RS-24-133, Supplement No. 2 - Changes to the Clinton Power Station, Unit 1 - License Renewal Application

Supplement No. 2 - Changes to the Clinton Power Station, Unit 1 - License Renewal Application

ML24355A050
Person / Time
Site:	Clinton
Issue date:	12/20/2024
From:	Wilson C Constellation Energy Generation
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
RS-24-133
Download: ML24355A050 (1)

Text

200 Energy Way Kennett Square, PA 19348 www.ConstellationEnergy.com RS-24-133 10 CFR 50 10 CFR 51 10 CFR 54 December 20, 2024 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461

Subject:

Supplement No. 2 - Changes to the Clinton Power Station, Unit 1, License Renewal Application

References:

1. Letter from Christopher D. Wilson (Constellation Energy Generation, LLC) to U.S. NRC, Application for Renewed Operating License, dated February 14, 2024 (ML24045A024)

2. Letter from Christopher D. Wilson (Constellation Energy Generation, LLC) to U.S. NRC, Supplement No. 1 - Changes to the Clinton Power Station, Unit 1, License Renewal Application, dated November 27, 2024 (ML24332A051)

In Reference 1, Constellation Energy Generation, LLC (CEG) submitted a License Renewal Application (LRA) for Clinton Power Station, Unit 1 (CPS). In Reference 2, CEG submitted Supplement No. 1 to the LRA for CPS. The purpose of this letter is to provide Supplement No. 2 to the LRA for CPS. Supplement No. 2 includes 10 changes to the LRA which provide additional information and clarifications to address NRC Safety Review Audit information needs, as well as a minor change identified by CEG.

Enclosure A to this letter provides a description of each change, and corresponding mark-ups to affected portions of the LRA, thereby supplementing the CPS LRA.

Enclosure B to this letter provides an update to the License Renewal Commitment List (LRA Appendix A, Section A.5). There are no other new or revised regulatory commitments contained in this letter.

This submittal has been discussed with the NRC License Renewal Project Manager for the CPS License Renewal project.

December 20, 2024 U.S. Nuclear Regulatory Commission Page 2 Should you have any questions regarding this submittal, please contact Ms. Lydia S.

Dworakowski, Licensing Lead, CPS License Renewal Project, by email at Lydia.Dworakowski@constellation.com.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 20th day of December 2024.

Respectfully, Christopher D. Wilson License Renewal Director Constellation Energy Generation, LLC

Enclosures:

A. Changes to the Clinton Power Station, Unit 1, License Renewal Application B. Clinton License Renewal Commitment List Update cc:

NRC Regional Administrator, Region III NRC Senior Resident Inspector - Clinton Power Station NRC Project Manager (Safety Review), NRR-DNRL NRC Project Manager (Environmental Review), NRR-DNRL NRC Project Manager, NRR-DORL - Clinton Power Station Illinois Emergency Management Agency - Division of Nuclear Safety Wilson, Christopher D Digitally signed by Wilson, Christopher D Date: 2024.12.20 09:33:21 -05'00'

December 20, 2024 Enclosure A Page 1 of 44 Enclosure A Changes to the Clinton Power Station, Unit 1, License Renewal Application Introduction This enclosure contains 10 changes that are being made to the License Renewal Application (LRA) that were identified after submittal of the LRA. For each item, the change is described and the affected page number(s) and portion(s) of the LRA are provided. For clarity, entire sentences or paragraphs from the LRA are provided. Previously submitted information is shown in normal font. Additions due to this submittal are highlighted with bolded italics for inserted text, and strikethroughs for deleted text. Revisions to LRA tables are shown by providing excerpts from the affected tables.

December 20, 2024 Enclosure A Page 2 of 44 Change #1 - Clarification Regarding Adverse Localized Environments Added to Appendix B, Section B.2.1.37 Affected LRA Section: Appendix B, Section B.2.1.37 LRA Page Number: B-160 Description of Change:

LRA Appendix B, Section B.2.1.37 is being revised to provide clarification regarding how adverse localized environments are identified at Clinton Power Station.

Accordingly, LRA Appendix B, Section B.2.1.37 is revised.

December 20, 2024 Enclosure A Page 3 of 44 LRA Appendix B, Section B.2.1.37, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Requirements, page B-160, second paragraph is revised as shown below.

B.2.1.37 Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program Description The Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements aging management program is a new condition monitoring program that will be used to manage the effects of reduced insulation resistance of the insulation material for non-EQ cables and connections within the scope of license renewal that are subject to adverse localized environments caused by heat, radiation, or moisture.

In most areas of Clinton, the actual ambient environments (e.g., temperature, radiation, or moisture) are less severe than the plant design environment. An adverse localized environment is a condition in a limited plant area that is significantly more severe than the specified service environment for the cable or connection. Adverse localized environments are identified considering CPS specific environmental considerations. Implementing procedures require identification and documentation of known adverse localized temperature and radiation environments. Sources for this list include plant operating history, corrective action work requests, previous walkdown data and radiation protection surveys. Conductor insulation materials used in electrical cables and connections may degrade more rapidly than expected in these adverse localized environments.

December 20, 2024 Enclosure A Page 4 of 44 Change #2 - Correct NUREG-1801 Line Item in Primary Containment Ventilation System Affected LRA Section: Table 3.3.2-14 LRA Page Number: 3.3-201 Description of Change:

Table 3.3.2-14 incorrectly cites NUREG-1801 VII.F3.AP-109, NUREG-1800 Item 3.3.1-79 for Heat Exchanger (CGCS Cubicle Coil Cabinet) Tube Side Components. Table 3.3.2-14 is being revised to align with VII.G.AP-143, Item 3.3.1-89.

Accordingly, LRA Table 3.3.2-14 is revised.

December 20, 2024 Enclosure A Page 5 of 44 LRA Table 3.3.2-14, Primary Containment Ventilation System, Summary of Aging Management Evaluation, page 3.3-201 is revised as shown below:

Table 3.3.2-14 Primary Containment Ventilation System Summary of Aging Management Evaluation Table 3.3.2-14 Primary Containment Ventilation System Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Programs NUREG-1801 Item NUREG-1800 Table 1 Item Notes Heat Exchanger (CGCS Cubicle Coil Cabinet) Tube Side Components Structural Integrity (Attached)

Copper Alloy with 15% Zinc or less Condensation (External)

Loss of Material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25)

VII.F3.AP-109 VII.G.AP-143 3.3.1-79 3.3.1-89 C, 2

December 20, 2024 Enclosure A Page 6 of 44 Change #3 - Revise NUREG-1801 Item and Associated Note for Fire Protection System Bolting in Raw Water Affected LRA Sections: Table 3.3.1 and Table 3.3.2-9 LRA Page Numbers: 3.3-60 and 3.3-150 Description of Change:

NUREG-1801 Item and Note associated with loss of material of submerged fire water pump bolting is inconsistent with similar bolting in the Open Cycle Cooling Water System. The fire water pump bolting line item and note are being revised.

Accordingly, LRA Table 3.3.1 and Table 3.3.2-9 are revised.

December 20, 2024 Enclosure A Page 7 of 44 LRA Table 3.3.1, Summary of Aging Management Evaluations for the Auxiliary Systems, page 3.3-60 is revised as shown below.

This LRA markup includes changes submitted in Supplement 1, dated November 27, 2004, which revised the Discussion to include reference to the Open Cycle Cooling Water System via Change #28 and is duplicated here as an aid to the reviewer.

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 3.3.1-64 Steel, Copper alloy Piping, piping components, and piping elements exposed to Raw water Loss of material due to general, pitting, crevice, and microbiologically-influenced corrosion; fouling that leads to corrosion; flow blockage due to fouling Chapter XI.M27, "Fire Water System" No Consistent with NUREG-1801 with exceptions. The Fire Water System (B.2.1.17) program will be used to manage loss of material, fouling that leads to corrosion, and flow blockage of carbon steel, copper alloy with 15% zinc or less, copper alloy with greater than 15% zinc, ductile cast iron, galvanized steel, and gray cast iron piping, piping components, and piping elements and tanks exposed to raw water in the Fire Protection System and Open Cycle Cooling Water System.

An exception applies to the NUREG-1801 recommendations for Fire Water System (B.2.1.17) program implementation.

The Bolting Integrity (B.2.1.11) program has been substituted and will be used to manage loss of material of carbon and low alloy steel bolting exposed to raw water in the Fire Protection System.

December 20, 2024 Enclosure A Page 8 of 44 LRA Table 3.3.2-9, Fire Protection System, Summary of Aging Management Evaluation, page 3.3-150 is revised as shown below:

Table 3.3.2-9 Fire Protection System Summary of Aging Management Evaluation Table 3.3.2-9 Fire Protection System Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Programs NUREG-1801 Item NUREG-1800 Table 1 Item Notes Bolting (Closure)

Mechanical Closure Carbon and Low Alloy Steel Bolting Air - Indoor, Uncontrolled (External)

Loss of Material Bolting Integrity (B.2.1.11)

VII.I.AP-125 3.3.1-12 A

Loss of Preload Bolting Integrity (B.2.1.11)

VII.I.AP-124 3.3.1-15 A

Air - Outdoor (External)

Loss of Material Bolting Integrity (B.2.1.11)

VII.I.AP-126 3.3.1-12 A

Loss of Preload Bolting Integrity (B.2.1.11)

VII.I.AP-263 3.3.1-15 A

Raw Water (External)

Loss of Material Bolting Integrity (B.2.1.11)

VII.G.A-33 3.3.1-64 E, 1 H, 1 Loss of Preload Bolting Integrity (B.2.1.11)

VII.I.AP-264 3.3.1-15 A

Soil (External)

Loss of Material Buried and Underground Piping and Tanks (B.2.1.28)

VII.I.AP-241 3.3.1-109 B

Loss of Preload Bolting Integrity (B.2.1.11)

VII.I.AP-242 3.3.1-14 A

Galvanized Bolting Air - Outdoor (External)

Loss of Material Bolting Integrity (B.2.1.11)

VII.I.AP-126 3.3.1-12 A

Loss of Preload Bolting Integrity (B.2.1.11)

VII.I.AP-263 3.3.1-15 A

Soil (External)

Loss of Material Buried and Underground Piping and Tanks (B.2.1.28)

VII.I.AP-241 3.3.1-109 B

Loss of Preload Bolting Integrity (B.2.1.11)

VII.I.AP-242 3.3.1-14 A

December 20, 2024 Enclosure A Page 9 of 44 Change #4 - Jet Pump Holddown Beam TLAA Removal and Addition of a Note for Clarification Affected LRA Section: Table 3.1.2-3 LRA Page Numbers: 3.1-69, 3.1-70, and 3.1-72 Description of Change:

Cumulative Fatigue Damage was incorrectly assigned as an aging effect requiring management for the Jet Pump Assemblies: Holddown beam component type. As such, the aging effect is being removed for this component type in LRA Table 3.1.2-3. Additionally, Plant Specific Note 5 is being added to LRA Table 3.1.2-3 to clearly state which jet pump components are evaluated as fatigue TLAAs.

Accordingly, LRA Table 3.1.2-3 is revised.

December 20, 2024 Enclosure A Page 10 of 44 LRA Table 3.1.2-3, Reactor Vessel Internals, Summary of Aging Management Evaluation, pages 3.1-69, 3.1-70, and 3.1-72 are revised as shown below:

Table 3.1.2-3 Reactor Vessel Internals (Continued)

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Programs NUREG-1801 Item NUREG-1800 Table 1 Item Notes Jet Pump Assemblies:

Holddown beam Direct Flow X-750 alloy Reactor Coolant and Neutron Flux Cracking BWR Vessel Internals (B.2.1.9)

IV.B1.RP-381 3.1.1-104 A

Water Chemistry (B.2.1.2)

IV.B1.RP-381 3.1.1-104 B

Cumulative Fatigue Damage TLAA IV.B1.R-53 3.1.1-3 A, 1

December 20, 2024 Enclosure A Page 11 of 44 Table 3.1.2-3 Reactor Vessel Internals (Continued)

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Programs NUREG-1801 Item NUREG-1800 Table 1 Item Notes Jet Pump Assemblies: Inlet riser, brace and sleeve, elbow, wedge, diffuser, holddown beam bolt Direct Flow Stainless Steel Reactor Coolant and Neutron Flux Cracking BWR Vessel Internals (B.2.1.9)

IV.B1.R-100 3.1.1-103 A

Water Chemistry (B.2.1.2)

IV.B1.R-100 3.1.1-103 B

Cumulative Fatigue Damage TLAA IV.B1.R-53 3.1.1-3 A, 15 Loss of Material BWR Vessel Internals (B.2.1.9)

IV.B1.RP-26 3.1.1-43 E, 2 Water Chemistry (B.2.1.2)

IV.B1.RP-26 3.1.1-43 B

BWR Vessel Internals (B.2.1.9)

IV.B1.RP-377 3.1.1-100 A

Loss of Preload TLAA H, 4

December 20, 2024 Enclosure A Page 12 of 44 Table 3.1.2-3 Reactor Vessel Internals (Continued)

Plant Specific Notes:

1. The TLAA designation in the Aging Management Program column indicates that fatigue of this component is evaluated in Section 4.3.

2. The BWR Vessel Internals AMP (B.2.1.9) is substituted to manage the aging effects applicable to this component type, material, and environment combination.

3. Nickel Alloy is evaluated to have no aging effects in an environment of Air/Gas - Dry consistent with other GALL entries for materials in dry air or gas.

4. The TLAA designation in the Aging Management Program column indicates that loss of preload due to thermal or irradiation-enhanced stress relaxation of the core shroud repair tie-rod and jet pump holddown beam bolt is evaluated in Section 4.2.

5. The TLAA designation in the Aging Management Program column indicates that fatigue of the Jet Pump Riser Brace is evaluated in Section 4.3.

December 20, 2024 Enclosure A Page 13 of 44 Change #5 - Modify Tables 3.2.1 and 3.5.1 Items for Not Used and Not Applicable Affected LRA Sections: Table 3.2.1 and Table 3.5.1 LRA Page Numbers: 3.2-15, 3.5-44, and 3.5-45 Description of Change:

LRA Table 3.2.1 Item Number 3.2.1-14 Discussion is modified to state that it is Not Used rather than Not Applicable.

LRA Table 3.5.1 Item Number 3.5.1-16 Discussion is modified to state that it is Not Applicable rather than Not Used, and to remove a reference to a separate item number.

LRA Table 3.5.1 Item Number 3.5.1-17 Discussion is modified to state that it is Not Applicable rather than Not Used, to add additional discussion as to why the item number is not applicable, and to remove a reference to a separate item number.

Accordingly, LRA Table 3.2.1 and LRA Table 3.5.1 are revised for clarity.

December 20, 2024 Enclosure A Page 14 of 44 LRA Table 3.2.1, Summary of Aging Management Evaluations for the ESF, page 3.2-15 is revised as shown below:

Table 3.2.1 Summary of Aging Management Evaluations for the ESF Item Number Component Aging Effect/

Mechanism Aging Management Programs Further Evaluation Recommended Discussion 3.2.1-14 Steel Closure bolting exposed to Air with steam or water leakage Loss of material due to general corrosion Chapter XI.M18, "Bolting Integrity" No Not Applicable Used.

The "air with steam or water leakage" environment was not used. Loss of material for bolting components in the ESF systems that are exposed to air environments is addressed in items 3.2.1-

13.

December 20, 2024 Enclosure A Page 15 of 44 LRA Table 3.5.1, Summary of Aging Management Evaluations for the Containments, Structures and Component Supports, pages 3.5-44 and 3.5-45 are revised as shown below:

Table 3.5.1 Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Item Number Component Aging Effect/

Mechanism Aging Management Programs Further Evaluation Recommended Discussion 3.5.1-16 Concrete (accessible areas): basemat, Concrete: containment; wall; basemat Increase in porosity and permeability; cracking; loss of material (spalling, scaling) due to aggressive chemical attack Chapter XI.S2, ASME Section XI, Subsection IWL, or Chapter XI.S6, Structures Monitoring No Not Used Applicable.

Clinton Power Station is a reinforced concrete BWR Mark III Primary Containment design. This item number is applicable to PWRs, BWR Mark I, Mark II, Mark III steel containments. For components applicable to Clinton Power Station, management of this aging effect/mechanism is addressed under item number 3.5.1-24.

December 20, 2024 Enclosure A Page 16 of 44 Table 3.5.1 Summary of Aging Management Evaluations for the Containments, Structures and Component Supports Item Number Component Aging Effect/

Mechanism Aging Management Programs Further Evaluation Recommended Discussion 3.5.1-17 Concrete (accessible areas): dome; wall; basemat; ring girders; buttresses Increase in porosity and permeability; cracking; loss of material (spalling, scaling) due to aggressive chemical attack Chapter XI.S2, ASME Section XI, Subsection IWL No Not Used Applicable.

For components applicable to Clinton Power Station, management of this aging effect/mechanism is addressed under item number 3.5.1-24.

The only applicable NUREG-1801 item is II.A1.CP-87 and PWR Concrete Containments are not applicable to CPS.

December 20, 2024 Enclosure A Page 17 of 44 Change #6 - Correction to Section 2.3.3.10 List of License Renewal Boundary Drawings Affected LRA Section: Section 2.3.3.10 LRA Page Number: 2.3-74 Description of Change:

LRA Section 2.3.3.10, Fuel Pool Cooling and Storage System, incorrectly lists Boundary Drawings LR-CPS-M05-1071, Sheets 1 and 2. There are no Fuel Pool Cooling and Storage System components shown on these drawings. As such, reference to these drawings is being deleted.

Accordingly, LRA Section 2.3.3.10 is revised.

December 20, 2024 Enclosure A Page 18 of 44 LRA Table Section 2.3.3.10, Fuel Pool Cooling and Storage System, page 2.3-74 is revised as shown below:

2.3.3.10 Fuel Pool Cooling and Storage System License Renewal Boundary Drawings LR-CPS-M05-1032, Sheet 2 LR-CPS-M05-1032, Sheet 6 LR-CPS-M05-1037, Sheet 1 LR-CPS-M05-1037, Sheet 2 LR-CPS-M05-1037, Sheet 3 LR-CPS-M05-1046, Sheet 1 LR-CPS-M05-1052, Sheet 1 LR-CPS-M05-1052, Sheet 2 LR-CPS-M05-1069, Sheet 1 LR-CPS-M05-1071, Sheet 1 LR-CPS-M05-1071, Sheet 2 LR-CPS-M05-1075, Sheet 1 LR-CPS-M05-1075, Sheet 2 LR-CPS-M05-1080, Sheet 1 LR-CPS-M05-1111, Sheet 3

December 20, 2024 Enclosure A Page 19 of 44 Change #7 - Revise Operating Experience on Backfill in Buried and Underground Piping and Tanks Program Affected LRA Section: Appendix B, Section B.2.1.28 LRA Page Numbers: B-126 Description of Change:

LRA Appendix B, Section B.2.1.28 Operating Experience (OE) Example 5 is being revised to clarify the number of excavations that the NEI 09-14, Guideline for the Management of Underground Piping and Tank Integrity, and 2011 Buried Piping engineering evaluations summarize.

Accordingly, LRA Appendix B, Section B.2.1.28 OE Example 5 is revised.

December 20, 2024 Enclosure A Page 20 of 44 LRA Appendix B, Section B.2.1.28, Buried and Underground Piping and Tanks, page B-126 is revised to clarify Operating Experience Example 5 as shown below. This LRA markup incorporates changes submitted in Supplement 1, dated November 27, 2024, which added OE Example 5 via Change #31 and is duplicated here as an aid to the reviewer.

B.2.1.28 Buried and Underground Piping and Tanks Operating Experience

5. In September of 2009 and July of 2016, two instances of coating damage were discovered during excavation activities. In 2009, damage to the coating of a carbon steel pipe in the Cycled Condensate (CY) system was discovered during performance of an excavation. The damage was assumed to be from backfill technique in the NEI 09-14 summary technical evaluation. No further information was provided in the excavation work order. However, the summary evaluation indicates that repairs were performed, and that the extent of condition evaluation concluded that the piping should be replaced with above ground piping.

This modification was completed in 2012. Therefore, in 2024 the CY piping is not buried and is not in scope of the Buried and Underground Piping and Tanks Aging Management Program for License Renewal. In addition, the NEI 09-14 summary evaluation discusses a 2011 summary evaluation of the Buried Pipe program which indicates the backfill around the subject CY line was compacted sand. Therefore, the damage was likely not from aggregate size but, rather, from the act of compacting the sand around the buried pipe.

In 2016, a leak that was identified in the Unit 2 diesel fuel oil fill line near the fill vault. This section of buried pipe is nonsafety-related (NSR) and is in scope of license renewal to demonstrate compliance with the Commissions regulation for fire protection (10 CFR 50.48). The leak was attributed to coating damage from poor backfill technique during an excavation performed in 2004 which specified compacted CA-6 gravel.

This gravel has a maximum size of 3/4-inch and is smaller than the allowed size of 11/2-inches per the construction specification for welded steel pipe.

The above two examples of OE attribute the coating damage to backfill technique which may relate to the type (e.g. size) of aggregate in the backfill or to human performance issues. A more specific cause was not stated. In both cases, the damage was to NSR piping. This OE is not relevant to the majority of the in scope buried pipe which is safety-related (SR) and associated with the Shutdown Service Water (SX) system. With respect to the in scope SR piping, the backfill requirements are summarized in USAR Section 2.5.4.5.3.5 and specified in a station construction specification and on a drawing. In most locations, flyash, defined as a slurry of cement, flyash, sand, and water, is specified in the construction specification. The drawing specifies bash, defined as a concrete-like material without aggregate, flyash, and Controlled Low-Strength Material (CLSM) (e.g. concrete). In some locations, buried

December 20, 2024 Enclosure A Page 21 of 44 piping is covered in structural fill which may contain a low percentage of aggregate up to 3-inches in size. Strong conformance to the USAR summary and to specifications is shown in the NEI 09-14 summary technical evaluation and the 2011 Buried Pipe summary technical evaluation. As documented in these evaluations, the backfill found during excavations around the in scope piping consisted summarily of bash and CLSM. No aggregate was present in the backfill when excavated.

Therefore, there is strong adherence to the backfill specification requirements for these SR pipes and the conditions identified in the subject OE are not representative of the conditions around the remaining in scope SR pipe. These evaluations documented the results of several excavations around in scope and not in scope piping. These evaluations documented the results of more than 30 excavations of which more than 90 percent were around in scope piping and less than 10 percent were around not in scope piping. No other notation of coating damage was documented in these evaluations. In fact, coatings were noted to be in good to excellent condition when discussed.

This example provides objective evidence that the coatings applied to unexcavated in scope safety-related piping is unlikely to be damaged due solely to the composition of the backfill. Direct visual inspections will be performed prior to the period of extended operation.

December 20, 2024 Enclosure A Page 22 of 44 Change #8 - Addition of Fire Water System Program Enhancement and Exception Affected LRA Sections: Table 3.3.1, Table 3.3.2-12, Appendix A, Section A.2.1.17, Appendix A, Section A.5, and Appendix B, Section B.2.1.17 LRA Page Numbers: 3.3-60, 3.3-181, 3.3-187, A-19, A-21, A-75, B-78, B-79, B-81, and B-83 Description of Change:

LRA Appendix A, Section A.2.1.17, Appendix A, Section A.5, and Appendix B, Section B.2.1.17 are being revised to add Enhancement 11 to inspect the fixed screens in the sluice gate flow path on both the Unit 1 and Unit 2 sides of the Screen House sub-structure for flow blockage. In addition, LRA Appendix B, Section B.2.1.17 is being revised to add Exception 2 for the inspection frequency of the fixed screen suction screens. Table 3.3.2-12 is being revised to add flow blockage as an aging effect for the fixed screens and the traveling screens. Table 3.3.1 Item 64 is being revised to credit the Open Cycle Cooling Water system for managing Loss of Material for the fixed screens and traveling screens.

Accordingly, LRA Table 3.3.1, Table 3.3.2-12, Appendix A, Section A.2.1.17, Appendix A, Section A.5, and Appendix B, Section B.2.1.17 are revised.

December 20, 2024 Enclosure A Page 23 of 44 LRA Table 3.3.1, Summary of Aging Management Evaluations for the Auxiliary Systems, page 3.3-60 is revised as shown below.

This LRA markup incorporates changes submitted in Supplement 1, dated November 27, 2024, via Change #28 which added the Open Cycle Cooling Water System to the Discussion and is duplicated here as an aid to the reviewer.

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 3.3.1-64 Steel, Copper alloy Piping, piping components, and piping elements exposed to Raw water Loss of material due to general, pitting, crevice, and microbiologically-influenced corrosion; fouling that leads to corrosion; flow blockage due to fouling Chapter XI.M27, "Fire Water System" No Consistent with NUREG-1801 with exceptions. The Fire Water System (B.2.1.17) program will be used to manage loss of material, fouling that leads to corrosion, and flow blockage of carbon steel, copper alloy with 15% zinc or less, copper alloy with greater than 15% zinc, ductile cast iron, galvanized steel, and gray cast iron piping, piping components, and piping elements and tanks exposed to raw water in the Fire Protection System and Open Cycle Cooling Water System.

An exception applies to the NUREG-1801 recommendations for Fire Water System (B.2.1.17) program implementation.

The Bolting Integrity (B.2.1.11) program has been substituted and will be used to manage loss of material of carbon and low alloy steel bolting exposed to raw water in the Fire Protection System.

The Open Cycle Cooling Water (B.2.1.12) manages loss of material for the fire water suction screens which consist of the fixed screens and the traveling screens.

December 20, 2024 Enclosure A Page 24 of 44 LRA Table 3.3.2-12, Open Cycle Cooling Water System, Summary of Aging Management Evaluation, pages 3.3-181 and 3.3-187 are revised as shown below.

Table 3.3.2-12 Open Cycle Cooling Water System Summary of Aging Management Evaluation Table 3.3.2-12 Open Cycle Cooling Water System Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Programs NUREG-1801 Item NUREG-1800 Table 1 Item Notes Bolting (Closure)

Mechanical Closure Carbon and Low Alloy Steel Bolting Air - Indoor, Uncontrolled (External)

Loss of Material Bolting Integrity (B.2.1.11)

VII.I.AP-125 3.3.1-12 A

Loss of Preload Bolting Integrity (B.2.1.11)

VII.I.AP-124 3.3.1-15 A

Air - Outdoor (External)

Loss of Material Bolting Integrity (B.2.1.11)

VII.I.AP-126 3.3.1-12 A

Loss of Preload Bolting Integrity (B.2.1.11)

VII.I.AP-263 3.3.1-15 A

Raw Water (External)

Loss of Material Bolting Integrity (B.2.1.11)

H, 2 Loss of Preload Bolting Integrity (B.2.1.11)

VII.I.AP-264 3.3.1-15 A

Soil (External)

Loss of Material Buried and Underground Piping and Tanks (B.2.1.28)

VII.I.AP-241 3.3.1-109 B

Loss of Preload Bolting Integrity (B.2.1.11)

VII.I.AP-242 3.3.1-14 A

Stainless Steel Bolting Air - Indoor, Uncontrolled (External)

Loss of Material Bolting Integrity (B.2.1.11)

VII.I.AP-125 3.3.1-12 A

Loss of Preload Bolting Integrity (B.2.1.11)

VII.I.AP-124 3.3.1-15 A

Fixed Screens Filter Galvanized Steel Raw Water (External)

Flow Blockage Fire Water System (B.2.1.17)

VII.G.A-33 3.3.1-64 D

Loss of Material Open-Cycle Cooling Water System (B.2.1.12)

VII.C1.AP-194 3.3.1-37 C, 4

December 20, 2024 Enclosure A Page 25 of 44 Table 3.3.2-12 Open Cycle Cooling Water System (Continued)

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Programs NUREG-1801 Item NUREG-1800 Table 1 Item Notes Spray Nozzles Spray Stainless Steel Raw Water (Internal)

Flow Blockage Open-Cycle Cooling Water System (B.2.1.12)

VII.G.A-55 3.3.1-66 E, 3 Loss of Material Open-Cycle Cooling Water System (B.2.1.12)

VII.C1.A-54 3.3.1-40 A

Strainer (Element)

Filter Stainless Steel Raw Water (Internal)

Loss of Material Open-Cycle Cooling Water System (B.2.1.12)

VII.C1.A-54 3.3.1-40 A

Traveling Water Screens Filter Galvanized Steel Raw Water (External)

Flow Blockage Fire Water System (B.2.1.17)

VII.G.A-33 3.3.1-64 D

Loss of Material Open-Cycle Cooling Water System (B.2.1.12)

VII.C1.AP-194 3.3.1-37 C, 4

December 20, 2024 Enclosure A Page 26 of 44 LRA Appendix A, Section A.2.1.17, Fire Water System, page A-19, second paragraph is revised as shown below:

A.2.1.17 Fire Water System The Fire Water System aging management program is an enhanced condition monitoring, performance monitoring, and preventive program that manages loss of material due to corrosion, including microbiologically influenced corrosion (MIC),

fouling, and flow blockage. The program manages these aging effects by monitoring system pressure, flushing the system header, flow testing the buried ring header, performance testing the fire pumps, full flow flushing and flow verification the fire hydrants, flushing and flow testing sprinkler and deluge systems, and visually inspecting systems using the guidance of NFPA 25, 2011 Edition, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems.

The program applies to water-based fire protection systems that consist of sprinklers, fittings, valves, hydrants, hose stations, standpipes, pumps, and aboveground and buried piping and components. The program manages aging of fire protection system components exposed to raw water. Aging of the external surfaces of buried fire main piping is managed as described in the Buried and Underground Piping and Tanks (A.2.1.28) aging management program. Fire water system components subject to selective leaching are evaluated as described in the Selective Leaching (A.2.1.22) aging management program. Loss of material of the fixed and traveling suction screens is managed by the Open Cycle Cooling Water (A.2.1.12) aging management program.

December 20, 2024 Enclosure A Page 27 of 44 LRA Appendix A, Section A.2.1.17, Fire Water System, page A-21 is revised to add Enhancement 11 as shown below. This LRA markup includes changes submitted in Supplement 1, dated November 27, 2024, which revised Enhancement 9 and added Enhancement 10 via Change #33 and Change #38; respectively, and are duplicated here as an aid to the reviewer.

A.2.1.17 Fire Water System The Fire Water System aging management program will be enhanced to:

9. Prior to 50 years of service, sprinklers shall be replaced or a representative sample of sprinklers will be removed and submitted for testing to a recognized laboratory. If sprinklers are not replaced, the testing shall be repeated every 10 years. This enhancement is in accordance with the requirements of NFPA 25 (2011), Section 5.3.1.

10. Perform air flow testing of in scope charcoal bed deluge systems on a refuel outage (2-year) frequency.

11. Visually inspect both the Unit 1 and Unit 2 fixed screens downstream of the Screen House sluice gates for flow blockage on a frequency not to exceed five years.

These enhancements will be implemented no later than six months prior to the period of extended operation.

December 20, 2024 Enclosure A Page 28 of 44 LRA Appendix A, Section A.5, License Renewal Commitment List, Commitment 17, Fire Water System, page A-75, is revised to add Enhancement 11 as shown below. This LRA markup includes changes submitted in Supplement 1, dated November 27, 2024, which revised Enhancement 9 and added Enhancement 10 via Change #33 and Change #38; respectively, and are duplicated here as an aid to the reviewer.

A.5 License Renewal Commitment List NO.

PROGRAM OR TOPIC COMMITMENT IMPLEMENTATION SCHEDULE SOURCE 17 Fire Water System Fire Water System is an existing program that will be enhanced to:

9.

Prior to 50 years of service, sprinklers shall be replaced or a representative sample of sprinklers will be removed and submitted for testing to a recognized laboratory. If sprinklers are not replaced, the testing shall be repeated every 10 years. This enhancement is in accordance with the requirements of NFPA 25 (2011), Section 5.3.1.

10. Perform air flow testing of in scope charcoal bed deluge systems on a refuel outage (2-year) frequency.

11. Visually inspect both the Unit 1 and Unit 2 fixed screens downstream of the Screen House sluice gates for flow blockage on a frequency not to exceed five years.

Program will be enhanced no later than six months prior to the period of extended operation.

Inspection schedule identified in the commitment.

Section A.2.1.17

December 20, 2024 Enclosure A Page 29 of 44 LRA Appendix B, Section B.2.1.17, Fire Water System, page B-78 is revised as shown below:

B.2.1.17 Fire Water System Program Description The Fire Water System aging management program is an enhanced condition monitoring, performance monitoring, and preventive program that manages the loss of material and flow blockage in raw water, condensation, air - outdoor, and air - indoor, environments for water-based fire protection systems that consist of sprinklers, nozzles, fittings, valve bodies, fire pump casings, hydrants, hose stations, standpipes, and aboveground and buried piping and components. Fire Water System component materials consist of carbon steel, ductile iron, stainless steel, galvanized steel, gray cast iron, and copper alloys.

December 20, 2024 Enclosure A Page 30 of 44 LRA Appendix B, Section B.2.1.17, Fire Water System, page B-79, third paragraph is revised as shown below:

B.2.1.17 Fire Water System The water-based fire protection system is normally maintained at required operating pressure and monitored such that loss of system pressure is immediately detected and corrective actions initiated. The system flow testing, visual inspections and volumetric inspections assure that aging effects are managed such that the system intended functions are maintained.

Flow testing results are reviewed and trended to identify degrading trends prior to loss of system function. The program ensures that testing and inspection activities have been performed and documented. Abnormal results are entered into the corrective action program for review and resolution.

Inspections and tests are performed by personnel qualified in accordance with station procedures and programs to perform the specified task. The inspections and tests follow station procedures that include inspection parameters for items such as lighting, distance, offset, presence of protective coatings, and cleaning processes.

External surfaces of buried fire main piping are evaluated as described in the Buried and Underground Piping (B.2.1.28) aging management program. Fire water system components subject to selective leaching are evaluated as described in the Selective Leaching (B.2.1.22) aging management program.

Loss of material of the fixed and traveling suction screens is managed by the Open Cycle Cooling Water (A.2.1.12) aging management program.

The program will be enhanced, as noted below, to provide reasonable assurance that the Fire Water System aging effects will be adequately managed during the period of extended operation.

December 20, 2024 Enclosure A Page 31 of 44 LRA Appendix B, Section B.2.1.17, Fire Water System, page B-81 is revised to add Exception 2 as shown below.

Exceptions to NUREG-1801

2. NUREG-1801, Element 4, Table 4a requires compliance with Section 8.3.3.7 of the 2011 edition of NFPA 25 which states: After the waterflow portions of the annual test or fire protection system activations, the suction screens shall be inspected and cleared of any debris or obstructions.

Clinton inspects the traveling screens in the primary suction channels more frequently than required by NFPA 25. However, in the sluice gate channel which includes fixed screens, Clinton performs these activities in accordance with the Generic Letter 89-13 inspections performed on the screen house on a frequency not to exceed five years.

Justification for Exception Sufficient clogging of the wet pit suction screens is unlikely to occur due to the configuration of the suction channels, and unlikely to occur for a duration capable of impacting the performance of fire water system due to the continuously operating circulating water pumps and the inspection frequency of the traveling screens. This is supported by review of Clinton operating experience.

The Clinton fire water system demand is supplied by up to two 100%

capacity vertical fire water pumps (A and B). The A fire pump is in the Unit 1 wet pit along with the other Unit 1 safety-related and non-safety related pumps. The B fire pump is in the Unit 2 wet pit.

However, Unit 2 was never built so the B fire pump is the only permanently installed pump in this pit. The Unit 1 pumps cannot take suction from the Unit 2 wet pit nor vice versa due to the physical separation of the two pits. On the Unit 1 side, water may pass through seven channels from Lake Clinton into the wet pit.

Each channel feeds all pumps that are in the Unit 1 wet pit. Six of these channels are the primary flow path where a bar grill first filters large debris and downstream traveling screens filter small debris.

The traveling screens are vertical conveyor systems. Each section of screen is either placed as a lead screen or is wrapped around the drive wheel and re-submerged behind the lead screen. The traveling screens rotate periodically and when a pressure sensor detects clogging and cycles the screen sections for automatic cleaning and debris removal. These six channels feed directly into the portion of the wet pit that primarily serves to feed the three circulating water pumps of which at least two are continuously operating during normal operation and the service water pumps during normal operation and shutdown. The seventh channel on the Unit 1 side consists of a bar grill, a normally closed motor operated sluice gate,

December 20, 2024 Enclosure A Page 32 of 44 and two sets of fixed screens in series. When the sluice gate is open, the bar grill filters large debris and the fixed screens filter small debris. The Unit 1 sluice gate is manually opened when required as an alternate source of water. All seven channels are common flow paths to all pumps. Therefore, the A fire pump will have a continuous water supply when the sluice gate is closed. On the Unit 2 side, the B fire pump may take suction through one channel which consists of a bar grill, a normally open sluice gate, and two sets of fixed screens in series. No traveling screens were installed on the Unit 2 side and the other six channels are blocked with stop logs.

NFPA 25, Figure A.8.2.2 depicts a wet pit and vertical fire pump where water into the wet pit is filtered by a rack and two screens that are in series. Final filtration is performed by a strainer on the end of the pump suction. At Clinton, there are two configurations into the wet pit. In six of the seven channels on the Unit 1 side, the bar grills are the rack and the traveling screens are the screens. Since the traveling screens are doubled over, they satisfy the requirement for two screens in series. In the seventh channel on the Unit 1 side and in the only channel on the Unit 2 side, the bar grills are the rack and the two in series fixed screens are the two screens in series. A strainer is also installed on the end of each fire pump suction column. Therefore, the configuration matches the NFPA 25 figure.

Clogging of the suction screens between inspection intervals is unlikely due to the configuration of the suction channels. The cross-sectional area of these suction channels is large and, in the case of A fire pump, there are channel redundancies and differential pressure monitoring across the screens. The bottom of the wet pit is at Elevation 657-6, the typical water level is at Elevation 690-0, and the 100 Year Flood elevation is at 697-0 which is roughly equivalent to the top of the wet pit. The fixed screens extend from bottom of the wet pit to the top of the wet pit or, roughly, 39.5 feet (697-657.5). The traveling screens extend from the bottom of the wet pit to well above the top of the wet pit. The sluice gate channel is seven feet wide and the six traveling screen channels are each 13 feet wide. Clinton conservatively assumes there is up to five feet of silt around the fixed screens. Therefore, the typical flow area through the fixed screens, the smallest flow area, is the difference between the normal water level and the silt level (690-662.5) multiplied by the width of the sluice gate channel (7) which is 192.5 ft2. The fire pump suction column has a diameter of 12 or, roughly, 1 ft2. Therefore, significant clogging of the fixed screens would be required to affect the B fire pump and only after the stored water in the Unit 2 wet pit is depleted. Further, the B pump is redundant to the A pump and would only initiate on a low-low pressure signal in the fire water system. The suction screens in front of the A fire pump have six channels that are continuously

December 20, 2024 Enclosure A Page 33 of 44 filtered and a seventh channel that is opened as required. The traveling screens are fitted with differential pressure sensors that alarm locally and in the control room. These alarms would be identified during daily operator rounds. Therefore, it is unlikely that significant suction screen clogging would occur for a duration that impacts the efficacy of the fire pumps between inspection intervals.

An OE review was performed to identify instances of clogging of the fixed screens. No OE was identified. In addition, completed work orders of prior Generic Letter 89-13 Screen House inspections were reviewed. Divers were not sent into the pits during the most recent, 2024, inspection due to industry OE relating to diver safety while performing these inspections. However, older inspections from 2017, 2012, and 2007 documented minimal biofouling of the fixed screens and no clogging via debris. Fouling of sufficient capacity to impact the performance of the on demand fire pumps would first be identified by performance degradation of the continuously running circulating water pumps during normal plant operation and the service water pumps during shutdown. There is no OE of clogging of the suction screens causing performance issues with these pumps.

Therefore, on the Unit 1 side, it is unlikely for the fixed screens to become clogged between the GL 89-13 inspection intervals, during the annual operation of the fire pumps, or during normal operation of the circulating water pumps due to the lack of water flow through the fixed screens in the normally closed sluice gate channel. It is also unlikely due to the capacity and the redundancies in the configuration. On the Unit 2 side, it is unlikely for the fixed screens to be clogged between the GL 89-13 inspection intervals due to the capacity of the configuration. Station OE supports this conclusion.

December 20, 2024 Enclosure A Page 34 of 44 LRA Appendix B, Section B.2.1.17, Fire Water System, page B-83 is revised to add Enhancement 11 as shown below. This LRA markup includes changes submitted in Supplement 1, dated November 27, 2024, which revised Enhancement 9 and added Enhancement 10 via Change #33 and Change #38; respectively, and are duplicated here as an aid to the reviewer.

B.2.1.17 Fire Water System The Fire Water System aging management program will be enhanced to:

9. Prior to 50 years of service, sprinklers shall be replaced or a representative sample of sprinklers will be removed and submitted for testing to a recognized laboratory. If sprinklers are not replaced, the testing shall be repeated every 10 years. This enhancement is in accordance with the requirements of NFPA 25 (2011), Section 5.3.1.

10. Perform air flow testing of in scope charcoal bed deluge systems on a refuel outage (2-year) frequency. Program Element Affected: Detection of Aging Effects (Element 4)

11. Visually inspect both the Unit 1 and Unit 2 fixed screens downstream of the Screen House sluice gates for flow blockage on a frequency not to exceed five years. Program Element Affected: Detection of Aging Effects (Element 4)

December 20, 2024 Enclosure A Page 35 of 44 Change #9 - Open-Cycle Cooling Water Aging Management Program Enhancement and Revision Affected LRA Sections: Appendix A, Section A.1.1, Appendix A, Section A.2.1.12, Appendix A, Section A.5, Appendix B, Section B.1.5, and Appendix B, Section B.2.1.12 LRA Page Numbers: A-5, A-16, A-71, B-7, B-58, and B-59 Description of Change:

LRA Appendix A, Section A.2.1.12, Appendix A, Section A.5, and Appendix B, Section B.2.1.12 are being revised to add Enhancement 1 to specify the minimum safety factor for corrosion rate calculations due to cavitation and to revise Operating Experience Example 1.

Accordingly, LRA Appendix A, Section A.1.1, Appendix A, Section A.2.1.12, Appendix A, Section A.5, Appendix B, Section B.1.5, and Appendix B, Section B.2.1.12 are revised.

December 20, 2024 Enclosure A Page 36 of 44 LRA Appendix A, Section A.1.1, NUREG-1801 Chapter XI Aging Management Programs, page A-5, Item 12 is revised as shown below:

NUREG-1801 Chapter XI Aging Management Programs The NUREG-1801 Chapter XI Aging Management Programs (AMPs) are described in the following sections. The AMPs are either consistent with generally accepted industry methods as discussed in NUREG-1801 or require enhancements.

The following list reflects the status of these programs at the time of the License Renewal Application (LRA) submittal. Commitments for program additions and enhancements are identified in the Appendix A.5 License Renewal Commitment List.

12. Open-Cycle Cooling Water System (Section A.2.1.12) [Existing -

Requires Enhancement]

December 20, 2024 Enclosure A Page 37 of 44 LRA Appendix A, Section A.2.1.12, Open-Cycle Cooling Water System, page A-16 is revised as shown below. This LRA markup incorporates changes submitted in Supplement 1, dated November 27, 2024, via Change #28 which removed flow blockage as a managed aging effect and is duplicated here as an aid to the reviewer.

A.2.1.12 Open-Cycle Cooling Water System The Open-Cycle Cooling Water System (OCCWS) aging management program is an existing preventive, mitigative, condition monitoring, and performance monitoring program based on the implementation of NRC Generic Letter (GL) 89-13, Service Water System Problems Affecting Safety-Related Equipment, which includes (a) surveillance and control of bio-fouling, (b) tests to verify heat transfer, (c) routine inspection and maintenance program, (d) system walkdown inspection, and (e) review of maintenance, operating, and training practices and procedures.

The OCCWS program applies to components constructed of various materials, including carbon steel, stainless steel, galvanized steel, nickel alloys, copper alloys, and PVC.

The OCCWS aging management program manages heat exchangers, piping, piping elements, and piping components in safety-related and nonsafety-related raw water systems that are exposed to a raw water environment for loss of material, wall thinning due to erosion, and reduction of heat transfer. The guidelines of NRC GL 89-13 are implemented through the site GL 89-13 activities for heat exchangers and piping segments, and the Raw Water Piping Integrity program for additional piping segments. System and component testing, visual inspections, non-destructive examination, cleaning, and chemical injection are conducted to ensure that identified aging effects are managed such that system and component intended functions and integrity are maintained.

The Open-Cycle Cooling Water System aging management program will be enhanced to:

1. Specify that the safety factor for corrosion rate calculations due to cavitation in raw water systems shall not be less than 1.5.

This enhancement will be implemented no later than six months prior to the period of extended operation.

December 20, 2024 Enclosure A Page 38 of 44 LRA Appendix A, Section A.5, License Renewal Commitment List, Commitment 12, Open-Cycle Cooling Water System, page A-71, is revised to add Enhancement 1 as shown below.

A.5 License Renewal Commitment List NO.

PROGRAM OR TOPIC COMMITMENT IMPLEMENTATION SCHEDULE SOURCE 12 Open Cycle Cooling Water System Existing program is credited.

Open Cycle Cooling Water System is an existing program that will be enhanced to:

1.

Specify that the safety factor for corrosion rate calculations due to cavitation in raw water systems shall not be less than 1.5.

Ongoing Program will be enhanced no later than six months prior to the period of extended operation.

Section A.2.1.12

December 20, 2024 Enclosure A Page 39 of 44 LRA Appendix B, Section B.1.5, NUREG-1801 Chapter XI Aging Management Programs, page B-7, Item 12 is revised as shown below:

B.1.5 NUREG-1801 Chapter XI Aging Management Programs The following AMPs are described in the sections listed in this appendix. The programs are either generic in nature as discussed in NUREG-1801,Section XI, or are plant-specific. NUREG-1801 Chapter XI programs are listed in Section B.2.1. Plant-specific programs are listed in Section B.2.2. All generic programs are fully consistent with or are, with some exceptions, consistent with programs discussed in NUREG-1801. Programs are identified as either existing or new.

12. Open-Cycle Cooling Water System (Section B.2.1.12) [Existing - Requires Enhancement]

December 20, 2024 Enclosure A Page 40 of 44 LRA Appendix B, Section B.2.1.12, Open-Cycle Cooling Water System, page B-58 is revised as shown below:

B.2.1.12 Open-Cycle Cooling Water System NUREG-1801 Consistency The Open-Cycle Cooling Water System aging management program is consistent with the ten elements of aging management program XI.M20, "Open-Cycle Cooling Water System, specified in NUREG-1801, as modified by LR-ISG-2012-02 and LR-ISG-2013-01 with the following enhancement.

Exceptions to NUREG-1801 None.

Enhancements None.

Prior to the period of extended operation, the following enhancement will be implemented in the following program elements:

1. Specify that the safety factor for corrosion rate calculations due to cavitation in raw water systems shall not be less than 1.5. Program Elements Affected: Acceptance Criteria (Element 6)

December 20, 2024 Enclosure A Page 41 of 44 LRA Appendix B, Section B.2.1.12, Open-Cycle Cooling Water System, page B-59, Operating Experience Example 1 is revised as shown below.

Operating Experience The following examples of operating experience provide objective evidence that the Open-Cycle Cooling Water System program will be effective in assuring that intended functions are maintained consistent with the current licensing basis for the period of extended operation:

1. In November 2019, during a system walkdown, a minor leak was observed in the C residual heat removal (RHR) room cooler. The leak was estimated at approximately 100 drops per minute. The leak was from the 1VY07C RHR pump room 1C supply fan cooling coil. The C RHR system was declared inoperable until the cooler could be isolated, at which time the Technical Specification Limiting Condition for Operation (LCO) was exited, and the subsystem declared operable. The condition was entered into the corrective action process for follow-up actions.

The cooling coil leak was a pinhole leak caused by wall thinning due to erosion/corrosion in the copper tubing. The ECCS equipment area cooling (VY) room coolers/heat exchangers were identified as part of the Clinton GL 89-13 Program. An extent of condition review was performed.

All room coolers (1VY08SA, 1VY08SB, 1VY08AA, 1VY08AB, 1VY08AC, 1VY08AD, 1VY06AA, 1VY06AB, 1VY07AA, 1VY07AB, 1VY01AA, 1VY01AB, 1VY03AA, 1VY03AB, 1VY05AA, 1VY05AB, 1VY04A, 1VY03S, 1VY04S, 1VY01S, 1VY02S, 1VY05S, 1VY06S, 1VH07SA and 1VH07SB) having a similar configuration and similar service conditions were walked down. No leakage issues were identified for the identified inspection scope.

A section of the failed tubing was removed and sent to Constellation Power Labs for analysis. It was determined that the failure was due to erosion-corrosion caused by turbulence associated with the configuration of the coil and adjacent fitting. The failure was initially attributed to erosion-corrosion. However, there are instances of Flow Accelerated Corrosion (FAC) being incorrectly referred to as erosion-corrosion. Based upon service media and conditions, the probable failure mechanism is from solid particle erosion given that FAC is not a wear mechanism in single phase systems with a temperature below 200-degree F with high levels of dissolved oxygen. Per the Power Labs report, no localized corrosion mechanisms, such as pitting or intergranular attack, were observed.

December 20, 2024 Enclosure A Page 42 of 44 In June of 2020, a pin hole leak was observed in the A RHR room cooler. In response to this room cooler leak and the 2019 room cooler leak, an emerging trend issue report was entered into the Corrective Action Program. In both leaks, it was identified that the location of the leak was within approximately an inch of where the tubing connects to the brass connection fitting. A review was performed of the inspection techniques employed during the periodic inspections of these room coolers. Prior inspections had detected wall thinning but the corrective action review identified a limitation in the probe design and in the inspection technique that prevented measurement of tube wall thickness within this last inch of tubing. To address these limitations, the vendor revised their examination technical specification sheets to include specific details of the area of interest. The vendor also revised their procedures to address the area of interest, to ensure the inspection crew is briefed on the unique cooler configuration, and to ensure the inspection crew is aware of the applicable damage mechanism prior to inspection. As a result, inspections performed after these changes were able to identify wear in the areas of concern. In addition to the inspection changes, replacement cooling coils were obtained for all cooling coils identified in the extent of condition.

The intent of procuring the replacements was to limit system unavailability when performing the inspections. The replacement coils allow the station to remove the in-service coils and return the system back to service with the replacement coils installed prior to completion of the NDE. This also eliminates NDE time-pressure.

This example provides objective evidence that the existing GL 89-13 aging management program activities are being effectively implemented to identify and manage aging effects of in scope heat exchangers serviced by raw water, and that the results of inspection activities are used to inform and enhance the program. Deficiencies identified during inspection activities are entered into the corrective action program and appropriate corrective actions are taken to evaluate and correct the deficiencies.

December 20, 2024 Enclosure A Page 43 of 44 Change #10 - Correction of an Error in Supplement 1, Change #2 Affected LRA Section: Table 3.3.2-9 LRA Page Number: 3.3-164 Description of Change:

Supplement 1, Change #2 incorrectly removed valve body, copper alloy with greater than 15%

zinc in air - indoor, uncontrolled from LRA Table 3.3.2-9, Fire Protection System. This change corrects this inadvertent error.

Accordingly, LRA Table 3.3.2-9 is revised.

December 20, 2024 Enclosure A Page 44 of 44 LRA Table 3.3.2-9, Fire Protection System, Summary of Aging Management Evaluation, page 3.3-164 is revised as shown below. This LRA markup includes changes submitted in Supplement 1, dated November 27, 2024, which removed the fuel oil (internal) environment via Change #2 and are duplicated here as an aid to the reviewer.

Table 3.3.2-9 Fire Protection System (Continued)

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Programs NUREG-1801 Item NUREG-1800 Table 1 Item Notes Valve Body Pressure Boundary Copper Alloy with greater than 15%

Zinc Air - Indoor, Uncontrolled (External)

None None VII.J.AP-144 3.3.1-114 A

Raw Water (Internal)

Flow Blockage Fire Water System (B.2.1.17)

VII.G.AP-197 3.3.1-64 B

Loss of Material Fire Water System (B.2.1.17)

VII.G.AP-197 3.3.1-64 B

Selective Leaching (B.2.1.22)

VII.G.A-47 3.3.1-72 B

December 20, 2024 Enclosure B Page 1 of 3 Enclosure B Clinton License Renewal Commitment List Update Introduction This enclosure identifies commitments made in this document and is an update to the Clinton LRA Appendix A, Section A.5, License Renewal Commitment List. Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRCs information and are not regulatory commitments.

Changes to the Clinton LRA Appendix A, Section A.5, License Renewal Commitment List, are as a result of this LRA Supplement.

These Enclosure B pages are the same as the corresponding Clinton LRA Appendix A, Section A.5 pages included in Enclosure A.

To facilitate understanding, relevant portions of the previously submitted License Renewal Commitment List have been repeated in this Enclosure, with revisions indicated. Previously submitted information is shown in normal font. Additions due to this submittal are highlighted with bolded italics for inserted text, and strikethroughs for deleted text.

December 20, 2024 Enclosure B Page 2 of 3 LRA Appendix A, Section A.5, License Renewal Commitment List, Commitment 12, Open-Cycle Cooling Water System, page A-71, is revised to add Enhancement 1 as shown below.

A.5 License Renewal Commitment List NO.

PROGRAM OR TOPIC COMMITMENT IMPLEMENTATION SCHEDULE SOURCE 12 Open Cycle Cooling Water System Existing program is credited.

Open Cycle Cooling Water System is an existing program that will be enhanced to:

1.

Specify that the safety factor for corrosion rate calculations due to cavitation in raw water systems shall not be less than 1.5.

Ongoing Program will be enhanced no later than six months prior to the period of extended operation.

Section A.2.1.12 CEG Letter CPS LRA Supplement No. 2, dated December 20, 2024

December 20, 2024 Enclosure B Page 3 of 3 LRA Appendix A, Section A.5, License Renewal Commitment List, Commitment 17, Fire Water System, page A-75, is revised to add Enhancement 11 as shown below. This LRA markup includes changes submitted in Supplement 1, dated November 27, 2024, which revised Enhancement 9 and added Enhancement 10 via Change #33 and Change #38; respectively, and are duplicated here as an aid to the reviewer.

A.5 License Renewal Commitment List NO.

PROGRAM OR TOPIC COMMITMENT IMPLEMENTATION SCHEDULE SOURCE 17 Fire Water System Fire Water System is an existing program that will be enhanced to:

9.

Prior to 50 years of service, sprinklers shall be replaced or a representative sample of sprinklers will be removed and submitted for testing to a recognized laboratory. If sprinklers are not replaced, the testing shall be repeated every 10 years. This enhancement is in accordance with the requirements of NFPA 25 (2011), Section 5.3.1.

10. Perform air flow testing of in scope charcoal bed deluge systems on a refuel outage (2-year) frequency.

11. Visually inspect both the Unit 1 and Unit 2 fixed screens downstream of the Screen House sluice gates for flow blockage on a frequency not to exceed five years.

Program will be enhanced no later than six months prior to the period of extended operation.

Inspection schedule identified in the commitment.

Section A.2.1.17 CEG Letter CPS LRA Supplement No. 2, dated December 20, 2024