ML23110A210

From kanterella
Jump to navigation Jump to search
9 to Updated Final Safety Analysis Report, Appendix R.5, Second License Renewal Commitment List, Pages R-90 to R-124
ML23110A210
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 04/10/2023
From:
Constellation Energy Generation
To:
Office of Nuclear Reactor Regulation
Shared Package
ML23110A266 List: ... further results
References
Download: ML23110A210 (1)
v • d • e


Text

PBAPS UFSAR R.5.0 SECOND LICENSE RENEWAL COMMITMENT LIST PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

1 ASME Section XI Existing program is credited. Ongoing Section R.2.1.1 Inservice Inspection, Subsections IWB, IWC, and IWD 2 Water Chemistry Existing program is credited. Ongoing Section R.2.1.2 3 Reactor Head Existing program is credited. Ongoing Section R.2.1.3 Closure Stud Bolting 4 BWR Vessel ID Existing program is credited. Ongoing Section R.2.1.4 Attachment Welds 5 BWR Stress Existing program is credited. Ongoing Section R.2.1.5 Corrosion Cracking 6 BWR Penetrations Existing program is credited. Ongoing Section R.2.1.6 7 BWR Vessel BWR Vessel Internals is an existing program that will be enhanced to: Program will be Section R.2.1.7 Internals 1. No longer applicable due to regulatory changes by revision of BWRVIP-25 enhanced in accordance Exelon Letter Rev 1-A and as analyzed in Engineering Change 635331, TECHNICAL with the schedule described within the PBAPS SLRA EVALUATION TO JUSTIFY CORE PLATE BOLT INSPECTION Supplement ELIMINATION AT PEACH BOTTOM.In accordance with BWRVIP-25, commitments. Initial steam dryer inspections No. 9, dated Revision 1, install core plate wedges, or inspect core plate rim hold-down October 9, 2019 bolts for stress corrosion cracking, or demonstrate via analysis that the will be completed no later installation of wedges and inspections of the core plate rim hold-down than six months prior to bolts are not required, no later than six months prior to the second period the second period of of extended operation, or before the end of the last refueling outage prior extended operation, or to the second period of extended operation, whichever occurs later. no later than the last refueling outage prior to

2. Perform a VT-3 inspection of the jet pump inlet mixer and beam regions the second period of every refuel cycle after a fluence value of 1.3E+20 n/cm2 (51 EFPY for extended operation.

Appendix R R-90 Rev. 29, APRIL 2023

  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

Unit 2 and 63 EFPY for Unit 3) is reached at the jet pump holddown beam.

3. Perform periodic visual inspections of the PBAPS Westinghouse (Nordic style) stainless steel steam dryers for the aging effects of loss of material and cracking at a frequency not exceeding 10 years, with the first inspections performed prior to the second period of extended operation, as described below.

The inspection guidance contained in BWRVIP-139-A does not address the Westinghouse (Nordic style) steam dryers installed in PBAPS Unit 2 and Unit 3 and therefore is not directly applicable. However, the general principles and conclusions from BWRVIP-139-A, "BWR Vessel and Internals Project: Steam Dryer Inspection and Flaw Evaluation Guidelines", BWRVIP-181-R1-A, "BWR Vessel and Internals Project:

Steam Dryer Repair Design Criteria", and Regulatory Guide 1.20, "Comprehensive Vibration Assessment Program for Reactor Internals During Preoperational and Initial Startup Testing" were applied to the inspection plan described in WCAP-17635-P, "Peach Bottom Atomic Power Station Unit 2 and Unit 3 Replacement Steam Dryer Comprehensive Vibration Assessment Program (CVAP)". WCAP-17635-P also includes manufacturer's recommendations based on relevant operating experience. The scope of the inspection will include the items listed in Table 1 below.

The steam dryer inspections are based on the BWRVIP-139-A and WCAP-17635-P guidelines to identify loss of material (wear) and cracking using appropriate visual examination techniques (e.g., VT-1, VT-3) and qualified inspectors. The examination procedures identify the type and location of examination required for each dryer component as well as the reason for inspection. Acceptance criteria are consistent with BWRVIP-139-A and are described in procedures and work instructions. Flaws and abnormal indications identified will be entered into the corrective action program for engineering evaluation. The evaluations will consider increasing inspection frequency and scope as appropriate. Identified degradation left in the as found condition will be reinspected as required by the engineering evaluation.

Appendix R R-91 Rev. 29, APRIL 2023

  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

The repair design criteria contained in BWRVIP-181-R1-A and BWRVIP-139-A will be used for any future repairs of the steam dryers. Repairs to the steam dryer will be inspected as specified in the repair design package.

Table 1 Steam Dryer Inspection Program for the Second Period of Extended Operation in accordance with WCAP-17635-P Inspection Location Basis for Selection

1. Overall General Industry Operating Experience (BWRVIP-Inspection of Outside of the 139-A, Section 1.1, Section 2.4.2)

Replacement Steam Dryer General Inspection for evidence of damage (to include outside of skirt)

2. Lifting Rods Top Ends Surfaces in contact during operation (Unit 3 only) RG 1.20 Sec 2.3 (1)(b,d)
3. Hold Down Rods Surfaces in contact during operation Top Ends (Unit 2 only) RG 1.20 Sec 2.3 (1)(b,d)
4. Support Ring Bottom RG 1.20 Sec 2.3 (1)(b,d) Surfaces in contact Surface during operation
5. Outer hood (welds Industry Operating Experience (BWRVIP-on outer surface) 139-A, Section 1.1, Section 2.4.2)

Higher stressed area identified in analysis (RG 1.20 Sec 2.3 (1)(e))

Inspection for evidence of IGSCC (weld not solution annealed)

Appendix R R-92 Rev. 29, APRIL 2023

  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

6. Outer Ring Top Cage Higher stressed area identified in analysis (RG 1.20 Sec 2.3 (1)(e))

Inspection for evidence of IGSCC (weld not solution annealed)

7. Weld attachments Industry Operating Experience (BWRVIP-139-between the brackets to the A, Section 2.4.8) lifting rod and hold down Higher stressed area identified in rod and weld attachments analysis (RG 1.20 Sec 2.3 (1)(e))

between the brackets to top Inspection for evidence of IGSCC (weld not plate (lifting rod, Unit 3 only) solution annealed) 8 Thermal Aging Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) aging Program will be Section R.2.1.8 Embrittlement of management program is a new condition monitoring program that will provide implemented no later Cast Austenitic assurance that reactor coolant pressure boundary CASS components (i.e., Class 1 than six months prior to Stainless Steel piping and pump casings) with the potential for significant thermal aging the second period of (CASS) embrittlement meet their intended functions. extended operation.

9 Flow-Accelerated Flow-Accelerated Corrosion is an existing program that will be enhanced to: Program will be Section R.2.1.9 Corrosion 1. Reassess infrequently used piping systems excluded from the scope of enhanced no later than the program to ensure adequate bases exist to justify this exclusion for the six months prior to the second period of extended operation. second period of extended operation.

10 Bolting Integrity Bolting Integrity is an existing program that will be enhanced to: Program will be Section R.2.1.10

1. Ensure that submerged carbon steel closure bolts on the ESW, HPSW, enhanced no later than and fire protection pumps are inspected for loss of material and to confirm six months prior to the second period of Exelon Letter that the closure bolting is hand tight. A minimum of 19 bolt inspections shall be performed each 10-year period during the second period of extended operation. PBAPS SLRA extended operation for each unit. Inspection of closure bolting on these Supplement pumps during pump overhaul and replacement activities may be credited No. 2, dated during each 10-year period in the second period of extended operation. January 23, 2019
2. Ensure that submerged stainless steel mechanical bolts on the 2AS008, 2BS008, 3AS008, and 3BS008 Circulating Water Pump Structure intake Appendix R R-93 Rev. 29, APRIL 2023
  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

traveling screens are inspected for loss of material and to confirm that the mechanical bolting is hand tight. A minimum of 19 bolt inspections shall be performed each 10-year period during the second period of extended operation for each unit. Inspection of mechanical bolting on these screens during overhaul and replacement activities may be credited during each 10-year period in the second period of extended operation.

3. Ensure that closure bolts on pressure-retaining components that contain air or gas are inspected for cracking and loss of material for the carbon steel/ air-indoor uncontrolled and the stainless steel/ air-indoor uncontrolled material and environment combinations. In addition, the inspections will confirm that this closure bolting is leak tight applying inspection techniques, such as soap bubble testing, thermography, acoustic testing, or verifying closure bolting is hand tight. A minimum of 19 bolt inspections shall be performed each 10-year period during the second period of extended operation for each unit. Opportunistic inspections during maintenance activities may be credited during the same 10-year period.
4. Ensure that closure bolts on pressure-retaining components that contain air or gas are inspected for loss of material for the carbon steel/

air-outdoor material and environment combination. In addition, the inspections will confirm that this closure bolting is leak tight applying inspection techniques, such as soap bubble testing, thermography, acoustic testing, or verifying closure bolting is hand tight. A minimum of 25 bolt inspections shall be performed each 10-year period during the second period of extended operation for both Units 2 and 3. Opportunistic inspections during maintenance activities may be credited during the same 10-year period.

5. Revise site walkdown procedures to specify proper lighting and appropriate distances to adequately identify visible component leakage, evidence of past leakage, or other age-related degradation on pressure-retaining bolted joints that contain fluids such as water, oil, or steam. Cameras and video equipment may be used to supplement these inspections.

Appendix R R-94 Rev. 29, APRIL 2023

  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

6. Revise existing repetitive tasks to provide guidance for proper lighting and appropriate inspection distances to adequately identify loss of material in submerged environments. Cameras and video equipment may be used to supplement these inspections.
7. Ensure no fewer than five additional bolts are inspected for each sample based inspection that does not meet acceptance criteria, or 20 percent of the total bolt population of each applicable material, environment, and aging effect combination; whichever is less. If these subsequent inspections do not meet acceptance criteria, an extent of condition and extent of cause analysis are performed to determine the further extent of inspections. These additional inspections will be completed within the inspection interval for which the original sample based inspections are conducted.
8. Revise engineering procedures to require volumetric examination in accordance with ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1, regardless of the code classification of the bolting, should high strength bolting greater than 2 inches in diameter be installed.
9. Clarify that the recommended guidance for proper selection of bolting material and lubricants, and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting is a requirement at Peach Bottom in accordance with the guidelines provided in EPRI NP-5067 and TR-104213. Clarify that the recommended requirements for storage, lubricant selection, and bolting and coating material selection to include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication Specification for Structural Joints Using High Strength Bolts, are a requirement at Peach Bottom.

Appendix R R-95 Rev. 29, APRIL 2023

  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

11 Open-Cycle Cooling Open-Cycle Cooling Water System is an existing program that will be enhanced to: Program will be Section R.2.1.11 Water System 1. Provide procedural direction to perform additional inspections if the cause enhanced no later than of the aging effect for each applicable material and environment six months prior to the second period of Exelon Letter combination is not corrected by repair or replacement for all components constructed of the same material and exposed to the same environment. extended operation. PBAPS SLRA These additional inspections will be conducted if any of the inspections do RAI Response, not meet acceptance criteria. No fewer than five additional inspections dated May 2, will be performed for each inspection that does not meet acceptance 2019 criteria, or 20 percent of each applicable material, environment, and aging effect combination, whichever is less.

2. Perform a minimum of 20 inspections for recurring internal corrosion in the raw water cooling water systems every 24 months until the rate of recurring internal corrosion occurrences no longer meets the criteria for recurring internal corrosion as defined in SLRA Section 3.3.2.2.7. The selected inspection locations will be periodically reviewed to validate their relevance and usefulness and adjusted as appropriate. Evaluation of the inspection results will include (1) a comparison to the nominal wall thickness or previous wall thickness measurements to determine rate of corrosion degradation; (2) a comparison to the design minimum allowable wall thickness to determine the acceptability of the component for continued use; and (3) a determination of reinspection interval.
3. Provide procedural direction to require the use of a mill tolerance of 12.5% for added conservatism when determining corrosion rates at new inspection locations if corrosion rates from other locations with nearly identical operating conditions, material, size, and configuration cannot be used.

12 Closed Treated Closed Treated Water Systems is an existing program that will be enhanced to: Program will be Section R.2.1.12 Water Systems 1. Perform condition monitoring including opportunistic visual inspections enhanced no later than and sample-based periodic inspections using techniques (visual, surface, six months prior to the or volumetric) capable of detecting loss of material, cracking, and fouling, second period of as appropriate to verify the effectiveness of water chemistry control to extended operation.

mitigate aging effects in each 10-year period during the second period of extended operation. The rate of identified degradation will be projected Appendix R R-96 Rev. 29, APRIL 2023

  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

until the next scheduled inspection. Additional sample-based inspections will be performed if aging effects are identified. If those inspections identify aging effects, the corrective action program will be used to determine the extent of condition and extent of cause to determine the further extent of inspections.

13 Inspection of Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Program will be Section R.2.1.13 Overhead Heavy Handling Systems is an existing program that will be enhanced to: enhanced no later than Load and Light Load 1. Provide additional guidance to include inspection of crane-related bridges, six months prior to the (Related to structural members, and structural components for deformation, cracking, second period of Refueling) Handling and loss of material due to corrosion or wear; and associated bolted extended operation.

Systems connections for loss of material, cracking, and indications of loss of preload.

2. Provide procedural direction to document deficiencies identified during inspection activities within the corrective action program.
3. Provide site-specific procedural direction to evaluate and repair visual indication of loss of material, deformation, or cracking, and any visual sign of loss of bolting preload in accordance with ASME B30.2 or other applicable industry standard in the ASME B30 series.

14 Compressed Air Compressed Air Monitoring is an existing program that will be enhanced to: Program will be Section R.2.1.14 Monitoring 1. Perform daily inspection of instrument nitrogen after dryer desiccant for enhanced no later than signs of moisture. Results will be recorded and reviewed to determine if six months prior to the corrective actions are required. second period of extended operation.

2. Perform opportunistic visual inspections of component internal surfaces exposed to a dry air environment for signs of loss of material due to corrosion.

15 BWR Reactor Water Existing program is credited. Ongoing Section R.2.1.15 Cleanup System Appendix R R-97 Rev. 29, APRIL 2023

  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

16 Fire Protection Fire Protection is an existing program that will be enhanced to: Program will be Section R.2.1.16

1. Perform periodic visual inspection every 18 36 months for identification of enhanced no later than corrosion that may lead to loss of material on the external surfaces of the six months prior to the low pressure carbon dioxide fire suppression systems. second period of extended operation.
2. Perform periodic visual inspection of combustible liquid spill retaining curbs every 24 months.

17 Fire Water System Fire Water System is an existing program that will be enhanced to: Program will be Section R.2.1.17

1. Revise flow test procedures to include: enhanced no later than Exelon Letter six months prior to the
a. Inspector test flush acceptance criteria for wet pipe sprinkler second period of PBAPS SLRA systems that currently do not include the requirement to record time extended operation. Supplement No.

to flow from the opened test valve. Inspections that are to be 2, dated January

b. Acceptance criteria for wet pipe main drain tests. Flowing completed prior to the 23, 2019 pressures from test to test will be monitored to determine if there is second period of a 10 percent reduction in full flow pressure when compared to Exelon Letter extended operation will previously performed tests. An issue report shall be generated in be completed no later PBAPS SLRA the corrective action program to determine the cause and corrective than six months prior to RAI Response, actions. the second period of dated May 2,
c. If flow test acceptance criteria are not met, perform an investigation extended operation, or 2019 within the corrective action program that includes review for no later than the last increased testing and perform at least two successful additional refueling outage prior to Exelon Letter tests. Additional tests shall be completed within the interval in the second period of PBAPS SLRA which the original test was conducted. If acceptance criteria are not extended operation. Revised Fire met during follow-up testing, an extent of condition and extent of Water System cause analysis shall be conducted to determine the further extent of RAI Response, tests which includes testing on the same system, on the other unit. dated May 30,
2. Perform air flow tests on the hydrogen seal oil and reactor building water 2019 curtains every two years to ensure deluge piping and nozzles are unobstructed and there are no flow blockages.
3. Increase the frequency of air flow tests through the standby gas treatment and recombiner system deluge piping and nozzles to every two years to ensure piping and nozzles are unobstructed and there are no flow blockages.

Appendix R R-98 Rev. 29, APRIL 2023

  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

4. Revise procedures to improve guidance for external visual inspections of the in scope sprinkler systems piping and sprinklers at least every two years to inspect for corrosion, loss of material, leaks, and proper sprinkler orientation. Corroded, leaking or damaged sprinklers shall be replaced.
5. Perform external visual inspections of the in scope above ground fire main piping every two years to identify excessive corrosion, loss of material, leaks, and physical damage.
6. Perform internal visual inspections of sprinkler and deluge system piping to identify internal corrosion, foreign material, and obstructions to flow.

Follow-up volumetric wall thickness examinations will be performed if internal visual inspections detect an unexpected level of degradation due to corrosion and corrosion product deposition. If organic or foreign material, or internal flow blockage that could result in failure of system function is identified, then an obstruction investigation will be performed within the corrective action program that includes removal of the material, an extent of condition determination, review for increased inspections, extent of follow-up examinations, and a flush in accordance with NFPA 25 Appendix D.5, Flushing Procedures. The internal visual inspections will consist of the following:

a. Wet pipe sprinkler systems - 50 percent of the wet pipe sprinkler systems in scope for license renewal will have visual internal inspections of piping by removing a hydraulically remote sprinkler, performed every five years, consistent with NFPA 25, 2011 Edition, Section 14.2. During the next five-year inspection period, the alternate systems previously not inspected shall be inspected.
b. Pre-action sprinkler systems - pre-action sprinkler systems in scope for license renewal will have visual internal inspections of piping by removing a hydraulically remote nozzle, performed every five years, consistent with NFPA 25, 2011 Edition, Section 14.2.
c. Deluge systems - Yard transformer deluge systems in scope for license renewal will have visual internal inspections of piping by removing a hydraulically remote nozzle, performed every five years, consistent with NFPA 25, 2011 Edition, Section 14.2.

Appendix R R-99 Rev. 29, APRIL 2023

  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

7. Perform a one-time volumetric wall thickness inspection, prior to the second period of extended operation, on a sample of the original yard transformer deluge system supply piping that was not replaced during transformer replacements and is periodically subjected to flow during functional testing.
8. Revise service water bay inspection procedures to include inspection of the motor driven fire pump intake strainer.
9. Perform flow tests for hose stations at the hydraulically most limiting locations for each zone of the system on a five-year frequency to demonstrate the capability to provide the design pressure at required flow.
10. Flush deluge system mainline supply basket strainers until clear, following functional testing of yard deluge systems.
11. Perform a one-time inspection of the auxiliary boiler fuel oil storage tank internal foam nozzle and deflector, prior to the second period of extended operation, to ensure proper configuration and orientation and no indication of flow blockage.
12. Perform an internal inspection of the auxiliary boiler oil storage tank foam system foam concentrate tank every 10 years to ensure it is free of corrosion, debris, or foreign material that could cause flow blockage, and to ensure there are no cracks or leaks and it is in good condition.
13. Revise restoration procedures for the hydrogen seal oil and reactor building water curtain systems to utilize low point drains following control valve actuations to ensure there is no trapped water in the system.
14. Revise restoration procedures for the yard transformer deluge systems to utilize low point drains after functional testing.
15. Revise the fire hydrant inspection and flush test procedure to include a minimum flow duration of one (1) minute after the hydrant valve is fully open to remove all foreign material.
16. Revise the underground fire main flow test to utilize the corrective action program to determine an increased test frequency when established test criteria is not met or when significant degraded trends that could adversely affect system intended function are identified. When test Appendix R R-100 Rev. 29, APRIL 2023
  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

results pass the established test criteria, the test frequency may be extended to a five (5) year frequency IAW NFPA 25.

17. Perform at least five additional ultrasonic test inspections on the fire water supply piping for each Fire Water System pipe wall inspection that does not meet acceptance criteria.
18. Provide procedural direction to require the use of a mill tolerance of 12.5% for added conservatism when determining corrosion rates at new inspection locations if corrosion rates from other locations with nearly identical operating conditions, material, size, and configuration cannot be used.

18 Outdoor and Large Outdoor and Large Atmospheric Metallic Storage Tanks is an existing program that Program will be Section R.2.1.18 Atmospheric Metallic will be enhanced to: enhanced no later than Storage Tanks 1. Perform a visual inspection of the sealant at the perimeter of the six months prior to the condensate storage tanks and refueling water storage tank bases for signs second period of of degradation every two years. The visual inspections of sealant and extended operation, caulking are supplemented with physical manipulation to detect unless a more specific degradation. schedule is described within the enhancement

2. Perform a pre-inspection review of the previous two inspections of the (i.e., Enhancement 4).

internal tank coatings, when available, that includes review of results of Inspections that are to be inspections and any subsequent repair activities. completed prior to the

3. Conduct training and qualification of individuals involved in internal coating second period of or lining inspections and evaluating degraded conditions in accordance extended operation will with an ASTM International standard endorsed in RG 1.54. be completed no later
4. Perform volumetric inspection of Unit 2 and 3 condensate storage tanks than six months prior to and refueling water storage tank bottoms at least once during the 10-year the second period of period prior to the second period of extended operation, and at least once extended operation, or every 10 years during the second period of extended operation. no later than the last Volumetric inspections are performed at representative sample locations refueling outage prior to to include 25 one square foot locations or 20 percent coverage conducted the second period of in different locations unless the program states the basis for why repeated extended operation.

inspections are conducted in the same location (i.e. previous findings).

Additionally, a minimum of 10 of the random one square foot sample locations will be performed within the 30-inch band at the perimeter of the Appendix R R-101 Rev. 29, APRIL 2023

  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

shell. The scope of subsequent examinations may be adjusted based upon the results of previous examinations.

19 Fuel Oil Chemistry Fuel Oil Chemistry is an existing program that will be enhanced to: Program will be Section R.2.1.19

1. Perform periodic internal inspection of the diesel fire pump fuel oil storage enhanced no later than tank (00T041) and the diesel fire pump day tank (00T543) at least once six months prior to the during the 10-year period prior to the second period of extended operation, second period of and at least once every 10 years during the second period of extended extended operation operation. Each diesel fuel tank will be drained and cleaned, the internal unless a more specific surfaces visually inspected (if physically possible), and, if evidence of schedule is described degradation is observed during inspections, or if visual inspection is not within the enhancement possible, these diesel fuel tanks will be volumetrically inspected. (i.e., Enhancement 1).

Inspections that are to be

2. Perform periodic (quarterly) removal of water collected at the bottom of the completed prior to the diesel fire pump fuel oil storage tank (00T041) and the diesel fire pump second period of day tank (00T543). extended operation will
3. Perform receipt testing of new fuel oil for particulate concentration and the be completed no later levels of microbiological organisms for the diesel generator fuel oil day than six months prior to tanks (0A(B,C,D)T040), diesel generator fuel oil storage tanks the second period of (0A(B,C,D)T038), and diesel fire pump fuel oil storage tank (00T041). extended operation, or
4. Perform periodic (quarterly) sampling and analysis for water and sediment no later than the last content, particulate concentration, and the levels of microbiological refueling outage prior to organisms for the diesel generator fuel oil day tanks (0A(B,C,D)T040). the second period of Sampling activities will include a sampling methodology that includes a extended operation.

representative sample from the lowest point in the tank.

5. Perform periodic (quarterly) sampling and analysis for water and sediment and the levels of microbiological organisms for the diesel generator fuel oil storage tanks (0A(B,C,D)T038).
6. Perform periodic (quarterly) sampling and analysis for particulate concentration and the levels of microbiological organisms for the diesel fire pump fuel oil storage tank (00T041) and the diesel fire pump day tank (00T543).

Appendix R R-102 Rev. 29, APRIL 2023

  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

7. Perform periodic (quarterly) trending of water and sediment content, particulate concentration, and the levels of microbiological organisms for all fuel oil tanks within the scope of the program.
8. Evaluate the need for biocide or corrosion inhibitor addition if periodic testing indicates biological activity or evidence of corrosion.
9. Evaluate degradation identified during tank internal inspections against acceptance criteria to confirm that the timing of subsequent inspections will maintain the components intended function throughout the second period of extended operation based on the projected rate of degradation.

20 Reactor Vessel Reactor Vessel Material Surveillance is an existing program that will be enhanced Enhancement 1 will be Section R.2.1.20 Material Surveillance to: implemented in

1. Withdraw and test the Unit 2, 120 degree reconstituted capsule and the accordance with the Unit 3, 120 degree capsule per the capsule withdrawal schedules below. schedules defined in the A technical summary report containing the test results shall be submitted commitment.

to the NRC per the requirements of 10 CFR Part 50, Appendix H. Any changes to the Reactor Vessel Material Surveillance program must be submitted for NRC review and approval in accordance with 10 CFR Part 50, Appendix H.

Peach Bottom Unit 2 Capsule Withdrawal Schedule Capsule Lead Capsule Withdrawal Capsule Factor (0T/1/4T) EFPY 30° 0.95/1.38 Per BWRVIP-86-R1-A 120° 0.95/1.38 7.53 (actual) 120° Reconstituted 0.95/1.38 60 - 62(1) 300° 0.95/1.38 Per BWRVIP-86-R1-A

1. Capsule 120° was withdrawn, tested, and reconstituted after Cycle 7 and re-inserted after Cycle 8, therefore capsule EFPY is 1.21 EFPY less than plant operating EFPY.

Appendix R R-103 Rev. 29, APRIL 2023

  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

Peach Bottom Unit 3 Capsule Withdrawal Schedule Capsule Lead Capsule Capsule Withdrawal EFPY Factor (0T/1/4T) 30° 0.95/1.38 7.57 (actual) 30° Reconstituted 0.95/1.38 Spare(1) 120° 0.95/1.38 60 - 62 300° 0.95/1.38 Spare(2)

1. Capsule 30° was withdrawn, tested, and reconstituted after Cycle 7 and re-inserted after Cycle 8, therefore capsule EFPY is 1.41 EFPY less than plant operating EFPY.
2. Capsule 300° was withdrawn after Cycle 7 and re-inserted after Cycle 8, therefore capsule EFPY is 1.41 EFPY less than plant operating EFPY.

21 One-Time Inspection One-Time Inspection aging management program is a new condition monitoring Program will be Section R.2.1.21 program consisting of a one-time inspection of selected components to verify: (a) implemented no later the system-wide effectiveness of an AMP that is designed to prevent or minimize than 10 years prior to the aging to the extent that it will not cause the loss of intended function during the second period of second period of extended operation; (b) the insignificance of an aging effect; and extended operation. The (c) that long-term loss of material will not cause a loss of intended function for steel one-time inspections are components exposed to environments that do not include corrosion inhibitors as a required to be performed preventive action. within the 10 years prior to the second period of extended operation, and no later than six months prior to the second period of extended operation, or no later than the last refueling outage prior to the second period of extended operation.

Appendix R R-104 Rev. 29, APRIL 2023

  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

22 Selective Leaching Selective Leaching aging management program is a new condition monitoring Program will be Section R.2.1.22 program that will monitor components constructed of materials which are implemented no later susceptible to selective leaching. The selective leaching program includes a one- than 10 years prior to the time inspection for susceptible components exposed to closed cycle cooling water second period of and treated water environment since plant-specific operating experience has not extended operation. The revealed selective leaching in these environments, as well as opportunistic and one-time inspections and periodic inspections for susceptible components exposed to raw water, waste initial periodic water, and soil (which may include groundwater) environments. inspections are required to be performed within the 10 years prior to the second period of extended operation, and no later than six months prior to the second period of extended operation, or no later than the last refueling outage prior to the second period of extended operation.

Appendix R R-105 Rev. 29, APRIL 2023

  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

23 ASME Code Class 1 ASME Code Class 1 Small-Bore Piping aging management program is a new Program will be Section R.2.1.23 Small-Bore Piping condition monitoring program that augments the existing ASME Code,Section XI implemented no later requirements and is applicable to ASME Code Class 1 small-bore piping and than six years prior to the systems with a NPS diameter less than 4 inches and greater than or equal to 1 second period of inch. This program provides for volumetric examination of a sample of full extended operation. The penetration (butt) welds and partial penetration (socket) welds in Class 1 piping to one-time inspections are manage cracking due to stress corrosion cracking or thermal or vibratory fatigue required to be performed loading. Volumetric examinations will employ techniques that have been within the six years prior demonstrated to be capable of detecting flaws and discontinuities in the to the second period of examination volume of interest. extended operation, and The extent and schedule for volumetric examination is based on plant-specific no later than six months operating experience and whether actions have been implemented that effectively prior to the second mitigate the cause(s) of any past cracking. The program provides for a one-time period of extended inspection of a sample of the population of welds (butt welds or socket welds) for operation, or no later plants that have not experienced cracking or have experienced cracking but have than the last refueling implemented corrective actions, such as a design change, to effectively mitigate outage prior to the the cause(s) of the cracking. The program provides for periodic inspection of a second period of sample of the population of welds (butt welds or socket welds) that have extended operation.

experienced cracking and have not implemented corrective actions to effectively mitigate the cause(s) of the cracking.

24 External Surfaces External Surfaces Monitoring of Mechanical Components aging management Program will be Section R.2.1.24 Monitoring of program is a new condition monitoring program that will manage loss of material implemented no later Mechanical and cracking of metallic components, as well as loss of material, cracking, and than six months prior to Components hardening and loss of strength for elastomeric components, loss of preload for the second period of HVAC closure bolting, and reduced thermal insulation resistance. Periodic visual extended operation.

inspections, not to exceed a refueling outage interval, of metallic components, elastomers, and insulation jacketing (insulation when not jacketed) will be conducted.

Appendix R R-106 Rev. 29, APRIL 2023

  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

25 Inspection of Internal Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program will be Section R.2.1.25 Surfaces in program is a new condition monitoring program that will manage loss of material implemented no later Miscellaneous and cracking of metallic components, as well as loss of material and hardening and than six months prior to Piping and Ducting loss of strength of elastomeric materials. Reduction of heat transfer will also be the second period of Components managed. This program will consist of visual inspections of all accessible internal extended operation.

surfaces of piping, piping components, ducting, heat exchanger components, and other mechanical components.

26 Lubricating Oil Existing program is credited. Ongoing Section R.2.1.26 Analysis 27 Monitoring of Existing program is credited. Ongoing Section R.2.1.27 Neutron-Absorbing Materials Other than Boraflex 28 Buried and Buried and Underground Piping is an existing program that will be enhanced to: Program will be Section R.2.1.28 Underground Piping 1. Manage cracking for buried stainless steel piping, utilizing a method that enhanced no later than and Tanks has been demonstrated to be capable of detecting cracking, whenever 10 years prior to the coatings are removed exposing the base material. second period of extended operation,

2. Perform direct visual inspection of buried piping within the scope of unless a more specific license renewal in accordance with NUREG-2191, Table XI.M41-2, and schedule is described sections 4.a and 4.b, during each 10-year period, beginning 10 years prior within the enhancement to the second period of extended operation. The number of inspections of (i.e., Enhancement 4).

buried piping will be based upon the as-found results of cathodic Inspections that are protection system availability and effectiveness. The length of piping for required to be performed each inspection will be based on the recommendations in section 4.c. in the 10-year period

3. Perform extent of condition inspections as follows: When measured pipe prior to the second wall thickness, projected to the end of the second period of extended period of extended operation, does not meet the minimum pipe wall thickness requirements operation will be due to external environments, the number of inspections within the completed no later than affected piping categories will be doubled or increased by five, whichever six months prior to the is smaller. If adverse indications are found in the expanded sample, an second period of analysis will be conducted to determine the extent of condition and extent extended operation, or of cause. The size of the follow-up inspections will be determined based no later than the last Appendix R R-107 Rev. 29, APRIL 2023
  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

on the analysis. Timing of any additional inspections will be based on the refueling outage prior to severity of the identified degradation and the consequences of leakage or the second period of loss of function. Any additional inspections will be performed within the extended operation.

same 10-year inspection interval in which the original degradation was identified, or within four years after the end of the 10-year interval if the degradation was identified in the latter half of the 10-year interval.

Expansion of sample size may be limited by the extent of piping subject to the observed degradation mechanism or if the piping system or portion of the system is replaced or otherwise mitigated within the same 10-year inspection interval in which the original degradation was identified or within four years after the end of the 10-year interval, if the degradation was identified in the latter half of the 10-year interval.

4. Upgrade existing cathodic protection system no later than 5 years prior to the second period of extended operation, in accordance with NACE SP0169-2007, to ensure effective control of external corrosion of underground piping and tanks.
5. Perform examination of buried emergency diesel generator fuel oil tanks from the internal surface of the tank using volumetric techniques during each 10-year period, beginning 10 years prior to the second period of extended operation. A minimum of 25 percent coverage is required.
6. Perform annual system monitoring of the cathodic protection system to ensure effective protection of buried piping.
7. Apply coating to buried portions of the 10-inch diameter stainless steel line from the torus dewatering tank to the condensate transfer pump suction line in accordance with approved station specifications, during the 10-year period prior to the second period of extended operation.

Appendix R R-108 Rev. 29, APRIL 2023

  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

29 Internal Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Program will be Section R.2.1.29 Coatings/Linings for Exchangers, and Tanks aging management program is a new condition monitoring implemented no later In-Scope Piping, program that manages degradation of internal coatings/linings exposed to raw than 10 years prior to the Piping Components, water, treated water, waste water, condensation, or lubricating oil that can lead to second period of Heat Exchangers, loss of material of base metals or downstream effects such as reduction in flow, extended operation.

and Tanks pressure, or heat transfer when coatings/linings become debris. Baseline inspections that may be required in the 10-year period prior to the second period of extended operation will be completed no later than six months prior to the second period of extended operation, or no later than the last refueling outage prior to the second period of extended operation.

Appendix R R-109 Rev. 29, APRIL 2023

  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

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

2. Clarify that the recommended guidance for proper selection of bolting No. 2, dated material and lubricants, and appropriate installation torque or tension January 23, 2019 to prevent or minimize loss of bolting preload and cracking of high-strength bolting is a requirement at Peach Bottom in accordance with the guidelines provided in EPRI NP-5067 and TR-104213. Clarify that the recommended requirements for storage, lubricant selection, and bolting and coating material selection include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication Specification for Structural Joints Using High-Strength Bolts, are a requirement at Peach Bottom.
3. Implement a one-time supplemental volumetric examination of the containment metal shell surfaces that are inaccessible from one side, if triggered by plant-specific OE. The trigger for this supplemental examination is plant-specific occurrence or recurrence of measurable metal shell corrosion (base metal material loss exceeding 10 percent of nominal plate thickness) initiated on the inaccessible side or areas, identified since the date of issuance of the first renewed license. This supplemental volumetric examination consists of a sample of one-foot square locations that include both randomly-selected and focused areas most likely to experience degradation based on plant-specific OE and/or other relevant considerations such as environment. The sample size, locations, and any needed scope expansion (based on findings) for this one-time set of volumetric examinations should be determined on a plant-specific basis to demonstrate statistically with 95 percent confidence that 95 percent of the accessible portion of the containment liner is not experiencing corrosion degradation with greater than 10 percent loss of nominal thickness.

Appendix R R-110 Rev. 29, APRIL 2023

  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR 31 ASME Section XI, ASME Section XI, Subsection IWF is an existing program that will be enhanced to: Program will be Section R.2.1.31 Subsection IWF 1. Perform periodic evaluations of the acceptability of inaccessible areas of enhanced in accordance supports (e.g., portions of supports encased in concrete, buried with the schedule described within the Exelon Letter underground, or encapsulated by guard pipe), when conditions exist in accessible areas that could indicate the presence of, or result in, enhancements. PBAPS SLRA degradation to inaccessible areas of supports. Perform these Inspections that are Supplement evaluations once every 10 years during the second period of extended required to be performed No. 2, dated operation. in the five-year period January 23, 2019 prior to the second

2. Perform a one-time inspection of an additional five percent of the period of extended currently inspected sample size specified in Table IWF-2500-1 for Class Exelon Letter operation will be 1, 2, and 3 piping supports. Conduct the one-time inspection within the completed no later than PBAPS SLRA five years prior to entering the second period of extended operation. six months prior to the Supplement Select the additional supports from the remaining population of IWF second period of No. 3, dated piping supports. Ensure that the sample expansion includes components extended operation, or February 11, that are most susceptible to age-related degradation (i.e., based on no later than the last 2019 factors such as time in service, material, and aggressiveness of the refueling outage prior to environment). the second period of
3. Perform VT-3 examinations of all ASTM A-490 bolting materials, used for extended operation.

the reactor vessel support skirts and for the core spray pump supports once per 10-year interval during the second period of extended operation. Perform volumetric examination comparable to that of ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1, of 12 ASTM A490 bolts at each of the reactor vessel support skirts, once per 10-year interval during the second period of extended operation. If the volumetric examination of these ASTM A490 bolts reveals conditions that do not meet acceptance criteria, enter the results into the corrective action program and extend the ASTM A490 bolt examination scope to include other ASTM A490 bolts used in similar joint configurations and subject to similar environmental exposure conditions, which is comparable to the methodology used by the ASME Code, section IWF-2430 for IWF component supports.

4. Clarify that the recommended guidance for proper selection of bolting material and lubricants, and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting is a requirement at Peach Bottom in accordance with the guidelines provided in EPRI NP-5067 and TR-104213. Clarify that the recommended requirements for storage, lubricant selection, and bolting Appendix R R-111 Rev. 29, APRIL 2023
  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

and coating material selection include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication Specification for Structural Joints Using High-Strength Bolts, are a requirement at Peach Bottom.

5. Enhance engineering procedures to require volumetric examination should high-strength bolting (actual measured yield strength greater than or equal to 150 ksi) in sizes greater than 1-inch nominal diameter (including ASTM A490 and equivalent ASTM F2280) be installed. The examination shall be comparable to that of ASME Code Section XI, Table IWB-2500-1, Examination Category B-G-1, at least once per 10-year interval, to detect cracking, in addition to the VT-3 examination.
6. Provide guidance, regarding the selection of supports to be inspected on subsequent inspections, when a support that does not meet the threshold of "unacceptable for continued service" as defined in IWF-3400, is restored in accordance with the Corrective Action Program. The enhanced guidance will ensure that the sample is increased or modified to include another support that is representative of the remaining population of supports that were not repaired.

32 10 CFR Part 50, Existing program is credited. Ongoing Section R.2.1.32 Appendix J 33 Masonry Walls Masonry Walls is an existing program that will be enhanced to: Program will be Section R.2.1.33

1. Expand the program to include masonry walls in the Administration enhanced no later than Building and Dewatering Building. six months prior to the second period of extended operation.

34 Structures Structures Monitoring is an existing program that will be enhanced to: Program will be Section R.2.1.34 Monitoring 1. Explicitly include the following components and commodities within the enhanced no later than scope of the program: six months prior to the second period of Exelon Letter

a. Bearing pads for supports extended operation. PBAPS SLRA
b. Electrical duct banks Baseline inspections will Supplement
c. Electrical raceway such as cable tray, conduit, and wireway gutter be completed no later than six months prior to Appendix R R-112 Rev. 29, APRIL 2023
  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

d. Hatches and plugs the second period of No. 2, dated
e. Manholes and handholes extended operation, or January 23, 2019 no later than the last
f. Miscellaneous components such as louvers refueling outage prior to
g. Panels, racks, frames, cabinets, and other enclosures the second period of Exelon Letter
h. Permanent shielding blankets extended operation. PBAPS SLRA RAI Response
2. Add the following structures to the scope of the program: dated May 23,
a. Administration Building 2019
b. Boiler House
c. Dewatering Building
3. Perform inspections under the enhanced program in order to establish quantitative baseline inspection data prior to the second period of extended operation.
4. Provide evaluation criteria for structural concrete using quantitative second tier criteria of Chapter 5 in ACI 349.3R.
5. Monitor for reduction in concrete anchor capacity if local concrete degradation such as cracking and loss of material is identified.
6. Develop a new implementing procedure or revise an existing implementing procedure to address aging management of inaccessible areas exposed to potentially aggressive groundwater/soil environment that will include the following:
a. Monitor raw water and ground water chemistry, for pH, chlorides, and sulfates, on a frequency not to exceed five years that accounts for seasonal variations (e.g., quarterly monitoring every fifth year),

from locations that are representative of the groundwater in contact with structures within the scope of second license renewal.

b. Enter adverse results, which exceed water chemistry criteria, into the corrective action program. As part of the corrective actions, if aggressive groundwater is identified that might affect structures in scope for license renewal, perform additional water testing at additional locations and perform soil testing in order to confirm the Appendix R R-113 Rev. 29, APRIL 2023
  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

extent, severity, and potential aging mechanisms resulting from the aggressive groundwater/soil.

c. Develop engineering evaluations to evaluate the water chemistry results to assess the impact, if any, on below-grade concrete, including the potential for further degradation due to the aggressive groundwater, as well as consideration of current conditions. As part of the engineering evaluations, determine if additional actions are warranted, which might include enhanced inspection techniques and/or increased frequency, destructive testing, and focused inspections of representative accessible (leading indicator) or below grade, inaccessible concrete structural elements exposed to aggressive groundwater/soil.
d. Develop the initial engineering evaluations prior to the second period of extended operation. Develop follow-up engineering evaluations on an interval not to exceed five years.
e. If aggressive groundwater and soil is identified, at a minimum, perform focused inspections of representative, accessible (leading indicator) structural elements, or if accessible areas will not be leading indicators for the potential aging mechanisms, excavate and inspect buried concrete elements exposed to aggressive groundwater/soil.
f. If degraded concrete is identified, as part of the focused inspections of leading indicators (representative, accessible or exposed inaccessible concrete), enter adverse results that exceed ACI 349.3R tier 2 criteria into the corrective action program, and expose inaccessible concrete so that the extent of the condition can be determined, baseline conditions documented, and additional actions identified such as repairs, new preventative actions, additional evaluations, and future inspections.
7. Monitor and trend through-wall groundwater leakage, infiltration volumes, and leakage water chemistry for signs of concrete or steel reinforcement degradation. Develop additional engineering evaluations, which consider more frequent inspections, as well as destructive testing of affected concrete to validate existing concrete properties, and leakage water Appendix R R-114 Rev. 29, APRIL 2023
  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

chemistry results. If leakage volumes allow, consider water chemistry analysis of the leakage pH, along with mineral, chloride, sulfate and iron content in the water.

8. Expand the program to monitor accessible sliding surfaces for indications of significant loss of material due to wear or corrosion, and for accumulation of debris or dirt. Establish acceptance criteria for sliding surfaces as no significant loss of material due to wear or corrosion, and no debris or dirt that could restrict or prevent sliding of the surfaces, as required by design.
9. Evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas
10. Expand the program to monitor elastomeric vibration isolators and bearing pads for cracking, loss of material, and hardening. Supplement visual inspection of elastomeric elements with tactile inspection to detect hardening, if the intended function is suspect. Establish acceptance criteria for elastomeric pads and vibration isolation elements as no loss of material, cracking, or hardening that can lead to loss of isolation or support function.
11. Clarify that loose bolts and nuts and cracked bolts are not acceptable unless accepted by engineering evaluations.
12. Expand the program to inspect the fiberglass outer covering of permanent shielding blankets for signs of tears. If a tear is found, enter the condition into the corrective action program for evaluation. Repair or replace the permanent shielding, unless an evaluation determines that the condition is acceptable.
13. Clarify that the recommended guidance for proper selection of bolting material and lubricants, and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting is a requirement at Peach Bottom in accordance with the guidelines provided in EPRI NP-5067 and TR-104213. Clarify that the recommended requirements for storage, lubricant selection, and bolting and coating material selection include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication Appendix R R-115 Rev. 29, APRIL 2023
  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

Specification for Structural Joints Using High-Strength Bolts, are a requirement at Peach Bottom.

35 Inspection of Inspection of Water-Control Structures Associated with Nuclear Power Plants is an Program will be Section R.2.1.35 Water-Control existing program that will be enhanced to: enhanced no later than Structures 1. Explicitly include the sluice gates at the Circulating Water Pump Structure six months prior to the Associated with second period of Exelon Letter within the scope of the program.

Nuclear Power extended operation. PBAPS SLRA Plants 2. Clarify parameters to be monitored and inspected at the Emergency Baseline inspections will Supplement Cooling Tower and Reservoir to include visual inspection for loss of be completed no later No. 2, dated material and reduction of heat transfer due to fouling for the cooling tower than six months prior to January 23, 2019 fill, and visual inspection of the drift eliminators. the second period of

3. Monitor for reduction in concrete anchor capacity if local concrete extended operation, or degradation such as cracking and loss of material is identified. Exelon Letter no later than the last
4. Expand the program to monitor accessible sliding surfaces for indications refueling outage prior to PBAPS SLRA of significant loss of material due to wear or corrosion, and for the second period of RAI Response accumulation of debris or dirt. extended operation. dated May 23, 2019
5. Include provisions for special inspections following significant natural phenomena, such as large floods, hurricanes, tornadoes, or intense local rainfall as part of the guidelines for severe weather and natural disasters.
6. Develop a new implementing procedure or revise an existing implementing procedure to address aging management of inaccessible areas exposed to potentially aggressive groundwater/soil environment that will include the following:
a. Monitor raw water and ground water chemistry, for pH, chlorides, and sulfates, on a frequency not to exceed five years that accounts for seasonal variations (e.g., quarterly monitoring every fifth year),

from locations that are representative of the groundwater in contact with structures within the scope of second license renewal.

b. Enter adverse results, which exceed water chemistry criteria, into the corrective action program. As part of the corrective actions, if aggressive groundwater is identified that might affect structures in scope for license renewal, perform additional water testing at additional locations and perform soil testing in order to confirm the Appendix R R-116 Rev. 29, APRIL 2023
  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

extent, severity, and potential aging mechanisms resulting from the aggressive groundwater/soil.

c. Develop engineering evaluations to evaluate the water chemistry results to assess the impact, if any, on below-grade concrete, including the potential for further degradation due to the aggressive groundwater, as well as consideration of current conditions. As part of the engineering evaluations, determine if additional actions are warranted, which might include enhanced inspection techniques and/or increased frequency, destructive testing, and focused inspections of representative accessible (leading indicator) or below grade, inaccessible concrete structural elements exposed to aggressive groundwater/soil.
d. Develop the initial engineering evaluations prior to the second period of extended operation. Develop follow-up engineering evaluations on an interval not to exceed five years.
e. If aggressive groundwater and soil is identified, at a minimum, perform focused inspections of representative, accessible (leading indicator) structural elements, or if accessible areas will not be leading indicators for the potential aging mechanisms, excavate and inspect buried concrete elements exposed to aggressive groundwater/soil.
f. If degraded concrete is identified, as part of the focused inspections of leading indicators (representative, accessible or exposed inaccessible concrete), enter adverse results that exceed ACI 349.3R tier 2 criteria into the corrective action program, and expose inaccessible concrete so that the extent of the condition can be determined, baseline conditions documented, and additional actions identified such as repairs, new preventative actions, additional evaluations, and future inspections.
7. Monitor and trend through-wall groundwater leakage, infiltration volumes, and leakage water chemistry for signs of concrete or steel reinforcement degradation. Develop additional engineering evaluations, which consider more frequent inspections, as well as destructive testing of affected concrete to validate existing concrete properties, and leakage water Appendix R R-117 Rev. 29, APRIL 2023
  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

chemistry results. If leakage volumes allow, consider water chemistry analysis of the leakage pH, along with mineral, chloride, sulfate and iron content in the water.

8. Evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas.
9. Document the concrete conditions of submerged concrete structures.
10. Specify a six-year frequency for the inspection of the submerged portions of the traveling screen bays to match the inspection frequency of the submerged portions of the Circulating Water Pump Structure bays.
11. Perform inspections under the enhanced program in order to establish quantitative baseline inspection data prior to the second period of extended operation.
12. Provide evaluation criteria for structural concrete using quantitative second tier criteria of Chapter 5 in ACI 349.3R.
13. Clarify that loose bolts and nuts and cracked bolts are not acceptable unless accepted by engineering evaluations.
14. Clarify that the recommended guidance for proper selection of bolting material and lubricants, and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting is a requirement at Peach Bottom in accordance with the guidelines provided in EPRI NP-5067 and TR-104213. Clarify that the recommended requirements for storage, lubricant selection, and bolting and coating material selection include the recommendations in Section 2 of Research Council on Structural Connections (RCSC) publication Specification for Structural Joints Using High-Strength Bolts, are a requirement at Peach Bottom.

36 Protective Coating Protective Coating Monitoring and Maintenance Program is an existing program Program will be Section R.2.1.36 Monitoring and that will be enhanced to: enhanced no later than Maintenance 1. Use Level II or Level III coating inspectors, certified to ANSI N45.2.6, for six months prior to the Program second period of Exelon Letter inspection of Service Level I coatings.

extended operation. PBAPS SLRA RAI Response Appendix R R-118 Rev. 29, APRIL 2023

  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

dated May 2, 2019 37 Electrical Insulation Electrical Insulation for Electrical Cables and Connections Not Subject to Program will be Section R.2.1.37 for Electrical Cables 10 CFR 50.49 Environmental Qualification Requirements is an existing program enhanced no later than and Connections that will be enhanced to: six months prior to the Not Subject to 1. Include potential follow-up actions when visual inspections identify second period of 10 CFR 50.49 degraded or damaged conditions that may impact the performance of extended operation. In Environmental intended functions: addition, the first Qualification inspections incorporating Requirements a. Perform tests, for condition monitoring when visual inspections enhancements will be identify damaged or degraded insulation of in scope cables and completed no later than connections. When a large number of cables are identified as six months prior to the damaged or degraded, a sample population will be tested. The second period of sample size will be 20 percent of each affected cable and extended operation, or connection type with a maximum sample size of 25. no later than the last

b. Document the basis for the samples selected for testing when refueling outage prior to visual inspections identify damaged or degraded insulation the second period of conditions for in scope cables and connections. extended operation.
2. Visually inspect and evaluate cables and connections that were exposed to adverse localized environments (ALEs), which have since been mitigated, on an at least once every 10-year frequency, to assure the cumulative aging effects for electrical insulation, in remedied ALEs are not impacting the ongoing ability of the cables and connections to perform their intended function during the second period of extended operation.

38 Electrical Insulation Electrical Insulation for Electrical Cables and Connections Not Subject to Program will be Section R.2.1.38 for Electrical Cables 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation enhanced no later than and Connections Circuits is an existing program that will be enhanced to: six months prior to the Not Subject to 1. Add the following radiation monitors to the scope of this program second period of 10 CFR 50.49 extended operation. The Environmental a. Main steam line radiation monitors first documented periodic Qualification b. Reactor building ventilation exhaust radiation monitors review will be completed Requirements Used c. Control room fresh air supply radiation monitors no later than six months prior to the second Appendix R R-119 Rev. 29, APRIL 2023

  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

in Instrumentation d. Control room emergency ventilation supply radiation monitors period of extended Circuits e. Main stack radiation monitors. operation, or no later than the last refueling

2. Revise the implementing procedures to include documented periodic outage prior to the review of calibration test results for neutron monitors and radiation second period of monitors within the scope of this program. Perform the first periodic extended operation.

review for second license renewal prior to the second period of extended operation and at least every 10 years thereafter.

39 Electrical Insulation Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to Program will be Section R.2.1.39 for Inaccessible 10 CFR 50.49 Environmental Qualification Requirements is an existing program enhanced no later than Medium-Voltage that will be enhanced to: six months prior to the Power Cables Not 1. Add periodic cable testing for additional circuits. second period of Subject to 10 CFR extended operation.

50.49 Environmental 2. Perform cable testing of the circuits in the scope of this program at a Tests and inspections Qualification frequency of at least once every six years. that are required to be Requirements 3. Add periodic condition monitoring, as a preventive action, for manholes. performed prior to the second period of extended operation will be completed no later than six months prior to the second period of extended operation, or no later than the last refueling outage prior to the second period of extended operation.

Appendix R R-120 Rev. 29, APRIL 2023

  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

40 Electrical Insulation Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to Program will be Section R.2.1.40 for Inaccessible 10 CFR 50.49 Environmental Qualification Requirements aging management implemented no later Instrument and program is a new condition monitoring program that will manage the effects of than six months prior to Control Cables Not reduced insulation resistance of non-EQ, in scope, inaccessible (e.g., installed in the second period of Subject to 10 CFR buried conduits, cable trenches, cable troughs, duct banks, underground vaults, or extended operation.

50.49 Environmental direct buried installations), instrument and control cables, exposed to significant One-time cable testing, Qualification moisture. initial manhole Requirements inspections, and initial visual cable inspections will be completed no later than six months prior to the second period of extended operation, or no later than the last refueling outage prior to the second period of extended operation.

41 Electrical Insulation Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 Program will be Section R.2.1.41 for Inaccessible CFR 50.49 Environmental Qualification Requirements aging management program implemented no later Low-Voltage Power is a new condition monitoring program that will manage the effects of reduced than six months prior to Cables Not Subject insulation resistance of non-EQ, in scope, inaccessible (e.g., installed in buried the period of extended to 10 CFR 50.49 conduits, cable trenches, cable troughs, duct banks, underground vaults, or direct operation. One-time Environmental buried installations), low-voltage power cables (operating voltage less than 2 kV), cable testing, initial Qualification exposed to significant moisture. manhole inspections, Requirements and initial visual cable inspections will be completed no later than six months prior to the second period of extended operation, or no later than the last refueling outage prior to the second period of extended operation.

Appendix R R-121 Rev. 29, APRIL 2023

  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

42 Metal Enclosed Bus Metal Enclosed Bus aging management program is a new condition monitoring Program will be Section R.2.1.42 program that uses sampling and will manage the identified aging effects of in implemented no later scope metal enclosed bus. than six months prior to the second period of extended operation.

Initial inspections and resistance measurements will be completed no later than six months prior to the second period of extended operation, or no later than the last refueling outage prior to the second period of extended operation.

43 Electrical Cable Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Program will be Section R.2.1.43 Connections Not Qualification Requirements aging management program is a new condition implemented no later Subject to monitoring program that consists of a representative sample of electrical than six months prior to 10 CFR 50.49 connections tested prior to the second period of extended operation. The results the second period of Environmental will be evaluated to determine if there is a need for subsequent periodic testing on extended operation.

Qualification a 10-year frequency. Testing and evaluation of Requirements results will be completed no later than six months prior to the second period of extended operation, or no later than the last refueling outage prior to the second period of extended operation.

Appendix R R-122 Rev. 29, APRIL 2023

  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

44 Wooden Pole Wooden Pole is an existing program that will be enhanced to: Program will be Section R.2.2.1

1. Document results that do not meet the acceptance criteria in the corrective enhanced no later than action program. six months prior to the second period of extended operation.

45 Fatigue Monitoring Fatigue Monitoring is an existing program that will be enhanced to: Program will be Section R.3.1.1 enhanced no later than six months prior to the

1. Update the SI:FatigueProTM software to include the calculation and second period of tracking of Environmentally Assisted Fatigue (EAF) in accordance extended operation.

NUREG/CR-6909, Revision 1.

2. Update applicable fatigue analyses and monitored component locations based on operating experience, plant modifications, inspection findings, changes to transient definitions, and unanticipated newly discovered fatigue loading events.
3. Provide procedural direction to require periodic validation of chemistry parameters used to determine Fen factors used in SI:FatigueProTM.
4. Provide procedural direction to add an additional acceptance criterion associated with HELB exclusion criteria.

46 Neutron Fluence Neutron Fluence Monitoring is an existing program that will be enhanced to: Program will be Section R.3.1.2 Monitoring 1. Perform periodic monitoring of reactor pressure vessel and reactor vessel enhanced no later than internals accumulated neutron fluence, every refueling cycle, to ensure six months prior to the that neutron fluence projections used to support reactor pressure vessel second period of neutron irradiation embrittlement analyses (i.e., TLAAs, pressure- extended operation.

temperature limits) and reactor vessel internals aging effect assessments remain bounding with respect to actual plant operating conditions.

Appendix R R-123 Rev. 29, APRIL 2023

  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

PBAPS UFSAR PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

47 Environmental Environmental Qualification of Electric Equipment is an existing program that will Program will be Section R.3.1.3 Qualification of be enhanced to: enhanced no later than Electric Equipment 1. Add activities to visually inspect accessible, passive EQ equipment six months prior to the located in adverse localized environments at least once every 10 years. second period of The first periodic visual inspection will be performed prior to the second extended operation.

period of extended operation. New visual inspections of accessible, passive EQ

2. Establish acceptance criteria for the visual inspections of accessible, equipment located in passive EQ equipment located in adverse localized environments. adverse localized environments will be completed no later than six months prior to the second period of extended operation, or no later than the last refueling outage prior to the second period of extended operation.

48 Operating Existing program is credited. Ongoing Section R.1.6 Experience 49 Operating Exelon The licensee will perform an evaluation of operating experience at Evaluation will be NUREG-2192 Experience Review extended power uprate (EPU) levels prior to the period of extended operation to completed no later than Section 1.2.2 ensure that operating experience at EPU levels is properly addressed by the aging six months prior to the management programs. The evaluation will include Peach Bottom and other BWR second period of plants operating at EPU levels. extended operation.

50 FERC Inspections of Existing program is credited. Ongoing FERC No. 405 the Conowingo NUREG-2191 Hydroelectric Plant Section XI.S7 (Dam)

Appendix R R-124 Rev. 29, APRIL 2023

  • The dates for the start of the respective second periods of extended operation for Peach Bottom Atomic Power Station, Units 2 and 3 are:

Peach Bottom Atomic Power Station Unit 2: August 8, 2033 / Peach Bottom Atomic Power Station Unit 3: July 2, 2034

Retrieved from "https://kanterella.com/w/index.php?title=ML23110A210&oldid=3591322"