ML24255A332
| ML24255A332 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 10/16/2024 |
| From: | Michele Sampson NRC/NRR/DNRL |
| To: | Snider S Duke Energy Carolinas |
| References | |
| EPID L-2021-SLR-0000 | |
| Download: ML24255A332 (1) | |
Text
Mr. Steven M. Snider Site Vice President Oconee Nuclear Station Duke Energy Carolinas, LLC 7800 Rochester Highway Seneca, SC 29672-0752
SUBJECT:
OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 - SUPPLEMENT TO THE SAFETY EVALUATION FOR THE SUBSEQUENT LICENSE RENEWAL APPLICATION REVIEW, (EPID NO. L-2021-SLR-0000)
Dear Mr. Snider:
By letter dated June 7, 2021 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML21158A193), as supplemented by letters dated October 22, 2021 (ML21295A035), October 28, 2021 (ML21302A208), November 11, 2021 (ML21315A012), December 2, 2021 (ML21336A001), December 15, 2021 (ML21349A005),
December 17, 2021 (ML21351A000), January 7, 2022 (ML22010A129), January 21, 2022 (ML22021A000), February 14, 2022 (ML22045A021), February 21, 2022 (ML22052A002),
March 22, 2022 (ML22081A027), March 31, 2022 (ML22090A046), April 20, 2022 (ML22110A207), April 22, 2022 (ML22112A016), May 11, 2022 (ML22131A023), May 20, 2022 (ML22140A016), May 27, 2022 (ML22147A001), June 7, 2022 (ML22158A028), June 8, 2022 (ML22159A151), July 8, 2022 (Package ML22189A008), July 25, 2022 (Package ML22206A005), and September 2, 2022 (Package ML22245A008), Duke Energy Carolinas, LLC (Duke Energy or applicant) submitted an application for the subsequent license renewal (SLR) of Renewed Facility Operating License Nos. DPR-38, DPR-47, and DPR-55 for Oconee Nuclear Station (ONS), Units 1, 2, and 3, respectively, to the U.S. Nuclear Regulatory Commission (NRC). Duke Energy submitted the application pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, for SLR.
The NRC staff determined that the application was complete and acceptable for docketing as communicated by letter dated July 22, 2021 (ML21194A245) and noticed in the Federal Register on July 28, 2021 (86 FR 40662). The staff completed its review of the ONS Subsequent License Renewal Application (SLRA) and issued the safety evaluation (SE) report on December 19, 2022 (Package ML22349A117).
By Subsequent License Renewal Application Third Annual Update to the License Renewal Application and Subsequent License Renewal Application Supplement 5|letter dated May 24, 2024]] (ML24145A069), Duke Energy submitted its annual update which is intended to identify changes to the ONS plant that materially affect the contents of the SLRA.
Based on the NRC Staffs review of the annual update, the NRC staff identified the need for additional information concerning the aging effect for the ductile iron fire hydrants with internal coatings/linings exposed internally to raw water. In its response dated July 31, 2024 (ML24213A095), Duke Energy revised the applicable Aging Management Review item and SLRA tables to state that the Fire Water System program manages flow blockage of the fire hydrants with internal coatings/linings. Section 3.0.3.2.11, Fire Water System, of the SE is hereby revised to reflect the change, as shown in the enclosure.
October 16, 2024
S. Snider If you have any questions regarding this matter, please contact the SLR project manager, Mr.
Vaughn Thomas, by e-mail at Vaughn.Thomas@nrc.gov.
Sincerely, Michele Sampson, Director Division of New and Renewed Licenses Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270, and 50-287
Enclosure:
Section 3.0.3.2.11 of the SE cc w/encl: Listserv Signed by Sampson, Michele on 10/16/24
S. Snider
SUBJECT:
OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 - SUPPLEMENT TO THE SAFETY EVALUATION FOR THE SUBSEQUENT LICENSE RENEWAL APPLICATION REVIEW, (EPID NO. L-2021-SLR-0000)
DATED: OCTOBER 16, 2024 DISTRIBUTION:
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PUBLIC RidsNrrDnrl Resource RidsNrrPMOconee Resource RidsACRS_MailCTR Resource RidsRgn2MailCenter Resource RidsRgn2Dnms Resource RidsRgn2Drp Resource RidsRgn2Drs Resource RidsRgn2Ora Resource RidsRgn2Opa Resource RidsNrrOd Resource VThomas, NRR/DNRL LGibson, NRR/DNRL LRakovan, NMSS/REFS TSmith, NMSS/REFS MSampson, NRR/DNRL SLee, NRR/DNRL SWilliams, NRR/DORL MMarkley, NRR/DORL MWoods, OGC MWright, OGC KBernstein, OGC RSkokowski, OEDO MMcCoppin, OEDO SBurnell, HQ/OPA DMcIntyre, HQ/OPA CWolf, OCA LWilkins, OCA DGasperson, RII/OPA JPelchat, RII/FCO DScrenci, RI/OPA JNadel, RII/DRP JBaptist, RII/DRS Paul.Guill@duke-energy.com ADAMS ML24255A332 Via Econcurrence NRR-106 OFFICE DNRL/NLRP:PM DNRL/NLRP:LA OGC NAME VThomas KBratcher MWoods DATE 9/11/2024 9/11/2024 10/9/2024 OFFICE DNLR/NLRP:BC DNRL:D NAME LGibson MSampson DATE 10/10/2024 10/16/24
Enclosure Enclosure 3.0.3.2.11 Fire Water System SLRA Section B2.1.16 states that the Fire Water System program is an existing program with enhancements that will be consistent with the program elements in the GALL SLR Report AMP XI.M27, Fire Water System, except for the exceptions identified in the SLRA. The applicant amended this SLRA section by Supplement 1 dated October 28, 2021; by Supplement 2 dated November 11, 2021; by letter dated February 14, 2022; by Supplement 4 dated June 7, 2022; and by Subsequent License Renewal Application Response to Request for Additional Information 2024 Annual Update and Subsequent License Renewal Application Supplement 5 Addition|letter dated July 31, 2024]] (ADAMS Accession Nos. ML21302A208, ML21315A012, ML22045A021, ML22158A028, and ML24213A095, respectively).
Staff Evaluation. During its audit, the staff reviewed the applicants claim of consistency with the GALL-SLR Report. The staff compared the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA to the corresponding program elements of GALL-SLR Report AMP XI.M27.
For the scope of the program, detection of aging effects, monitoring and trending, and acceptance criteria program elements, the staff had questions regarding main drain pressure test monitoring, inspection guidance, status of previous changes to SLRA Table A6.0-1 for the Fire Water System program, internal inspections of piping, test result trending, and flow blockage of ductile iron fire hydrants with internal coatings/linings and issued RAI B2.1.16-1, RAI B2.1.16-2, RAI B2.1.16-2a, RAI B2.1.16-3, RCI 2.1.16-A, and RAI - 2024 Annual Update. The staffs requests and the applicants responses are documented in ADAMS Accession Nos. ML22045A021, ML22112A016, ML21336A001, and ML24213A095.
In its response to B2.1.16-1, the applicant stated that the results of original acceptance testing would not provide a valid baseline for the main drain testing due to system modifications since initial construction. The applicant stated that the baseline value will be established using the results of the initial main drain testing. The staff finds the applicants response acceptable because main drain testing results will be compared with a baseline value established using the initial main drain testing results and, as a result, degradation of the fire water system supply over several years can be reasonably identified. For additional information related to the main drain testing of deluge systems, see the discussion of Enhancement 9 below.
In its response to B2.1.16-2, the applicant revised SLRA Sections A2.16 and B2.1.16 and SLRA Table A6.0-1 to clarify the additional inspection guidance for age-related degradation that will be added to the Fire Water System program inspection procedures.
The staff finds the applicants response acceptable because the SLRA has been updated to clarify that inspection procedures will be revised to include specific guidance for the identification and documentation of age-related degradation. For additional information, see the discussion of Enhancement 5 below.
In its response to B2.1.16-2a, the applicant stated that previous changes made to the Fire Water System program are still in effect and provided a consolidated SLRA Table A6.0-1 showing all previously made changes. In addition, the applicant revised SLRA Table A6.0-1 by making two editorial changes to Enhancement 9. The staff finds the applicants response acceptable because the consolidated SLRA Table A6.0-1 includes all previous changes made to the Fire Water System program, and the two editorial changes to Enhancement 9 do not change the previous changes related to main drain testing of deluge systems.
In its response to B2.1.16-3, the applicant revised SLRA Section B2.1.16 to clarify that Exception 3 applies to sprinkler system piping within the scope of the Fire Water System program. Specifically, the applicant stated that Exception 3 applies to all system piping that is maintained dry between the first block isolation valve and the sprinklers in the manually actuated dry sprinkler systems for the cable room, cable shaft level 3, and cable shaft level 4 & 5 rooms. The staff finds the applicants response acceptable because the SLRA was revised to clarify the applicability of Exception 3. For additional information, see the discussion of Exception 3 below.
The applicant confirmed the following in its response to RCI 2.1.16-A: (1) the Oconee Fire Water System program trends flow test and ultrasonic test results not entered into the corrective actions program in addition to trending flow test and ultrasonic test results not meeting acceptance criteria that are entered into the corrective actions program, and (2) all unexpected results of flushes are entered into the corrective actions program (all flush result trending is performed under the corrective actions program). The staff finds the applicants response acceptable because results of flow tests, ultrasonic tests, and flushes will be trended, which is consistent with GALL-SLR Report AMP XI.M27.
In its response to RAI - 2024 Annual Update, the applicant revised Item Number 3.3.1-063 in SLRA Table 3.3.1 to state that the Fire Water System program manages flow blockage of the fire hydrants with internal coatings/linings; revised SLRA Table 3.3.2-24 to cite Item Number 3.3.1-063 for managing flow blockage of the ductile iron with internal coating/lining fire hydrant exposed internally to raw water by the Fire Water System program; and revised SLRA Section B2.1.16 to state that the internal surface of the fire hydrants with an internal coating/lining is managed by the Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks program. The response also stated that SLRA Section 3.3.2.1.26 and SLRA Table 3.3.2-26 were not revised to include gray cast iron and ductile iron fire hydrants with internal coatings/linings because the new model hydrants were not installed in the Keowee Fire Detection/Protection System. The staff finds the applicants response acceptable because, consistent with the GALL-SLR Report, flow blockage of the ductile iron with internal coating/lining fire hydrant exposed internally to raw water will be managed by the Fire Water System program. In addition, consistent with the GALL-SLR Report, loss of material and loss of coating or lining integrity for the internal surfaces of the fire hydrants with an internal coating/lining will be managed by the Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks program.
The staff also reviewed the portions of the parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements associated with the exceptions and enhancements to determine whether the program will be adequate to manage the aging effects for which it is credited. The staffs evaluation of these exceptions and enhancements are as follows.
Exception 1. As amended by Supplement 2 dated November 11, 2021 (ADAMS Accession No. ML21315A012), SLRA Section B2.1.16 was updated to delete Exception 1 to the detection of aging effects program element related to flow testing at hose stations other than the hose station that is hydraulically the most remote. See discussion of Enhancement 6 below regarding hose station flow testing.
Exception 2. SLRA Section B2.1.16 includes an exception to the detection of aging effects program element related to air discharge testing of deluge systems without compressed air connections. The staff reviewed this exception against the corresponding program element in GALL-SLR Report AMP XI.M27 and finds it acceptable because deluge systems that will not be air tested will have (1) periodic visual inspections to verify correct spray nozzle positions, consistent with Section 10.3.4.3 of National Fire Protection Association (NFPA) 25, (2) trip testing every 2 years to verify operation of the deluge valves, (3) periodic main drain testing at each deluge valve to ensure that the water supply pipe is not excessively fouled and any accumulated debris is cleared, (4) internal inspections of upstream and downstream piping attached to the deluge valve in each system every 5 years, (5) internal inspections of branch lines supplying individual spray nozzles for loss of material and flow blockage, and (6) internal inspections following removal of a spray nozzle every 5 years from one branch line in 50 percent of the deluge systems that are not flow tested for detecting plugged nozzles and degradation that may result in plugged nozzles.
Exception 3. As amended by letter dated February 14, 2022 (ADAMS Accession No. ML22045A021), SLRA Section B2.1.16 includes an exception to the detection of aging effects program element related to periodic internal inspections of sprinkler system piping. Specifically, periodic internal inspections will not be performed for all system piping that is maintained dry between the first block isolation valve and the sprinklers in the manually actuated dry sprinkler systems for the cable room, cable shaft level 3, and cable shaft level 4 & 5 rooms. The applicant stated that these systems are maintained dry and are not subject to periodic wetting during testing, and plant-specific OE did not identify instances of these systems being actuated. In addition, these systems are isolated from the supply header by two locked, closed isolating valves. Downstream, at a system low point from the two locked, closed isolating valves is a tell-tale drain with a normally open drain valve. The staff reviewed this exception against the corresponding program element in GALL-SLR Report AMP XI.M27 and finds it acceptable because (1) the manually actuated dry sprinkler systems for the cable room, cable shaft level 3, and cable shaft level 4 and 5 rooms are maintained dry and are not subject to periodic wetting during testing, (2) the two locked isolating valves are verified to be locked closed, (3) the tell-tale drain valve is verified to be open, and (4) the tell-tale drain is inspected monthly for leakage.
Enhancement 1. SLRA Section B2.1.16 includes an enhancement to the parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements related to internal visual inspections of deluge system piping. The staff reviewed this enhancement against the corresponding program elements in GALL-SLR Report AMP XI.M27 and finds it acceptable because, when it is implemented, (1) internal visual inspection of the deluge system piping not subject to flow testing every 5 years (see discussion of Exception 2 above) will be performed by removing a hydraulically remote nozzle (50 percent every 5 years, alternate systems inspected during subsequent 5 year inspection period, so that 100 percent are inspected every 10 years), and (2) follow-up volumetric wall thickness examinations will be performed when an unexpected level of degradation is identified by the internal visual inspections and, as a result, these inspections can detect internal corrosion, foreign material, and obstructions to flow.
Enhancement 2. SLRA Section B2.1.16 includes an enhancement to the parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements related to submitting sprinkler heads for field-service testing prior to 50 years in service. The staff reviewed this enhancement against the corresponding program elements in GALL-SLR Report AMP XI.M27 and finds it acceptable because, when it is implemented, sprinkler heads that have been in service for 50 years will be submitted for field-service testing by a recognized testing laboratory consistent with Section 5.3.1 of NFPA 25, which is consistent with GALL-SLR Report AMP XI.M27.
Enhancement 3. As amended by Supplement 2 dated November 11, 2021 (ADAMS Accession No. ML21315A012), SLRA Section B2.1.16 includes an enhancement to the parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements related to one-time volumetric wall thickness inspection of deluge system supply piping that is periodically subject to flow during functional testing. The staff reviewed this enhancement against the corresponding program elements in GALL-SLR Report AMP XI.M27 and finds it acceptable because, when it is implemented, a one-time volumetric inspection will be performed on a representative sample of deluge system supply piping that is periodically subject to flow during functional testing and will include criteria for selecting the inspection locations and acceptance criteria and determining the need for follow-up examinations based on results.
Enhancement 4. SLRA Section B2.1.16 includes an enhancement to the parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements related to internal flow blockage identified during internal inspections. The staff reviewed this enhancement against the corresponding program elements in GALL-SLR Report AMP XI.M27 and finds it acceptable because, when it is implemented, (1) an obstruction investigation consistent with Section 14.3 of NFPA 25 will be performed if unacceptable internal flow blockage is identified during internal inspections, and (2) corrective actions for unacceptable internal flow blockage will include removal of the material, an extent of condition determination, a review for increased inspections, follow-up examinations, and a flush consistent with Annex D.5 of NFPA 25, which are consistent with the GALL-SLR Report AMP XI.M27.
Enhancement 5. As amended by letter dated February 14, 2022 (ADAMS Accession No. ML22045A021), SLRA Section B2.1.16 includes an enhancement to the parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements related to revising procedures to provide additional inspection guidance for identification and documentation of age-related degradation and to include inspection parameters (i.e., lighting, distance, offset, protective coatings, and cleaning processes). The staff reviewed this enhancement against the corresponding program elements in GALL-SLR Report AMP XI.M27 and finds it acceptable because, when it is implemented, procedures will include guidance specific to the identification and documentation of age-related degradation and inspection parameters for items such as lighting, distance, offset, protective coatings, and cleaning processes, which is consistent with GALL-SLR Report AMP XI.M27.
Enhancement 6. As amended by Supplement 2 dated November 11, 2021 (ADAMS Accession No. ML21315A012), SLRA Section B2.1.16 includes an enhancement to the parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements related to flow testing at hose stations. The staff reviewed this enhancement against the corresponding program elements in GALL-SLR Report AMP XI.M27 and finds it acceptable because, when it is implemented, (1) at least one hose station in each building will be flow tested every 5 years; (2) the flow testing will be performed at the hose station that is hydraulically the most remote; (3) at least two additional tests will be performed within 2 years if acceptance criteria are not met; (4) an extent of condition and extent of cause analysis will be conducted if subsequent tests do not meet acceptance criteria; and (5) additional tests will include at least one test at one of the other units with same material, environment, and aging effect combination, consistent with GALL-SLR Report AMP XI.M27.
Enhancement 7. SLRA Section B2.1.16 includes an enhancement to the parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements related to performing external visual inspections of the elevated water storage tank (EWST). The staff reviewed this enhancement against the corresponding program elements in GALL-SLR Report AMP XI.M27 and finds it acceptable because, when it is implemented, external visual inspections of the EWST will be performed every 2 years, consistent with Section 9.2.5.5 of NFPA 25, which is consistent with GALL-SLR Report AMP XI.M27.
Enhancement 8. SLRA Section B2.1.16 includes an enhancement to the parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements related to performing flushing of mainline strainers. The staff reviewed this enhancement against the corresponding program elements in GALL-SLR Report AMP XI.M27 and finds it acceptable because, when it is implemented, mainline strainers will be flushed after system actuation, consistent with Section 10.2.7 of NFPA 25, which is consistent with GALL-SLR Report AMP XI.M27.
Enhancement 9. As amended by Supplement 2 dated November 11, 2021 (ADAMS Accession No. ML21315A012), SLRA Section B2.1.16 includes an enhancement to the parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements related to main drain testing of deluge systems. The staff reviewed this enhancement against the corresponding program elements in GALL-SLR Report AMP XI.M27 and finds it acceptable because, when it is implemented, (1) main drain testing of deluge systems will be performed, consistent with Sections 13.2.5 and A.13.2.5 of NFPA 25; (2) when there is a 10 percent reduction in full flow pressure when compared to a baseline value established using the results of the initial main drain testing results, the cause shall be identified and corrected; (3) at least two additional tests will be performed within 2 years if acceptance criteria are not met; (4) an extent of condition and extent of cause analysis will be conducted if subsequent tests do not meet acceptance criteria; and (5) additional tests will include at least one test at one of the other units with same material, environment, and aging effect combination, consistent with GALL-SLR Report AMP XI.M27.
Enhancement 10. SLRA Section B2.1.16 includes an enhancement to the parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements related to internal inspections and wall thickness measurements of the EWST. The staff reviewed this enhancement against the corresponding program elements in GALL-SLR Report AMP XI.M27 and finds it acceptable because, when it is implemented, the acceptance criteria and corrective actions for the EWST will be in accordance with the recommendations in GALL-SLR Report AMP XI.M42 for internally coated or lined fire water tanks, and EWST wall thickness measurements will be performed when interior pitting or general corrosion (beyond minor surface rust) is detected, consistent with GALL-SLR Report AMP XI.M27.
Enhancement 11. As amended by Supplement 1 dated October 28, 2021 (ADAMS Accession No. ML21302A208), SLRA Section B2.1.16 includes an enhancement to the parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements related to training and qualification of personnel involved with inspecting the EWST internal coatings and evaluating degraded conditions. The staff reviewed this enhancement against the corresponding program elements in GALL-SLR Report AMP XI.M27 and finds it acceptable because, when it is implemented, personnel involved with inspecting the EWST internal coatings and evaluating degraded conditions will be trained and qualified in accordance with an American Society for Testing and Materials (ASTM) international standard endorsed in RG 1.54, which is consistent with the GALL-SLR Report AMP XI.M42 recommendation to enhance the Fire Water System program to include its training and qualification recommendations for internally coated fire water storage tanks.
Based on a review of the SLRA, amendments, and the applicants response to RAI B2.1.16-1, RAI B2.1.16-2, RAI B2.1.16-2a, RAI B2.1.16-3, RCI 2.1.16-A, and RAI - 2024 Annual Update, the staff finds that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements for which the applicant claimed consistency with the GALL-SLR Report are consistent with the corresponding program elements of GALL-SLR Report AMP XI.M27. The staff also reviewed the exceptions associated with the detection of aging effects program element and their justifications and finds that the AMP, with the exceptions, is adequate to manage the applicable aging effects. In addition, the staff reviewed the enhancements associated with the parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements and finds that, when implemented, they will make the AMP adequate to manage the applicable aging effects.
OE. SLRA Section B2.1.16 summarizes OE related to the Fire Water System program.
The staff reviewed OE information in the application and during the audit. As discussed in the Audit Report, the staff reviewed the plant OE information the applicant provided for this program to: (a) identify examples of age-related degradation, and (b) provide a basis for the staffs conclusions on the ability of the applicants proposed AMPs to manage the effects of aging in the subsequent period of extended operation. The staff did not identify any OE indicating that the applicant should modify its proposed program. Based on its audit and review of the application, the staff finds that the conditions and OE at the plant are bounded by those for which the Fire Water System program was evaluated.
UFSAR Supplement. SLRA Section A2.16, as amended by Supplement 1 dated October 28, 2021; by Supplement 2 dated November 11, 2021; by letter dated February 14, 2022; and by Supplement 4 dated June 7, 2022 (ADAMS Accession Nos. ML21302A208, ML21315A012, ML22045A021, and ML22158A028, respectively), provides the UFSAR supplement for the Fire Water System program. The staff reviewed this UFSAR supplement description of the program, as amended, and noted that it is consistent with the recommended description in GALL-SLR Report Table XI-01. The staff also noted in SLRA Table A6.0-1 that the applicant committed to enhance the Fire Water System program by implementing Enhancements 1 through 11, discussed above, 5 years prior to the subsequent period of extended operation. The staff finds that the information in the UFSAR supplement is an adequate summary description of the program.
Conclusion. Based on its review of the applicants Fire Water System program, the staff concludes that those program elements for which the applicant claimed consistency with the GALL-SLR Report are consistent. The staff also reviewed the exceptions and enhancements, and finds that, with the exceptions and the enhancements when implemented prior to the subsequent period of extended operation, the AMP will be adequate to manage the applicable aging effects. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the subsequent period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).