L-24-178, License Renewal Application Revision O - Supplement 4
| ML24221A093 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 08/08/2024 |
| From: | Penfield R Vistra Operations Company |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| L-24-178 | |
| Download: ML24221A093 (1) | |
Text
L-24-178 August 8, 2024 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Perry Nuclear Power Plant, Unit No. 1 Docket No. 50-440, License No. NPF-58 Perry Nuclear Power Plant Rod L. Penfield Site Vice President 10 Center Road Perry, Ohio 44081 10 CFR 54 License Renewal Application for the Perry Nuclear Power Plant Revision O -Supplement 4
REFERENCES:
- 1. Letter L-23-146, from Rod L. Penfield to the Nuclear Regulatory Commission, dated July 3, 2023, submitting the Perry Nuclear Power Plant License Renewal Application Revision 0, (ADAMS Accession No. ML23184A081)
- 2. Nuclear Regulatory Commission Letter from Lauren K. Gibson to Rod L. Penfield, Perry Nuclear Power Plant, Unit No. 1 dated September 25, 2023-Aging Management Audit Plan Regarding the License Renewal Application Review, (ADAMS Accession No. ML232618019)
- 3. Letter L-24-109, from Rod L. Penfield to the Nuclear Regulatory Commission, dated May 30, 2024, submitting the Perry Nuclear Power Plant License Renewal Application Revision 0, Supplement 1 (ADAMS Accession No. ML24151A637).
- 4. Letter L-24-020, from Rod L. Penfield to the Nuclear Regulatory Commission, dated June 27, 2024, submitting the Perry Nuclear Power Plant License Renewal Application Revision 0, Supplement 2 (ADAMS Accession No. ML24180A010).
- 5. Letter L-24-110, from Rod L. Penfield to the Nuclear Regulatory Commission, dated July 3, 2024, submitting 10 CFR 54.21(b) Annual Amendment to the Perry Nuclear Power Plant License Renewal Application (ADAMS Accession No. ML24185A092).
6555 SIERRA DRIVE IRVING. TEXAS 75039 o 214-812-4600 VISTRACORP COM
Perry Nuclear Power Plant L-24-178 Page 2 of 3
- 6. Letter L-24-108, from Rod L. Penfield to the Nuclear Regulatory Commission, dated July 24, 2024, submitting the Perry Nuclear Power Plant License Renewal Application Revision 0, Supplement 3 (ADAMS Accession No. ML24206A150).
In Reference 1, Energy Harbor Nuclear Corp, submitted a license renewal application (LRA) for the Facility Operating License for Perry Nuclear Power Plant, Unit No. 1 (PNPP). Since submittal of the LRA, the PNPP Facility Operating License has been transferred to Vistra Operations Company LLC (VistraOps) per conforming license Amendment 203 and the license transfer transaction was closed on March 1, 2024 (EPID L-2024-LLM-0000). The license transfer changes impacting the PNPP LRA are documented in Reference 5, which is the annual amendment required by 10 CFR 54.21(b).
During the Nuclear Regulatory Commission (NRC) staff's aging management audit of the PNPP LRA (Reference 2), PNPP Staff agreed to supplement the LRA with clarifying information which has led to several LRA supplements. In Reference 3, VistraOps submitted the first supplement (Supplement 1) to the PNPP LRA that provided clarifying information for the electrical and Time Limited Aging Analysis (TLAA) portion of the LRA addressed via the audit and breakout discussions with the NRC auditors. In Reference 4, VistraOps submitted the second supplement (Supplement 2) to the PNPP LRA that provided clarifying information for the mechanical portion of the LRA addressed via the audit and breakout discussions with the NRC auditors. In Reference 6, VistraOps submitted the third supplement (Supplement 3) to the PNPP LRA that provided clarifying information for the civil/structural portion of the LRA addressed via the audit and breakout discussions with the NRC auditors.
The attachments to this letter provides PNPP LRA Supplement 4 with the clarifying information related to the selective leaching aging management program and other updates of the LRA as addressed via the audit and breakout discussions with the NRC auditors.
For ease of reference, an index listing the supplemented LRA sections and tables and the associated attachments is provided. In each attachment the changes are described along with the affected section(s) and page number(s) of the LRA (Reference 1 ). For clarity, supplemented information is indicated by, red, bolded and underlined text and text to be deleted is indicated by strikethrough. Revisions to LRA tables may be shown by providing excerpts from each affected table.
The commitments provided in the PNPP LRA Appendix A (Table A.3) that are supplemented are indicated in the attachments.
If there are any questions or if additional information is required, please contact Mr. Mark Bensi, PNPP License Renewal Manager at (440) 280-6179 or via email at Mark.Bensi@vistracorp.com.
Perry Nuclear Power Plant L-24-178 Page 3 of 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on August 8, 2024.
Sincerely,
--;t}o( lr.,,..,,,IVV"'l Rod L. Penfield Attachments:
PNPP LRA Supplement 4 - Attachments for Selective Leaching Program Update and Other Supplemented PNPP LRA Sections and Tables cc: NRC Region Ill Administrator NRC Resident Inspector NRR Project Manager Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)
Utility Radiological Safety Board
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachments Index Page 1 of 3 PNPP LRA Supplement 4 Attachments Index for Selective Leaching Program Update and Other Supplemented LRA Sections and Tables Attachment No.
LRA Section, Table or Appendix Supplemented Subject Source 1
Table of Contents Update for addition of new plant specific Selective Leaching Program Applicant Initiated 2
Section 2.1.1.3.5 Clarification for 125 VDC circuits Applicant Initiated 3
Section 2.3.3.45 Table 2.3.3-45 Plant Radiation Monitoring and Process Monitoring update Applicant Initiated 4
Table 3.3.1 Update for addition of plant new plant specific Selective Leaching Program Applicant Initiated 5
Section 3.3.2.1.22 Table 3.3.2-22 Update for addition of plant new plant specific Selective Leaching Program Applicant Initiated 6
Section 3.3.2.1.24 Table 3.3.2-24 Editorial corrections and incorporation of new plant specific Selective Leaching Program Applicant Initiated 7
Section 3.3.2.1.47 Table 3.3.2-47 Update for addition of plant new plant specific Selective Leaching Program Applicant Initiated 8
Section 3.3.2.1.45 Table 3.3.2-45 Plant Radiation Monitoring and Process Monitoring update Applicant Initiated 9
Not Used Not Used Not Used 10 Table A.1 Update for addition of plant new plant specific Selective Leaching Program Applicant Initiated 11 Section A.1.42 Update for addition of plant new plant specific Selective Leaching Program Applicant Initiated
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachments Index Page 2 of 3 Attachment No.
LRA Section, Table or Appendix Supplemented Subject Source 12 Section A.1.45 Update for addition of plant new plant specific Selective Leaching Program Applicant Initiated 13 Table A.3 Update for addition of plant new plant specific Selective Leaching Program Applicant Initiated 14 Table B.1-1 Update for addition of plant new plant specific Selective Leaching Program Applicant Initiated 15 Table B.1-2 Update for addition of plant new plant specific Selective Leaching Program Applicant Initiated 16 Section B.2.24 Update for Fuse Holder Program Applicant Initiated 17 Section B.2.42 Update for addition of plant new plant specific Selective Leaching Program Applicant Initiated 18 Section B.2.45 Update for addition of plant new plant specific Selective Leaching Program Applicant Initiated
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachments Index Page 3 of 3 Key for Attachments:
LRA = License Renewal Application TRP = Technical Review Package from NRC aging management audit inquiry S&S = NRC Scoping and Screening audit inquiry Each of the attachments provides a description of the change and the resulting LRA changes.
As described in the cover letter, the attachments reflect the Perry Nuclear Power Plant LRA changes made via the following Vistra correspondence:
- 1. LRA Supplement 1 (Vistra Letter L024-109)
Therefore, the LRA changes made as a result of this supplement (Supplement 4) build on and are made on clean LRA pages that reflect the previously docketed Vistra correspondence listed above.
For clarity, consistent with LRA Supplements 1, 2, 3, and the Annual Update, changes are indicated by, red, bolded and underlined text and text to be deleted is indicated by strikethrough. Revisions to LRA tables may be shown by providing excerpts from each affected table, i.e., only the affected parts of the table may be included in the attachment.
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 1 Page 1 of 4 LRA Section: Preface, Table of Contents LRA Page Number(s): xxiv and xxviii
References:
Applicant Initiated Description of Change: The PNPP LRA Table of Contents is revised to reflect inclusion of new Section A.1.45 and B.2.45. Both new sections address the new Plant-Specific Periodic Inspections for Selective Leaching Program.
PNPP LRA Preface, Table of Contents, Pages xxiv and xxviii are revised as follows:
NOTE: Only the portion of the Table of Contents (TOC) on LRA pages xxiv and xxviii have been included. The remainder of the TOC is unchanged.
Page xxiv A.1.25 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program.............................................................. A-27 A.1.26 Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Program.............................. A-28 A.1.27 Internal Coatings/Linings for In Scope Piping, Piping Components, Heat Exchangers, and Tanks Program.......... A-29 A.1.28 Lubricating Oil Analysis Program................................................................. A-29 A.1.29 Masonry Walls Monitoring Program........................................................... A-30 A.1.30 Monitoring of Neutron Absorbing Materials Other Than Boraflex Program................................................................................................ A-30 A.1.31 Non-EQ Cable Connections Program........................................................... A-31 A.1.32 Non-EQ Inaccessible Power Cables Program........................................... A-31 A.1.33 Non-EQ Instrumentation Circuits Test Review Program.................... A-32 A.1.34 Non-EQ Insulated Cables and Connections Program........................... A-33 A.1.35 One Time Inspection Program....................................................................... A-34
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 1 Page 2 of 4 A.1.36 One Time Inspection of ASME Code Class 1 Small Bore Piping Program.................................................................................................... A-35 A.1.37 Open Cycle Cooling Water System Program............................................ A-36 A.1.38 Protective Coating Monitoring and Maintenance Program............... A-36 A.1.39 Reactor Head Closure Stud Bolting Program........................................... A-37 A.1.40 Reactor Vessel Surveillance Program......................................................... A-38 A.1.41 RG 1.127, Inspection of Water Control Structures Associated with Nuclear Power Plants Program................................... A-39 A.1.42 Selective Leaching Program............................................................................ A-40 A.1.43 Structures Monitoring Program.................................................................... A-41 A.1.44 Water Chemistry Program............................................................................... A-45 A.1.45 PlantSpecific Periodic Inspections for Selective Leaching Program.. A45 A.2 Evaluation Summaries of Time Limited Aging Analyses................................. A-46 A.2.1 Introduction.............................................................................................................. A-46 A.2.2 Reactor Vessel Neutron Embrittlement Analyses.................................... A-46 A.2.2.1 Neutron Fluence.................................................................................... A-46 A.2.2.2 Upper Shelf Energy............................................................................... A-47
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 1 Page 3 of 4 Page xxviii B.2.21 Fire Water System Program......................................................................... B-70 B.2.22 Flow Accelerated Corrosion Program...................................................... B-74 B.2.23 Fuel Oil Chemistry Program.......................................................................... B-76 B.2.24 Fuse Holders Program..................................................................................... B-79 B.2.25 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program........................................................... B-80 B.2.26 Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Program..................................................... B-82 B.2.27 Internal Coatings/Linings for In Scope Piping, Piping Components, Heat Exchangers, and Tanks Program............ B-84 B.2.28 Lubricating Oil Analysis Program................................................................ B-86 B.2.29 Masonry Walls Monitoring Program.......................................................... B-88 B.2.30 Monitoring of Neutron Absorbing Materials Other Than Boraflex Program................................................................................... B-90 B.2.31 Non-EQ Cable Connections Program......................................................... B-91 B.2.32 Non-EQ Inaccessible Power Cables Program......................................... B-93 B.2.33 Non-EQ Instrumentation Circuits Program............................................. B-95 B.2.34 Non-EQ Insulated Cables and Connections Program........................... B-97 B.2.35 One Time Inspection Program....................................................................... B-99 B.2.36 One Time Inspection of ASME Code Class 1 Small Bore Piping Program.................................................................................................. B-101 B.2.37 Open Cycle Cooling Water System Program.......................................... B-103 B.2.38 Protective Coating Monitoring and Maintenance Program............ B-107 B.2.39 Reactor Head Closure Stud Bolting Program...................................... B-109 B.2.40 Reactor Vessel Surveillance Program....................................................... B-111 B.2.41 RG 1.127, Inspection of Water Control Structures
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 1 Page 4 of 4 Associated with Nuclear Power Plants Program................................ B-113 B.2.42 Selective Leaching Program......................................................................... B-117 B.2.43 Structures Monitoring Program................................................................. B-119 B.2.44 Water Chemistry Program............................................................................ B-126 B.2.45 PlantSpecific Periodic Inspections for Selective Leaching Program.B130
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 2 Page 1 of 1 LRA Section: 2.1.1.3.5 LRA Page Number(s): 2.1-12
References:
Applicant Initiated Description of Change: Provide clarification that the 125 VDC circuits are described in Table 2.2-3.
PNPP LRA Section 2.1.1.3.5, Page 2.1-12 is revised as follows:
2.1.1.3.5 Station Blackout (10 CFR 50.63) 10 CFR 50.63 [Reference 1.3-7], requires that each light-water-cooled nuclear power plant be able to withstand, for a specified duration, and recover from a station blackout (SBO). An SBO is the loss of offsite and onsite AC electric power to the essential and nonessential switchgear buses in a nuclear power plant. It does not include the loss of AC power fed from inverters powered by station batteries or by alternate AC sources. The objective of this requirement is to assure that nuclear power plants can withstand an SBO while maintaining adequate reactor core cooling and containment integrity for the specified duration.
Appendix 15H of the UFSAR describes the licensing bases for SBO at the Perry Nuclear Power Plant (PNPP). PNPP has developed a four-hour coping analysis to address the requirements of 10 CFR 50.63. Based on the PNPP current licensing bases for SBO, structure and system intended functions performed in support of 10 CFR 50.63 requirements were determined. The results of this determination are provided for mechanical systems in Section 2.3, for structures in Section 2.4, and electrical commodities in Section 2.5.
For Station Blackout Recovery, the license renewal scoping boundary is extended to the first interconnection device that would restore offsite power to the main switchyard busses and the step-up station transformer (startup transformers). At PNPP, the boundary with the offsite transmission system has been defined at the 345kV switchyard circuit breakers: breakers S-612, S-620, S-621, S-650, S-652, S-660 and S-661. Scoping boundary drawing 206-0010 (Figure 2.1-1) shows the Station Blackout Recovery boundary in red. This boundary definition is consistent with NUREG-1800 [Reference 1.3-9], Section 2.1.3.1.
The 125 VDC control circuits for the switchyard boundary breakers, and their protective structures are included in scope and subject to aging management review. These circuits are identified in Table 2.2-3 System S42 (reference UFSAR 8.2.2.1.f).
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 3 Page 1 of 8 LRA Section: 2.3.3.45, Table 2.3.3-45 LRA Page Number(s): 2.3-150 through 2.3-156
References:
Applicant Initiated Description of Change: While reviewing a revision to the Plant Radiation Monitoring and Process Monitoring Maintenance Rule Basis Document, it was identified that some of the non-safety related radiation monitors have sampling lines and internal components that would also perform a passive pressure boundary function for the Control Room Envelope and/or the Secondary Containment boundary. As a result, the scoping for the system was revised to reflect the revised system boundary and additional 10 CFR 54.4(a)(2) system functions.
PNPP LRA Section 2.3.3.45, Pages 2.3-150 through 2.3-156, discussion text is revised:
Note: Additional shading was added in the Ventilation Systems section of the table included in the LRA section. This additional shading is denoted by a RED box.
2.3.3.45 Plant Radiation Monitoring and Process Monitoring D17),
and Post Accident Radiation Monitoring (D19)
System Description
This system consists of airborne radiation monitors, gaseous process and effluent radiation monitors, liquid process and effluent radiation monitors, and post-accident radiation monitors. The intermediate building ventilation system (M33) flow straighteners in the Unit 1 and 2 plant Vents are also evaluated within this system.
Airborne radiation monitoring:
An airborne radiation monitor typically consists of a particulate measuring channel, an iodine measuring channel and a gas measuring channel. A representative sample of air from a ventilation duct is drawn through a sample line to the airborne monitor unit by means of an air blower. Sampling of the ducts is achieved using an isokinetic sample probe placed in the air stream. The sample passes through a particulate, iodine and gas channel in series. Each channel is independent. In the particulate channel, the sample air passes through a fixed or
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 3 Page 2 of 8 moving filter which collects particulates and is monitored by a beta scintillation detector, the output of which is pre-amplified and transmitted to a ratemeter located in the control room. In the iodine channel, the sample passes through an activated charcoal cartridge which traps the radioactive iodine. The gas is exhausted back to the ventilation duct. Differential pressure switches across the filter and charcoal cartridges are provided to give a low flow alarm at the unit and in the control room.
Gaseous process and effluent monitoring:
Gaseous process monitors are provided for detecting and monitoring radiation levels in certain plant process streams.
The Gaseous effluent units monitor a sample of the effluent discharge for particulate, iodine and gas radioactivity and provide samples of the collected particulate and halogen for laboratory analysis. For the unit vents a representative sample is continuously extracted from each plant vent through an isokinetic probe. The sample is supplied through a 1-inch sample line which is also used to supply a representative sample to the post-accident effluent radiation monitors. For the offgas and turbine building/heater bay vents a representative sample is continuously extracted from the vent pipe downstream of the exhaust fans.
Liquid process and effluent radiation monitoring:
These units monitor the gamma radiation levels of liquid process and effluent streams. With the exception of the radwaste system effluent, the streams monitored normally contain only background levels of radioactive materials.
Increases in radiation level may be indicative of heat exchanger leakage or equipment malfunction.
For each liquid monitoring location, except for the underdrain system, a continuous sample is extracted from the liquid process pipe, passed through a liquid sample panel which contains a detection assembly for gross gamma radiation monitoring, and returned to the process pipe. The detection assembly consists of a scintillation detector mounted in a shielded sample chamber equipped with a check source. A ratemeter in the control room displays the measured gross radiation level and the analog signal is recorded.
Post-accident radiation monitoring:
Some monitors are designated and installed as post-accident radiation instruments. They provide radiation level readings and alarm functions. These monitors include area monitors, vent radioactive gas release monitors and area airborne activity monitors.
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 3 Page 3 of 8 System Boundary System components subject to aging management review include the following, as shown on LR boundary drawings:
Safety-related post-accident effluent radiation monitors.
Safety-related air sample piping and the attached nonsafety air sample piping up to an equivalent anchor for the containment and drywell atmosphere monitors,
Nonsafety-related (liquid) sample piping, valves, pumps and monitor equipment for the ADHR service water, radwaste effluent to ESW, NCC, and ESW loops A and B monitors.
Non-safety related sample piping, valves, and pumps associated with radiation monitors for the Annulus Exhaust Gas Treatment system and the Control Room HVAC and Emergency Recirculation system.
Other radiation monitors either have no passive mechanical components, or do not perform a function corresponding to the criteria in 10 CFR 54.4.
System Functions (and scoping criteria, if intended function)
The system is within the scope of license renewal because it contains safety-related components that are relied upon to remain functional during or following a design basis event, because it contains nonsafety-related components whose failure could prevent accomplishment of a safety-related function, and because it is relied on to perform functions that demonstrates compliance with the regulations for EQ.
Safety-related piping provides system pressure boundary integrity. [10 CFR 54.4(a)(1)] Containment isolation limits radiological release. [10 CFR 54.4(a)(1)]
Indication from the intermediate building ventilation safety related flow elements (straighteners) is used together with the Unit 1 & 2 plant vent radiation monitors to establish a release rate. [10 CFR 54.4(a)(1)]
The integrity of nonsafety-related, fluid-retaining components in safety-related area(s) prevents interactions that could affect safety-related SSCs. [10 CFR 54.4(a)(2)]
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 3 Page 4 of 8 Nonsafety-related piping provides pressure boundary integrity for the Control Room Envelope and Secondary Containment. [10 CFR 54.4(a)(2)]
Nonsafety-related piping up to and including the first equivalent anchor beyond safety/nonsafety interface(s) provides mechanical support for safety-related SSCs. [10 CFR 54.4(a)(2)]
The system contains components within the scope of 10 CFR 50.49. [10 CFR 54.4(a)(3)
- EQ]
Plant radiation monitoring provides actuation logic to limit radiological release.
[10 CFR 54.4(a)(1) applicable only to active electrical components]
Process radiation monitoring systems are provided to monitor and control radioactivity in process and effluent streams and to activate appropriate alarms and controls.
Provide the capability to detect an offgas system failure by an alarmed increase in activity at the plant vent.
Component Types Subject to Aging Management Review Table 2.3.3-45 lists the component types that require aging management review and their intended functions and Table 2.3.3-45a summarizes the scoping determination for individual monitors.
Table 3.3.2-45, Auxiliary Systems - Plant Radiation Monitoring and Process Monitoring and Post Accident Radiation Monitoring System - Summary of Aging Management Evaluation, provides the results of the aging management review.
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 3 Page 5 of 8 Table 2.3.3-45 Plant Radiation Monitoring and Process Monitoring and Post Accident Radiation Monitoring Component Types Subject to Aging Management Review Component Type Intended function Bolting Leakage boundary, Pressure boundary, Structural integrity Detector housing Leakage boundary, Pressure boundary Filter housing Pressure boundary Flexible hose Leakage boundary Flow element Pressure boundary Flow straightener Pressure boundary Piping Leakage boundary, Pressure boundary, Structural integrity Pump casing Leakage boundary, Pressure boundary Valve body Leakage boundary, Pressure boundary, Structural integrity Table 2.3.3-45a Scoping Determination for Individual Plant Monitors The following table summarizes the scoping determination for individual monitors. The safety-related [(a)(1)] determination was based on quality classification. The [(a)(2)] determination was based on location of fluid-filled components. The (a)(2) determination was also based on providing a boundary function for either the Control Room Envelope or Secondary Containment for ventilation systems radiation monitors. The [(a)(3)] EQ function was determined based on the SAP EQ classification. No CLB (a)(2) or (a)(3) function other than EQ has been identified by review of UFSAR and regulated event bases. Only the shaded monitors have passive components that are within scope.
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 3 Page 6 of 8 Monitor Passive
?
(a)(1)
(a)(2)
(a)(3)
Drawing EFFLUENT Offgas Vent Pipe 1D17K0830 Y
N N
N 806-0008 Unit 1 Plant Vent 1D17K0780 Y
N N
N 806-0007 Unit 2 Plant Vent 2D17K0780 Y
N N
N 856-0007 Turbine Building/
Heater Bay 1D17K0850 Y
N N
N 806-0023 VENTILATION SYSTEMS Containment Vessel and Drywell Purge Exhaust 1D17K0660 Y
N N
N 806-0006 Annulus Exhaust Train A 1D17K0690A Y
N Y
N 806-0006 Annulus Exhaust Train B 1D17K0690B Y
N Y
N 806-0006 Control Room HVAC and Emerg Recirc 0D17K0770 Y
N Y
N 806-0005 Radwaste Building Ventilation Exhaust 0D17K0720 Y
N N
N 806-0003 Intermediate Building Ventilation Exhaust 0D17K0730 Y
N N
N 806-0003 Offgas Building Ventilation Exhaust 1D17K0760 Y
N N
N 806-0004 Auxiliary Building Ventilation Exhaust 1D17K0700 Y
N N
N 806-0004
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 3 Page 7 of 8 Monitor Passive
?
(a)(1)
(a)(2)
(a)(3)
Drawing Fuel Handling Building Ventilation Exhaust 0D17K0710 Y
N N
N 806-0005 ATMOSPHERE (No Ventilation Train)
Drywell Atmosphere 1D17K0670 Y
Y N
Y 806-0004 Containment Atmosphere 1D17K0680 Y
Y N
Y 806-0007 Miscellaneous Steam Packing Exhauster 1D17K0840 N
N N
N 806-0008 Process Monitors ESW Loop A 1D17K0604 Y
N Y
N 806-0010 ESW Loop B 1D17K0605 Y
N Y
N 806-0010 Radwaste to ESW 0D17K0606 Y
N Y
N 806-0009 NCC 0D17K0607 Y
N Y
N 806-0009 ADHR Serv Wtr 1D17K0608 Y
N Y
N 806-0009 Offgas Pre-treatment 1D17K0612 Y
N N
N 806-0018 Offgas Post-treatment A 1D17K0601A Y
N N
N 806-0019 Offgas Post-treatment B 1D17K0601B Y
N N
N 806-0019 Containment Ventilation Exhaust A-D 1D17K0609A-D N
Y N
N 912-0604 806-0024 Main Steam Line A-D 1D17K0610A-D N
Y N
Y 806-0024 Carbon Bed Vault A 1D17K0611A N
N N
N 806-0025 Carbon Bed Vault B 1D17K0611B N
N N
N 806-0025 Underdrain Manhole 23 0D17K0820A N
N N
N 806-0017
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 3 Page 8 of 8 Monitor Passive
?
(a)(1)
(a)(2)
(a)(3)
Drawing Underdrain Manhole 20 0D17K0820B N
N N
N 806-0017 Post-Accident Monitors Drywell & Rx Bldg A
1D19K0100 N
Y N
Y 806-0033 Drywell & Rx Bldg B
1D19K0200 N
Y N
Y 806-0033 TSC Area 1D19K0650 N
N N
N 806-0034 Plant Vent Gas (Unit
- 1) 1D19K0300 Y
Y N
N 806-0033 Off-Gas Vent Gas 1D19K0400 Y
Y N
N 806-0033 Turb/Heater Bay Vent Gas 1D19K0500 Y
Y N
N 806-0033 Plant Vent Gas (Unit
- 2) 2D19K0300 Y
Y N
N 856-0033 TSC Airborne 0D19K0600 Y
N N
N 806-0034 References UFSAR: 1.2.2.10.1, 15.7.1.1.2.b, 11.5, 12.3.4 License Renewal Drawings: 806-0004, 806-0005, 806-0006, 806-0007, 806-0009, 806-0010, 806-0033, 856-0033, 912-0613
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 4 Page 1 of 3 LRA Section: Table 3.3.1 LRA Page Number(s): 3.3-107
References:
Applicant Initiated Description of Change: The purpose of NUREG-1801, XI.M33 is to demonstrate the absence of selective leaching. The program for selective leaching of materials ensures the integrity of the components made of gray cast iron and copper alloys (except for inhibited brass) that contain greater than 15 percent zinc (> 15% Zn) or greater than 8 percent aluminum (>8% Al in the case of aluminum-bronze) exposed to a raw water, closed cooling water, treated water, or ground water environment that may lead to selective leaching of one of the metal components where there has not been previous experience of selective leaching. Program scope states For materials and environments where selective leaching is currently occurring, a plant-specific program is required. Plant-specific OE CR-2024-02317 identifies specific instances of selective leaching occurring at PNPP.
PNPP LRA Table 3.3.1, Page 3.3-107 is revised:
Note: Only those table rows with revised text are included in the following table. Table rows unaffected by these changes are omitted from this attachment,
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 4 Page 2 of 3 Table 3.3.1 Summary of Aging Management Evaluations for the Auxiliary Systems Item Number Component Aging Effect/Mechanism Aging Management Programs Further Evaluation Recommended Discussion 3.3.1-72 (LR-ISG-2012-02)
(>15% Zn or >8%
Al) Piping, piping components, and piping elements, Heat exchanger components exposed to Treated water, Closed-cycle cooling water, Soil, Raw water Loss of material due to selective leaching Chapter XI.M33, Selective Leaching No Consistent with NUREG-1801 (as modified by LR-ISG-2012-02) and with someone program exceptions and the following clarifications. The Selective Leaching program will manage loss of material due to selective leaching for gray cast iron, ductile iron and copper alloy
(>15% Zn) components exposed to treated water, closed-cycle cooling water, soil, raw water, waste water, or condensation.
Evidence of selective leaching was found in three material/environment populations including gray cast iron exposed to raw water and soil and ductile iron exposed to soil. See Section B.2.45 for the Plant-Specific Inspections for Selective Leaching Program for those populations. In addition, to the Auxiliary systems, gray cast iron heat exchanger components exposed to Closed-cycle cooling water and gray cast iron heat exchanger, strainer body, valves, and ductile iron pump casing exposed to condensation in the Off Gas system are also aligned
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 4 Page 3 of 3 Table 3.3.1 Summary of Aging Management Evaluations for the Auxiliary Systems Item Number Component Aging Effect/Mechanism Aging Management Programs Further Evaluation Recommended Discussion to this row. Also, copper alloy
>15% zinc (brass), pressure regulators exposed to treated water in the Nuclear Boiler system are aligned with this row. See Appendix B Section B.2.421 for Selective Leaching program exceptions to NUREG-1801.
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 5 Page 1 of 6 LRA Section: 3.3.2.1.22 and Table 3.3.2-22 LRA Page Number(s): 3.3-29, 3.3-287 through 3.3-289
References:
Applicant Initiated Description of Change: A new aging management program, Plant-Specific Periodic Inspections for Selective Leaching Program, will manage the selective leaching for Gray cast iron components exposed to Raw water since selective leaching has occurred in a different system for this material environment combination. There are no ductile iron components in this system subject to aging management. Prior changes to Table 3.3.2-22 made by PNPP Licensing letter L-24-020 are included but not shown as a change here.
PNPP LRA Section 3.3.2.1.22 is changed to read:
Materials Emergency Service Water Screen Wash system components are constructed of the following materials:
Gray cast iron
Stainless steel
Steel Environments Emergency Service Water Screen Wash system components are exposed to the following environments:
Air - indoor, uncontrolled
Lubricating oil
Raw water Aging Effects Requiring Management The following aging effects associated with the Emergency Service Water Screen Wash system require management:
Loss of material
Loss of preload
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 5 Page 2 of 6 Aging Management Programs The following aging management programs manage the effects of aging on Emergency Service Water Screen Wash system components:
Bolting Integrity (B.2.7)
External Surfaces Monitoring of Mechanical Components (B.2.18)
Lubricating Oil Analysis (B.2.28)
One-Time Inspection (B.2.35)
Open-Cycle Cooling Water System (B.2.37)
Plant-Specific Periodic Inspections for Selective Leaching (B.2.45)
Selective Leaching (B.2.42)
PNPP LRA Table 3.3.2-22, Page 3.3-288, is revised as follows:
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 5 Page 3 of 6 Table 3.3.2-22 Auxiliary Systems - Emergency Service Water Screen Wash Summary of Aging Management Evaluation Table 3.3.2 Emergency Service Water Screen Wash System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801Item Table 1 Item Notes 1
Bolting Pressure boundary Steel Air -
- indoor, uncontrolle d(Ext)
Loss of material Bolting Integrity VII.I.AP-125 3.3.1-12 B
2 Bolting Pressure boundary Steel Air -
- indoor, uncontrolle d(Ext)
Loss of preload Bolting Integrity VII.I.AP-124 3.3.1-15 B
3 Bolting Pressure boundary Steel Raw water (Ext)
Loss of material Bolting Integrity VII.C1.AP-183 3.3.1-38 E
4 Bolting Pressure boundary Steel Raw water (Ext)
Loss of preload Bolting Integrity VII.I.AP-264 3.3.1-15 B
5 Nozzle Flow control Stainles s steel Air -
- indoor, uncontrolle d(Ext)
None None VII.J.AP-17 3.3.1-120 A
6 Nozzle Flow control Stainles s steel Raw water (Int)
Loss of material Open-Cycle Cooling Water System VII.C1.A-54 3.3.1-40 A
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 5 Page 4 of 6 Table 3.3.2 Emergency Service Water Screen Wash System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801Item Table 1 Item Notes 7
Piping Leakage boundary Stainles s steel Air - indoor, uncontrolled(
Ext)
None None VII.J.AP-17 3.3.1-120 A
8 Piping Leakage boundary Stainles s steel Raw water (Int)
Loss of material Open-Cycle Cooling Water System VII.C1.A-54 3.3.1-40 A
9 Piping Pressure boundary Stainles s steel Air -
- indoor, uncontrolle d(Ext)
None None VII.J.AP-17 3.3.1-120 A
10 Piping Pressure boundary Stainles s steel Lubricatin g oil (Int)
Loss of material Lubricating Oil Analysis and One-Time Inspection VII.C1.AP-138 3.3.1-100 A
11 Piping Pressure boundary Stainles s steel Raw water (Int)
Loss of material Open-Cycle Cooling Water System VII.C1.A-54 3.3.1-40 A
12 Piping Pressure boundary Steel Air -
- indoor, uncontrol led(Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
13 Piping Pressure boundary Steel Raw water (Int)
Loss of material Open-Cycle Cooling Water System VII.C1.AP-194 (LR-ISG-2013-01) 3.3.1-37 A
14 Pump casing (Bowl)
Pressure boundary Stainles s steel Raw water (Ext)
Loss of material Open-Cycle Cooling Water System VII.C1.A-54 3.3.1-40 A
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 5 Page 5 of 6 Table 3.3.2 Emergency Service Water Screen Wash System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801Item Table 1 Item Notes 15 Pump casing (Bowl)
Pressure boundary Stainles s steel Raw water (Int)
Loss of material Open-Cycle Cooling Water System VII.C1.A-54 3.3.1-40 A
16 Pump casing (Column)
Pressure boundary Steel Air -
- indoor, uncontrol led(Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
17 Pump casing (Column)
Pressure boundary Steel Raw water (Ext)
Loss of material Open-Cycle Cooling Water System VII.C1.AP-194 (LR-ISG-2013-01) 3.3.1-37 A
18 Pump casing (Column)
Pressure boundary Steel Raw water (Int)
Loss of material Open-Cycle Cooling Water System VII.C1.AP-194 (LR-ISG-2013-
- 01) 3.3.1-37 A
19 Strainer body Pressure boundary Gray cast iron Air -
- indoor, uncontrol led(Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
20 Strainer body Pressure boundary Gray cast iron Raw water (Int)
Loss of material Open-Cycle Cooling Water System VII.C1.AP-194 (LR-ISG-2013-01) 3.3.1-37 A
21 Strainer body Pressure boundary Gray cast iron Raw water (Int)
Loss of material Plant-Specific Periodic Inspections for Selective Leaching Selective Leaching VII.C1.A-51(LR-ISG-2012-02) 3.3.1-72 BE 22 Traveling screen Filtration Stainles s steel Raw water (Ext)
Loss of material Open-Cycle Cooling Water System VII.C1.A-54 3.3.1-40 A
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 5 Page 6 of 6 Table 3.3.2 Emergency Service Water Screen Wash System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801Item Table 1 Item Notes 23 Valve body Pressure boundary Stainles s steel Air -
- indoor, uncontrol led(Ext)
None None VII.J.AP-17 3.3.1-120 A
24 Valve body Pressure boundary Stainles s steel Lubricati ng oil (Int)
Loss of material Lubricating Oil Analysis and One-Time Inspection VII.C1.AP-138 3.3.1-100 A
25 Valve body Pressure boundary Steel Air -
- indoor, uncontrol led(Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
26 Valve body Pressure boundary Steel Raw water (Int)
Loss of material Open-Cycle Cooling Water System VII.C1.AP-194 (LR-ISG-2013-01) 3.3.1-37 A
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 1 of 31 LRA Section: 3.3.2.1.24 and Table 3.3.2-24 LRA Page Number(s): 3.3-30 through 3.3-32, and 3.3-292 through 3.3-314
References:
Applicant Initiated Description of Change: Section 3.3.2.1.24 and Table 3.3.2-24 are revised to:
Corrected editorial errors in Section 3.3.2.1.24 to reflect aging management programs and aging effects requiring management to align with Table 3.3.2-24.
Provide additional detail on the materials susceptible to selective leaching.
Incorporate a new aging management program, Plant-Specific Periodic Inspections for Selective Leaching Program, which is being developed to manage the material/environment combinations where selective leaching has occurred.
In LRA Table is 3.3.2-24, added ductile iron to the component type names to distinguish between Gray Cast Iron and Ductile Iron. Previously, ductile iron was identified by searching the Material column for Gray Cast Iron and reading the custom note, for example 331.
Note: Prior changes to Section 3.3.2.1.24 and Table 3.3.2-24 made by PNPP Licensing letter L-24-020 are included but not shown as a change here.
PNPP LRA Chapter 3, Section 3.3.2.1.24, Page 3.3-31 and 3.3-32, is revised as follows:
3.3.2.1.24 Fire Protection Materials Fire Protection system components are constructed of the following materials:
Copper alloy <15% Zn
Copper alloy >15% Zn
Fiberglass
Glass
Gray cast iron
Gray cast iron with internal coating/lining
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 2 of 31
Polymers
Stainless steel
Steel Environments Fire Protection system components are exposed to the following environments:
Air - indoor, uncontrolled
Air - outdoor
Closed-cycle cooling water
Condensation
Diesel exhaust
Fuel oil
Gas
Lubricating oil
Raw water
Soil Aging Effects Requiring Management The following aging effects associated with the Fire Protection system require management:
Change in mechanical properties (cracking, loss of strength), Blistering
Cracking
Cumulative fatigue damage
Flow blockage
Loss of coating or lining integrity
Loss of material
Loss of preload
Reduction of heat transfer
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 3 of 31 Aging Management Programs The following aging management programs manage the effects of aging on Fire Protection system components:
Bolting Integrity (B.2.7)
Buried and Underground Piping and Tanks (B.2.8)
External Surfaces Monitoring of Mechanical Components (B.2.18)
Fire Protection (B.2.20)
Fire Water System (B.2.21)
Fuel Oil Chemistry (B.2.23)
Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.25)
Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks (B.2.27)
Lubricating Oil Analysis (B.2.28)
Plant-Specific Periodic Inspections for Selective Leaching (B.2.45)
One-Time Inspection (B.2.35)
Selective Leaching (B.2.42)
TLAA PNPP LRA Table 3.3.2-24, Pages 3.3-292 through 3.3-314, is revised as follows:
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 4 of 31 Table 3.3.2-24 Auxiliary Systems - Fire Protection Summary of Aging Management Evaluation Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 1
Bolting Leakage boundary Steel Air - indoor, uncontrolled (Ext)
Loss of material Bolting Integrity VII.I.AP-125 3.3.1-12 B
2 Bolting Leakage boundary Steel Air - indoor, uncontrolled (Ext)
Loss of preload Bolting Integrity VII.I.AP-124 3.3.1-15 B
3 Bolting Pressure boundary Steel Air - indoor, uncontrolled (Ext)
Loss of material Bolting Integrity VII.I.AP-125 3.3.1-12 B
4 Bolting Pressure boundary Steel Air - indoor, uncontrolled (Ext)
Loss of preload Bolting Integrity VII.I.AP-124 3.3.1-15 B
5 Bolting Pressure boundary Steel Raw water (Ext)
Loss of material Bolting Integrity VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 E
6 Bolting Pressure boundary Steel Raw water (Ext)
Loss of preload Bolting Integrity VII.I.AP-264 3.3.1-15 B
7 Bolting Pressure boundary Steel Soil (Ext)
Loss of material Buried and Underground Piping and Tanks VII.I.AP-241 3.3.1-109 B
8 Bolting Pressure boundary Steel Soil (Ext)
Loss of preload Bolting Integrity VII.I.AP-242 3.3.1-14 B
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 5 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 9
Flame arrestor Pressure boundary Aluminu m
Air - indoor, uncontrolled (Int)
None None VII.J.AP-135 3.3.1-113 A
10 Flame arrestor Pressure boundary Aluminu m
Air -
outdoor (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.AP-256 3.3.1-81 A
11 Flame arrestor Pressure boundary Copper alloy
>15% Zn Air - indoor, uncontrolled (Int)
None None VII.J.AP-144 3.3.1-114 A
12 Flame arrestor Pressure boundary Copper alloy
>15% Zn Air -
outdoor (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.AP-159 3.3.1-81 A
13 Flexible hose Pressure boundary Stainless steel Air - indoor, uncontrolled (Ext)
None None VII.J.AP-17 3.3.1-120 A
14 Flexible hose Pressure boundary Stainless steel Diesel exhaust (Int)
Cracking Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components VII.H2.AP-128 3.3.1-83 A
15 Flexible hose Pressure boundary Stainless steel Diesel exhaust (Int)
Cumulative fatigue damage TLAA N/A N/A H, 337
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 6 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 16 Flexible hose Pressure boundary Stainless steel Diesel exhaust (Int)
Loss of material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components VII.H2.AP-104 3.3.1-88 A
17 Foam chamber (Discharge outlet)
Pressure boundary Steel Air -
outdoor (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-78 3.3.1-78 A
18 Foam chamber (Discharge outlet)
Pressure boundary Steel Raw water (Int)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 D
19 Heat exchanger (Diesel fire pump HX channel)
Pressure boundary Steel Air - indoor, uncontrolled (Ext)
Loss of material Fire Water System VII.I.A-77 3.3.1-78 E
20 Heat exchanger (Diesel fire pump HX channel)
Pressure boundary Steel Raw water (Int)
Flow blockage Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 D
21 Heat exchanger (Diesel fire pump HX channel)
Pressure boundary Steel Raw water (Int)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 D
22 Heat exchanger (Diesel fire pump HX shell)
Pressure boundary Steel Air - indoor, uncontrolled (Ext)
Loss of material Fire Water System VII.I.A-77 3.3.1-78 E
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 7 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 23 Heat exchanger (Diesel fire pump HX shell)
Pressure boundary Steel Closed-cycle cooling water (Int)
Loss of material Fire Water System VII.C2.AP-189 3.3.1-46 E
24 Heat exchanger (Diesel fire pump HX tube)
Heat transfer, Pressure boundary Copper alloy
<15% Zn Closed-cycle cooling water (Ext)
Loss of material Fire Water System VII.F1.AP-203 3.3.1-46 E
25 Heat exchanger (Diesel fire pump HX tube)
Heat transfer, Pressure boundary Copper alloy
<15% Zn Closed-cycle cooling water (Ext)
Reduction of heat transfer Fire Water System VII.C2.AP-205 3.3.1-50 E
26 Heat exchanger (Diesel fire pump HX tube)
Heat transfer, Pressure boundary Copper alloy
<15% Zn Raw water (Int)
Flow blockage Fire Water System VII.G.AP-197 (LR-ISG-2012-02) 3.3.1-64 D
27 Heat exchanger (Diesel fire pump HX tube)
Heat transfer, Pressure boundary Copper alloy
<15% Zn Raw water (Int)
Loss of material Fire Water System VII.G.AP-197 (LR-ISG-2012-02) 3.3.1-64 D
28 Heat exchanger (Diesel fire pump HX tube)
Heat transfer, Pressure boundary Copper alloy
<15% Zn Raw water (Int)
Reduction of heat transfer Fire Water System VII.C1.A-72 3.3.1-42 E, 304 29 Muffler Pressure boundary Stainless steel Air - indoor, uncontrolled (Ext)
None None VII.J.AP-17 3.3.1-120 A
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 8 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 30 Muffler Pressure boundary Stainless steel Diesel exhaust (Int)
Cracking Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components VII.H2.AP-128 3.3.1-83 A
31 Muffler Pressure boundary Stainless steel Diesel exhaust (Int)
Cumulative fatigue damage TLAA N/A N/A H, 337 32 Muffler Pressure boundary Stainless steel Diesel exhaust (Int)
Loss of material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components VII.H2.AP-104 3.3.1-88 A
33 Orifice Flow restriction, Pressure boundary Stainless steel Air - indoor, uncontrolled (Ext)
None None VII.J.AP-17 3.3.1-120 A
34 Orifice Flow restriction, Pressure boundary Stainless steel Raw water (Int)
Loss of material Fire Water System VII.G.A-55 (LR-ISG-2012-02) 3.3.1-66 B
35 Orifice Flow restriction, Pressure boundary Steel Air - indoor, uncontrolled (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
36 Orifice Flow restriction, Pressure boundary Steel Raw water (Int)
Flow blockage Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 9 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 37 Orifice Flow restriction, Pressure boundary Steel Raw water (Int)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
38 Orifice Leakage boundary Steel Air - indoor, uncontrolled (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
39 Orifice Leakage boundary Steel Raw water (Int)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
40 Piping Leakage boundary Stainless steel Air - indoor, uncontrolled (Ext)
None None VII.J.AP-17 3.3.1-120 A
41 Piping Leakage boundary Stainless steel Raw water (Int)
Loss of material Fire Water System VII.G.A-55 (LR-ISG-2012-02) 3.3.1-66 B
42 Piping Leakage boundary Steel Air - indoor, uncontrolled (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
43 Piping Leakage boundary Steel Raw water (Int)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
44 Piping Leakage boundary Steel Raw water (Int)
Loss of material Fire Water System VII.G.A-400 (LR-ISG-2012-02) 3.3.1-127 E
45 Piping Pressure boundary Copper alloy
<15% Zn Air - indoor, uncontrolled (Ext)
None None VII.J.AP-144 3.3.1-114 A
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 10 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 46 Piping Pressure boundary Copper alloy
<15% Zn Fuel oil (Int)
Loss of material Fuel Oil Chemistry and One-Time Inspection VII.G.AP-132 3.3.1-69 A
47 Piping Pressure boundary Copper alloy
<15% Zn Gas (Int)
None None VII.J.AP-9 3.3.1-114 A
48 Piping Pressure boundary Fiberglas s
Raw water (Int)
Change in mechanical properties (cracking, loss of strength), Blistering Fire Water System VII.C1.AP-238 3.3.1-30x H
49 Piping Pressure boundary Fiberglas s
Raw water (Int)
Flow Blockage Fire Water System VII.C1.AP-238 3.3.1-30x H, 341 50 Piping Pressure boundary Fiberglas s
Soil (Ext)
Change in mechanical properties (cracking, loss of strength), Blistering Buried and Underground Piping and Tanks VII.C1.AP-176 3.3.1-104 H
51 Piping Pressure boundary Stainless steel Air - indoor, uncontrolled (Ext)
None None VII.J.AP-17 3.3.1-120 A
52 Piping Pressure boundary Stainless steel Raw water (Int)
Flow blockage Fire Water System VII.G.A-55 (LR-ISG-2012-02) 3.3.1-66 B
53 Piping Pressure boundary Stainless steel Raw water (Int)
Loss of material Fire Water System VII.G.A-55 (LR-ISG-2012-02) 3.3.1-66 B
54 Piping Pressure boundary Stainless steel Soil (Ext)
Cracking Buried and Underground Piping and Tanks VII.C3.A-401 (LR-ISG-2012-02) 3.3.1-128 E
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 11 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 55 Piping Pressure boundary Stainless steel Soil (Ext)
Loss of material Buried and Underground Piping and Tanks VII.C1.AP-137 (LR-ISG-2011-
- 03) 3.3.1-107 B
56 Piping Pressure boundary Steel Air - indoor, uncontrolled (Int)
Flow blockage Fire Water System VII.G.A-404 (LR-ISG-2012-02) 3.3.1-131 B
57 Piping Pressure boundary Steel Air - indoor, uncontrolled (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
58 Piping Pressure boundary Steel Air - indoor, uncontrolled (Ext)
Loss of material Fire Protection VII.G.AP-150 3.3.1-58 A
59 Piping Pressure boundary Steel Air - indoor, uncontrolled (Int)
Loss of material Fire Water System VII.G.A-404 (LR-ISG-2012-02) 3.3.1-131 B
60 Piping Pressure boundary Steel Air -
- indoor, uncontroll ed (Int)
Loss of material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components V.D2.E-29 3.2.1-44 A
61 Piping Pressure boundary Steel Air -
outdoor (Int)
Flow blockage Fire Water System VII.G.A-404 (LR-ISG-2012-02) 3.3.1-131 B
62 Piping Pressure boundary Steel Air -
outdoor (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-78 3.3.1-78 A
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 12 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 63 Piping Pressure boundary Steel Air -
outdoor (Ext)
Loss of material Fire Protection VII.I.A-78 3.3.1-78 E
64 Piping Pressure boundary Steel Air -
outdoor (Int)
Loss of material Fire Water System VII.G.A-404 (LR-ISG-2012-02) 3.3.1-131 B
65 Piping Pressure boundary Steel Closed-cycle cooling water (Int)
Loss of material Fire Water System VII.C2.AP-202 3.3.1-45 E
66 Piping Pressure boundary Steel Diesel exhaust (Int)
Cumulative fatigue damage TLAA N/A N/A H, 337 67 Piping Pressure boundary Steel Diesel exhaust (Int)
Loss of material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components VII.H2.AP-104 3.3.1-88 A
68 Piping Pressure boundary Steel Fuel oil (Int)
Loss of material Fuel Oil Chemistry and One-Time Inspection VII.H1.AP-105 3.3.1-70 A
69 Piping Pressure boundary Steel Gas (Int)
None None VII.J.AP-6 3.3.1-121 A
70 Piping Pressure boundary Steel Raw water (Int)
Flow blockage Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
71 Piping Pressure boundary Steel Raw water (Int)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 13 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 72 Piping Pressure boundary Steel Raw water (Int)
Loss of material Fire Water System VII.G.A-400 (LR-ISG-2012-02) 3.3.1-127 E
73 Piping Pressure boundary Steel Soil (Ext)
Loss of material Buried and Underground Piping and Tanks VII.G.AP-198 (LR-ISG-2011-03) 3.3.1-106 B
74 Piping Pressure boundary, Flow restriction Copper alloy
<15% Zn Air - indoor, uncontrolled (Ext)
None None VII.J.AP-144 3.3.1-114 A
75 Piping Pressure boundary, Flow restriction Copper alloy
<15% Zn Raw water (Int)
Loss of material Fire Water System VII.G.AP-197 (LR-ISG-2012-02) 3.3.1-64 B
76 Piping - Ductile Iron Leakage boundary Gray cast iron Air - indoor, uncontrolled (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A, 331 77 Piping - Ductile Iron Leakage boundary Gray cast iron Raw water (Int)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B, 331 78 Piping - Ductile Iron Leakage boundary Gray cast iron Raw water (Int)
Loss of material Selective Leaching VII.G.A-51 3.3.1-72 B, 331 79 Piping - Ductile Iron Pressure boundary Gray cast iron Air - indoor, uncontrolled (Int)
Flow blockage Fire Water System VII.G.A-404 (LR-ISG-2012-02) 3.3.1-131 B, 331 80 Piping - Ductile Iron Pressure boundary Gray cast iron Air - indoor, uncontrolled (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A, 331
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 14 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 81 Piping - Ductile Iron Pressure boundary Gray cast iron Air - indoor, uncontrolled (Int)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A, 331 82 Piping - Ductile Iron Pressure boundary Gray cast iron Air - indoor, uncontrolled (Int)
Loss of material Fire Water System VII.G.A-404 (LR-ISG-2012-02) 3.3.1-131 B, 331 83 Piping - Ductile Iron Pressure boundary Gray cast iron Air -
outdoor (Int)
Flow blockage Fire Water System VII.G.A-404 (LR-ISG-2012-02) 3.3.1-131 B, 331, 340 84 Piping - Ductile Iron Pressure boundary Gray cast iron Air -
outdoor (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-78 3.3.1-78 A, 331 85 Piping - Ductile Iron Pressure boundary Gray cast iron Air -
outdoor (Int)
Loss of material Fire Water System VII.G.A-404 (LR-ISG-2012-02) 3.3.1-131 B, 331 86 Piping - Ductile Iron Pressure boundary Gray cast iron Raw water (Int)
Flow blockage Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B, 331, 340 87 Piping - Ductile Iron Pressure boundary Gray cast iron Raw water (Int)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B, 331 88 Piping - Ductile Iron Pressure boundary Gray cast iron Raw water (Int)
Loss of material Selective Leaching VII.G.A-51 3.3.1-72 B, 331 89 Piping - Ductile Iron Pressure boundary Gray cast iron Soil (Ext)
Loss of material Buried and Underground Piping and Tanks VII.G.AP-198 (LR-ISG-2011-03) 3.3.1-106 B, 331
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 15 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 90 Piping - Ductile Iron Pressure boundary Gray cast iron Soil (Ext)
Loss of material Plant-Specific Periodic Inspections for Selective Leaching Selective Leaching VII.G.A-02 3.3.1-72 B, 331 E, 331 91 Piping - Ductile Iron Pressure boundary Gray cast iron with internal coating/l ining Raw water (Int)
Loss of coating or lining integrity Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks VII.G.A-416 (LR-ISG-2013-01) 3.3.1-138 B, 331 92 Piping - Ductile Iron Pressure boundary Gray cast iron with internal coating/l ining Raw water (Int)
Loss of material Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks VII.G.A-415 (LR-ISG-2013-01) 3.3.1-140 B, 331 68 Piping Pressure boundary Gray cast iron with internal coating
/lining Raw water (Int)
Loss of material Selective Leaching VII.G.A-51 3.3.1-72 A, 331 93 Pump casing Leakage boundary Gray cast iron Air - indoor, uncontrolled (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
94 Pump casing Leakage boundary Gray cast iron Raw water (Int)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 16 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 95 Pump casing Leakage boundary Gray cast iron Raw water (Int)
Loss of material Plant-Specific Periodic Inspections for Selective Leaching Selective Leaching VII.G.A-51 3.3.1-72 B
E 96 Pump casing Pressure boundary Gray cast iron Air - indoor, uncontrolled (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
97 Pump casing Pressure boundary Gray cast iron Raw water (Int)
Flow blockage Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
98 Pump casing Pressure boundary Gray cast iron Raw water (Int)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
99 Pump casing Pressure boundary Gray cast iron Raw water (Int)
Loss of material Plant-Specific Periodic Inspections for Selective Leaching Selective Leaching VII.G.A-51 3.3.1-72 B
E 100 Pump casing (Column)
Pressure boundary Steel Raw water (Int)
Flow blockage Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
101 Pump casing (Column)
Pressure boundary Steel Raw water (Ext)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
102 Pump casing (Column)
Pressure boundary Steel Raw water (Int)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 17 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 103 Pump casing (Diesel fire pump fuel oil)
Pressure boundary Copper alloy
>15% Zn Air - indoor, uncontrolled (Ext)
None None VII.J.AP-144 3.3.1-114 A
104 Pump casing (Diesel fire pump fuel oil)
Pressure boundary Copper alloy
>15% Zn Fuel oil (Int)
Cracking Fuel Oil Chemistry and One-Time Inspection N/A N/A H, 336 105 Pump casing (Diesel fire pump fuel oil)
Pressure boundary Copper alloy
>15% Zn Fuel oil (Int)
Loss of material Fuel Oil Chemistry and One-Time Inspection VII.G.AP-132 3.3.1-69 A
106 Pump casing (Diesel fire pump fuel oil)
Pressure boundary Steel Air - indoor, uncontrolled (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
107 Pump casing (Diesel fire pump fuel oil)
Pressure boundary Steel Fuel oil (Int)
Loss of material Fuel Oil Chemistry and One-Time Inspection VII.H1.AP-105 3.3.1-70 A
108 Pump casing (Diesel fire pump jacket water)
Pressure boundary Steel Air - indoor, uncontrolled (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
109 Pump casing (Diesel fire pump jacket water)
Pressure boundary Steel Closed-cycle cooling water (Int)
Loss of material Fire Water System VII.C2.AP-202 3.3.1-45 E
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 18 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 110 Pump casing (Suction bell)
Pressure boundary Gray cast iron with internal coating/l ining Raw water (Int)
Loss of coating or lining integrity Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks VII.G.A-416 (LR-ISG-2013-01) 3.3.1-138 B
111 Pump casing (Suction bell)
Pressure boundary Gray cast iron with internal coating/l ining Raw water (Ext)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
112 Pump casing (Suction bell)
Pressure boundary Gray cast iron with internal coating/l ining Raw water (Int)
Loss of material Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks VII.G.A-414 (LR-ISG-2013-01) 3.3.1-139 B
113 Pump casing (Suction bell)
Pressure boundary Gray cast iron with internal coating/l ining Raw water (Int)
Loss of material Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks VII.G.A-415 (LR-ISG-2013-01) 3.3.1-140 B
114 Pump casing (Suction bell)
Pressure boundary Gray cast iron with internal coating/l ining Raw water (Ext)
Loss of material Plant-Specific Periodic Inspections for Selective Leaching Selective Leaching VII.G.A-51 3.3.1-72 B
E
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 19 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 115 Pump casing (Suction strainer element)
Filtration Copper alloy
<15% Zn Raw water (Ext)
Loss of material Fire Water System VII.G.AP-197 (LR-ISG-2012-02) 3.3.1-64 B, 342 116 Pump casing (Suction strainer element)
Filtration Stainless steel Raw water (Ext)
Loss of material Fire Water System VII.G.A-55 (LR-ISG-2012-02) 3.3.1-66 B, 330 117 Sight glass Leakage boundary Polymer s
Air - indoor, uncontrolled (Ext)
None None VII.J.AP-268 3.3.1-119 A, 310 118 Sight glass Leakage boundary Polymer s
Raw water (Int)
None None N/A N/A G, 310 119 Sight glass Pressure boundary Glass Air - indoor, uncontrolled (Ext)
None None VII.J.AP-14 3.3.1-117 A
120 Sight glass Pressure boundary Glass Raw water (Int)
None None VII.J.AP-50 3.3.1-117 A
121 Sight glass Pressure boundary Polymer s
Air - indoor, uncontrolled (Ext)
None None VII.J.AP-268 3.3.1-119 A, 310 122 Sight glass Pressure boundary Polymer s
Raw water (Int)
None None N/A N/A G, 310
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 20 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 123 Sight glass (Body)
Leakage boundary Gray cast iron Air - indoor, uncontrolled (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
124 Sight glass (Body)
Leakage boundary Gray cast iron Raw water (Int)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
125 Sight glass (Body)
Leakage boundary Gray cast iron Raw water (Int)
Loss of material Plant-Specific Periodic Inspections for Selective Leaching Selective Leaching VII.G.A-51 3.3.1-72 B
E 126 Sight glass (Body)
Pressure boundary Gray cast iron Air - indoor, uncontrolled (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
127 Sight glass (Body)
Pressure boundary Gray cast iron Raw water (Int)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
128 Sight glass (Body)
Pressure boundary Gray cast iron Raw water (Int)
Loss of material Plant-Specific Periodic Inspections for Selective Leaching Selective Leaching VII.G.A-51 3.3.1-72 B
E 129 Sight glass (Body)
Pressure boundary Steel Air - indoor, uncontrolled (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 21 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 130 Sight glass (Body)
Pressure boundary Steel Raw water (Int)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
131 Spray nozzle Direct flow Copper alloy
>15% Zn Air -
outdoor (Int)
Flow blockage Fire Water System VII.G.AP-197 (LR-ISG-2012-02) 3.3.1-64 B
132 Spray nozzle Direct flow Copper alloy
>15% Zn Air -
outdoor (Int)
Loss of material Fire Water System VII.G.A-404 (LR-ISG-2012-02) 3.3.1-131 B
133 Spray nozzle Direct flow Copper alloy
>15% Zn Air -
outdoor (Ext)
Loss of material Fire Water System VII.I.AP-159 3.3.1-81 E
134 Sprinkler head Direct flow Copper alloy
<15% Zn Air - indoor, uncontrolled (Int)
Flow blockage Fire Water System VII.G.A-403 (LR-ISG-2012-02) 3.3.1-130 B
135 Sprinkler head Direct flow Copper alloy
<15% Zn Air - indoor, uncontrolled (Ext)
None None VII.J.AP-144 3.3.1-114 A
136 Sprinkler head Direct flow Copper alloy
<15% Zn Raw water (Int)
Flow blockage Fire Water System VII.G.A-403 (LR-ISG-2012-02) 3.3.1-130 B
137 Sprinkler head Direct flow Copper alloy
<15% Zn Raw water (Int)
Loss of material Fire Water System VII.G.A-403 (LR-ISG-2012-02) 3.3.1-130 B
138 Sprinkler head Direct flow Copper alloy
>15% Zn Air - indoor, uncontrolled (Int)
Flow blockage Fire Water System VII.G.A-403 (LR-ISG-2012-02) 3.3.1-130 B
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 22 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 139 Sprinkler head Direct flow Copper alloy
>15% Zn Air - indoor, uncontrolled (Ext)
None None VII.J.AP-144 3.3.1-114 A
140 Sprinkler head Direct flow Copper alloy
>15% Zn Raw water (Int)
Flow blockage Fire Water System VII.G.A-403 (LR-ISG-2012-02) 3.3.1-130 B
141 Sprinkler head Direct flow Copper alloy
>15% Zn Raw water (Int)
Loss of material Fire Water System VII.G.A-403 (LR-ISG-2012-02) 3.3.1-130 B
142 Sprinkler head Direct flow Copper alloy
>15% Zn Raw water (Int)
Loss of material Selective Leaching VII.G.A-47 3.3.1-72 B
143 Strainer body Pressure boundary Copper alloy
<15% Zn Air - indoor, uncontrolled (Ext)
None None VII.J.AP-144 3.3.1-114 A
144 Strainer body Pressure boundary Copper alloy
<15% Zn Raw water (Int)
Flow blockage Fire Water System VII.G.AP-197 (LR-ISG-2012-02) 3.3.1-64 B
145 Strainer body Pressure boundary Copper alloy
<15% Zn Raw water (Int)
Loss of material Fire Water System VII.G.AP-197 (LR-ISG-2012-02) 3.3.1-64 B
146 Strainer body Pressure boundary Copper alloy
>15% Zn Air - indoor, uncontrolled (Ext)
None None VII.J.AP-144 3.3.1-114 A
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 23 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 147 Strainer body Pressure boundary Copper alloy
>15% Zn Raw water (Int)
Flow blockage Fire Water System VII.G.AP-197 (LR-ISG-2012-02) 3.3.1-64 B
148 Strainer body Pressure boundary Copper alloy
>15% Zn Raw water (Int)
Loss of material Fire Water System VII.G.AP-197 (LR-ISG-2012-02) 3.3.1-64 B
149 Strainer body Pressure boundary Copper alloy
>15% Zn Raw water (Int)
Loss of material Selective Leaching VII.G.A-47 3.3.1-72 B
150 Strainer body Pressure boundary Gray cast iron Air - indoor, uncontrolled (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
151 Strainer body Pressure boundary Gray cast iron Raw water (Int)
Flow blockage Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
152 Strainer body Pressure boundary Gray cast iron Raw water (Int)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
153 Strainer body Pressure boundary Gray cast iron Raw water (Int)
Loss of material Plant-Specific Periodic Inspections for Selective Leaching Selective Leaching VII.G.A-51 3.3.1-72 B
E 154 Strainer body Pressure boundary Steel Air - indoor, uncontrolled (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 24 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 155 Strainer body Pressure boundary Steel Raw water (Int)
Flow blockage Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
156 Strainer body Pressure boundary Steel Raw water (Int)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
157 Tank Pressure boundary Steel Air - indoor, uncontrolled (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
158 Tank Pressure boundary Steel Raw water (Int)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 D
159 Tank (CO2)
Pressure boundary Steel Condensa tion (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.G.A-405 (LR-ISG-2012-02) 3.3.1-132 A
160 Tank (CO2)
Pressure boundary Steel Gas (Int)
None None VII.J.AP-6 3.3.1-121 C
161 Tank (Fuel oil)
Pressure boundary Steel Air - indoor, uncontrolled (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
162 Tank (Fuel oil)
Pressure boundary Steel Fuel oil (Int)
Loss of material Fuel Oil Chemistry and One-Time Inspection VII.H1.AP-105 3.3.1-70 A
163 Tank (Pressure maintenance)
Leakage boundary Steel Air - indoor, uncontrolled (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 25 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 164 Tank (Pressure maintenance)
Leakage boundary Steel Raw water (Int)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 D
165 Tank (Retarding chamber)
Pressure boundary Gray cast iron Air - indoor, uncontrolled (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
166 Tank (Retarding chamber)
Pressure boundary Gray cast iron Raw water (Int)
Flow blockage Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
167 Tank (Retarding chamber)
Pressure boundary Gray cast iron Raw water (Int)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
168 Tank (Retarding chamber)
Pressure boundary Gray cast iron Raw water (Int)
Loss of material Plant-Specific Periodic Inspections for Selective Leaching Selective Leaching VII.G.A-51 3.3.1-72 B
E 169 Valve body Leakage boundary Copper alloy
<15% Zn Air - indoor, uncontrolled (Ext)
None None VII.J.AP-144 3.3.1-114 A
170 Valve body Leakage boundary Copper alloy
<15% Zn Raw water (Int)
Loss of material Fire Water System VII.G.AP-197 (LR-ISG-2012-02) 3.3.1-64 B
171 Valve body Leakage boundary Copper alloy
>15% Zn Air - indoor, uncontrolled (Ext)
None None VII.J.AP-144 3.3.1-114 A
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 26 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 172 Valve body Leakage boundary Copper alloy
>15% Zn Raw water (Int)
Loss of material Fire Water System VII.G.AP-197 (LR-ISG-2012-02) 3.3.1-64 B
173 Valve body Leakage boundary Copper alloy
>15% Zn Raw water (Int)
Loss of material Selective Leaching VII.G.A-47 3.3.1-72 B
174 Valve body Leakage boundary Gray cast iron Air - indoor, uncontrolled (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
175 Valve body Leakage boundary Gray cast iron Raw water (Int)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
176 Valve body Leakage boundary Gray cast iron Raw water (Int)
Loss of material Plant-Specific Periodic Inspections for Selective Leaching Selective Leaching VII.G.A-51 3.3.1-72 B
E 177 Valve body Leakage boundary Stainless steel Air - indoor, uncontrolled (Ext)
None None VII.J.AP-17 3.3.1-120 A
178 Valve body Leakage boundary Stainless steel Raw water (Int)
Loss of material Fire Water System VII.G.A-55 (LR-ISG-2012-02) 3.3.1-66 B
179 Valve body Pressure boundary Copper alloy
<15% Zn Air - indoor, uncontrolled (Ext)
None None VII.J.AP-144 3.3.1-114 A
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 27 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 180 Valve body Pressure boundary Copper alloy
<15% Zn Air -
outdoor (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.AP-159 3.3.1-81 A
181 Valve body Pressure boundary Copper alloy
<15% Zn Gas (Int)
None None VII.J.AP-9 3.3.1-114 A
182 Valve body Pressure boundary Copper alloy
<15% Zn Raw water (Int)
Flow blockage Fire Water System VII.G.AP-197 (LR-ISG-2012-02) 3.3.1-64 B
183 Valve body Pressure boundary Copper alloy
<15% Zn Raw water (Int)
Loss of material Fire Water System VII.G.AP-197 (LR-ISG-2012-02) 3.3.1-64 B
184 Valve body Pressure boundary Copper alloy
>15% Zn Air - indoor, uncontrolled (Ext)
None None VII.J.AP-144 3.3.1-114 A
185 Valve body Pressure boundary Copper alloy
>15% Zn Fuel oil (Int)
Cracking Fuel Oil Chemistry and One-Time Inspection N/A N/A H, 336 186 Valve body Pressure boundary Copper alloy
>15% Zn Fuel oil (Int)
Loss of material Fuel Oil Chemistry and One-Time Inspection VII.G.AP-132 3.3.1-69 A
187 Valve body Pressure boundary Copper alloy
>15% Zn Raw water (Int)
Flow blockage Fire Water System VII.G.AP-197 (LR-ISG-2012-02) 3.3.1-64 B
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 28 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 188 Valve body Pressure boundary Copper alloy
>15% Zn Raw water (Int)
Loss of material Fire Water System VII.G.AP-197 (LR-ISG-2012-02) 3.3.1-64 B
189 Valve body Pressure boundary Copper alloy
>15% Zn Raw water (Int)
Loss of material Selective Leaching VII.G.A-47 3.3.1-72 B
190 Valve body Pressure boundary Gray cast iron Air - indoor, uncontrolled (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
191 Valve body Pressure boundary Gray cast iron Raw water (Int)
Flow blockage Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
192 Valve body Pressure boundary Gray cast iron Raw water (Int)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
193 Valve body Pressure boundary Gray cast iron Raw water (Int)
Loss of material Plant-Specific Periodic Inspections for Selective Leaching Selective Leaching VII.G.A-51 3.3.1-72 B
E 194 Valve body Pressure boundary Gray cast iron Soil (Ext)
Loss of material Buried and Underground Piping and Tanks VII.G.AP-198 (LR-ISG-2011-03) 3.3.1-106 B
195 Valve body Pressure boundary Gray cast iron Soil (Ext)
Loss of material Plant-Specific Periodic Inspections for Selective Leaching Selective Leaching VII.G.A-02 3.3.1-72 B
E
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 29 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 196 Valve body Pressure boundary Stainless steel Air - indoor, uncontrolled (Ext)
None None VII.J.AP-17 3.3.1-120 A
197 Valve body Pressure boundary Stainless steel Gas (Int)
None None VII.J.AP-22 3.3.1-120 A
198 Valve body Pressure boundary Stainless steel Lubricatin g oil (Int)
Loss of material Lubricating Oil Analysis and One-Time Inspection VII.G.AP-138 3.3.1-100 A
199 Valve body Pressure boundary Stainless steel Raw water (Int)
Loss of material Fire Water System VII.G.A-55 (LR-ISG-2012-02) 3.3.1-66 B
200 Valve body Pressure boundary Steel Air - indoor, uncontrolled (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
201 Valve body Pressure boundary Steel Air - indoor, uncontrolled (Ext)
Loss of material Fire Protection VII.G.AP-150 3.3.1-58 A
202 Valve body Pressure boundary Steel Air -
outdoor (Ext)
Loss of material Fire Protection VII.I.A-78 3.3.1-78 E
203 Valve body Pressure boundary Steel Gas (Int)
None None VII.J.AP-6 3.3.1-121 A
204 Valve body Pressure boundary Steel Raw water (Int)
Flow blockage Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 30 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 205 Valve body Pressure boundary Steel Raw water (Int)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
206 Valve body -
Ductile Iron Pressure boundary Gray cast iron Air - indoor, uncontrolled (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A, 331 207 Valve body -
Ductile Iron Pressure boundary Gray cast iron Raw water (Int)
Flow blockage Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B, 331, 340 208 Valve body -
Ductile Iron Pressure boundary Gray cast iron Raw water (Int)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B, 331 209 Valve body -
Ductile Iron Pressure boundary Gray cast iron Raw water (Int)
Loss of material Selective Leaching VII.G.A-51 3.3.1-72 B, 331 210 Valve body (Hydrant)
Pressure boundary Gray cast iron Air -
outdoor (Ext)
Loss of material Fire Water System VII.G.AP-149 3.3.1-63 B
211 Valve body (Hydrant)
Pressure boundary Gray cast iron Raw water (Int)
Flow blockage Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
212 Valve body (Hydrant)
Pressure boundary Gray cast iron Raw water (Int)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
213 Valve body (Hydrant)
Pressure boundary Gray cast iron Raw water (Int)
Loss of material Plant-Specific Periodic Inspections for Selective Leaching Selective Leaching VII.G.A-51 3.3.1-72 B
E
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 6 Page 31 of 31 Table 3.3.2 Fire Protection System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 214 Valve body (Hydrant)
Pressure boundary Gray cast iron Soil (Ext)
Loss of material Buried and Underground Piping and Tanks VII.G.AP-198 (LR-ISG-2011-03) 3.3.1-106 B
215 Valve body (Hydrant)
Pressure boundary Gray cast iron Soil (Ext)
Loss of material Plant-Specific Periodic Inspections for Selective Leaching Selective Leaching VII.G.A-02 3.3.1-72 B
E 210 Valve body (Hydrant)
Pressure boundary Gray cast iron Air -
outdoor (Ext)
Loss of material Fire Water System VII.G.AP-149 3.3.1-63 B
211 Valve body (Hydrant)
Pressure boundary Gray cast iron Raw water (Int)
Flow blockage Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
212 Valve body (Hydrant)
Pressure boundary Gray cast iron Raw water (Int)
Loss of material Fire Water System VII.G.A-33 (LR-ISG-2012-02) 3.3.1-64 B
213 Valve body (Hydrant)
Pressure boundary Gray cast iron Raw water (Int)
Loss of material Periodic Inspections for Selective Leaching Selective Leaching VII.G.A-51 3.3.1-72 B
E 214 Valve body (Hydrant)
Pressure boundary Gray cast iron Soil (Ext)
Loss of material Buried and Underground Piping and Tanks VII.G.AP-198 (LR-ISG-2011-03) 3.3.1-106 B
215 Valve body (Hydrant)
Pressure boundary Gray cast iron Soil (Ext)
Loss of material Periodic Inspections for Selective Leaching Selective Leaching VII.G.A-02 3.3.1-72 B
E
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 7 Page 1 of 6 LRA Section: 3.3.2.1.47 and Table 3.3.2-47 LRA Page Number(s): 3.3-51, 3.3-401 through 3.3-404
References:
Applicant Initiated Description of Change: A new aging management program, Plant-Specific Periodic Inspections for Selective Leaching Program, will manage the selective leaching for Gray cast iron components exposed to Raw water since selective leaching has occurred in a different system for this material environment combination. There are no ductile iron components in this system subject to aging management. Prior changes to Table 3.3.2-47 made by PNPP LRA Supplement 2 (Letter L-24-020) are included but not shown as a change here.
PNPP LRA Section 3.3.2.1.47 Potable Water Supply System, Page 3.3-51 is revised as follows:
Materials Potable Water Supply system components are constructed of the following materials:
Copper alloy <15% Zn
Gray cast iron
Stainless steel
Steel
Steel with internal coating/lining Environments Potable Water Supply system components are exposed to the following environments:
Air - indoor, uncontrolled
Raw water Aging Effects Requiring Management The following aging effects associated with the Potable Water Supply system require management:
Loss of coating or lining integrity
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 7 Page 2 of 6
Loss of material
Loss of preload Aging Management Programs The following aging management programs manage the effects of aging on Potable Water Supply system components:
Bolting Integrity (B.2.7)
External Surfaces Monitoring of Mechanical Components (B.2.18)
Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.25)
Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks (B.2.27)
Plant-Specific Periodic Inspections for Selective Leaching (B.2.45)
Selective Leaching (B.2.42)
PNPP LRA Table 3.3.2-47, Page 3.3-404, is revised as follows:
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 7 Page 3 of 6 Table 3.3.2-47 Auxiliary Systems - Potable Water Supply Summary of Aging Management Evaluation Table 3.3.2 Potable Water Supply System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Managemen t Program NUREG-1801Item Table 1 Item Notes 1
Bolting Leakage boundary Steel Air - indoor, uncontrolle d(Ext)
Loss of material Bolting Integrity VII.I.AP-125 3.3.1-12 B
2 Bolting Leakage boundary Steel Air - indoor, uncontrolle d(Ext)
Loss of preload Bolting Integrity VII.I.AP-124 3.3.1-15 B
3 Eyewash station Leakage boundary Steel Air -
- indoor, uncontrol led(Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
4 Eyewash station Leakage boundary Steel Raw water (Int)
Loss of material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components VII.E5.AP-270 3.3.1-88 A
5 Flexible hose Leakage boundary Stainles s steel Air - indoor, uncontrolle d(Ext)
None None VII.J.AP-17 3.3.1-120 A
6 Flexible hose Leakage boundary Stainles s steel Raw water (Int)
Loss of material Inspection of Internal Surfaces in Miscellaneou s Piping and Ducting Components VII.E5.AP-270 3.3.1-88 A
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 7 Page 4 of 6 Table 3.3.2 Potable Water Supply System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Managemen t Program NUREG-1801Item Table 1 Item Notes 7
Piping Leakage boundary Copper alloy
<15% Zn Air - indoor, uncontrolled(
Ext)
None None VII.J.AP-144 3.3.1-114 A
8 Piping Leakage boundary Copper alloy
<15% Zn Raw water (Int)
Loss of material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components VII.E5.AP-271 3.3.1-93 A
9 Piping Leakage boundary Steel Air - indoor, uncontrolle d(Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
10 Piping Leakage boundary Steel Raw water (Int)
Loss of material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components VII.E5.AP-270 3.3.1-88 A
11 Piping Leakage boundary Steel with internal coating/
lining Air -
- indoor, uncontrol led(Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.D.A-80 3.3.1-78 A, 313 12 Piping Leakage boundary Steel with internal coating/
lining Raw water (Int)
Loss of coating or lining integrity Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks VII.E5.A-416 (LR-ISG-2013-01) 3.3.1-138 B, 313
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 7 Page 5 of 6 Table 3.3.2 Potable Water Supply System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Managemen t Program NUREG-1801Item Table 1 Item Notes 13 Piping Leakage boundary Steel with internal coating/
lining Raw water (Int)
Loss of material Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks VII.E5.A-414 (LR-ISG-2013-01) 3.3.1-139 B, 312 14 Pump casing Leakage boundary Copper alloy
<15% Zn Air -
- indoor, uncontrol led(Ext)
None None VII.J.AP-144 3.3.1-114 A
15 Pump casing Leakage boundary Copper alloy
<15% Zn Raw water (Int)
Loss of material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components VII.E5.AP-271 3.3.1-93 A
16 Tank (Water heater lining)
Leakage boundary Copper alloy
<15% Zn Raw water (Int)
Loss of material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components VII.E5.AP-271 3.3.1-93 A
17 Tank (Water heater)
Leakage boundary Steel Air -
- indoor, uncontrol led(Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
18 Valve body Leakage boundary Copper alloy
<15% Zn Air -
- indoor, uncontrol led(Ext)
None None VII.J.AP-144 3.3.1-114 A
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 7 Page 6 of 6 Table 3.3.2 Potable Water Supply System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Managemen t Program NUREG-1801Item Table 1 Item Notes 19 Valve body Leakage boundary Copper alloy
<15% Zn Raw water (Int)
Loss of material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components VII.E5.AP-271 3.3.1-93 A
20 Valve body Leakage boundary Gray cast iron Air -
- indoor, uncontrol led(Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
21 Valve body Leakage boundary Gray cast iron Raw water (Int)
Loss of material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components VII.E5.AP-270 3.3.1-88 A
22 Valve body Leakage boundary Gray cast iron Raw water (Int)
Loss of material Plant-Specific Periodic Inspections for Selective Leaching Selective Leaching VII.C1.A-51 (LR-ISG-2012-
- 02) 3.3.1-72 B E
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 8 Page 1 of 8 LRA Section: 3.3.2.1.45 and Table 3.3.2-45 LRA Page Number(s): 3.3-49, 3.3-50, 3.3-392 through 3.3-396
References:
Applicant Initiated Description of Change: Attachment 3 of this supplement (Letter L-24-178) identifies new component type and system intended functions. A new component type Flow elements and material environment combinations have been identified for this system during the AMR review process. Additionally, the aging effects are being managed by an existing aging management program that wasnt previously relied upon for this system. These changes are shown in LRA Section 3.3.2.1.45 and LRA Table 3.3.2-45. The discussion text for the affected line items in LRA Table 3.3.1 were reviewed with no recommended changes. Prior changes to LRA Table 3.3.2-45 made by PNPP Supplement 2 (Letter L-24-020) are included but not shown as a change here.
PNPP LRA Section 3.3.2.1.45 Plant Radiation Monitoring and Process Monitoring and Post-Accident Radiation Monitoring, Page 3.3-49, is revised as follows:
Materials Plant Radiation Monitoring and Process Monitoring and Post Accident Radiation Monitoring systems components are constructed of the following materials:
Copper alloy <15% Zn
Gray cast iron
Stainless steel
Steel Environments Plant Radiation Monitoring and Process Monitoring and Post Accident Radiation Monitoring systems components are exposed to the following environments:
Air - indoor, uncontrolled
Closed-cycle cooling water
Raw water
Waste water
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 8 Page 2 of 8 Aging Effects Requiring Management The following aging effects associated with the Plant Radiation Monitoring and Process Monitoring and Post Accident Radiation Monitoring systems require management:
Loss of material
Loss of preload Aging Management Programs The following aging management programs manage the effects of aging on Plant Radiation Monitoring and Process Monitoring and Post Accident Radiation Monitoring systems components:
Bolting Integrity (B.2.7)
Closed Treated Water Systems (B.2.15)
External Surfaces Monitoring of Mechanical Components (B.2.18)
Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.25)
Open-Cycle Cooling Water System (B.2.37)
PNPP LRA Table 3.3.2-45, Page 3.3-392 through 3.3-396, is revised as follows:
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 8 Page 3 of 8 Table 3.3.2-45 Auxiliary Systems - Plant Radiation Monitoring and Process Monitoring, and Post Accident Radiation Monitoring Summary of Aging Management Evaluation Table 3.3.2 Plant Radiation Monitoring and Process Monitoring, and Post Accident Radiation Monitoring System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 1
Bolting Leakage boundary Steel Air - indoor, uncontrolled (Ext)
Loss of material Bolting Integrity VII.I.AP-125 3.3.1-12 B
2 Bolting Leakage boundary Steel Air - indoor, uncontrolled (Ext)
Loss of preload Bolting Integrity VII.I.AP-124 3.3.1-15 B
3 Bolting Pressure boundary Steel Air - indoor, uncontrolled (Ext)
Loss of material Bolting Integrity VII.I.AP-125 3.3.1-12 B
4 Bolting Pressure boundary Steel Air - indoor, uncontrolled (Ext)
Loss of preload Bolting Integrity VII.I.AP-124 3.3.1-15 B
5 Bolting Structural integrity Steel Air - indoor, uncontrolled (Ext)
Loss of material Bolting Integrity VII.I.AP-125 3.3.1-12 B
6 Bolting Structural integrity Steel Air - indoor, uncontrolled (Ext)
Loss of preload Bolting Integrity VII.I.AP-124 3.3.1-15 B
7 Detector housing Leakage boundary Stainless steel Air - indoor, uncontrolled (Ext)
None None VII.J.AP-17 3.3.1-120 A
8 Detector housing Leakage boundary Stainless steel Closed-cycle cooling water (Int)
Loss of material Closed Treated Water Systems VII.C2.A-52 3.3.1-49 A
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 8 Page 4 of 8 Table 3.3.2 Plant Radiation Monitoring and Process Monitoring, and Post Accident Radiation Monitoring System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 9
Detector housing Leakage boundary Stainless steel Raw water (Int)
Loss of material Open-Cycle Cooling Water System VII.C1.A-54 3.3.1-40 A
10 Detector housing Leakage boundary Stainless steel Waste water (Int)
Loss of material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components VII.E5.AP-278 3.3.1-95 A
11 Detector housing Pressure boundary Stainless steel Air - indoor, uncontrolled (Int)
None None VII.J.AP-123 3.3.1-120 A
12 Detector housing Pressure boundary Stainless steel Air - indoor, uncontrolled (Ext)
None None VII.J.AP-17 3.3.1-120 A
13 Filter housing Pressure boundary Stainless steel Air - indoor, uncontrolled (Int)
None None VII.J.AP-123 3.3.1-120 A
14 Filter housing Pressure boundary Stainless steel Air - indoor, uncontrolled (Ext)
None None VII.J.AP-17 3.3.1-120 A
15 Flexible hose Leakage boundary Stainless steel Air - indoor, uncontrolled (Ext)
None None VII.J.AP-17 3.3.1-120 A
16 Flexible hose Leakage boundary Stainless steel Closed-cycle cooling water (Int)
Loss of material Closed Treated Water Systems VII.C2.A-52 3.3.1-49 A
17 Flexible hose Leakage boundary Stainless steel Raw water (Int)
Loss of material Open-Cycle Cooling Water System VII.C1.A-54 3.3.1-40 A
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 8 Page 5 of 8 Table 3.3.2 Plant Radiation Monitoring and Process Monitoring, and Post Accident Radiation Monitoring System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 18 Flexible hose Leakage boundary Stainless steel Waste water (Int)
Loss of material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components VII.E5.AP-278 3.3.1-95 A
19 Flow element Pressure boundary Stainless steel Air - indoor, uncontrolled (Int)
None None VII.J.AP-123 3.3.1-120 A
20 Flow element Pressure boundary Stainless steel Air - indoor, uncontrolled (Ext)
None None VII.J.AP-17 3.3.1-120 A
21 Flow straightener Pressure boundary Stainless steel Air - indoor, uncontrolled (Int)
None None VII.J.AP-123 3.3.1-120 A
22 Flow straightener Pressure boundary Stainless steel Air - indoor, uncontrolled (Ext)
None None VII.J.AP-17 3.3.1-120 A
23 Piping Leakage boundary Stainless steel Air - indoor, uncontrolled (Ext)
None None VII.J.AP-17 3.3.1-120 A
24 Piping Leakage boundary Stainless steel Closed-cycle cooling water (Int)
Loss of material Closed Treated Water Systems VII.C2.A-52 3.3.1-49 A
25 Piping Leakage boundary Stainless steel Raw water (Int)
Loss of material Open-Cycle Cooling Water System VII.C1.A-54 3.3.1-40 A
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 8 Page 6 of 8 Table 3.3.2 Plant Radiation Monitoring and Process Monitoring, and Post Accident Radiation Monitoring System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 26 Piping Leakage boundary Stainless steel Waste water (Int)
Loss of material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components VII.E5.AP-278 3.3.1-95 A
27 Piping Pressure boundary Stainless steel Air - indoor, uncontrolled (Int)
None None VII.J.AP-123 3.3.1-120 A
28 Piping Pressure boundary Stainless steel Air - indoor, uncontrolled (Ext)
None None VII.J.AP-17 3.3.1-120 A
29 Piping Pressure boundary Steel Air - indoor, uncontrolled (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
30 Piping Pressure boundary Steel Air - indoor, uncontrolled (Int)
Loss of material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components V.D2.E-29 3.2.1-44 A
31 Piping Structural integrity Stainless steel Air - indoor, uncontrolled (Int)
None None VII.J.AP-123 3.3.1-120 A
32 Piping Structural integrity Stainless steel Air - indoor, uncontrolled (Ext)
None None VII.J.AP-17 3.3.1-120 A
33 Pump casing Leakage boundary Copper alloy
<15% Zn Air - indoor, uncontrolled (Ext)
None None VII.J.AP-144 3.3.1-114 A
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 8 Page 7 of 8 Table 3.3.2 Plant Radiation Monitoring and Process Monitoring, and Post Accident Radiation Monitoring System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 34 Pump casing Leakage boundary Copper alloy
<15% Zn Closed-cycle cooling water (Int)
Loss of material Closed Treated Water Systems VII.C2.AP-199 3.3.1-46 A
35 Pump casing Leakage boundary Copper alloy
<15% Zn Raw water (Int)
Loss of material Open-Cycle Cooling Water System VII.C1.AP-196 3.3.1-36 A
36 Pump casing Leakage boundary Copper alloy
<15% Zn Waste water (Int)
Loss of material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components VII.E5.AP-272 3.3.1-95 A
37 Pump casing Pressure boundary Gray cast iron Air - indoor, uncontrolled (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components VII.I.A-77 3.3.1-78 A
38 Pump casing Pressure boundary Gray cast iron Air - indoor, uncontrolled (Int)
Loss of material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components V.D2.E-29 3.2.1-44 A
39 Pump casing Pressure boundary Stainless steel Air - indoor, uncontrolled (Int)
None None VII.J.AP-123 3.3.1-120 A
40 Pump casing Pressure boundary Stainless steel Air - indoor, uncontrolled (Ext)
None None VII.J.AP-17 3.3.1-120 A
41 Valve body Leakage boundary Stainless steel Air - indoor, uncontrolled (Ext)
None None VII.J.AP-17 3.3.1-120 A
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 8 Page 8 of 8 Table 3.3.2 Plant Radiation Monitoring and Process Monitoring, and Post Accident Radiation Monitoring System Row Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes 42 Valve body Leakage boundary Stainless steel Closed-cycle cooling water (Int)
Loss of material Closed Treated Water Systems VII.C2.A-52 3.3.1-49 A
43 Valve body Leakage boundary Stainless steel Raw water (Int)
Loss of material Open-Cycle Cooling Water System VII.C1.A-54 3.3.1-40 A
44 Valve body Leakage boundary Stainless steel Waste water (Int)
Loss of material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components VII.E5.AP-278 3.3.1-95 A
45 Valve body Pressure boundary Stainless steel Air - indoor, uncontrolled (Int)
None None VII.J.AP-123 3.3.1-120 A
46 Valve body Pressure boundary Stainless steel Air - indoor, uncontrolled (Ext)
None None VII.J.AP-17 3.3.1-120 A
47 Valve body Structural integrity Stainless steel Air - indoor, uncontrolled (Int)
None None VII.J.AP-123 3.3.1-120 A
48 Valve body Structural integrity Stainless steel Air - indoor, uncontrolled (Ext)
None None VII.J.AP-17 3.3.1-120 A
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 9 Page 1 of 1 Place Holder Page - This Attachment is not used.
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 10 Page 1 of 2 0 LRA Section: Table A.1 LRA Page Number(s): A-7
Reference:
Applicant Initiated Description of Change: The new Plant-Specific Periodic Inspections for Selective Leaching Program monitors for and manages the effects of selective leaching for the following material/environment populations:
gray cast iron/raw water,
gray cast iron/soil,
gray cast iron (ductile iron)/soil Appendix A for the LRA and Table A.1 is revised to accommodate the new plant specific program.
PNPP LRA Table A.1, Page A-7 is revised as follows:
NOTE: Only those table rows with revised text are included in the following table. Table rows unaffected by these changes are omitted from this attachment.
Table A.1 Correlation of NUREG-1801 and PNPP Aging Management Programs NUREG-1801 Number NUREG-1801 Program PNPP Program Program Status LRA Sections XI.S8 Protective Coating Monitoring and Maintenance Program Protective Coating Monitoring and Maintenance Program Existing A.1.38 B.2.38 XI.E1 Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Non-EQ Insulated Cables and Connections Program Existing A.1.34 B.2.34
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 10 Page 2 of 2 NUREG-1801 Number NUREG-1801 Program PNPP Program Program Status LRA Sections XI.E2 Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Non-EQ Instrumentation Circuits Program New A.1.33 B.2.33 XI.E3 Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Non-EQ Inaccessible Power Cables Program Existing A.1.32 B.2.32 XI.E4 Metal Enclosed Bus Not applicable. There are no in-scope metal enclosed bus for PNPP N/A N/A XI.E5 Fuse Holders Fuse Holders New A.1.24 B.2.24 XI.E6 Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Non-EQ Electrical Cable Connections Program New (One-Time)
A.1.31 B.2.31 N/A N/A Plant-Specific Periodic Inspections for Selective Leaching Program New A.1.45 B.2.45
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 11 Page 1 of 3 1 LRA Section: A.1.42 LRA Page Number(s): A-40, and A-41
Reference:
Applicant Initiated Description of Change: The purpose of NUREG-1801, XI.M33 is to demonstrate the absence of selective leaching. The program for selective leaching of materials ensures the integrity of the components made of gray cast iron and copper alloys (except for inhibited brass) that contain greater than 15 percent zinc (> 15% Zn) or greater than 8 percent aluminum (>8% Al in the case of aluminum-bronze) exposed to a raw water, closed cooling water, treated water, or ground water environment that may lead to selective leaching of one of the metal components where there has not been previous experience of selective leaching. Program scope states For materials and environments where selective leaching is currently occurring, a plant-specific program is required. Plant-specific OE CR-2024-02317 identifies instances of selective leaching occurring at PNPP. As such, LRA Section A.1.42 is revised to reflect use of a new, plant-specific, on-going aging management program for the material/environment combinations where selective leaching has been identified. Note, consistent with is change, a new LRA Section A.1.45 is incorporated via Attachment 12 of this supplement.
PNPP LRA Section A.1.42, Pages A-40 and 41 (as previously modified under L-24-110 Annual Update Attachment 8), is revised as follows:
A.1.42 SELECTIVE LEACHING PROGRAM The Selective Leaching Program is a new plant-specificcondition monitoring aging management program that will monitor for and manage the effectsensure the integrity of components within the scope of license renewal that are susceptible to loss of material due to selective leaching by demonstrating the absence of selective leaching.
The Selective Leaching pProgram for selective leaching of materials will ensure the integrity of the components made of ductile iron, gray cast iron and copper alloys (except for inhibited brass) that contain greater than 15 percent zinc (> 15% Zn) exposed toidentify the aging effects of loss of material due to selective leaching for components subject to an environment of raw water, closed cycle cooling water (CCCW),
treated water, waste water, or soil or condensationthat may lead to selective leaching of one of the metal components.
Components include piping, heat exchangers, pump casings, sight glasses (body),
valve bodies and strainer bodies. The materials of construction for these components that are susceptible to selective leaching are ductile iron, gray cast iron and copper alloys (except for inhibited brass) that contain greater than 15 percent zinc (> 15% Zn).
There are no aluminum bronze in-scope components with greater than eight percent aluminum.
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 11 Page 2 of 3 The program will include is a
one-time visual inspection coupled with eithersupplemented by hardness measurement or other mechanical examination techniques such as destructive testing (when the opportunity arises), scraping, or chipping (where practicable based on component form and configuration) of a representative sample of selected components that may be susceptible to selective leaching. Periodic selective leaching inspections are conducted on component populations with materials and environments that have exhibited selective leaching at PNPP. Follow-up of unacceptable inspection findings will include an evaluation using the corrective action program and a possible expansion of the inspection sample size and location. Destructive examinations of components to determine the presence and depth of dealloying through-wall thickness are conducted.
One-time inspections are conducted on a representative sample of the component population and will focus on the bounding or lead components most susceptible to aging due to time in service, severity of operating conditions, and lowest design margin for each population. A representative sample size will be 20%Each group of components with the same material/environment combination is considered a separate population.
theTwenty percent of a susceptible component population (defined as components having the same material and environment combination) with a maximum of 25 componentsconstitutes a
representative sample size.
Where practical, the representative sample of each of those populations will focus on the bounding or lead components most susceptible to aging due to time in service, severity of operating conditions, and lowest design margin. Otherwise, a technical justification of the methodology and sample size used for selecting components for theone-time inspections will be included as part of the programs documentation.
The scope of this program does not include material and environment combinations where selective leaching has occurred and either (1) the component was replaced with the same material or (2) selective leaching is actively occurring. For those material/environment combination populations, a plant specific program will be used.
Follow-up of unacceptable inspection findings will include an evaluation using the corrective action program to determine acceptability of the affected components for further service, and a possible expansion of the inspection sample size and location.
According to the GALL Section XI.M33, for materials and environments where selective leaching is currently occurring, a plant specific program is required. PNPP has recently observed selective leaching in valve bodies (hydrants) that are buried (soil external environment), gray cast iron, fire protection components (raw water internal environment). A review of aging management data confirms that material and environment combination is limited to the fire protection system. Thus, the population of buried, gray cast iron and ductile iron, fire protection components are subject to periodic inspections, beyond this programs one-time inspection scope. In these periodic inspections, a sample of 3 percent of the population or a maximum of 10 components per population are visually and mechanically (for buried fire protection gray cast iron and ductile iron components) inspected during each 10 year period.
The acceptance criteria will consist of no visible evidence of selective leaching. For copper based alloys the acceptance criteria will be no noticeable change in color from the normal yellow color to the reddish copper color or green-copper oxide. For gray cast iron and
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 11 Page 3 of 3 ductile iron, the acceptance criteria is the presence of no more than a removable superficial layer of dealloying. The components must meet system design requirements such as minimum wall thickness, when extended to the end of the period of extended operation.
The Selective Leaching Program one-time visual inspections will be conducted within 5 years of, and no later than six months prior to, the period of extended operation. The periodic inspections will recur on 10-year intervals thereafter.
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 12 Page 1 of 2 2 LRA Section: A.1.45 LRA Page Number(s): A-45
Reference:
Applicant Initiated Description of Change: The purpose of NUREG-1801, XI.M33 is to demonstrate the absence of selective leaching. The program for selective leaching of materials ensures the integrity of the components made of gray cast iron and copper alloys (except for inhibited brass) that contain greater than 15 percent zinc (> 15% Zn) or greater than 8 percent aluminum (>8% Al in the case of aluminum-bronze) exposed to a raw water, closed cooling water, treated water, or ground water environment that may lead to selective leaching of one of the metal components where there has not been previous experience of selective leaching. Program scope states For materials and environments where selective leaching is currently occurring, a plant-specific program is required. Plant-specific OE CR-2024-02317 identifies instances of selective leaching occurring at PNPP.
A new section A.1.45 is added to the LRA to accommodate the new plant specific program.
PNPP LRA Section A.1.45, Page A-45 is revised as follows:
A.1.45 PLANT-SPECIFIC PERIODIC INSPECTIONS FOR SELECTIVE LEACHING PROGRAM The Plant-Specific Periodic Inspections for Selective Leaching Program is a new plant-specific program that will monitor for and manage the effects of selective leaching for component material/environment populations that have incurred selective leaching at PNPP. The component material/environment populations included in this program are limited to:
gray cast iron/raw water,
gray cast iron/soil,
gray cast iron (ductile iron)/soil The scope of this program does not include the component material/environment populations that are included in the scope of the XI.M33, Selective Leaching program.
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 12 Page 2 of 2 The Plant-Specific Periodic Inspections for Selective Leaching Program includes periodic and opportunistic inspections using visual examinations coupled with mechanical examination techniques, and destructive examinations. These techniques can determine whether loss of materials due to selective leaching is occurring and whether selective leaching will affect the ability of the components to perform their intended function for the period of extended operation.
The Plant-Specific Periodic Inspections for Selective Leaching Program is a new program, and the initial inspections will commence at least 6 months prior to the period of extended operation, with all required inspections completed within the first 10-year period of the period of extended operation, and a second inspection interval will occur in the second 10-year period of the period of extended operation.
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 13 Page 1 of 2 3 LRA Section: Table A.3 LRA Page Number(s): A-83
Reference:
Applicant Initiated Description of Change: The new Plant-Specific Selective Leaching Program monitors for and manages the effects of selective leaching for the following material/environment populations:
gray cast iron/raw water,
gray cast iron/soil,
gray cast iron (ductile iron)/soil The LRA commitment table of Appendix A (Table A.3) is modified to incorporate the new plant specific program. Also a minor typographical error is corrected for Commitment No. 43.
PNPP LRA Table A.3, Page A-83 (as previously modified under L-24-108 Supplement 3 Attachment 30), is revised as follows:
NOTE: Only those table rows with revised text are included in the following table. Table rows unaffected by these changes are omitted from this attachment.
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 13 Page 2 of 2 Table A.3 License Renewal Commitments Item No.
AMP Commitment Implementation Schedule Related LRA Sections 43 (Cont.)
XI.S6 30.
Acceptance criteria for indication of leaching of calcium hydroxide will be as follows:
Groundwater parameters are no longer be considered non-aggressive if they exceed:
pH < 5.5, chlorides > 500 ppm sulfates >1500 ppm 44 XI.M2 Continue the existing Water Chemistry Program Ongoing A.1.44 B.2.44 45 N/A Continue the existing operating experience program to evaluate age-related degradation or aging management impacts to structures and components to manage aging management program effectiveness and determine the need for new programs consistent with LR-ISG-2011-05.
Ongoing A.1 B.1.4 46 PS-SL Implement the new Plant-Specific Periodic Inspections for Selective Leaching Program May 8, 2026 A.1.45 B.2.45
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 14 Page 1 of 2 4 LRA Section: Table B.1-1 LRA Page Number(s): B-10
Reference:
Applicant Initiated Description of Change: The new Plant-Specific Periodic Inspections for Selective Leaching Program monitors for and manages the effects of selective leaching for the following material/environment populations:
gray cast iron/raw water,
gray cast iron/soil,
gray cast iron (ductile iron)/soil Appendix B for the LRA and Table B.1-1 is revised to accommodate the new plant specific program.
PNPP LRA Table B.1-1, Page B-10 is revised as follows:
NOTE: Only those table rows with the revised text are included in the following table. Table rows unaffected by these changes are omitted from this attachment.
Table B.1-1 Correlation of NUREG-1801 and PNPP Aging Management Programs NUREG-1801 Number NUREG-1801 Program PNPP Program LRA Sections XI.S8 Protective Coating Monitoring and Maintenance Program Protective Coating Monitoring and Maintenance Program B.2.38 XI.E1 Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Non-EQ Insulated Cables and Connections Program B.2.34
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 14 Page 2 of 2 NUREG-1801 Number NUREG-1801 Program PNPP Program LRA Sections XI.E2 Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Non-EQ Instrumentation Circuits Program B.2.33 XI.E3 Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Non-EQ Inaccessible Power Cables Program B.2.32 XI.E4 Metal Enclosed Bus Not applicable. There are no in-scope metal enclosed bus for PNPP N/A XI.E5 Fuse Holders Fuse Holders B.2.24 XI.E6 Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Non-EQ Electrical Cable Connections Program B.2.31 N/A N/A Plant-Specific Periodic Inspections for Selective Leaching Program B.2.45
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 15 Page 1 of 2 5 LRA Section: Table B.1-2 LRA Page Number(s): B-14
Reference:
Applicant Initiated Description of Change: The new Plant-Specific Selective Leaching Program monitors for and manages the effects of selective leaching for the following material/environment populations:
gray cast iron/raw water,
gray cast iron/soil,
gray cast iron (ductile iron)/soil Appendix B for the LRA and Table B.1-2 is revised to accommodate the new plant specific program.
PNPP LRA Table B.1-2, Page B-14 (as previously modified under L-24-110 Annual Update Attachment 8) is revised as follows:
NOTE: Only those table rows with revised text are included in the following table. Table rows unaffected by these changes are omitted from this attachment.
Table B.1-2 Consistency of PNPP Aging Management Programs with NUREG-1801 Program Name New/
Existing Consistent With NUREG-1801 Consistent With NUREG-1801 With Exceptions Plant Specific Enhancement Required Selective Leaching Program New Yes Yes Yes (*) --
Structures Monitoring Program Existing Yes Yes Water Chemistry Program Existing Yes Yes
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 15 Page 2 of 2 Program Name New/
Existing Consistent With NUREG-1801 Consistent With NUREG-1801 With Exceptions Plant Specific Enhancement Required Plant-Specific Periodic Inspections for Selective Leaching Program New Yes Addresses one material/environment combination that experienced selective leaching. The remaining program scope is consistence with NUREG-1801.
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 16 Page 1 of 2 6 LRA Section: B.2.24 LRA Page Number(s): B-79
References:
Applicant Initiated Description of Change: LRA Section B.2.24, Fuse Holders Program is supplemented to correct the text in the conclusion by deleting the text that states there are program enhancements.
PNPP LRA Section B.2.24, Page B-79, (as previously modified under L-24-109 and L-24-189 Supplement 1 Attachment 4) is revised as follows:
B.2.24 FUSE HOLDERS PROGRAM Program Description The Fuse Holders Program is a new Condition Monitoring Program. The program provides reasonable assurance that the intended functions of the metallic clamps of fuse holders located outside of active devices are maintained consistent with the current licensing basis through the period of extended operation. Fuse holders located inside an active device are not within the scope of this program. Fuse holders subject to increased resistance of connection due to chemical contamination, corrosion, and oxidation or fatigue caused by ohmic heating, thermal cycling or electrical transients will be tested, by thermography, contact resistance testing, or other appropriate test methods, at least once every 10 years to provide an indication of the condition of the metallic clamps of the fuse holders.
The first tests for license renewal will be completed no later than six months prior to the period of extended operation.
NUREG-1801 Consistency The Fuse Holders Program is a new PNPP program that is consistent with the 10 elements of an effective aging management program as described in NUREG-1801,Section XI.E5, Fuse Holders.
Exceptions to NUREG-1801:
None.
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 16 Page 2 of 2 Enhancements:
None.
Operating Experience Industry operating experience and guidance as documented in NUREG-1760, IEEE Std. 1205-2000, and NRC Information Notices 86-87, 87-42 and 91-78 has shown that loosening of fuse holders and corrosion of fuse clips are aging mechanisms that could lead to a loss of electrical continuity if left unmanaged.
A review of plant-specific operating experience has found no evidence of thermal anomalies in annual tests of fuse holders outside active devices from 2003 to 2023.
Conclusion The implementation of the Fuse Holders program, with enhancement, provides reasonable assurance that the aging effects will be managed such that components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 17 Page 1 of 6 7 LRA Section: B.2.42 LRA Page Number(s): B-117, B-118, and B-119
References:
Applicant Initiated Description of Change: The purpose of NUREG-1801, XI.M33 is to demonstrate the absence of selective leaching. The program for selective leaching of materials ensures the integrity of the components made of gray cast iron and copper alloys (except for inhibited brass) that contain greater than 15 percent zinc (> 15% Zn) or greater than 8 percent aluminum (>8% Al in the case of aluminum-bronze) exposed to a raw water, closed cooling water, treated water, or ground water environment that may lead to selective leaching of one of the metal components where there has not been previous experience of selective leaching. Program scope states For materials and environments where selective leaching is currently occurring, a plant-specific program is required. Plant-specific OE CR-2024-02317 identifies instances of selective leaching occurring at PNPP. As such, LRA Section B.2.42 is revised to reflect use of a new, plant-specific, on-going aging management program for the material/environment combinations where selective leaching has been identified in the new LRA Section B.2.45 as incorporated in 8 of this supplement.
PNPP LRA Section B.2.42, Pages B-117 through B-119 (as previously modified under L-24-110 Annual Update Attachment 8) is revised as follows:
B.2.42 SELECTIVE LEACHING PROGRAM Program Description The Selective Leaching Program is a new plant-specificcondition monitoring aging management program that will monitor for and manage the effects ofensure the integrity of components within the scope of license renewal that are susceptible to loss of material due to selective leaching by demonstrating the absence of such leaching.
The Selective Leaching Pprogram for selective leaching of materials will ensure the integrity of the components made of ductile iron, gray cast iron and copper alloys (except for inhibited brass) that contain greater than 15 percent zinc (> 15% Zn) exposed toidentify the aging effects of loss of material due to selective leaching for components subject to an environment of raw water, closed cycle cooling water
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 17 Page 2 of 6 (CCCW), treated water, waste water or soil that may lead to selective leaching of one of the metal componentsor condensation.
Components include piping, heat exchangers, pump casings, sight glass (body),
valve bodies and strainer bodies. The materials of construction for these components that are susceptible to selective leaching are ductile iron, gray cast iron and copper alloys (except for inhibited brass) that contain greater than 15 percent zinc (> 15% Zn). There are no aluminum bronze in-scope components with greater than eight percent aluminum.
The program will includeis a one-time visual inspection coupled with eithersupplemented by hardness measurement or other mechanical examination techniques such as destructive testing (when the opportunity arises), scraping, or chipping (where practicable based on component form and configuration) of a representative sample of selected components that may be susceptible to selective leaching. Periodic selective leaching inspections are conducted on component populations with materials and environments that have exhibited selective leaching at PNPP. Follow-up of unacceptable inspection findings will include an evaluation using the corrective action program and a possible expansion of the inspection sample size and location. Destructive examinations of components to determine the presence and depth of dealloying through-wall thickness are conducted.
Each group of components with the same material/environment combination is considered a separate population. Twenty percent of a susceptible component populationOne-time inspections are conducted on a representative sample of the component population and will focus on the bounding or lead components most susceptible to aging due to time in service, severity of operating conditions, and lowest design margin for each population. A representative sample size will be 20% of the population (defined as components having the same material and environment combination) with a maximum of 25 constitutes a representative sample sizecomponents. Where practical, the representative sample of each of those populations will focus on the bounding or lead components most susceptible to aging due to time in service, severity of operating conditions, and lowest design margin. Otherwise, a technical justification of the methodology and sample size used for selecting components for theone-time inspections will be included as part of the programs documentation.
The scope of this program does not include material and environment combinations where selective leaching has occurred and either (1) the component was replaced with the same material or (2) selective leaching is actively occurring. For those material/environment combination populations, a plant specific program will be used as discussed in the OE section below.
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 17 Page 3 of 6 Follow-up of unacceptable inspection findings will include an evaluation using the corrective action program to determine acceptability of the affected components for further service, and a possible expansion of the inspection sample size and location.
According to the GALL Section XI.M33, for materials and environments where selective leaching is currently occurring, a plant specific program is required.
PNPP has recently observed selective leaching in valve bodies (hydrants) that are buried (soil external environment), gray cast iron, fire protection components (raw water internal environment). A review of aging management data confirms that material and environment combination is limited to the fire protection system.
Thus, the population of buried, gray cast iron and ductile iron, fire protection components are subject to periodic inspections, beyond this programs one-time inspection scope. In these periodic inspections, a sample of 3 percent of the population or a maximum of 10 components per population are visually and mechanically (for buried fire protection gray cast iron and ductile iron components) inspected during each 10 year period.
The acceptance criteria will consist of no visible evidence of selective leaching. For copper based alloys the acceptance criteria will be no noticeable change in color from the normal yellow color to the reddish copper color or green-copper oxide.
For gray cast iron and ductile iron, the acceptance criteria is the presence of no more than a removable superficial layer of dealloying. The components must meet system design requirements such as minimum wall thickness, when extended to the end of the period of extended operation.
extended operation.
The Selective Leaching Program one-time visual inspections will be conducted within 5 years of, and no later than six6 months prior to, the period of extended operation. The periodic inspections will recur on 10-year intervals thereafter.
NUREG-1801 Consistency The Selective Leaching Program is a new plant-specific program for PNPP that will be consistent with the 10 elements of an effective aging management program guidance as described in NUREG-1801,Section XI.M33 Selective Leaching andas revised by LR-ISG-2011-03 and LR-ISG-2015-01, with twoone exceptions.
Exceptions to NUREG-1801 1.
Materials exposed to contaminated fuel oil and water-contaminated lube oil are managed under the XI.M39, Lubricating Oil Analysis, and XI.M30, Fuel Oil Chemistry, programs. Program Element Affected: Scope (Element 1)
Justification for exception
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 17 Page 4 of 6 The XI.M39, Lubricating Oil Analysis and XI.M30, Fuel Oil Chemistry programs assure the exclusion of water such that materials susceptible to selective leaching are not exposed to water contamination consistent with NUREG 2191 Section XI.M33.
2.
The periodic selective leaching program is developed using guidance from NUREG-2191. Program Elements Affected: Scope (Element 1), Preventive Actions (Element 2), Parameters Monitored/Inspected (Element 3), Detection of Aging Effects (Element 4), Monitoring and Trending (Element 5),
Acceptance Criteria (Element 6), Operating Experience (Element 10),
ence (Element 10),
Justification for exception NUREG-1801 XI-M33, Selective Leaching, provides guidance for a one-time inspection program provided no plant-specific operating experience identifies multiple occurrences of selective leaching. However, PNPP has observed selective leaching in buried, gray cast iron, fire water system components.
NUREG-2191 XI.M33, Selective
- Leaching, provides recommendations for an acceptable periodic selective leaching aging management program.
Enhancements None Operating Experience The following operating experience review provides objective evidence that the Selective Leaching Program will be effective in ensuring that component intended functions are maintained consistent with the current licensing basis during the period of extended operation.
An extensive review of Operating Experience since 2013 is documented, the following findings were identified in the PNPP corrective action program for selective leaching.
Recent evidence of selective leaching in two gray cast iron fire hydrants was identified as part of one-time inspections at PNPP.PNPP evaluates industry OE items for applicability per the OE Program and takes appropriate corrective actions.
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 17 Page 5 of 6 NRC IN 94-59, Accelerated de-alloying of cast aluminum bronze valves caused by microbiologically induced corrosion, noted that a number of service water Jamesbury cast aluminum bronze ball valves (1.5 to 2 inch) were seeping water through the valve body at the Surrey Power Station.
The cause was determined to be accelerated de-alloying of cast aluminum bronze valves (i.e., selective leaching) initiated by MIC caused by a number or factors.
At PNPP there are no aluminum-bronze in-scope components with greater than eight percent aluminum.
ter than eight percent aluminum.
IN 2020-04 The NRC issued IN 2020-04 Operating Experience Related to Failure of Buried Fire Protection Main Yard Piping dated December 17, 2020. The IN was issued to inform the addressees of OE involving the loss of function of buried cast iron fire water main yard piping due to multiple factors, including graphitic corrosion (i.e., selective leaching), corrosion buildup, low-cyclic fatigue, and general wall thinning or localized loss of material.
PNPP evaluated this IN for applicability and determined the site uses the more reliable cement-lined ductile iron. Opportunistic inspections throughout the fleet have found the cement lining and internal piping in good condition. No further actions were required (see plant-specific OE).
the more reliable cement-lined ductile iron. Opportunistic inspections throughout the fleet have found the cement lining and internal piping in good condition. No further actions were required (see plant-specific OE).
Plant-Specific Operating Experience In 2014 PNPP experienced an unplanned fire impairment due to a leak in underground piping. The leak was found be between two 45° elbows on a 10 ductile iron drain pipe (with concrete lining) between one catch basin and another. The section of pipe was replaced. The failure analysis concluded that the analyzed pipe section suffered OD corrosion around most of the circumference. The bottom surface, with respect to in service orientation, was severely attacked in comparison to the other surfaces. The corrosion type was classified as dealloying. (Component population; Ductile iron material in a soil environment.)
In 2024 a visual inspection found evidence of selective leaching on two fire protection hydrant bowls, the hydrant bowls were replaced.
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 17 Page 6 of 6 Destructive testing was performed on both hydrant bowls. One hydrant bowl had exterior graphitic corrosion. The other had graphitic corrosion on both the interior and exterior surfaces. Hardness measurements were not taken. Both fire hydrants were made of gray cast iron (Component populations: Gray cast iron in a soil environment, and gray cast iron in a raw water environment).
nt).
The NUREG-2191 XI.M33, Selective Leaching program for periodic and one-time inspections provides guidance for developing this plant-specific 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 assured.
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 assured.
Based on the above plant-specific operating experience, a plant-specific leaching program shall be implemented at least 6 months prior to entry into the period of extended operation for the following component material/environment populations.
Gray cast iron/raw water
Gray cast iron/soil
Gray cast iron (ductile iron)/soil Conclusion The Selective Leaching Pprogram will provide reasonable assurance that aging effects will be managed such that the applicable components will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 18 Page 1 of 6 8 LRA Section: B.2.45 LRA Page Number(s): B-130
References:
Applicant Initiated Description of Change: The purpose of NUREG-1801, XI.M33 is to demonstrate the absence of selective leaching. The program for selective leaching of materials ensures the integrity of the components made of gray cast iron and copper alloys (except for inhibited brass) that contain greater than 15 percent zinc (> 15% Zn) or greater than 8 percent aluminum (>8% Al in the case of aluminum-bronze) exposed to a raw water, closed cooling water, treated water, or ground water environment that may lead to selective leaching of one of the metal components where there has not been previous experience of selective leaching. Program scope states For materials and environments where selective leaching is currently occurring, a plant-specific program is required. Plant-specific OE CR-2024-02317 identifies instances of selective leaching occurring at PNPP.
Consistent with Attachment 12 of this supplement, a new LRA Section B.2.45 is incorporated for the new plant specific selective leaching monitoring program.
PNPP LRA Section B.2.45, Page B-130 is revised as follows:
B.2.45 PLANT-SPECIFIC PERIODIC INSPECTIONS FOR SELECTIVE LEACHING PROGRAM Program Description The Plant-Specific Periodic Inspections for Selective Leaching Program is a new plant-specific program that will monitor for and manage the effects of selective leaching for component material/environment populations that have incurred selective leaching at PNPP. This is a plant-specific AMP with the following ten elements defined specifically for PNPP.
Element 1 - Scope of Program: The Plant-Specific Periodic Inspections for Selective Leaching Program will manage loss of material due to selective leaching for component material/environment populations that have incurred selective leaching effects at PNPP. This program will determine whether selective leaching will affect the ability of the components to perform their intended function for the period of extended operation. The component material/environment populations included in this program are limited to:
gray cast iron/raw water,
gray cast iron/soil,
gray cast iron (ductile iron)/soil
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 18 Page 2 of 6 The scope of this program does not include the component material/environment populations that are included in the scope of the Selective Leaching Program (B.2.42).
Element 2 - Preventive Actions: Although the Plant-Specific Periodic Inspections for Selective Leaching Program will not provide guidance on preventive actions, water chemistry control of certain parameters (e.g., pH, concentration of corrosive contaminants, dissolved oxygen),
cathodic protection, or coatings can be effective in minimizing selective leaching.
Element 3 - Parameters Monitored or Inspected: The Plant-Specific Periodic Inspections for Selective Leaching Program will monitor visual appearance (differences in color, porosity, general abnormal surface conditions of materials), surface conditions through mechanical examination techniques (e.g., chipping, scraping), and the presence and depth of dealloying through-wall thickness and surface hardness through destructive examinations. This monitoring will be performed where feasible based on form and configuration.
Element 4 - Detection of Aging Effects: Selective leaching inspections are conducted on a representative sample of each population. A population is defined as the same material and environment combination. Inspections and examinations will consist of the following:
Visual inspections of all accessible surfaces for the component material/environment populations in the scope of this program.
Graphitized cast iron cannot be reliably identified through visual examination, as the appearance of the graphite surface layer created by selective leaching does not always differ appreciably from the typical cast iron surface.
Mechanical examination techniques, such as chipping and scraping, augmented visual inspections for gray cast iron components.
Destructive examinations are used to determine the presence of and depth of dealloying through-wall thickness of components.
Opportunistic and periodic inspections will be conducted for the component material/environment populations in the scope of this program. Opportunistic inspections will be conducted whenever components are opened, or buried or submerged surfaces are exposed.
These inspections will commence at least 6 months prior to the period of extended operation, with all required inspections completed within the first 10 year period of the period of extended operation, and a second inspection interval will occur in the second 10 year period of the period of extended operation.
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 18 Page 3 of 6 The plant-specific periodic inspections in each inspection period consist of two facets: (1) visual/mechanical, and (2) destructive.
The visual/mechanical periodic inspections will consist of a sample of 3 percent of the population or a maximum of 10 components per population. The populations will be visually inspected and mechanically inspected. When inspections are conducted on piping, a 1-foot axial length section is considered as one inspection.
The destructive examinations are dependent on population size and established as follows:
o There are more than 35 gray cast iron valves and other components in a raw water environment (applies to the P49 ESW Screenwash System, P54 Fire Protection System, and P71 Potable Water Systems).
For sample populations with greater than 35 components, PNPP will perform two destructive examinations for this population during each inspection period; otherwise, a technical justification of the methodology and sample size used for selecting components for inspection will be included as part of the programs documentation.
o umentation.
o There are more than 35 gray cast iron valves in a soil environment (applies to the P54 Fire Protection System). For sample populations with greater than 35 components, PNPP will perform two destructive examinations for this population during each inspection period; otherwise, a technical justification of the methodology and sample size used for selecting components for inspection will be included as part of the programs documentation.
o The Fire Protection System contains one gray cast iron (ductile iron) piping component with a soil environment. For populations with less than 35 components, PNPP will perform one destructive examination for this population during each inspection period; otherwise, a technical justification of the methodology and sample size used for selecting components for inspection will be included as part of the programs documentation.
o ping component with a soil environment. For populations with less than 35 components, PNPP will perform one destructive examination for this population during each inspection period; otherwise, a technical justification of the methodology and sample size used for selecting components for inspection will be included as part of the programs documentation.
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 18 Page 4 of 6 The number of visual and mechanical inspections may be reduced by two for each component that is destructively examined beyond the minimum number of destructive examinations recommended in each inspection interval. Inspections, where possible, focus on the bounding or lead components most susceptible to aging based on time-in-service and severity of operating conditions for each population. Opportunistic inspections may be credited as periodic inspections as long as the inspection locations selection criteria are met.
ia are met.
The inspections will follow site procedures that include inspection parameters such as lighting, distance, offset, surface coverage, presence of protective coatings, and cleaning processes.
Element 5 - Monitoring and Trending: Where practical, identified degradation will be evaluated and subsequent rates of degradation will be projected until the next scheduled inspection. Results will be evaluated against acceptance criteria to confirm that the sampling bases (e.g., selection, size, frequency) will maintain the components intended functions throughout the period of extended operation based on the projected rate and extent of degradation.
Program effectiveness will be assessed every five years per NEI 14-12.
Element 6 - Acceptance Criteria: The acceptance criteria for gray cast iron and ductile iron will include:
a) for gray cast iron and ductile iron, the absence of a surface layer that can be easily removed by chipping or scraping or identified in the destructive examinations, b) the presence of no more than a superficial layer of dealloying, as determined by removal of the dealloyed material by mechanical removal, and c) the components meet system design requirements such as minimum wall thickness, when projected to the end of the period of extended operation. When evaluating a component in relation to criterion (b), no credit is taken for the material properties of the dealloyed portion of the component.
When the acceptance criteria are not met such that, it is determined that the affected component should be replaced prior to the end of the period of extended operation, additional inspections will be performed 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
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 18 Page 5 of 6 and exposed to the same environment. The number of additional inspections will be equal to the number of failed inspections for each population within the scope of this program with either of the following, whichever is less:
ach population within the scope of this program with either of the following, whichever is less:
a minimum of five additional visual and mechanical inspections when visual and mechanical inspections did not meet acceptance criteria, or
20 percent of each applicable material and environment combination is inspected, and
a minimum of one additional destructive examination when destruction examination(s) did not meet acceptance criteria.
If subsequent inspections do not meet acceptance criteria, an extent of condition and extent of cause analysis will be conducted to determine the further extent of inspections. The timing of the additional inspections will be 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 will be 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. Additional samples will be inspected for any recurring degradation to ensure corrective actions appropriately address the associated causes. The additional inspections include inspections at each unit with the same material, environment, and aging effect combination within the scope of this program.
n the scope of this program.
The program will include a process to evaluate difficult-to-access surfaces if there are unacceptable inspection findings within the same material and environment population.
Element 7 - Corrective Actions: This element is common to Perry programs and activities that are credited with aging management during the period of extended operation and is discussed in LRA Section B.1.3, Quality Assurance Program and Administrative Controls.
Element 8 - Confirmation Process: This element is common to Perry programs and activities that are credited with aging management during the period of extended operation and is discussed in LRA Section B.1.3, Quality Assurance Program and Administrative Controls.
Perry Nuclear Power Plant LRA Supplement 4 L-24-178 Attachment 18 Page 6 of 6 Element 9 - Administrative Controls: This element is common to Perry programs and activities that are credited with aging management during the period of extended operation and is discussed in LRA Section B.1.3, Quality Assurance Program and Administrative Controls.
Element 10 - Operating Experience: The operating experience review provides objective evidence that the Plant-Specific Periodic Inspections for Selective Leaching Program will be effective in ensuring that component intended functions are maintained consistent with the current licensing basis during the period of extended operation. An extensive review of Operating Experience since 2013 is documented.
Industry OE Industry OE items are evaluated for applicability in accordance with the PNPP OE Program and takes appropriate corrective actions.
Plant-Specific OE
In 2014 PNPP experienced an unplanned fire impairment due to a leak in underground piping. The leak was found be between two 45° elbows on a 10 ductile iron drain pipe (with concrete lining) between one catch basin and another. The section of pipe was replaced. The failure analysis report concluded that the analyzed pipe section suffered OD corrosion around most of the circumference. The bottom surface, with respect to in-service orientation, was severely attacked in comparison to the other surfaces. The corrosion type was classified as dealloying. The affected piping material was ductile iron.
corrosion type was classified as dealloying. The affected piping material was ductile iron.
In 2024 a visual inspection found evidence of selective leaching on two fire protection hydrant bowls, the hydrant bowls were replaced.
Destructive testing was performed on both hydrant bowls. One hydrant bowl had exterior graphitic corrosion. The other had graphitic corrosion on both the interior and exterior surfaces. Hardness measurements were not taken. Both fire hydrants were made of gray cast iron.
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 program is periodically evaluated.