5-1, 042 Concrete Concrete Air - outdoor, Loss of material Plant-specific Yes (inaccessible groundwater/soil (spalling, scaling) aging management areas): and cracking due to program to be foundation freeze-thaw evaluated for plants in moderate to severe weathering conditions or AMP XI.S6, Structures Monitoring, enhanced as Page 26 of 33 necessary E III.A7.TP-30 3.5-1, 044 Concrete: all Concrete Soil Cracking and AMP XI.S6, Yes distortion due to "Structures increased stress Monitoring" levels from settlement

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A7 Group 7 Structures (Concrete Tanks and Missile Barriers)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation E III.A7.TP-31 3.5-1, 046 Concrete: Concrete; Water - flowing Reduction of AMP XI.S6, Yes foundation; porous foundation strength "Structures subfoundation concrete and cracking due to Monitoring" differential settlement and erosion of porous concrete subfoundation III.A7.TP-28 3.5-1, 067 Concrete: Concrete Air - indoor Increase in porosity AMP XI.S6, No interior; above- uncontrolled, air and permeability; "Structures grade exterior - outdoor cracking; loss of Monitoring" material (spalling, scaling) due to aggressive chemical attack E III.A7.TP-302 3.5-1, 077 Steel Steel Air - indoor Loss of material due AMP XI.S6, No components: all uncontrolled, air to corrosion "Structures structural steel - outdoor Monitoring" E III.A7.T-23 3.5-1, 052 Steel Stainless steel Water - standing Cracking due to Plant-specific Yes components: SCC; loss of material aging management tank liner due to pitting and program crevice corrosion E III.A7.TP-261 3.5-1, 088 Structural Any Any Loss of preload due AMP XI.S6, No bolting to self-loosening "Structures Monitoring" M III.A7.TP-248 3.5-1, 080 Structural Steel Air - indoor Loss of material due AMP XI.S6, No bolting uncontrolled, air to general, pitting, "Structures

- outdoor crevice corrosion Monitoring" III.A7.TP-274 3.5-1, 082 Structural Steel; Air - outdoor Loss of material due AMP XI.S6, No bolting galvanized to general, pitting, "Structures steel crevice corrosion Monitoring" D III.A7.TP-300 Page 27 of 33

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A8 Group 8 Structures (Steel Tanks and Missile Barriers)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation E III.A8.TP-25 3.5-1, 054 Concrete Concrete Any Cracking due to AMP XI.S6, No (accessible expansion from "Structures areas): all reaction with Monitoring" aggregates III.A8.TP-27 3.5-1, 065 Concrete Concrete Groundwater/soil Cracking; loss of AMP XI.S6, No (accessible bond; and loss of "Structures areas): below- material (spalling, Monitoring" grade exterior; scaling) due to foundation corrosion of embedded steel III.A8.TP-23 3.5-1, 064 Concrete Concrete Air - outdoor Loss of material AMP XI.S6, No (accessible (spalling, scaling) "Structures areas): exterior and cracking due to Monitoring" above- and freeze-thaw below-grade; foundation III.A8.TP-24 3.5-1, 063 Concrete Concrete Water - flowing Increase in porosity AMP XI.S6, No (accessible and permeability; "Structures areas): exterior loss of strength due Monitoring" above- and to leaching of below-grade; calcium hydroxide foundation and carbonation M III.A8.TP-204 3.5-1, 043 Concrete Concrete Any Cracking due to Plant-specific aging Yes (inaccessible expansion from management areas): all reaction with program or AMP aggregates XI.S6, Structures Monitoring, enhanced as necessary III.A8.TP-212 3.5-1, 065 Concrete Concrete Groundwater/soil Cracking; loss of AMP XI.S6, No (inaccessible bond; and loss of "Structures Page 28 of 33 areas): below- material (spalling, Monitoring" grade exterior; scaling) due to foundation corrosion of embedded steel

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A8 Group 8 Structures (Steel Tanks and Missile Barriers)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation III.A8.TP-29 3.5-1, 067 Concrete Concrete Groundwater/soil Increase in porosity AMP XI.S6, No (inaccessible and permeability; "Structures areas): below- cracking; loss of Monitoring" grade exterior; material (spalling, foundation scaling) due to aggressive chemical attack M III.A8.TP-67 3.5-1, 047 Concrete Concrete Water - flowing Increase in porosity Plant-specific aging Yes (inaccessible and permeability; management areas): exterior loss of strength due program or AMP above- and to leaching of XI.S6, Structures below-grade; calcium hydroxide Monitoring, foundation and carbonation enhanced as necessary M III.A8.TP-108 3.5-1, 042 Concrete Concrete Air - outdoor, Loss of material Plant-specific aging Yes (inaccessible groundwater/soil (spalling, scaling) management areas): and cracking due to program to be foundation freeze-thaw evaluated for plants in moderate to severe weathering conditions or AMP XI.S6, Structures Monitoring, enhanced as necessary E III.A8.TP-30 3.5-1, 044 Concrete: all Concrete Soil Cracking and AMP XI.S6, Yes distortion due to "Structures increased stress Monitoring" levels from settlement Page 29 of 33

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A8 Group 8 Structures (Steel Tanks and Missile Barriers)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation E III.A8.TP-31 3.5-1, 046 Concrete: Concrete; Water - flowing Reduction of AMP XI.S6, Yes foundation; porous foundation strength "Structures subfoundation concrete and cracking due to Monitoring" differential settlement and erosion of porous concrete subfoundation E III.A8.TP-302 3.5-1, 077 Steel Steel Air - indoor Loss of material due AMP XI.S6, No components: uncontrolled, air to corrosion "Structures all structural - outdoor Monitoring" steel E III.A8.T-23 3.5-1, 052 Steel Stainless steel Water - standing Cracking due to Plant-specific aging Yes components: SCC; loss of material management tank liner due to pitting and program crevice corrosion E III.A8.TP-261 3.5-1, 088 Structural Any Any Loss of preload due AMP XI.S6, No bolting to self-loosening "Structures Monitoring" M III.A8.TP-248 3.5-1, 080 Structural Steel Air - indoor Loss of material due AMP XI.S6, No bolting uncontrolled, air to general, pitting, "Structures

- outdoor crevice corrosion Monitoring" III.A8.TP-274 3.5-1, 082 Structural Steel; Air - outdoor Loss of material due AMP XI.S6, No bolting galvanized to general, pitting, "Structures steel crevice corrosion Monitoring" D III.A8.TP-300 Page 30 of 33

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A9 Group 9 Structures (BWR Unit Vent Stack)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation E III.A9.TP-25 3.5-1, 054 Concrete Concrete Any Cracking due to AMP XI.S6, No (accessible expansion from "Structures areas): all reaction with Monitoring" aggregates III.A9.TP-27 3.5-1, 065 Concrete Concrete Groundwater/soil Cracking; loss of AMP XI.S6, No (accessible bond; and loss of "Structures areas): below- material (spalling, Monitoring" grade exterior; scaling) due to foundation corrosion of embedded steel III.A9.TP-23 3.5-1, 064 Concrete Concrete Air - outdoor Loss of material AMP XI.S6, No (accessible (spalling, scaling) "Structures areas): exterior and cracking due to Monitoring" above- and freeze-thaw below-grade; foundation III.A9.TP-24 3.5-1, 063 Concrete Concrete Water - flowing Increase in porosity AMP XI.S6, No (accessible and permeability; "Structures areas): exterior loss of strength due Monitoring" above- and to leaching of calcium below-grade; hydroxide and foundation carbonation III.A9.TP-26 3.5-1, 066 Concrete Concrete Air - indoor Cracking; loss of AMP XI.S6, No (accessible uncontrolled, air bond; and loss of "Structures areas): interior - outdoor material (spalling, Monitoring" and above- scaling) due to grade exterior corrosion of embedded steel M III.A9.TP-204 3.5-1, 043 Concrete Concrete Any Cracking due to Plant-specific aging Yes (inaccessible expansion from management areas): all reaction with program or AMP Page 31 of 33 aggregates XI.S6, Structures Monitoring, enhanced as necessary

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A9 Group 9 Structures (BWR Unit Vent Stack)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation III.A9.TP-212 3.5-1, 065 Concrete Concrete Groundwater/soil Cracking; loss of AMP XI.S6, No (inaccessible bond; and loss of "Structures areas): below- material (spalling, Monitoring" grade exterior; scaling) due to foundation corrosion of embedded steel III.A9.TP-29 3.5-1, 067 Concrete Concrete Groundwater/soil Increase in porosity AMP XI.S6, No (inaccessible and permeability; "Structures areas): below- cracking; loss of Monitoring" grade exterior; material (spalling, foundation scaling) due to aggressive chemical attack M III.A9.TP-67 3.5-1, 047 Concrete Concrete Water - flowing Increase in porosity Plant-specific aging Yes (inaccessible and permeability; management areas): exterior loss of strength due program or AMP above- and to leaching of calcium XI.S6, Structures below-grade; hydroxide and Monitoring, foundation carbonation enhanced as necessary M III.A9.TP-108 3.5-1, 042 Concrete Concrete Air - outdoor, Loss of material Plant-specific aging Yes (inaccessible groundwater/soil (spalling, scaling) management areas): and cracking due to program to be foundation freeze-thaw evaluated for plants in moderate to severe weathering conditions or AMP XI.S6, Structures Monitoring, enhanced as necessary Page 32 of 33 E III.A9.TP-30 3.5-1, 044 Concrete: all Concrete Soil Cracking and AMP XI.S6, Yes distortion due to "Structures increased stress Monitoring" levels from settlement

III STRUCTURES AND COMPONENT SUPPORTS SLR-ISG-2021-03-STRUCTURES: Appendix D Table A9 Group 9 Structures (BWR Unit Vent Stack)

New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation E III.A9.TP-31 3.5-1, 046 Concrete: Concrete; Water - flowing Reduction in AMP XI.S6, Yes foundation; porous foundation strength, "Structures subfoundation concrete cracking due to Monitoring" differential settlement, erosion of porous concrete subfoundation III.A9.TP-28 3.5-1, 067 Concrete: Concrete Air - indoor Increase in porosity AMP XI.S6, No interior; above- uncontrolled, air and permeability; "Structures grade exterior - outdoor cracking; loss of Monitoring" material (spalling, scaling) due to aggressive chemical attack E III.A9.TP-261 3.5-1, 088 Structural Any Any Loss of preload due AMP XI.S6, No bolting to self-loosening "Structures Monitoring" M III.A9.TP-248 3.5-1, 080 Structural Steel Air - indoor Loss of material due AMP XI.S6, No bolting uncontrolled, air to general, pitting, "Structures

- outdoor crevice corrosion Monitoring" III.A9.TP-274 3.5-1, 082 Structural Steel; Air - outdoor Loss of material due AMP XI.S6, No bolting galvanized to general, pitting, "Structures steel crevice corrosion Monitoring" D III.A9.TP-300 Page 33 of 33

APPENDIX E REVISIONS TO SRP-SLR SECTION 3.5 TO ALLOW OPTIONS IN LIEU OF PLANT-SPECIFIC AGING MANAGEMENT Summary of Revisions This appendix modifies NUREG-2192, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants (SRP-SLR) Section 3.5 including Table 3.5-1, Summary of Aging Management Programs for Containments, Structures and Component Supports Evaluated in Chapters II and III of the GALL-SLR Report, to manage the effects of aging in concrete for the following:

• reduction of strength and modulus of elasticity due to elevated temperature (greater than 66 degrees Celsius (150 degrees Fahrenheit) general: greater than 93 degrees Celsius (200 degrees Fahrenheit) local)

• loss of material (spalling, scaling) and cracking due to freeze-thaw

• cracking due to expansion from reaction with aggregates

• increase in porosity and permeability; loss of strength due to leaching of calcium hydroxide and carbonation

• reduction of strength; loss of mechanical properties due to irradiation (i.e., radiation interactions with material and radiation-induced heating) for boiling-water reactor (BWR) and pressurized-water reactor (PWR) components in question, including those located in inaccessible areas Appendix A to this ISG, modified SRP-SLR Table 3.5-1 and GALL-SLR Report AMR tables to provide the option to perform a further evaluation based on ASME Code Section III, Division 1, Subsection NE, fatigue waiver analysis for containment metallic pressure-retaining boundary components that are subject to cyclic loading but have no current licensing basis (CLB) fatigue analysis.

Basis for Revisions Modifications to GALL-SLR Report AMR items and SRP-SLR Table 3.5-1 line items with associated further evaluations provide the option to use plant-specific enhancements to GALL-SLR Report AMP XI.S2, ASME Section XI Subsection IWL, AMP XI.S6, Structures Monitoring, or other AMPs in lieu of a plant-specific AMP. The option to use plant-specific enhancements to GALL-SLR Report AMPs increases the efficiency of subsequent license renewal application (SLRA) reviews by limiting the use of AMR Note E designations for plant-specific aging management activities when aging effects are managed by a plant-specific AMP.

Appendix A to this ISG provides the basis for revisions with regard to fatigue analysis.

AMP Revisions None

SLR-ISG-2021-03-STRUCTURES: Appendix E Page 2 of 31 Revisions to FSAR Supplement None Revisions to SRP-SLR Section 3.5 3.5.2.2.1.2 Reduction of Strength and Modulus Due to Elevated Temperature Reduction of strength and modulus of concrete due to elevated temperatures could occur in PWR and BWR concrete and steel containments. The implementation of 10 CFR 50.55a and ASME Code Section XI, Subsection IWL would not be able to identify the reduction of strength and modulus of concrete due to elevated temperature. Subsection CC-3440 of ASME Code Section III, Division 2, specifies the concrete temperature limits for normal operation or any other long-term period. Further evaluation is recommended to determine the need for of a plant-specific AMP if or plant-specific enhancements to ASME Code Section XI Subsection IWL and/or Structures Monitoring AMPs, essential to manage these aging effects for any portions of the concrete containment components that exceeds specified temperature limits {i.e., general area temperature greater than 66 degrees °C (Celsius) [(150 degrees°F (Fahrenheit)] and local area temperature greater than 93 degrees Celsius °C (200 degrees Fahrenheit)°F)}. Higher temperatures may be allowed if tests and/or calculations are provided to evaluate the reduction in strength and modulus of elasticity and these reductions are applied to the design calculations.

Acceptance criteria are described in Branch Technical Position (BTP) RLSB (License Renewal and Standardization Branch)-1, Aging Management Review - Generic, July 2017 (Appendix A.1 of this SRP-SLR).

3.5.2.2.1.7 Loss of Material (Scaling, Spalling) and Cracking Due to Freeze-Thaw Loss of material (scaling, spalling) and cracking due to freeze-thaw could occur in inaccessible areas of PWR and BWR concrete containments. Further evaluation is recommended of this aging effect to determine the need for a plant-specific AMP or plant-specific enhancements to ASME Code Section XI, Subsection IWL, and/or Structures Monitoring AMPs, to manage these aging effects for plants located in moderate to severe weathering conditions. Acceptance criteria are described in BTP RLSB-1 (Appendix A.1 of this SRP-SLR).

3.5.2.2.1.8 Cracking Due to Expansion From Reaction With Aggregates Cracking due to expansion from reaction with aggregates could occur in inaccessible areas of concrete elements of PWR and BWR concrete and steel containments. The GALL-SLR Report recommends further evaluation to determine the need for if a plant-specific AMPaging management program or plant-specific enhancements to ASME Code Section XI, Subsection IWL, and/or Structures Monitoring AMPs is required to manage this aging effect.

Acceptance criteria are described in BTP RLSB-1 (Appendix A.1 of this SRP-SLR).

3.5.2.2.1.9 Increase in Porosity and Permeability Due to Leaching of Calcium Hydroxide and Carbonation Increase in porosity and permeability due to leaching of calcium hydroxide and carbonation could occur in inaccessible areas of concrete elements of PWR and BWR concrete and steel containments. Further evaluation is recommended to determine the need for a plant-specific AMP or plant-specific enhancements to ASME Code Section XI, Subsection IWL and/or Structures Monitoring AMPs, essential to manage these aging effects if leaching is observed in

SLR-ISG-2021-03-STRUCTURES: Appendix E Page 3 of 31 accessible areas that impact intended functions. Acceptance criteria are described in BTP RLSB-1 (Appendix A.1 of this SRP-SLR).

3.5.2.2.2.1 Aging Management of Inaccessible Areas

1. Loss of material (spalling, scaling) and cracking due to freeze-thaw could occur in below-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 to determine the need for a plant-specific AMP or plant-specific enhancements to Structures Monitoring AMP, to manage these aging effects. Acceptance criteria are described in BTP RLSB-1 (Appendix A.1 of this SRP-SLR).

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 the need forif a plant-specific AMP or plant-specific enhancements to Structures Monitoring AMP, is required to manage this aging effect. Acceptance criteria are described in BTP RLSB-1 (Appendix A.1 of this SRP-SLR).

3. Cracking and distortion due to increased stress levels from settlement could occur in below-grade inaccessible concrete areas of structures for all Groups, and reduction in foundation strength and cracking due to differential settlement and erosion of porous concrete subfoundations could occur in below-grade inaccessible concrete areas of Groups 1-3, 5-9 structures. The existing program relies on structure monitoring programs to manage these aging effects. Some plants may rely on a dewatering system to lower the site groundwater level. If the plants CLB credits a dewatering system, verification is recommended of the continued functionality of the dewatering system during the subsequent period of extended operation. No further evaluation is recommended if this activity is included in the scope of the applicants structures monitoring program.

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 to determine the need for a plant-specific AMP or plant-specific enhancements to Structures Monitoring AMP, to manage these aging effects if leaching is observed in accessible areas that impact intended functions. Acceptance criteria are described in BTP RLSB-1 (Appendix A.1 of this SRP-SLR).

3.5.2.2.2.2 Reduction of Strength and Modulus Due to Elevated Temperature Reduction of strength and modulus of concrete due to elevated temperatures could occur in PWR and BWR Group 1-5 concrete structures. For any concrete elements that exceed specified temperature limits, further evaluations are recommended. Appendix A of American Concrete Institute (ACI) 349-85, Code Requirements for Nuclear Safety-Related Concrete Structures, specifies the concrete temperature limits for normal operation or any other long-term period. The temperatures shall not exceed 66 °C (150 °F) except for local areas, which are allowed to have increased temperatures not to exceed 93 °C (200 °F). Further evaluation is recommended of a plant-specific program to determine the need for a plant-specific AMP or plant-specific enhancements to Structures Monitoring AMP, to manage these aging effects if

SLR-ISG-2021-03-STRUCTURES: Appendix E Page 4 of 31 any portion of the safety-related and other concrete structures exceeds specified temperature limits [i.e., general area temperature greater than 66 °C (150 °F) and local area temperature greater than 93 °C (200 °F)]. Higher temperatures may be allowed if tests and/or calculations are provided to evaluate the reduction in strength and modulus of elasticity and these reductions are applied to the design calculations. The acceptance criteria are described in BTP RLSB-1 (Appendix A.1 of this SRP-SLR).

3.5.2.2.2.3 Aging Management of Inaccessible Areas for Group 6 Structures Further evaluation is recommended for inaccessible areas of certain Group 6 structure/aging effect combinations as identified below, whether or not they are covered by inspections in accordance with the GALL-SLR Report AMP XI.S7, Inspection of Water-Control Structures Associated with Nuclear Power Plants, or Federal Energy Regulatory Commission (FERC)/U.S. Army Corp of Engineers dam inspection and maintenance procedures.

1. Loss of material (spalling, scaling) and cracking due to freeze-thaw could occur in below-grade inaccessible concrete areas of Group 6 structures. Further evaluation is recommended of this aging effect to determine the need for a plant-specific AMP or plant-specific enhancements to Structures Monitoring AMP to manage these aging effects for inaccessible areas for plants located in moderate to severe weathering conditions. Acceptance criteria are described in BTP RLSB-1 (Appendix A1 of this SRP-SLR).

2. Cracking due to expansion and reaction with aggregates could occur in inaccessible concrete areas of Group 6 structures. Further evaluation is recommended to determine the need forif a plant-specific AMP or plant-specific enhancements to Structures Monitoring AMP, is required to manage this aging effect. Acceptance criteria are described in BTP RLSB-1 (Appendix A.1 of this SRP-SLR).

3. Increase in porosity and permeability and loss of strength due to leaching of calcium hydroxide and carbonation could occur in inaccessible areas of concrete elements of Group 6 structures. Further evaluation is recommended to determine the need for if a plant-specific AMP or plant-specific enhancements to Structures Monitoring AMP, to manage these aging effects if leaching is observed in accessible areas that impact intended functions. Acceptance criteria are described in BTP RLSB-1 (Appendix A.1 of this SRP-SLR).

3.5.2.2.2.6 Reduction of Strength and Mechanical Properties of Concrete Due to Irradiation Reduction of strength, loss of mechanical properties, and cracking due to irradiation could occur in PWR and BWR Group 4 concrete structures that are exposed to high levels of neutron and gamma radiation. These structures include the reactor (primary/biological) shield wall, the sacrificial shield wall, and the reactor vessel support/pedestal structure. Data related to the effects and significance of neutron and gamma radiation on concrete mechanical and physical properties is limited, especially for conditions (dose, temperature, etc.) representative of light-water reactor (LWR) plants. However, based on literature review of existing research, radiation fluence limits of 1 x 1019 neutrons/cm2 neutron radiation and 1 x 108 Gy (1 x 1010 rad) gamma dose are considered conservative radiation exposure levels beyond which concrete material properties may begin to degrade markedly (Ref. 17, 18, 19).

SLR-ISG-2021-03-STRUCTURES: Appendix E Page 5 of 31 Further evaluation is recommended ofto determine the need for a plant-specific AMP or plant-specific enhancements to selected existing AMPs to manage the program to manage aging effects of irradiation if the estimated (calculated) fluence levels or irradiation dose received by any portion of the concrete from neutron (fluence cutoff energy E > 0.1 MeV) or gamma radiation exceeds the respective threshold level during the subsequent period of extended operation that could affect or if plant-specific OE of concrete irradiation degradation exists that may impact intended functions. Higher fluence or dose levels may be allowed in the concrete if tests and/or calculations are provided to evaluate the reduction in strength and/or loss of mechanical properties of concrete from those fluence levels, at or above the operating temperature experienced by the concrete, and the effects are applied to the design calculations.

Supporting calculations/analyses, test data, and other technical basis are provided to estimate and evaluate fluence levels and the plant-specific program. The acceptance criteria are described in BTP RLSB-1 (Appendix A.1 of this SRP-SLR).

3.5.3.2.1.2 Reduction of Strength and Modulus Due to Elevated Temperature Further evaluation is recommended of programs to manage reduction of strength and modulus of concrete due to elevated temperature for PWR and BWR concrete and steel containments.

The implementation of ASME Code Section XI, Subsection IWL examinations and 10 CFR 50.55a would not be able to detect the reduction of concrete strength and modulus due to elevated temperature and also notes that no mandated aging management exists for managing this aging effect.

A plant-specific evaluation should be performed if any portion of the concrete containment components exceeds specified temperature limits [i.e., general temperature greater than 66 °C (150 °F) and local area temperature greater than 93 °C (200 °F)]. Higher temperatures may be allowed if tests and/or calculations are provided to evaluate the reduction in strength and modulus of elasticity and these reductions are applied to the design calculations. The reviewer reviews and confirms that the applicants discussion in the renewal application indicates that the affected PWR and BWR containment components are not exposed to a temperature that exceeds the temperature limits. If active cooling is relied upon to maintain acceptable temperatures, then the reviewer ensures that the aging effects associated with the cooling system are being properly managed or temperatures are being monitored to identify a problem with the cooling system. If the limits are exceeded the reviewer reviews the technical basis (i.e.,

tests and/or calculations) provided by the applicant to justify the higher temperature. Otherwise, the reviewer reviews the applicants proposed programs plant- specific AMP or plant-specific enhancements to ASME Code Section XI, Subsection IWL and/or Structures Monitoring AMPs, needed to manage these aging effects. Plant-specific evaluations verify that, where appropriate, an effective enhanced inspection program has been developed and implemented, to ensure that reduction of strength and modulus of elasticity due to elevated temperatures are to ensure that the effects of elevated temperature will be adequately managed during the subsequent period of extended operation.

3.5.3.2.1.7 Loss of Material (Scaling, Spalling) and Cracking Due to Freeze-Thaw Further evaluation is recommended of programs to manage loss of material (scaling, spalling) and cracking due to freeze-thaw for concrete elements of PWR and BWR containments.

Containment ISI Subsection IWL may not be sufficient for plants located in moderate to severe weathering conditions. Evaluation is needed for plants that are located in moderate to severe weathering conditions (weathering index >100 day-inch/yr) (NUREG-1557). The weathering index for the continental United States is shown in ASTM International (formerly American

SLR-ISG-2021-03-STRUCTURES: Appendix E Page 6 of 31 Society for Testing and Materials) Standard (ASTM) C33-90, Standard Specification for Concrete Aggregates, Figure 1. A plant-specific AMPprogram or plant-specific enhancements to ASME Code Section XI, Subsection IWL and/or Structures Monitoring AMPs, needed to manage this aging effect are isnot required if documented evidence confirms that the existing concrete had air content of 3 percent to 8 percent (including tolerance) and subsequent inspection of accessible areas did not exhibit degradation related to freeze-thaw. Such inspections are considered a part of the evaluation. The reviewer reviews and confirms that the applicant has satisfied the recommendations for inaccessible concrete. Otherwise, the reviewer reviews the applicants proposed AMP to verify that, where appropriate, an effective inspection program has been developed and implemented to ensure that these aging effects in inaccessible areas for plants located in moderate to severe weathering conditions are adequately managed. proposed plant-specific AMP, or plant-specific enhancements to ASME Code Section XI, Subsection IWL and/or Structures Monitoring AMPs, needed to manage these aging effects. Plant-specific evaluations verify that, where appropriate, an effective enhanced inspection program has been developed and implemented to ensure that loss of material (scaling, spalling) and cracking due to freeze thaw in inaccessible areas for plants located in moderate to severe weathering conditions are adequately managed during the subsequent period of extended operation.

3.5.3.2.1.8 Cracking Due to Expansion from Reaction With Aggregates Further evaluation is recommended of programs to manage cracking due to expansion from reaction with aggregates in inaccessible areas of concrete elements of PWR and BWR concrete and steel containments. A Either a plant-specific AMP, or plant-specific enhancement(s) to ASME Code Section XI, Subsection IWL and/or Structures Monitoring AMP is necessary to manage this aging effect if (1) reactivity tests or petrographic examinations of concrete samples identify reaction with aggregates, or (2) accessible concrete exhibits visual indications of aggregate reactions, such as map or patterned cracking, alkali-silica gel, exudations, surface staining, expansion causing structural deformation, relative movement or displacement, or misalignment/distortion of attached components. The reviewer confirms that the applicant has not identified one of the above conditions. Otherwise, the reviewer reviews the applicants proposed plant-specific AMP or plant-specific enhancements to ASME Code Section XI, Subsection IWL and/or Structures Monitoring AMP, needed to manage this aging effect. Plant-specific evaluations verify that, where appropriate, an effective enhanced inspection program has been developed and implemented to ensure that cracking due to expansion from reaction with aggregates in inaccessible areas is adequately managed during the subsequent period of extended operation. AMP or plant-specific evaluation to verify that, an effective evaluation or inspection program has been developed and implemented to ensure that this aging effect in inaccessible areas is adequately managed.

3.5.3.2.1.9 Increase in Porosity and Permeability Due to Leaching of Calcium Hydroxide and Carbonation Further evaluation is recommended of programs to manage increase in porosity and permeability due to leaching of calcium hydroxide and carbonation in inaccessible areas of PWR and BWR concrete and steel containments. A plant-specific AMP is not required, even if reinforced concrete is exposed to flowing water if (1) there is evidence in the accessible areas that the flowing water has not caused leaching and carbonation, or (2) evaluation determined that the observed leaching of calcium hydroxide and carbonation in accessible areas is not significant and has no impact on the intended function of the concrete structure. The reviewer confirms that the applicant has satisfied these conditions. Otherwise, the reviewer reviews the

SLR-ISG-2021-03-STRUCTURES: Appendix E Page 7 of 31 applicants proposed plant-specific AMP, or plant-specific enhancement(s) to ASME Code Section XI, Subsection IWL and/or Structures Monitoring AMP, needed to manage these aging effects. Plant-specific evaluations verify that, where appropriate, an effective enhanced inspection program has been developed and implemented to ensure that increase in porosity and permeability due to leaching in inaccessible areas are adequately managed during the subsequent period of extended operation. AMP to verify that, where appropriate, an effective inspection program has been developed and implemented to ensure that this aging effect in inaccessible areas is adequately managed.

3.5.3.2.2.1 Aging Management of Inaccessible Areas

1. Further evaluation is recommended of programs to manage loss of material (spalling, scaling) and cracking due to freeze-thaw in below-grade inaccessible concrete areas of Groups 1-3, 5, and 7-9 structures. Structure monitoring programs may not be sufficient for plants located in moderate to severe weathering conditions. Further evaluation is needed for plants that are located in moderate to severe weathering conditions (weathering index >100 day-inch/yr) (NUREG-1557). The weathering index for the continental United States is shown in ASTM C33-90, Figure 1. A plant-specific program is not required if documented evidence confirms that the existing concrete had air content of 3 percent to 8 percent and subsequent inspection did not exhibit degradation related to freeze-thaw. Such inspections should be considered a part of the evaluation.

The reviewer confirms that the applicant has satisfied these conditions. Otherwise, the reviewer reviews the applicants proposed plant-specific AMP or plant-specific enhancements to structures monitoring AMPs needed to manage these aging effects.

Plant-specific evaluations verify that, where appropriate, an effective enhanced inspection program has been developed and implemented to ensure that loss of material (spalling, scaling) and cracking due to freeze-thaw in inaccessible areas for plants located in moderate to severe weathering conditions are adequately managed during the subsequent period of extended operation. Otherwise, the reviewer reviews the applicants proposed AMP to verify that, where appropriate, an effective inspection program has been developed and implemented to ensure that this aging effect in inaccessible areas for plants located in moderate to severe weathering conditions is adequately managed.

2. Further evaluation is recommended to determine if a plant-specific program is required to manage cracking due to expansion from reaction with aggregates in inaccessible concrete areas of Groups 1-5 and 7-9 structures. A plant-specific evaluation or program is required if (1) reactivity tests or petrographic examinations of concrete samples identify reaction with aggregates, or (2) accessible concrete exhibits visual indications of aggregate reactions, such as map or patterned cracking, alkali-silica gel exudations, surface staining, expansion causing structural deformation, relative movement or displacement, or misalignment/distortion of attached components. The reviewer confirms that the applicant has not identified any of the above conditions.

Otherwise, the reviewer reviews the applicants proposed AMP or plant-specific enhancements to structures monitoring AMPs needed to manage this aging effect.

Plant-specific evaluations verify that, where appropriate, an effective enhanced inspection program has been developed and implemented to ensure that cracking due to expansion from reaction with aggregates in inaccessible concrete areas is adequately managed during the subsequent period of extended operation. Otherwise, the reviewer reviews the applicants proposed AMP or plant-specific evaluation to verify that, an

SLR-ISG-2021-03-STRUCTURES: Appendix E Page 8 of 31 effective evaluation or inspection program has been developed and implemented to ensure that the aging effect is adequately managed.

3. Further evaluation is recommended of aging management of (a) cracking and distortion due to increased stress levels from settlement for inaccessible concrete areas of structures for all Groups and (b) reduction of foundation strength, and cracking due to differential settlement and erosion of porous concrete subfoundations for inaccessible concrete areas of Groups 1-3, and 5-9 structures if a dewatering system is relied upon to manage the aging effect. The reviewer confirms that, if the applicants plant credits a dewatering system in its CLB, the applicant has committed to monitor the functionality of the dewatering system under the applicants structures monitoring program. If not, the reviewer reviews and evaluates the plant-specific program for monitoring the dewatering system during the subsequent period of extended operation.

4. Further evaluation is recommended of programs to manage increase in porosity and permeability due to leaching of calcium hydroxide and carbonation in below-grade inaccessible concrete areas of Groups 1-5, and 7-9 structures. A plant-specific AMP is not required for the reinforced concrete exposed to flowing water if (1) there is evidence in the accessible areas that the flowing water has not caused leaching of calcium hydroxide and carbonation or (2) evaluation determined that the observed leaching of calcium hydroxide and carbonation in accessible areas has no impact on the intended function of the concrete structure. The reviewer confirms that the applicant has satisfied these conditions. Otherwise, the reviewer reviews the applicants proposed plant-specific AMP or plant-specific enhancements to Structures Monitoring AMP needed to manage these aging effects. Plant-specific evaluations verify that, where appropriate, an effective enhanced inspection program has been developed and implemented to ensure that increase in porosity and permeability due to leaching of calcium hydroxide and carbonation in inaccessible areas are adequately managed during the subsequent period of extended operation. Otherwise, the reviewer reviews the applicants proposed AMP to verify that, where appropriate, an effective inspection program has been developed and implemented to ensure that this aging effect in inaccessible areas is adequately managed.

3.5.3.2.2.2 Reduction of Strength and Modulus Due to Elevated Temperature Further evaluation is recommended of programs to manage reduction of strength and modulus of concrete structures due to elevated temperature temperatures for PWR and BWR safety-related and other structures.

A plant-specific evaluation should be performed if any portion of the concrete Groups 1-5 structures exceeds specified temperature limits [i.e., general temperature greater than 66 °C (150 °F) and local area temperature greater than 93 °C (200 °F)]. Higher temperatures may be allowed if tests and/or calculations are provided to evaluate the reduction in strength and modulus of elasticity and these reductions are applied to the design calculations. The reviewer reviews and confirms that the applicants discussion in the renewal application indicates that the affected Groups 1-5 structures are not exposed to temperature that exceeds the temperature limits. If active cooling is relied upon to maintain acceptable temperatures, then the reviewer ensures that the aging effects associated with the cooling system are being properly managed or temperatures are being monitored to identify a problem with the cooling system. If the limits are exceeded, the reviewer reviews the technical basis (i.e., tests and/or calculations) provided by the applicant to justify the higher temperature. Otherwise the reviewer reviews the

SLR-ISG-2021-03-STRUCTURES: Appendix E Page 9 of 31 applicants proposed plant-specific AMP or plant-specific enhancements to the Structures Monitoring AMP needed to manage these aging effects. Plant-specific evaluations verify that, where appropriate, an effective enhanced inspection program has been developed and implemented, to ensure that reduction of strength and modulus of concrete structures due to elevated temperatures are adequately managed during the subsequent period of extended operation. Otherwise the reviewer reviews the applicants proposed programs on a case-by-case basis to ensure that the effects of elevated temperature will be adequately managed during the subsequent period of extended operation.

3.5.3.2.2.3 Aging Management of Inaccessible Areas for Group 6 Structures Further evaluation is recommended for inaccessible areas of certain Group 6 structure/aging effect combinations as identified below, whether or not they are covered by inspections in accordance with GALL-SLR Report AMP XI.S7, or FERC/US Army Corp of Engineers dam inspection and maintenance procedures.

1. Loss of material (spalling, scaling) and cracking due to freeze-thaw could occur in below-grade inaccessible concrete areas of Group 6 structures. Further evaluation is needed for plants that are located in moderate to severe weathering conditions (weathering index >100 day-inch/yr) (NUREG-1557, Ref. 15). The weathering index for the continental U.S. is shown in ASTM C33-90, Figure 1. A plant-specific program is not required if documented evidence confirms that the existing concrete had air content of 3 percent to 8 percent and subsequent inspection of accessible areas did not exhibit degradation related to freeze-thaw. Such inspections should be considered a part of the evaluation. The reviewer reviews and confirms that the applicant has satisfied these conditions. Otherwise, the reviewer reviews the applicants proposed plant-specific AMP or plant-specific enhancements to Structures Monitoring AMP essential to manage theseis aging effects. Plant-specific evaluations verify that, where appropriate, an effective enhanced inspection program has been developed and implemented, to ensure that loss of material (spalling, scaling) and cracking due to freeze-thaw in inaccessible areas for plants located in moderate to severe weathering conditions are adequately managed during the subsequent period of extended operation. Otherwise, the reviewer reviews the applicants proposed AMP to determine that, where appropriate, an effective inspection program has been developed and implemented to ensure that this aging effect in inaccessible areas for plants located in moderate to severe weathering conditions will be adequately managed.

2. Cracking due to expansion from reaction with aggregates could occur in inaccessible concrete areas of Group 6 structures. Further evaluation is recommended to determine if a plant-specific program is required to manage the aging effect. A plant-specific evaluation or program is required if (1) reactivity tests or petrographic examinations of concrete samples identify reaction with aggregates, or (2) accessible concrete exhibits visual indications of aggregate reactions, such as map or patterned cracking, alkali-silica gel exudations, surface staining, expansion causing structural deformation, relative movement or displacement, or misalignment/distortion of attached components.

The reviewer confirms that the applicant has not identified any of the above conditions.

Otherwise, the reviewer reviews the applicants proposed plant-specific AMP, or plant-specific enhancements to Structures Monitoring AMP, needed to manage this aging effect. Plant-specific evaluations verify that, where appropriate, an effective enhanced inspection program has been developed and implemented to ensure cracking due to expansion from reaction with aggregates are adequately managed during the

SLR-ISG-2021-03-STRUCTURES: Appendix E Page 10 of 31 subsequent period of extended operation. Otherwise, the reviewer reviews the applicants proposed AMP or plant-specific evaluation to verify that, an effective evaluation or inspection program has been developed and implemented to ensure that the aging effect will be adequately managed.

3. Increase in porosity and permeability due to leaching of calcium hydroxide and carbonation could occur in below-grade inaccessible concrete areas of Group 6 structures. Further evaluation is recommended to determine if a plant-specific program is required to manage the aging effect. A plant-specific program is not required for the reinforced structures exposed to flowing water if (1) there is evidence in the accessible areas that the flowing water has not caused leaching and carbonation, or (2) evaluation determined that the observed leaching of calcium hydroxide and carbonation in accessible areas has no impact on the intended function of the concrete structure. The reviewer confirms that the applicant has satisfied these conditions. Otherwise, the reviewer reviews the applicants proposed AMP or plant-specific enhancements to Structures Monitoring AMP needed manage this aging effect. Plant-specific evaluations verify that, where appropriate, an effective enhanced inspection program has been developed and implemented to ensure that porosity and permeability due to leaching of calcium hydroxide and carbonation in inaccessible areas are adequately managed during the subsequent period of extended operation. Otherwise, the reviewer reviews the applicants proposed AMP to verify that, where appropriate, an effective inspection program has been developed and implemented to ensure that this aging effect in inaccessible areas will be adequately managed.

3.5.3.2.2.6 Reduction of Strength and Mechanical Properties of Concrete Due to Irradiation Further evaluation is recommended of a plant-specific AMP or plant-specific enhancements to selected AMPs program to manage reduction of strength, loss of mechanical properties, and cracking of concrete due to irradiation in PWR and BWR Group 4 concrete structures, exposed to high levels of neutron and gamma radiation. These structures include the reactor (primary/biological) shield wall, the sacrificial shield wall, and the reactor vessel support/pedestal structure. The irradiation mechanism consists of radiation interactions with the material and heating due to absorption of radiation energy at the operating temperature experienced by the concrete. The intensity of radiation is typically characterized by the measure of its field or fluence. Both neutron and gamma radiation produce internal heating from absorption of radiation energy and, at high fluence levels, changes in microstructure and certain mechanical properties of concrete (e.g., compressive strength, tensile strength, modulus of elasticity) from radiation interactions with the material. Limited data are available in the open literature related to the effects and significance of radiation fluences (neutron and gamma radiation) on intended functions of concrete structures, especially for conditions (dose, temperature, etc.) representative of existing LWR plants. However, based on literature review of existing research, fluence limits of 1 x 1019 neutrons/cm2 neutron radiation and 1 x 108 Gy (1 x 1010 rad) gamma dose are considered conservative radiation exposure levels beyond which concrete material properties may begin to degrade markedly.

Plant-specific calculations/analyses should be performed to identify the neutron (fluence cutoff energy E > 0.1 MeV) and gamma fields that develop in any portion of the concrete structures of interest at 80 years of operation and compare them to the above threshold limits. The impact of any plant-specific OE of concrete irradiation effects on intended functions are evaluated. The reviewer reviews these analyses, OE and supporting technical basis (e.g., calculations, test data, plant-specific evaluations) on a case-by-case basis. Higher fluence or dose levels may be

SLR-ISG-2021-03-STRUCTURES: Appendix E Page 11 of 31 allowed in the concrete if tests and/or calculations are provided to evaluate the reduction in strength and/or change in mechanical properties of concrete, if any, from those fluence levels and the effects are applied to the design calculations. The reviewer confirms that the applicants discussion in the SLRA indicates that the affected PWR and BWR concrete components are not exposed to neutron and gamma radiation fluence levels that exceed the threshold limits, or are otherwise evaluated, for example, the concrete is primarily for shielding and non-structural. The reviewer also confirms that the impact of any plant-specific OE of concrete irradiation degradation on intended functions is addressed. If the limits are exceeded, the technical basis (i.e., tests and/or calculations or evaluations) provided by the applicant to justify higher fluence or dose limits is reviewed. Otherwise, the applicants proposed plant-specific AMP or plant-specific enhancements to selected AMPs program and the supporting technical basis is reviewed to ensure that the effects of irradiation on the concrete components will be adequately managed during the subsequent period of extended operation.

Revisions to SRP-SLR Table 3.5-1 SLR-ISG-2021-03-STRUCTURES: Appendix E Table 3.5-1 Summary of Aging Management Programs for Containments, Structures and Component Supports Evaluated in Chapters II and III of the GALL-SLR Report New, Aging Modified, Management Deleted, Aging Program Further Evaluation GALL-SLR Edited Item ID Type Component Effect/Mechanism (AMP)/TLAA Recommended Item E 001 BWR/PWR Concrete: dome; wall; Cracking and distortion AMP XI.S2, Yes (SRP-SLR II.A1.CP-101 basemat; ring girders; due to increased stress "ASME Section XI, Section 3.5.2.2.1.1) II.A2.CP-69 buttresses, concrete levels from settlement Subsection IWL," II.B1.2.CP-105 elements, all and/or II.B2.2.CP-105 AMP XI.S6, II.B3.1.CP-69 "Structures II.B3.2.CP-105 Monitoring" E 002 BWR/PWR Concrete: foundation; Reduction of foundation AMP XI.S6, Yes (SRP-SLR II.A1.C-07 subfoundation strength and cracking due "Structures Section 3.5.2.2.1.1) II.A2.C-07 to differential settlement Monitoring" II.B1.2.C-07 and erosion of porous II.B2.2.C-07 concrete subfoundation II.B3.1.C-07 II.B3.2.C-07 M 003 BWR/PWR Concrete: dome; wall; Reduction of strength and Plant-specific Yes (SRP-SLR II.A1.CP-34 basemat; ring girders; modulus of elasticity due aging Section 3.5.2.2.1.2) II.B1.2.CP-57 buttresses, concrete: to elevated temperature management II.B2.2.CP-57 containment; wall; (>150°F general; >200°F program or AMP II.B3.1.CP-65 basemat, concrete: local) XI.S2, ASME II.B3.2.CP-108 basemat, concrete fill-in Section XI, annulus Subsection IWL, and/or AMP XI.S6, Structures Monitoring, enhanced as necessary E 004 BWR Steel elements Loss of material due to AMP XI.S1, Yes (SRP-SLR II.B3.1.CP-113 (inaccessible areas): general, pitting, crevice "ASME Section XI, Section 3.5.2.2.1.3.1) drywell shell; drywell corrosion Subsection IWE,"

head and AMP XI.S4, "10 CFR Part 50, Page 12 of 31 Appendix J"

Table 3.5-1 Summary of Aging Management Programs for Containments, Structures and Component Supports Evaluated in Chapters II and III of the SLR-ISG-2021-03-STRUCTURES: Appendix E GALL-SLR Report New, Aging Modified, Management Deleted, Aging Program Further Evaluation GALL-SLR Edited Item ID Type Component Effect/Mechanism (AMP)/TLAA Recommended Item E 005 BWR/PWR Steel elements Loss of material due to AMP XI.S1, Yes (SRP-SLR II.A1.CP-98 (inaccessible areas): general, pitting, crevice "ASME Section XI, Section 3.5.2.2.1.3.1) II.A2.CP-98 liner; liner anchors; corrosion Subsection IWE," II.B1.2.CP-63 integral attachments, and AMP XI.S4, II.B2.1.CP-63 steel elements "10 CFR Part 50, II.B2.2.CP-63 (inaccessible areas): Appendix J" II.B3.2.CP-98 suppression chamber; drywell; drywell head; embedded shell; region shielded by diaphragm floor (as applicable)

E 006 BWR Steel elements: torus Loss of material due to AMP XI.S1, Yes (SRP-SLR II.B1.1.CP-48 shell general, pitting, crevice "ASME Section XI, Section 3.5.2.2.1.3.2) corrosion Subsection IWE,"

and AMP XI.S4, "10 CFR Part 50, Appendix J" E 007 BWR Steel elements: torus ring Loss of material due to AMP XI.S1, Yes (SRP-SLR II.B1.1.CP-109 girders; downcomers;, general, pitting, crevice "ASME Section XI, Section 3.5.2.2.1.3.3) II.B3.1.CP-158 Steel elements: corrosion Subsection IWE" suppression chamber shell (interior surface)

M 008 BWR/PWR Prestressing system: Loss of prestress due to TLAA, SRP-SLR Yes (SRP-SLR II.A1.C-11 tendons relaxation; shrinkage; Section 4.5, Section 3.5.2.2.1.4) II.B2.2.C-11 creep; elevated "Concrete temperature Containment Tendon Prestress," and/or SRP-SLR Section 4.7, "Other Plant-Specific Time-Limited Aging Page 13 of 31 Analyses"

Table 3.5-1 Summary of Aging Management Programs for Containments, Structures and Component Supports Evaluated in Chapters II and III of the SLR-ISG-2021-03-STRUCTURES: Appendix E GALL-SLR Report New, Aging Modified, Management Deleted, Aging Program Further Evaluation GALL-SLR Edited Item ID Type Component Effect/Mechanism (AMP)/TLAA Recommended Item M 009 BWR/PWR Metal liner, metal plate, Cumulative fatigue TLAA, SRP-SLR Yes (SRP-SLR II.A3.C-13 personnel airlock, damage due to cyclic Section 4.6, Section 3.5.2.2.1.5) II.B1.1.C-21 equipment hatch, CRD loading (Only if CLB "Containment II.B2.1.C-45 hatch, penetration fatigue analysis exists) Liner Plate and II.B2.2.C-48 sleeves; penetration Penetration II.B4.C-13 bellows, steel elements: Fatigue Analysis" torus; vent line; vent header; vent line bellows; downcomers, suppression pool shell; unbraced downcomers, steel elements: vent header; downcomers E 010 BWR/PWR Penetration sleeves; Cracking due to SCC AMP XI.S1, Yes (SRP-SLR II.A3.CP-38 penetration bellows "ASME Section XI, Section 3.5.2.2.1.6) II.B4.CP-38 Subsection IWE,"

and AMP XI.S4, "10 CFR Part 50, Appendix J" EM 011 BWR/PWR Concrete (inaccessible Loss of material (spalling, Plant-specific Yes (SRP-SLR II.A1.CP-147 areas): dome; wall; scaling) and cracking due aging Section 3.5.2.2.1.7) II.A2.CP-70 basemat; ring girders; to freeze-thaw management II.B3.2.CP-135 buttresses program or AMP XI.S2, ASME Section XI, Subsection IWL, and/or AMP XI.S6, Structures Monitoring, enhanced as necessary Page 14 of 31

Table 3.5-1 Summary of Aging Management Programs for Containments, Structures and Component Supports Evaluated in Chapters II and III of the SLR-ISG-2021-03-STRUCTURES: Appendix E GALL-SLR Report New, Aging Modified, Management Deleted, Aging Program Further Evaluation GALL-SLR Edited Item ID Type Component Effect/Mechanism (AMP)/TLAA Recommended Item M 012 BWR/PWR Concrete (inaccessible Cracking due to Plant-specific Yes (SRP-SLR II.A1.CP-67 areas): dome; wall; expansion from reaction aging Section 3.5.2.2.1.8) II.A2.CP-104 basemat; ring girders; with aggregates management II.B1.2.CP-99 buttresses, containment, program or AMP II.B2.2.CP-99 concrete fill-in annulus XI.S2, ASME II.B3.1.CP-83 Section XI, II.B3.2.CP-121 Subsection IWL, and/or AMP XI.S6, Structures Monitoring, enhanced as necessary D 013 M 014 BWR/PWR Concrete (inaccessible Increase in porosity and Plant-specific Yes (SRP-SLR II.A1.CP-102 areas): dome; wall; permeability; loss of aging Section 3.5.2.2.1.9) II.A2.CP-53 basemat; ring girders; strength due to leaching management II.B1.2.CP-110 buttresses, containment of calcium hydroxide and program or AMP II.B2.2.CP-110 carbonation XI.S2, ASME II.B3.1.CP-53 Section XI, II.B3.2.CP-122 Subsection IWL, and/or AMP XI.S6, Structures Monitoring, enhanced as necessary D 015 M 016 BWR/PWR Concrete (accessible Increase in porosity and AMP XI.S2, No II.A1.CP-87 areas): basemat, permeability; cracking; "ASME Section XI, II.A2.CP-72 concrete: containment; loss of material (spalling, Subsection IWL," II.B1.2.CP-106 wall scaling) due to aggressive and/or AMP XI.S6, II.B2.2.CP-106 chemical attack "Structures II.B3.1.CP-72 Monitoring" Page 15 of 31 D 017

Table 3.5-1 Summary of Aging Management Programs for Containments, Structures and Component Supports Evaluated in Chapters II and III of the SLR-ISG-2021-03-STRUCTURES: Appendix E GALL-SLR Report New, Aging Modified, Management Deleted, Aging Program Further Evaluation GALL-SLR Edited Item ID Type Component Effect/Mechanism (AMP)/TLAA Recommended Item M 018 BWR/PWR Concrete (accessible Loss of material (spalling, AMP XI.S2, No II.A1.CP-31 areas): dome; wall; scaling) and cracking due "ASME Section XI, II.A2.CP-51 basemat; ring girders; to freeze-thaw Subsection IWL," II.B3.2.CP-52 buttresses and/or AMP XI.S6, "Structures Monitoring" M 019 BWR/PWR Concrete (accessible Cracking due to AMP XI.S2, No II.A1.CP-33 areas): dome; wall; expansion from reaction "ASME Section XI, II.A2.CP-58 basemat; ring girders; with aggregates Subsection IWL," II.B1.2.CP-59 buttresses, containment; and/or AMP XI.S6, II.B2.2.CP-59 concrete fill-in annulus "Structures II.B3.1.CP-66 Monitoring" II.B3.2.CP-60 M 020 BWR/PWR Concrete (accessible Increase in porosity and AMP XI.S2, No II.A1.CP-32 areas): dome; wall; permeability; loss of "ASME Section XI, II.A2.CP-155 basemat; ring girders; strength due to leaching Subsection IWL" II.B1.2.CP-54 buttresses, containment of calcium hydroxide and II.B2.2.CP-54 carbonation II.B3.1.CP-156 II.B3.2.CP-55 E 021 BWR/PWR Concrete (accessible Cracking; loss of bond; AMP XI.S2, No II.A1.CP-68 areas): dome; wall; and loss of material "ASME Section XI, II.A2.CP-74 basemat; ring girders; (spalling, scaling) due to Subsection IWL," II.B1.2.CP-79 buttresses; reinforcing corrosion of embedded and/or AMP XI.S6, II.B2.2.CP-79 steel steel "Structures II.B3.1.CP-74 Monitoring" II.B3.2.CP-88 D 022 M 023 BWR/PWR Concrete (inaccessible Cracking; loss of bond; AMP XI.S2, No II.A1.CP-97 areas): basemat; and loss of material "ASME Section XI, II.A2.CP-75 reinforcing steel, dome; (spalling, scaling) due to Subsection IWL," II.B1.2.CP-80 wall corrosion of embedded and/or AMP XI.S6, II.B2.2.CP-80 steel "Structures II.B3.1.CP-75 Monitoring" II.B3.2.CP-89 E 024 BWR/PWR Concrete (inaccessible Increase in porosity and AMP XI.S2, No II.A1.CP-100 Page 16 of 31 areas): dome; wall; permeability; cracking; "ASME Section XI, II.A2.CP-71 basemat; ring girders; loss of material (spalling, Subsection IWL," II.B3.1.CP-71 buttresses, concrete scaling) due to aggressive and/or AMP XI.S6, II.B3.2.CP-73 (accessible areas): dome; chemical attack "Structures II.B3.2.CP-84 wall; basemat Monitoring" D 025

Table 3.5-1 Summary of Aging Management Programs for Containments, Structures and Component Supports Evaluated in Chapters II and III of the SLR-ISG-2021-03-STRUCTURES: Appendix E GALL-SLR Report New, Aging Modified, Management Deleted, Aging Program Further Evaluation GALL-SLR Edited Item ID Type Component Effect/Mechanism (AMP)/TLAA Recommended Item 026 BWR/PWR Moisture barriers Loss of sealing due to AMP XI.S1, No II.A3.CP-40 (caulking, flashing, and wear, damage, erosion, "ASME Section XI, II.B4.CP-40 other sealants) tear, surface cracks, other Subsection IWE" defects M 027 BWR/PWR Metal liner, metal plate, Cracking due to cyclic AMP XI.S1, No Yes (SRP-SLR II.A3.CP-37 airlock, equipment hatch, loading (CLB fatigue "ASME Section XI, Section 3.5.2.2.1.5) II.B1.1.CP-49 CRD hatch; penetration analysis does not exist) Subsection IWE," II.B2.1.CP-107 sleeves; penetration and AMP XI.S4, II.B4.CP-37 bellows, steel elements: "10 CFR Part 50, torus; vent line; vent Appendix J" header; vent line bellows; downcomers, suppression pool shell 028 BWR/PWR Personnel airlock, Loss of material due to AMP XI.S1, No II.A3.C-16 equipment hatch, CRD general, pitting, crevice "ASME Section XI, II.B4.C-16 hatch corrosion Subsection IWE,"

and AMP XI.S4, "10 CFR Part 50, Appendix J" M 029 BWR/PWR Personnel airlock, Loss of leak tightness due AMP XI.S1, No II.A3.CP-39 equipment hatch, CRD to mechanical wear "ASME Section XI, II.B4.CP-39 hatch: locks, hinges, and Subsection IWE,"

closure mechanisms and AMP XI.S4, "10 CFR Part 50, Appendix J" 030 BWR/PWR Pressure-retaining bolting Loss of preload due to AMP XI.S1, No II.A3.CP-150 self-loosening "ASME Section XI, II.B4.CP-150 Subsection IWE,"

and AMP XI.S4, "10 CFR Part 50, Appendix J" 031 BWR/PWR Pressure-retaining Loss of material due to AMP XI.S1, No II.A3.CP-148 Page 17 of 31 bolting, steel elements: general, pitting, crevice "ASME Section XI, II.B1.2.CP-117 downcomer pipes corrosion Subsection IWE" II.B2.1.CP-117 II.B2.2.CP-117 II.B4.CP-148

Table 3.5-1 Summary of Aging Management Programs for Containments, Structures and Component Supports Evaluated in Chapters II and III of the SLR-ISG-2021-03-STRUCTURES: Appendix E GALL-SLR Report New, Aging Modified, Management Deleted, Aging Program Further Evaluation GALL-SLR Edited Item ID Type Component Effect/Mechanism (AMP)/TLAA Recommended Item 032 BWR/PWR Prestressing system: Loss of material due to AMP XI.S2, No II.A1.C-10 tendons; anchorage corrosion "ASME Section XI, II.B2.2.C-10 components Subsection IWL" 033 BWR/PWR Seals and gaskets Loss of sealing due to AMP XI.S4, No II.A3.CP-41 wear, damage, erosion, "10 CFR Part 50, II.B4.CP-41 tear, surface cracks, other Appendix J "

defects 034 BWR/PWR Service Level I coatings Loss of coating or lining AMP XI.S8, No II.A3.CP-152 integrity due to blistering, "Protective II.B4.CP-152 cracking, flaking, peeling, Coating Monitoring delamination, rusting, or and Maintenance" physical damage M 035 BWR/PWR Steel elements Loss of material due to AMP XI.S1, Yes (SRP-SLR II.A1.CP-35 (accessible areas): liner; general, pitting, crevice "ASME Section XI, Section 3.5.2.2.1.3.1) II.A2.CP-35 liner anchors; integral corrosion Subsection IWE," II.A3.CP-36 attachments, penetration and AMP XI.S4, II.B1.1.CP-43 sleeves, drywell shell; "10 CFR Part 50, II.B1.2.CP-46 drywell head; drywell Appendix J" II.B2.1.CP-46 shell in sand pocket II.B2.2.CP-46 regions; suppression II.B3.1.CP-43 chamber; drywell; II.B3.2.CP-35 embedded shell; region II.B4.CP-36 shielded by diaphragm floor (as applicable)

M 036 BWR Steel elements: drywell Loss of material due to AMP XI.S1, No II.B1.1.C-23 head; downcomers mechanical wear, "ASME Section XI, II.B1.2.C-23 including fretting Subsection IWE" II.B2.1.C-23 II.B2.2.C-23 037 BWR Steel elements: Loss of material due to AMP XI.S1, No II.B1.2.C-49 suppression chamber general (steel only), "ASME Section XI, II.B2.2.C-49 (torus) liner (interior pitting, crevice corrosion Subsection IWE,"

surface) and AMP XI.S4, Page 18 of 31 "10 CFR Part 50, Appendix J"

Table 3.5-1 Summary of Aging Management Programs for Containments, Structures and Component Supports Evaluated in Chapters II and III of the SLR-ISG-2021-03-STRUCTURES: Appendix E GALL-SLR Report New, Aging Modified, Management Deleted, Aging Program Further Evaluation GALL-SLR Edited Item ID Type Component Effect/Mechanism (AMP)/TLAA Recommended Item M 038 BWR Steel elements: Cracking due to SCC AMP XI.S1, Yes (SRP-SLR II.B3.1.C-24 suppression chamber "ASME Section XI, Section 3.5.2.2.1.6) II.B3.2.C-24 shell (interior surface) Subsection IWE,"

and AMP XI.S4, "10 CFR Part 50, Appendix J" M 039 BWR Steel elements: vent line Cracking due to SCC AMP XI.S1, Yes (SRP-SLR II.B1.1.CP-50 bellows "ASME Section XI, Section 3.5.2.2.1.6)

Subsection IWE,"

and AMP XI.S4, "10 CFR Part 50, Appendix J" M 040 BWR Unbraced downcomers, Cracking due to cyclic AMP XI.S1, No Yes (SRP-SLR II.B2.1.CP-142 steel elements: vent loading (CLB fatigue "ASME Section XI, Section 3.5.2.2.1.5) II.B2.2.CP-64 header; downcomers analysis does not exist) Subsection IWE" E 041 BWR Steel elements: drywell None None No II.B1.1.CP-44 support skirt, steel II.B1.2.CP-114 elements (inaccessible II.B2.1.CP-114 areas): support skirt II.B2.2.CP-114 M 042 BWR/PWR Groups 1-3, 5, 7- 9: Loss of material (spalling, Plant-specific Yes (SRP-SLR III.A1.TP-108 concrete (inaccessible scaling) and cracking due aging Section 3.5.2.2.2.1.1) III.A2.TP-108 areas): foundation to freeze-thaw management III.A3.TP-108 program or III.A5.TP-108 AMP XI.S6, III.A7.TP-108 Structures III.A8.TP-108 Monitoring, III.A9.TP-108 enhanced as necessary M 043 BWR/PWR All Groups except Group Cracking due to Plant-specific Yes (SRP-SLR III.A1.TP-204 6: concrete (inaccessible expansion from reaction aging Section 3.5.2.2.2.1.2) III.A2.TP-204 areas): all with aggregates management III.A3.TP-204 program or III.A4.TP-204 Page 19 of 31 AMP XI.S6, III.A5.TP-204 Structures III.A7.TP-204 Monitoring, III.A8.TP-204 enhanced as III.A9.TP-204 necessary

Table 3.5-1 Summary of Aging Management Programs for Containments, Structures and Component Supports Evaluated in Chapters II and III of the SLR-ISG-2021-03-STRUCTURES: Appendix E GALL-SLR Report New, Aging Modified, Management Deleted, Aging Program Further Evaluation GALL-SLR Edited Item ID Type Component Effect/Mechanism (AMP)/TLAA Recommended Item E 044 BWR/PWR All Groups: concrete: all Cracking and distortion AMP XI.S6, Yes (SRP-SLR III.A1.TP-30 due to increased stress "Structures Section 3.5.2.2.2.1.3) III.A2.TP-30 levels from settlement Monitoring" III.A3.TP-30 III.A4.TP-30 III.A5.TP-30 III.A6.TP-30 III.A7.TP-30 III.A8.TP-30 III.A9.TP-30 D 045 E 046 BWR/PWR Groups 1-3, 5-9: Reduction of foundation AMP XI.S6, Yes (SRP-SLR III.A1.TP-31 concrete: foundation; strength and cracking due "Structures Section 3.5.2.2.2.1.3) III.A2.TP-31 subfoundation to differential settlement Monitoring" III.A3.TP-31 and erosion of porous III.A5.TP-31 concrete subfoundation III.A6.TP-31 III.A7.TP-31 III.A8.TP-31 III.A9.TP-31 M 047 BWR/PWR Groups 1-5, 7-9: concrete Increase in porosity and Plant-specific Yes (SRP-SLR III.A1.TP-67 (inaccessible areas): permeability; loss of aging Section 3.5.2.2.2.1.4) III.A2.TP-67 exterior above- and strength due to leaching management III.A3.TP-67 below-grade; foundation of calcium hydroxide and program or III.A4.TP-305 carbonation AMP XI.S6, III.A5.TP-67 Structures III.A7.TP-67 Monitoring, III.A8.TP-67 enhanced as III.A9.TP-67 necessary M 048 BWR/PWR Groups 1-5: concrete: all Reduction of strength and Plant-specific Yes (SRP-SLR III.A1.TP-114 modulus due to elevated aging Section 3.5.2.2.2.2) III.A2.TP-114 temperature (>150°F management III.A3.TP-114 general; >200°F local) program or III.A4.TP-114 AMP XI.S6, III.A5.TP-114 Page 20 of 31 Structures Monitoring, enhanced as necessary

Table 3.5-1 Summary of Aging Management Programs for Containments, Structures and Component Supports Evaluated in Chapters II and III of the SLR-ISG-2021-03-STRUCTURES: Appendix E GALL-SLR Report New, Aging Modified, Management Deleted, Aging Program Further Evaluation GALL-SLR Edited Item ID Type Component Effect/Mechanism (AMP)/TLAA Recommended Item M 049 BWR/PWR Groups 6 - concrete Loss of material (spalling, Plant-specific Yes (SRP-SLR III.A6.TP-110 (inaccessible areas): scaling) and cracking due aging Section 3.5.2.2.2.3.1) exterior above- and to freeze-thaw management below-grade; foundation; program or interior slab AMP XI.S6, Structures Monitoring, enhanced as necessary M 050 BWR/PWR Groups 6: concrete Cracking due to Plant-specific Yes (SRP-SLR III.A6.TP-220 (inaccessible areas): all expansion from reaction aging Section 3.5.2.2.2.3.2) with aggregates management program or AMP XI.S6, Structures Monitoring, enhanced as necessary M 051 BWR/PWR Groups 6: concrete Increase in porosity and Plant-specific Yes (SRP-SLR III.A6.TP-109 (inaccessible areas): permeability; loss of aging Section 3.5.2.2.2.3.3) exterior above- and strength due to leaching management below-grade; foundation; of calcium hydroxide and program or interior slab carbonation AMP XI.S6, Structures Monitoring, enhanced as necessary E 052 BWR/PWR Groups 7, 8 - steel Cracking due to SCC; Plant-specific Yes (SRP-SLR III.A7.T-23 components: tank liner Loss of material due to aging Section 3.5.2.2.2.4) III.A8.T-23 pitting and crevice management corrosion program M 053 BWR/PWR Support members; welds; Cumulative fatigue TLAA, SRP-SLR Yes (SRP-SLR III.B1.1.T-26 Page 21 of 31 bolted connections; damage due to cyclic Section 4.3 "Metal Section 3.5.2.2.2.5) III.B1.2.T-26 support anchorage to loading (Only if CLB Fatigue," and/or III.B1.3.T-26 building structure fatigue analysis exists) Section 4.7 "Other Plant-Specific Time-Limited Aging Analyses"

Table 3.5-1 Summary of Aging Management Programs for Containments, Structures and Component Supports Evaluated in Chapters II and III of the SLR-ISG-2021-03-STRUCTURES: Appendix E GALL-SLR Report New, Aging Modified, Management Deleted, Aging Program Further Evaluation GALL-SLR Edited Item ID Type Component Effect/Mechanism (AMP)/TLAA Recommended Item M 054 BWR/PWR All groups except 6: Cracking due to AMP XI.S6, No III.A1.TP-25 concrete (accessible expansion from reaction "Structures III.A2.TP-25 areas): all with aggregates Monitoring" III.A3.TP-25 III.A4.TP-25 III.A5.TP-25 III.A6.TP-25 III.A7.TP-25 III.A8.TP-25 III.A9.TP-25 055 BWR/PWR Building concrete at Reduction in concrete AMP XI.S6, No III.B1.1.TP-42 locations of expansion anchor capacity due to "Structures III.B1.2.TP-42 and grouted anchors; local concrete Monitoring" III.B1.3.TP-42 grout pads for support degradation/ service- III.B2.TP-42 base plates induced cracking or other III.B3.TP-42 concrete aging III.B4.TP-42 mechanisms III.B5.TP-42 E 056 BWR/PWR Concrete: exterior above- Loss of material due to AMP XI.S7, No III.A6.T-20 and below- grade; abrasion; cavitation "Inspection of foundation; interior slab Water-Control Structures Associated with Nuclear Power Plants" or the FERC/US Army Corp of Engineers dam inspections and maintenance programs.

M 057 BWR/PWR Constant and variable Loss of mechanical AMP XI.S3, No III.B1.1.T-28 load spring hangers; function due to corrosion, "ASME Section XI, III.B1.2.T-28 guides; stops distortion, dirt or debris Subsection IWF" III.B1.3.T-28 accumulation, overload, Page 22 of 31 wear

Table 3.5-1 Summary of Aging Management Programs for Containments, Structures and Component Supports Evaluated in Chapters II and III of the SLR-ISG-2021-03-STRUCTURES: Appendix E GALL-SLR Report New, Aging Modified, Management Deleted, Aging Program Further Evaluation GALL-SLR Edited Item ID Type Component Effect/Mechanism (AMP)/TLAA Recommended Item E 058 BWR/PWR Earthen water-control Loss of material; loss of AMP XI.S7, No III.A6.T-22 structures: dams; form due to erosion, "Inspection of embankments; settlement, Water-Control reservoirs; channels; sedimentation, frost Structures canals and ponds action, waves, currents, Associated with surface runoff, seepage Nuclear Power Plants" or the FERC/US Army Corp of Engineers dam inspections and maintenance programs.

E 059 BWR/PWR Group 6: concrete Cracking; loss of bond; AMP XI.S7, No III.A6.TP-38 (accessible areas): all and loss of material "Inspection of (spalling, scaling) due to Water-Control corrosion of embedded Structures steel Associated with Nuclear Power Plants" or the FERC/US Army Corp of Engineers dam inspections and maintenance programs.

E 060 BWR/PWR Group 6: concrete Loss of material (spalling, AMP XI.S7, No III.A6.TP-36 (accessible areas): scaling) and cracking due "Inspection of exterior above- and to freeze-thaw Water-Control below-grade; foundation Structures Associated with Nuclear Power Plants" or the FERC/US Army Corp of Engineers Page 23 of 31 dam inspections and maintenance programs.

Table 3.5-1 Summary of Aging Management Programs for Containments, Structures and Component Supports Evaluated in Chapters II and III of the SLR-ISG-2021-03-STRUCTURES: Appendix E GALL-SLR Report New, Aging Modified, Management Deleted, Aging Program Further Evaluation GALL-SLR Edited Item ID Type Component Effect/Mechanism (AMP)/TLAA Recommended Item E 061 BWR/PWR Group 6: concrete Increase in porosity and AMP XI.S7, No III.A6.TP-37 (accessible areas): permeability; loss of "Inspection of exterior above- and strength due to leaching Water-Control below-grade; foundation; of calcium hydroxide and Structures interior slab carbonation Associated with Nuclear Power Plants" or the FERC/US Army Corp of Engineers dam inspections and maintenance programs.

E 062 BWR/PWR Group 6: Wooden Piles; Loss of material; change AMP XI.S7, No III.A6.TP-223 sheeting in material properties due "Inspection of to weathering, chemical Water-Control degradation, and insect Structures infestation repeated Associated with wetting and drying, fungal Nuclear Power decay Plants" or the FERC/US Army Corp of Engineers dam inspections and maintenance programs.

063 BWR/PWR Groups 1-3, 5, 7-9: Increase in porosity and AMP XI.S6, No III.A1.TP-24 concrete (accessible permeability; loss of "Structures III.A2.TP-24 areas): exterior above- strength due to leaching Monitoring" III.A3.TP-24 and below-grade; of calcium hydroxide and III.A5.TP-24 foundation carbonation III.A7.TP-24 III.A8.TP-24 III.A9.TP-24 064 BWR/PWR Groups 1-3, 5, 7-9: Loss of material (spalling, AMP XI.S6, No III.A1.TP-23 Page 24 of 31 concrete (accessible scaling) and cracking due "Structures III.A2.TP-23 areas): exterior above- to freeze-thaw Monitoring" III.A3.TP-23 and below-grade; III.A5.TP-23 foundation III.A7.TP-23 III.A8.TP-23 III.A9.TP-23

Table 3.5-1 Summary of Aging Management Programs for Containments, Structures and Component Supports Evaluated in Chapters II and III of the SLR-ISG-2021-03-STRUCTURES: Appendix E GALL-SLR Report New, Aging Modified, Management Deleted, Aging Program Further Evaluation GALL-SLR Edited Item ID Type Component Effect/Mechanism (AMP)/TLAA Recommended Item 065 BWR/PWR Groups 1-3, 5, 7-9: Cracking; loss of bond; AMP XI.S6, No III.A1.TP-212 concrete (inaccessible and loss of material "Structures III.A1.TP-27 areas): below-grade (spalling, scaling) due to Monitoring" III.A2.TP-212 exterior; foundation, corrosion of embedded III.A2.TP-27 Groups 1-3, 5, 7-9: steel III.A3.TP-212 concrete (accessible III.A3.TP-27 areas): below-grade III.A5.TP-212 exterior; foundation, III.A5.TP-27 Groups 6: concrete III.A6.TP-104 (inaccessible areas): all III.A7.TP-212 III.A7.TP-27 III.A8.TP-212 III.A8.TP-27 III.A9.TP-212 III.A9.TP-27 066 BWR/PWR Groups 1-5, 7, 9: Cracking; loss of bond; AMP XI.S6, No III.A1.TP-26 concrete (accessible and loss of material "Structures III.A2.TP-26 areas): interior and (spalling, scaling) due to Monitoring" III.A3.TP-26 above-grade exterior corrosion of embedded III.A4.TP-26 steel III.A5.TP-26 III.A7.TP-26 III.A9.TP-26 067 BWR/PWR Groups 1-5, 7, 9: Increase in porosity and AMP XI.S6, No III.A1.TP-28 Concrete: interior; permeability; cracking; "Structures III.A1.TP-29 above-grade exterior, loss of material (spalling, Monitoring" III.A2.TP-28 Groups 1-3, 5, 7 scaling) due to aggressive III.A2.TP-29 concrete (inaccessible chemical attack III.A3.TP-28 areas): below-grade III.A3.TP-29 exterior; foundation, III.A4.TP-28 Group 6: concrete III.A5.TP-28 (inaccessible areas): all III.A5.TP-29 III.A6.TP-107 III.A7.TP-28 Page 25 of 31 III.A7.TP-29 III.A8.TP-29 III.A9.TP-28 III.A9.TP-29

Table 3.5-1 Summary of Aging Management Programs for Containments, Structures and Component Supports Evaluated in Chapters II and III of the SLR-ISG-2021-03-STRUCTURES: Appendix E GALL-SLR Report New, Aging Modified, Management Deleted, Aging Program Further Evaluation GALL-SLR Edited Item ID Type Component Effect/Mechanism (AMP)/TLAA Recommended Item M 068 BWR/PWR High-strength steel Cracking due to SCC AMP XI.S3, No III.B1.1.TP-41 structural bolting "ASME Section XI, Subsection IWF" D 069 070 BWR/PWR Masonry walls: all Cracking due to restraint AMP XI.S5, No III.A1.T-12 shrinkage, creep, "Masonry Walls" III.A2.T-12 aggressive environment III.A3.T-12 III.A5.T-12 III.A6.T-12 M 071 BWR/PWR Masonry walls: all Loss of material (spalling, AMP XI.S5, No III.A1.TP-34 scaling) and cracking due "Masonry Walls" III.A2.TP-34 to freeze-thaw III.A3.TP-34 III.A5.TP-34 III.A6.TP-34 M 072 BWR/PWR Seals; gasket; moisture Loss of sealing due to AMP XI.S6, No III.A6.TP-7 barriers (caulking, wear, damage, erosion, "Structures flashing, and other tear, surface cracks, other Monitoring" sealants) defects 073 BWR/PWR Service Level I coatings Loss of coating or lining AMP XI.S8, No III.A4.TP-301 integrity due to blistering, "Protective cracking, flaking, peeling, Coating Monitoring delamination, rusting, or and Maintenance" physical damage M 074 BWR/PWR Sliding support bearings; Loss of mechanical AMP XI.S6, No III.B2.TP-46 sliding support surfaces function due to corrosion, "Structures III.B2.TP-47 distortion, dirt or debris Monitoring" III.B4.TP-46 accumulation, overload, III.B4.TP-47 wear M 075 BWR/PWR Sliding surfaces Loss of mechanical AMP XI.S3, No III.B1.1.TP-45 function due to corrosion, "ASME Section XI, III.B1.2.TP-45 distortion, dirt or debris Subsection IWF" III.B1.3.TP-45 accumulation, overload, Page 26 of 31 wear M 076 BWR/PWR Sliding surfaces: radial Loss of mechanical AMP XI.S6, No III.A4.TP-35 beam seats in BWR function due to corrosion, "Structures drywell distortion, dirt or debris Monitoring" accumulation, overload, wear

Table 3.5-1 Summary of Aging Management Programs for Containments, Structures and Component Supports Evaluated in Chapters II and III of the SLR-ISG-2021-03-STRUCTURES: Appendix E GALL-SLR Report New, Aging Modified, Management Deleted, Aging Program Further Evaluation GALL-SLR Edited Item ID Type Component Effect/Mechanism (AMP)/TLAA Recommended Item E 077 BWR/PWR Steel components: all Loss of material due to AMP XI.S6, No III.A1.TP-302 structural steel corrosion "Structures III.A2.TP-302 Monitoring" III.A3.TP-302 III.A4.TP-302 III.A5.TP-302 III.A7.TP-302 III.A8.TP-302 M 078 BWR/PWR Stainless steel fuel pool Cracking due to SCC; AMP XI.M2, No III.A5.T-14 liner Loss of material due to "Water Chemistry,"

pitting and crevice and monitoring of corrosion the spent fuel pool water level and leakage from the leak chase channels.

079 BWR/PWR Steel components: piles Loss of material due to AMP XI.S6, No III.A3.TP-219 corrosion "Structures Monitoring" 080 BWR/PWR Structural bolting Loss of material due to AMP XI.S6, No III.A1.TP-248 general, pitting, crevice "Structures III.A2.TP-248 corrosion Monitoring" III.A3.TP-248 III.A4.TP-248 III.A5.TP-248 III.A6.TP-248 III.A7.TP-248 III.A8.TP-248 III.A9.TP-248 III.B2.TP-248 III.B3.TP-248 III.B4.TP-248 III.B5.TP-248 081 BWR/PWR Structural bolting Loss of material due to AMP XI.S3, No III.B1.1.TP-226 Page 27 of 31 general, pitting, crevice "ASME Section XI, III.B1.2.TP-226 corrosion Subsection IWF" III.B1.3.TP-226

Table 3.5-1 Summary of Aging Management Programs for Containments, Structures and Component Supports Evaluated in Chapters II and III of the SLR-ISG-2021-03-STRUCTURES: Appendix E GALL-SLR Report New, Aging Modified, Management Deleted, Aging Program Further Evaluation GALL-SLR Edited Item ID Type Component Effect/Mechanism (AMP)/TLAA Recommended Item 082 BWR/PWR Structural bolting Loss of material due to AMP XI.S6, No III.A1.TP-274 general, pitting, crevice "Structures III.A2.TP-274 corrosion Monitoring" III.A3.TP-274 III.A4.TP-274 III.A5.TP-274 III.A7.TP-274 III.A8.TP-274 III.A9.TP-274 III.B2.TP-274 III.B3.TP-274 III.B4.TP-274 III.B5.TP-274 E 083 BWR/PWR Structural bolting Loss of material due to AMP XI.S7, No III.A6.TP-221 general, pitting, crevice "Inspection of corrosion Water-Control Structures Associated with Nuclear Power Plants" or the FERC/US Army Corp of Engineers dam inspections and maintenance programs.

D 084 M 085 BWR/PWR Structural bolting Loss of material due to AMP XI.M2, No III.B1.1.TP-232 pitting, crevice corrosion "Water Chemistry," III.B1.2.TP-232 and AMP XI.S3, III.B1.3.TP-232 "ASME Section XI, Subsection IWF" 086 BWR/PWR Structural bolting Loss of material due to AMP XI.S3, No III.B1.1.TP-235 pitting, crevice corrosion "ASME Section XI, III.B1.2.TP-235 Page 28 of 31 Subsection IWF" III.B1.3.TP-235 087 BWR/PWR Structural bolting Loss of preload due to AMP XI.S3, No III.B1.1.TP-229 self-loosening "ASME Section XI, III.B1.2.TP-229 Subsection IWF" III.B1.3.TP-229

Table 3.5-1 Summary of Aging Management Programs for Containments, Structures and Component Supports Evaluated in Chapters II and III of the SLR-ISG-2021-03-STRUCTURES: Appendix E GALL-SLR Report New, Aging Modified, Management Deleted, Aging Program Further Evaluation GALL-SLR Edited Item ID Type Component Effect/Mechanism (AMP)/TLAA Recommended Item 088 BWR/PWR Structural bolting Loss of preload due to AMP XI.S6, No III.A1.TP-261 self-loosening "Structures III.A2.TP-261 Monitoring" III.A3.TP-261 III.A4.TP-261 III.A5.TP-261 III.A6.TP-261 III.A7.TP-261 III.A8.TP-261 III.A9.TP-261 III.B2.TP-261 III.B3.TP-261 III.B4.TP-261 III.B5.TP-261 089 PWR Support members; welds; Loss of material due to AMP XI.M10, No III.B1.1.T-25 bolted connections; boric acid corrosion "Boric Acid III.B1.1.TP-3 support anchorage to Corrosion" III.B1.2.T-25 building structure III.B1.3.TP-3 III.B1.2.TP-3 III.B2.T-25 III.B2.TP-3 III.B3.T-25 III.B3.TP-3 III.B4.T-25 III.B4.TP-3 III.B5.T-25 III.B5.TP-3 E 090 BWR/PWR Support members; welds; Loss of material due to AMP XI.M2, No III.B1.1.TP-10 bolted connections; general (steel only), "Water Chemistry,"

support anchorage to pitting, crevice corrosion and AMP XI.S3, building structure "ASME Section XI, Subsection IWF" 091 BWR/PWR Support members; welds; Loss of material due to AMP XI.S3, No III.B1.1.T-24 Page 29 of 31 bolted connections; general, pitting corrosion "ASME Section XI, III.B1.2.T-24 support anchorage to Subsection IWF" III.B1.3.T-24 building structure

Table 3.5-1 Summary of Aging Management Programs for Containments, Structures and Component Supports Evaluated in Chapters II and III of the SLR-ISG-2021-03-STRUCTURES: Appendix E GALL-SLR Report New, Aging Modified, Management Deleted, Aging Program Further Evaluation GALL-SLR Edited Item ID Type Component Effect/Mechanism (AMP)/TLAA Recommended Item 092 BWR/PWR Support members; welds; Loss of material due to AMP XI.S6, No III.B2.TP-43 bolted connections; general, pitting corrosion "Structures III.B3.TP-43 support anchorage to Monitoring" III.B4.TP-43 building structure III.B5.TP-43 M 093 BWR/PWR Galvanized steel support Loss of material due to AMP XI.S6, No III.B2.TP-6 members; welds; bolted pitting, crevice corrosion "Structures III.B4.TP-6 connections; support Monitoring" anchorage to building structure M 094 BWR/PWR Vibration isolation Reduction or loss of AMP XI.S3, No III.B1.1.T-33 elements isolation function due to "ASME Section XI, III.B1.2.T-33 radiation hardening, Subsection IWF," III.B1.3.T-33 temperature, humidity, and/or AMP XI.S6, III.B4.TP-44 sustained vibratory "Structures loading Monitoring" E 095 BWR/PWR Galvanized steel support None None No III.B1.1.TP-8 members; welds; bolted III.B1.2.TP-8 connections; support III.B1.3.TP-8 anchorage to building III.B2.TP-8 structure III.B3.TP-8 III.B4.TP-8 III.B5.TP-8 N 096 BWR/PWR Groups 6: concrete Cracking due to AMP XI.S7, No III.A6.T-34 (accessible areas): all expansion from reaction "Inspection of with aggregates Water-Control Structures Associated with Nuclear Power Plants" NM 097 BWR/PWR Group 4: Concrete Reduction of strength; Plant-specific Yes (SRP-SLR III.A4.T-35 (reactor cavity area loss of mechanical aging Section 3.5.2.2.2.6) proximate to the reactor properties due to management Page 30 of 31 vessel): reactor irradiation (i.e., radiation program or (primary/biological) shield interactions with material plant-specific wall; sacrificial shield and radiation-induced enhancements to wall; reactor vessel heating) selected AMPs support/pedestal structure

Table 3.5-1 Summary of Aging Management Programs for Containments, Structures and Component Supports Evaluated in Chapters II and III of the SLR-ISG-2021-03-STRUCTURES: Appendix E GALL-SLR Report New, Aging Modified, Management Deleted, Aging Program Further Evaluation GALL-SLR Edited Item ID Type Component Effect/Mechanism (AMP)/TLAA Recommended Item N 098 BWR/PWR Stainless steel, aluminum None None No III.B1.1.TP-4 alloy support members; III.B1.2.TP-4 welds; bolted III.B1.3.TP-4 connections; support III.B2.TP-4 anchorage to building III.B3.TP-4 structure III.B4.TP-4 III.B5.TP-4 N 099 BWR/PWR Aluminum, stainless steel Loss of material due to AMP XI.M32, Yes (SRP-SLR III.B1.1.T-36a support members; welds; pitting and crevice "One-Time Section 3.5.2.2.2.4) III.B1.1.T-36b bolted connections; corrosion, cracking due to Inspection," III.B1.1.T-36c support anchorage to SCC AMP XI.S3, III.B1.2.T-36a building structure "ASME Section XI, III.B1.2.T-36b Subsection IWF," III.B1.2.T-36c or AMP XI.M36, III.B1.3.T-36a "External Surfaces III.B1.3.T-36b Monitoring of III.B1.3.T-36c Mechanical Components" N 100 BWR/PWR Aluminum, stainless steel Loss of material due to AMP XI.M32, Yes (SRP-SLR III.B2.T-37a support members; welds; pitting and crevice "One-Time Section 3.5.2.2.2.4) III.B2.T-37b bolted connections; corrosion, cracking due to Inspection," III.B2.T-37c support anchorage to SCC AMP XI.S6, III.B3.T-37a building structure "Structures III.B3.T-37b Monitoring," or III.B3.T-37c AMP XI.M36, III.B4.T-37a "External Surfaces III.B4.T-37b Monitoring of III.B4.T-37c Mechanical III.B5.T-37a Components" III.B5.T-37b III.B5.T-37c Page 31 of 31

APPENDIX F DISPOSITION OF PUBLIC COMMENTS Comments received on the draft interim staff guidance (ISG) are available electronically through the U.S. Nuclear Regulatory Commissions (NRCs) electronic Reading Room at http://www.nrc.gov/reading-rm/adams.html.

From this page, the public can access the Agencywide Documents Access and Management System (ADAMS), which provides text and image files of the NRCs public documents. The following table lists the comments the NRC received on the draft version of this ISG.

Letter Number ADAMS Accession No Commenter Affiliation Commenter Name 1 ML20224A465 Nuclear Energy Institute Peter W. Kissinger The NRC received one public comment letter. The table below provides the comment number as listed in the public comment letter, the original comment as written by the commenter, and the NRC staffs response.

Disposition of Public Comments SLR-ISG-2021-03-STRUCTURES: Appendix F Comment # ISG Section/Page Comment NRC Staff Response 1 Appendix B AMP XI.S8 Aging management of in-vessel debris limits is not Agreed and incorporated.

Page 2, 3, and 4 of 7 required. Consistent with GSI-191 evaluations and closure documentation, aging management of coating integrity and the contribution of qualified, unqualified, and damaged coatings to the ECCS suction strainer total debris term/inventory will provide reasonable assurance of ECCS sump strainer functions including associated downstream effects and in-vessel effects.

2 Appendix B, AMP XI.S8, The trending of the total amount of degraded coatings, Agreed and incorporated.

Protective Coating which is allowed, is generally completed by someone Page 1 of 7 else in the engineering organization that is Item #1 in Basis of knowledgeable of the ECCS Strainer debris loading Revision analysis and is not typically performed by the qualified coating inspector.

3 Appendix B, AMP XI.S8, Any coating degradation mechanisms noted in Agreed and incorporated.

Protective Coating item #5 second paragraph in the Basis For Revision Page 2 of 7 section is not consistent with guidance in Item #5 in Basis of NUREG-2191 AMP XI.S8. Clarify the second Revision paragraph to identify aging effects monitored or inspected (e.g., blistering, cracking, flaking, peeling, rusting, and physical damage) to be consistent with element #3 of NUREG-2191 AMP XI.S8.

Page 2 of 3

Comment # ISG Section/Page Comment NRC Staff Response SLR-ISG-2021-03-STRUCTURES: Appendix F 4 Appendices C, D, and E The use of the term enhanced as necessary in the NUREG-2192 AMP column of NUREG-2192 Table 3.5-1 and The staff did not agree with this comment. No changes Table 3.5-1, NUREG-2191 Chapter II and Chapter III AMR Tables were made to the ISG.

NUREG-2191 are not necessary and should be deleted. The ISG incorporates changes requested by Industry to Chapters II & III Tables reduce Plant-Specific AMPs associated with several Page - various structural AMR items. Specifically, by email dated January 14, 2020, the Industry noted that:

No operating experience justifies a Plant Specific AMP for these aging mechanisms.

NUREG-2192 Further Evaluations would review plant specific materials, environments, and operating experience to determine if an enhancement or a Plant Specific AMP is required in addition to those aging management activities identified in NUREG-2191 AMPs. If plant specific aging management activities are required, an AMP enhancement or plant specific AMP (AMR Note E) would be required.

The staff reviewed Industrys proposed changes and concluded that the inclusion of enhancements to AMPs XI.S2, ASME Section XI, Subsection IWL, and/or XI.S6, Structures Monitoring, would improve the efficiency of application reviews based on past reviews of LRAs and SLRAs and was therefore justified. The addition of AMP XI.S2 and/or XI.S6, along with any necessary enhancements, expands the SLR guidance to allow greater flexibility to applicants. The phrase enhance as necessary emphasizes to staff and applicants that the existing GALL SLR XI.S2 and XI.S6 AMPs may not be adequate to address the aging effects, depending on the results of the associated further evaluations. Therefore, it may be necessary for applicants to enhance their programs to adequately manage the aging effects.

Deleting enhanced as necessary from the modifications could lead to decreased efficiency in reviews, increased number of RAIs, and potential staff and applicant confusion in future implementation of the SLR guidance.

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