ML20181A434

SLR-ISG-2021-02-Mechanical - Updated Aging Management Criteria for Mechanical Portions of Subsequent License Renewal Guidance

ML20181A434
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Issue date:	02/18/2021
From:	Jeffrey Mitchell NRC/NRR/DNRL/NLRP
To:
Mitchell J
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ML2034A164	List: ML20181A434
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SLR-ISG-2021-02
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SLR-ISG-2021-02-MECHANICAL Updated Aging Management Criteria for Mechanical Portions of Subsequent License Renewal Guidance Interim Staff Guidance February 2021

ML20181A434 CAC: TM3021 OFFICE PM:DNLR:NLRP LA:DRO:IRSB PM:DRO:IRSB QTE NAME JMitchell BCurran TGovan JDougherty DATE 10/7/2020 10/09/2020 10/13/2020 10/13/2020 OFFICE STA:DNLR BC:DNLR:NLRP OGC D:NRR:DSS NAME AHiser LGibson STurk JDonoghue DATE 10/13/2020 10/13/2020 11/16/2020 11/25/2020 OFFICE D:NRR:DRO D:DNRL NAME GSuber for CMiller ABradford DATE 01/28/2021 02/16/2021 INTERIM STAFF GUIDANCE UPDATED AGING MANAGEMENT CRITERIA FOR MECHANICAL PORTIONS OF SUBSEQUENT LICENSE RENEWAL GUIDANCE SLR-ISG-2021-02-MECHANICAL PURPOSE The U.S. Nuclear Regulatory Commission (NRC) staff is providing this subsequent license renewal (SLR) interim staff guidance (ISG) to provide clarifying 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 mechanical 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, both the staff and applicants have identified ways to make the preparation and review of future SLR applications more effective and efficient.

RATIONALE Public meetings took place on March 28, 2019; December 12, 2019; February 20, 2020; March 25, 2020; April 3, 2020; and April 7, 2020, between the staff and 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:

• Aging Management Program (AMP) X.M2, Neutron Fluence Monitoring

• AMP XI.M2, Water Chemistry

• AMP XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)

• AMP XI.M21A, Closed Treated Water System

• Aging Management Review Line Items Associated with AMP XI.M26, Fire Protection

• SRP-SLR Table 3.3-1 and GALL-SLR Table VII H2 to Address Reduction of Heat Transfer for Heat Exchanger Tubes in a Fuel Oil Environment

SLR-ISG-2021-02-MECHANICAL Page 2 of 4

• SRP-SLR Table 3.3-1 and GALL-SLR Table VII H2 to Address Loss of Material in Nickel Alloy Strainer Components in Fuel Oil

• AMP XI.M42, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks 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 The NRC provides requirements for the submission and review of applications to extend plant operations beyond the initial 40-year operating period in 10 CFR Part 54.

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 a number of 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 that the information provided in this ISG provides an acceptable approach for managing aging in mechanical components within the scope of 10 CFR Part 54 and 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 subsequent license renewal application demonstrates that the effects of aging on structures and components subject to an aging management review are adequately managed so 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 AMPs 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 on 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 on 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.

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,

SLR-ISG-2021-02-MECHANICAL Page 3 of 4 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.

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.

SLR-ISG-2021-02-MECHANICAL Page 4 of 4 FINAL RESOLUTION By July 1, 2027, the staff will transition this information into NUREG-2191 (GALL-SLR Report) and NUREG-2192 (SRP-SLR). Following the transition of this guidance to NUREG-2191 and NUREG-2192, this ISG will be closed.

APPENDICES A. Revisions to Aging Management Program (AMP) X.M2, Neutron Fluence Monitoring B. Revisions to AMP XI.M2, Water Chemistry C. Revisions to AMP XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)

D. Revisions to AMP XI.M21A, Closed Treated Water System E. Revisions to Aging Management Review Line Items Associated with AMP XI.M26, Fire Protection F. Revisions to SRP-SLR Table 3.3-1 and GALL-SLR Table VII H2 to Address Reduction of Heat Transfer for Heat Exchanger Tubes in a Fuel Oil Environment G. Revisions to SRP-SLR Table 3.3-1 and GALL-SLR Table VII H2 to Address Loss of Material in Nickel Alloy Strainer Components in Fuel Oil H. Revisions to AMP XI.M42, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks I. Disposition of Public Comments

APPENDIX A REVISIONS TO AGING MANAGEMENT PROGRAM (AMP) X.M2, NEUTRON FLUENCE MONITORING Summary of Revisions This ISG revises AMP X.M2 to reference approaches that have been found to be acceptable in recent staff reviews of extended beltline and reactor vessel internals fluence calculations, as RG 1.190 is not applicable, and the NRC staff continues to develop regulatory guidance for such calculations.

Basis for Revisions The added references to this AMP provide examples of acceptable approaches from recent reviews. These examples provided acceptable justification to apply the methods used for fluence calculations in the traditional reactor vessel beltline, to the extended beltline and to reactor vessel internal components.

AMP Revisions Program Description This aging management program (AMP) provides a means to ensure the validity of the neutron fluence analysis and related neutron fluence-based, time-limited aging analyses (TLAAs). In so doing, this AMP also provides an acceptable basis for managing aging effects attributable to neutron fluence in accordance with requirements in Title 10 of the Code of Federal Regulations (10 CFR) 54.21(c)(1)(iii). This program monitors neutron fluence for reactor pressure vessel (RPV) components and reactor vessel internal (RVI) components and is used in conjunction with the Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report AMP XI.M31, Reactor Vessel Material Surveillance. Neutron fluence is a time-dependent input parameter for evaluating the loss of fracture toughness due to neutron irradiation embrittlement.

Accurate neutron fluence values are also necessary to identify the RPV beltline region, for which neutron fluence is projected to exceed 1 x 1017 n/cm2 (E > 1 MeV) during the subsequent period of extended operation.

Neutron fluence is an input to a number of RPV irradiation embrittlement analyses that are required by specific regulations in 10 CFR Part 50. These analyses are TLAAs for subsequent license renewal applications (SLRAs) and are the topic of the acceptance criteria and review procedures in Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants (SRP-SLR) Section 4.2, Reactor Vessel Neutron Embrittlement Analyses. The neutron irradiation embrittlement TLAAs that are within the scope of this AMP include, but are not limited to: (a) neutron fluence, (b) pressurized thermal shock analyses for pressurized water reactors, as required by 10 CFR 50.61 or alternatively [if applicable for the current licensing basis (CLB)] by 10 CFR 50.61a; (c) RPV upper-shelf energy analyses, as required by Section IV.A.1 of 10 CFR Part 50, Appendix G, and (d) pressure-temperature (P-T) limit analyses that are required by Section IV.A.2 of 10 CFR Part 50, Appendix G and controlled by plant technical specifications (TS) update and reporting requirements (i.e., the 10 CFR 50.90 license amendment process for updates of P-T limit curves located in the TS limiting conditions

SLR-ISG-2021-02-MECHANICAL: Appendix A Page 2 of 6 of operation, or TS administrative control section requirements for updates of P-T limit curves that have been relocated into a pressure-temperature limits report).

The calculations of neutron fluence also factor into other analyses or technical report methodologies that assess irradiation-related aging effects. Examples include, but are not limited to: (a) determination of the RPV beltline as defined in Regulatory Issue Summary 2014-11, Information On Licensing Applications For Fracture Toughness Requirements For Ferritic Reactor Coolant Pressure Boundary Components, (b) evaluation of the susceptibility of RVI components to neutron radiation damage mechanisms, including irradiation embrittlement (IE), irradiation-assisted stress corrosion cracking (IASCC),

irradiation-enhanced stress relaxation or creep (IESRC) and void swelling or neutron induced component distortion; and (c) evaluating the dosimetry data obtained from an RPV surveillance program.

Guidance on acceptable methods and assumptions for determining reactor vessel neutron fluence is described in the U.S. Nuclear Regulatory Commission (NRC) Regulatory Guide (RG) 1.190, Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence. The methods developed and approved using the guidance contained in RG 1.190 are specifically intended for determining neutron fluence in the region of the RPV close to the active fuel region of the core and are not intended to apply to vessel regions significantly above and below the active fuel region of the core, nor to RVI components. Therefore, the use of RG 1.190-adherent methods to estimate neutron fluence for the RPV regions significantly above and below the active fuel region of the core and RVI components may require additional justification, even if those methods were approved by the NRC for RPV neutron fluence calculations. This program monitors in-vessel or ex-vessel dosimetry capsules and evaluates the dosimetry data, as needed. Additional in-vessel or ex-vessel dosimetry capsules may be needed when the reactor surveillance program has exhausted the available capsules for in-vessel exposure.

Evaluation and Technical Basis

1. Scope of Program: The scope of the program includes RPV and RVI components that are subject to a neutron embrittlement TLAA or other analysis involving time-dependent neutron irradiation. The program monitors neutron fluence throughout the subsequent period of extended operation for determining the susceptibility of the components to IE, IASCC, IESRC, and void swelling or distortion. The use of this program also continues to ensure the adequacy of the neutron fluence estimates by: (a) monitoring plant and core operating conditions relative to the assumptions used in the neutron fluence calculations, and (b) continuously updating the qualification database associated with the neutron fluence method as new calculational and measurement data become available for benchmarking. This program is used in conjunction with GALL-SLR Report AMP XI.M31, Reactor Vessel Material Surveillance.

Updated neutron fluence calculations, plant modifications, and RPV surveillance program data are used to identify component locations within the scope of this program, including the beltline region of the RPV. Applicable requirements in 10 CFR Part 50, and if appropriate, plant TS, related to calculating neutron fluence estimates and incorporating those calculations into neutron irradiation analyses for the RPVs and RVIs must be met.

SLR-ISG-2021-02-MECHANICAL: Appendix A Page 3 of 6

2. Preventive Actions: This program is a condition monitoring program through calculation of neutron fluence values, and continuous monitoring of their validity; thus, there are no specific preventive actions. Because this program can be used to verify that the inputs and assumptions associated with neutron fluence in the irradiation embrittlement TLAAs (described in SRP-SLR Section 4.2) remain within their respective limits, this program can prevent those TLAAs from being outside of the acceptance criteria that are set as regulatory or design limits in the analyses. Since the program is used to determine that the inputs and assumptions associated with neutron fluence in irradiation embrittlement TLAAs will remain within their respective limits, this program does have some preventative aspects to it.

3. Parameters Monitored or Inspected: The program monitors component neutron fluence as determined by the neutron fluence analyses, and appropriate plant and core operating parameters that affect the calculated neutron fluence. The calculational methods, benchmarking, qualification, and surveillance data are monitored to maintain the adequacy of neutron fluence calculations. Neutron fluence levels in specific components are monitored to verify component locations within the scope of this program are identified.

Neutron fluence is estimated using a computational method that incorporates the following major elements: (1) determination of the geometrical and material input data for the reactor core, vessel and internals, and cavity; (2) determination of the characteristics of the neutron flux emitting from the core; (3) transport of the neutrons from the core to the vessel, and into the cavity; and (4) qualification of the calculational procedure.

Guidance on acceptable methods and assumptions for determining RPV neutron fluence is described in NRC RG 1.190. The use of RG 1.190-adherent methods to estimate neutron fluence for the RPV beltline regions significantly above and below the active fuel region of the core, and RVI components may require additional justification, even if those methods were approved by the NRC for RPV neutron fluence calculations.

4. Detection of Aging Effects: The program uses applicant-defined activities or methods to track the RPV and RVI component neutron fluence levels. The neutron fluence levels estimated in this program are used as input to the evaluation for determining applicable aging effects for RPV and RVI components, including evaluation of TLAAs as described in SRP-SLR Section 4.2.

5. Monitoring and Trending: Monitoring and trending of neutron fluence are needed to ensure the continued adequacy of various neutron fluence analyses as identified as TLAAs for the SLRA. When applied to RVI components and to components significantly above and below the active fuel region of the core, the program also assesses and justifies whether the current neutron fluence methodology for the CLB is acceptable for monitoring and projecting the neutron fluence values for these components during the subsequent period of extended operation, or else appropriately enhances (with justification) the programs monitoring and trending element activities accordingly on an as-needed basis. Trending is performed to ensure that plant and core operating conditions remain consistent with the assumptions used in the neutron fluence analyses and that the analyses are updated as necessary.

SLR-ISG-2021-02-MECHANICAL: Appendix A Page 4 of 6 Neutron fluence estimates are typically determined using a combination of plant and core operating history data that address past plant operating conditions, and projections that are intended to address future operation. Although projections for future operation may conservatively over-estimate the core neutron flux to cover potential variations in plant and core operation and increases in neutron flux at any given time, there is no explicit requirement to do so. Therefore, projections for future plant and core operation should be periodically verified to ensure that any projections used in the neutron fluence calculations remain bounding with respect to actual plant operating conditions.

This program monitors in-vessel or ex-vessel dosimetry capsules and evaluates the dosimetry data, as needed. Additional in-vessel or ex-vessel dosimetry capsules may be needed when the reactor surveillance program has exhausted the available capsules for in-vessel exposure.

6. Acceptance Criteria: There are no specified acceptance values for neutron fluence; the acceptance criteria relate to the different parameters that are evaluated using neutron fluence, as described in SRP-SLR Section 4.2.

NRC RG 1.190 provides guidance for acceptable methods to determine neutron fluence for the RPV beltline region. It should be noted, however, that applying RG 1.190-adherent methods to determine neutron fluence in locations other than those close to the active fuel region of the core may require additional justification regarding, for example, the level of detail used to represent the core neutron source, the methods to synthesize the three-dimensional flux field, and the order of angular quadrature used in the neutron transport calculations. The applicability of existing qualification data may also require additional justification.

Several examples of acceptable approaches used to provide the above-suggested justification are available. The NRC staff reviewed additional qualification data in the safety evaluation approving Licensing Topical Report BWRVIP 145NP-A, BWR Vessel Internals Project, Evaluation of Susquehanna Unit 2 Top Guide and Core Shroud Materials Samples Using RAMA Fluence Methodology.. An additional example of an approach which uses more refined nuclear and transport methods than recommended in RG 1.190, instead of additional qualification data, is available on Page 3-156 of NUREG-2181, the Safety Evaluation Report Related to the License Renewal of Sequoyah Nuclear Plant Units 1 and 2. These examples supported the qualification of different methods to estimate fluence for RVI components. Another example, specific to subsequent license renewal, is available in the NRC Staffs Safety Evaluation Report

[SER] Related to the Subsequent License Renewal of Turkey Point Generating Units 3 and 4. The NRC staffs evaluation of the fluence AMP appears on Pages 3 3-51, for RPV beltline regions significantly above and below the active fuel region of the core and RVI components. In addition, at Pages 3 3-74 of that SER, the staff evaluated plant-specific fluence calculations for RVI components to demonstrate the validity of a more generic fluence estimate for downstream consideration in the aging management of those RVI components. These examples all describe ways in which applicants justified the application of RG 1.190-adherent methods, or appropriate alternatives, to evaluate fluence in regions outside the immediate, core-adjacent area of the RPV beltline.

SLR-ISG-2021-02-MECHANICAL: Appendix A Page 5 of 6

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 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.

The program provides for corrective actions by updating the analyses for the RPV components, or assessing the need for revising the augmented inspection bases for RVI components, if the neutron fluence assumptions in RPV analyses or augmented inspection bases for RVI components are projected to be exceeded during the subsequent period of extended operation. Acceptable corrective actions include revisions to the neutron fluence calculations to incorporate additional operating history data, as such data become available; use of improved modeling approaches to obtain more accurate neutron fluence estimates; and rescreening of RPV and RVI components when the estimated neutron fluence exceeds threshold values for specific aging mechanisms.

When the fluence monitoring activities are used to confirm the validity of existing RPV neutron irradiation embrittlement analyses and result in the need for an update of an analysis that is required by a specific 10 CFR Part 50 regulation, the corrective actions to be taken follow those prescribed in the applicable regulation.

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 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: The program reviews industry and plant operating experience (OE) relevant to neutron fluence. Applicable OE affecting the neutron fluence estimate is to be considered in selecting the components for monitoring. RG 1.190 provides expectations for updating the qualification database for the neutron fluence methods via the operational experience gathered from RPV material surveillance program data.

This operational experience is in accordance with the requirements of 10 CFR Part 50 Appendix H.

The program is informed and enhanced when necessary through the systematic and ongoing review of both plant-specific and industry OE 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.

SLR-ISG-2021-02-MECHANICAL: Appendix A Page 6 of 6 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.

10 CFR Part 50, Appendix G, Fracture Toughness Requirements. Washington, DC:

U.S. Nuclear Regulatory Commission. 2016.

10 CFR Part 50, Appendix H, Reactor Vessel Material Surveillance Program Requirements.

Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

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

10 CFR 50.60, Acceptance Criteria for Fracture Prevention Measures for Lightwater Nuclear Power Reactors for Normal Operation. Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.61, Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events. Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

10 CFR 50.61a, Alternate Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events. Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

NRC. Regulatory Guide 1.190, Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence. Agencywide Documents Access and Management System (ADAMS)

Accession No. ML010890301. Washington, DC: U.S. Nuclear Regulatory Commission.

March 2001.

. NUREG-2181, Safety Evaluation Report Related to the License Renewal of Sequoyah Nuclear Plant Units 1 and 2. Dockets 50-327 and 50-328, ADAMS Accession No. ML15187A206. Washington, DC: U.S. Nuclear Regulatory Commission. July 2015.

. Safety Evaluation Report Related to the Subsequent License Renewal of Turkey Point Generating Units 3 and 4. Dockets 50-250 and 50-251, ADAMS Accession No. ML19191A057.

Washington, DC: U.S. Nuclear Regulatory Commission. December 2019.

Watkins, K.E., BWR Vessel Internals Project, Evaluation of Susquehanna Unit 2 Top Guide and Core Shroud Materials Samples Using RAMA Fluence Methodology, BWRVIP-145-NP-A, ADAMS Accession No. ML100260948. Palo Alto, CA: Electric Power Research Institute.

October 2009.

Revisions to FSAR Supplement None Revisions to AMR Items None

APPENDIX B REVISIONS TO AGING MANAGEMENT PROGRAM XI.M2, WATER CHEMISTRY Summary of Revisions This ISG revises AMP XI.M2, Water Chemistry, to include the latest revision of EPRI guidelines for BWR and PWR.

Basis for Revisions EPRI issued 3002010645, Pressurized Water Reactor Secondary Water Chemistry Guidelines, Revision 8, in 2017 from the previous version (1016555). According to EPRI, a committee of industry experts collaborated in reviewing data and generating water-chemistry guidelines, which should be used at all nuclear plants, that has been endorsed by the utility chemistry community. Approved precedent for use of the more recent version of the above guideline is documented in the NRC staffs SER for subsequent license renewal of Surry Units 1 and 2 (Agencywide Documents Access Management System (ADAMS) Accession No. ML20052F523)

EPRI has issued BWRVIP-190, BWR Water Chemistry Guidelines - Mandatory, Needed, and Good Practice Guidance. Revision 1. Consistent with the staffs evaluation of an exception documented in NUREG-2205, Safety Evaluation Report Related to the License Renewal of LaSalle County Station, Units 1 and 2, September 2016, Section 3.0.3.2.1, Water Chemistry, the staff finds the use of BWRVIP-190, Revision 1, BWR Vessel and Internals Project, Volume 1, BWR Water Chemistry Guidelines - Mandatory, Needed, and Good Practice Guidance, EPRI 3002002623, dated April 24, 2014, acceptable to cite.

AMP Revisions Program Description The main objective of this program is to mitigate loss of material due to corrosion, cracking due to stress corrosion cracking (SCC) and related mechanisms, and reduction of heat transfer due to fouling in components exposed to a treated water environment. The program includes periodic monitoring of the treated water in order to minimize loss of material or cracking.

The water chemistry program for boiling water reactors (BWRs) relies on monitoring and control of reactor water chemistry based on industry guidelines contained in the Boiling Water Reactor Vessel and Internals Project (BWRVIP)-190 (Electric Power Research Institute (EPRI) 3002002623, BWR Vessel and Internals Project: BWR Water Chemistry Guidelines, Revision 1. 1016579The BWRVIP-190 has three sets of guidelines: (i) one for reactor water, (ii) one for condensate and feedwater, and (iii) one for control rod drive mechanism cooling water.

The water chemistry program for pressurized water reactors (PWRs) relies on monitoring and control of reactor water chemistry based on industry guidelines contained in EPRI 30020005051014986, PWR Primary Water Chemistry Guidelines, Revision 7 and EPRI 30020106451016555, PWR Secondary Water Chemistry Guidelines, Revision 87.

The water chemistry programs are generally effective in removing impurities from intermediate and high flow areas. The Generic Aging Lessons Learned for Subsequent License Renewal

SLR-ISG-2021-02-MECHANICAL: Appendix B Page 2 of 10 (GALL-SLR) Report identifies those circumstances in which the water chemistry program is to be augmented to manage the effects of aging for license renewal. For example, the water chemistry program may not be effective in low flow or stagnant flow areas. Accordingly, in certain cases as identified in the GALL-SLR Report, verification of the effectiveness of the chemistry control program is undertaken to provide reasonable assurance that significant degradation is not occurring and that the components intended function is maintained during the subsequent period of extended operation. For these specific cases, an acceptable verification program is a one-time inspection of selected components at susceptible locations in the system.

Evaluation and Technical Basis

1. Scope of Program: The program includes components in the reactor coolant system, the engineered safety features, the auxiliary systems, and the steam and power conversion system. This program addresses the metallic components subject to aging management review that are exposed to a treated water environment controlled by the water chemistry program.

2. Preventive Actions: The program includes specifications for chemical species, impurities and additives, sampling and analysis frequencies, and corrective actions for control of reactor water chemistry. System water chemistry is controlled to minimize contaminant concentration and mitigate loss of material due to general, crevice, and pitting corrosion and cracking caused by SCC. For BWRs, maintaining high water purity reduces susceptibility to SCC, and chemical additive programs such as hydrogen water chemistry or noble metal chemical application also may be used. For PWRs, additives are used for reactivity control, to control pH and dose rates, and inhibit corrosion.

3. Parameters Monitored or Inspected: The concentrations of corrosive impurities listed in the EPRI water chemistry guidelines are monitored to mitigate loss of material, cracking, and reduction of heat transfer. Water quality also is maintained in accordance with the guidance. Chemical species and water quality are monitored by in-process methods or through sampling. The chemical integrity of the samples is maintained and verified to provide reasonable assurance that the method of sampling and storage will not cause a change in the concentration of the chemical species in the samples.

4. Detection of Aging Effects: This is a mitigation program and does not provide for detection of any aging effects of concern for the components within its scope. The monitoring methods and frequency of water chemistry sampling and testing is performed in accordance with the EPRI water chemistry guidelines and based on plant operating conditions. The main objective of this program is to mitigate loss of material due to corrosion and cracking due to SCC in components exposed to a treated water environment.

5. Monitoring and Trending: Chemistry parameter data are recorded, evaluated, and trended in accordance with the EPRI water chemistry guidelines.

6. Acceptance Criteria: Maximum levels for various chemical parameters are maintained within the system-specific limits as indicated by the limits specified in the corresponding EPRI water chemistry guidelines.

SLR-ISG-2021-02-MECHANICAL: Appendix B Page 3 of 10

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 aging management program (AMP) for both safety-related and nonsafety-related structures and components (SCs) within the scope of this program.

Any evidence of aging effects or unacceptable water chemistry results are evaluated, the cause identified, and the condition corrected. When measured water chemistry parameters are outside the specified range, corrective actions are taken to bring the parameter back within the acceptable range (or to change the operational mode of the plant) within the time period specified in the EPRI water chemistry guidelines.

Whenever corrective actions are taken to address an abnormal chemistry condition, increased sampling or other appropriate actions are taken and analyzed to verify that the corrective actions were effective in returning the concentrations of contaminants, such as chlorides, fluorides, sulfates, and dissolved oxygen, to within the acceptable ranges.

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 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: The EPRI guideline documents have been developed based on plant experience and have been shown to be effective over time with their widespread use. The specific examples of operating experience (OE) are as follows:

BWR: Intergranular stress corrosion cracking (IGSCC) has occurred in small- and large-diameter BWR piping made of austenitic stainless steels (SSs) and nickel-base alloys. Significant cracking has occurred in recirculation, core spray, residual heat removal systems, and reactor water cleanup system piping welds. IGSCC has also occurred in a number of vessel internal components, including core shroud, access hole cover, top guide, and core spray spargers [U.S. Nuclear Regulatory Commission (NRC) Inspection and Enforcement Bulletin (IEB) 80-13, NRC Information Notice (IN) 95-17, NRC Generic Letter (GL) 94-03, and NUREG-1544]. No occurrence of SCC in piping and other components in standby liquid control systems exposed to sodium pentaborate solution has ever been reported (NUREG/CR-6001).

SLR-ISG-2021-02-MECHANICAL: Appendix B Page 4 of 10 PWR Primary System: The potential for SCC-type mechanisms might normally occur because of inadvertent introduction of contaminants into the primary coolant system, including contaminants introduced from the free surface of the spent fuel pool (which can be a natural collector of airborne contaminants) or the introduction of oxygen during plant cooldowns (NRC IN 84-18). Ingress of demineralizer resins into the primary system has caused IGSCC of Alloy 600 vessel head penetrations (NRC IN 96-11, NRC GL 97-01).

Inadvertent introduction of sodium thiosulfate into the primary system has caused IGSCC of steam generator tubes. SCC has occurred in safety injection lines (NRC INs 97-19 and 84-18), charging pump casing cladding (NRC INs 80-38 and 94-63),

instrument nozzles in safety injection tanks (NRC IN 91-05), and safety-related SS piping systems that contain oxygenated, stagnant, or essentially stagnant borated coolant (NRC IN 97-19). Steam generator tubes and plugs and Alloy 600 penetrations have experienced primary water SCC (NRC INs 89-33, 94-87, 97-88, 90-10, and 96-11; NRC Bulletin 89-01 and its two supplements). IGSCC-induced circumferential cracking has occurred in PWR pressurizer heater sleeves (NRC IN 2006-27).

PWR Secondary System: Steam generator tubes have experienced outside diameter stress corrosion cracking, intergranular attack, wastage, and pitting (NRC IN 97-88, NRC GL 95-05). Carbon steel support plates in steam generators have experienced general corrosion. The steam generator shell has experienced pitting and SCC (NRC INs 82-37, 85-65, and 90-04). Extensive buildup of deposits at steam generator tube support holes can result in flow-induced vibrations and tube cracking (NRC-IN-2007-37).

Such OE has provided feedback to revisions of the EPRI water chemistry guideline documents.

The program is informed and enhanced when necessary through the systematic and ongoing review of both plant-specific and industry OE 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.

EPRI. BWRVIP-190 (EPRI 10165793002002623), BWR Vessel and Internals Project: BWR Water Chemistry Guidelines.-2008 Revision 1. Palo Alto, California: Electric Power Research Institute. October 2008April 2014.

. EPRI 1014986 3002000505, PWR Primary Water Chemistry Guidelines. Revision 7, Volumes 1 and 2. Palo Alto, California: Electric Power Research Institute. April 2014.

. EPRI 10165553002010645, PWR Secondary Water Chemistry Guidelines. Revision

78. Palo Alto, California: Electric Power Research Institute. February 2009September 2017.

NRC.Bulletin 89-01, Failure of Westinghouse Steam Generator Tube Mechanical Plugs.

Washington, DC: U.S. Nuclear Regulatory Commission. May 1989.

SLR-ISG-2021-02-MECHANICAL: Appendix B Page 5 of 10

.Bulletin 89-01, Supplement 1, Failure of Westinghouse Steam Generator Tube Mechanical Plugs. Washington, DC: U.S. Nuclear Regulatory Commission. November 1989.

.Bulletin 89-01, Supplement 2, Failure of Westinghouse Steam Generator Tube Mechanical Plugs. Washington, DC: U.S. Nuclear Regulatory Commission. June 1991.

. Generic Letter 94-03, Intergranular Stress Corrosion Cracking of Core Shrouds in Boiling Water Reactors. Washington, DC: U.S. Nuclear Regulatory Commission. July 1994.

. Generic Letter 95-05, Voltage-Based Repair Criteria for Westinghouse Steam Generator Tubes Affected by Outside Diameter Stress Corrosion Cracking. Washington, DC: U.S. Nuclear Regulatory Commission. August 1995.

. Generic Letter 97-01, Degradation of Control Rod Drive Mechanism Nozzle and Other Vessel Closure Head Penetrations. Washington, DC: U.S. Nuclear Regulatory Commission. April 1997.

. IE Bulletin 80-13, Cracking in Core Spray Piping. Washington, DC: U.S.

Nuclear Regulatory Commission. May 1980.

. Information Notice 80-38, Cracking In Charging Pump Casing Cladding. Washington, DC: U.S. Nuclear Regulatory Commission. October 1980.

. Information Notice 82-37, Cracking in the Upper Shell to Transition Cone Girth Weld of a Steam Generator at an Operating PWR. Washington, DC: U.S. Nuclear Regulatory Commission. September 1982.

. Information Notice 84-18, Stress Corrosion Cracking in Pressurized Water Reactor Systems. Washington, DC: U.S. Nuclear Regulatory Commission. March 1984.

. Information Notice 85-65, Crack Growth in Steam Generator Girth Welds. Washington, DC: U.S. Nuclear Regulatory Commission. July 1985.

. Information Notice 89-33, Potential Failure of Westinghouse Steam Generator Tube Mechanical Plugs. Washington, DC: U.S. Nuclear Regulatory Commission. March 1989.

. Information Notice 90-04, Cracking of the Upper Shell-to-Transition Cone Girth Welds in Steam Generators. Washington, DC: U.S. Nuclear Regulatory Commission. January 1990.

. Information Notice 90-10, Primary Water Stress Corrosion Cracking (PWSCC) of Inconel 600. Washington, DC: U.S. Nuclear Regulatory Commission. February 1990.

. Information Notice 91-05, Intergranular Stress Corrosion Cracking In Pressurized Water Reactor Safety Injection Accumulator Nozzles. Washington, DC: U.S. Nuclear Regulatory Commission. January 1991.

SLR-ISG-2021-02-MECHANICAL: Appendix B Page 6 of 10

. Information Notice 94-63, Boric Acid Corrosion of Charging Pump Casing Caused by Cladding Cracks. Washington, DC: U.S. Nuclear Regulatory Commission. August 1994.

. Information Notice 94-87, Unanticipated Crack in a Particular Heat of Alloy 600 Used for Westinghouse Mechanical Plugs for Steam Generator Tubes. Washington, DC: U.S. Nuclear Regulatory Commission. December 1994.

. Information Notice 95-17, Reactor Vessel Top Guide and Core Plate Cracking. Washington, DC: U.S. Nuclear Regulatory Commission. March 1995.

. Information Notice 96-11, Ingress of Demineralizer Resins Increase Potential for Stress Corrosion Cracking of Control Rod Drive Mechanism Penetrations. Washington, DC:

U.S. Nuclear Regulatory Commission. February 1996.

. Information Notice 97-19, Safety Injection System Weld Flaw at Sequoyah Nuclear Power Plant, Unit 2. Washington, DC: U.S. Nuclear Regulatory Commission.

April 1997.

. Information Notice 97-88, Experiences During Recent Steam Generator Inspections. Washington, DC: U.S. Nuclear Regulatory Commission. December 1997.

. Information Notice 2006-27, Circumferential Cracking in the Stainless Steel Pressurizer Heater Sleeves of Pressurized Water Reactors. Washington, DC: U.S. Nuclear Regulatory Commission. December 2006.

. Information Notice 2007-37, Buildup of Deposits in Steam Generators. Washington, DC: U.S. Nuclear Regulatory Commission. November 2007.

. NUREG-1544, Status Report: Intergranular Stress Corrosion Cracking of BWR Core Shrouds and Other Internal Components. Washington, DC: U.S. Nuclear Regulatory Commission. March 1996.

. NUREG/CR-6001, Aging Assessment of BWR Standby Liquid Control Systems.

G.D. Buckley, R.D. Orton, A.B. Johnson Jr., and L.L. Larson. Washington, DC: U.S. Nuclear Regulatory Commission. 1992.

Revisions to SRP-SLR 3.1.6 References

1. NEI. NEI 97-06, Steam Generator Program Guidelines. Revision 2. Agencywide Documents Access and Management System (ADAMS) Accession No. ML052710007. Washington, DC: Nuclear Energy Institute. September 2005.

SLR-ISG-2021-02-MECHANICAL: Appendix B Page 7 of 10

2. 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.

3. NRC. Information Notice 90-04, Cracking of the Upper Shell-to-Transition Cone Girth Welds in Steam Generators. ADAMS Accession No. ML031470418. Washington, DC: U.S. Nuclear Regulatory Commission. January 26, 1990.

4. NRC. NUREG-0313, Technical Report on Material Selection and Processing Guidelines for BWR Coolant Pressure Boundary Piping. Revision 2. ADAMS Accession No. ML031470422. Washington, DC: U.S. Nuclear Regulatory Commission.

January 1988.

5. EPRI. EPRI 1013706, PWR Steam Generator Examination Guidelines.

Revision 7. Palo Alto, California: Electric Power Research Institute. October 2007.

6. NRC. Regulatory Guide 1.121, Bases for Plugging Degraded PWR Steam Generator Tubes (for Comment). ADAMS Accession No.ML003739366.

Washington, DC: U.S. Nuclear Regulatory Commission. May 1976.

7. NRC. Generic Letter 95-05, Voltage-Based Repair Criteria for Westinghouse Steam Generator Tubes Affected by Outside Diameter Stress Corrosion Cracking. ADAMS Accession No. ML041680635. Washington, DC: U.S. Nuclear Regulatory Commission. August 3, 1995.

8. NRC. Information Notice 90-10, Primary Water Stress Corrosion Cracking (PWSCC) of Inconel 600. ADAMS Accession No. ML053070392. Washington, DC: U.S.

Nuclear Regulatory Commission. February 23, 1990.

9. NRC. Information Notice 90-30, Ultrasonic Inspection Techniques for Dissimilar Metal Welds. ADAMS Accession No. ML031470652. Washington, DC: U.S.

Nuclear Regulatory Commission. May 1, 1990.

10. NRC. Generic Letter 89-08, Erosion/Corrosion-Induced Pipe Wall Thinning. ADAMS Accession No. ML082320534. Washington, DC: U.S. Nuclear Regulatory Commission. May 2, 1989.

11. NRC. Information Notice 96-11, Ingress of Demineralizer Resins Increase Potential for Stress Corrosion Cracking of Control Rod Drive Mechanism Penetrations.

ADAMS Accession No. ML031060264. Washington, DC: U.S. Nuclear Regulatory Commission. February 14, 1996.

12. EPRI. BWRVIP-190 (EPRI 10165793002002623), BWR Vessel and Internals Project: BWR Water Chemistry Guidelines. Revision 1. Palo Alto, California:

Electric Power Research Institute. October 2008 April 2014.

13. EPRI. EPRI NP-5769, Degradation and Failure of Bolting in Nuclear Power Plants.

Volumes 1 and 2. Palo Alto, California: Electric Power Research Institute. April 1988.

SLR-ISG-2021-02-MECHANICAL: Appendix B Page 8 of 10

14. EPRI. EPRI TR-10149863002000505, PWR Primary Water Chemistry Guidelines.

Revision 7. Volumes 1 and 2. Palo Alto, California: Electric Power Research Institute. April 2014.

15. NRC. Generic Letter 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping. ADAMS Accession No. ML031130463. Washington, DC: U.S. Nuclear Regulatory Commission. January 25, 1988.

16. NRC. Generic Letter 97-01, Degradation of Control Rod Drive Mechanism Nozzle and Other Vessel Closure Head Penetrations. ADAMS Accession No. ML993550383. Washington, DC: U.S. Nuclear Regulatory Commission. April 1, 1997.

17. NRC. Information Notice 97-46, Unisolable Crack in High-Pressure Injection Piping. Washington, DC: U.S. Nuclear Regulatory Commission. July 9, 1997.

18. NRC. Regulatory Guide 1.99, Radiation Embrittlement of Reactor Vessel Materials. Washington, DC: U.S. Nuclear Regulatory Commission. May 1988.

19. NRC. Information Notice 2013-20, Steam Generator Channel Head and Tubesheet Degradation. ADAMS Accession No. ML13204A143. Washington, DC: U.S. Nuclear Regulatory Commission. October 3, 2013.

20. NRC. NUREG-0619, BWR Feedwater Nozzle and Control Rod Drive Return Line Nozzle Cracking. ADAMS Accession No. ML031600712. Washington, DC: U.S.

Nuclear Regulatory Commission. November 1980.

21. NRC. NUREG-1339, Resolution of Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear Power Plants. ADAMS Accession No. ML031430208.

Washington, DC: U.S. Nuclear Regulatory Commission. June 1990.

22. EPRI. EPRI TR-104213, Bolted Joint Maintenance & Application Guide, Electric Power Research Institute. Palo Alto, California: Electric Power Research Institute.

December 1995.

23. Dave Modeen. NEI Letter (December 11) to Gus Lainas, Responses to NRC Requests for Additional Information (RAIs) on GL 97-01. Washington, DC: Nuclear Energy Institute. 1998.

24. EPRI. EPRI TR-10165553002010645, PWR Secondary Water Chemistry Guidelines. Revision 78. Palo Alto, California: Electric Power Research Institute.

February 2009September 2017.

25. NRC. Information Notice 91-19, Steam Generator Feedwater Distribution Piping Damage. Washington, DC: U.S. Nuclear Regulatory Commission.

March 12, 1991.

26. EPRI. EPRI TR-1022863, Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guidelines (MRP-227-A). Palo Alto, California: Electric Power Research Institute. December 2011.

SLR-ISG-2021-02-MECHANICAL: Appendix B Page 9 of 10

27. Entergy Operations, Inc. Demonstration of the Management of Aging Effects for the Reactor Vessel Internals. Topical Report BAW-2248A. Russellville, Arkansas: Entergy Operations, Inc. March 2000.

28. EPRI. EPRI TR-1014982, Divider Plate Cracking in Steam Generators - Results of Phase 1: Analysis of Primary Water Stress Corrosion Cracking and Mechanical Fatigue in the Alloy 600 Stub Runner to Divider Plate Weld Material. Palo Alto, California:

Electric Power Research Institute. June 2007.

29. Dominion Nuclear Connecticut, Inc. Letter (July 13) to NRC, Dominion Nuclear Connecticut, Inc. Millstone Power Station Unit 3 Results of the Reactor Pressure Vessel Head Inspections Required by NRC Order EA-03-009. 2007.

30. Southern Company. Letter (June 21) to the NRC, Vogtle Electric Generating Plant -

Unit 2 Results of Reactor Pressure Vessel Head Inspections Required by First Revised Order EA-03-009. Atlanta, Georgia: Southern Company. 2007.

31. EPRI. EPRI 3002002850, Steam Generator Management Program: Investigation of Crack Initiation and Propagation in the Steam Generator Channel Head Assembly. Palo Alto, California: Electric Power Research Institute, October 2014.

32. EPRI. EPRI 1020988, Steam Generator Management Program: Phase II Divider Plate Cracking Engineering Study. Palo Alto, California: Electric Power Research Institute. November 2010.

33. EPRI. EPRI 1016552, Divider Plate Cracking in Steam Generators: Results of Phase II:

Evaluation of the Impact of a Cracked Divider Plate on LOCA and Non-LOCA Analyses.

Palo Alto, California: Electric Power Research Institute. November 2008.

34. EPRI. Presentation, NRC/Industry Meeting Regarding Tube-to-Tubesheet Weld and Divider Plate Cracking Report. Palo Alto, California: Electric Power Research Institute.

July 30, 2015.

35. ACI. ACI Standard 318-95, Building Code Requirements for Reinforced Concrete and Commentary. Farmington Hills, Michigan: American Concrete Institute. 1995.

36. ACI. ACI Standard. 349-85, Code Requirements for Nuclear Safety-Related Concrete Structures. Farmington Hills, Michigan: American Concrete Institute. 1985.

37. NRC. NUREG-1557, Summary of Technical Information and Agreements from Nuclear Management and Resources Council Industry Reports Addressing License Renewal.

Washington, DC: U.S. Nuclear Regulatory Commission. October 1996.

SLR-ISG-2021-02-MECHANICAL: Appendix B Page 10 of 10 Revisions to FSAR Supplement Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging Management Programs GALL-SLR Implementation AMP Program Description of Program Schedule*

XI.M2 Water This program mitigates aging effects of loss of Program is Chemistry material due to corrosion, cracking due to implemented 6 SCC, and related mechanisms, and reduction months prior to of heat transfer due to fouling in components the exposed to a treated water environment. subsequent Chemistry programs are used to control water period of chemistry for impurities (e.g., chloride, extended fluoride, and sulfate) that accelerate operation corrosion. This program relies on monitoring and control of water chemistry to keep peak levels of various contaminants below the system-specific limits, based on EPRI guidelines (a) BWRVIP-190 (EPRI 1016579 3002002623, BWR Water Chemistry Guidelines 2008 2014 Revision) for BWRs or (b) EPRI 10149863002000505 (PWR Primary Water Chemistry - Revision 7) and EPRI 1016555 3002010645 (PWR Secondary Water Chemistry Revision 78) for PWRs.

Revisions to AMR Items None

APPENDIX C REVISIONS TO AMP XI.M12, THERMAL AGING EMBRITTLEMENT OF CAST AUSTENITIC STAINLESS STEEL (CASS)

Summary of Revisions The acceptance criteria program element of GALL-SLR AMP XI.M12 is changed to add the 2019 Edition of ASME Code,Section XI, Non-mandatory Appendix C, which provides flaw evaluation procedures for cast austenitic stainless steel (CASS) with ferrite content 20 percent.

Basis for Revisions Non-mandatory Appendix C to the 2019 Edition of ASME Code,Section XI provides the flaw evaluation procedures for CASS with ferrite content 20 percent1 The prior edition of the Code did not provide flaw evaluation methods for CASS with ferrite content 20 percent. The flaw evaluation procedures in the 2019 Edition of the Code were developed by considering the ferrite content, fracture toughness, tensile data of CASS materials and the relevant elastic-plastic correction factors (Z-factors) as a function of ferrite content.

Currently, rulemaking activities are ongoing to incorporate by reference the 2019 Edition of ASME Code,Section XI in 10 CFR 50.55a. Given the ongoing rulemaking status, the NRC staff finds that Appendix C to the 2019 Edition of ASME Code,Section XI may be used in GALL-SLR AMP XI.M12 until the appendix is formally incorporated by reference in 10 CFR 50.55a. Once the appendix is incorporated by reference in 10 CFR 50.55a, the program may use the appendix as incorporated by reference in 10 CFR 50.55a.

AMP Revisions Program Description The reactor coolant system components are inspected in accordance with the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section XI2. This inspection is augmented to detect the effects of loss of fracture toughness due to thermal aging embrittlement of cast austenitic stainless steel (CASS) piping components except for valve bodies.

This aging management program (AMP) includes determination of the potential significance of thermal aging embrittlement of CASS components based on casting method, molybdenum content, and percent ferrite. For components for which thermal aging embrittlement is potentially significant as defined below, aging management is accomplished through either (a) qualified visual inspections, such as enhanced visual examination (EVT-1); (b) a qualified ultrasonic testing (UT) methodology; or (c) a component-specific flaw tolerance evaluation in accordance with the ASME Code,Section XI. Additional inspection or evaluations to 1

PVP2017-66100, Technical Basis for Flaw Acceptance Criteria for Cast Austenitic Stainless Steel Piping, D.J. Shim et al., Proceedings of the ASME 2017 Pressure Vessels and Piping Conference, July 16-20, 2017, Waikoloa, Hawaii, United States.

2 GALL-SLR Report. Chapter 1, Table 1, identifies the ASME Code Section XI editions and addenda that are acceptable to use for this AMP.

SLR-ISG-2021-02-MECHANICAL: Appendix C Page 2 of 6 demonstrate that the material has adequate fracture toughness are not required for components for which thermal aging embrittlement in is not significant. The scope of the program includes ASME Code Class 1 piping all primary pressure boundary components constructed from CASS with service conditions above 250 °C (Celsius) [482 °F (Fahrenheit)]. (see comment previous section on this)

For pump casings, as an alternative to the screening and other actions described above, no further actions are needed if applicants demonstrate that the original flaw tolerance evaluation performed as part of Code Case N-481 implementation remains bounding and applicable for the subsequent license renewal (SLR) period or the evaluation is revised to be applicable for 80 years. For valve bodies, based on the results of the assessment documented in the letter dated May 19, 2000, from Christopher Grimes, U.S. Nuclear Regulatory Commission (NRC), to Douglas Walters, Nuclear Energy Institute (May 19, 2000 NRC letter), screening for significance of thermal aging embrittlement is not required. The existing ASME Code,Section XI inspection requirements are adequate for valve bodies.

Reactor vessel internal (RVI) components fabricated from CASS are not within the scope of this AMP. GALL-SLR Report AMP XI.M9, BWR Vessel Internals contains aging management guidance for CASS RVI components of boiling water reactors (BWRs). GALL-SLR Report AMP XI.M16A, PWR Vessel Internals contains aging management guidance for CASS RVI components of pressurized water reactors (PWRs).

Evaluation and Technical Basis

1. Scope of Program: This program manages loss of fracture toughness in ASME Code Class 1 piping components made from CASS. The program includes screening criteria to determine which CASS components have the potential for significant loss of fracture toughness due to thermal aging embrittlement and require augmented inspection. The screening criteria are applicable to all primary pressure boundary components constructed from CASS with service conditions above 250 °C [482 °F]. The screening criteria for the significance of thermal aging embrittlement are not applicable to niobium-containing steels; such steels require evaluation on a case-by-case basis.

Based on the criteria set forth in the May 19, 2000, NRC letter, the potential significance of thermal aging embrittlement of CASS materials is determined in terms of casting method, molybdenum content, and ferrite content. For low-molybdenum content steels

{SA-351 Grades CF3, CF3A, CF8, CF8A or other steels with 0.5 weight percent [wt.%]

Mo}, only static-cast steels with >20 percent ferrite are potentially susceptible to thermal embrittlement. Static-cast low-molybdenum steels with 20 percent ferrite and all centrifugal-cast low-molybdenum steels are not susceptible. For high-molybdenum content steels (SA-351 Grades CF3M, CF3MA, and CF8M or other steels with 2.0 to 3.0 wt.% Mo), static-cast steels with >14 percent ferrite and centrifugal-cast steels with >20 percent ferrite thermal embrittlement can be potentially significant, (i.e., screens in). For static-cast high-molybdenum steels with 14 percent ferrite and centrifugal-cast high-molybdenum steels with 20 percent ferrite, thermal aging embrittlement is not significant, (i.e., screens out). The thermal embrittlement screening criteria of CASS with different molybdenum and ferrite contents are summarized in Table XI.M12-1, Thermal Embrittlement Screening Criteria.

In the significance screening method, ferrite content is calculated by using the Hulls equivalent factors (described in NUREG/CR-4513, Revision 1) or a staff-approved

SLR-ISG-2021-02-MECHANICAL: Appendix C Page 3 of 6 method for calculating delta ferrite in CASS materials. A fracture toughness value of 255 kilo-joules per square meter (kJ/m2) [1,450 inch-pounds per square inch] at a crack extension of 2.5 millimeters [0.1 inch] is used to differentiate between CASS materials for which thermal aging embrittlement is not significant and those for which thermal aging embrittlement is potentially significant. Extensive research data indicate that for CASS materials without the potential for significant thermal aging embrittlement, the saturated lower-bound fracture toughness is greater than 255 kJ/m2 (NUREG/CR-4513, Revision 1).

Table XI.M12-1. Thermal Embrittlement Screening Criteria Potentially Not Molybdenum (Mo) Fe Casting Significant Significant Content Content Method (Screens In) (Screens Out)

>20%

Low or 0.5 wt.% Static X ferrite 20%

Low or 0.5 wt.% Static X ferrite Low or 0.5 wt.% Any Centrifugal X

>14%

High or 2.0-3.0 wt.% Static X ferrite

>20%

High or 2.0-3.0 wt.% Centrifugal X ferrite 14%

High or 2.0-3.0 wt.% Static X ferrite 20%

High or 2.0-3.0 wt.% Centrifugal X ferrite For valve bodies, screening for significance of thermal aging embrittlement is not needed (and thus there are no AMR items). For valve bodies greater than 4 inches nominal pipe size (NPS), the existing ASME Code,Section XI inspection requirements are adequate. ASME Code,Section XI, Subsection IWB requires only surface examination of valve bodies less than 4 inches NPS. For these valve bodies less than 4 inches NPS, the adequacy of inservice inspection (ISI) according to ASME Code,Section XI has been demonstrated by an NRC-performed bounding integrity analysis (May 19, 2000 letter). For pump casings, as an alternative to screening for significance of thermal aging, no further actions are needed if applicants demonstrate that the original flaw tolerance evaluation performed as part of Code Case N-481 implementation remains bounding and applicable for the SLR period, or the evaluation is revised to be applicable to 80 years.

2. Preventive Actions: This program is a condition monitoring program and does not mitigate thermal aging embrittlement.

3. Parameters Monitored or Inspected: The program monitors the effects of loss of fracture toughness on the intended function of the component by identifying the CASS materials that are susceptible to thermal aging embrittlement.

SLR-ISG-2021-02-MECHANICAL: Appendix C Page 4 of 6 The program does not directly monitor for loss of fracture toughness that is induced by thermal aging; instead, the impact of loss of fracture toughness on component integrity is indirectly managed by using visual or volumetric examination techniques to monitor for cracking in the components.

4. Detection of Aging Effects: For valve bodies, and other not susceptible CASS piping components, no additional inspection or evaluations are needed to demonstrate that the material has adequate fracture toughness.

For piping components for which thermal aging embrittlement is potentially significant, the AMP provides for qualified inspections of the base metal, such as EVT-1 or a qualified UT methodology, with the scope of the inspection covering the portions determined to be limiting from the standpoint of applied stress, operating time, and environmental considerations. Examination methods that meet the criteria of the ASME Code,Section XI, Appendix VIII are acceptable. Alternatively, a plant-specific or component-specific flaw tolerance evaluation, using specific geometry, stress information, material properties, and ASME Code,Section XI can be used to demonstrate that the thermally-embrittled material has adequate toughness. For CASS piping, UT may be performed in accordance with the methodology of Code Case N-824, as conditioned by Title 10 of the Code of Federal Regulations (10 CFR) 50.55a.

5. Monitoring and Trending: Inspection schedules in accordance with ASME Code,Section XI, IWB-2400 or IWC-2400, reliable examination methods, and qualified inspection personnel provide timely and reliable detection of cracks. If flaws are detected, the period of acceptability is determined from analysis of the flaw, depending on the crack growth rate and mechanism.

6. Acceptance Criteria: Flaws detected in CASS components are evaluated in accordance with the applicable procedures of ASME Code,Section XI. The most recent versions of the ASME Code,Section XI incorporated by reference in 10 CFR 50.55a (2007 edition through 2008 addendae.g., 2010 and 2013 Editions), doesdo not contain any evaluation procedures applicable to CASS with ferrite content 20 percent (nonmandatory Appendix C to the 2013 Edition of ASME Code,Section XI states that flaw evaluation methods for CASS with 20 percent ferrite are currently in the course of preparation.). Therefore, methods used for evaluations of flaws detected in CASS piping or components containing 20 percent ferrite, and methods used for flaw tolerance evaluations of such components, must be approved by the NRC staff on a case-by-case basis until such methods are incorporated into editions of the ASME Code,Section XI or code cases that are incorporated by reference in 10 CFR 50.55a, or in NRC-approved code cases, as documented in the latest revision to Regulatory Guide (RG) 1.147. Non-mandatory Appendix C to the 2019 Edition of ASME Code,Section XI, has not yet been incorporated by reference in 10 CFR 50.55a. Non-mandatory Appendix C to the 2019 ASME Code,Section XI, provides flaw evaluation procedures for CASS with ferrite content 20 percent. Those procedures may be used for flaw evaluations or flaw tolerance evaluations in this program until Appendix C to the 2019 Edition of ASME Code,Section XI is incorporated by reference in 10 CFR 50.55a. Once it is incorporated by reference in 10 CFR 50.55a, the evaluation procedures, as incorporated by reference in 10 CFR 50.55a, may be used in this program. This program may also use the flaw evaluation or flaw tolerance evaluation methods in the NRC-approved code cases that are documented in the

SLR-ISG-2021-02-MECHANICAL: Appendix C Page 5 of 6 latest revision of Regulatory Guide 1.147. NUREG/CR-4513, Revision 1 provides methods for predicting the fracture toughness of thermally aged CASS materials with delta ferrite content up to 25 percent.

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 10 CFR Part 50, Appendix B. Appendix A of the Generic Aging Lessons Learned for Subsequent License Renewal (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.

Repair and replacement are performed in accordance with ASME Code,Section XI, IWA-4000.

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 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: The AMP was developed by using research data obtained on both laboratory-aged and service-aged materials. Based on this information, the effects of thermal aging embrittlement on the intended function of CASS components will be effectively managed.

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.

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

SLR-ISG-2021-02-MECHANICAL: Appendix C Page 6 of 6 ASME. ASME Code Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components. New York, New York: The American Society of Mechanical Engineers. 2008.3

. ASME Code Section XI, Division 1, Code Case N-824, Ultrasonic Examination of Cast Austenitic Piping Welds From the Outside Surface. New York, New York: The American Society of Mechanical Engineers. Approval Date October 16, 2012.

. ASME Code Section XI, Division 1, Code Case N-481, Alternative Examination Requirements for Cast Austenitic Pump Casings. New York, New York: The American Society of Mechanical Engineers. Approval Date March 5, 1990.

EPRI. BWRVIP-03, Revision 6 (EPRI 105696-R6), BWR Vessel and Internals Project, Reactor Pressure Vessel and Internals Examination Guidelines. Palo Alto, California: Electric Power Research Institute. December 2003.

. MRP-228, The Materials Reliability Program: Inspection Standard for PWR Internals. Palo Alto, California: Electric Power Research Institute. 2009.

Grimes, Christopher I., U.S. Nuclear Regulatory Commission, License Renewal and Standardization Branch, letter to Douglas J. Walters, Nuclear Energy Institute, License Renewal Issue No. 98-0030, Thermal Aging Embrittlement of Cast Stainless Steel Components.

Agencywide Documents Access and Management System (ADAMS) Accession No. ML003717179. Washington, DC: U.S. Nuclear Regulatory Commission. May 19, 2000.

Lee, S., P.T. Kuo, K. Wichman, and O. Chopra. Flaw Evaluation of Thermally-Aged Cast Stainless Steel in Light-Water Reactor Applications. International Journal of Pressure Vessel and Piping. pp 37-44. 1997.

Maxin, Mark J., letter to Rick Libra (BWRVIP Chairman), Safety Evaluation for Electric Power Research Institute (EPRI) Boiling Water Reactor Vessel and Internals project (BWRVIP)

Report TR-105696-R6 (BWRVIP-03), Revision 6, BWR Vessel and Internals Examination Guidelines (TAC No MC2293). June 2008. ADAMS Accession No. ML081500814.

NRC. NUREG/CR-4513, Estimation of Fracture Toughness of Cast Stainless Steels During Thermal Aging in LWR Systems. Revision 1. Washington, DC: U.S. Nuclear Regulatory Commission. August 1994.

. Regulatory Guide 1.147, Revision 17, Inservice Inspection Code Case Acceptability. Washington, DC: U.S. Nuclear Regulatory Commission. August 2014.

Revisions to FSAR Supplement None Revisions to AMR Items None 3

GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are acceptable to use for this AMP.

APPENDIX D REVISIONS TO AMP XI.M21A, CLOSED TREATED WATER SYSTEM Summary of Revisions This ISG revises AMP XI.M21A, Closed Treated Water Systems, to include the latest revision of EPRI closed cooling water chemistry guideline.

Basis for Revisions EPRI issued 3002000590, Closed Cooling Water Chemistry Guideline, Revision 2 in 2013 from the previous version (1007820). According to EPRI, a committee of industry experts collaborated in reviewing data and generating water-chemistry guidelines, which should be used at all nuclear plants, that has been endorsed by the utility chemistry community. Approved precedents for use of the more recent version of the above guideline are documented in the NRC staffs SERs for subsequent license renewal (SLR) of Turkey Point and Peach Bottom (Agencywide Documents Access Management System (ADAMS) Accession Nos.

ML19191A057, and ML20044D902, respectively).

AMP Revisions Program Description Nuclear power plants contain many closed, treated water systems. These systems undergo water treatment to control water chemistry and prevent corrosion (i.e., treated water systems). These systems are also recirculating systems in which the rate of recirculation is much higher than the rate of addition of makeup water (i.e., closed systems). This is a mitigation program that also includes condition monitoring to verify the effectiveness of the mitigation activities. The program includes: (a) water treatment, including the use of corrosion inhibitors, to modify the chemical composition of the water such that the function of the equipment is maintained and such that the effects of corrosion are minimized; (b) chemical testing of the water to demonstrate that the water treatment program maintains the water chemistry within acceptable guidelines; and (c) inspections to determine the presence or extent of degradation. Depending on the water treatment program selected for use in association with this aging management program (AMP) and/or plant operating experience (OE), this program also may include corrosion monitoring (e.g., corrosion coupon testing) and microbiological testing.

The water used in systems covered by this AMP may be, but need not be, demineralized and receives chemical treatment, including corrosion inhibitors, unless the systems meet the industry guidance for pure water systems. Otherwise, untreated water systems are addressed using other AMPs, such as Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (XI.M38). Examples of systems managed by this AMP include closed-cycle cooling water (CCCW) systems (as defined by the U.S. Nuclear Regulatory Commission (NRC) Generic Letter

SLR-ISG-2021-02-MECHANICAL: Appendix D Page 2 of 6 (GL)89-131); closed portions of heating, ventilation, and air conditioning systems; and diesel generator cooling water. Examples of systems not addressed by this AMP include those systems containing boiling water reactor (BWR) coolant, pressurized water reactor (PWR) primary and secondary water, and PWR/BWR condensate that does not contain corrosion inhibitors. Aging in these systems is managed by the water chemistry AMP (XI.M2) and the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, Inservice Inspection, Subsections IWB, IWC, and IWD AMP (XI.M1).2 Treated fire water systems, if present, are also not included in this AMP.

Evaluation and Technical Basis

1. Scope of Program: This program manages the aging effects of loss of material due to corrosion, cracking due to stress corrosion cracking (SCC), and reduction of heat transfer due to fouling of the internal surfaces of piping, piping components, piping elements and heat exchanger components fabricated from any material and exposed to treated water.

2. Preventive Actions: This program mitigates the aging effects of loss of material, cracking, and reduction of heat transfer through water treatment. The water treatment program includes corrosion inhibitors and is designed to maintain the function of associated equipment and minimize the corrosivity of the water and the accumulation of corrosion products that can foul heat transfer surfaces.

3. Parameters Monitored or Inspected: This program monitors water chemistry parameters (preventive monitoring) and the condition of surfaces exposed to the water (condition monitoring). Depending on the water treatment program selected for use in association with this AMP and/or plant OE, this program may also include corrosion monitoring (e.g., corrosion coupon testing) and microbiological testing.

Water chemistry parameters (such as the concentration of iron, copper, silica, oxygen, and hardness, alkalinity, specific conductivity, and pH) are monitored because maintenance of optimal water chemistry prevents loss of material and cracking due to corrosion and SCC.

The specific water chemistry parameters monitored and the acceptable range of values for these parameters are in accordance with the Electric Power Research Institute (EPRI) 30020005901007820 Closed Cooling Water Chemistry Guideline, which is used in its entirety for the water chemistry control or guidance.

The visual appearance of surfaces is evaluated for evidence of loss of material. The results of surface or volumetric examinations are evaluated for surface discontinuities indicative of cracking. The heat transfer capability of heat exchanger surfaces is evaluated by either visual inspections to determine surface cleanliness, or functional testing to verify that design heat removal rates are maintained.

1 NRC GL 89-13 defines a service water system as the system or systems that transfer heat from safety-related structures, systems, or components to the ultimate heat sink. NRC GL 89-13 further defines a closed-cycle system as a part of the service water system that is not subject to significant sources of contamination, one in which water chemistry is controlled and in which heat is not directly rejected to an ultimate heat sink.

2GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are acceptable to use for this AMP.

SLR-ISG-2021-02-MECHANICAL: Appendix D Page 3 of 6

4. Detection of Aging Effects: In this program, aging effects are detected through water testing and periodic inspections. Water testing determines whether the water treatment program effectively maintains acceptable water chemistry. Water testing frequency is conducted in accordance with the selected water treatment program.

Because the control of water chemistry may not be fully effective in mitigating the aging effects, inspections are conducted. Visual inspections of internal surfaces are conducted whenever the system boundary is opened. At a minimum, in each 10-year period during the subsequent period of extended operation, a representative sample of 20 percent of the population (defined as components having the same material, water treatment program, and aging effect combination) or a maximum of 25 components per population at each unit is inspected using techniques capable of detecting loss of material, cracking, and fouling, as appropriate. The 20 percent minimum is surface area inspected unless the component is measured in linear feet, such as piping. In that case, any combination of 1-foot length sections and components can be used to meet the recommended extent of 25 inspections. Technical justification for an alternative sampling methodology is included in the programs documentation. For multi-unit sites where the sample size is not based on the percentage of the population, it is acceptable to reduce the total number of inspections at the site as follows. For two-unit sites, 19 components are inspected per unit and for a three-unit site, 17 components are inspected per unit. In order to conduct 17 or 19 inspections at a unit in lieu of 25, the subsequent license renewal application includes the basis for why the operating conditions at each unit are sufficiently similar (e.g., flowrate, chemistry, temperature, excursions) to provide representative inspection results. The basis should include consideration of potential differences such as the following:

• Have power uprates been performed and, if so, could more aging have occurred on one unit that has been in the uprate period for a longer time period?

• Are there any systems which have had an out-of-spec water chemistry condition for a longer period of time or out-of-spec conditions occur more frequently?

If degradation is identified in the initial sample, additional samples are inspected to determine the extent of the condition.

The ongoing opportunistic visual inspections are credited towards the representative samples for the loss of material and fouling; however, surface or volumetric examinations are used to detect cracking. The inspections focus on the components most susceptible to aging because of time in service and severity of operating conditions, including locations where local conditions may be significantly more severe than those in the bulk water (e.g., heat exchanger tube surfaces).

Inspections and tests are performed by personnel qualified in accordance with site procedures and programs to perform the specified task. Inspections within the scope of the ASME Code should follow procedures consistent with the ASME Code. Non-ASME Code inspections follow site procedures that include requirements for items such as lighting, distance, offset, surface coverage, presence of protective coatings, and cleaning processes.

SLR-ISG-2021-02-MECHANICAL: Appendix D Page 4 of 6

5. Monitoring and Trending: Water chemistry data are evaluated against the standards contained in the selected water treatment program. These data are trended, so corrective actions are taken, based on trends in water chemistry, prior to loss of intended function.

Where practical, identified degradation is projected until the next scheduled inspection.

Results are evaluated against acceptance criteria to confirm that the sampling bases (e.g., selection, size, frequency) will maintain the components intended functions throughout the subsequent period of extended operation based on the projected rate and extent of degradation.

6. Acceptance Criteria: Water chemistry concentrations are maintained within the limits specified in the selected industry standard documents. Due to the water chemistry controls, no age-related degradation is expected. Therefore, any detectable loss of material, cracking, or fouling is evaluated in the corrective action program.

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 Generic Aging Lessons Learned for Subsequent License Renewal (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.

Water chemistry concentrations that are not in accordance with the selected water treatment program should be returned to the normal operating range within the prescribed timeframe for each action level. If fouling is identified, the overall effect is evaluated for reduction of heat transfer, flow blockage, and loss of material.

If the cause of the aging effect for each applicable material and environment is not corrected by repair or replacement for all components constructed of the same material and exposed to the same environment, additional inspections are conducted if one of the inspections does not meet acceptance criteria. The number of increased inspections is determined in accordance with the sites corrective action process; however, there are no fewer than five additional inspections for each inspection that did not meet acceptance criteria, or 20 percent of each applicable material, environment, and aging effect combination is inspected, whichever is less. If subsequent inspections do not meet acceptance criteria, an extent of condition and extent of cause analysis is conducted to determine the further extent of inspections. Additional samples are inspected for any recurring degradation to ensure corrective actions appropriately address the associated causes. At multi-unit sites, the additional inspections include inspections at all of the units with the same material, environment, and aging effect combination. The additional inspections are completed within the interval (e.g., refueling outage interval, 10-year inspection interval) in which the original inspection was conducted.

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 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.

SLR-ISG-2021-02-MECHANICAL: Appendix D Page 5 of 6

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: Degradation of CCCW systems due to corrosion product buildup

[Licensee Event Report (LER) 327/1993-029] or through-wall cracks in supply lines (LER 280/1991-019) has been observed in operating plants. In addition, SCC of stainless steel reactor recirculation pump seal heat exchanger coils has been attributed to localized boiling of the closed cooling water, concentrating water impurities on the coil surfaces (LER 263/2014-001). Accordingly, OE demonstrates the need for this program.

The program is informed and enhanced when necessary through the systematic and ongoing review of both plant-specific and industry OE 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.

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

ASME. ASME Code Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components. New York, New York: The American Society of Mechanical Engineers. 2008. 3 EPRI. EPRI 30020005901007820, Closed Cooling Water Chemistry Guideline., Revision 2.

Palo Alto, California: Electric Power Research Institute. April 2004December 2013.

Flynn, Daniel. The Nalco Water Handbook. Nalco Company. 2009.

Licensee Event Report 263/2014-001, Primary System Leakage Found in Recirculation Pump Upper Seal Heat Exchanger. Agencywide Documents Access and Management System (ADAMS) Accession No. ML14073A599. https://lersearch.inl.gov/LERSearchCriteria.aspx.

March 2014.

Licensee Event Report 280/1991-019, Loss of Containment Integrity due to Crack in Component Cooling Water Piping. https://lersearch.inl.gov/LERSearchCriteria.aspx. October 1991.

Licensee Event Report 327/1993-029, Inoperable Check Valve in the Component Cooling System as a Result of a Build-Up of Corrosion Products between Valve Components.

https://lersearch.inl.gov/LERSearchCriteria.aspx. December 1993.

3 GALL-SLR Report Chapter I, Table 1, identifies the ASME Code Section XI editions and addenda that are acceptable to use for this AMP.

SLR-ISG-2021-02-MECHANICAL: Appendix D Page 6 of 6 NRC. Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Components. Washington, DC: U.S. Nuclear Regulatory Commission. July 1989.

_____. Generic Letter 89-13, Supplement 1, Service Water System Problems Affecting Safety-Related Components. Washington, DC: U.S. Nuclear Regulatory Commission.

April 1990.

Revisions to FSAR Supplement AMP GALL-SLR Description of Program Implementation Program Schedule XI.21A Closed This is a mitigation program that also includes Program and Treated a condition monitoring program to verify the SLR Water effectiveness of the mitigation activities. The enhancements, Systems program consists of: (a) water treatment, when including the use of corrosion inhibitors, to applicable, are modify the chemical composition of the water implemented such that the effects of corrosion are 6 months prior minimized; (b) chemical testing of the water to the so that the water treatment program maintains subsequent the water chemistry within acceptable period of guidelines; and (c) inspections to determine extended the presence or extent of degradation. The operation.

program uses as applicable, EPRI 10078203002000590, Closed Cooling Water Chemistry Guideline, and includes corrosion coupon testing and microbiological testing.

Revisions to AMR Items None

APPENDIX E REVISIONS TO AGING MANAGEMENT REVIEW LINE ITEMS ASSOCIATED WITH AMP XI.M26, FIRE PROTECTION Summary of Revisions This ISG adds new AMR Items VII.G.A-805, VII.G.A-806, and VII.G.A-807 to GALL-SLR Report Table VII.G, Fire Protection, and makes conforming changes to SRP-SLR Table 3.3-1, Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report.

Basis for Revisions VII.G.A-805: A new aging management review (AMR) item for subliming compounds used as fireproofing/fire barriers is being added to NUREG-2191 because they are materials that are widely used throughout industry and are likely to be cited in future subsequent license renewal application (SLRAs). The aging effects and aging mechanisms for subliming compounds used as fireproofing/fire barriers exposed to air are based on the U.S. Nuclear Regulatory Commission (NRC) staffs review and approval of applicants programs for aging management of fire protection materials listed in previous SLRAs. In addition, the aging effects and aging mechanisms are consistent with Section 6, Fire Barriers, of Electric Power Research Institute (EPRI) 3002013084, Long-Term Operations: Subsequent License Renewal Aging Affects for Structures and Structural Components (Structural Tools), issued November 2018, and those cited by industry as part of SLRA lessons learned activities and public comments on the draft AMR item.

New AMR item A-805 manages loss of material due to abrasion, flaking, and vibration; cracking/delamination due to chemical reaction and settlement; change in material properties due to gamma irradiation exposure; and separation for subliming compounds (Thermo-lag, Darmatt', 3M' Interam', and other similar materials) exposed to air.

The periodic inspections recommended by AMP XI.M26, Fire Protection, are capable of detecting these aging effects for these materials.

VII.G.A-806: A new AMR item for cementitious coatings used as fireproofing/fire barriers is being added to NUREG-2191 because they are materials that are widely used throughout industry and are likely to be cited in future SLRAs. The aging effects and aging mechanisms for cementitious coatings used as fireproofing/fire barriers exposed to air are based on the NRC staffs review and approval of applicants programs for aging management of fire protection materials listed in previous SLRAs. In addition, the aging effects and aging mechanisms are consistent with Section 5, Structural Concrete Members, and Section 6, Fire Barriers, of EPRI 3002013084, and those cited by industry as part of SLRA lessons learned activities and public comments on the draft AMR item.

This item manages loss of material due to abrasion, exfoliation, elevated temperature, flaking, and spalling; cracking/delamination; change in material properties; and separation for cementitious coatings (Pyrocrete, BIO' K-10 Mortar, Cafecote, and other similar materials) exposed to air.

SLR-ISG-2021-02-MECHANICAL: Appendix E Page 2 of 74 The periodic inspections recommended by AMP XI.M26 are capable of detecting these aging effects for these materials.

VII.G.A-807: A new AMR item for silicates used as fireproofing/fire barriers is being added to NUREG-2191 because they are materials that are widely used throughout industry and are likely to be cited in future SLRAs. The aging effects and aging mechanisms for silicates used as fireproofing/fire barriers exposed to air are based on the NRC staffs review and approval of applicants programs for aging management of fire protection materials listed in previous SLRAs. In addition, the aging effects and aging mechanisms are consistent with Section 6 of EPRI 3002013084, and those cited by industry as part of SLRA lessons learned activities and public comments on the draft AMR item.

New AMR Item A-807 manages loss of material due to abrasion and flaking; cracking/delamination due to settlement; change in material properties due to gamma irradiation exposure; and separation for silicates (Marinite, Kaowool', Cerafiber, Cera blanket, or other similar materials) exposed to air.

The periodic inspections recommended by AMP XI.M26 are capable of detecting these aging effects for these materials AMP Revisions None Revisions to FSAR Supplement None

Revisions to GALL-SLR Table VII G SLR-ISG-2021-02-MECHANICAL: Appendix E Note - this table is provided below in its entirety. The only changes to this table are the addition of the following three items near the end of the table: VII.G.A-805, VII.G.A-806, and VII.G.A-807.

VII AUXILIARY SYSTEMS Table G Fire Protection 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 VII.G.A-532 3.3-1, 193 Any Steel Raw water, Long-term loss of AMP XI.M32, No raw water material due to "One-Time (potable) general corrosion Inspection" N VII.G.A-439 3.3-1, 193 Any Steel Treated water Long-term loss of AMP XI.M32, No material due to "One-Time general corrosion Inspection" M VII.G.A-19 3.3-1, 057 Fire barrier Elastomer Air, Hardening, loss of AMP XI.M26, "Fire No penetration condensation strength, shrinkage Protection" seals due to elastomer degradation N VII.G.A-789 3.3-1, 255 Fire damper Any Air Loss of material due AMP XI.M26, "Fire No assemblies to general, pitting, Protection" crevice corrosion; cracking due to SCC; hardening, loss of strength, shrinkage due to elastomer degradation M VII.G.AP-149 3.3-1, 063 Fire hydrants Steel Air - outdoor, Loss of material due AMP XI.M27, "Fire No raw water, raw to general, pitting, Water System" water crevice corrosion; (potable), flow blockage due to treated water fouling (raw water, raw water (potable)

Page 3 of 74 only)

M VII.G.A-21 3.3-1, 059 Fire rated doors Steel Air Loss of material due AMP XI.M26, "Fire No to wear Protection"

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix E Table G Fire Protection 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 VII.G.A-623 3.3-1, 185 Fire water Aluminum Air, Cracking due to SCC AMP XI.M27, "Fire No storage tanks condensation, Water System" soil, concrete, raw water, raw water (potable),

treated water N VII.G.A-744 3.3-1, 215 Fire water Aluminum Air, Loss of material due AMP XI.M27, "Fire No storage tanks condensation, to pitting, crevice Water System" soil, concrete, corrosion raw water, raw water (potable),

treated water N VII.G.A-745 3.3-1, 216 Fire water Stainless steel Air, Cracking due to SCC AMP XI.M27, "Fire No storage tanks condensation, Water System" soil, concrete N VII.G.A-747 3.3-1, 218 Fire water Stainless steel Air, Loss of material due AMP XI.M27, "Fire No storage tanks condensation, to pitting, crevice Water System" soil, concrete, corrosion, MIC (water raw water, raw and soil environment water only)

(potable),

treated water M VII.G.A-412 3.3-1, 136 Fire water Steel Air, Loss of material due AMP XI.M27, "Fire No storage tanks condensation, to general, pitting, Water System" soil, concrete, crevice corrosion, raw water, raw MIC (raw water, raw water water (potable),

(potable), treated water, soil treated water only)

Page 4 of 74

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix E Table G Fire Protection 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 VII.G.A-650 3.3-1, 198 Fire water Metallic Any except Loss of material due AMP XI.M38, No system piping, soil, concrete to general (steel, "Inspection of piping copper alloy only), Internal Surfaces in components, pitting, crevice Miscellaneous heat exchanger, corrosion, MIC (all Piping and Ducting heat exchanger metallic materials Components" components except aluminum; in with only a liquid environments leakage only) boundary (spatial) or structural integrity (attached) intended function N VII.G.A-649 3.3-1, 197 Fire water Metallic Any external Loss of material due AMP XI.M36, No system piping, environment to general (steel, "External Surfaces piping except soil, copper alloy only), Monitoring of components, concrete pitting, crevice Mechanical heat exchanger, corrosion Components" heat exchanger components with only a leakage boundary (spatial) or structural integrity (attached) intended function Page 5 of 74

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix E Table G Fire Protection 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 VII.G.AP-150 3.3-1, 058 Halon/carbon Steel Air - indoor Loss of material due AMP XI.M26, "Fire No dioxide fire uncontrolled, to general, pitting, Protection" suppression air - outdoor, crevice corrosion system piping, condensation piping components N VII.G.A-565 3.3-1, 161 Heat exchanger Copper alloy Condensation Reduction of heat AMP XI.M38, No tubes transfer due to fouling "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components" M VII.G.AP-187 3.3-1, 042 Heat exchanger Stainless Raw water, Cracking due to SCC AMP XI.M38, No tubes steel, copper raw water (titanium only), "Inspection of alloy, titanium (potable), reduction of heat Internal Surfaces in treated water transfer due to fouling Miscellaneous Piping and Ducting Components" N VII.G.A-791 3.3-1, 257 Heat exchanger Steel, Lubricating oil Reduction of heat AMP XI.M39, No tubes stainless steel, transfer due to fouling "Lubricating Oil copper alloy Analysis," and AMP XI.M32, "One-Time Inspection" N VII.G.A-765 3.3-1, 236 Heat exchanger Titanium Treated water Cracking due to SCC, AMP XI.M2, "Water No tubes reduction of heat Chemistry," and transfer due to fouling AMP XI.M32, "One-Time Inspection" M VII.G.A-415 3.3-1, 140 Piping Gray cast iron, Closed-cycle Loss of material due AMP XI.M42, No components ductile iron cooling water, to selective leaching "Internal with internal with internal raw water, raw Coatings/Linings coatings/linings coating/lining water for In-Scope Page 6 of 74 (potable), Piping, Piping treated water, Components, Heat waste water Exchangers, and Tanks"

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix E Table G Fire Protection 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 VII.G.AP-129 3.3-1, 071 Piping, piping Aluminum Fuel oil Loss of material due AMP XI.M30, "Fuel No components to pitting, crevice Oil Chemistry," and corrosion, MIC AMP XI.M32, "One-Time Inspection" N VII.G.AP- 3.3-1, 071 Piping, piping Aluminum Fuel oil Loss of material due AMP XI.M30, "Fuel No 129a components to pitting, crevice Oil Chemistry" corrosion, MIC N VII.G.AP-162 3.3-1, 099 Piping, piping Aluminum Lubricating oil Loss of material due AMP XI.M39, No components to pitting, crevice "Lubricating Oil corrosion Analysis," and AMP XI.M32, "One-Time Inspection" M VII.G.AP-180 3.3-1, 065 Piping, piping Aluminum Raw water, Loss of material due AMP XI.M27, "Fire No components treated water, to pitting, crevice Water System" raw water corrosion; flow (potable) blockage due to fouling (raw water only)

N VII.G.A-451a 3.3-1, 189 Piping, piping Aluminum Air, Cracking due to SCC AMP XI.M32, Yes components condensation, "One-Time raw water, raw Inspection" water (potable),

waste water N VII.G.A-451b 3.3-1, 189 Piping, piping Aluminum Air, Cracking due to SCC AMP XI.M36, Yes components condensation, "External Surfaces raw water, raw Monitoring of water Mechanical (potable), Components" waste water Page 7 of 74

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix E Table G Fire Protection 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 VII.G.A-451c 3.3-1, 189 Piping, piping Aluminum Air, Cracking due to SCC AMP XI.M38, Yes components condensation, "Inspection of raw water, raw Internal Surfaces in water Miscellaneous (potable), Piping and Ducting waste water Components" N VII.G.A-451d 3.3-1, 189 Piping, piping Aluminum Air, Cracking due to SCC AMP XI.M42, Yes components condensation, "Internal raw water, raw Coatings/Linings water for In-Scope (potable), Piping, Piping waste water Components, Heat Exchangers, and Tanks" M VII.G.AP-132 3.3-1, 069 Piping, piping Copper alloy Fuel oil Loss of material due AMP XI.M30, "Fuel No components to pitting, crevice Oil Chemistry," and corrosion, MIC AMP XI.M32, "One-Time Inspection" N VII.G.AP- 3.3-1, 069 Piping, piping Copper alloy Fuel oil Loss of material due AMP XI.M30, "Fuel No 132a components to pitting, crevice Oil Chemistry" corrosion, MIC M VII.G.AP-133 3.3-1, 099 Piping, piping Copper alloy Lubricating oil Loss of material due AMP XI.M39, No components to pitting, crevice "Lubricating Oil corrosion, MIC Analysis," and AMP XI.M32, "One-Time Inspection" M VII.G.AP-197 3.3-1, 064 Piping, piping Copper alloy Raw water, Loss of material due AMP XI.M27, "Fire No components treated water, to general (raw water, Water System" raw water raw water (potable)

(potable) only), pitting, crevice corrosion, MIC; flow Page 8 of 74 blockage due to fouling (raw water only)

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix E Table G Fire Protection 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 VII.G.A-47 3.3-1, 072 Piping, piping Copper alloy Raw water, Loss of material due AMP XI.M33, No components (>15% Zn or raw water to selective leaching "Selective

>8% Al) (potable), Leaching" treated water N VII.G.A-743 3.3-1, 214 Piping, piping Copper alloy Soil Loss of material due AMP XI.M33, No components (>15% Zn or to selective leaching "Selective

>8% Al) Leaching" M VII.G.A-51 3.3-1, 072 Piping, piping Gray cast iron, Raw water, Loss of material due AMP XI.M33, No components ductile iron raw water to selective leaching "Selective (potable), Leaching" treated water M VII.G.A-02 3.3-1, 072 Piping, piping Gray cast iron, Soil Loss of material due AMP XI.M33, No components ductile iron to selective leaching "Selective Leaching" M VII.G.AP-31 3.3-1, 072 Piping, piping Gray cast iron, Treated water Loss of material due AMP XI.M33, No components ductile iron to selective leaching "Selective Leaching" N VII.G.A-458 3.3-1, 172 Piping, piping PVC Air - outdoor Reduction in impact AMP XI.M36, No components strength due to "External Surfaces photolysis Monitoring of Mechanical Components" N VII.G.A-787b 3.3-1, 253 Piping, piping PVC Raw water, Loss of material due AMP XI.M27, "Fire No components raw water to wear; flow Water System" (potable), blockage due to treated water fouling (raw water only)

M VII.G.AP- 3.3-1, 004 Piping, piping Stainless steel Air, Cracking due to SCC AMP XI.M32, Yes 209a components condensation "One-Time Inspection" M VII.G.AP- 3.3-1, 004 Piping, piping Stainless steel Air, Cracking due to SCC AMP XI.M36, Yes 209b components condensation "External Surfaces Monitoring of Page 9 of 74 Mechanical Components"

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix E Table G Fire Protection 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 VII.G.AP- 3.3-1, 004 Piping, piping Stainless steel Air, Cracking due to SCC AMP XI.M38, Yes 209c components condensation "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components" M VII.G.AP-136 3.3-1, 071 Piping, piping Stainless steel Fuel oil Loss of material due AMP XI.M30, "Fuel No components to pitting, crevice Oil Chemistry," and corrosion, MIC AMP XI.M32, "One-Time Inspection" N VII.G.AP- 3.3-1, 071 Piping, piping Stainless steel Fuel oil Loss of material due AMP XI.M30, "Fuel No 136a components to pitting, crevice Oil Chemistry" corrosion, MIC M VII.G.AP-138 3.3-1, 100 Piping, piping Stainless steel Lubricating oil Loss of material due AMP XI.M39, No components to pitting, crevice "Lubricating Oil corrosion, MIC Analysis," and AMP XI.M32, "One-Time Inspection" M VII.G.A-55 3.3-1, 066 Piping, piping Stainless steel Raw water, Loss of material due AMP XI.M27, "Fire No components treated water, to pitting, crevice Water System" raw water corrosion, MIC; flow (potable) blockage due to fouling (raw water only)

M VII.G.AP- 3.3-1, 006 Piping, piping Stainless Air, Loss of material due AMP XI.M32, Yes 221a components steel, nickel condensation to pitting, crevice "One-Time alloy corrosion Inspection" M VII.G.AP- 3.3-1, 006 Piping, piping Stainless Air, Loss of material due AMP XI.M36, Yes 221b components steel, nickel condensation to pitting, crevice "External Surfaces alloy corrosion Monitoring of Page 10 of 74 Mechanical Components"

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix E Table G Fire Protection 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 VII.G.AP- 3.3-1, 006 Piping, piping Stainless Air, Loss of material due AMP XI.M38, Yes 221c components steel, nickel condensation to pitting, crevice "Inspection of alloy corrosion Internal Surfaces in Miscellaneous Piping and Ducting Components" M VII.G.AP- 3.3-1, 006 Piping, piping Stainless Air, Loss of material due AMP XI.M42, Yes 221d components steel, nickel condensation to pitting, crevice "Internal alloy corrosion Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks" M VII.G.AP-143 3.3-1, 089 Piping, piping Steel Condensation Loss of material due AMP XI.M27, "Fire No components (internal) to general, pitting, Water System" crevice corrosion M VII.G.AP-234 3.3-1, 070 Piping, piping Steel Fuel oil Loss of material due AMP XI.M30, "Fuel No components to general, pitting, Oil Chemistry," and crevice corrosion, AMP XI.M32, MIC "One-Time Inspection" M VII.G.AP-127 3.3-1, 097 Piping, piping Steel Lubricating oil Loss of material due AMP XI.M39, No components to general, pitting, "Lubricating Oil crevice corrosion, Analysis," and MIC AMP XI.M32, "One-Time Inspection" M VII.G.A-33 3.3-1, 064 Piping, piping Steel Raw water, Loss of material due AMP XI.M27, "Fire No components treated water, to general, pitting, Water System" raw water crevice corrosion, (potable) MIC; flow blockage Page 11 of 74 due to fouling (raw water, raw water (potable) only)

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix E Table G Fire Protection 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 VII.G.A-404 3.3-1, 131 Piping, piping Steel, Air, Flow blockage due to AMP XI.M27, "Fire No components stainless steel, condensation fouling Water System" copper alloy, aluminum N VII.G.A-647 3.3-1, 195 Piping, piping Concrete, Raw water, Cracking due to AMP XI.M27, "Fire No components concrete treated water, chemical reaction, Water System" cylinder piping, raw water weathering, reinforced (potable) settlement, or concrete, corrosion of asbestos reinforcement cement, (reinforced concrete cementitious only); loss of material due to delamination, exfoliation, spalling, popout, scaling, or cavitation; flow blockage due to fouling (raw water only)

N VII.G.A-648 3.3-1, 196 Piping, piping HDPE Raw water, Cracking, blistering; AMP XI.M27, "Fire No components treated water, flow blockage due to Water System" raw water fouling (raw water (potable) only)

N VII.G.A-495 3.3-1, 159 Piping, piping Fiberglass Air Loss of material due AMP XI.M38, No components, to wear "Inspection of ducting, ducting Internal Surfaces in components Miscellaneous Piping and Ducting Components" Page 12 of 74

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix E Table G Fire Protection 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 VII.G.A-797b 3.3-1, 263 Piping, piping Polymeric Air, Hardening or loss of AMP XI.M38, No components, condensation, strength due to "Inspection of ducting, ducting raw water, raw polymeric Internal Surfaces in components, water degradation; loss of Miscellaneous seals (potable), material due to Piping and Ducting treated water, peeling, Components" waste water, delamination, wear; underground, cracking or blistering concrete, soil due to exposure to ultraviolet light, ozone, radiation, or chemical attack; flow blockage due to fouling N VII.G.A-722 3.3-1, 157 Piping, piping Steel Air - outdoor Loss of material due AMP XI.M27, "Fire No components, to general, pitting, Water System" heat exchanger crevice corrosion components M VII.G.A-416 3.3-1, 138 Piping, piping Any material Raw water, Loss of coating or AMP XI.M42, No components, with an raw water lining integrity due to "Internal heat internal (potable), blistering, cracking, Coatings/Linings exchangers with coating/lining treated water, flaking, peeling, for In-Scope internal lubricating oil delamination, rusting, Piping, Piping coatings/linings physical damage; Components, Heat loss of material or Exchangers, and cracking for Tanks" cementitious coatings/linings M VII.G.A-414 3.3-1, 139 Piping, piping Any material Raw water, Loss of material due AMP XI.M42, No components, with an raw water to general, pitting, "Internal heat internal (potable), crevice corrosion, Coatings/Linings exchangers with coating/lining treated water, MIC for In-Scope Page 13 of 74 internal lubricating oil Piping, Piping coatings/linings Components, Heat Exchangers, and Tanks"

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix E Table G Fire Protection 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 VII.G.A-504 3.3-1, 085 Piping, piping Elastomer Air, Hardening or loss of AMP XI.M38, No components, condensation strength due to "Inspection of seals elastomer Internal Surfaces in degradation Miscellaneous Piping and Ducting Components" M VII.G.AP-76 3.3-1, 096 Piping, piping Elastomer Air, raw water, Loss of material due AMP XI.M38, No components, raw water to wear; flow "Inspection of seals (potable), blockage due to Internal Surfaces in treated water fouling (raw water Miscellaneous only) Piping and Ducting Components" N VII.G.A-729 3.3-1, 085 Piping, piping Elastomer Gas Hardening or loss of AMP XI.M38, No components, strength due to "Inspection of seals elastomer Internal Surfaces in degradation Miscellaneous Piping and Ducting Components" N VII.G.AP-75 3.3-1, 085 Piping, piping Elastomer Raw water, Hardening or loss of AMP XI.M38, No components, raw water strength due to "Inspection of seals (potable), elastomer Internal Surfaces in treated water degradation; flow Miscellaneous blockage due to Piping and Ducting fouling (raw water Components" only)

N VII.G.A-644 3.3-1, 175 Piping, piping Fiberglass Raw water, Cracking, blistering, AMP XI.M38, No components, raw water loss of material due "Inspection of tanks (potable), to exposure to Internal Surfaces in treated water ultraviolet light, Miscellaneous ozone, radiation, Piping and Ducting temperature, or Components" moisture; flow Page 14 of 74 blockage due to fouling (raw water only)

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix E Table G Fire Protection 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 VII.G.A-645 3.3-1, 176 Piping, piping Fiberglass Raw water, Loss of material due AMP XI.M38, No components, raw water to wear; flow "Inspection of tanks (potable), blockage due to Internal Surfaces in treated water fouling (raw water Miscellaneous only) Piping and Ducting Components" M VII.G.A-400 3.3-1, 127 Piping, piping Metallic Raw water, Loss of material due AMP XI.M27, "Fire Yes components, raw water to recurring internal Water System" tanks (potable), corrosion treated water M VII.G.AP- 3.3-1, 004 Piping, piping Stainless steel Air, Cracking due to SCC AMP XI.M42, Yes 209d components, condensation "Internal tanks Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks" N VII.G.AP- 3.3-1, 070 Piping, piping Steel Fuel oil Loss of material due AMP XI.M30, "Fuel No 234a components, to general, pitting, Oil Chemistry" tanks crevice corrosion, MIC M VII.G.AP-117 3.3-1, 250 Reactor coolant Steel Lubricating oil Loss of material due AMP XI.M32, No pump oil (waste oil) to general, pitting, "One-Time collection crevice corrosion, Inspection" system: piping, MIC piping components M VII.G.AP-116 3.3-1, 250 Reactor coolant Steel Lubricating oil Loss of material due AMP XI.M32, No pump oil (waste oil) to general, pitting, "One-Time collection crevice corrosion, Inspection" system: tanks MIC Page 15 of 74

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix E Table G Fire Protection 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 VII.G.A-403 3.3-1, 130 Sprinklers Metallic Air, Loss of material due AMP XI.M27, "Fire No condensation, to general (where Water System" raw water, raw applicable), pitting, water crevice corrosion, (potable), MIC (except for treated water aluminum, and in raw water, raw water (potable), treated water only), flow blockage due to fouling N VII.G.A-626 3.3-1, 179 Structural fire Masonry walls Air Cracking due to AMP XI.M26, "Fire No barrier walls restraint shrinkage, Protection," and creep, aggressive AMP XI.S5, environment; loss of "Masonry Walls" material (spalling, scaling) and cracking due to freeze-thaw M VII.G.A-90 3.3-1, 060 Structural fire Reinforced Air Cracking due to AMP XI.M26, "Fire No barriers: walls, concrete chemical reaction, Protection," and ceilings and weathering, AMP XI.S6, floors settlement, or "Structures corrosion of Monitoring" reinforcement; loss of material due to delamination, exfoliation, spalling, popout, or scaling Page 16 of 74

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix E Table G Fire Protection 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 VII.G.A-805 3.3-1, 267 Fireproofing; fire Subliming Air Loss of material due AMP XI.M26, Fire No barriers compounds to abrasion, flaking, Protection (Thermo-lag, vibration; Darmatt', cracking/delamination 3M' due to chemical Interam', and reaction, settlement; other similar change in material materials) properties due to gamma irradiation exposure; separation N VII.G.A-806 3.3-1, 268 Fireproofing; fire Cementitious Air Loss of material due AMP XI.M26, Fire No barriers coatings to abrasion, Protection (Pyrocrete, exfoliation, elevated BIO' K-10 temperature, flaking, Mortar, spalling; cracking/

Cafecote, and delamination due to other similar chemical reaction, materials) elevated temperature, settlement, vibration; change in material properties due to elevated temperature, gamma irradiation exposure; separation N VII.G.A-807 3.3-1, 269 Fireproofing; fire Silicates Air Loss of material due AMP XI.M26, Fire No barriers (Marinite, to abrasion, flaking; Protection Kaowool', cracking/delamination Cerafiber, due to settlement; Cera change in material blanket, or properties due to Page 17 of 74 other similar gamma irradiation materials) exposure; separation D VII.G.A-20 D VII.G.A-22 D VII.G.A-23

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix E Table G Fire Protection 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 D VII.G.A-402 D VII.G.A-405 D VII.G.A-425 D VII.G.A-426 D VII.G.A-456 D VII.G.A-462 D VII.G.A-627 D VII.G.A-637 D VII.G.A-641 D VII.G.A-651 D VII.G.A-654 D VII.G.A-714a D VII.G.A-714b D VII.G.A-714c D VII.G.A-746 D VII.G.A-749 D VII.G.A-750 D VII.G.A-786 D VII.G.A-790a D VII.G.A-790b D VII.G.A-91 D VII.G.A-92 D VII.G.A-93 D VII.G.A-95 D VII.G.AP-137 D VII.G.AP-198 D VII.G.AP-209e D VII.G.AP-40 D VII.G.AP-41 Page 18 of 74

Revisions to SRP-SLR Table 3.3-1 SLR-ISG-2021-02-MECHANICAL: Appendix E SRP-SLR Table 3.3-1 is provided in its entirety below. The only change to SRP-SLR Table 3.3-1 associated with this appendix is the addition of items 267 through 269.

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item M 001 BWR/PWR Steel cranes: bridges, Cumulative fatigue damage TLAA, SRP-SLR Yes (SRP-SLR VII.B.A-06 structural members, due to fatigue Section 4.7 "Other Section 3.3.2.2.1) structural components Plant-Specific exposed to any TLAAs" environment M 002 BWR/PWR Stainless steel, steel Cumulative fatigue damage TLAA, SRP-SLR Yes (SRP-SLR VII.E1.A-100 heat exchanger due to fatigue Section 4.3 Section 3.3.2.2.1) VII.E1.A-34 components and "Metal Fatigue" VII.E1.A-57 tubes, piping, piping VII.E3.A-34 components exposed VII.E3.A-62 to any environment VII.E4.A-62 M 003 PWR Stainless steel heat Cracking due to SCC; cyclic AMP XI.M2, Yes (SRP-SLR VII.E1.A-69 exchanger tubing, loading "Water Chemistry" Section 3.3.2.2.2) non-regenerative exposed to treated borated water >60°C

(>140°F)

N 003a PWR Stainless steel heat Cracking due to SCC; cyclic AMP XI.M2, "Water Yes (SRP-SLR VII.E1.A-69a exchanger tubing, loading Chemistry," and Section 3.3.2.2.2) non-regenerative AMP XI.M21A, exposed to treated "Closed Treated borated water >60°C Water Systems"

(>140°F)

M 004 BWR/PWR Stainless steel piping, Cracking due to SCC AMP XI.M32, Yes (SRP-SLR VII.C1.AP-209a piping components, "One-Time Section 3.3.2.2.3) VII.C1.AP-209b Page 19 of 74 tanks exposed to air, Inspection," VII.C1.AP-209c condensation AMP XI.M36, VII.C1.AP-209d "External Surfaces VII.C2.AP-209a Monitoring of VII.C2.AP-209b Mechanical VII.C2.AP-209c Components," VII.C2.AP-209d AMP XI.M38, VII.C3.AP-209a

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item "Inspection of VII.C3.AP-209b Internal Surfaces in VII.C3.AP-209c Miscellaneous Piping VII.C3.AP-209d and Ducting VII.D.AP-209a Components," or VII.D.AP-209b AMP XI.M42, VII.D.AP-209c "Internal VII.D.AP-209d Coatings/Linings for VII.E1.AP-209a In-Scope Piping, VII.E1.AP-209b Piping Components, VII.E1.AP-209c Heat Exchangers, VII.E1.AP-209d and Tanks" VII.E4.AP-209a VII.E4.AP-209b VII.E4.AP-209c VII.E4.AP-209d VII.F1.AP-209a VII.F1.AP-209b VII.F1.AP-209c VII.F1.AP-209d VII.F2.AP-209a VII.F2.AP-209b VII.F2.AP-209c VII.F2.AP-209d VII.F3.AP-209a VII.F3.AP-209b VII.F3.AP-209c VII.F3.AP-209d VII.F4.AP-209a VII.F4.AP-209b VII.F4.AP-209c VII.F4.AP-209d VII.G.AP-209a VII.G.AP-209b Page 20 of 74 VII.G.AP-209c VII.G.AP-209d VII.H1.AP-209a VII.H1.AP-209b VII.H1.AP-209c VII.H1.AP-209d

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item VII.H2.AP-209a VII.H2.AP-209b VII.H2.AP-209c VII.H2.AP-209d D 005 M 006 BWR/PWR Stainless steel, nickel Loss of material due to AMP XI.M32, Yes (SRP-SLR VII.C1.AP-221a alloy piping, piping pitting, crevice corrosion "One-Time Section 3.3.2.2.4) VII.C1.AP-221b components exposed Inspection," VII.C1.AP-221c to air, condensation AMP XI.M36, VII.C1.AP-221d "External Surfaces VII.C2.AP-221a Monitoring of VII.C2.AP-221b Mechanical VII.C2.AP-221c Components," VII.C2.AP-221d AMP XI.M38, VII.C3.AP-221a "Inspection of VII.C3.AP-221b Internal Surfaces in VII.C3.AP-221c Miscellaneous Piping VII.C3.AP-221d and Ducting VII.D.AP-221a Components," or VII.D.AP-221b AMP XI.M42, VII.D.AP-221c "Internal VII.D.AP-221d Coatings/Linings for VII.E1.AP-221a In-Scope Piping, VII.E1.AP-221b Piping Components, VII.E1.AP-221c Heat Exchangers, VII.E1.AP-221d and Tanks" VII.E4.AP-221a VII.E4.AP-221b VII.E4.AP-221c VII.E4.AP-221d VII.F1.AP-221a VII.F1.AP-221b VII.F1.AP-221c VII.F1.AP-221d Page 21 of 74 VII.F2.AP-221a VII.F2.AP-221b VII.F2.AP-221c VII.F2.AP-221d VII.F3.AP-221a

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item VII.F3.AP-221b VII.F3.AP-221c VII.F3.AP-221d VII.F4.AP-221a VII.F4.AP-221b VII.F4.AP-221c VII.F4.AP-221d VII.G.AP-221a VII.G.AP-221b VII.G.AP-221c VII.G.AP-221d VII.H1.AP-221a VII.H1.AP-221b VII.H1.AP-221c VII.H1.AP-221d VII.H2.AP-221a VII.H2.AP-221b VII.H2.AP-221c VII.H2.AP-221d 007 PWR Stainless steel high- Cracking due to cyclic AMP XI.M1, "ASME No VII.E1.AP-115 pressure pump, loading Section XI Inservice casing exposed to Inspection, treated borated water Subsections IWB, IWC, and IWD" 008 PWR Stainless steel heat Cracking due to cyclic AMP XI.M1, "ASME No VII.E1.AP-119 exchanger loading Section XI Inservice components and Inspection, tubes exposed to Subsections IWB, treated borated water IWC, and IWD"

>60°C (>140°F)

M 009 PWR Steel, copper alloy Loss of material due to boric AMP XI.M10, No VII.I.A-79

(>15% Zn) external acid corrosion "Boric Acid VII.I.AP-66 surfaces, piping, Corrosion" Page 22 of 74 piping components exposed to air with borated water leakage

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item M 010 BWR/PWR High-strength steel Cracking due to SCC; cyclic AMP XI.M18, No VII.I.A-04 closure bolting loading "Bolting Integrity" exposed to air, soil, underground D 011 M 012 BWR/PWR Steel; stainless steel, Loss of material due to AMP XI.M18, No VII.I.A-03 nickel alloy closure general (steel only), pitting, "Bolting Integrity" bolting exposed to air crevice corrosion

- indoor uncontrolled, air - outdoor, condensation D 013 D 014 M 015 BWR/PWR Metallic closure Loss of preload due to AMP XI.M18, No VII.I.AP-124 bolting exposed to any thermal effects, gasket "Bolting Integrity" environment, soil, creep, self-loosening underground M 016 BWR Stainless steel piping, Cracking due to SCC, AMP XI.M2, "Water No VII.E3.AP-283 piping components IGSCC Chemistry," and outboard the second AMP XI.M25, containment isolation "BWR Reactor Water valves with a diameter Cleanup System" 4 inches nominal pipe size exposed to treated water >93°C

(>200°F) 017 BWR/PWR Stainless steel heat Reduction of heat transfer AMP XI.M2, "Water No VII.A4.AP-139 exchanger tubes due to fouling Chemistry," and VII.A3.A-101 exposed to treated AMP XI.M32, VII.E1.A-101 water, treated borated "One-Time water Inspection" Page 23 of 74

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item M 018 BWR/PWR Stainless steel high- Cracking due to SCC AMP XI.M2, "Water No VII.E1.AP-114 pressure pump Chemistry," and VII.E2.AP-181 casing, piping, piping AMP XI.M32, components, tanks "One-Time exposed to treated Inspection" borated water >60°C

(>140°F), sodium pentaborate solution

>60°C (>140°F)

M 019 BWR Stainless steel Cracking due to SCC AMP XI.M2, "Water No VII.E3.AP-120 regenerative heat Chemistry," and exchanger AMP XI.M32, components exposed "One-Time to treated water >60°C Inspection"

(>140°F) 020 BWR/PWR Stainless steel, steel Cracking due to SCC AMP XI.M2, "Water No VII.E1.AP-118 with stainless steel Chemistry," and VII.E3.AP-112 cladding heat AMP XI.M32, exchanger "One Time components exposed Inspection" to treated borated water >60°C (>140°F),

treated water >60°C

(>140°F)

M 021 BWR Steel piping, piping Loss of material due to AMP XI.M2, "Water No VII.E3.AP-106 components exposed general, pitting, crevice Chemistry," and VII.E4.AP-106 to treated water corrosion, MIC AMP XI.M32, "One-Time Inspection" M 022 BWR Copper alloy piping, Loss of material due to AMP XI.M2, "Water No VII.A4.AP-140 piping components pitting, crevice corrosion, Chemistry," and VII.E3.AP-140 exposed to treated MIC AMP XI.M32, VII.E4.AP-140 water "One-Time Page 24 of 74 Inspection" D 023 D 024

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item M 025 BWR/PWR Aluminum piping, Loss of material due to AMP XI.M2, "Water No VII.A4.AP-130 piping components pitting, crevice corrosion Chemistry," and VII.C2.AP-130 exposed to treated AMP XI.M32, VII.E3.AP-130 water, treated borated "One-Time VII.E4.AP-130 water Inspection" VII.H2.AP-130 M 026 BWR Steel (with stainless Loss of material due to AMP XI.M2, "Water No VII.A4.AP-108 steel cladding) piping, general (only after cladding Chemistry," and piping components degradation), pitting, crevice AMP XI.M32, exposed to treated corrosion, MIC "One-Time water Inspection" 027 BWR Stainless steel heat Reduction of heat transfer AMP XI.M2, "Water No VII.E3.AP-139 exchanger tubes due to fouling Chemistry," and exposed to treated AMP XI.M32, water "One Time Inspection" M 028 PWR Stainless steel piping, Cracking due to SCC AMP XI.M2, "Water No VII.E1.AP-82 piping components, Chemistry," and tanks exposed to AMP XI.M32, treated borated water "One-Time

>60°C (>140°F) Inspection" D 029 M 030 BWR/PWR Concrete, concrete Cracking due to chemical AMP XI.M20, No VII.C1.AP-250 cylinder piping, reaction, weathering, "Open-Cycle Cooling reinforced concrete, settlement, or corrosion of Water System" asbestos cement, reinforcement (reinforced cementitious piping, concrete only); loss of piping components material due to exposed to raw water delamination, exfoliation, spalling, popout, scaling, or cavitation; flow blockage due to fouling M 030a BWR/PWR Fiberglass, HDPE Cracking, blistering, loss of AMP XI.M20, No VII.C1.AP-238 piping, piping material due to exposure to "Open-Cycle Cooling VII.C1.AP-239 Page 25 of 74 components exposed ultraviolet light, ozone, Water System" to raw water radiation, temperature, or moisture; flow blockage due to fouling D 031

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item D 032 D 032a D 033 M 034 BWR/PWR Nickel alloy, copper Loss of material due to AMP XI.M20, No VII.C1.AP-196 alloy piping, piping general (copper alloy only), "Open-Cycle Cooling VII.C1.AP-206 components exposed pitting, crevice corrosion, Water System" VII.C3.AP-195 to raw water MIC; flow blockage due to VII.C3.AP-206 fouling VII.H2.AP-193 D 035 D 036 M 037 BWR/PWR Steel piping, piping Loss of material due to AMP XI.M20, No VII.C1.AP-194 components exposed general, pitting, crevice "Open-Cycle Cooling VII.C3.AP-194 to raw water corrosion, MIC; flow Water System" VII.H2.AP-194 blockage due to fouling M 038 BWR/PWR Copper alloy, steel Loss of material due to AMP XI.M20, No VII.C1.AP-179 heat exchanger general, pitting, crevice "Open-Cycle Cooling VII.C1.AP-183 components exposed corrosion, MIC; flow Water System" to raw water blockage due to fouling D 039 M 040 BWR/PWR Stainless steel piping, Loss of material due to AMP XI.M20, No VII.C1.A-54 piping components pitting, crevice corrosion, "Open-Cycle Cooling VII.C3.A-53 exposed to raw water MIC; flow blockage due to Water System" VII.H2.AP-55 fouling D 041 M 042 BWR/PWR Copper alloy, titanium, Cracking due to SCC AMP XI.M20, No VII.C1.AP-187 stainless steel heat (titanium only), reduction of "Open-Cycle Cooling VII.C3.AP-187 exchanger tubes heat transfer due to fouling Water System," or VII.G.AP-187 exposed to raw water, AMP XI.M38, VII.H2.AP-187 raw water (potable), "Inspection of treated water Internal Surfaces in Miscellaneous Piping and Ducting Components" Page 26 of 74 M 043 BWR/PWR Stainless steel piping, Cracking due to SCC AMP XI.M21A, No VII.C2.AP-186 piping components "Closed Treated VII.E3.AP-186 exposed to closed- Water Systems" VII.E4.AP-186 cycle cooling water

>60°C (>140°F)

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item 044 BWR/PWR Stainless steel; steel Cracking due to SCC AMP XI.M21A, No VII.E3.AP-192 with stainless steel "Closed Treated cladding heat Water Systems" exchanger components exposed to closed-cycle cooling water >60°C (>140°F)

M 045 BWR/PWR Steel piping, piping Loss of material due to AMP XI.M21A, No VII.C2.AP-202 components, tanks general, pitting, crevice "Closed Treated VII.F1.AP-202 exposed to closed- corrosion, MIC Water Systems" VII.F2.AP-202 cycle cooling water VII.F3.AP-202 VII.F4.AP-202 VII.H2.AP-202 M 046 BWR/PWR Steel, copper alloy Loss of material due to AMP XI.M21A, No VII.A3.AP-189 heat exchanger general (steel only), pitting, "Closed Treated VII.A3.AP-199 components, piping, crevice corrosion, MIC Water Systems" VII.A4.AP-189 piping components VII.A4.AP-199 exposed to closed- VII.C2.AP-189 cycle cooling water VII.C2.AP-199 VII.E1.AP-189 VII.E1.AP-199 VII.E1.AP-203 VII.E3.AP-189 VII.E3.AP-199 VII.E4.AP-189 VII.E4.AP-199 VII.F1.AP-189 VII.F1.AP-199 VII.F1.AP-203 VII.F2.AP-189 VII.F2.AP-199 VII.F3.AP-189 VII.F3.AP-199 Page 27 of 74 VII.F3.AP-203 VII.F4.AP-189 VII.F4.AP-199 VII.H1.AP-199 VII.H2.AP-199

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item M 047 BWR Stainless steel; steel Loss of material due to AMP XI.M21A, No VII.E3.AP-191 with stainless steel pitting, crevice corrosion, "Closed Treated VII.E4.AP-191 cladding heat MIC Water Systems" exchanger components exposed to closed-cycle cooling water M 048 BWR/PWR Aluminum piping, Loss of material due to AMP XI.M21A, No VII.C2.AP-254 piping components pitting, crevice corrosion "Closed Treated VII.H2.AP-255 exposed to closed- Water Systems" cycle cooling water M 049 BWR/PWR Stainless steel piping, Loss of material due to AMP XI.M21A, No VII.C2.A-52 piping components pitting, crevice corrosion, "Closed Treated exposed to closed- MIC Water Systems" cycle cooling water M 050 BWR/PWR Stainless steel, copper Reduction of heat transfer AMP XI.M21A, No VII.C2.AP-188 alloy, steel heat due to fouling "Closed Treated VII.C2.AP-205 exchanger tubes Water Systems" VII.E3.AP-188 exposed to closed- VII.E4.AP-188 cycle cooling water VII.F1.AP-204 VII.F1.AP-205 VII.F2.AP-204 VII.F2.AP-205 VII.F3.AP-204 VII.F3.AP-205 VII.F4.AP-204 VII.F4.AP-205 051 BWR/PWR Boraflex spent fuel Reduction of neutron- AMP XI.M22, No VII.A2.A-86 storage racks: absorbing capacity due to "Boraflex Monitoring" VII.A2.A-87 neutron-absorbing boraflex degradation sheets (PWR), spent fuel storage racks:

neutron-absorbing Page 28 of 74 sheets (BWR) exposed to treated borated water, treated water

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item M 052 BWR/PWR Steel cranes: rails, Loss of material due to AMP XI.M23, No VII.B.A-07 bridges, structural general corrosion, wear, "Inspection of members, structural deformation, cracking Overhead Heavy components exposed Load and Light Load to air (Related to Refueling) Handling Systems" D 053 D 054 M 055 BWR/PWR Steel piping, piping Loss of material due to AMP XI.M38, No VII.D.A-26 components, tanks general, pitting, crevice "Inspection of VII.E5.A-26 exposed to corrosion Internal Surfaces in VII.F1.A-26 condensation Miscellaneous Piping VII.F2.A-26 and Ducting VII.F3.A-26 Components" VII.F4.A-26 VII.H2.A-26 D 056 M 057 BWR/PWR Elastomer fire barrier Hardening, loss of strength, AMP XI.M26, No VII.G.A-19 penetration seals shrinkage due to elastomer "Fire Protection" exposed to air, degradation condensation M 058 BWR/PWR Steel halon/carbon Loss of material due to AMP XI.M26, No VII.G.AP-150 dioxide fire general, pitting, crevice "Fire Protection" suppression system corrosion piping, piping components exposed to air - indoor uncontrolled, air -

outdoor, condensation M 059 BWR/PWR Steel fire rated doors Loss of material due to wear AMP XI.M26, No VII.G.A-21 exposed to air "Fire Protection" M 060 BWR/PWR Reinforced concrete Cracking due to chemical AMP XI.M26, No VII.G.A-90 structural fire barriers: reaction, weathering, "Fire Protection," and Page 29 of 74 walls, ceilings and settlement, or corrosion of AMP XI.S6, floors exposed to air reinforcement; loss of "Structures material due to Monitoring" delamination, exfoliation, spalling, popout, or scaling

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item D 061 D 062 M 063 BWR/PWR Steel fire hydrants Loss of material due to AMP XI.M27, No VII.G.AP-149 exposed to air - general, pitting, crevice "Fire Water System" outdoor, raw water, corrosion; flow blockage due raw water (potable), to fouling (raw water, raw treated water water (potable) only)

M 064 BWR/PWR Steel, copper alloy Loss of material due to AMP XI.M27, No VII.G.A-33 piping, piping general (steel; copper alloy "Fire Water System" VII.G.AP-197 components exposed in raw water and raw water to raw water, treated (potable) only), pitting, water, raw water crevice corrosion, MIC; flow (potable) blockage due to fouling (raw water; raw water (potable) for steel only)

M 065 BWR/PWR Aluminum piping, Loss of material due to AMP XI.M27, No VII.G.AP-180 piping components pitting, crevice corrosion; "Fire Water System" exposed to raw water, flow blockage due to fouling treated water, raw (raw water only) water (potable)

M 066 BWR/PWR Stainless steel piping, Loss of material due to AMP XI.M27, No VII.G.A-55 piping components pitting, crevice corrosion, "Fire Water System" exposed to raw water, MIC; flow blockage due to treated water, raw fouling (raw water only) water (potable)

D 067 D 068 M 069 BWR/PWR Copper alloy piping, Loss of material due to AMP XI.M30, "Fuel No VII.G.AP-132 piping components pitting, crevice corrosion, Oil Chemistry," and VII.G.AP-132a exposed to fuel oil MIC AMP XI.M32, VII.H1.AP-132 "One-Time VII.H1.AP-132a Inspection," or VII.H2.AP-132 AMP XI.M30, VII.H2.AP-132a Page 30 of 74 "Fuel Oil Chemistry"

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item M 070 BWR/PWR Steel piping, piping Loss of material due to AMP XI.M30, "Fuel No VII.H1.AP-105 components, tanks general, pitting, crevice Oil Chemistry," and VII.H1.AP-105a exposed to fuel oil corrosion, MIC AMP XI.M32, VII.H2.AP-105 "One-Time VII.H2.AP-105a Inspection," or VII.G.AP-234 AMP XI.M30, VII.G.AP-234a "Fuel Oil Chemistry" M 071 BWR/PWR Stainless steel, Loss of material due to AMP XI.M30, "Fuel No VII.G.AP-129 aluminum, nickel alloy pitting, crevice corrosion, Oil Chemistry," and VII.G.AP-129a piping, piping MIC AMP XI.M32, VII.G.AP-136 components exposed "One-Time VII.G.AP-136a to fuel oil Inspection," or VII.H1.AP-129 AMP XI.M30, VII.H1.AP-129a "Fuel Oil Chemistry" VII.H1.AP-136 VII.H1.AP-136a VII.H2.AP-129 VII.H2.AP-129a VII.H2.AP-136 VII.H2.AP-136a VII.H2.A-801 VII.H2.A-802 M 072 BWR/PWR Gray cast iron, ductile Loss of material due to AMP XI.M33, No VII.A3.AP-31 iron, copper alloy selective leaching "Selective Leaching" VII.A3.AP-43

(>15% Zn or >8% Al) VII.A4.AP-31 piping, piping VII.A4.AP-32 components, heat VII.A4.AP-43 exchanger VII.C1.A-02 components exposed VII.C1.A-47 to treated water, VII.C1.A-51 closed-cycle cooling VII.C1.A-66 water, soil, raw water, VII.C2.A-50 raw water (potable), VII.C2.AP-31 waste water VII.C2.AP-32 Page 31 of 74 VII.C2.AP-43 VII.C3.A-02 VII.C3.A-47 VII.C3.A-51 VII.E1.AP-31 VII.E1.AP-43

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item VII.E1.AP-65 VII.E3.AP-31 VII.E3.AP-32 VII.E3.AP-43 VII.E4.AP-31 VII.E4.AP-32 VII.E4.AP-43 VII.E5.A-547 VII.E5.A-724 VII.F1.AP-31 VII.F1.AP-43 VII.F1.AP-65 VII.F2.AP-31 VII.F2.AP-43 VII.F3.A-50 VII.F3.AP-43 VII.F3.AP-65 VII.F4.AP-31 VII.F4.AP-43 VII.G.A-02 VII.G.A-47 VII.G.A-51 VII.G.AP-31 VII.H1.A-02 VII.H1.AP-43 VII.H2.A-02 VII.H2.A-47 VII.H2.A-51 VII.H2.AP-43 M 073 BWR/PWR Concrete, concrete Cracking due to chemical AMP XI.M36, No VII.I.AP-253 cylinder piping, reaction, weathering, or "External Surfaces reinforced concrete, corrosion of reinforcement Monitoring of asbestos cement, (reinforced concrete only); Mechanical Page 32 of 74 cementitious piping, loss of material due to Components" piping components delamination, exfoliation, exposed to air - spalling, popout, or scaling outdoor D 074

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item D 075 M 076 BWR/PWR Elastomer piping, Hardening or loss of AMP XI.M36, No VII.I.AP-102 piping components, strength due to elastomer "External Surfaces ducting, ducting degradation Monitoring of components, seals Mechanical exposed to air, Components" condensation D 077 M 078 BWR/PWR Steel external Loss of material due to AMP XI.M36, No VII.I.A-77 surfaces exposed to general, pitting, crevice "External Surfaces air - indoor corrosion Monitoring of uncontrolled, air - Mechanical outdoor, condensation Components" D 079 M 080 BWR/PWR Steel heat exchanger Loss of material due to AMP XI.M36, No VII.I.A-24 components, piping, general, pitting, crevice "External Surfaces VII.I.AP-40 piping components corrosion Monitoring of VII.I.AP-41 exposed to air - Mechanical indoor uncontrolled, Components" air - outdoor D 081 M 082 BWR/PWR Elastomer, fiberglass Loss of material due to wear AMP XI.M36, No VII.I.A-719 piping, piping "External Surfaces VII.I.AP-113 components, ducting, Monitoring of ducting components, Mechanical seals exposed to air Components" M 083 BWR/PWR Stainless steel diesel Cracking due to SCC AMP XI.M38, No VII.H2.AP-128 engine exhaust piping, "Inspection of piping components Internal Surfaces in exposed to diesel Miscellaneous Piping exhaust and Ducting Components" Page 33 of 74

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item M 085 BWR/PWR Elastomer piping, Hardening or loss of AMP XI.M38, No VII.A3.AP-100 piping components, strength due to elastomer "Inspection of VII.A4.AP-101 seals exposed to air, degradation; flow blockage Internal Surfaces in VII.C1.AP-75 condensation, closed- due to fouling (raw water, Miscellaneous Piping VII.C2.AP-259 cycle cooling water, waste water only) and Ducting VII.D.A-729 treated borated water, Components" VII.E1.A-504 treated water, raw VII.E2.A-504 water, raw water VII.E3.A-504 (potable), waste VII.E4.A-504 water, gas, fuel oil, VII.E5.A-504 lubricating oil VII.E5.A-728 VII.F1.A-504 VII.F2.A-504 VII.F3.A-504 VII.F4.A-504 VII.G.A-504 VII.G.A-729 VII.G.AP-75 VII.H1.A-660 VII.H2.A-677 D 086 M 088 BWR/PWR Steel; stainless steel Loss of material due to AMP XI.M38, No VII.E5.AP-270 piping, piping general (steel only), pitting, "Inspection of VII.H2.AP-104 components, diesel crevice corrosion, flow Internal Surfaces in engine exhaust blockage due to fouling Miscellaneous Piping exposed to raw water (steel only for raw water and Ducting (potable), diesel (potable) environment) Components" exhaust M 089 BWR/PWR Steel piping, piping Loss of material due to AMP XI.M27, "Fire No VII.G.AP-143 components exposed general, pitting, crevice Water System" to condensation corrosion (internal)

M 090 BWR/PWR Steel ducting, ducting Loss of material due to AMP XI.M38, No VII.F1.A-08 Page 34 of 74 components (internal general, pitting, crevice "Inspection of VII.F2.A-08 surfaces) exposed to corrosion, MIC (for drip pans Internal Surfaces in VII.F3.A-08 condensation and drain lines only) Miscellaneous Piping VII.F4.A-08 and Ducting Components"

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item M 091 BWR/PWR Steel piping, piping Loss of material due to AMP XI.M38, No VII.E5.AP-281 components, heat general, pitting, crevice "Inspection of exchanger corrosion, MIC; flow Internal Surfaces in components, tanks blockage due to fouling Miscellaneous Piping exposed to waste and Ducting water Components" D 092 M 093 BWR/PWR Copper alloy piping, Loss of material due to AMP XI.M38, No VII.E5.AP-271 piping components general, pitting, crevice "Inspection of exposed to raw water corrosion, MIC Internal Surfaces in (potable) Miscellaneous Piping and Ducting Components" M 094 BWR/PWR Stainless steel Loss of material due to AMP XI.M32, Yes (SRP-SLR VII.F1.AP-99a ducting, ducting pitting, crevice corrosion "One-Time Section 3.3.2.2.4) VII.F2.AP-99a components exposed Inspection," VII.F3.AP-99a to air, condensation AMP XI.M36, VII.F4.AP-99a "External Surfaces VII.F1.AP-99b Monitoring of VII.F2.AP-99b Mechanical VII.F3.AP-99b Components," or VII.F4.AP-99b AMP XI.M38, VII.F1.AP-99c "Inspection of VII.F2.AP-99c Internal Surfaces in VII.F3.AP-99c Miscellaneous Piping VII.F4.AP-99c and Ducting Components" Page 35 of 74

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 094a BWR/PWR Stainless steel Cracking due to SCC AMP XI.M32, Yes (SRP-SLR VII.F1.A-781a ducting, ducting "One-Time Section 3.3.2.2.3) VII.F2.A-781a components exposed Inspection," VII.F3.A-781a to air, condensation AMP XI.M36, VII.F4.A-781a "External Surfaces VII.F1.A-781b Monitoring of VII.F2.A-781b Mechanical VII.F3.A-781b Components," or VII.F4.A-781b AMP XI.M38, VII.F1.A-781c "Inspection of VII.F2.A-781c Internal Surfaces in VII.F3.A-781c Miscellaneous Piping VII.F4.A-781c and Ducting Components" M 095 BWR/PWR Copper alloy, stainless Loss of material due to AMP XI.M38, No VII.E5.AP-272 steel, nickel alloy general (copper alloy only), "Inspection of VII.E5.AP-275 piping, piping pitting, crevice corrosion, Internal Surfaces in VII.E5.AP-276 components, heat MIC; flow blockage due to Miscellaneous Piping VII.E5.AP-278 exchanger fouling and Ducting VII.E5.AP-279 components, tanks Components" exposed to waste water M 096 BWR/PWR Elastomer piping, Loss of material due to AMP XI.M38, No VII.C1.AP-76 piping components, wear; flow blockage due to "Inspection of VII.E5.A-550 seals exposed to air, fouling (raw water, waste Internal Surfaces in VII.F1.AP-103 raw water, raw water water only) Miscellaneous Piping VII.F2.AP-103 (potable), treated and Ducting VII.F3.AP-103 water, waste water Components" VII.F4.AP-103 VII.G.AP-76 N 096a BWR/PWR Steel, aluminum, Reduction of heat transfer AMP XI.M38, No VII.C1.A-419 copper alloy, stainless due to fouling "Inspection of VII.F1.A-419 steel, titanium heat Internal Surfaces in VII.F2.A-419 exchanger tubes Miscellaneous Piping VII.F3.A-419 Page 36 of 74 internal to and Ducting VII.F4.A-419 components exposed Components" to air, condensation (external)

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 096b BWR/PWR Steel heat exchanger Loss of material due to AMP XI.M36, No VII.C1.A-417 components exposed general, pitting, crevice "External Surfaces VII.F1.A-417 to condensation corrosion Monitoring of VII.F2.A-417 Mechanical VII.F3.A-417 Components" VII.F4.A-417 M 097 BWR/PWR Steel piping, piping Loss of material due to AMP XI.M39, No VII.C1.AP-127 components exposed general, pitting, crevice "Lubricating Oil VII.C2.AP-127 to lubricating oil corrosion, MIC Analysis," and VII.E1.AP-127 AMP XI.M32, VII.E4.AP-127 "One-Time VII.F1.AP-127 Inspection" VII.F2.AP-127 VII.F3.AP-127 VII.F4.AP-127 VII.G.AP-127 VII.H2.AP-127 M 098 BWR/PWR Steel heat exchanger Loss of material due to AMP XI.M39, No VII.H2.AP-131 components exposed general, pitting, crevice "Lubricating Oil to lubricating oil corrosion, MIC Analysis," and AMP XI.M32, "One-Time Inspection" M 099 BWR/PWR Copper alloy, Loss of material due to AMP XI.M39, No VII.C1.AP-133 aluminum piping, pitting, crevice corrosion, "Lubricating Oil VII.C2.AP-133 piping components MIC (copper alloy only) Analysis," and VII.E1.AP-133 exposed to lubricating AMP XI.M32, VII.E4.AP-133 oil "One-Time VII.G.AP-133 Inspection" VII.G.AP-162 VII.H2.AP-133 VII.H2.AP-162 M 100 BWR/PWR Stainless steel piping, Loss of material due to AMP XI.M39, No VII.C1.AP-138 piping components pitting, crevice corrosion, "Lubricating Oil VII.C2.AP-138 exposed to lubricating MIC Analysis," and VII.E1.AP-138 oil AMP XI.M32, VII.E4.AP-138 Page 37 of 74 "One-Time VII.G.AP-138 Inspection" VII.H2.AP-138

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item 101 BWR/PWR Aluminum heat Reduction of heat transfer AMP XI.M39, No VII.H2.AP-154 exchanger tubes due to fouling "Lubricating Oil exposed to lubricating Analysis," and oil AMP XI.M32, "One-Time Inspection" 102 BWR/PWR Boral; boron steel, Reduction of neutron- AMP XI.M40, No VII.A2.AP-235 and other materials absorbing capacity; change "Monitoring of VII.A2.AP-236 (excluding Boraflex) in dimensions and loss of Neutron-Absorbing spent fuel storage material due to effects of Materials other than racks: neutron- SFP environment Boraflex" absorbing sheets (PWR), spent fuel storage racks:

neutron-absorbing sheets (BWR) exposed to treated borated water, treated water M 103 BWR/PWR Concrete, concrete Cracking due to chemical AMP XI.M41, "Buried No VII.I.AP-157 cylinder piping, reaction, weathering, or and Underground reinforced concrete, corrosion of reinforcement Piping and Tanks" asbestos cement, (reinforced concrete only);

cementitious piping, loss of material due to piping components delamination, exfoliation, exposed to soil, spalling, popout, or scaling concrete M 104 BWR/PWR HDPE, fiberglass Cracking, blistering, loss of AMP XI.M41, "Buried No VII.I.AP-175 piping, piping material due to exposure to and Underground VII.I.AP-176 components exposed ultraviolet light, ozone, Piping and Tanks" to soil, concrete radiation, temperature, or moisture D 105 Page 38 of 74 D 106 M 107 BWR/PWR Stainless steel, nickel Loss of material due to AMP XI.M41, "Buried No VII.I.AP-137 alloy piping, piping pitting, crevice corrosion, and Underground components exposed MIC (soil only) Piping and Tanks" to soil, concrete

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item M 108 BWR/PWR Titanium, super Loss of material due to AMP XI.M41, "Buried No VII.I.AP-171 austenitic, copper general (copper alloy only), and Underground VII.I.AP-172 alloy, stainless steel, pitting, crevice corrosion, Piping and Tanks" VII.I.AP-174 nickel alloy piping, MIC (super austenitic, VII.I.AP-243 piping components, copper alloy, stainless steel, tanks, closure bolting nickel alloy; soil exposed to soil, environment only) concrete, underground M 109 BWR/PWR Steel piping, piping Loss of material due to AMP XI.M41, "Buried No VII.I.AP-198 components, closure general, pitting, crevice and Underground VII.I.AP-241 bolting exposed to corrosion, MIC (soil only) Piping and Tanks" VII.I.AP-284 soil, concrete, underground D 109a M 110 BWR Stainless steel, nickel Cracking due to SCC, AMP XI.M7, "BWR No VII.E4.A-61 alloy piping, piping IGSCC Stress Corrosion components greater Cracking," and than or equal to 4 AMP XI.M2, NPS exposed to "Water Chemistry" treated water >93°C

(>200°F)

M 111 BWR/PWR Steel structural steel Loss of material due to AMP XI.S6, No VII.A1.A-94 exposed to air - general, pitting, crevice "Structures indoor uncontrolled corrosion Monitoring" M 112 BWR/PWR Steel piping, piping None None Yes (SRP-SLR VII.J.AP-282 components exposed Section 3.3.2.2.9) to concrete M 113 BWR/PWR Aluminum piping, None None No piping components VII.J.AP-37 exposed to gas M 114 BWR/PWR Copper alloy piping, None None No VII.J.AP-144 piping components VII.J.AP-9 Page 39 of 74 exposed to air, condensation, gas

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item M 115 BWR/PWR Copper alloy, copper None None No VII.J.AP-11 alloy (>8% Al) piping, piping components exposed to air with borated water leakage M 116 BWR/PWR Galvanized steel None None No VII.J.AP-13 piping, piping components exposed to air - indoor uncontrolled M 117 BWR/PWR Glass piping elements None None No VII.J.AP-14 exposed to air, VII.J.AP-15 lubricating oil, closed- VII.J.AP-166 cycle cooling water, VII.J.AP-48 fuel oil, raw water, VII.J.AP-49 treated water, treated VII.J.AP-50 borated water, air with VII.J.AP-51 borated water VII.J.AP-52 leakage, VII.J.AP-96 condensation, gas, VII.J.AP-97 underground VII.J.AP-98 D 118 M 119 BWR/PWR Nickel alloy, PVC, None None No VII.J.AP-260 glass piping, piping VII.J.AP-268 components exposed VII.J.AP-269 to air with borated VII.J.AP-277 water leakage, air -

indoor uncontrolled, condensation, waste water, raw water (potable)

M 120 BWR/PWR Stainless steel piping, None None No VII.J.AP-18 piping components Page 40 of 74 exposed to air with VII.J.AP-22 borated water leakage, gas

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item M 121 BWR/PWR Steel piping, piping None None No VII.J.AP-2 components exposed VII.J.AP-6 to air - indoor controlled, gas M 122 BWR/PWR Titanium heat None None No VII.J.AP-151 exchanger VII.J.AP-160 components, piping, piping components exposed to air -

indoor uncontrolled, air - outdoor M 123 BWR/PWR Titanium heat Cracking due to SCC, flow AMP XI.M20, No VII.C1.AP-152a exchanger blockage due to fouling "Open-Cycle Cooling VII.C3.AP-152a components other Water System," or VII.E4.AP-152a than tubes, piping and AMP XI.M38, VII.H2.AP-152a piping components "Inspection of VII.C1.AP-152b exposed to raw water Internal Surfaces in VII.C1.AP-161a Miscellaneous Piping VII.C3.AP-161a and Ducting VII.E4.AP-161a Components" VII.H2.AP-161a VII.C1.AP-161b M 124 BWR/PWR Stainless steel, steel Cracking due to SCC AMP XI.M2, No VII.A2.A-96 (with stainless steel or "Water Chemistry," VII.A2.A-97 nickel alloy cladding) and AMP XI.M32, VII.A3.A-56 spent fuel storage "One-Time VII.E1.A-103 racks (BWR), spent Inspection" fuel storage racks (PWR), piping, piping components exposed to treated water >60°C

(>140°F), treated borated water >60°C

(>140°F)

Page 41 of 74

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item M 125 BWR/PWR Stainless steel, steel Loss of material due to AMP XI.M2, "Water No VII.A2.AP-79 (with stainless steel pitting, crevice corrosion, Chemistry," and VII.A3.AP-79 cladding), nickel alloy MIC AMP XI.M32, VII.E1.AP-79 spent fuel storage "One-Time VII.A2.A-98 racks (BWR), spent Inspection" VII.A2.A-99 fuel storage racks (PWR), piping, piping components exposed to treated water, treated borated water M 126 BWR/PWR Metallic piping, piping Wall thinning due to erosion AMP XI.M17, No VII.C1.A-409 components exposed "Flow-Accelerated VII.E1.A-407 to treated water, Corrosion" VII.E3.A-408 treated borated water, raw water M 127 BWR/PWR Metallic piping, piping Loss of material due to AMP XI.M20, Yes (SRP-SLR VII.C1.A-400 components, tanks recurring internal corrosion "Open-Cycle Cooling Section 3.3.2.2.7) VII.C3.A-400 exposed to closed- Water System," VII.E5.A-400 cycle cooling water, AMP XI.M27, "Fire VII.G.A-400 raw water, raw water Water System," or (potable), treated AMP XI.M38, water, waste water "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components" M 128 BWR/PWR Steel tanks (within the Loss of material due to AMP XI.M29, No VII.C3.A-401 scope of AMP XI.M29, general, pitting, crevice "Outdoor and Large VII.E5.A-401 "Outdoor and Large corrosion, MIC (soil, raw Atmospheric Metallic VII.H1.A-401 Atmospheric Metallic water only) Storage Tanks" Storage Tanks")

exposed to soil, concrete, air, Page 42 of 74 condensation, raw water D 129

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item M 130 BWR/PWR Metallic sprinklers Loss of material due to AMP XI.M27, No VII.G.A-403 exposed to air, general (where applicable), "Fire Water System" condensation, raw pitting, crevice corrosion, water, raw water MIC (except for aluminum, (potable), treated and in raw water, raw water water (potable), treated water only); flow blockage due to fouling M 131 BWR/PWR Steel, stainless steel, Flow blockage due to fouling AMP XI.M27, No VII.G.A-404 copper alloy, "Fire Water System" aluminum piping, piping components exposed to air, condensation M 132 BWR/PWR Insulated steel, Loss of material due to AMP XI.M36, No VII.I.A-405a copper alloy (>15% Zn general (steel only), pitting, "External Surfaces VII.I.A-405b or >8% Al), piping, crevice corrosion; cracking Monitoring of piping components, due to SCC (copper alloy Mechanical tanks, tanks (within (>15% Zn or >8% Al) only) Components" or the scope of AMP AMP XI.M29, XI.M29, "Outdoor and "Outdoor and Large Large Atmospheric Atmospheric Metallic Metallic Storage Storage Tanks" Tanks") exposed to air, condensation M 133 BWR/PWR HDPE underground Cracking, blistering AMP XI.M41, "Buried No VII.I.A-406 piping, piping and Underground components Piping and Tanks" M 134 BWR/PWR Steel, stainless steel, Loss of material due to AMP XI.M38, No VII.C1.A-727 copper alloy piping, general (steel, copper alloy "Inspection of piping components, only), pitting, crevice Internal Surfaces in and heat exchanger corrosion, MIC; flow Miscellaneous Piping components exposed blockage due to fouling and Ducting Page 43 of 74 to raw water (for Components" components not covered by NRC GL 89-13)

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item M 135 BWR/PWR Steel, stainless steel Loss of material due to AMP XI.M36, No VII.E5.A-410 pump casings general (steel only), pitting, "External Surfaces VII.E5.A-411 exposed to waste crevice corrosion, MIC Monitoring of water environment Mechanical Components" M 136 BWR/PWR Steel fire water Loss of material due to AMP XI.M27, No VII.G.A-412 storage tanks general, pitting, crevice "Fire Water System" exposed to air, corrosion, MIC (raw water, condensation, soil, raw water (potable), treated concrete, raw water, water, soil only) raw water (potable),

treated water M 137 BWR/PWR Steel, stainless steel, Loss of material due to AMP XI.M29, No VII.C3.A-413 aluminum tanks general (steel only), pitting, "Outdoor and Large VII.E5.A-413 (within the scope of crevice corrosion, MIC Atmospheric Metallic VII.H1.A-413 AMP XI.M29, (steel, stainless steel only) Storage Tanks" "Outdoor and Large Atmospheric Metallic Storage Tanks")

exposed to treated water, raw water, waste water M 138 BWR/PWR Any material piping, Loss of coating or lining AMP XI.M42, No VII.C1.A-416 piping components, integrity due to blistering, "Internal VII.C2.A-416 heat exchangers, cracking, flaking, peeling, Coatings/Linings for VII.C3.A-416 tanks with internal delamination, rusting, or In-Scope Piping, VII.E4.A-416 coatings/linings physical damage; loss of Piping Components, VII.E5.A-416 exposed to closed- material or cracking for Heat Exchangers, VII.F1.A-416 cycle cooling water, cementitious coatings/linings and Tanks" VII.F2.A-416 raw water, raw water VII.F3.A-416 (potable), treated VII.F4.A-416 water, treated borated VII.G.A-416 water, fuel oil, VII.H1.A-416 Page 44 of 74 lubricating oil, waste VII.H2.A-416 water

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item M 139 BWR/PWR Any material piping, Loss of material due to AMP XI.M42, No VII.C1.A-414 piping components, general, pitting, crevice "Internal VII.C2.A-414 heat exchangers, corrosion, MIC Coatings/Linings for VII.C3.A-414 tanks with internal In-Scope Piping, VII.E4.A-414 coatings/linings Piping Components, VII.E5.A-414 exposed to closed- Heat Exchangers, VII.F1.A-414 cycle cooling water, and Tanks" VII.F2.A-414 raw water, raw water VII.F3.A-414 (potable), treated VII.F4.A-414 water, treated borated VII.G.A-414 water, fuel oil, VII.H1.A-414 lubricating oil, waste VII.H2.A-414 water M 140 BWR/PWR Gray cast iron, ductile Loss of material due to AMP XI.M42, No VII.C1.A-415 iron piping selective leaching "Internal VII.C2.A-415 components with Coatings/Linings for VII.C3.A-415 internal In-Scope Piping, VII.E2.A-415 coatings/linings Piping Components, VII.E3.A-415 exposed to closed- Heat Exchangers, VII.E4.A-415 cycle cooling water, and Tanks" VII.E5.A-415 raw water, raw water VII.G.A-415 (potable), treated VII.H1.A-415 water, waste water VII.H2.A-415 D 141 N 142 BWR/PWR Stainless steel, steel, Loss of material due to AMP XI.M18, No VII.I.A-423 nickel alloy, copper general (steel; copper alloy "Bolting Integrity" alloy closure bolting in raw water, waste water exposed to fuel oil, only), pitting, crevice lubricating oil, treated corrosion, MIC (raw water water, treated borated and waste water water, raw water, environments only) waste water D 143 Page 45 of 74 N 144 BWR/PWR Stainless steel, steel, Cracking due to SCC (steel AMP XI.M41, "Buried No VII.I.A-425 aluminum piping, in carbonate/bicarbonate and Underground piping components, environment only) Piping and Tanks" tanks exposed to soil, concrete

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 145 BWR/PWR Stainless steel closure Cracking due to SCC AMP XI.M18, No VII.I.A-426 bolting exposed to air, "Bolting Integrity" soil, concrete, underground, waste water N 146 BWR/PWR Stainless steel Cracking due to SCC AMP XI.M32, Yes (SRP-SLR VII.I.A-714a underground piping, "One-Time Section 3.3.2.2.3) VII.I.A-714b piping components, Inspection," VII.I.A-714c tanks AMP XI.M41, "Buried and Underground Piping and Tanks," or AMP XI.M42, "Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks" N 147 BWR/PWR Nickel alloy, nickel Loss of material due to AMP XI.M21A, No VII.C2.A-471 alloy cladding piping, pitting, crevice corrosion, "Closed Treated piping components MIC Water Systems" exposed to closed-cycle cooling water D 148 N 149 BWR/PWR Fiberglass piping, Cracking, blistering, loss of AMP XI.M36, No VII.I.A-428 piping components, material due to exposure to "External Surfaces ducting, ducting ultraviolet light, ozone, Monitoring of components exposed radiation, temperature, or Mechanical to air - outdoor moisture Components" N 150 BWR/PWR Fiberglass piping, Cracking, blistering, loss of AMP XI.M36, No VII.I.A-720 piping components, material due to exposure to "External Surfaces ducting, ducting ultraviolet light, ozone, Monitoring of components exposed radiation, temperature, or Mechanical Page 46 of 74 to air moisture Components"

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 151 BWR/PWR Stainless steel, steel, Reduction of heat transfer AMP XI.M36, No VII.I.A-716 aluminum, copper due to fouling "External Surfaces alloy, titanium heat Monitoring of exchanger tubes Mechanical exposed to air, Components" condensation D 153 D 154 N 155 BWR/PWR Stainless steel piping, Cracking due to SCC AMP XI.M38, No VII.E5.A-721 piping components, "Inspection of and tanks exposed to Internal Surfaces in waste water >60°C Miscellaneous Piping

(>140°F) and Ducting Components" D 156 N 157 BWR/PWR Steel piping, piping Loss of material due to AMP XI.M27, "Fire No VII.E1.A-722 components, heat general, pitting, crevice Water System," or VII.E2.A-722 exchanger corrosion AMP XI.M38, VII.E3.A-722 components exposed "Inspection of VII.E4.A-722 to air-outdoor Internal Surfaces in VII.E5.A-722 Miscellaneous Piping VII.F1.A-722 and Ducting VII.F2.A-722 Components" VII.F3.A-722 VII.F4.A-722 VII.G.A-722 VII.H1.A-722 VII.H2.A-722 N 158 BWR/PWR Nickel alloy piping, Loss of material due to AMP XI.M38, No VII.C1.A-454 piping components pitting, crevice corrosion, "Inspection of heat exchanger MIC; flow blockage due to Internal Surfaces in components (for fouling Miscellaneous Piping components not and Ducting covered by NRC GL Components" Page 47 of 74 89-13) exposed to raw water

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 159 BWR/PWR Fiberglass piping, Loss of material due to wear AMP XI.M38, No VII.D.A-495 piping components, "Inspection of VII.E5.A-495 ducting, ducting Internal Surfaces in VII.F1.A-495 components exposed Miscellaneous Piping VII.F2.A-495 to air and Ducting VII.F3.A-495 Components" VII.F4.A-495 VII.G.A-495 VII.H1.A-495 VII.H2.A-495 N 160 BWR/PWR Copper alloy (>15% Cracking due to SCC AMP XI.M20, No VII.C1.A-473b Zn or >8% Al) piping, "Open-Cycle Cooling VII.C2.A-473a piping components, Water System," VII.E5.A-473c heat exchanger AMP XI.M21A, components exposed "Closed Treated to closed-cycle cooling Water Systems," or water, raw water, AMP XI.M38, waste water "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components" N 161 BWR/PWR Copper alloy heat Reduction of heat transfer AMP XI.M38, No VII.F1.A-565 exchanger tubes due to fouling "Inspection of VII.F2.A-565 exposed to Internal Surfaces in VII.F3.A-565 condensation Miscellaneous Piping VII.F4.A-565 and Ducting VII.G.A-565 Components" VII.H2.A-565 D 162 D 164 D 165 N 166 BWR/PWR Copper alloy piping, None None No VII.J.A-711 piping components exposed to concrete Page 48 of 74 N 167 BWR/PWR Zinc piping None None No VII.J.A-712 components exposed to air-indoor controlled, air - indoor uncontrolled

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 169 BWR/PWR Steel, copper alloy Loss of material due to AMP XI.M2, "Water No VII.F1.A-566 piping, piping general (steel only), pitting, Chemistry," and VII.F2.A-566 components exposed crevice corrosion AMP XI.M32, VII.F3.A-566 to steam "One-Time VII.F4.A-566 Inspection" N 170 BWR/PWR Stainless steel piping, Loss of material due to AMP XI.M2, "Water No VII.F1.A-567 piping components pitting, crevice corrosion Chemistry," and VII.F2.A-567 exposed to steam AMP XI.M32, VII.F3.A-567 "One-Time VII.F4.A-567 Inspection" D 171 N 172 BWR/PWR PVC piping, piping Reduction in impact strength AMP XI.M36, No VII.C1.A-458 components exposed due to photolysis "External Surfaces VII.E5.A-458 to air-outdoor Monitoring of VII.G.A-458 Mechanical Components" D 173 D 174 N 175 BWR/PWR Fiberglass piping, Cracking, blistering, loss of AMP XI.M38, No VII.C1.A-460 piping components, material due to exposure to "Inspection of VII.E5.A-551 tanks exposed to raw ultraviolet light, ozone, Internal Surfaces in VII.G.A-644 water (for components radiation, temperature, or Miscellaneous Piping not covered by NRC moisture; flow blockage due and Ducting GL 89-13), raw water to fouling (raw water, waste Components" (potable), treated water only) water, waste water N 176 BWR/PWR Fiberglass piping, Loss of material due to AMP XI.M38, No VII.C1.A-461 piping components, wear; flow blockage due to "Inspection of VII.E5.A-552 tanks exposed to raw fouling (raw water, waste Internal Surfaces in VII.G.A-645 water environment (for water only) Miscellaneous Piping components not and Ducting covered by NRC GL Components" 89-13), raw water Page 49 of 74 (potable), treated water, waste water N 177 BWR/PWR Fiberglass piping, Loss of material due to wear AMP XI.M41, "Buried No VII.I.A-462 piping components and Underground exposed to soil Piping and Tanks"

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 178 BWR/PWR Fiberglass piping and None None No VII.J.A-710 piping components exposed to concrete N 179 BWR/PWR Masonry walls: Cracking due to restraint AMP XI.M26, "Fire No VII.G.A-626 structural fire barriers shrinkage, creep, Protection," and exposed to air aggressive environment; AMP XI.S5, loss of material (spalling, "Masonry Walls" scaling) and cracking due to freeze-thaw D 180 N 181 BWR/PWR Titanium piping, piping None None No VII.J.A-703 components exposed to condensation N 182 BWR/PWR Non-metallic thermal Reduced thermal insulation AMP XI.M36, No VII.I.A-704 insulation exposed to resistance due to moisture "External Surfaces air, condensation intrusion Monitoring of Mechanical Components" N 184 BWR/PWR PVC piping, piping None None No VII.J.A-709 components, tanks exposed to concrete N 185 BWR/PWR Aluminum fire water Cracking due to SCC AMP XI.M27, No VII.G.A-623 storage tanks "Fire Water System" exposed to air, condensation, soil, concrete, raw water, raw water (potable),

treated water Page 50 of 74

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 186 BWR/PWR Aluminum tanks Cracking due to SCC AMP XI.M29, Yes (SRP-SLR VII.C3.A-482a (within the scope of "Outdoor and Large Section 3.3.2.2.8) VII.C3.A-482b AMP XI.M29, Atmospheric Metallic VII.C3.A-482c "Outdoor and Large Storage Tanks," VII.E5.A-482a Atmospheric Metallic AMP XI.M32, VII.E5.A-482b Storage Tanks") "One-Time VII.E5.A-482c exposed to air, Inspection," or VII.H1.A-482a condensation, soil, AMP XI.M42, VII.H1.A-482b concrete, raw water, "Internal VII.H1.A-482c waste water Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks" D 187 N 189 BWR/PWR Aluminum piping, Cracking due to SCC AMP XI.M32, Yes (SRP-SLR VII.A2.A-451a piping components, "One-Time Section 3.3.2.2.8) VII.A2.A-451b tanks exposed to air, Inspection," VII.A2.A-451c condensation, raw AMP XI.M36, VII.A2.A-451d water, raw water "External Surfaces VII.A3.A-451a (potable), waste water Monitoring of VII.A3.A-451b Mechanical VII.A3.A-451c Components," VII.A3.A-451d AMP XI.M38, VII.A4.A-451a "Inspection of VII.A4.A-451b Internal Surfaces in VII.A4.A-451c Miscellaneous Piping VII.A4.A-451d and Ducting VII.C1.A-451a Components," or VII.C1.A-451b AMP XI.M42, VII.C1.A-451c "Internal VII.C1.A-451d Coatings/Linings for VII.C2.A-451a In-Scope Piping, VII.C2.A-451b Page 51 of 74 Piping Components, VII.C2.A-451c Heat Exchangers, VII.C2.A-451d and Tanks" VII.C3.A-451a VII.C3.A-451b VII.C3.A-451c

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item VII.C3.A-451d VII.D.A-451a VII.D.A-451b VII.D.A-451c VII.D.A-451d VII.E1.A-451a VII.E1.A-451b VII.E1.A-451c VII.E1.A-451d VII.E2.A-451a VII.E2.A-451b VII.E2.A-451c VII.E2.A-451d VII.E3.A-451a VII.E3.A-451b VII.E3.A-451c VII.E3.A-451d VII.E4.A-451a VII.E4.A-451b VII.E4.A-451c VII.E4.A-451d VII.E5.A-451a VII.E5.A-451b VII.E5.A-451c VII.E5.A-451d VII.F1.A-451a VII.F1.A-451b VII.F1.A-451c VII.F1.A-451d VII.F2.A-451a VII.F2.A-451b VII.F2.A-451c VII.F2.A-451d Page 52 of 74 VII.F3.A-451a VII.F3.A-451b VII.F3.A-451c VII.F3.A-451d VII.F4.A-451a VII.F4.A-451b

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item VII.F4.A-451c VII.F4.A-451d VII.G.A-451a VII.G.A-451b VII.G.A-451c VII.G.A-451d VII.H1.A-451a VII.H1.A-451b VII.H1.A-451c VII.H1.A-451d VII.H2.A-451a VII.H2.A-451b VII.H2.A-451c VII.H2.A-451d D 190 D 191 N 192 BWR/PWR Aluminum Cracking due to SCC AMP XI.M32, Yes (SRP-SLR VII.I.A-706a underground piping, "One-Time Section 3.3.2.2.8) VII.I.A-706b piping components, Inspection," VII.I.A-706c tanks AMP XI.M41, "Buried and Underground Piping and Tanks," or AMP XI.M42, "Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks" Page 53 of 74

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 193 BWR/PWR Steel components Long-term loss of material AMP XI.M32, No VII.A3.A-439 exposed to treated due to general corrosion "One-Time VII.A4.A-439 water, raw water, raw Inspection" VII.C1.A-532 water (potable), waste VII.C2.A-439 water VII.C3.A-532 VII.E1.A-439 VII.E2.A-439 VII.E3.A-439 VII.E4.A-532 VII.E5.A-785 VII.G.A-439 VII.G.A-532 VII.H2.A-439 VII.H2.A-532 N 194 BWR/PWR PVC piping, piping Loss of material due to wear AMP XI.M41, "Buried No VII.I.A-537 components, and and Underground tanks exposed to soil Piping and Tanks" N 195 BWR/PWR Concrete, concrete Cracking due to chemical AMP XI.M27, No VII.G.A-647 cylinder piping, reaction, weathering, "Fire Water System" reinforced concrete, settlement, or corrosion of asbestos cement, reinforcement (reinforced cementitious piping, concrete only); loss of piping components material due to exposed to raw water, delamination, exfoliation, treated water, raw spalling, popout, scaling, or water (potable) cavitation; flow blockage due to fouling (raw water only)

N 196 BWR/PWR HDPE piping, piping Cracking, blistering; flow AMP XI.M27, No VII.G.A-648 components exposed blockage due to fouling (raw "Fire Water System" to raw water, treated water only) water, raw water (potable)

Page 54 of 74

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 197 BWR/PWR Metallic fire water Loss of material due to AMP XI.M36, No VII.G.A-649 system piping, piping general (steel, copper alloy "External Surfaces components, heat only), pitting, crevice Monitoring of exchanger, heat corrosion Mechanical exchanger Components" components (any material) with only a leakage boundary (spatial) or structural integrity (attached) intended function exposed to any external environment except soil, concrete N 198 BWR/PWR Metallic fire water Loss of material due to AMP XI.M38, No VII.G.A-650 system piping, piping general (steel, copper alloy "Inspection of components, heat only), pitting, crevice Internal Surfaces in exchanger, heat corrosion, MIC (all metallic Miscellaneous Piping exchanger materials except aluminum; and Ducting components (any in liquid environments only) Components" material) with only a leakage boundary (spatial) or structural integrity (attached) intended function N 199 BWR/PWR Cranes: steel Loss of preload due to self- AMP XI.M23, No VII.B.A-730 structural bolting loosening; loss of material "Inspection of exposed to air due to general corrosion; Overhead Heavy cracking Load and Light Load (Related to Refueling) Handling Systems" D 200 Page 55 of 74 N 202 BWR/PWR Stainless steel piping, None None Yes (SRP-SLR VII.J.AP-19 piping components Section 3.3.2.2.9) exposed to concrete

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 203 BWR Stainless steel; steel Loss of material due to AMP XI.M2, "Water No VII.A4.AP-110 with stainless steel pitting, crevice corrosion, Chemistry," and VII.A4.AP-111 cladding, nickel alloy MIC AMP XI.M32, VII.E2.AP-141 piping, piping "One Time VII.E3.AP-110 components, heat Inspection" VII.E4.AP-110 exchanger components, tanks exposed to treated water, sodium pentaborate solution D 204 N 205 BWR/PWR Insulated stainless Cracking due to SCC AMP XI.M29, Yes (SRP-SLR VII.I.A-734a steel piping, piping "Outdoor and Large Section 3.3.2.2.3) VII.I.A-734b components, tanks Atmospheric Metallic VII.I.A-734c exposed to air, Storage Tanks," VII.I.A-734d condensation AMP XI.M32, "One-Time Inspection,"

AMP XI.M36, "External Surfaces Monitoring of Mechanical Components," or AMP XI.M42, "Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks" D 206 N 207 BWR/PWR Stainless steel, copper Cracking due to SCC AMP XI.M38, No VII.C1.A-736 alloy, titanium heat (titanium only), reduction of "Inspection of Page 56 of 74 exchanger tubes heat transfer due to fouling Internal Surfaces in exposed to raw water Miscellaneous Piping (for components not and Ducting covered by NRC Components" GL 89-13)

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 208 BWR/PWR Concrete, concrete Cracking due to chemical AMP XI.M38, No VII.C1.A-737 cylinder piping, reaction, weathering, "Inspection of reinforced concrete, settlement, or corrosion of Internal Surfaces in asbestos cement, reinforcement (reinforced Miscellaneous Piping cementitious piping, concrete only); loss of and Ducting piping components material due to Components" exposed to raw water delamination, exfoliation, (for components not spalling, popout, scaling, or covered by NRC cavitation; flow blockage GL 89-13) due to fouling D 209 N 210 BWR/PWR HDPE piping, piping Cracking, blistering; flow AMP XI.M38, No VII.C1.A-739 components exposed blockage due to fouling "Inspection of to raw water (for Internal Surfaces in components not Miscellaneous Piping covered by NRC and Ducting GL 89-13) Components" D 211 D 212 D 213 N 214 BWR/PWR Copper alloy (>15% Loss of material due to AMP XI.M33, No VII.C1.A-743 Zn or >8% Al) piping, selective leaching "Selective Leaching" VII.C2.A-743 piping components VII.C3.A-743 exposed to soil VII.D.A-743 VII.E4.A-743 VII.E5.A-743 VII.G.A-743 VII.H1.A-743 VII.H2.A-743 N 215 BWR/PWR Aluminum fire water Loss of material due to AMP XI.M27, No VII.G.A-744 storage tanks pitting, crevice corrosion "Fire Water System" exposed to air, condensation, soil, Page 57 of 74 concrete, raw water, raw water (potable),

treated water

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 216 BWR/PWR Stainless steel fire Cracking due to SCC AMP XI.M27, "Fire No VII.G.A-745 water storage tanks Water System" exposed to air, condensation, soil, concrete D 217 N 218 BWR/PWR Stainless steel fire Loss of material due to AMP XI.M27, "Fire No VII.G.A-747 water storage tanks pitting, crevice corrosion, Water System" exposed to air, MIC (water and soil condensation, soil, environment only) concrete, raw water, raw water (potable),

treated water N 219 BWR/PWR Stainless steel piping, Cracking due to SCC AMP XI.M2, "Water No VII.F1.A-748 piping components Chemistry," and VII.F2.A-748 exposed to steam AMP XI.M32, VII.F3.A-748 "One-Time VII.F4.A-748 Inspection" D 220 D 221 Page 58 of 74

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 222 BWR/PWR Stainless steel, nickel Loss of material due to AMP XI.M32, Yes (SRP-SLR VII.I.A-751b alloy tanks exposed to pitting, crevice corrosion "One-Time Section 3.3.2.2.4) VII.I.A-751c air, condensation Inspection," VII.I.A-751d (internal/external) AMP XI.M36, VII.I.A-751e "External Surfaces Monitoring of Mechanical Components,"

AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components," or AMP XI.M42, "Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks" N 223 BWR/PWR Aluminum Loss of material due to AMP XI.M32, Yes (SRP-SLR VII.I.A-752a underground piping, pitting, crevice corrosion "One-Time Section 3.3.2.2.10) VII.I.A-752b piping components, Inspection," VII.I.A-752c tanks AMP XI.M41, "Buried and Underground Piping and Tanks," or AMP XI.M42, "Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, Page 59 of 74 and Tanks" D 224 D 225

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 226 BWR/PWR Aluminum tanks Loss of material due to AMP XI.M29, No VII.I.A-755 (within the scope of pitting, crevice corrosion "Outdoor and Large AMP XI.M29, Atmospheric Metallic "Outdoor and Large Storage Tanks" Atmospheric Metallic Storage Tanks")

exposed to soil, concrete N 227 BWR/PWR Aluminum tanks Loss of material due to AMP XI.M29, Yes (SRP-SLR VII.C3.A-756a (within the scope of pitting, crevice corrosion "Outdoor and Large Section 3.3.2.2.10) VII.C3.A-756b AMP XI.M29, Atmospheric Metallic VII.C3.A-756c "Outdoor and Large Storage Tanks," VII.E5.A-756a Atmospheric Metallic AMP XI.M32, VII.E5.A-756b Storage Tanks") "One-Time VII.E5.A-756c exposed to air, Inspection," or VII.H1.A-756a condensation AMP XI.M42, VII.H1.A-756b "Internal VII.H1.A-756c Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks" N 228 BWR/PWR Stainless steel, nickel Loss of material due to AMP XI.M29, Yes (SRP-SLR VII.C3.A-757a alloy tanks (within the pitting, crevice corrosion "Outdoor and Large Section 3.3.2.2.4) VII.C3.A-757b scope of AMP XI.M29, Atmospheric Metallic VII.C3.A-757c "Outdoor and Large Storage Tanks," VII.E5.A-757a Atmospheric Metallic AMP XI.M32, VII.E5.A-757b Storage Tanks") "One Time VII.E5.A-757c exposed to air, Inspection," or VII.H1.A-757a condensation AMP XI.M42, VII.H1.A-757b "Internal VII.H1.A-757c Coatings/Linings for In-Scope Piping, Page 60 of 74 Piping Components, Heat Exchangers, and Tanks"

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 229 BWR/PWR Stainless steel tanks Loss of material due to AMP XI.M29, No VII.C3.A-758 (within the scope of pitting, crevice corrosion, "Outdoor and Large VII.E5.A-758 AMP XI.M29, MIC (soil only) Atmospheric Metallic VII.H1.A-758 "Outdoor and Large Storage Tanks" Atmospheric Metallic Storage Tanks")

exposed to soil, concrete N 230 BWR/PWR Stainless steel tanks Cracking due to SCC AMP XI.M29, No VII.C3.A-759 (within the scope of "Outdoor and Large VII.E5.A-759 AMP XI.M29, Atmospheric Metallic VII.H1.A-759 "Outdoor and Large Storage Tanks" Atmospheric Metallic Storage Tanks")

exposed to soil, concrete N 231 BWR/PWR Stainless steel tanks Cracking due to SCC AMP XI.M29, Yes (SRP-SLR VII.C3.A-760a (within the scope of "Outdoor and Large Section 3.3.2.2.3) VII.C3.A-760b AMP XI.M29, Atmospheric Metallic VII.C3.A-760c "Outdoor and Large Storage Tanks," VII.E5.A-760a Atmospheric Metallic AMP XI.M32, VII.E5.A-760b Storage Tanks") "One-Time VII.E5.A-760c exposed to air, Inspection," or VII.H1.A-760a condensation AMP XI.M42, VII.H1.A-760b "Internal VII.H1.A-760c Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks" Page 61 of 74

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 232 BWR/PWR Insulated stainless Loss of material due to AMP XI.M29, Yes (SRP-SLR VII.I.A-761a steel, nickel alloy pitting, crevice corrosion "Outdoor and Large Section 3.3.2.2.4) VII.I.A-761b piping, piping Atmospheric Metallic VII.I.A-761c components, tanks Storage Tanks," VII.I.A-761d exposed to air, AMP XI.M32, condensation "One-Time Inspection,"

AMP XI.M36, "External Surfaces Monitoring of Mechanical Components," or AMP XI.M42, "Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks" N 233 BWR/PWR Insulated aluminum Cracking due to SCC AMP XI.M29, Yes (SRP-SLR VII.I.A-762a piping, piping "Outdoor and Large Section 3.3.2.2.8) VII.I.A-762b components, tanks Atmospheric Metallic VII.I.A-762c exposed to air, Storage Tanks," VII.I.A-762d condensation AMP XI.M32, "One-Time Inspection,"

AMP XI.M36, "External Surfaces Monitoring of Mechanical Components," or AMP XI.M42, "Internal Page 62 of 74 Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks"

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 234 BWR/PWR Aluminum piping, Loss of material due to AMP XI.M32, Yes (SRP-SLR VII.A4.A-763a piping components, pitting, crevice corrosion "One-Time Section 3.3.2.2.10) VII.A4.A-763b tanks exposed to air, Inspection," VII.A4.A-763c condensation AMP XI.M36, VII.A4.A-763d "External Surfaces VII.C1.A-763a Monitoring of VII.C1.A-763b Mechanical VII.C1.A-763c Components," VII.C1.A-763d AMP XI.M38, VII.C3.A-763a "Inspection of VII.C3.A-763b Internal Surfaces in VII.C3.A-763c Miscellaneous Piping VII.C3.A-763d and Ducting VII.E5.A-763a Components," or VII.E5.A-763b AMP XI.M42, VII.E5.A-763c "Internal VII.E5.A-763d Coatings/Linings for VII.F1.A-763a In-Scope Piping, VII.F1.A-763b Piping Components, VII.F1.A-763c Heat Exchangers, VII.F1.A-763d and Tanks" VII.F2.A-763a VII.F2.A-763b VII.F2.A-763c VII.F2.A-763d VII.F3.A-763a VII.F3.A-763b VII.F3.A-763c VII.F3.A-763d VII.F4.A-763a VII.F4.A-763b VII.F4.A-763c VII.F4.A-763d VII.H1.A-763a Page 63 of 74 VII.H1.A-763b VII.H1.A-763c VII.H1.A-763d VII.H2.A-763a VII.H2.A-763b

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item VII.H2.A-763c VII.H2.A-763d N 235 BWR/PWR Metallic piping, piping Loss of material due to AMP XI.M24, No VII.D.A-764 components exposed general (steel only), pitting, "Compressed Air to air-dry (internal) crevice corrosion Monitoring" N 236 BWR/PWR Titanium heat Cracking due to SCC, AMP XI.M2, "Water No VII.A3.A-765 exchanger tubes reduction of heat transfer Chemistry," and VII.A4.A-765 exposed to treated due to fouling AMP XI.M32, VII.C1.A-765 water "One-Time VII.C3.A-765 Inspection" VII.E1.A-765 VII.E3.A-765 VII.G.A-765 VII.H2.A-765 N 237 BWR/PWR Titanium (ASTM None None No VII.J.A-766 Grades 1, 2, 7, 9, 11, or 12) heat exchanger components other than tubes, piping, piping components exposed to treated water N 238 BWR/PWR Titanium heat Cracking due to SCC, AMP XI.M21A, No VII.C2.A-767 exchanger tubes reduction of heat transfer "Closed Treated VII.E3.A-767 exposed to closed- due to fouling Water Systems" VII.E4.A-767 cycle cooling water VII.F1.A-767 VII.F2.A-767 VII.F3.A-767 VII.F4.A-767 N 239 BWR/PWR Titanium (ASTM None None No VII.J.A-768 Grades 1, 2, 7, 9, 11, or 12) heat exchanger components other than tubes, piping, Page 64 of 74 piping components exposed to closed-cycle cooling water

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 240 BWR/PWR Aluminum heat Loss of material due to AMP XI.M32, Yes (SRP-SLR VII.E5.A-769a exchanger pitting, crevice corrosion "One-Time Section 3.3.2.2.10) VII.E5.A-769b components exposed Inspection," VII.E5.A-769c to waste water AMP XI.M36, VII.E5.A-769d "External Surfaces Monitoring of Mechanical Components,"

AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components," or AMP XI.M42, "Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks" Page 65 of 74

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 241 BWR/PWR Stainless steel, nickel Loss of material due to AMP XI.M32, Yes (SRP-SLR VII.F1.A-770a alloy heat exchanger pitting, crevice corrosion "One-Time Section 3.3.2.2.4) VII.F1.A-770b components exposed Inspection," VII.F1.A-770c to air, condensation AMP XI.M36, VII.F1.A-770d "External Surfaces VII.F2.A-770a Monitoring of VII.F2.A-770b Mechanical VII.F2.A-770c Components," VII.F2.A-770d AMP XI.M38, VII.F3.A-770a "Inspection of VII.F3.A-770b Internal Surfaces in VII.F3.A-770c Miscellaneous Piping VII.F3.A-770d and Ducting VII.F4.A-770a Components," or VII.F4.A-770b AMP XI.M42, VII.F4.A-770c "Internal VII.F4.A-770d Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks" Page 66 of 74

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 242 BWR/PWR Aluminum heat Loss of material due to AMP XI.M32, Yes (SRP-SLR VII.F1.A-771a exchanger pitting, crevice corrosion "One-Time Section 3.3.2.2.10) VII.F1.A-771b components exposed Inspection," VII.F1.A-771c to air, condensation AMP XI.M36, VII.F1.A-771d "External Surfaces VII.F2.A-771a Monitoring of VII.F2.A-771b Mechanical VII.F2.A-771c Components," VII.F2.A-771d AMP XI.M38, VII.F3.A-771a "Inspection of VII.F3.A-771b Internal Surfaces in VII.F3.A-771c Miscellaneous Piping VII.F3.A-771d and Ducting VII.F4.A-771a Components," or VII.F4.A-771b AMP XI.M42, VII.F4.A-771c "Internal VII.F4.A-771d Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks" D 243 N 244 BWR Stainless steel, nickel Cracking due to SCC AMP XI.M2, "Water No VII.E3.A-773 alloy piping, piping Chemistry," and VII.E4.A-773 components exposed AMP XI.M32, to treated water >60°C "One-Time

(>140°F) Inspection" Page 67 of 74

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 245 BWR/PWR Insulated aluminum Loss of material due to AMP XI.M29, Yes (SRP-SLR VII.I.A-774a piping, piping pitting, crevice corrosion "Outdoor and Large Section 3.3.2.2.10) VII.I.A-774b components, tanks Atmospheric Metallic VII.I.A-774c exposed to air, Storage Tanks," VII.I.A-774d condensation AMP XI.M32, "One-Time Inspection,"

AMP XI.M36, "External Surfaces Monitoring of Mechanical Components," or AMP XI.M42, "Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks" N 246 BWR/PWR Stainless steel, nickel Loss of material due to AMP XI.M32, Yes (SRP-SLR VII.I.A-775a alloy underground pitting, crevice corrosion "One-Time Section 3.3.2.2.4) VII.I.A-775b piping, piping Inspection," VII.I.A-775c components, tanks AMP XI.M41, "Buried and Underground Piping and Tanks," or AMP XI.M42, "Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks" Page 68 of 74

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 247 BWR/PWR Aluminum piping, Loss of material due to AMP XI.M29, Yes (SRP-SLR VII.C1.A-776a piping components, pitting, crevice corrosion "Outdoor and Large Section 3.3.2.2.10) VII.C1.A-776b tanks exposed to raw Atmospheric Metallic VII.C1.A-776c water, waste water Storage Tanks," VII.C1.A-776d AMP XI.M32, VII.C3.A-776a "One-Time VII.C3.A-776b Inspection," VII.C3.A-776c AMP XI.M38, VII.C3.A-776d "Inspection of VII.E5.A-776a Internal Surfaces in VII.E5.A-776b Miscellaneous Piping VII.E5.A-776c and Ducting VII.E5.A-776d Components," or AMP XI.M42, "Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks" N 248 BWR/PWR Aluminum piping, None None No VII.J.A-777 piping components, tanks exposed to air with borated water leakage N 249 BWR/PWR Steel heat exchanger Loss of material due to AMP XI.M38, No VII.C1.A-778 tubes internal to general, pitting, crevice "Inspection of VII.F1.A-778 components exposed corrosion Internal Surfaces in VII.F2.A-778 to air-outdoor, air- Miscellaneous Piping VII.F3.A-778 indoor uncontrolled, and Ducting VII.F4.A-778 condensation Components" N 250 BWR/PWR Steel reactor coolant Loss of material due to AMP XI.M32, No VII.G.AP-116 pump oil collection general, pitting, crevice "One-Time VII.G.AP-117 Page 69 of 74 system tanks, piping, corrosion, MIC Inspection" piping components exposed to lubricating oil (waste oil)

D 251

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 252 BWR/PWR Aluminum piping, Loss of material due to AMP XI.M41, "Buried No VII.I.AP-173 piping components pitting, crevice corrosion and Underground exposed to soil, Piping and Tanks" concrete N 253 BWR/PWR PVC piping, piping Loss of material due to AMP XI.M20, No VII.C1.A-787a components exposed wear; flow blockage due to "Open-Cycle Cooling VII.C1.A-787c to raw water, raw fouling (raw water only) Water System," VII.E5.A-787d water (potable), AMP XI.M27, "Fire VII.G.A-787b treated water, waste Water System," or water AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components" N 254 BWR/PWR Aluminum heat Cracking due to SCC AMP XI.M32, Yes (SRP-SLR VII.F1.A-788a exchanger "One-Time Section 3.3.2.2.8) VII.F1.A-788b components exposed Inspection," VII.F1.A-788c to air, condensation AMP XI.M36, VII.F1.A-788d "External Surfaces VII.F2.A-788a Monitoring of VII.F2.A-788b Mechanical VII.F2.A-788c Components," VII.F2.A-788d AMP XI.M38, VII.F3.A-788a "Inspection of VII.F3.A-788b Internal Surfaces in VII.F3.A-788c Miscellaneous Piping VII.F3.A-788d and Ducting VII.F4.A-788a Components," or VII.F4.A-788b AMP XI.M42, VII.F4.A-788c "Internal VII.F4.A-788d Coatings/Linings for In-Scope Piping, Page 70 of 74 Piping Components, Heat Exchangers, and Tanks"

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 255 BWR/PWR Any material fire Loss of material due to AMP XI.M26, No VII.G.A-789 damper assemblies general, pitting, crevice "Fire Protection" exposed to air corrosion; cracking due to SCC; hardening, loss of strength, shrinkage due to elastomer degradation D 256 N 257 BWR/PWR Steel, stainless steel, Reduction of heat transfer AMP XI.M39, No VII.C1.A-791 copper alloy heat due to fouling "Lubricating Oil VII.C2.A-791 exchanger tubes Analysis," and VII.C3.A-791 exposed to lubricating AMP XI.M32, "One- VII.E1.A-791 oil Time Inspection" VII.E4.A-791 VII.F1.A-791 VII.F2.A-791 VII.F3.A-791 VII.F4.A-791 VII.G.A-791 VII.H2.A-791 N 258 BWR/PWR Metallic, elastomer, Flow blockage due to fouling AMP XI.M38, No VII.E5.A-780 fiberglass, HDPE "Inspection of piping, piping Internal Surfaces in components exposed Miscellaneous Piping to waste water and Ducting Components" Page 71 of 74

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 259 BWR/PWR Aluminum piping, Flow blockage due to fouling AMP XI.M20, No VII.A3.A-793 piping components "Open-Cycle Cooling VII.A4.A-793 exposed to raw water Water System," or VII.C1.A-793a AMP XI.M38, VII.C1.A-793b "Inspection of VII.C2.A-793 Internal Surfaces in VII.C3.A-793 Miscellaneous Piping VII.E1.A-793 and Ducting VII.E2.A-793 Components" VII.E3.A-793 VII.E4.A-793 VII.F1.A-793 VII.F2.A-793 VII.F3.A-793 VII.F4.A-793 VII.H1.A-793 VII.H2.A-793 N 260 BWR/PWR Metallic HVAC closure Loss of material due to AMP XI.M36, No VII.F1.A-794 bolting exposed to air, general (where applicable), "External Surfaces VII.F2.A-794 condensation pitting, crevice corrosion; Monitoring of VII.F3.A-794 cracking due to SCC, loss of Mechanical VII.F4.A-794 preload Components" N 261 BWR/PWR Titanium (ASTM Cracking due to SCC AMP XI.M20, No VII.C1.A-795a Grades 3, 4, or 5) heat "Open-Cycle Cooling VII.C2.A-795b exchanger tubes Water System," or VII.C3.A-795a exposed to closed- AMP XI.M21A, VII.E4.A-795a cycle cooling water, "Closed Treated VII.H2.A-795a raw water Water Systems" Page 72 of 74

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 262 BWR/PWR Titanium piping, piping Cracking due to SCC AMP XI.M20, No VII.C1.A-796a components, heat "Open-Cycle Cooling VII.C2.A-796b exchanger Water System," or VII.C3.A-796a components exposed AMP XI.M21A, VII.E2.A-796c to closed-cycle cooling "Closed Treated VII.E3.A-796c water, treated water Water Systems," or VII.E4.A-796a AMP XI.M38, VII.H2.A-796a "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components" N 263 BWR/PWR Polymeric piping, Hardening or loss of AMP XI.M36, No VII.C1.A-797b piping components, strength due to polymeric "External Surfaces VII.C2.A-797b ducting, ducting degradation; loss of material Monitoring of VII.C3.A-797b components, seals due to peeling, Mechanical VII.D.A-797b exposed to air, delamination, wear; cracking Components," or VII.E5.A-797b condensation, raw or blistering due to exposure AMP XI.M38, VII.F1.A-797b water, raw water to ultraviolet light, ozone, "Inspection of VII.F2.A-797b (potable), treated radiation, or chemical attack; Internal Surfaces in VII.F3.A-797b water, waste water, flow blockage due to fouling Miscellaneous Piping VII.F4.A-797b underground, and Ducting VII.G.A-797b concrete, soil Components" VII.H1.A-797b VII.H2.A-797b VII.I.A-797a Reserved for ID number 264 N 265 BWR/PWR Steel heat exchanger Reduction of heat transfer XI.M30, Fuel Oil No VII.H2.A-799 tubes exposed to fuel due to fouling Chemistry, and oil XI.M32, One-Time Inspection N 266 BWR/PWR Steel heat exchanger Reduction of heat transfer XI.M30, Fuel Oil No VII.H2.A-800 tubes exposed to fuel due to fouling Chemistry, oil Page 73 of 74

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL-SLR Report SLR-ISG-2021-02-MECHANICAL: Appendix E New, Modified, Deleted, Aging Management Edited Program Further Evaluation Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended GALL-SLR Item N 267 BWR/PWR Subliming compound Loss of material due to AMP XI.M26, Fire No VII.G.A-805 fireproofing/fire abrasion, flaking, vibration; Protection barriers (Thermo- cracking/delamination due to lag, Darmatt', chemical reaction, 3M' Interam', and settlement; change in other similar material properties due to materials) exposed to gamma irradiation exposure; air separation N 268 BWR/PWR Cementitious coating Loss of material due to AMP XI.M26, Fire No VII.G.A-806 fireproofing/fire abrasion, exfoliation, Protection barriers (Pyrocrete, elevated temperature, BIO' K-10 Mortar, flaking, spalling; Cafecote, and other cracking/delamination due similar materials) to chemical reaction, exposed to air elevated temperature, settlement, vibration; change in material properties due to elevated temperature, gamma irradiation exposure; separation N 269 BWR/PWR Silicate Loss of material due to AMP XI.M26, Fire No VII.G.A-807 fireproofing/fire abrasion, flaking; Protection barriers (Marinite, cracking/delamination due to Kaowool', settlement; change in Cerafiber, Cera material properties due to blanket, or other gamma irradiation exposure; similar materials) separation exposed to air Page 74 of 74

APPENDIX F REVISIONS TO ADDRESS REDUCTION OF HEAT TRANSFER FOR HEAT EXCHANGER TUBES IN A FUEL OIL ENVIRONMENT Summary of Revisions This ISG revises the SRP-SLR and GALL-SLR Volume 1 to include a line item to manage the reduction of heat transfer for a steel heat exchanger radiator exposed internally to diesel fuel oil.

The NRC staffs review of an SLRA identified an acceptable way to manage this aging effect for the material and environment described; this may occur in other SLRAs as well.

Basis for Revisions The Fuel Oil Chemistry program is capable of mitigating reduction of heat transfer for heat exchanger tubes by periodic sampling of fuel oil for contaminants that may cause the reduction of heat transfer due to fouling. The Fuel Oil Chemistry program can manage contaminants that would promote corrosion (e.g. water or microbial activity), particulate concentration, or other contaminants that are tested for under ASTM D975 that could contribute to heat exchanger tube fouling. In the GALL-SLR, Element 4, Detection of Aging Effects, of AMP XI.M30, Fuel Oil Chemistry, describes scenarios where inspections of fuel oil tanks may be used to inform the condition of downstream components. As described in the AMP, if the tank is coated or constructed of a different material than the steel heat exchanger tubes, a one-time inspection may be necessary.

AMP Revisions None Revisions to FSAR Supplement None Revisions to SRP-SLR Table 3.3-1 SRP-SLR Table 3.3-1 is provided in its entirety in Appendix E of this ISG. The only change to SRP-SLR Table 3.3-1 associated with this appendix is the addition of line items 265 and 266.

Revisions to GALL-SLR Chapter VII, Table H2 On the next page, GALL-SLR Chapter VII, Table H2 is reproduced in its entirety. Most of the line items in this table are unchanged. The revisions are the addition of the following four items near the end of the table: VII.H2.A-799, VII.H2.A-800, VII.H2.A-801, and, VII.H2.A-802.

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix F Table H2 Emergency Diesel Generator System Aging New, Modified, SRP Item Structure Management Deleted, Edited (Table, and/or Aging Program Further Item Item ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation N VII.H2.A-532 3.3-1, Any Steel Raw water Long-term loss of AMP XI.M32, No 193 material due to "One-Time general corrosion Inspection" N VII.H2.A-439 3.3-1, Any Steel Treated water Long-term loss of AMP XI.M32, No 193 material due to "One-Time general corrosion Inspection" M VII.H2.AP- 3.3-1, Diesel engine Stainless Diesel Cracking due to AMP XI.M38, No 128 083 exhaust piping, steel exhaust SCC "Inspection of piping components Internal Surfaces in Miscellaneous Piping and Ducting Components" M VII.H2.AP- 3.3-1, Heat exchanger Steel Lubricating oil Loss of material AMP XI.M39, No 131 098 components due to general, "Lubricating Oil pitting, crevice Analysis," and corrosion, MIC AMP XI.M32, "One-Time Inspection" M VII.H2.AP- 3.3-1, Heat exchanger Titanium Raw water Cracking due to AMP XI.M20, No 152a 123 components other SCC, flow "Open-Cycle than tubes blockage due to Cooling Water fouling System" VII.H2.AP- 3.3-1, Heat exchanger Aluminum Lubricating oil Reduction of heat AMP XI.M39, No 154 101 tubes transfer due to "Lubricating Oil fouling Analysis," and AMP XI.M32, "One-Time Inspection" N VII.H2.A-565 3.3-1, Heat exchanger Copper alloy Condensation Reduction of heat AMP XI.M38, No 161 tubes transfer due to "Inspection of fouling Internal Surfaces in Miscellaneous Page 2 of 12 Piping and Ducting Components"

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix F Table H2 Emergency Diesel Generator System Aging New, Modified, SRP Item Structure Management Deleted, Edited (Table, and/or Aging Program Further Item Item ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M VII.H2.AP- 3.3-1, Heat exchanger Stainless Raw water Cracking due to AMP XI.M20, No 187 042 tubes steel, copper SCC (titanium "Open-Cycle alloy, only), reduction of Cooling Water titanium heat transfer due System" to fouling N VII.H2.A-765 3.3-1, Heat exchanger Titanium Treated water Cracking due to AMP XI.M2, No 236 tubes SCC, reduction of "Water heat transfer due Chemistry," and to fouling AMP XI.M32, "One-Time Inspection" N VII.H2.A- 3.3-1, Heat exchanger Titanium Raw water Cracking due to AMP XI.M20, No 795a 261 tubes (ASTM SCC "Open-Cycle Grades 3, 4, Cooling Water or 5) System" M VII.H2.A-415 3.3-1, Piping Gray cast Closed-cycle Loss of material AMP XI.M42, No 140 components with iron, ductile cooling water, due to selective "Internal internal iron with raw water, leaching Coatings/Linings coatings/linings internal treated water, for In-Scope coating/lining waste water Piping, Piping Components, Heat Exchangers, and Tanks" M VII.H2.AP- 3.3-1, Piping, piping Aluminum Closed-cycle Loss of material AMP XI.M21A, No 255 048 components cooling water due to pitting, "Closed Treated crevice corrosion Water Systems" M VII.H2.AP- 3.3-1, Piping, piping Aluminum Fuel oil Loss of material AMP XI.M30, No 129 071 components due to pitting, "Fuel Oil crevice corrosion, Chemistry," and MIC AMP XI.M32, "One-Time Inspection" N VII.H2.AP- 3.3-1, Piping, piping Aluminum Fuel oil Loss of material AMP XI.M30, No Page 3 of 12 129a 071 components due to pitting, "Fuel Oil crevice corrosion, Chemistry" MIC

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix F Table H2 Emergency Diesel Generator System Aging New, Modified, SRP Item Structure Management Deleted, Edited (Table, and/or Aging Program Further Item Item ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M VII.H2.AP- 3.3-1, Piping, piping Aluminum Lubricating oil Loss of material AMP XI.M39, No 162 099 components due to pitting, "Lubricating Oil crevice corrosion Analysis," and AMP XI.M32, "One-Time Inspection" N VII.H2.A-793 3.3-1, Piping, piping Aluminum Raw water Flow blockage due AMP XI.M38, No 259 components to fouling "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components" N VII.H2.AP- 3.3-1, Piping, piping Aluminum Treated water Loss of material AMP XI.M2, No 130 025 components due to pitting, "Water crevice corrosion Chemistry," and AMP XI.M32, "One-Time Inspection" M VII.H2.AP- 3.3-1, Piping, piping Copper alloy Closed-cycle Loss of material AMP XI.M21A, No 199 046 components cooling water due to pitting, "Closed Treated crevice corrosion, Water Systems" MIC M VII.H2.AP- 3.3-1, Piping, piping Copper alloy Fuel oil Loss of material AMP XI.M30, No 132 069 components due to pitting, "Fuel Oil crevice corrosion, Chemistry," and MIC AMP XI.M32, "One-Time Inspection" N VII.H2.AP- 3.3-1, Piping, piping Copper alloy Fuel oil Loss of material AMP XI.M30, No 132a 069 components due to pitting, "Fuel Oil crevice corrosion, Chemistry" MIC Page 4 of 12

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix F Table H2 Emergency Diesel Generator System Aging New, Modified, SRP Item Structure Management Deleted, Edited (Table, and/or Aging Program Further Item Item ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M VII.H2.AP- 3.3-1, Piping, piping Copper alloy Lubricating oil Loss of material AMP XI.M39, No 133 099 components due to pitting, "Lubricating Oil crevice corrosion, Analysis," and MIC AMP XI.M32, "One-Time Inspection" M VII.H2.AP- 3.3-1, Piping, piping Copper alloy Raw water Loss of material AMP XI.M20, No 193 034 components due to general, "Open-Cycle pitting, crevice Cooling Water corrosion, MIC; System" flow blockage due to fouling M VII.H2.AP-43 3.3-1, Piping, piping Copper alloy Closed-cycle Loss of material AMP XI.M33, No 072 components (>15% Zn or cooling water due to selective "Selective

>8% Al) leaching Leaching" M VII.H2.A-47 3.3-1, Piping, piping Copper alloy Raw water Loss of material AMP XI.M33, No 072 components (>15% Zn or due to selective "Selective

>8% Al) leaching Leaching" N VII.H2.A-743 3.3-1, Piping, piping Copper alloy Soil Loss of material AMP XI.M33, No 214 components (>15% Zn or due to selective "Selective

>8% Al) leaching Leaching" M VII.H2.A-51 3.3-1, Piping, piping Gray cast Raw water Loss of material AMP XI.M33, No 072 components iron, ductile due to selective "Selective iron leaching Leaching" M VII.H2.A-02 3.3-1, Piping, piping Gray cast Soil Loss of material AMP XI.M33, No 072 components iron, ductile due to selective "Selective iron leaching Leaching" M VII.H2.AP- 3.3-1, Piping, piping Stainless Air, Cracking due to AMP XI.M32, Yes 209a 004 components steel condensation SCC "One-Time Inspection" M VII.H2.AP- 3.3-1, Piping, piping Stainless Air, Cracking due to AMP XI.M36, Yes 209b 004 components steel condensation SCC "External Surfaces Page 5 of 12 Monitoring of Mechanical Components"

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix F Table H2 Emergency Diesel Generator System Aging New, Modified, SRP Item Structure Management Deleted, Edited (Table, and/or Aging Program Further Item Item ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M VII.H2.AP- 3.3-1, Piping, piping Stainless Air, Cracking due to AMP XI.M38, Yes 209c 004 components steel condensation SCC "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components" M VII.H2.AP- 3.3-1, Piping, piping Stainless Fuel oil Loss of material AMP XI.M30, No 136 071 components steel due to pitting, "Fuel Oil crevice corrosion, Chemistry," and MIC AMP XI.M32, "One-Time Inspection" N VII.H2.AP- 3.3-1, Piping, piping Stainless Fuel oil Loss of material AMP XI.M30, No 136a 071 components steel due to pitting, "Fuel Oil crevice corrosion, Chemistry" MIC M VII.H2.AP- 3.3-1, Piping, piping Stainless Lubricating oil Loss of material AMP XI.M39, No 138 100 components steel due to pitting, "Lubricating Oil crevice corrosion, Analysis," and MIC AMP XI.M32, "One-Time Inspection" M VII.H2.AP-55 3.3-1, Piping, piping Stainless Raw water Loss of material AMP XI.M20, No 040 components steel due to pitting, "Open-Cycle crevice corrosion, Cooling Water MIC; flow blockage System" due to fouling M VII.H2.AP- 3.3-1, Piping, piping Stainless Air, Loss of material AMP XI.M32, Yes 221a 006 components steel, nickel condensation due to pitting, "One-Time alloy crevice corrosion Inspection" M VII.H2.AP- 3.3-1, Piping, piping Stainless Air, Loss of material AMP XI.M36, Yes 221b 006 components steel, nickel condensation due to pitting, "External Surfaces Page 6 of 12 alloy crevice corrosion Monitoring of Mechanical Components"

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix F Table H2 Emergency Diesel Generator System Aging New, Modified, SRP Item Structure Management Deleted, Edited (Table, and/or Aging Program Further Item Item ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M VII.H2.AP- 3.3-1, Piping, piping Stainless Air, Loss of material AMP XI.M38, Yes 221c 006 components steel, nickel condensation due to pitting, "Inspection of alloy crevice corrosion Internal Surfaces in Miscellaneous Piping and Ducting Components" M VII.H2.AP- 3.3-1, Piping, piping Stainless Air, Loss of material AMP XI.M42, Yes 221d 006 components steel, nickel condensation due to pitting, "Internal alloy crevice corrosion Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks" M VII.H2.AP- 3.3-1, Piping, piping Steel Fuel oil Loss of material AMP XI.M30, No 105 070 components due to general, "Fuel Oil pitting, crevice Chemistry," and corrosion, MIC AMP XI.M32, "One-Time Inspection" M VII.H2.AP- 3.3-1, Piping, piping Steel Lubricating oil Loss of material AMP XI.M39, No 127 097 components due to general, "Lubricating Oil pitting, crevice Analysis," and corrosion, MIC AMP XI.M32, "One-Time Inspection" M VII.H2.AP- 3.3-1, Piping, piping Steel Raw water Loss of material AMP XI.M20, No 194 037 components due to general, "Open-Cycle pitting, crevice Cooling Water corrosion, MIC; System" flow blockage due to fouling Page 7 of 12 M VII.H2.AP- 3.3-1, Piping, piping Titanium Raw water Cracking due to AMP XI.M20, No 161a 123 components SCC, flow "Open-Cycle blockage due to Cooling Water fouling System"

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix F Table H2 Emergency Diesel Generator System Aging New, Modified, SRP Item Structure Management Deleted, Edited (Table, and/or Aging Program Further Item Item ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M VII.H2.AP- 3.3-1, Piping, piping Steel; Diesel Loss of material AMP XI.M38, No 104 088 components, stainless exhaust due to general "Inspection of diesel engine steel (steel only), pitting, Internal Surfaces exhaust crevice corrosion in Miscellaneous Piping and Ducting Components" N VII.H2.A-495 3.3-1, Piping, piping Fiberglass Air Loss of material AMP XI.M38, No 159 components, due to wear "Inspection of ducting, ducting Internal Surfaces components in Miscellaneous Piping and Ducting Components" N VII.H2.A- 3.3-1, Piping, piping Polymeric Air, Hardening or loss AMP XI.M38, No 797b 263 components, condensation, of strength due to "Inspection of ducting, ducting raw water, polymeric Internal Surfaces components, seals raw water degradation; loss in Miscellaneous (potable), of material due to Piping and treated water, peeling, Ducting waste water, delamination, Components" underground, wear; cracking or concrete, soil blistering due to exposure to ultraviolet light, ozone, radiation, or chemical attack; flow blockage due to fouling N VII.H2.A-722 3.3-1, Piping, piping Steel Air - outdoor Loss of material AMP XI.M38, No 157 components, heat due to general, "Inspection of exchanger pitting, crevice Internal Surfaces components corrosion in Miscellaneous Page 8 of 12 Piping and Ducting Components"

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix F Table H2 Emergency Diesel Generator System Aging New, Modified, SRP Item Structure Management Deleted, Edited (Table, and/or Aging Program Further Item Item ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation N VII.H2.A- 3.3-1, Piping, piping Titanium Closed-cycle Cracking due to AMP XI.M20, No 796a 262 components, heat cooling water, SCC "Open-Cycle exchanger treated water Cooling Water components System" M VII.H2.A-416 3.3-1, Piping, piping Any material Raw water, Loss of coating or AMP XI.M42, No 138 components, heat with an treated water lining integrity due "Internal exchangers, tanks internal to blistering, Coatings/Linings with internal coating/lining cracking, flaking, for In-Scope coatings/linings peeling, Piping, Piping delamination, Components, rusting, physical Heat Exchangers, damage; loss of and Tanks" material or cracking for cementitious coatings/linings M VII.H2.A-414 3.3-1, Piping, piping Any material Raw water, Loss of material AMP XI.M42, No 139 components, heat with an treated water due to general, "Internal exchangers, tanks internal pitting, crevice Coatings/Linings with internal coating/lining corrosion, MIC for In-Scope coatings/linings Piping, Piping Components, Heat Exchangers, and Tanks" N VII.H2.A-677 3.3-1, Piping, piping Elastomer Lubricating oil Hardening or loss AMP XI.M38, No 085 components, seals of strength due to "Inspection of elastomer Internal Surfaces degradation in Miscellaneous Piping and Ducting Components" N VII.H2.A- 3.3-1, Piping, piping Aluminum Air, Loss of material AMP XI.M32, Yes 763a 234 components, tanks condensation due to pitting, "One-Time Page 9 of 12 crevice corrosion Inspection"

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix F Table H2 Emergency Diesel Generator System Aging New, Modified, SRP Item Structure Management Deleted, Edited (Table, and/or Aging Program Further Item Item ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation N VII.H2.A- 3.3-1, Piping, piping Aluminum Air, Loss of material AMP XI.M36, Yes 763b 234 components, tanks condensation due to pitting, "External Surfaces crevice corrosion Monitoring of Mechanical Components" N VII.H2.A- 3.3-1, Piping, piping Aluminum Air, Loss of material AMP XI.M38, Yes 763c 234 components, tanks condensation due to pitting, "Inspection of crevice corrosion Internal Surfaces in Miscellaneous Piping and Ducting Components" N VII.H2.A- 3.3-1, Piping, piping Aluminum Air, Loss of material AMP XI.M42, Yes 763d 234 components, tanks condensation due to pitting, "Internal crevice corrosion Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks" N VII.H2.A- 3.3-1, Piping, piping Aluminum Air, Cracking due to AMP XI.M32, Yes 451a 189 components, tanks condensation, SCC "One-Time raw water, Inspection" waste water N VII.H2.A- 3.3-1, Piping, piping Aluminum Air, Cracking due to AMP XI.M36, Yes 451b 189 components, tanks condensation, SCC "External Surfaces raw water, Monitoring of waste water Mechanical Components" N VII.H2.A- 3.3-1, Piping, piping Aluminum Air, Cracking due to AMP XI.M38, Yes 451c 189 components, tanks condensation, SCC "Inspection of raw water, Internal Surfaces Page 10 of 12 waste water in Miscellaneous Piping and Ducting Components"

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix F Table H2 Emergency Diesel Generator System Aging New, Modified, SRP Item Structure Management Deleted, Edited (Table, and/or Aging Program Further Item Item ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation N VII.H2.A- 3.3-1, Piping, piping Aluminum Air, Cracking due to AMP XI.M42, Yes 451d 189 components, tanks condensation, SCC "Internal raw water, Coatings/Linings waste water for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks" M VII.H2.AP- 3.3-1, Piping, piping Stainless Air, Cracking due to AMP XI.M42, Yes 209d 004 components, tanks steel condensation SCC "Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks" M VII.H2.AP- 3.3-1, Piping, piping Steel Closed-cycle Loss of material AMP XI.M21A, No 202 045 components, tanks cooling water due to general, "Closed Treated pitting, crevice Water Systems" corrosion, MIC M VII.H2.A-26 3.3-1, Piping, piping Steel Condensation Loss of material AMP XI.M38, No 055 components, tanks due to general, "Inspection of pitting, crevice Internal Surfaces corrosion in Miscellaneous Piping and Ducting Components" N VII.H2.AP- 3.3-1, Piping, piping Steel Fuel oil Loss of material AMP XI.M30, No 105a 070 components, tanks due to general, "Fuel Oil pitting, crevice Chemistry" corrosion, MIC D VII.H2.A-23 Page 11 of 12 D VII.H2.A-400 D VII.H2.A-405 D VII.H2.A-425 D VII.H2.A-426 D VII.H2.A-456 D VII.H2.A-651

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix F Table H2 Emergency Diesel Generator System Aging New, Modified, SRP Item Structure Management Deleted, Edited (Table, and/or Aging Program Further Item Item ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation D VII.H2.A-667 D VII.H2.A-714a D VII.H2.A-714b D VII.H2.A-714c D VII.H2.A-733 D VII.H2.A-749 D VII.H2.A-750 D VII.H2.A-790a D VII.H2.A-790b D VII.H2.AP-258 D VII.H2.AP-40 D VII.H2.AP-41 N VII.H2.A-799 3.3.1-265 Heat exchanger Steel Fuel oil Reduction of heat AMP XI.M30, No tubes transfer due to Fuel Oil fouling Chemistry, and AMP XI.M32, One Time Inspection N VII.H2.A-800 3.3.1-266 Heat exchanger Steel Fuel oil Reduction of heat AMP XI.M30, No tubes transfer due to Fuel Oil fouling Chemistry N VII.H2.A-801 3.3-1, Piping, piping Nickel Alloy Fuel oil Loss of material AMP XI.M30, No 071 components due to pitting, Fuel Oil crevice corrosion, Chemistry, and MIC AMP XI.M32, One Time Inspection Page 12 of 12 N VII.H2.A-802 3.3-1, Piping, piping Nickel Alloy Fuel oil Loss of material AMP XI.M30, No 071 components due to pitting, Fuel Oil crevice corrosion, Chemistry MIC

APPENDIX G REVISIONS TO ADDRESS LOSS OF MATERIAL IN NICKEL ALLOY STRAINER COMPONENTS IN FUEL OIL Summary of Revisions This ISG revises SRP-SLR and GALL-SLR Volume 1 to include a line item for managing loss of material for nickel alloy externally exposed to diesel fuel oil. The review of an SLRA identified an acceptable way to manage aging effects for the material and environment described here; this may occur in other SLRAs as well.

Basis for Revisions The staff noted that the GALL-SLR recommends the use of the Fuel Oil Chemistry and One-Time Inspection AMPs to manage loss of material of several different materials that are exposed to a fuel oil environment. These AMR items credit the Fuel Oil Chemistry program to minimize contaminants which could lead to loss of material and the One-Time Inspection program to verify the effectiveness of the Fuel Oil Chemistry program. The use of the Fuel Oil Chemistry program can minimize contaminants regardless of the material of the affected component. Therefore, the staff has reasonable assurance that the Fuel Oil Chemistry program will be effective in managing loss of material for nickel alloy strainer elements exposed to diesel fuel oil.

AMP Revisions None Revisions to FSAR Supplement None Revisions to SRP-SLR Table 3.3-1 SRP-SLR Table 3.3-1 is provided in its entirety in Appendix E of this ISG. The only change to SRP-SLR Table 3.3-1 associated with this appendix is a modification of item 071.

Revisions to GALL-SLR Chapter VII, Table H2 GALL-SLR Chapter VII, Table H2 is reproduced in its entirety in Appendix F of this ISG. Most of the line items in this table are unchanged. The revisions are the addition of the following four items near the end of the table: VII.H2.A-799, VII.H2.A-800, VII.H2.A-801, and, VII.H2.A-802.

APPENDIX H REVISIONS TO AMP XI.M42, INTERNAL COATINGS/LININGS FOR IN-SCOPE PIPING, PIPING COMPONENTS, HEAT EXCHANGERS, AND TANKS Summary of Revisions This ISG revises AMP XI.M42, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks, to recommend opportunistic inspections, in lieu of periodic inspections, as an acceptable alternative for buried internally coated/lined fire water system piping provided: (a) flow tests and internal piping inspections will occur at intervals specified in NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water Based Fire Protection Systems, or as modified by AMP XI.M27, Fire Water System, Table XI.M27-1, Fire Water System Inspection and Testing Recommendations; (b) through-wall flaws in the piping can be detected through continuous system pressure monitoring; and (c) plant-specific operating experience (OE) is acceptable (i.e., no leaks due to the age related degradation of representative internal coatings/linings used in buried in scope fire water system components).

This ISG also revises AMP XI.M42 environments as follows: (a) adds air and condensation environments to the scope of the program; (b) adds soil, concrete, and underground external environments to the final safety analysis report (FSAR) supplement; and (c) corrects inconsistencies for the lubricating oil environment. In addition, this ISG adds new aging management review (AMR) items in NUREG-2191, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, issued July 2017, for managing loss of coating/lining integrity and loss of material in piping, piping components, heat exchangers, and tanks with internal coatings/linings exposed to air dry using AMP XI.M42.

Further, this ISG revises Table 3.3-1 in NUREG-2192, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants, issued July 2017 (SRP-SLR), and the tables in GALL-SLR Report Volume 1,Section VII, to include AMR items for managing recurring internal corrosion of metallic components exposed to raw water that are not covered by Generic Letter (GL) 89-13, Service Water System Problems Affecting Safety-Related Equipment, dated July 18, 1989, using the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program. Additionally, this ISG corrects other associated AMR items by including the a, b, or c designation after the AMR item number to distinguish among the various AMPs that are acceptable for managing the cited aging effect, and deletes closed-cycle cooling water from environments listed in the associated AMR Item 3.3-1-127.

Basis for Revisions The staff has accepted opportunistic inspections, in lieu of periodic inspections, as an acceptable alternative for buried internally coated/lined fire water system piping provided: (a) flow tests and internal piping inspections will occur at intervals specified in NFPA 25, or as modified by AMP XI.M27, Table XI.M27-1; and (b) through-wall flaws in the piping can be detected through continuous system pressure monitoring. Examples of the staffs acceptance of this alternative approach are documented in the Safety Evaluation Report Related to the License Renewal of Fermi 2 Nuclear Power Plant (ADAMS Accession No. ML16190A241) and the Safety Evaluation Report Related to the Subsequent License Renewal of Peach Bottom Atomic Power Station, Units 2 and 3 (ADAMS Accession No. ML20044D902). Based on recent

SLR-ISG-2021-02-MECHANICAL: Appendix H Page 2 of 21 OE involving ruptures of buried fire water system piping due to age-related degradation (ADAMS Accession No. ML19294A044), the staff added a third condition for using this alternative approach related to plant specific operating experience. The staff notes that the subject OE involved degradation of the external surfaces of the piping; however, degradation of internal coatings/linings could also result in significant degradation of buried fire water system piping.

The GALL-SLR Report discusses the reason for citing specific AMPs to manage recurring internal corrosion rather than a plant-specific AMP in the section titled Explanation of the Use of Multiple Aging Management Programs in Aging Management Review Items. For the associated AMR item in the SRP-SLR (item 3.3-1-127), the listed environments still include closed-cycle cooling water even though NUREG-2221, Technical Bases for Changes in the Subsequent License Renewal Guidance Documents NUREG-2191 and NUREG-2192, Table 2-13, notes that the associated item in Table C2, Closed-Cycle Cooling Water System, was deleted because recurring internal corrosion is not anticipated in this system. This ISG corrects this error in conjunction with the adjustments above for the use of multiple AMPs.

AMP Revisions Program Description Proper maintenance of internal coatings/linings is essential to provide reasonable assurance that the intended functions of in-scope components are met. Degradation of coatings/linings can lead to loss of material or cracking of base materials and downstream effects such as reduction in flow, reduction in pressure, or reduction of heat transfer when coatings/linings become debris. The program consists of periodic visual inspections of internal coatings/linings exposed to closed-cycle cooling water (CCCW), raw water, treated water, treated borated water, waste water, fuel oil, and lubricating oil, air, and condensation. Where the visual inspection of the coated/lined surfaces determines that the coating/lining is deficient or degraded, physical tests are performed, where physically possible, in conjunction with the visual inspection. Electric Power Research Institute (EPRI) Report 1019157, Guideline on Nuclear Safety-Related Coatings, provides information on the American Society for Testing and Materials (ASTM) standard guidelines and coatings.

American Concrete Institute (ACI) Standard 201.1R, Guide for Conducting a Visual Inspection of Concrete in Service, provides guidelines for inspecting concrete. In addition, this program may be used to manage aging effects associated with coatings on external surfaces.

Evaluation and Technical Basis

1. Scope of Program: The scope of the program is internal coatings/linings for in-scope piping, piping components, heat exchangers, and tanks exposed to CCCW, raw water, treated water, treated borated water, waste water, fuel oil, and lubricating oil, air, and condensation, where loss of coating or lining integrity could prevent satisfactory accomplishment of any of the components or downstream components current licensing basis (CLB) intended functions identified under Title 10 of the Code of Federal Regulations (10 CFR) 54.4(a)(1), (a)(2), or (a)(3). The aging effects associated with fire water tank internal coatings/linings are managed by Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report aging management program (AMP) XI.M27, Fire Water System, instead of this AMP. However, where the fire water storage tank internals are coated, the Fire Water System Program and Final Safety Analysis Report (FSAR)

Summary Description of the Program should be enhanced to include the

SLR-ISG-2021-02-MECHANICAL: Appendix H Page 3 of 21 recommendations associated with training and qualification of personnel and the corrective actions program element. The Fire Water System Program should also be enhanced to include the recommendations from the acceptance criteria program element.

If a coating/lining has a qualified life, and it will be replaced prior to the end of its qualified life without consideration of extending the life through condition monitoring, it would not be considered long lived and therefore, it would not be within the scope of this AMP.

Coatings/linings are an integral part of an in-scope component. The CLB-intended function(s) of the component dictates whether the component has an intended function(s) that meets the scoping criteria of 10 CFR 54.4(a). Internal coatings/linings for in-scope piping, piping components, heat exchangers, and tanks are not evaluated as standalone components to determine whether they meet the scoping criteria of 10 CFR 54.4(a). It is immaterial whether the coating/lining has an intended function identified in the CLB because it is the CLB-intended function of the component that dictates whether the component is in-scope and thereby the aging effects of the coating/lining integral to the component must be evaluated for potential impact on the components and downstream components intended function(s).

An applicant may elect to manage the aging effects for internal coatings/linings for in-scope piping, piping components, heat exchangers, and tanks in an alternative AMP that is specific to the component or system in which the coatings/linings are installed (e.g., GALL-SLR Report AMP XI.M20, Open-Cycle Cooling Water System, for service water coatings/linings) as long as the following are met:

• The recommendations of this AMP are incorporated into the alternative program.

• Exceptions or enhancements associated with the recommendations in this AMP are included in the alternative AMP.

• The FSAR supplement for this AMP as shown in the GALL-SLR Report Table XI-01, FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging Management Programs, is included in the application with a reference to the alternative AMP.

For components where the aging effects of internally coated/lined surfaces are managed by this program, loss of material, cracking, and loss of material due to selective leaching need not be managed for these components by another program.

This program may be used to manage aging effects associated with external surfaces as indicated in in GALL-SLR Report AMR items and corresponding SRP-SLR Further Evaluation sections[e.g., Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants (SRP-SLR) Section 3.2.2.2.2]. When the external coatings are credited to isolate the external surface of a component from the environment, the recommendations as noted in this AMP are metthe following recommendations are met as noted.

2. Preventive Actions: The program is a condition monitoring program and does not recommend any preventive actions. However, external coatings can be credited as a

SLR-ISG-2021-02-MECHANICAL: Appendix H Page 4 of 21 preventive action based on the coating isolating the external surfaces of a component from the environment.

3. Parameters Monitored or Inspected: Visual inspections are intended to identify coatings/linings that do not meet acceptance criteria, such as peeling and delamination.

Aging mechanisms associated with coatings/linings are described as follows:

• Blistering-formation of bubbles in a coating/lining

• Cracking-formation of breaks in a coating/lining that extend through to the underlying surface

• Flaking-detachment of pieces of the coating/lining itself either from its substrate or from previously applied layers

• Peeling-separation of one or more coats or layers of a coating/lining from the substrate

• Delamination-separation of one coat or layer from another coat or layer, or from the substrate

• Rusting-corrosion of the substrate that occurs beneath or through the applied coating/lining Loss of material and cracking is managed for cementitious materials. See the term Cracking due to chemical reaction, weathering, settlement, or corrosion of reinforcement (reinforced concrete only); loss of material due to delamination, exfoliation, spalling, popout, scaling, or cavitation, in the GALL-SLR Report Chapter IX.F.

Physical damage consists of removal or reduction of the thickness of coating/lining by mechanical damage. For the purposes of this AMP, this would include damage such as that which could occur downstream of a throttled valve as a result of cavitation or erosion.

It does not include physical damage caused by actions such as installing scaffolding or assembly and disassembly of flanged joints.

Physical testing is intended to identify the extent of potential degradation of the coating/lining.

4. Detection of Aging Effects: If a baseline has not been previously established, baseline coating/lining inspections occur in the 10-year period prior to the subsequent period of extended operation. Subsequent inspections are based on an evaluation of the effect of a coating/lining failure on the in-scope components intended function, potential problems identified during prior inspections, and known service life history. Subsequent inspection intervals are established by a coating specialist qualified in accordance with an ASTM International standard endorsed in Regulatory Guide (RG) 1.54. However, inspection intervals should not exceed those in Table XI.M42-1, Inspection Intervals for Internal Coatings/Linings for Tanks, Piping, Piping Components, and Heat Exchangers.

The extent of baseline and periodic inspections is based on an evaluation of the effect of a coating/lining failure on the in-scope components intended function(s), potential problems identified during prior inspections, and known service life history; however, the extent of

SLR-ISG-2021-02-MECHANICAL: Appendix H Page 5 of 21 inspection is not any less than the following for each coating/lining material and environment combination.

• All tanks-all accessible internal surfaces (and external surfaces when credited to isolate the external surfaces of a component from the environment).

• All heat exchangers-all accessible internal surfaces (and external surfaces when credited to isolate the external surfaces of a component from the environment.)

• Piping-either inspect a representative sample of seventy-three 1-foot axial length circumferential segments of piping or 50 percent of the total length of each coating/lining material and environment combination, whichever is less at each unit. The inspection surface includes the entire inside (or outside when applicable) surface of the 1-foot sample. If geometric limitations impede movement of remote or robotic inspection tools, the number of inspection segments is increased in order to cover an equivalent of seventy-three 1-foot axial length sections. For example, if the remote tool can only be maneuvered to view one-third of the inside surface, 219 feet of pipe is inspected.

Table XI.M42-1. Inspection Intervals for Internal Coatings/Linings for Tanks, Piping, Piping Components, and Heat Exchangers1, 6 Inspection Category2 Inspection Interval A 6 years3 B4,5 4 years

1. CLB requirements (e.g., Generic Letter 89-13) might require more frequent inspections.

2. Inspection Categories A. No peeling, delamination, blisters, or rusting are observed during inspections. Any cracking and flaking has been found acceptable in accordance with the acceptance criteria program element of this AMP. No cracking or loss of material in cementitious coatings/linings.

B. Prior inspection results do not meet Category A.

• As an alternative to conducting inspections at the intervals in inspection Category B, an extent of condition inspection is conducted prior to the end of the next refueling outage. The extent of condition inspects either double the number of components or an additional five piping inspections (i.e., five 1-foot segments of piping). If Inspection Category A criteria are satisfied for the other coatings in the initial sample and the expanded scope, Inspection Category A may be used for subsequent inspections.

3. If the following conditions are met, the inspection interval may be extended to 12 years:

a. The identical coating/lining material was installed with the same installation requirements in redundant trains (e.g., piping segments, tanks) with the same operating conditions and at least one of the trains is inspected every 6 years.

b. The coating/lining is not in a location subject to erosion that could result in damage to the coating/lining (e.g., certain heat exchanger end bells, piping downstream of certain control valves, windborn erosive particles for external coatings).

4. Subsequent inspections for Inspection Category B are reinspections at the original location(s), when the coatings/linings have not been repaired, replaced, or removed, as well as inspections of new locations.

5. When conducting inspections for Inspection Category B, if two sequential subsequent inspections demonstrate no change in coating/lining condition (i.e., at least three consecutive inspections with no change in condition),

subsequent inspections at those locations may be conducted to Inspection Category A.

6. Internal inspection intervals for diesel fuel oil storage tanks may meet either Table XI.M42-1, or if the inspection results meet Inspection Category A, GALL-SLR Report AMP XI.M30, Fuel Oil Chemistry.

Where documentation exists that manufacturer recommendations and industry consensus documents (i.e., those recommended in RG 1.54, or earlier versions of those standards) were complied with during installation, the extent of piping inspections may be reduced to the lesser of twenty-five 1-foot axial length circumferential segments of piping or 20 percent of the total length of each coating/lining material and environment combination at each unit.

SLR-ISG-2021-02-MECHANICAL: Appendix H Page 6 of 21 For multiunit sites where the piping sample size is not based on the percentage of the population, it is acceptable to reduce the total number of inspections at the site as follows:

• For two-unit sites, fifty-five 1-foot axial length sections of piping (19 if manufacturer recommendations and industry consensus documents were complied with during installation) are inspected per unit.

• For a three-unit site, forty-nine 1-foot axial length sections of piping (17 if manufacturer recommendations and industry consensus documents were complied with during installation) are inspected per unit.

In order to conduct the reduced number of inspections, the applicant states in the subsequent license renewal application the basis for why the operating conditions at each unit are similar enough (e.g., flowrate, temperature, excursions) to provide representative inspection results.

The coating/lining environment includes both the environment inside (and outside when applicable) the component and the metal to which the coating/lining is attached.

Inspection locations are selected based on susceptibility to degradation and consequences of failure.

Coating/lining surfaces captured between interlocking surfaces (e.g., flange faces) are not required to be inspected unless the joint has been disassembled to allow access for an internal coating/lining inspection or other reasons. For areas not readily accessible for direct inspection, such as small pipelines, heat exchangers, and other equipment, consideration is given to the use of remote or robotic inspection tools.

Either of the following options [i.e., item (a) or (b)] is an acceptable alternative to the inspections recommended in this AMP for internal coatings when all of the following conditions exist:

• Loss of coating or lining integrity cannot result in downstream effects such as reduction in flow, drop in pressure, or reduction of heat transfer for in-scope components,

• The components only CLB intended function is leakage boundary (spatial) or structural integrity (attached) as defined in SRP-SLR Table 2.1-4(b),

• The internal environment does not contain chemical compounds that could cause accelerated corrosion of the base material if coating/lining degradation resulted in exposure of the base metal,

• The internal environment would not promote microbiologically influenced corrosion of the base metal,

• The coated/lined components are not located in the vicinity of uncoated components that could cause a galvanic couple to exist, and

• The design for the component did not credit the coating/lining (e.g., the corrosion allowance was not zero).

SLR-ISG-2021-02-MECHANICAL: Appendix H Page 7 of 21 (a) A representative sample of external wall thickness measurements can be performed every 10 years commencing 10 years prior to the subsequent period of extended operation to confirm the acceptability of the corrosion rate of the base metal. For heat exchangers and tanks, a representative sample includes 25 percent coverage of the accessible external surfaces.

For piping, a representative sample size is defined above.

(b) In lieu of external wall thickness measurements, use GALL-SLR Report AMP XI.M36, External Surfaces Monitoring of Mechanical Components, and GALL-SLR Report AMP XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, or other appropriate internal surfaces inspection program (e.g., GALL-SLR Report AMP XI.M20, AMP XI M21A) to manage loss of coating or lining integrity.

In addition, where loss of internal coating or lining integrity cannot result in downstream effects such as reduction in flow, drop in pressure, or reduction of heat transfer for in-scope components, a representative sample of external wall thickness measurements can be performed every 10 years commencing 10 years prior to the subsequent period of extended operation to confirm the acceptability of the corrosion rate of the base metal in lieu of visual inspections of the coatings/linings. For heat exchangers and tanks, a representative sample includes 25 percent coverage of the accessible external surfaces.

For piping, a representative sample size is described above.

The training and qualification of individuals involved in coating/lining inspections and evaluating degraded conditions is conducted in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with a particular standard, except for cementitious materials. For cementitious coatings/linings inspectors should have a minimum of 5 years of experience inspecting or testing concrete structures or cementitious coatings/linings or a degree in the civil/structural discipline and a minimum of 1 year of experience.

Opportunistic inspections, in lieu of periodic inspections, are an acceptable alternative for buried internally lined/coated fire water system piping provided the following are met:

(a) flow tests and internal piping inspections will occur at intervals specified in NFPA 25, or as modified by AMP XI.M27, Table XI.M27-1; (b) through-wall flaws in the piping can be detected through continuous system pressure monitoring; and (c) plant-specific OE is acceptable (i.e., no leaks due to age-related degradation of representative internal coatings/linings used in buried in-scope fire water system components). If exceptions are taken to Table XI.M27-1 related to flow tests or internal piping inspections, the exception should justify why the exceptions will not impact detecting potential internal loss of coating/lining integrity.

5. Monitoring and Trending: A preinspection review of the previous two inspections, when available (i.e., two sets of inspection results may not be available to review for the baseline and first subsequent inspection of a particular coating/lining location), is conducted that includes reviewing the results of inspections and any subsequent repair activities. A coatings specialist prepares the post-inspection report to include: a list and location of all areas evidencing deterioration, a prioritization of the repair areas into areas that must be repaired before returning the system to service and areas where repair can be postponed to the next refueling outage, and where possible, photographic documentation indexed to inspection locations.

SLR-ISG-2021-02-MECHANICAL: Appendix H Page 8 of 21 Where practical, (e.g., wall thickness measurements, blister size and frequency),

degradation is projected until the next scheduled inspection. Results are evaluated against acceptance criteria to confirm that the sampling bases (e.g., selection, size, frequency) will maintain the components intended functions throughout the subsequent period of extended operation based on the projected rate and extent of degradation.

6. Acceptance Criteria: Acceptance criteria are as follows:

a. There are no indications of peeling or delamination.

b. Blisters are evaluated by a coatings specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with use of a particular standard. Blisters should be limited to a few intact small blisters that are completely surrounded by sound coating/lining bonded to the substrate. Blister size or frequency should not be increasing between inspections (e.g., ASTM D714-02, Standard Test Method for Evaluating Degree of Blistering of Paints).

c. Indications such as cracking, flaking, and rusting are to be evaluated by a coatings specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with use of a particular standard.

d. Minor cracking and spalling of cementitious coatings/linings is acceptable provided there is no evidence that the coating/lining is debonding from the base material.

e. As applicable, wall thickness measurements, projected to the next inspection, meet design minimum wall requirements.

f. Adhesion testing results, when conducted, meet or exceed the degree of adhesion recommended in plant-specific design requirements specific to the coating/lining and substrate.

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 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.

Coatings/linings that do not meet acceptance criteria are repaired, replaced, or removed.

Physical testing is performed where physically possible (i.e., sufficient room to conduct testing) or examination is conducted to ensure that the extent of repaired or replaced coatings/linings encompasses sound coating/lining material.

As an alternative, internal coatings exhibiting indications of peeling and delamination may be returned to service if: (a) physical testing is conducted to ensure that the remaining coating is tightly bonded to the base metal; (b) the potential for further degradation of the coating is minimized, (i.e., any loose coating is removed, the edge of the remaining coating is feathered); (c) adhesion testing using ASTM International standards endorsed in RG 1.54 (e.g., pull-off testing, knife adhesion testing) is conducted at a minimum of

SLR-ISG-2021-02-MECHANICAL: Appendix H Page 9 of 21 3 sample points adjacent to the defective area; (d) an evaluation is conducted of the potential impact on the system, including degraded performance of downstream components due to flow blockage and loss of material or cracking of the coated component; and (e) follow-up visual inspections of the degraded coating are conducted within 2 years from detection of the degraded condition, with a reinspection within an additional 2 years, or until the degraded coating is repaired or replaced.

If coatings/linings are credited for corrosion prevention (e.g., corrosion allowance in design calculations is zero, the preventive actions program element of a SLRA AMP credited the coating/lining) and the base metal has been exposed or it is beneath a blister, the components base material in the vicinity of the degraded coating/lining is examined to determine if the minimum wall thickness is met and will be met until the next inspection.

When a blister does not meet acceptance criteria, and it is not repaired, physical testing is conducted to ensure that the blister is completely surrounded by sound coating/lining bonded to the surface. Physical testing consists of adhesion testing using ASTM International standards endorsed in RG 1.54. Where adhesion testing is not possible due to physical constraints, another means of determining that the remaining coating/lining is tightly bonded to the base metal is conducted such as lightly tapping the coating/lining.

Acceptance of a blister to remain inservice should be based both on the potential effects of flow blockage and degradation of the base material beneath the blister.

Additional inspections are conducted if one of the inspections does not meet acceptance criteria due to current or projected degradation (i.e., trending) unless the cause of the aging effect for each applicable material and environment is corrected by repair or replacement for all components constructed of the same material and exposed to the same environment. The number of increased inspections is determined in accordance with the sites corrective action process; however, there are no fewer than five additional inspections for each inspection that did not meet acceptance criteria, or 20 percent of each applicable material, environment, and aging effect combination is inspected, whichever is less. When inspections are based on the percentage of piping length, an additional 5 percent of the total length is inspected. The timing of the additional inspections is based on the severity of the degradation identified and is commensurate with the potential for loss of intended function. However, in all cases, the additional inspections are completed within the interval in which the original inspection was conducted, or if identified in the latter half of the current inspection interval, within the next refueling outage interval. These additional inspections conducted in the next inspection interval cannot also be credited towards the number of inspections in the latter interval. If subsequent inspections do not meet acceptance criteria, an extent of condition and extent of cause analysis is conducted to determine the further extent of inspections. Additional samples are inspected for any recurring degradation to provide reasonable assurance that corrective actions appropriately address the associated causes. At multi-unit sites, the additional inspections include inspections at all of the units with the same material, environment, and aging effect combination.

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 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.

SLR-ISG-2021-02-MECHANICAL: Appendix H Page 10 of 21

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: The inspection techniques and training of inspection personnel associated with this program are consistent with industry practice and have been demonstrated effective at detecting loss of coating or lining integrity. Not to exceed inspection intervals have been established that are dependent on the results of previous plant-specific inspection results. The following examples describe operating experience (OE) pertaining to loss of coating or lining integrity for coatings/linings installed on the internal surfaces of piping systems:

a. In 1982, a licensee experienced degradation of internal coatings in its spray pond piping system. This issue contains many key aspects related to coating degradation. These include installation details such as improper curing time, restricted availability of air flow leading to improper curing, installation layers that were too thick, and improper surface preparation (e.g., oils on surface, surface too smooth). The aging mechanisms included severe blistering, moisture entrapment between layers of the coating, delamination, peeling, and widespread rusting. The failure to install the coatings to manufacturer recommendations resulted in flow restrictions to the ultimate heat sink and blockage of an emergency diesel generator governor oil cooler. (Information Notice 85-24, Failures of Protective Coatings in Pipes and Heat Exchangers.)

b. During an U.S. Nuclear Regulatory Commission inspection, the staff found that coating degradation, which occurred as a result of weakening of the adhesive bond of the coating to the base metal due to turbulent flow, resulted in the coating eroding away and leaving the base metal subject to wall thinning and leakage.

[Agencywide Documents Access and Management System (ADAMS) Accession No. ML12045A544].

c. In 1994, a licensee replaced a portion of its cement lined steel service water piping with piping lined with polyvinyl chloride material. The manufacturer stated that the lining material had an expected life of 15-20 years. An inspection in 1997 showed some bubbles and delamination in the coating material at a flange. A 2002 inspection found some locations that had lack of adhesion to the base metal. In 2011, diminished flow was observed downstream of this line. Inspections revealed that a majority of the lining in one spool piece was loose or missing. The missing material had clogged a downstream orifice. A sample of the lining was sent to a testing lab where it was determined that cracking was evident on both the base metal and water side of the lining and there was a noticeable increase in the hardness of the in service sample as compared to an unused sample. (ADAMS Accession No. ML12041A054).

d. A licensee has experienced multiple instances of coating degradation resulting in coating debris found downstream in heat exchanger end bells. None of the debris had been large enough to result in reduced heat exchanger performance.

(ADAMS Accession No. ML12097A064).

SLR-ISG-2021-02-MECHANICAL: Appendix H Page 11 of 21

e. A licensee experienced continuing flow reduction over a 14 day period, resulting in the service water room cooler being declared inoperable. The flow reduction occurred due to the rubber coating on a butterfly valve becoming detached.

(ADAMS Accession No. ML073200779).

f. At an international plant, cavitation in the piping system damaged the coating of a piping system, which subsequently resulted in unanticipated corrosion through the pipe wall. (ADAMS Accession No. ML13063A135).

g. A licensee experienced degradation of the protective concrete lining which allowed brackish water to contact the unprotected carbon steel piping resulting in localized corrosion. The degradation of the concrete lining was likely caused by the high flow velocities and turbulence from the valve located just upstream of the degraded area. (ADAMS Accession No. ML072890132).

h. A licensee experienced through-wall corrosion when a localized area of coating degradation resulted in base metal corrosion. The cause of the coating degradation is thought to have been nonage related mechanical damage.

(ADAMS Accession No. ML14087A210).

i. A licensee experienced through-wall corrosion when a localized polymeric repair of a rubber lined spool failed. (ADAMS Accession No. ML14073A059).

j. A licensee experienced accelerated galvanic corrosion when loss of coating integrity occurred in the vicinity of carbon steel components attached to AL6XN components. (ADAMS Accession No. ML12297A333).

The program is informed and enhanced when necessary through the systematic and ongoing review of both plant-specific and industry OE 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.

10 CFR 54.4(a), Scope. Washington, DC: U.S. Nuclear Regulatory Commission. 2016.

ACI. ACI Standard 201.1R-08, Guide for Conducting a Visual Inspection of Concrete in Service.

Farmington Hills, Michigan: American Concrete Institute. 2008.

_____. ACI Standard 349.3R-02, Evaluation of Existing Nuclear Safety-Related Concrete Structures. Farmington Hills, Michigan: American Concrete Institute. 2002.

ASTM. ASTM 6677-07, Standard Test Method for Evaluating Adhesion by Knife.

West Conshohocken, Pennsylvania: ASTM International. 2013.

_____. ASTM D714-02, Standard Test Method for Evaluating Degree of Blistering of Paints.

West Conshohocken, Pennsylvania: ASTM International. 2009.

SLR-ISG-2021-02-MECHANICAL: Appendix H Page 12 of 21

_____. ASTM D4538-05, Standard Terminology Relating to Protective Coating and Lining Work for Power Generation Facilities. West Conshohocken, Pennsylvania: ASTM International. 2006.

_____. ASTM D4541-09, Standard Test Method for Pull-Off Strength of Coatings Using Portable Adhesion Testers. West Conshohocken, Pennsylvania: ASTM International. 2011.

_____. ASTM D7167-12, Standard Guide for Establishing Procedures to Monitor the Performance of Safety-Related Coating Service Level III Lining Systems in an Operating Nuclear Power Plant. West Conshohocken, Pennsylvania: ASTM International. 2012.

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

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

December 2009.

NRC. Information Notice 85-24, Failures of Protective Coatings in Pipes and Heat Exchangers.

Washington, DC: U.S. Nuclear Regulatory Commission. March 1985.

_____. 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.

SLR-ISG-2021-02-MECHANICAL: Appendix H Page 13 of 21 Revisions to FSAR Supplement Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging Management Programs GALL-SLR Implementation AMP Program Description of Program Schedule*

This program is a condition monitoring program that manages degradation of internal coatings/linings exposed to closed-cycle cooling water, raw water, treated water, treated borated water, waste water, lubricating oil, or fuel oil, air, or condensation, that can lead to loss of material of base materials or downstream effects such as reduction in flow, reduction in pressure or reduction of heat transfer when Program is coatings/linings become debris. This program can also be implemented and used to manage loss of coating integrity for external coatings inspections begin exposed to any air environment or condensation, soil, 10 years before concrete, or underground environment, that are credited with the subsequent isolating the external surface of a component from the period of environmentthese environments (e.g., as discussed in extended SRP-SLR Section 3.2.2.2.2).

operation.

This program manages these aging effects for internal Inspections that coatings by conducting periodic visual inspections of all are to be Internal coatings/linings applied to the internal surfaces of in-scope completed prior to Coatings/ components where loss of coating or lining integrity could the subsequent Linings for In- impact the components or downstream components current period of Scope Piping, licensing basis intended function(s). Visual inspections are extended XI.M42 Piping conducted on external surfaces when applicable.

operation are Components, completed Heat For tanks and heat exchangers, all accessible surfaces are Exchangers, inspected. Piping inspections are sampling-based. The 6 months prior to and Tanks training and qualification of individuals involved in the subsequent coating/lining inspections of non-cementitious coatings/linings period of are conducted in accordance with ASTM International extended Standards endorsed in RG 1.54 including guidance from the operation or no staff associated with a particular standard. For cementitious later than the last coatings, training and qualifications are based on an refueling outage appropriate combination of education and experience related prior to the to inspecting concrete surfaces. Peeling and delamination is subsequent not acceptable. Blisters are evaluated by a coatings period of specialist with the blisters being surrounded by sound extended material and with the size and frequency not increasing.

operation.

Minor cracks in cementitious coatings are acceptable provided there is no evidence of debonding. All other degraded conditions are evaluated by a coatings specialist.

For coated/lined surfaces determined to not meet the acceptance criteria, physical testing is performed where physically possible (i.e., sufficient room to conduct testing) in conjunction with repair or replacement of the coating/lining.

Revisions to GALL-SLR Report Tables V.A, V.B, V.D1, V.D2, VII.C1, VII.C3, VII.D, VII.E5, and VII.G SLR-ISG-2021-02-MECHANICAL: Appendix H The following tables provide changes to AMR items related to this ISG, with redline formatting indicating changes from the GALL-SLR Report.

V ENGINEERED SAFETY FEATURES Table A Containment Spray System (PWR)

New, Modified, SRP Deleted, Item Structure Aging Management Edited (Table, and/or Program Further Item Item ID) Component Material Environment Aging Effect/Mechanism (AMP)/TLAA Evaluation M V.A.E- 3.2-1, Piping, piping Any material Treated Loss of coating or lining AMP XI.M42, "Internal No 401 072 components, heat with an borated water, integrity due to blistering, Coatings/Linings for exchangers, tanks internal lubricating oil cracking, flaking, peeling, In-Scope Piping, with internal coating/lining delamination, rusting, Piping Components, coatings/linings physical damage; loss of Heat Exchangers, and material or cracking for Tanks" cementitious coatings/linings V ENGINEERED SAFETY FEATURES Table B Standby Gas Treatment System (BWR)

New, Modified, SRP Deleted, Item Structure Aging Management Edited (Table, and/or Program Further Item Item ID) Component Material Environment Aging Effect/Mechanism (AMP)/TLAA Evaluation M V.B.E- 3.2-1, Piping, piping Any material Treated water, Loss of coating or lining AMP XI.M42, "Internal No 401 072 components, heat with an raw water, integrity due to blistering, Coatings/Linings for exchangers, tanks internal lubricating oil cracking, flaking, peeling, In-Scope Piping, with internal coating/lining delamination, rusting, Piping Components, Page 14 of 21 coatings/linings physical damage; loss of Heat Exchangers, material or cracking for and Tanks" cementitious coatings/linings

V ENGINEERED SAFETY FEATURES SLR-ISG-2021-02-MECHANICAL: Appendix H Table D1 Emergency Core Cooling System (PWR)

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 V.D1.E-401 3.2-1, 072 Piping, piping Any material Treated Loss of coating or AMP XI.M42, "Internal No components, with an borated water, lining integrity due to Coatings/Linings for In-heat internal lubricating oil, blistering, cracking, Scope Piping, Piping exchangers, coating/lining condensation flaking, peeling, Components, Heat tanks with delamination, rusting, Exchangers, and internal physical damage; loss Tanks" coatings/linings of material or cracking for cementitious coatings/linings M V.D1.E-414 3.2-1, 073 Piping, piping Any material Treated Loss of material due AMP XI.M42, "Internal No components, with an borated water, to general, pitting, Coatings/Linings for In-heat internal lubricating oil, crevice corrosion, Scope Piping, Piping exchangers, coating/lining condensation MIC Components, Heat tanks with Exchangers, and internal Tanks" coatings/linings Page 15 of 21

V ENGINEERED SAFETY FEATURES SLR-ISG-2021-02-MECHANICAL: Appendix H Table D2 Emergency Core Cooling System (BWR)

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 V.D2.E-401 3.2-1, 072 Piping, piping Any material Treated water, Loss of coating or AMP XI.M42, No components, with an lubricating oil, lining integrity due to "Internal heat internal condensation blistering, cracking, Coatings/Linings exchangers, coating/lining flaking, peeling, for In-Scope tanks with delamination, rusting, Piping, Piping internal physical damage; Components, coatings/linings loss of material or Heat Exchangers, cracking for and Tanks" cementitious coatings/linings M V.D2.E-414 3.2-1, 073 Piping, piping Any material Treated water, Loss of material due AMP XI.M42, No components, with an lubricating oil, to general, pitting, "Internal heat internal condensation crevice corrosion, Coatings/Linings exchangers, coating/lining MIC for In-Scope tanks with Piping, Piping internal Components, coatings/linings Heat Exchangers, and Tanks" Page 16 of 21

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix H Table C1 Open-Cycle Cooling Water System (Service Water System)

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 VII.C1.A-400a 3.3-1, 127 Piping, piping Metallic Raw water Loss of material due AMP XI.M20, Yes components, to recurring internal "Open-Cycle tanks corrosion Cooling Water System" N VII.C1.A-400b 3.3-1, 127 Piping, piping Metallic Raw water Loss of material due AMP XI.M38, Yes components, to recurring internal Inspection of tanks (for corrosion Internal Surfaces components not in Miscellaneous covered by NRC Piping and GL 89-13) Ducting Components VII AUXILIARY SYSTEMS Table C3 Ultimate Heat Sink 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 VII.C3.A-400a 3.3-1, 127 Piping, piping Metallic Raw water Loss of material due AMP XI.M20, Yes components, to recurring internal "Open-Cycle tanks corrosion Cooling Water System" N VII.C3.A-400b 3.3-1, 127 Piping, piping Metallic Raw water Loss of material due AMP XI.M38, Yes components, to recurring internal Inspection of tanks (for corrosion Internal Surfaces components not in Miscellaneous covered by NRC Piping and Page 17 of 21 GL 89-13) Ducting Components

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix H Table D Compressed Air System 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 DN VII.D.A-414 3.3-1, 139 Piping, piping Any material Air-dry, air, Loss of material due AMP XI.M42, No components, with an condensation to general, pitting, "Internal heat internal crevice corrosion, Coatings/Linings exchangers, coating/lining MIC for In-Scope tanks with Piping, Piping internal Components, coatings/linings Heat Exchangers, and Tanks" DN VII.D.A-416 3.3-1, 138 Piping, piping Any material Air-dry, air, Loss of coating or AMP XI.M42, No components, with an condensation lining integrity due to "Internal heat internal blistering, cracking, Coatings/Linings exchangers, coating/lining flaking, peeling, for In-Scope tanks with delamination, Piping, Piping internal rusting, physical Components, coatings/linings damage; loss of Heat Exchangers, material or cracking and Tanks" for cementitious coatings/linings Page 18 of 21

VII AUXILIARY SYSTEMS SLR-ISG-2021-02-MECHANICAL: Appendix H Table E5 Waste Water Systems 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 VII.E5.A-400b 3.3-1, 127 Piping, piping Metallic Waste water Loss of material due AMP XI.M38, Yes components, to recurring internal "Inspection of tanks corrosion Internal Surfaces in Miscellaneous Piping and Ducting Components" VII AUXILIARY SYSTEMS Table G Fire Protection 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 VII.G.A-400c 3.3-1, 127 Piping, piping Metallic Raw water, Loss of material due AMP XI.M27, "Fire Yes components, raw water to recurring internal Water System" tanks (potable), corrosion treated water Page 19 of 21

Revisions to SRP-SLR Tables 3.2-1 and 3.3-1 SLR-ISG-2021-02-MECHANICAL: Appendix H The following tables provide changes to Table 1 items related to this ISG, with redline formatting indicating changes from the SRP-SLR.

Table 3.2-1 Summary of Aging Management Programs for Engineered Safety Features Evaluated in Chapter V of the GALL-SLR Report New, Modified, Aging Management Deleted, Program Further Evaluation GALL-SLR Edited Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended Item M 072 BWR/PWR Any material piping, Loss of coating or lining AMP XI.M42, No V.A.E-401 piping components, integrity due to blistering, "Internal V.B.E-401 heat exchangers, cracking, flaking, peeling, Coatings/Linings for V.C.E-401 tanks with internal delamination, rusting, or In-Scope Piping, V.D1.E-401 coatings/linings physical damage; loss of Piping Components, V.D2.E-401 exposed to closed- material or cracking for Heat Exchangers, cycle cooling water, cementitious and Tanks" raw water, treated coatings/linings water, treated borated water, lubricating oil, condensation M 073 BWR/PWR Any material piping, Loss of material due to AMP XI.M42, No V.A.E-414 piping components, general, pitting, crevice "Internal V.B.E-414 heat exchangers, corrosion, MIC Coatings/Linings for V.C.E-414 tanks with internal In-Scope Piping, V.D1.E-414 coatings/linings Piping Components, V.D2.E-414 exposed to closed- Heat Exchangers, cycle cooling water, and Tanks" raw water, treated water, treated borated water, lubricating oil, condensation Page 20 of 21

Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the SLR-ISG-2021-02-MECHANICAL: Appendix H GALL-SLR Report New, Modified, Deleted, Edited Aging Aging Management Further Evaluation GALL-SLR Item ID Type Component Effect/Mechanism Program (AMP)/TLAA Recommended Item M 127 BWR/PWR Metallic piping, piping Loss of material due to AMP XI.M20, "Open- Yes (SRP-SLR VII.C1.A-400a components, tanks recurring internal Cycle Cooling Water Section 3.3.2.2.7) VII.C1.A-400b exposed to closed- corrosion System," AMP XI.M27, VII.C3.A-400a cycle cooling water, "Fire Water System," or VII.C3.A-400b raw water, raw water AMP XI.M38, "Inspection VII.E5.A-400b (potable), treated of Internal Surfaces in VII.G.A-400c water, waste water Miscellaneous Piping and Ducting Components" M 138 BWR/PWR Any material piping, Loss of coating or AMP XI.M42, "Internal No VII.C1.A-416 piping components, lining integrity due to Coatings/Linings for In- VII.C2.A-416 heat exchangers, blistering, cracking, Scope Piping, Piping VII.C3.A-416 tanks with internal flaking, peeling, Components, Heat VII.D.A-416 coatings/linings delamination, rusting, Exchangers, and Tanks" VII.E4.A-416 exposed to closed- or physical damage; VII.E5.A-416 cycle cooling water, loss of material or VII.F1.A-416 raw water, raw water cracking for VII.F2.A-416 (potable), treated cementitious VII.F3.A-416 water, treated borated coatings/linings VII.F4.A-416 water, fuel oil, VII.G.A-416 lubricating oil, waste VII.H1.A-416 water, air-dry, air, VII.H2.A-416 condensation M 139 BWR/PWR Any material piping, Loss of material due to AMP XI.M42, "Internal No VII.C1.A-414 piping components, general, pitting, crevice Coatings/Linings for In- VII.C2.A-414 heat exchangers, corrosion, MIC Scope Piping, Piping VII.C3.A-414 tanks with internal Components, Heat VII.D.A-414 coatings/linings Exchangers, and Tanks" VII.E4.A-414 exposed to closed- VII.E5.A-414 cycle cooling water, VII.F1.A-414 raw water, raw water VII.F2.A-414 Page 21 of 21 (potable), treated VII.F3.A-414 water, treated borated VII.F4.A-414 water, fuel oil, VII.G.A-414 lubricating oil, waste VII.H1.A-414 water, air-dry, air, VII.H2.A-414 condensation

APPENDIX I 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, with comments presented in separate tables for the original draft Mechanical ISG and the errata letter. The two tables below provide 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 - Original Draft ISG SLR-ISG-2021-02-MECHANICAL: Appendix I Comment # ISG Section/Page Comment NRC Staff Response ISG-1 Appendix B AMP XI.M2 AMP XI.M2, Water Chemistry The correct EPRI Agreed and incorporated.

Page 1, 4, 8 of 10 document number for EPRI PWR Primary Water Chemistry Guidelines Rev 7, April 2014 is EPRI 3002000505. The following ISG sections for AMP XI.M2 require update of the EPRI document number: -Program Description (pg 1)-References (pg 4)-3.1.6 References (pg 8)

ISG-2 Appendix B, XI.M2, Proposed Revisions to Aging Management Agreed and incorporated.

Water Chemistry, Program XI.M2, Water Chemistry, incorrectly Page 1 of 10 state that the EPRI Secondary Water Chemistry Guidelines Rev 8 was published in 2014. EPRI Report 3002010645 Revision 8 was published in 2017.

ISG-3 Appendix E VII.G.A-806 Cementitious Coatings A new AMR Item A-806 for cementitious coatings (Pyrocrete, Page 1, 17, 77 BIO' K-10 Mortar, Cafecote, and other similar materials) used AMP XI.M26 manages cracking and loss of as fireproofing/fire barriers exposed to air was proposed materials for cementitious coatings. ISG because they are materials that are widely used throughout proposed aging effects are not consistent with industry and are likely to be cited in future subsequent license aging effects managed for cementitious renewal applications (SLRAs).

coatings identified in NUREG-2191 AMP XI.M42 element 3 and Peach Bottom SER The NRC staff notes that the components with cementitious (ML# 19317E013), Section 3.3.2.3.5. Based on coatings for which aging effects are managed by AMP XI.M42, the intended function, delamination and Internal Coatings/Linings for In-Scope Piping, Piping separation are aging mechanisms that Components, Heat Exchangers, and Tanks, in NUREG-2191, potentially result in a loss of material. Change Generic Aging Lessons Learned for Subsequent License in material properties is not an aging effect that Renewal (GALL-SLR) Report (Agencywide Documents Access results in a loss of intended function in and Management System (ADAMS) Accession Nos.

cementitious coatings. No reference is provided ML1787A031 and ML17187A204), have a different intended in the Basis for Revision section of the ISG for function and may be exposed to different environments than change in material properties of cementitious cementitious coatings used for fireproofing/fire barriers.

materials. Therefore, the aging effects/mechanisms may be different.

Page 2 of 10 AMR items related to fire barrier seals, fire stops, fire wraps and coatings, and radiant energy shields in Table 3.5.2-37, Containments, Structures and Component Supports -

Miscellaneous Structural Commodities - Aging Management Evaluation, of the Surry Power Station SLRA (ADAMS

Comment # ISG Section/Page Comment NRC Staff Response SLR-ISG-2021-02-MECHANICAL: Appendix I Accession No. ML18291A828), included loss of material, change in material properties, cracking/delamination, and separation as applicable aging effects for certain cementitious coatings, subliming compounds, and silicates. These aging effects are consistent with Section 6, Fire Barriers, of EPRI 3002013084, Long-Term Operations: Subsequent License Renewal Aging Affects for Structures and Structural Components (Structural Tools), issued November 2018, that cites loss of material, cracking/delamination, change in material properties, and separation as aging effects that potentially result in the loss of intended function of fire barriers.

Table 6-3, Structural Tools Comparison with GALL-SLR-Fire Barriers, in Section 6 of EPRI 3002013084 provides applicability criteria for aging effects/mechanisms for fire barrier materials. Table 6-3 notes that change in material properties due to gamma irradiation exposure is applicable for cementitious fireproofing when exposures exceed 1 x 106 rads. A plant-specific determination would need to be made on whether cementitious coatings used as fireproofing/fire barriers would be exposed to greater than 1 x 106 rads. Therefore, the NRC staff disagrees with the comment to remove change in material properties as an aging effect for cementitious coatings used as fireproofing/fire barriers. However, consistent with EPRI 3002013084, the staff updated AMR item A-806 for cementitious coatings to include the aging mechanism of gamma irradiation exposure that potentially results in a change of material properties.

Table 5-3, Structural Tools Comparison with GALL-SLR-Structural Concrete Members, in Section 5, Structural Concrete Members, of EPRI 3002013084 provides applicability criteria for aging effects/mechanisms for concrete structures and concrete components. Table 5-3 notes that change in material properties due to elevated temperature is applicable for concrete structures and concrete components when the general area temperature exceeds 150°F (65.6°C) or when the local area temperature exceeds 200°F (93.3°C). Therefore, Page 3 of 10 applicants need to make a plant-specific determination of whether concrete structures and concrete components are exposed to temperatures exceeding these values. This is consistent with further evaluations related to concrete exposed to elevated temperatures recommended in Section 3.5, Aging

Comment # ISG Section/Page Comment NRC Staff Response SLR-ISG-2021-02-MECHANICAL: Appendix I Management of Containments, Structures, and Component Supports, of NUREG-2192, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants, issued July 2017 (ADAMS Accession No. ML17188A158). Table 5-3 of EPRI 3002013084 also notes that temperatures exceeding these values potentially result in loss of material and cracking of concrete structures and concrete components. Therefore, consistent with EPR 3002013084, the staff updated AMR item A-806 for cementitious coatings to include change in material properties, cracking, and loss of material due to elevated temperature.

The NRC staff does not agree with citing delamination and separation as aging mechanisms that potentially result in a loss of material. The Surry Power Station SLRA and EPRI 3002013084 cite delamination and separation as aging effects, not aging mechanisms. Specifically, the Surry Power Station SLRA and EPRI 3002013084 cite cracking/delamination as an aging effect. Therefore, the staff updated AMR item A-806 for cementitious coatings to cite cracking/delamination as an aging effect. EPRI 3002013084 describes separation as an aging effect in which the adhesion between fire barrier materials and adjacent surfaces is degraded which could allow communication between different fire zones.

Therefore, the staff did not remove separation as an aging effect for cementitious coatings used as fireproofing/fire barriers.

The NRC staff agrees that, if available, the aging mechanisms that potentially result in the aging effects should be included for completeness and to be consistent with other AMR items in NUREG-2191. Therefore, the staff updated AMR item A-806 for cementitious coatings used for fireproofing/fire barriers to include available aging mechanisms cited in EPRI 3002013084, and those cited by industry as part of SLRA lessons learned activities and public comments on the draft AMR item.

For the above reasons, the staff revised the aging effects/mechanisms for AMR Item A-806 to read as follows:

Page 4 of 10 Loss of material due to abrasion, exfoliation, elevated temperature, flaking, spalling; cracking/delamination due to chemical reaction, elevated temperature, settlement, vibration; change in material properties due to elevated temperature, gamma irradiation exposure; separation.

Comment # ISG Section/Page Comment NRC Staff Response SLR-ISG-2021-02-MECHANICAL: Appendix I ISG-4 Appendix E VII.G.A-805 Subliming Compounds A new AMR Item A-805 for subliming compounds (Thermo-Page 1, 16 and 77 lag, Darmatt', 3M' Interam', and other similar materials)

Subliming compounds are fire-resistant coating used as fireproofing/fire barriers exposed to air was proposed materials. Based on the fire proofing because they are materials that are widely used throughout application, loss of material and cracking are industry and are likely to be cited in future SLRAs.

the appropriate aging effects to be managed by the Fire Protection program based upon the AMR items related to fire barrier seals, fire stops, fire wraps and intended function of enclosing the material to coatings, and radiant energy shields in Table 3.5.2-37, be protected. Based on the intended function, Containments, Structures and Component Supports -

delamination and separation are aging Miscellaneous Structural Commodities - Aging Management mechanisms that potentially result in a loss of Evaluation, of the Surry Power Station SLRA (ADAMS material. Change in material properties is not Accession No. ML18291A828) included loss of material, change an aging effect that results in a loss of intended in material properties, cracking/delamination, and separation as function in subliming compounds. No reference applicable aging effects for certain cementitious coatings, is provided in the Basis for Revision section of subliming compounds, and silicates. These aging effects are the ISG for change in material properties of consistent with Section 6, Fire Barriers, of EPRI 3002013084, subliming materials. Long-Term Operations: Subsequent License Renewal Aging Affects for Structures and Structural Components (Structural Tools), issued November 2018, that cites loss of material, cracking/delamination, change in material properties, and separation as aging effects that potentially result in the loss of intended function of fire barriers.

Table 6-3, Structural Tools Comparison with GALL-SLR-Fire Barriers, in Section 6 of EPRI 3002013084 provides applicability criteria for aging effects/mechanisms for fire barrier materials. Table 6-3 notes that change in material properties due to gamma irradiation exposure is applicable for rigid fire boards (subliming compounds) when exposures exceed 1 x 106 rads. A plant-specific determination would need to be made on whether subliming compounds used as fireproofing/fire barriers would be exposed to greater than 1 x 106 rads. Therefore, the NRC staff disagrees with the comment to remove change in material properties as an aging effect for subliming compounds used as fireproofing/fire barriers. However, consistent with EPRI 3002013084, the staff updated AMR item A-805 for subliming compounds to include the aging mechanism of Page 5 of 10 gamma irradiation exposure that potentially results in a change of material properties.

The NRC staff does not agree with citing delamination and separation as aging mechanisms that potentially result in a loss of material. The Surry Power Station SLRA and

Comment # ISG Section/Page Comment NRC Staff Response SLR-ISG-2021-02-MECHANICAL: Appendix I EPRI 3002013084 cite delamination and separation as aging effects, not aging mechanisms. Specifically, the Surry Power Station SLRA and EPRI 3002013084 cite cracking/delamination as an aging effect. Therefore, the staff updated AMR item A-805 for subliming compounds to cite cracking/delamination as an aging effect. EPRI 3002013084 describes separation as an aging effect where the adhesion between fire barrier materials and adjacent surfaces is degraded which could allow communication between different fire zones.

Therefore, the staff did not remove separation as an aging effect for subliming compounds used as fireproofing/fire barriers.

The NRC staff agrees that, if available, the aging mechanisms that potentially result in the aging effects should be included for completeness and to be consistent with other AMR items in NUREG-2191, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report (ADAMS Accession Nos. ML1787A031 and ML17187A204). Therefore, the staff updated AMR item A-805 for subliming compounds used for fireproofing/fire barriers to include available aging mechanisms cited in EPRI 3002013084, and those cited by industry as part of SLRA lessons learned activities and their public comments on the draft AMR item.

For the above reasons, the staff revised the aging effects/mechanisms for AMR Item A-805 to read:

Loss of material due to abrasion, flaking, vibration; cracking/delamination due to chemical reaction, settlement; change in material properties due to gamma irradiation exposure; separation.

ISG-5 Appendix E, VII.G.A-807 Silicates A new AMR Item A-807 for silicates (Marinite, Kaowool',

Page 1, 17and 77 Cerafiber, Cera blanket, or other similar materials) used as Silicates are fire-resistant insulation or barrier fireproofing/fire barriers exposed to air was proposed because materials. Based on the fire proofing they are materials that are widely used throughout industry and application, loss of material and cracking are are likely to be cited in future subsequent license renewal the appropriate aging effects to be managed by applications (SLRAs).

Page 6 of 10 the Fire Protection program based upon the intended function of enclosing or acting as a AMR items related to fire barrier seals, fire stops, fire wraps and barrier for the material to be protected. Based coatings, and radiant energy shields in Table 3.5.2-37, on the intended function, delamination or Containments, Structures and Component Supports -

separation are aging mechanisms that Miscellaneous Structural Commodities - Aging Management potentially result in a loss of material. Change Evaluation, of the Surry Power Station SLRA (ADAMS

Comment # ISG Section/Page Comment NRC Staff Response SLR-ISG-2021-02-MECHANICAL: Appendix I in material properties is not an aging effect that Accession No. ML18291A828) included loss of material, change results in a loss of intended function in silicates. in material properties, cracking/delamination, and separation as applicable aging effects for certain cementitious coatings, No reference is provided in the Basis for subliming compounds, and silicates. These aging effects are Revision section of the ISG for change in consistent with Section 6, Fire Barriers, of EPRI 3002013084, material properties of silicates Long-Term Operations: Subsequent License Renewal Aging Affects for Structures and Structural Components (Structural Tools), November 2018, that cites loss of material, cracking/delamination, change in material properties, and separation as aging effects that potentially result in the loss of intended function of fire barriers.

Table 6-3, Structural Tools Comparison with GALL-SLR-Fire Barriers, in Section 6 of EPRI 3002013084 provides applicability criteria for aging effects/mechanisms for fire barrier materials. Table 6-3 notes that change in material properties due to gamma irradiation exposure is applicable for fibrous fire wraps (silicates) when exposures exceed 1 x 106 rads. A plant-specific determination would need to be made on whether silicates used as fireproofing/fire barriers would be exposed to greater than 1 x 106 rads. Therefore, the NRC staff disagrees with the comment to remove change in material properties as an aging effect for silicates used as fireproofing/fire barriers.

However, consistent with EPRI 3002013084, the staff updated AMR item A-807 for silicates to include the aging mechanism of gamma irradiation exposure that potentially results in a change of material properties.

The NRC staff does not agree with citing delamination and separation as aging mechanisms that potentially result in a loss of material. The Surry Power Station SLRA and EPRI 3002013084 cite delamination and separation as aging effects, not aging mechanisms. Specifically, the Surry Power Station SLRA and EPRI 3002013084 cite cracking/delamination as an aging effect. Therefore, the staff updated AMR item A-807 for silicates to cite cracking/delamination as an aging effect. EPRI 3002013084 describes separation as an aging effect in which the adhesion Page 7 of 10 between fire barrier materials and adjacent surfaces is degraded which could allow communication between different fire zones.

Therefore, the staff did not remove separation as an aging effect for silicates used as fireproofing/fire barriers.

Comment # ISG Section/Page Comment NRC Staff Response SLR-ISG-2021-02-MECHANICAL: Appendix I The NRC staff agrees that, if available, the aging mechanisms that potentially result in the aging effects should be included for completeness and to be consistent with other AMR items in NUREG-2191, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report (ADAMS Accession Nos. ML1787A031 and ML17187A204). Therefore, the staff updated AMR item A-807 for silicates used for fireproofing/fire barriers to include available aging mechanisms cited in EPRI 3002013084, and those cited by industry as part of SLRA lessons learned activities and their public comments on the draft AMR item.

For the above reasons, the staff revised the aging effects/mechanisms for AMR Item A-807 to read as follows:

Loss of material due to abrasion, flaking; cracking/delamination due to settlement; change in material properties due to gamma irradiation exposure; separation.

ISG-6 Appendix E Page 76 and NUREG-2192 Table 3.3-1 item 265 & 266 Agreed and incorporated. The staff notes that the applicable Appendix F, NUREG-2191 VII.H2.A-790 and VII.H2.A-800: AMR items are VII.H2.A-799 (instead of VII.H2.A-790 as listed in Page 12 Dont limit the component type to radiator the NEI comment letter) and VII.H2.A-800.

tubes. Recommend using a component type of heat exchanger tubes.

ISG-7 Appendix H AMP XI.M42 Internal Coatings: The staff does not agree with this comment. The operating Page 7 of 12 experience condition relates specifically to leaks attributed to the Delete item (c) in the last paragraph of AMP age-related degradation of representative internal element 4 that permits opportunistic inspections coatings/linings used in buried in-scope fire water system of internally coated fire water system piping if components (i.e., not no leaks due to aging). Leaks due to plant-specific OE is acceptable (i.e., no leaks external corrosion or leakage at mechanical joints would not due to aging). This sets an unreasonable preclude the use of this alternative approach. If leaks have standard that is not consistent with plant CLB been attributed to the age related degradation of representative

[current licensing basis] and License Renewal internal coatings/linings used in buried in-scope fire water guidance. One age related leak allowed by the system components, opportunistic inspections of these CLB anytime during plant lifetime that was coatings/linings would not be appropriate during the subsequent corrected with no recurrence at a dual unit site period of extended operation (SPEO), unless a technical basis is (fire water is typically a common system) could Page 8 of 10 provided to explain why similar degradation would not be be considered unacceptable OE for both units. expected during the SPEO.

This is also inconsistent with NUREG-2191/2192 guidance on the use of The use of operating experience as one of the criteria for operating experience that permits corrective allowing opportunistic inspections is neither inconsistent with actions to prevent recurrence and augmenting plant CLB nor license renewal guidance. Overall fire water

Comment # ISG Section/Page Comment NRC Staff Response SLR-ISG-2021-02-MECHANICAL: Appendix I AMPs beyond GALL-SLR to effectively manage system leakage, as allowed by a plants current licensing basis, aging. is not germane to this issue, only leakage due to age-related degradation of internal coatings/linings. Leakage that is allowed by a plants CLB may detrimentally affect aging of passive components. License renewal guidance in many further evaluation sections (e.g., 3.3.2.2.3, 3.3.2.2.4, 3.3.2.2.7, 3.3.2.2.9, 3.3.2.2.10) include discussions where operating experience reviews establish the need for additional aging management activities. The issue for the Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks program only pertains to the allowance of opportunistic inspections in lieu of periodic inspections.

ISG-8 Appendix H AMP XI.M42 Internal Coatings: The staff does not agree with this comment. The operating Page 1 of 12, Basis for experience discussion in the Basis for Revision section Revision Section Delete Operating Experience discussion in the provides the rationale for the addition of the operating Basis for Revision Section. It implies that OE experience condition (i.e., condition (c)) in the Summary of associated with different materials, Proposed Revisions section. Condition (c) specifically environments and aging effects (buried addresses age-related degradation of representative internal externally fire water piping vs Internally coated coatings/linings used in buried in-scope fire water system fire water piping with different coatings) could components. Operating experience related to different be used to demonstrate OE is unacceptable. materials, environments, or aging effects (e.g., leaks due to the age-related degradation of external coatings used in buried in-scope fire water system piping, leaks due to the age-related degradation of non-representative internal coatings/linings) would not preclude the use of this alternative approach.

ISG-9 TBD (missing AMRs) The following AMRs were discussed with the The staff issued an errata letter dated July 24, 2020 (ADAMS Industry during prior ISG meetings are missing Accession No. ML20198M382), which is integrated into this final from the Draft Mechanical ISG: ISG. Comments regarding the errata letter are discussed below in this table.

-Loss of coating integrity in compressed air steel tanks (#2)

-LOM in compressed air steel tanks (#3)

-LOM/etc. in Zn in condensation environment

(#4)

Page 9 of 10

-LOM/etc. in carbon steel, SS, and copper alloy intreated water (#12)

-Use of XI.M20 or XI.M38 for AMR items VII.C1.A-400 & VII.C3.A-400 (#16)

Disposition of Public Comments - Draft ISG Errata SLR-ISG-2021-02-MECHANICAL: Appendix I Comment # ISG Section/Page Comment NRC Staff Response Errata-1 Mechanical ISG, Changes to add NUREG-2191 Chapter VII AMR lines The staff does not agree with the industrys proposed Appendix H, for stainless steel in a treated water environment were resolution. As discussed during public lessons learned pages 5 to 15 of 15, discussed during the lessons learned meetings but not meetings, the use of cross-chapter annotations has never Revised AMRs provided in the ISGs. Revise existing AMR lines to caused an issue with the NRC staff reviews of past Table VII.E1 provide PWR stainless steel in a treated water license renewal applications.

environment AMR lines in NUREG-2191 Chapter VII consistent with those in NUREG-2191 Chapter VIII. The NRC staff notes that previous LRAs and SLRAs used (See Comment 1 details on the next page). a number of cross-chapter AMR items, many with and some without cross-chapter annotations, which did not complicate the staffs review. The need for applicants to provide cross-chapter annotations in SLRA Table 1s is not clear.

Errata-2 Mechanical ISG, As discussed in the GALL Lesson learned meeting, a See the NRC staff response discussion above for industry Appendix H, NUREG-2191 Chapter VII AMR line and an associated comment 1 related to Draft ISG Errata.

pages 5 to 15 of 15, NUREG-2192 Table 1 line are requested for carbon Revised AMRs steel in a treated water environment consistent with Table VII.E1 NUREG-2192 Table 3.4-1 item 14.

Errata-3 Mechanical ISG, On NUREG-2192 Table 3.3-1 item 138 and item 139, Agreed and incorporated.

Appendix H, add air-dry, air, and condensation environments in the page 15 of 15 component column to be consistent with the proposed changes for AMR lines VII.D.A-416 and VII.V.A-414.

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