PLA-6400, Request for Additional Information for the Review of the Susquehanna Steam Electric Station Units 1 and 2, License Renewal Application (LRA) Sections B.2.14, B.2.25, B.2.32, and B.2.33, PLA-6400

Request for Additional Information for the Review of the Susquehanna Steam Electric Station Units 1 and 2, License Renewal Application (LRA) Sections B.2.14, B.2.25, B.2.32, and B.2.33, PLA-6400

ML082330526
Person / Time
Site:	Susquehanna
Issue date:	08/12/2008
From:	Mckinney B Susquehanna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PLA-6400
Download: ML082330526 (70)

Text

Britt T. McKinney PPL Susquehanna, LLC Sr. Vice President & Chief Nuclear Officer 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3149 Fax 570.542.1504 btmckinney@pplweb.com S P J;,C)

~2008 U. S. Nuclear Regulatory Commission Document Control Desk Mail Stop OP l-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE SUSQUEHANNA STEAM ELECTRIC STATION UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (LRA)

SECTIONS B.2.14, B.2.25, B.2.32, AND B.2.33 Docket Nos. 50-387 PLA-6400 and 50-388 References. 1) PLA-6110, Mr. B. T. McKinney (PPL)to Document ControlDesk (USNRC),

"Applicationfor Renewed OperatingLicense Numbers NPF-14 and NPF-22, dated September 13, 2006.

2) Letterfrom Ms. E. H. Gettys (USNRC) to Mr. B. T McKinney (PPL),

"Requestfor Additional Informationfor the Review of the Susquehanna Steam Electric Station, Units 1 and 2 License Renewal Application, "dated July 10, 2008.

3) PLA-6387, Mr. B. T. McKinney (PPL)to Document Control Desk (USNRC), "Request for Additional Informationfor the Review of the Susquehanna Steam ElectricStation Units 1 and 2, License Renewal Application (LRA) Sections B.2.19 and 3.3.2.2.6,"

dated July 24, 2008.

In accordance with the requirements of 10 CFR 50, 51, and 54, PPL requested the renewal of the operating licenses for the Susquehanna Steam Electric Station (SSES)

Units 1 and 2 in Reference 1.

Reference 2 is a request for additional information (RAI) related to License Renewal Application (LRA) Sections B.2.14, B.2.25, B.2.32, and B.2.33. The enclosure to this letter provides the question responses and the additional requested information.

The Attachment provides our response to RAI B.2.14-2, which consists of revisions to applicable LRA sections and tables as a result of explicitly crediting the Chemistry Program Effectiveness Inspection in conjunction with the Closed Cooling Water Chemistry Program for loss of material.

A2-o

Document Control Desk PLA-6400 There are no new regulatory commitments contained herein as a result of the attached responses. However, License Renewal commitment #48 is revised in response to RAI B.2.25-1 and commitment #28 is revised in response to RAI B.2.32-4.

If you have any questions, please contact Mr. Duane L Filchner at (610) 774-7819.

I declare, under penalty of perjury, that the foregoing is true and correct.

Executed on: <61 .

Enclosure:

PPL Responses to NRC's Request for Additional Information (RAI)

Attachment:

Response to RAI B.2.14-2 Copy: NRC Region I Ms. E. H. Gettys, NRC Project Manager, License Renewal, Safety Mr. R. Janati, DEP/BRP Mr. F. W. Jaxheimer, NRC Sr. Resident Inspector Mr. A. L. Stuyvenberg, NRC Project Manager, License Renewal, Environmental

Enclosure to PLA-6400 PPL Responses to NRC's Request for Additional Information (RAI)

Enclosure to PLA-6400 Page 1 of 15 RAI B.2.14-1:

The aging management program (AMP) B.2.14 Closed Cooling Water (CCW) Chemistry Program takes the following exception to the "parameters monitored or inspected,"

"detection of aging effects," "monitoring and trending," and "acceptance criteria" program elements in the GALL Report AMP XI.M21 "Closed Coolant Water System."

"In lieu of performance monitoring/functional testing, program includes monitoring of corrosion in the emergency diesel generator jacket water subsystem and is supplemented by one time chemistry program effectiveness inspection."

a) Clarify whether performance monitoring and functional testing are within the scope of the CCW Chemistry Program. If not, provide your basis why performance monitoring and functional testing do not need to be included within the scope of the CCW Chemistry Program.

b) Clarify whether the one-time inspection is being performed instead of the periodic inspections as recommended in the generic aging lessons learned (GALL) Report AMP XI.M2 1. If yes, please justify how a one-time inspection is capable of accomplishing the same tasks as the periodic inspections recommended by the GALL Report. Also, justify why a one-time inspection is considered to be capable of trending any corrosion data when only one round of inspections will be done on the components that are within the scope of the AMP.

PPL Response:

a) Performance monitoring and functional testing are not within the scope of the Closed Cooling Water (CCW) Chemistry Program. The CCW Chemistry program is credited with mitigating the aging effects of loss of material and cracking. The relevant conditions that could lead to the onset and propagation of degradation are managed through proper monitoring and control of corrosion inhibitor concentrations consistent with EPRI water chemistry guidelines. System parameters such as operating pressures, flows, and temperature are monitored to provide an assurance that the system is functioning properly. However, this does not provide an indication of the effectiveness of the water chemistry controls. Loss of material or cracking would have to progress to a significant degree to affect these type of system functions.

Aging management for the systems within the scope of the CCW Chemistry Program is based on maintaining the water chemistry based on industry experience and guidance, periodic evaluation of water chemistry parameters, and feedback from plant operating experience.

Enclosure to PLA-6400 Page 2 of 15 b) As stated in LRA Section B.2.14, the CCW Chemistry Program is intended to be supplemented by one-time inspections. The one-time inspections are provided as the basis for the exception to performance monitoring and testing and are performed instead of the periodic inspections. Based on control of the water chemistry and review of plant operating experience, the aging effects of loss of material and cracking are not expected to occur. The CCW Chemistry Program has been demonstrated to be effective in mitigating the effects of aging.

Therefore, periodic inspections are determined not to be necessary to ensure the effectiveness of the CCW Chemistry Program. Rather, a one-time inspection will be used to verify that the CCW Chemistry Program is effective and to confirm that aging is not occurring that could affect the intended function of the component during the period of extended operation.

The one-time inspections will evaluate the subject components for loss of material.

As stated in the response to RAI B.22-02, the inspection observations will be compared to predetermined acceptance criteria and any indication of degradation will be evaluated. If corrosion is detected, it will be evaluated under the corrective action program.

The diesel jacket cooling water system is an exception to the above discussion.

Problems with control of microbiological activity and indication of corrosion are currently being addressed with corrosion monitoring equipment to ensure that the corrective actions have been effective. Trending of corrosion data is applied on the basis of plant operating experience and in response to the identification of corrosion.

Per the response to RAI B.2.14-2, applicable LRA sections and tables are revised as a result of explicitly crediting the Chemistry Program Effectiveness Inspection in conjunction with the Closed Cooling Water Chemistry Program for loss of material.

RAI-B.2.14-2:

In the program description of AMP B.2.14, Closed Cooling Water Chemistry Program, it states that the CCW Chemistry Program is supplemented by an appropriate one time inspection. The description mentions the AMP B.2.22 Chemistry Program Effectiveness Inspection and the AMP B.2.24 Heat Exchanger Inspection. Clarify whether the appropriate one-time inspection will be performed for all the Aging Management Review (AMR) Table-2 line items credited with using the AMP B.2.14. Also, please identify which one-time inspection, if any, will be used for any applicable AMR Table-2 line items that credit the AMP B.2.14 for aging management.

Enclosure to PLA-6400 Page 3 of 15 PPL Response:

The Chemistry Program Effectiveness Inspection (CPEI) will be used to supplement the Closed Cooling Water (CCW) Chemistry Program in the associated Table-2 line items, with the exception of the Diesel Jacket Cooling Water system. Corrosion monitoring probes are installed in the Diesel Jacket Cooling Water system to identify actual corrosion rates; therefore a separate one-time inspection is not necessary.

LRA Table 3.3.2-9 is revised in the Attachment to remove the reference to the CPEI and to credit only the CCW Chemistry Program for management of loss of material in the treated water environment of the Diesel Jacket Cooling Water system.

In association with this change the CCW Chemistry Program is being revised to delete reference to the Heat Exchanger Inspection. The Heat Exchanger Inspection will not be credited as supplementing the CCW Chemistry Program. The Heat Exchanger Inspection will be used to verify that the aging effect of reduction in heat transfer, which is not expected to occur, is not in evidence and that aging management is not required.

The Attachment contains the revised sections of the LRA which explicitly credit the Chemistry Program Effectiveness Inspection in conjunction with the Closed Cooling Water Chemistry Program.

RAI-B.2.14-3:

The "operating experience" program element for AMP B.2.14, Closed Cooling Water Chemistry Program states, in part that:

"... some continuing problems with the effectiveness of the program with respect to diesel jacket water corrosion/microbiological control were identified and evaluated in 1999. Additionally, instances of degradation (e.g., corrosion of the corresponding components) were noted by inspections associated with a 20-year overhaul in the same time period. Corrective actions included flushing of the jacket water, retaining an industry expert, and consideration of different biocide/corrosion inhibitor treatments. The appropriate improvements to the Closed Cooling Water Chemistry Program, including installation of instantaneous corrosion probes to monitor actual corrosion rates, were successfully implemented, as supported by subsequent operating experience with the diesel jacket water subsystem."

Clarify whether or not the addition of alternative biocides or corrosion inhibitors was actually implemented as a corrective action for the diesel j ack[et] water system components that are exposed to closed cooling water. If so, clarify whether on not any

Enclosure to PLA-6400 Page 4 of 15 supplemental inspections have been performed since the time of the change in the biocide control compound or corrosion inhibitor to verify the effectiveness of the biocide control compound or corrosion inhibitor in managing microbiological organism growth or corrosion of the component surfaces that are exposed to CCW. If a change in biocide control compound or corrosion inhibitors is planned but has not been implemented, clarify when the change in the biocide control compound or corrosion inhibitor will be performed and whether any supplement inspections are planned to confirm the effectiveness of the biocide control compound or corrosion inhibitor to mange microbiological organism growth or corrosion in the components.

PPL Response:

During 1999 the use of biocide treatment glutaraldhyde was discontinued and the use of alternative biocide isothiazoline was implemented. Isothiazoline is the biocide in use. The water chemistry control issues identified in the "operating experience" program element for AMP B.2.14 have been corrected and stabilized since 2001.

Since the change to the alternative biocide in 1999, supplemental inspections were conducted on all the diesel generators to assure the effectiveness of the new biocide treatment. More recent inspections of the diesels show no significant degradation. A 2007 review of jacket water chemistry samples shows the chemistry parameters are maintained within specifications, corrosive metal levels are low and biological activity is negligible. Inspections continue to show the current chemistry control program is effective.

RAI-B.2.25-1:

The license renewal application (LRA) credits the AMP B.2.25 Lubricating Oil Inspection and the AMP B.2.33 Lubricating Oil Analysis Program as two of the AMPs for managing the aging effects in plant systems that are exposed to lubricating oil, including components in the Emergency Diesel Generator System, Control Structures Chilled Water System, Residual CCW System, and High Pressure Coolant Injection System. Identify whether there are any other systems that are within the scope of license renewal and are exposed to lubricating oil.

PPL Response:

In addition to the systems listed in the RAI, the systems within the scope of license renewal that are exposed to lubricating oil are the Residual Heat Removal (RHR) System, the Reactor Core Isolation Cooling System, the Fire Protection System and the Reactor Building Chilled Water System. (Note that the "Residual CCW System" identified in the RAI is not an SSES system.)

Enclosure to PLA-6400 Page 5 of 15 The Piping Corrosion Program is credited for managing reduction in heat transfer for select heat exchanger tubes exposed to lubricating oil. This is reflected in LRA Section 3.2.2.2.4.1 and Table 3.2.2-1 for the RHR pump motor oil cooler tubes and in LRA Section 3.3.2.2.9.2 and Table 3.3.2-9 for diesel generator lube oil heat exchanger tubes.

Review of LRA Section B.2.25 identified that the Reactor Building Chilled Water System was inadvertently omitted from the listing of systems within the scope of the lubricating oil aging management programs. LRA Table 3.3.2-21 indicates that chillers (RBCW lube oil cooler shell) formed of cast iron and subject to a lubricating oil environment credit the combination of the Lubricating Oil Analysis Program and the Lubricating Oil Inspection for management of loss of material.

AMPS B.2.25, B.2.33, and Commitment #48 are revised to add the Reactor Building Chilled Water System as follows:

B.2.25 Lubricating Oil Inspection

) The text under the Scope of Program bullet under the Aging Management Program Elements heading (on LRA page B-78) is revised by addition (bold italics) as follows:

Aging Management Program Elements The results of an evaluation of each program element are provided below.

Scope of Program The scope of the Lubricating Oil Inspection includes the internal surfaces of aluminum, copper alloy, carbon steel, cast iron, and stainless steel components in the following license renewal systems that contain lubricating oil:

- Diesel Generator, Control Structure Chilled Water, Residual Heat Removal, Reactor Core Isolation Cooling, Reactor Building Chilled Water, and High Pressure Coolant Injection systems B.2.33 Lubricating Oil Analysis Program

• > The text under the Required Enhancements heading (on LRA page B-1 04) is revised by addition (bold italics)as follows:

Required Enhancements Prior to the period of extended operation the enhancements listed below will be implemented in the identified program element:

0 Scope

Enclosure to PLA-6400 Page 6 of 15 The scope of the Lubricating Oil Analysis Program must be enhanced to sample the lubricating oil from the Control Structure Chiller when the oil is changed. A particle count and a check for water must be performed on the drained oil.

The scope of the LubricatingOil Analysis Programmust be enhanced to sample the lubricatingoil from the Reactor Building Chiller when the oil is changed. A particle count and a check for water must be performed on the drainedoil.

Enclosure to PLA-6400 Page 7 of 15 A.1.4 License Renewal Commitment List The text in LRA Table A-I (on LRA page A-53) is revised by addition (bold italics) as follows:

Table A-1 SSES License Renewal Commitments FSAR Enhancement Supplement or Item Number Commitment loca tion Location Implementation (LRA App. A) Schedule

48) Lubricating Oil Existing program is credited with the following enhancement: A.1.2.28 Prior to the period Analysis The Lubricating Oil Analysis Program will be revised to include of extended Program sampling of the lubricating oil from the Control Structure Chiller operation.

when the oil is changed. The oil will be tested for water and for particle count.

0 The LubricatingOil Analysis Program will be revised to include sampling of the lubricatingoil from the Reactor Building Chiller when the oil is changed. The oil will be tested for water and for particle count.

Enclosure to PLA-6400 Page 8 of 15 RAI-B.2.32-1:

The "operating experience" program element for this AMP states that a review of operating experience revealed that component leakage, damage, and/or degradation are routinely identified by the system walk downs, and that subsequent timely corrective action were taken to correct these problems.

a) For those plant systems that are within the scope of the Systems Walkdown Program, identify the plant systems that have had problems with age related degradation in the past, and identify the specific age-related degradation problems that have occurred in these systems.

b) For those plant systems that are within the scope of the Systems Walkdown Program and have had age-related degradation issues in the past, clarify whether or not these age-related degradation issues have had any impact on the ability of the AMP's program elements to manage aging in these systems and whether the program elements for this program will need to be augmented or enhanced to ensure adequate management of aging in these systems.

c) Identify the corrective actions that have been taken to correct any issues with leakage, damage and degradation in those systems.

PPL Response:

To answer this question, examples of degradation issues that were identified for systems within the scope of the System Walkdown Program are provided, along with the corrective actions that were taken. In the process of preparing the LRA, a review of plant-specific operating experience was performed of the most recent five-year period that included a search of Action Requests and Condition Reports. This search found instances of component leakage, damage, and degradation. The following are examples of discrepancies that were found and the action taken to correct them:

" Light to medium corrosion was noted on various components of the Core Spray and the Standby Liquid Control Systems. Inspection revealed the corrosion was tightly adhered to the metal of the component with little to no material loss. No repair was recommended, and monitoring of the components continues via the system walkdowns.

" Pitting was noted on the upstream side flange face on Emergency Service Water (ESW) piping at Spray Pond A Loop Bypass Valve. Engineering review determined the observed pitting is acceptable as it does not exceed the depth of the raised flange portion of the gasket seating surface.

" A crack was found in Instrument Air piping downstream of an isolation valve.

The cracked section of pipe was replaced.

Enclosure to PLA-6400 Page 9 of 15 The portion of the Circulating Water pipes that extend above ground at the base of the cooling towers was discovered to have a severely degraded enamel/wrap coating that normally protects the pipe. The exposed portions of pipe had undergone considerable corrosion. UT thickness measurements were taken to ensure proper pipe wall thickness prior to the pipe being recoated. Additionally, during the next refueling outage the buried portion of the piping was excavated to ensure it was still protected by an intact coating and had not experienced wall thinning.

These examples demonstrate the effectiveness of the System Walkdown Program to identify and correct material deficiencies in a timely manner prior to a component losing its ability to fulfill its design basis function. The operating experience identified to-date does not identify age-related degradation issues that have an impact on the AMP's program elements ability to manage aging in these systems nor does it suggest the need for any program changes to ensure adequate aging management.

RAI-B.2.32-2:

The AMP B.2.32 System Walk down Program includes following enhancement:

"The governing procedure for system walk down program must be revised to add the listing of systems crediting the program for license renewal."

In addition, the AMP B.2.32 System Walkdowns Program indicates that Susquehanna Steam Electric Station may change the frequency of the system walkdowns in the future.

a) Identify the systems that are within the scope of the Systems Walkdown Program and that are subject to the stated enhancement.

b) Clarify what the current frequency is for performing these system walkdowns, or the current frequencies that are currently being used if the frequencies for the different plant systems in the scope of the program vary from one another.

c) Provide your basis for changing the frequency of the system walkdowns. Clarify the process that will be used to change the walkdown frequencies and whether or not any changes to the system walkdown frequencies will be subject for NRC approval.

Enclosure to PLA-6400 Page 10 of 15 PPL Response:

a) The following systems will be added to the scope of the governing document of the System Walkdown Program:

" Auxiliary Boiler System

" Building Drains Nonradioactive System

• Condensate Transfer and Storage System

" Condenser and Air Removal

• Control Structure Chilled Water

" Cooling Tower

" Diesel Generator Buildings HVAC

• Domestic Water System

" Engineered Safeguards Service Water (ESSW) Pumphouse HVAC

" Fuel Pools and Auxiliaries

" Makeup Demineralizer System

" Makeup Transfer and Storage System

" Primary Containment Atmosphere Circulation System

" Radwaste Liquid

" Radwaste Solids Handling System

" Refueling Water Transfer and Storage

• Sampling System

" Sanitary Drainage System

" Raw Water Treatment b) Consistent with NUREG- 1801, which states that system walkdowns are normally performed on a frequency that exceeds once per fuel cycle, formal system walkdowns are performed by the responsible System Engineer at least bi-weekly for accessible active components (such as pumps and valves), and at least semi-annually for accessible inactive components (e.g., piping). Surfaces that are inaccessible during normal plant operation are inspected during refueling outages. Opportunistic inspections are performed for surfaces that are not accessible during either normal operations or refueling outages (e.g., those that are insulated).

c) It may be determined by an engineering evaluation, which is based on site operating experience, that some active components do not require monitoring every two weeks.

The basis and justification for a change in walkdown frequency is required by procedure to be documented by the System Engineer and approved by engineering supervision. Any changes to walkdown frequencies will be subject to review under the 50.59 and SSES commitment change processes to determine if prior NRC approval is required.

Enclosure to PLA-6400 Page 11 of 15 RAI-B.2.32-3:

In the AMP B.2.19 Condensate and Refueling Water Storage Tanks Inspection Program, the applicant states that the scope of the AMP includes condition monitoring of paints, coatings, sealants and caulking, and condition monitoring of these tank materials will be accomplished through visual examinations that are implemented as part of the LRA AMP B.2.32 Systems Walkdown Program. The staff has verified that the program description of AMP B.2.32 Systems Walkdown Program does not indicate that these tank materials are within the scope of the AMP. Clarify whether paints, coatings, sealants, and caulking, including those for the condensate and refueling water storage tanks, are within the scope of the Systems Walkdown Program and if so, clarify the inspection techniques that will be credited to monitor for changes in material properties, such as, cracking, flaking, pealing, delamination, or other aging effects or loss of material that may be applicable to these materials. If these materials are not within the scope of the Systems Walkdown Program, justify how the Systems Walkdown Program can be credited for aging management of paints, coatings, sealants and caulking that are used in the fabrication or design of the condensate and refueling water storage tanks.

PPL Response:

Paints, coatings, sealants, and caulking are not within the scope of the System Walkdown Program.

Paints and coatings are not credited for preventing or mitigating the effects of aging, do not perform an intended function for license renewal, and do not require aging management. The System Walkdown Program is not credited for aging management of paints or coatings. The System Walkdown Program is credited for visual inspection of the accessible surfaces of the condensate and refueling water storage tanks. Although the condition of paints or coatings on component external surfaces may be indicative of the condition of the underlying metal surfaces they are not credited and do not require aging management for license renewal. Reference to the System Walkdown Program inspecting the coatings has been removed from the Condensate and Refueling Water Storage Tanks Inspection in response to RAIs B.2.19-01 and B.2.19-02.

The responses to RAI B.2.19 in Reference 3 also modified the Condensate and Refueling Water Storage Tanks Inspection to clarify that sealants and caulking are not within the scope of the System Walkdown Program. Reference to the System Walkdown Program for sealants and caulking has been removed from the Condensate and Refueling Water Storage Tanks Inspection. The System Walkdown Program is not credited for aging management of sealants or caulking.

Enclosure to PLA-6400 Page 12 of 15 RAI-B.2.32-4:

In the AMP B.2.32 Systems Walkdown Program the applicant states that the AMP is credited to manage cracking in and/or change in material properties for elastomers (neoprene and rubber) and polymers (Teflon) that are exposed to indoor air or ventilation environments. The GALL Report AMP XI.M36, "External Surfaces Monitoring,"

pertains to the external surfaces of steel components in systems that are within the scope of license renewal and are subject to AMRs for loss of material and leakage. The GALL Report program does not apply to elastomeric components or to the management of cracking or material property changes (including hardening or loss of strength) in elastomeric or polymeric components. Justify your basis for crediting the External Surfaces Monitoring Program to manage cracking and changes in material properties that may occur in the external surfaces of in-scope components that are fabricated from either an elastomeric or polymeric material. Using a technical basis, clarify how a visual examination alone from the external surfaces of these materials would be capable of detecting the following aging effects: (1) a tightly configured crack that penetrates the external surface of the component, (2) a subsurface crack or a crack that only penetrates the internal surface of the materials, and (3) a change in a material property, such as a potential change in the hardness property or strength property for the elastomer or polymer material used to fabricate the component.

PPL Response:

The AMP B.2.32 and Commitment #28 for the System Walkdown Program are revised as follows to identify inclusion of elastomers and polymers in the scope of the AMP as an exception to GALL, and to clarify how the program will manage cracking and/or change in material properties of elastomers and/or polymers in indoor air or ventilation environments.

The following text in LRA Section B.2.32 (on LRA pages B-101 and B-102) is revised by addition (bold italics) and deletion (strke4ffaugh).

B.2.32 System Walkdown Program NUREG-1801 Consistency The System Walkdown Program is an existing SSES program that, with enhancement, will be consistent with the 10 elements of an effective aging management program as described in NUREG-1801,Section XI.M36, "External Surfaces Monitoring-", with the following exception(s):

Enclosure to PLA-6400 Page 13 of 15 Exceptions to NUREG-1801 NG4e. ProgramElements Affected:

Scope, ParametersMonitored or Inspected, Detection of Aging Effects, Monitoring and Trending Elastomers and polymers are included within the scope of the System Walkdown Program. The program is credited with managing cracking and change in materialpropertiesfor elastomers and polymers exposed to indoor air or ventilation environments.

Required Enhancements Prior to the period of extended operation the enhancements listed below will be implemented in the identified program elements:

• Scope -

The governing procedure for the System Walkdown Program must be revised to add the listing of systems crediting the program for license renewal.

• ParametersMonitored or Inspected -

A routine activity to supplement the existing plant program must be generatedto inspect elastomers andpolymers for cracking and/or change in materialproperties. Evidence of surface degradation,such as cracking or discoloration,as well as physical manipulation and/orprodding, will be used as measures of the materialcondition.

" Detection of Aging Effects -

All of the systems to be added to the procedure contain mechanical components whose external surfaces require aging management during the period of extended operation. It may be determined by engineering evaluation that these components do not require monitoring every two weeks, and the basis for a different walkdown frequency may be documented on the appropriate procedure form.

" Detection of Aging Effects -

The governing procedure for the System Walkdown Program must be enhanced to address the license renewal requirement for opportunistic inspections of normally inaccessible components (e.g., those that are insulated), and those that are accessible only during refueling outages.

Enclosure to PLA-6400 Page 14 of 15 Detection of Aging Effects The routine activity to inspect elastomers and polymers will be based on inspection of a representativesample of components. The sample will be determined by engineering evaluation with a focus on components consideredto be most susceptible to aging, such as due to their time in service, the severity of conditions during normal plant operations,and any pertinent design margins.

A.1.2.47 System Walkdown Program The following text in LRA Section A.1.2.47 (on LRA page A-21) is revised by addition (bold italics):

Prior to the period of extended operation, the System Walkdown Program will be enhanced to include the license renewal systems that contain mechanical components whose external surfaces require aging management during the period of extended operation. The program will also be enhanced to address opportunistic inspections of normally inaccessible components (e.g., those that are insulated), and those that are accessible only during refueling outages. The program will also be enhancedby addition of a routine activity to inspect elastomers and polymers for cracking and/orchange in materialproperties.

Table A-1 SSES License Renewal Commitments The following text in LRA Table A-i, Commitment 28 (on LRA page A-44) is revised by addition (bold italics):

28) System Existing program is credited with the following A.1.2.28 Prior to the Walkdown enhancements: period of Program - The governing procedure for the System extended Walkdown Program must be revised to add the operation listing of systems crediting the program for license renewal.

- The governing procedure for the System Walkdown Program must be enhanced to address the license renewal requirement for opportunistic inspections of normally inaccessible components (e.g., those that are insulated), and those that are accessible only during refueling outages.

- A routine activity to supplement the existing plant program will be generatedto inspect elastomers and polymers for cracking and/or change in materialproperties. Evidence of surface degradation,such as cracking or discoloration,as well as physical manipulation and/orprodding, will be used as measures of the materialcondition.

Enclosure to PLA-6400 Page 15 of 15 RAI-B.2.33-1:

In the LRA AMP B.2.33 Lube Oil Analysis Program, the applicant takes an exception to the "parameters monitored or inspected" program element in the GALL AMP XI.M39, Lubricating Oil Analysis," and for particulate counting, credits "direct read ferrography" testing in lieu of the lubricating oil analysis testing that is recommended in the "parameters monitored or inspected" program element in the GALL Report AMP XI.M39. Justify why "direct read ferrography" is an acceptable alternative to performance of periodic particular content counting of the samples taken from the lubricating oil inventory. In your justification, discuss the techniques that "direct read ferrography" will use to monitor for particulates in the lubricating oil samples and clarify why these techniques are considered to provide for acceptable alternative monitoring of particulates in the lubricating oil inventory.

PPL Response:

PPL performs Direct Read Ferrography rather than particle counting on Diesel lube oil.

Diesel lubricating oil is dark in color and not easily "seen" through. Particle counters are optical devices that need to be able to pass light through the oil to count the particles.

With dark oils, visible detection is not possible without dilution of the sample. Dilution creates a concern with the cleanliness of the diluent used. Discussions with Fluid Analysis Laboratory, used by PPL for sample analysis, indicate that it is very difficult and time consuming to perform particle counting on the dark lubricating oil.

Particle Counting is used to measure the cleanliness of the oil by measuring the number of particles within certain size ranges. ISO 11171 quantifies particles into 3 size ranges,

>4, >6 and >14-microns. Direct Read Ferrography measures the number of primarily ferrous particles/ml of fluid, which is characteristic of mechanical wear. The results are reported as >5-microns and >15-microns.

In addition to Direct Read Ferrography, PPL employs spectrochemical testing which measures up to 21 different metals less than 10-microns in size to detect changing trends in wear debris, additive depletion and contamination. Therefore, because optical particle counters are not well suited for dark diesel oils, PPL relies on the Direct Read Ferrography as well as spectrochemical testing

Attachment to PLA-6400 Response to RAI B.2.14-2

Attachment to PLA 6400 Page 1 of 51 The following text in LRA Section 3.3.2.1.2 (on LRA page 3.3-6) is revised by addition (bold italics):

3.3.2.1.2 Containment Instrument Gas System Aging Management Programs The following aging management programs manage the aging effects for the Containment Instrument Gas System components/commodities:

" Area-Based NSAS Inspection

" Bolting Integrity Program

• Chemistry ProgramEffectiveness Inspection

• Closed Cooling Water Chemistry Program

• Selective Leaching Inspection

• System Walkdown Program

> The following text in LRA Section 3.3.2.1.4 (on LRA page 3.3-9) is revised by addition (bold italics):

3.3.2.1.4 Control Structure Chilled Water System Aging Management Programs The following aging management programs manage the aging effects for the Control Structure Chilled Water System components/commodities:

" Bolting Integrity Program

" Chemistry ProgramEffectiveness Inspection

• Closed Cooling Water Chemistry Program

• Cooling Units Inspection

• Heat Exchanger Inspection

• Lubricating Oil Analysis Program

• Lubricating Oil Inspection

" Piping Corrosion Program

" Selective Leaching Inspection

• Supplemental Piping/Tank Inspection

• System Walkdown Program

Attachment to PLA 6400 Page 2 of 51 The following text in LRA Section 3.3.2.1.5 (on LRA page 3.3-10) is revised by addition (bold italics):

3.3.2.1.5 Control Structure HVAC Systems Aging Management Programs The following aging management programs manage the aging effects for the Control Structure HVAC Systems components/commodities:

" Bolting Integrity Program

• Chemistry ProgramEffectiveness Inspection

• Closed Cooling Water Chemistry Program

• Cooling Units Inspection

" Fire Water System Program

• System Walkdown Program The following text in LRA Section 3.3.2.1.9 (on LRA pages 3.3 3.3-15) is revised by deletion (s14kethfeugh):

3.3.2.1.9 Diesel Generators System Aging Management Programs The following aging management programs manage the aging effects for the Diesel Generators System components/commodities:

" Bolting Integrity Program

" Closed Cooling Water Chemistry Program

" Chomistry Pro~gram EffoctiVonesr, InspectionR

" Lubricating Oil Analysis Program

• Lubricating Oil Inspection

" Piping Corrosion Program

• Selective Leaching Inspection

• Supplemental Piping/Tank Inspection

• System Walkdown Program

Attachment to PLA 6400 Page 3 of 51

> The following text in LRA Section 3.3.2.1.21 (on LRA page 3.3-27) is revised by addition (bold italics):

3.3.2.1.21 Reactor Building Chilled Water System Aging Management Programs The following aging management programs manage the aging effects for the Reactor Building Chilled Water System components/commodities:

• Area-Based NSAS Inspection

• Bolting Integrity Program

• Chemistry ProgramEffectiveness Inspection

" Closed Cooling Water Chemistry Program

• Lubricating Oil Analysis Program

" Lubricating Oil Inspection

" Piping Corrosion Program

• Selective Leaching Inspection

• System Walkdown Program

> The following text in LRA Section 3.3.2.1.22 (on LRA page 3.3-28) is revised by addition (bold italics):

3.3.2.1.22 Reactor Building Closed Cooling Water System Aging Management Programs The following aging management programs manage the aging effects for the Reactor Building Closed Cooling Water System components/commodities:

" Bolting Integrity Program

" Chemistry ProgramEffectiveness Inspection

• Closed Cooling Water Chemistry Program

• Piping Corrosion Program

" Selective Leaching Inspection

" System Walkdown Program

Attachment to PLA 6400 Page 4 of 51 The following text in LRA Section 3.3.2.1.23 (on LRA page 3.3-29) is revised by addition (bold italics):

3.3.2.1.23 Reactor Building HVAC System Aging Management Programs The following aging management programs manage the aging effects for the Reactor Building HVAC System components/commodities:

• Bolting Integrity Program

" Chemistry Program Effectiveness Inspection

• Closed Cooling Water Chemistry Program

• Cooling Units Inspection

• Piping Corrosion Program

• System Walkdown Program The following text in LRA Section 3.3.2.1.32 (on LRA page 3.3-38) is revised by addition (bold italics):

3.3.2.1.32 Turbine Building Closed Cooling Water System Aging Management Programs The following aging management programs manage the aging effects for the Turbine Building Closed Cooling Water System components:

• Bolting Integrity Program

" Chemistry ProgramEffectiveness Inspection

" Closed Cooling Water Chemistry Program

• Piping Corrosion Program

• System Walkdown Program

> The following text in LRA Section 3.3.2.2.10.2 (on LRA page 3.3-45) is revised by addition (bold italics):

3.3.2.2.10.2 Piping, Piping Components, Piping Elements, and Heat Exchanger Components Loss of material due to pitting and crevice corrosion for stainless steel and aluminum heat exchanger components exposed to treated water is managed by the Closed Cooling Water Chemistry Program. The Closed Cooling Water Chemistry Program manages aging effects through periodic monitoring and control of contaminants.

Attachment to PLA 6400 Page 5 of 51 Loss of materialfor stainless steel and aluminum components exposed to treated water is managed by the BWR Water Chemistry Programand the Chemistry Program.Effectiveness Inspection.

Loss of material for aluminum spent fuel racks and cracking of aluminum components exposed to treatedwater is managed by the BWR Water Chemistry Program.

The following text in LRA Section A. 1.2.13 (on LRA page A-9) is revised by addition (bold italics) and deletion (sti4kethfeugh):

A. 1.2.13 Closed Cooling Water Chemistry Program The Closed Cooling Water Chemistry Program is an existing program that mitigates damage due to loss of material and cracking of plant components that are within the scope of license renewal and that contain treated water in a closed cooling water system or component (e.g., a heat exchanger) served by a closed cooling water system.

The program manages the relevant conditions that could lead to the onset and propagation of a loss of material or cracking through proper monitoring and control of corrosion inhibitor concentrations consistent with the pertinent EPRI water chemistry guideline. The Closed Cooling Water Chemistry Program is a mitigation program. The Closed Cooling Water Chemistry Program is supplemented by the Chemistry Program Effectiveness Inspection and the Heat Exchanger In*,pction which provides verification of the effectiveness of the Closed Cooling Water Chemistry Program in mitigating the effects of aging.

The following text in LRA Section B.2.14 (on LRA page B B-48) is revised by deletion (stfkethfough):

B.2.14 Closed Cooling Water Chemistry Program The Closed Cooling Water Chemistry Program also includes monitoring of corrosion in the emergency diesel generator jacket water subsystem and is supplemented by a separate one-time inspection of representative areas of select closed cooling water cooling systems, as well as heat exchanger components served by closed cooling water systems, to provide confirmation that loss of material and cracking are effectively mitigated or to further detect and characterize whether, and to what extent, degradation is occurring. Refer to Section B.2.22 for discussion of the Chemistry Program Effectiveness Inspection and Seo*to B.2.2 fr discusion

,4 of the Heat E.xchanger IRPGj~GtRGF.

Attachment to PLA 6400 Page 6 of 51 Exceptions to NUREG-1801 Program Elements Affected:

Parameters Monitored or Inspected (and Detection of Aging Effects, Monitoring and Trending, and Acceptance Criteria)

The Closed Cooling Water Chemistry Program does not include performance or functional testing since performance and functional testing verify that component active functions can be accomplished, but in most cases, provide little definitive information or value with respect to the condition of passive components. In lieu of performance monitoring/functional testing, the Closed Cooling Water Chemistry Program includes monitoring of corrosion in the emergency diesel generator jacket water subsystem and is supplemented by the one-time Chemistry Program Effectiveness Inspection, which includes closed cooling water system locations, and the one time Heat EXchang..

Isypection, Which icncides heatmXchangeas snned by flowosod coaotlinRg systems, to confirm adequate mitigation in low flow and stagnant areas.

Attachment to PLA 6400 Page 7 of 51 The following text in LRA Table 3.3.1 (on LRA page 3.3-62) is revised by addition (bold italics)and deletion (stfikethfewtgh):

Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL Report Item Component/Commodity Aging Aging Management Further Discussion Number Effect/Mechanism Programs Evaluation Recommended 3.3.1-23 Stainless steel and steel with Loss of material Water Chemistry and Yes, detection of The Closed Cooling Water stainless steel cladding heat due to pitting and One-Time Inspection aging effects is Chemistry Program aid-the exchanger components crevice corrosion to be evaluated Chemistry ProFraFm*

exposed to treated water Er-,ctivenoc6.Inspection ar. is credited to manage loss of material for stainless steel heat exchanger components that are exposed to treated water.

A Note E is used.

There are no steel with stainless steel cladding heat exchanger components that are exposed to treated water in the Auxiliary Systems for SSES.

Further evaluation is documented in Section 3.3.2.2.10.2.

Attachment to PLA 6400 Page 8 of 51 SThe following text in LRA Table 3.3.1 (on LRA page 3.3-63) is revised by addition (bold italics):

Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL Report__ _____

Item Component/Commodity Aging Aging Management Further Discussion Number Effect/Mechanism Programs Evaluation Recommended 3.3.1-24 Stainless steel and Loss of material Water Chemistry and Yes, detection of Consistent with NUREG-1 801.

aluminum piping, piping due to pitting and One-Time Inspection aging effects is to The BWR Water Chemistry Program and components, and piping crevice corrosion be evaluated the Chemistry Program Effectiveness elements exposed to Inspection are credited to manage loss treated water of material for stainless steel and aluminum components exposed to treated water.

The BWR Water Chemistry Program is also credited to manage loss of material for spent fuel racks (see Table 3.5.2-2).

The BWR Water Chemistry Program is also credited to manage cracking of aluminum components exposed to treated water.

This item is also applicable to accumulators and immersion heaters. A Note C is used.

The Closed Cooling Water Chemistry Program is credited to manage loss of material for aluminum heat exchanger components in the Diesel Generators System. A Note E is used.

Further evaluation is documented in Section 3.3.2.2.10.2.

Attachment to PLA 6400 Page 9 of 51

> The following text in LRA Table 3.3.1 (on LRA pages 3.3 77) is revised by addition (bold italics) and deletion Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL Report Item Component/Commodity Aging Aging Management Further Discussion Number Effect/Mechanism Programs Evaluation Recommended 3.3.1-46 Stainless steel and stainless Cracking due to Closed-Cycle Cooling No CnCiAm,-t;,n-,,t with NUREG 1-804-,

clad steel piping, piping stress corrosion Water System with eXccptin. The Closed components, piping elements, cracking Cooling Water Chemistry Program and heat exchanger and the Chemistry Program components exposed to closed Effectiveness Inspection are is cycle cooling water >60 0 C credited to manage cracking for

(>140°F) stainless steel components that are exposed to closed cycle cooling water >60'C (>140'F). A Note E is used.

There are no stainless steel clad steel components in the Auxiliary Systems for SSES.

3.3.1-47 Steel piping, piping Loss of material Closed-Cycle Cooling No Ccistent with NUREG 1801, components, piping elements, due to general, Water System with eXepUGR-The Closed tanks, and heat exchanger pitting, and crevice Cooling Water Chemistry Program components exposed to closed corrosion and the Chemistry Program cycle cooling water Effectiveness Inspection are is credited to manage loss of material for steel components that are exposed to closed cycle cooling water. A Note E is used.

Attachment to PLA 6400 Page 10 of 51 Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL Report Item Component/Commodity Aging Aging Management Further Discussion Number Effect/Mechanism Programs Evaluation Recommended 3.3.1-48 Steel piping, piping Loss of material Closed-Cycle Cooling No Consistent with NUREG 1801, components, piping elements, due to general, Water System i cxepio_.-The Closed tanks, and heat exchanger pitting, crevice, Cooling Water Chemistry Program components exposed to closed and galvanic and the Chemistry Program cycle cooling water corrosion Effectiveness Inspection are is credited to manage loss of material for steel components that are exposed to treated water, including closed cycle cooling water. A Note E is used.

3.3.1-50 Stainless steel piping, piping Loss of material Closed-Cycle Cooling No COncsstent'with NUREG 1801, components, and piping due to pitting and Water System with

,,,,*cpt,. The Closed elements exposed to closed crevice corrosion Cooling Water Chemistry Program cycle cooling water and the Chemistry Program Effectiveness Inspection are is credited to manage loss of material for stainless steel components that are exposed to treated water, including closed cycle cooling water. A Note E is used.

Attachment to PLA 6400 Page 11 of 51 Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL Report Item Component/Commodity Aging Aging Management Further Discussion Number Effect/Mechanism Programs Evaluation Recommended 3.3.1-51 Copper alloy piping, piping Loss of material Closed-Cycle Cooling No Consistcnt with NJUREG 1801, components, piping elements, due to pitting, Water System wi4theXept*4en&-The Closed

'and heat exchanger crevice, and Cooling Water Chemistry Program components exposed to closed galvanic corrosion and the Chemistry Program cycle cooling water Effectiveness Inspection are is credited to manage loss of material for copper and copper alloy components that are exposed to treated water, including closed cycle cooling water. A Note E is used.

This item is also applicable to cracking of copper alloy components that are exposed to treated water, where Note H is used.

Attachment to PLA 6400 Page 12 of 51

) The following text in LRA Table 3.3.2-2 (on LRA page 3.3-100) is revised by addition (bold italics) and deletion (stfikethfe'ttgh)

Table 3.3.2-2 Aging Management Review Results - Containment Instrument Gas System Component / Intended Aging Effect Aging NUREG-1801 Commodity ntin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Chemistry Loss of Program E D, Heat Material Chemistry 0348 Exchangers - Program shells Effectiveness (intercoolers Structural Copper Alloy Treated Water Inspection 1/2E2100A/B Integrity (Brass) (Internal) Closed for Cooling Water compressors Chemistry 1/2K205A/B) Program H, Cracking N/A N/A 04 Chemistry 0347 Program Effectiveness Inspection Closed Heat Cooling Water Exchangers - Chemistry shells, Structural Program E D, channels/!trity Carbon Steel Treated Water Loss of VII.C2-1 3.3.1-48 E34 heads Integrity (Internal) Material Chemistry 0348 (Aftercooler Program 1/2E214A/B) Effectiveness Inspection

Attachment to PLA 6400 Page 13 of 51 The following text in LRA Table 3.3.2-4 (on LRA page 3.3-113) is revised by addition (bold italics) and deletion (stfikethffe'gh):

Table 3.3.2-4 Aging Management Review Results - Control Structure Chilled Water System Component/ Intended Aging Effect Aging NUREG-1801 Commodety ntin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Chiller Chemistry Evaporator Pressure Carbon Steel Treated Water Loss of Program VII.C2-1 3.3.1-48 EB, (OS118A/B) Boundary (Internal) Material Chemistry 0307 Channel Head Program Effectiveness Inspection

Attachment to PLA 6400 Page 14 of 51 The following text in LRA Table 3.3.2-4 (on LRA page 3.3-114) is revised by addition (bold italics) and deletion (stfikedffeugh):

Table 3.3.2-4 Aging Management Review Results - Control Structure Chilled Water System Component / Intended Aging Effect Aging NUREG-1801 Commodity Functon Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Chiller Chemistry Evaporator Pressureer PressureTreated Water ossofVI1.C2-4 Loss of Program 3.3.1-51 00 ED, (0S118A/B) Boundary, Copper (Internal) Material Chemistry 0308 Tubes Heat Transfer Program Effectiveness Inspection Closed Cooling Water Chiller Chemistry Evaporator Pressure Carbon Steel Treated Water Loss of Program VII.C2-1 3.3.1-48 E9, (OS1 18A/B) Boundary (Internal) Material Chemistry 0307 Tubesheet Program Effectiveness Inspection

Attachment to PLA 6400 Page 15 of 51 The following text in LRA Table 3.3.2-4 (on LRA page 3.3-115) is revised by addition (bold italics) and deletion (SPtrketfletigh):

Table 3.3.2-4 Aging Management Review Results - Control Structure Chilled Water System Component / Intended Aging Effect Aging NUREG-1801 Commodety nctin Material Environment Requiring Management Volume 2 Table I Item Notes Commodity Function Management Programs Item Closed Cooling Water Chemistry Cracking Program N/A N/A H Chemistry Program Chiller Effectiveness Evaporator Pressure Copper Alloy Treated Water Inspection (OS1 18A/B) Boundary (Brass) (External) Closed Tube Plugs Cooling Water Chemistry Loss of Program EQD, Material Chemistry 0308 Program Effectiveness Inspection Closed Cooling Water Chiller Oil Chemistry Cooler Pressure Cast Iron Treated Water Loss of ProgramVI1.C2-1 3.3.1-48 E B, (0S1 19A/B) Boundary (Internal) Material Chemistry 0307 Channel Head Program Effectiveness Inspection

Attachment to PLA 6400 Page 16 of 51 The following text in LRA Table 3.3.2-4 (on LRA page 3.3-117) is revised by addition (bold italics) and deletion (s*i*ke-the.gh):

Table 3.3.2-4 Aging Management Review Results - Control Structure Chilled Water System Component I Intended Aging Effect Aging NUREG-1801 Commodity nctin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Chemistry Program Cracking N/A N/A H Chemistry Program Chiller Oil Effectiveness Cooler Pressure Copper Alloy Treated Water Inspection (OS1 19A/B) Boundary, (Admiralty (Internal) Closed Tubes Heat Transfer Brass) Cooling Water Chemistry Loss of Program VII.C2-4 3.3.1-51 ED, Material Chemistry 0308 Program Effectiveness Inspection

Attachment to PLA 6400 Page 17 of 51 The following text in LRA Table 3.3.2-4 (on LRA page 3.3-118) is revised by addition (bold italics) and deletion (stfkedffetigh):

Table 3.3.2-4 Aging Management Review Results - Control Structure Chilled Water System Component / Intended Aging Effect Aging NUREG-1801 Commodity nctin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Chiller Oil Chemistry Cooler Pressure Carbon Steel Treated Water Loss of Program VII.C2-1 3.3.1-48 E9, (OS119AIB) Boundary (Internal) Material Chemistry 0307 Tubesheet Program Effectiveness Inspection Closed Cooling Water Chemistry Program Cracking N/A N/A H Chemistry Program Chiller Oil Effectiveness Cooler Pressure Copper Alloy Treated Water Inspection (OS1 19A/B) Boundary (Brass) (External) Closed Tube Plugs Cooling Water Chemistry Loss of Program VII.C2-4 3.3.1-51 Material Chemistry 0308 Program Effectiveness Inspection

Attachment to PLA 6400 Page 18 of 51 The following text in LRA Table 3.3.2-4 (on LRA page 3.3-121) is revised by addition (bold italics) and deletion Table 3.3.2-4 Aging Management Review Results - Control Structure Chilled Water System Component / Intended Aging Effect Aging NUREG-1801 Commodity Function Material Environment Requiring Management Volume 2 Table 1 Item Notes Management Programs Item Closed Cooling Water Chemistry Chiller Pressure Treated Water Loss of Program E84, Separator Boundary, Carbon Steel (Internal) Material Chemist VI.C2-14 3.3.1-47 0307 (0S1 14AIB) Filtration Program Effectiveness Inspection The following text in LRA Table 3.3.2-4 (on LRA page 3.3-122) is revised by addition (bold italics) and deletion Table 3.3.2-4 Aging Management Review Results - Control Structure Chilled Water System Component / Intended Aging Effect Aging NUREG-1801 Commodity nctn Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Chemistry Piping (Skid- Pressure Carbon Steel Treated Water Loss of Program VII.C2-14 3.3.1-47 E9, Mounted) Boundary (Internal) Material Chemistry 0307 Program Effectiveness Inspection

Attachment to PLA 6400 Page 19 of 51

) The following text in LRA Table 3.3.2-4 (on LRA page 3.3-124) is revised by addition (bold italics) and deletion Table 3.3.2-4 Aging Management Review Results - Control Structure Chilled Water System Aging Effect Aging NUREG-1801 Component Intended Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Chemistry Valve Bodies Pressure Treated Water Loss of Program E ,

(Skid-Mounted) Boundary Bonay(nenl Carbon Steel (Internal) Material aeil Chemistry VI1.C2-14 3.3.1-47 0307 00 Program Effectiveness Inspection The following text in LRA Table 3.3.2-4 (on LRA page 3.3-125) is revised by addition (bold italics) and deletion Table 3.3.2-4 Aging Management Review Results - Control Structure Chilled Water System Component / Intended Aging Effect Aging NUREG-1801 Commodity nctin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Chemistry Pressure Stainless Treated Water Loss of Program Orifices Boundary, Steel (Internal) Material Chemistry VI1.C2-10 3.3.1-50 EB Throttling Program Effectiveness Inspection

Attachment to PLA 6400 Page 20 of 51 The following text in LRA Table 3.3.2-4 (on LRA page 3.3-126) is revised by addition (bold italics) and deletion (stfikethfetgh):

Table 3.3.2-4 Aging Management Review Results - Control Structure Chilled Water System Component / Intended Aging Effect Aging NUREG-1801 Commodity nten Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Chemistry Piping Pressure Carbon Steel Treated Water Loss of Program VII.C2-14 3.3.1-47 Boundary (Internal) Material Chemistry 0307 Program Effectiveness Inspection Closed Cooling Water Chemistry Pump Casings Pressure Stainless Treated Water Loss of Program VII.C2-10 3.3.1-50 (OP162A/B) Boundary Steel (Internal) Material Chemistry Program Effectiveness Inspection

Attachment to PLA 6400 Page 21 of 51 The following text in LRA Table 3.3.2-4 (on LRA page 3.3-127) is revised by addition (bold italics) and deletion (stfikethfatigh):

Table 3.3.2-4 Aging Management Review Results - Control Structure Chilled Water System Component! Intended Aging Effect Aging NUREG-1801 Commodity nctin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Maaeet Programs Ie Management PrgasItem Closed Cooling Water Tanks Pressure Treated Water Loss of Chemistry Program EB (OT109A/B, Boury Carbon Steel (Inter Mtrao VI1.C2-14 3.3.1-47 0307, OT1 13A/B) Boundary (internal) Material Chemistry 0360 Program Effectiveness Inspection

Attachment to PLA 6400 Page 22 of 51 The following text in LRA Table 3.3.2-4 (on LRA page 3.3-128) is revised by addition (bold italics) and deletion (stfkehfouegh):

Table 3.3.2-4 Aging Management Review Results - Control Structure Chilled Water System Component/ Intended Aging Effect Aging NUREG-1 801 Commodity ntin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Chemistry Tubing Pressure Stainless Treated Water Loss of Program VII.C2-1O 3.3.1-50 EB Boundary Steel (Internal) Material Chemistry Program Effectiveness Inspection Closed Cooling Water Chemistry Valve Bodies Pressure Carbon Steel Treated Water Loss of Program VII.C2-14 3.3.1-47 EB, Boundary (Internal) Material Chemistry 0307 Program Effectiveness Inspection

Attachment to PLA 6400 Page 23 of 5l The following text in LRA Table 3.3.2-4 (on LRA page 3.3-129) is revised by addition (bold italics) and deletion (stfiketfle'&gh):

Table 3.3.2-4 AgingManagement Review Results - Control Structure Chilled Water System Component / Intended Aging Effect Aging NUREG-1801 Commodity ntin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Piping and Chemistry PormEB Piping Structural Treated Water Loss of ProgramVII.C2-14 Components 3.3.1-47 Integrity Carbon Steel (Internal) Material Chemistry 0348 Program Effectiveness Inspection Closed Cooling Water Chemistry Tanks Structural Carbon Steel Treated Water Loss of ProgramVII.C2-14 3.3.1-47 E ,

(OT204A/B) Integrity (Internal) Material Chemistry 0348 Program Effectiveness Inspection

Attachment to PLA 6400 Page 24 of 51

> The following text in LRA Table 3.3.2-5 (on LRA page 3.3-131) is revised by addition (bold italics) and deletion Table 3.3.2-5 Aging Management Review Results - Control Structure HVAC System Component / Intended Aging Effect Aging NUREG-1801 Commodity nctin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Chemistry Program Cracking N/A N/A H Chemistry H&V Unit, Program Control Effectiveness Structure Pressure Copper Alloy Treated Water Inspection (0E146A1/2 & Boundary (Red Brass) (Internal) Closed 0E146B1/2) Cooling Water Channels Chemistry Loss of Program VII.C2-4 3.3.1-51 ED, Material Chemistry 0312 Program Effectiveness Inspection Closed H&V Unit, Cooling Water Control Chemistry Structure Pressure Treated Water Loss of Program ED, (E146A1/2 (0E146A31/2 && Boundary, Heat TransferPrga Copper (Internal) Material Chemistry VI1.C2-4 3.3.1-51 0312 0El146B1/2) Program Cooling Coils Effectiveness Inspection

Attachment to PLA 6400 Page 25 of 51 The following text in LRA Table 3.3.2-5 (on LRA page 3.3-132) is revised by addition (bold italics) and deletion (st-i~kethfe'ugh):

Attachment to PLA 6400 Page 26 of 51 The following text in LRA Table 3.3.2-5 (on LRA page 3.3-133) is revised by addition (bold italics) and deletion (Stfiketh.e..gh):

Table 3.3.2-5 Aging Management Review Results - Control Structure HVAC System Component / Intended Aging Effect Aging NUREG-1801 Commodity ntin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Unit, Cooling Water Control Room Chemistry Floor Pressure PrsueVII.C2-4 Treated Water Loss of Program 3.3.1-51 01 ED, (0El51Al2 &Heat (OE151AI/2 & Transfer Boundary, Copper (Internal) Material Chemistry 0312 0E151 B11/2) Program Cooling Coils Effectiveness Inspection

Attachment to PLA 6400 Page 27 of 5l The following text in LRA Table 3.3.2-5 (on LRA page 3.3-134) is revised by addition (bold italics) and deletion (st4kethfettgh):

Table 3.3.2-5 Aging Management Review Results - Control Structure HVAC System Component / Intended Aging Effect Aging NUREG-1801 Commodity ntin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Chemistry Program Cracking N/A N/A H Chemistry Cooling Unit, Program Computer Effectiveness Room Floor Pressure Copper Alloy Treated Water Inspection (OE15OA1/2 & Boundary (Red Brass) (Internal) Closed OE1 503B1/2) Cooling Water Channels Chemistry Loss of Program VII.C2-4 3.3.1-51 ED, Material Chemistry 0312 Program Effectiveness Inspection Closed Cooling Unit, Cooling Water Control Room Chemistry Floor Pressure Treated Water Loss of Program ED, (OE15OA1/2 Chemistry VI1.C2-4 3.3.1-51 0312 (0El 50Al/2) & Boundary, Copper (Internal) Material 0El150B1/2) & Heat Transfer Program Cooling Coils Effectiveness Inspection

Attachment to PLA 6400 Page 28 of 51 The following text in LRA Table 3.3.2-5 (on LRA page 3.3-142) is revised by addition (bold italics) and deletion (stfkethfetg-h):

Table 3.3.2-5 Aging Management Review Results - Control Structure HVAC System Aging Effect Aging NUREG-1801 Componenty Intended Material Environment Requiring Management Volume 2 Table I Item Notes Commodity Function Management Programs Item Closed Cooling Water Chemistry PrsueTreated Water Loss of Program 3.3.1-47 EB, E.4 Piping Pressure Carbon Steel TetdWer Lsof PgamVI1.C2-14 Boundary (Internal) Material Chemistry 0311 Program Effectiveness Inspection The following text in LRA Table 3.3.2-9 (on LRA page 3.3-176) is revised by deletion (s):kethfedh Table 3.3.2-9 Aging Management Review Results - Diesel Generators System Component / Intended Aging Effect Aging NUREG-1801 Commodity nctin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Heat Chemistry Exchangers Pressure Aluminum Treated Water Loss of Program V 2 E (0E533A-E) Boundary (Internal) Material Chemist VII.A4-5 3.3.1-24 End Bells P .. ai.

InEffectPenes

Attachment to PLA 6400 Page 29 of 51

> The following text in LRA Table 3.3.2-14 (on LRA page 3.3-259) is revised by addition (bold italics) and deletion (stfikedhfeug ):

Table 3.3.2-14 Aging Management Review Results - Fuel Pool Cooling and Cleanup System and Fuel Pools and Auxiliaries Aging Effect Aging NUREG-1801 Component Commodity Intended Material Environment Requiring Management Volume 2 Table 1 Item Function Maaeet Programs Ie Notes Management PrgasItem Closed Cooling Water Heat Chemistry Exchangers/ Structural Carbon Steel Treated Water Loss of Program 3, E CabnSelVII.A4-3 3.3.1-48 0348, Coolers - shell Integrity (Internal) Material Chemistry 0353 (1/2E202A-C) Program Effectiveness Inspection

> The following text in LRA Table 3.3.2-17 (on LRA page 3.3-269) is revised by addition (bold italics) and deletion (stiikethfetg ):

Table 3.3.2-17 Aging Management Review Results - Process and Area Radiation Monitoring System Aging Effect Aging NUREG-1801 Component Intended Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Chemistry Piping and Structural Treated Water Loss of Program E3, Piping Integrity Carbon Steel (Internal) Material Chemistry VI1.C2-14 3.3.1-47 0348, Components Intet0358 Program Effectiveness Inspection

Attachment to PLA 6400 Page 30 of 51 The following text in LRA Table 3.3.2-17 (on LRA page 3.3-270) is revised by addition (bold italics) and deletion (stfkethfettgh):

Table 3.3.2-17 Aging Management Review Results - Process and Area Radiation Monitoring System Component / Intended Aging Effect Aging NUREG-1801 Commodity nctin Material Environment Requiring Management Volume 2 Table 1 Item Notes Management Programs Item Closed Cooling Water Chemistry Loss of Program EB, VII.C2-4 3.3.1-51 0348, Material Chemistry 0358 Program Effectiveness Piping and Structural Copper Alloy Treated Water Inspection Components Integrity (Internal) Closed Cooling Water Chemistry Program H, Cracking Chem N/A N/A 04 Chemistry 0347 Program Effectiveness Inspection

Attachment to PLA 6400 Page 31 of 51 The following text in LRA Table 3.3.2-21 (on LRA page 3.3-279) is revised by addition (bold italics) and deletion (stfikethfeih):

Table 3.3.2-21 Aging Management Review Results - Reactor Building Chilled Water System Component / Intended Aging Effect Aging NUREG-1801 Commodity nctin Material Environment Requiring Management Volume 2 Table 1 Item Notes Management Programs Item Closed Cooling Water Chemistry Piping Pressure Carbon Steel Treated Water Loss of Program VII.C2-14 3.3.1-47 Boundary (Internal) Material Chemistry 0307 Program Effectiveness Inspection Closed Cooling Water Chemistry Valve Bodies Pressure Stainless Treated Water Loss of Program VII.C2-10 3.3.1-50 E9 Boundary Steel (Internal) Material Chemistry Program Effectiveness Inspection

Attachment to PLA 6400 Page 32 of 51 The following text in LRA Table 3.3.2-21 (on LRA page 3.3-280) is revised by addition (bold italics) and deletion (str-keth1wetgh):

Table 3.3.2-21 Aging Management Review Results - Reactor Building Chilled Water System Component! Intended Aging Effect Aging NUREG-1801 Commodity Functn Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Chemistry Valve Bodies Pressure Carbon Steel Treated Water Loss of ProgramV11.C2-14 3.3.1-47 E8, Boundary (Internal) Material Chemistry 0307 Program Effectiveness Inspection Chillers - Closed evaporator/ Cooling Water condenser Chemistry channel/ Structural Carbon Steel Treated Water Loss of Program VII.C2-1 3.3.1-48 E8, header, Integrity (Internal) Material Chemistry 0348 integral Program piping/tubing Effectiveness (1/2K206A/B) Inspection

Attachment to PLA 6400 Page 33 of 51

• The following text in LRA Table 3.3.2-21 (on LRA page 3.3-28 1) is revised by addition (bold italics) and deletion (st-i~kethfettgh):

The following text in LRA Table 3.3.2-21 (on LRA page 3.3-282) is revised by addition (bold italics) and deletion Table 3.3.2-21 Aging Management Review Results - Reactor Building Chilled Water System Component I Intended Aging Effect Aging NUREG-1801 Commodity ntin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Chemistry Piping and Structural Treated Water Loss of Program E3, Piping Integrity Carbon Steel (Internal) Material Chemistry 0348 Components Integrity Program Effectiveness Inspection

Attachment to PLA 6400 Page 34 of 51 The following text in LRA Table 3.3.2-21 (on LRA page 3.3-283) is revised by addition (bold italics) and deletion (str4kethfatgh):

Table 3.3.2-21 Aging Management Review Results - Reactor Building Chilled Water System Component / Intended Aging Effect Aging NUREG-1801 Commodity nctin Material Environment Requiring Management Volume 2 Table I Item Notes Commodity Function Management Programs Item Closed Cooling Water Piping and Chemistry Piping Structural Treated Water Loss of Program EB, Components - Integrity Cast Iron (Internal) Material Chemistry VI1.C2-14 3.3.1-47 0348 pump casings (1/2P235A1B) Program Effectiveness Inspection

Attachment to PLA 6400 Page 35 of 51

> The following text in LRA Table 3.3.2-21 (on LRA page 3.3-285) is revised by addition (bold italics) and deletion (stfikethf ough):

Table 3.3.2-21 Aging Management Review Results - Reactor Building Chilled Water System Aging Effect Aging NUREG-1801 Component Intended Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Chemistry Loss of Los f Program Prgrm EB VI1.C2-4 3.3.1-51 E4 Material Chemistry 0348 Program Effectiveness Piping and Structural Copper Alloy Treated Water Inspection Piping Integrity (Internal) Closed Components Cooling Water Chemistry Program H, Cracking Chem N/A N/A 04 Chemistry 0347 Program Effectiveness Inspection

Attachment to PLA 6400 Page 36 of 51 The following text in LRA Table 3.3.2-21 (on LRA page 3.3-286) is revised by addition (bold italics) and deletion Table 3.3.2-21 Aging Management Review Results - Reactor Building Chilled Water System Component I Intended Aging Effect Aging NUREG-1801 Commodity nctin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Tanks Chemistry (1/2T205, Structural Carbon Steel Treated Water Loss of ProgramVII.C2-14 3.3.1-47 E, 1/2T221, Integrity (Internal) Material Chemistry 0348 1/2T224) Program Effectiveness Inspection

Attachment to PLA 6400 Page 37 of 51 The following text in LRA Table 3.3.2-21 (the line item was added to the LRA by PLA-6177 in response to RAI 2.1-3b) is revised by addition (bold italics) and deletion (stfikethferugh):

Table 3.3.2-21 Aging Management Review Results - Reactor Building Chilled Water System Component / Intended Aging Effect Aging NUREG-1801 Commodety ntin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Heat Cooling Water Exchangers/ Chemistry C o ole rs -

Shell/Channel/ St u t r lT Strity Carbon Steel e t d Wter reated W t rL Losss offP ro g ra m VII.C2-1 E 4B

,

3.3.1-48 Header Integrity Chemistry (Recirculation Program Pump Cooler) Effectiveness Inspection

Attachment to PLA 6400 Page 38 of 51 The following text in LRA Table 3.3.2-22 (on LRA page 3.3-287) is revised by addition (bold italics) and deletion (stfkethfettgh):

Table 3.3.2-22 Aging Management Review Results - Reactor Building Closed Cooling Water System Component! Intended Aging Effect Aging NUREG-1801 Commodity Funtin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Chemistry PrsueTreated Water Loss of Program 3.3.1-47 EB E ,

Piping Pressure Carbon Steel TetdWer Lsof PgamVII.C2-14 Boundary (Internal) Material Chemistry 0301 Program Effectiveness Inspection Closed Cooling Water Chemistry Valve Bodies Pressure Carbon Steel Treated Water Loss of ProgramVI1.C2-14 3.3.1-47 E9, Boundary (Internal) Material Chemistry 0301 Program Effectiveness Inspection

Attachment to PLA 6400 Page 39 of 5l The following text in LRA Table 3.3.2-22 (on LRA page 3.3-288) is revised by addition (bold italics) and deletion (stfiketh*fet*gh):

Table 3.3.2-22 Aging Management Review Results - Reactor Building Closed Cooling Water System Component / Intended Aging Effect Aging NUREG-1801 Commodity nctin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Heat Chemistry Exchangers/ Structural Carbon Steel Treated Water Loss of ProgramVII.C21 3.3.1-48 EB, Coolers - shell Integrity (Internal) Material Chemistry 0348 (1/2E201A/B) Program Effectiveness Inspection Closed Cooling Water Chemistry Piping and Structural Treated Water Loss of Program Components E9, Integrity (Internal) Material Chemistry3 0348 Program Effectiveness Inspection

Attachment to PLA 6400 Page 40 of 51 The following text in LRA Table 3.3.2-22 (on LRA page 3.3-289) is revised by addition (bold italics) and deletion Table 3.3.2-22 Aging Management Review Results - Reactor Building Closed Cooling Water Systemr Component / Intended Aging Effect Aging NUREG-1801 Commodity nctin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Piping and Chemistry Piping Structural Treated Water Loss of Program E93, Components - Integrity Cast Iron (Internal) Material Chemistry 0348 pump casings (1/2P21OA/B) Program Effectiveness Inspection Closed Cooling Water Chemistry Loss of Program VII.C2-4 3.3.1-51B, Material Chemistry 0348 Program Piping Effectiveness Pipingand Structural Treated Water Inspection Components Integrity Copper Alloy (Internal) Closed Cooling Water Chemistry Cracking Program VII.C2-4 3.3.1-51 H, Chemistry 0347 Program Effectiveness Inspection

Attachment to PLA 6400 Page 41 of 51

) The following text in LRA Table 3.3.2-22 (on LRA page 3.3-290) is revised by addition (bold italics) and deletion (stfikeflhfetigh):

Table 3.3.2-22 Aging Management Review Results - Reactor Building Closed Cooling Water System Component / Intended Aging Effect Aging NUREG-1801 Commodity ntin Material Environment Requiring Management Volume 2 Table I Item Notes Commodity Function Management Programs Item Closed Cooling Water Chemistry Loss of Program EB Los o Pogam VII.C2-10 3.3.1-50 ES Material Chemistry 0348 Program Effectiveness Piping and Structural Stainless Treated Water Inspection Components Integrity Steel (Internal) Closed Cooling Water Chemistry Cracking Program VII.C2-11 3.3.1-46 ER, Chemistry 0357 Program Effectiveness Inspection Closed Cooling Water Chemistry Tanks Structural Treated Water Loss of Program 3.1, E (1/2T201, Strutu Carbon Steel (Internal) Material y3.3.1-47 1/2T202) Integrity Chemistry Program Effectiveness Inspection

Attachment to PLA 6400 Page 42 of 51 The following text in LRA Table 3.3.2-23 (on LRA page 3.3-297) is revised by addition (bold italics) and deletion (stfikethreugh):

Table 3.3.2-23 Aging Management Review Results - Reactor Building HVAC System Component / Intended Aging Effect Aging NUREG-1801 Commodity nctin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Units, Cooling Water Emergency Chemistry SWGR and Pressure Treated Water Loss of Program E D, Load Center Boundary, Copper (Internal) Material Chemistry VII.C2-4 3.3.1-51 0312 Rooms Heat TransferPrga (1/2E240A/B) Program Cooling Coils ____ ___

____ ______ ____ ___ ____ __ ___ ___ ___ ___ ___ ___

Effectiveness Inspection The following text in LRA Table 3.3.2-23 (on LRA page 3.3-298) is revised by addition (bold italics) and deletion (stfikethfettgh):

Table 3.3.2-23 Aging Management Review Results - Reactor Building HVAC System Component / Intended Aging Effect Aging NUREG-1801 Commodity nctin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Units, Cooling Water Emergency Chemistry SWGR and Pressure Copper Alloy Treated Water Loss of Program ED, Load Center Boundary, (Copper- (Internal) Material Chemistry VI.C2-4 3.3.1-51 0312 Rooms Heat Transfer Nickel) Program (1E257A/B) Effectiveness Cooling Coils _______

______ ___

_ ____

____ ____ ___ ___ ____ ____ ____ ___ Effetivn Inspection _ _ _

Attachment to PLA 6400 Page 43 of 51 The following text in LRA Table 3.3.2-23 (on LRA page 3.3-303) is revised by addition (bold italics) and deletion (s .i4kethfLttgh):

Table 3.3.2-23 Aging Management Review Results - Reactor Building HVAC System Component / Intended Aging Effect Aging NUREG-1801 Commodity nctin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Chemistry Pressure Treated Water Loss of Program E8, Piping Boundary Carbon Steei (Internal) Material Chemistry 0311 Program Effectiveness Inspection The following text in LRA Table 3.3.2-23 (on LRA page 3.3-306) is revised by addition (bold italics) and deletion (stfikedflettgh):

Table 3.3.2-23 Aging Management Review Results - Reactor Building HVAC System Component I Intended Aging Effect Aging NUREG-1801 Commodity Functn Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Chemistry Unit Coolers UntCoes-- Structural Treated Water Loss of Program E D, channels/ Strutu Carbon Steel Tretednate Loss ofmPro VII.C2-14 3.3.1-47 heads Integrity (Internal) Material Chemistry 0348 Program Effectiveness Inspection

Attachment to PLA 6400 Page 44 of 51 The following text in LRA Table 3.3.2-23 (on LRA page 3.3-307) is revised by addition (bold italics) and deletion (str-ikethfettgh):

Table 3.3.2-23 Aging Management Review Results - Reactor Building HVAC System Aging Effect Aging NUREG-1801 Component Intended Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Chemistry Unit Coolers - Structural Stainless Treated Water Loss of Program VII.C2-10 3.3.1-50D, channels! I.2103315 Steel (Internal) Material Chemistry 0348 heads Integrity Program Effectiveness Inspection

) The following text in LRA Table 3.3.2-25 (on LRA page 3.3-314) is revised by addition (bold italics) and deletion

(&ti#7iethfe'ctgh):

Table 3.3.2-25 Aging Management Review Results - Reactor Water Cleanup System Aging Effect Aging NUREG-1801 Component Intended Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Heat Chemistry Exchangers/ Structural Treated Water Loss of Program EA, Coolers - shell Strutu Carbon Steel (internal)VII.E3-4 3.3.1-48 0 (1/2E208A/B, Integrity Chemistry 1/2E239A/B) Program Effectiveness Inspection

Attachment to PLA 6400 Page 45 of 51

> The following text in LRA Table 3.3.2-27 (on LRA page 3.3-329) is revised by addition (bold italics) and deletion (stfikethreugh):

Table 3.3.2-27 Aging Management Review Results - Sampling System Component / Intended Aging Effect Aging NUREG-1801 Commodity nctn Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Chillers - Closed condenser Cooling Water channel/ Chemistry header, Structural Treated Water Loss of Program E B, evaporator Integrity Carbon Steel (Internal) Material Chemisty VII.C21 3.3.1-48 0348 shell, integral Program piping/tubing Effectiveness (1/2K207) Inspection

Attachment to PLA 6400 Page 46 of 51 The following text in LRA Table 3.3.2-27 (on LRA page 3.3-330) is revised by addition (bold italics) and deletion (st-kethifettg-h):

Table 3.3.2-27 Aging Management Review Results - Sampling System Component! Intended Aging Effect Aging NUREG-1801 Commodity nctin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Chemistry Loss of Program E D, Chillers - Material Chemistry 0348 condenser Program channel/ Effectiveness header, Structural Copper Alloy Treated Water Inspection evaporator Integrity (Internal) Closed shell, integral Cooling Water piping/tubing Chemistry (1/2K207) Program H, Cracking CeityN/A N/A 04 0347 Chemistry Program Effectiveness Inspection

Attachment to PLA 6400 Page 47 of 51

> The following text in LRA Table 3.3.2-27 (on LRA page 3.3-331) is revised by addition (bold italics) and deletion (stfikethfetigh):

Table 3.3.2-27 Aging Management Review Results - Sampling System Component / Intended Aging Effect Aging NUREG-1801 Commodity ntin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Chillers - Closed condenser Cooling Water channel/ Chemistry header, Structural Stainless Treated Water Loss of Program evaporator ED, Integrity Steel (Internal) Material Chemistry 0348 shell, integral piping/tubing Program and tanks Effectiveness (1/2K207) Inspection Heat Exchangers/ Closed Coolers - Cooling Water channel/head, Chemistry shell Structural Stainless Treated Water Loss of Program E D, (1/2E224, Integrity Steel (Internal) Material Chemistry 0348 1/2E225, Program 1/2E226A/B, Effectiveness 1/2E233, Inspection 1/2E237)

Attachment to PLA 6400 Page 48 of 51

) The following text in LRA Table 3.3.2-27 (on LRA page 3.3-332) is revised by addition (bold italics) and deletion Table 3.3.2-27 Aging Management Review Results - Sampling System Aging Effect Aging NUREG-1801 Component Intended Material Environment Requiring Management Volume 2 Table I Item Notes Commodity Function Management Programs Item Closed Cooling Water Chemistry Heat Loss of Program VII.C2-1 3.3.1-50, Exchangers/ Material Chemistry 0348 Coolers - Program channel/head, Effectiveness shell Structural Stainless Treated Water Inspection (1/2E223, Integrity Steel (Internal) Closed 1/2E234A/B, Cooling Water 1/2E235, Chemistry 1/2E236,1/2E Program ED, 604, 1/2E605) Cracking Chemistry VII.C2-11 3.3.1-46 0357 Program Effectiveness Inspection

Attachment to PLA 6400 Page 49 of 51 The following text in LRA Table 3.3.2-27 (on LRA page 3.3-332) is revised by addition (bold italics) and deletion Table 3.3.2-27 Aging Management Review Results - Sampling System Component / Intended Aging Effect Aging NUREG-1801 Commodity ntin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Chemistry Loss of Program E B, Material Chemistry 0348 Program Piping and Effectiveness Piping Structural Copper Alloy Treated Water Inspection Components Integrity (Internal) Closed Cooling Water Chemistry Program H, Cracking Chemistry N/A N/A 0347 Program Effectiveness Inspection

Attachment to PLA 6400 Page 50 of 51 The following text in LRA Table 3.3.2-27 (on LRA page 3.3-333) is revised by addition (bold italics) and deletion (stf_ th-er.lgh):

Table 3.3.2-27 Aging Management Review Results - Sampling System Component / Intended Aging Effect Aging NUREG-1801 Commodity ntin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Chemistry Loss of Program E B, Material Chemistry 0348 Program Effectiveness Piping Structural Stainless Treated Water Inspection Components Integrity Steel (Internal) Closed Cooling Water Chemistry Cracking Program VII.C2-11 3.3.1-46 Chemistry 0357 Program Effectiveness Inspection

Attachment to PLA 6400 Page 51 of 51 The following text in LRA Table 3.3.2-32 (on LRA page 3.3-343) is revised by addition (bold italics) and deletion (stfikethfeugh):

Table 3.3.2-32 Aging Management Review Results - Turbine Building Closed Cooling Water System Component / Intended Aging Effect Aging NUREG-1801 Commodity Functin Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Closed Cooling Water Heat Chemistry Exchangers/ Structural Treated Water Loss of Program E9.,

Coolers - Carbon Steel VII.C2-1 3.3.1-48 Integrity (Internal) Material Chemistry 0348 shells (1/2E123A/B) Program Effectiveness Inspection