PLA-6401, Response to Request for Additional Information for the Review of License Renewal Application (LRA) Sections 3.1, 3.2, 3.3, and 3.4

Response to Request for Additional Information for the Review of License Renewal Application (LRA) Sections 3.1, 3.2, 3.3, and 3.4

ML082400534
Person / Time
Site:	Susquehanna
Issue date:	08/15/2008
From:	Mckinney B Susquehanna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PLA-6401
Download: ML082400534 (64)

Text

Britt T. McKinney Sr. Vice President & Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3149 Fax 570.542.1504 btmckinney@ppiweb.com S 000 pp 4ý%

AUG 1."s mm-U. S. Nuclear Regulatory Commission Document Control Desk Mail Stop OP1-17 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 3.1, 3.2, 3.3, AND 3.4 PLA-6401 Docket Nos. 50-387 and 50-388 References.

1) PLA-6110, Mr. B. T McKinney (PPL) to Document Control Desk (USNRC),

"Application for Renewed Operating License Numbers NPF-14 and NPF-22, dated September 13, 2006.

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

"Request for Additional Information for the Review of the Susquehanna Steam Electric Station, Units 1 and 2 License Renewal Application, "dated July 15, 2008.

3) PLA-6383, Mr. B. T McKinney (PPL) to Document Control Desk (USNRC), "Request for Additional Information for the Review of the Susquehanna Steam Electric Station Units 1 and 2, License Renewal Application (LRA) Sections B. 2.1, B.2.5, B.2.7, B.2.9, and B.2.10, " dated July 14, 2008.

4) PLA-6391, Mr. B. T. McKinney (PPL) to Document Control Desk (USNRC), "Request for Additional Information for the Review of the Susquehanna Steam Electric Station Units 1 and 2, License Renewal Application (LRA) Sections B.2.23, B.2.24, B.2.26, B.2.27, B.2.28, B.2.31, "dated July 25, 2008.

5) PLA-6296, Mr. B. T. McKinney (PPL) to Document Control Desk (USNRC),

"Application for Renewed Operating License Numbers NPF-14 and NPF-22 Requests for Additional Information-License Renewal Application (LRA) Section 2.3.3.13 RAI Follow-up, "dated October 24, 2007.

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.

Document Control Desk PLA-6401 Reference 2 is a request for additional information (RAI) related to License Renewal Application (LRA) Sections 3.1, 3.2, 3.3, and 3.4. The enclosure to this letter provides the question responses and the additional requested information.

The Attachment contains revised LRA Sections and Tables in response to RAIs 3.1-1 and 3.1-8.

There are no new regulatory commitments contained herein as a result of the attached responses.

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:

'311, zp*

B.

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Enclosure:

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

Attachment:

LRA Revisions in response to RAIs 3.1-1 and 3.1-8.

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-6401 PPL Responses to NRC's Request for Additional Information (RAI)

Enclosure to PLA-6401 Page 1 of 49 RAI 3.1-1:

For multiple aging management review (AMR) result lines in Table 3.1.2-1 where the environment is "treated water (internal)" and the aging effect is either "loss of material" or "loss of material (cladding)," the aging management program (AMP) identified in the license renewal application (LRA) is the boiling water reactor (BWR) Water Chemistry Program, which provides an aging mitigation (preventive) function. For these AMR results the LRA does not identify an AMP to confirm effectiveness of the BWR Water Chemistry Program for these components. Please provide an AMP to confirm effectiveness of the BWR Water Chemistry Program for these components, or provide a technical justification as to why confirmation of effectiveness of the BWR Water Chemistry Program to mitigate loss of material during the period of extended operation is not needed for these components.

PPL Response:

Confirmation of the effectiveness of the BWR Water Chemistry Program to mitigate loss of material during the period of extended operation is needed. The SSES LRA Sections A. 1.2.11, A. 1.2.12, B.2.2, and B.2.22 state that the BWR Water Chemistry Program is supplemented by the Chemistry Program Effectiveness Inspection to provide verification of the effectiveness of the BWR Water Chemistry Program in mitigating the aging effects of loss of material and cracking.

LRA Table 3.1.2-1 is revised to list the Chemistry Program Effectiveness Inspection in addition to the BWR Water Chemistry Program for the AMR result lines where the environment is "treated water (internal)," the aging effect is either "loss of material" or "loss of material (cladding)," and the BWR Water Chemistry Program was the only program originally credited for aging management.

The affected LRA Sections and Tables are revised, as detailed in the Attachment, to show the necessary changes.

RAI 3.1-2:

For the AMR result line on page 3.1-76 of the LRA where the component is "Main Steam flow elements / restrictors," the material is "carbon steel," and the aging effect is "loss of material," please provide a technical justification as to why confirmation of effectiveness of the BWR Water Chemistry Program is not needed. Also, please justify use of Note D for this AMR result.

Enclosure to PLA-6401 Page 2 of 49 PPL Response:

Confirmation of the effectiveness of the BWR Water Chemistry Program to mitigate loss of material during the period of extended operation is needed. The SSES LRA Sections A. 1.2.11, A. 1.2.12, B.2.2, and B.2.22 state that the BWR Water Chemistry Program is supplemented by the Chemistry Program Effectiveness Inspection which provides verification of the effectiveness of the BWR Water Chemistry Program in mitigating the aging effects of loss of material and cracking.

The LRA Table 3.1.2-3 entry for the carbon steel main steam flow elements/restrictors is revised to credit the Chemistry Program Effectiveness Inspection in addition to the BWR Water Chemistry Program for management of loss of material.

A Note C is used instead of a Note D in the AMR result line in Table 3.1.2-3, because GALL item IV.A1-11 is for a different component (vessel top head enclosure versus flow restrictor), but both the BWR Water Chemistry Program and the Chemistry Program Effectiveness Inspection are credited, which is consistent with GALL.

The revisions to Table 3.1.2-3 discussed above were previously made in Attachment 2 to PPL letter PLA-6391 (Reference 4). Thus, no further LRA changes are necessary to address this RAI.

RAI 3.1-3:

For multiple AMR result lines in LRA Table 3.1.2-3, the environment is "treated water (internal)," the aging effect is "loss of material," and the AMPs are BWR Water Chemistry Program and Small Bore Class 1 Piping Inspection. The note assigned to these AMR result lines is either note A, or note C, and the AMP is consistent with the GALL Report. However, the AMPs recommended in the GALL Report for this material, environment and aging effect combination are XI.M2 Water Chemistry and XI.M32 One-Time Inspection. Since the AMP stated in the LRA is not the same as the AMP recommended in the GALL Report for these component, material, environment and aging effect combinations, please justify why notes A and C are appropriate for these AMR results lines.

PPL Response:

The LRA Table 3.1.2-3 AMR result lines that credit the combination of BWR Water Chemistry and Small Bore Class 1 Piping Inspection for managing loss of material in treated water are aligned to GALL items IV.C 1-14 and IV.AI-1 1.

The Chemistry Program Effectiveness Inspection is a more appropriate verification activity than the Small Bore Class 1 Piping Inspection for loss of material.

Enclosure to PLA-6401 Page 3 of 49 Therefore, LRA Table 3.1.2-3 is revised to replace the Small Bore Class 1 Piping Inspection with the Chemistry Program Effectiveness Inspection to manage loss of material in treated water for result lines compared to GALL items IV.C1-14 and IV.AI-1 1. Notes A and C are appropriate with these revisions. Note 0105 is no longer necessary with these revisions.

The associated revisions to LRA Table 3.1.2-3 to credit the aging management programs, as discussed above, were previously made in Attachment 3 to PPL letter PLA-6391 (Reference 4). Thus, no further LRA changes are necessary to address this RAI.

RAI 3.1-4:

On page 3.1-84 of the LRA, an AMR result line for stainless steel tubing in treated water identifies an aging effect of cracking and identifies the AMP as the BWR Water Chemistry Program. This line also refers to the GALL Report item IV.C 1-1, which recommends that this component, material, environment and aging effect combination use AMP XI.M1 American Society of Mechanical Engineers (ASME)Section XI Inservice Inspection (ISI), AMP XI.M2 Water Chemistry, and AMP XI.M35 One-Time Inspection of ASME Code Class 1 Small-bore Piping. Please provide a technical justification as to why an inspection program is not needed to confirm effectiveness of the BWR Water Chemistry Program in preventing or mitigating the aging effect of cracking in these components.

PPL Response:

An inspection program is needed to confirm the effectiveness of the BWR Water Chemistry Program. LRA Table 3.1.2-3 is revised to credit the Inservice Inspection (ISI)

Program and the Small Bore Class 1 Piping Inspection in addition to the BWR Water Chemistry Program to manage cracking for stainless steel tubing in treated water. This is consistent with the combination of aging management programs identified in GALL item IV.C1-1. Note A is applicable because the ISI Program is consistent with GALL, as detailed in the response to RAI B.2.1-5 in PLA-6383 (Reference 3).

The necessary changes to the LRA are addressed in the response to RAI 3.1-6, which addressed the tubing and several similar AMR result lines in LRA Table 3.1.2-3.

Enclosure to PLA-6401 Page 4 of 49 RAI 3.1-5:

In the GALL Report item IV.C1-3 recommends AMP XL.M1 ASME Section XI Inservice Inspection for managing the aging effect of reduction of facture toughness in cast austenitic stainless steel (CASS) valve bodies. On page 3.1-90 of the LRA, for valve bodies <4 inch, the AMP used to manage this aging effect is the Small Bore Class 1 Piping Inspection. Please provide technical justification for use of the Small Bore Class 1 Piping Inspection for managing this aging effect in Valve Bodies <4 inches; and include in your response what inspection techniques will be used and what part of the valve bodies will be inspected.

PPL Response:

The LRA Table 3.1.2-3 entry for cast austenitic stainless steel (CASS) valve bodies < 4 inches originally credited the Small Bore Class 1 Piping Inspection to manage the reduction of fracture toughness. This table entry is revised to credit the Inservice Inspection (ISI) Program to be consistent with GALL item IV.C1-3. This will also

.change the associated note from Note E to Note A, which is applicable because the ISI Program is consistent with GALL, as detailed in the response to RAI B.2.1-5 in PLA-6383 (Reference 3). The LRA Table 3.1.1, Item 3.1.1-55, is also revised to remove the statement that the ISI Program contains an exception.

The associated revisions to LRA Sections A. 1.2.44 and B.2.31 and LRA Table 3.1.1, Item 3.1.1-55, to delete the references to the Small Bore Class 1 Piping Inspection as the program credited to manage the reduction of fracture toughness, as discussed above, were previously made in Attachment 3 to PPL letter PLA-6391 (Reference 4).

It is noted that, in Attachment 3 to PLA-6391 (Reference 4), the LRA Table 3.1.2-3 line entry for CASS valve bodies < 4 inches, in a treated water (internal) environment, and subject to reduction of fracture toughness was erroneously deleted. This RAI response restores the original LRA Table 3.1.2-3 entry and revises it, as discussed above, to credit the Inservice Inspection (ISI) Program.

Enclosure to PLA-6401 Page 5 of 49 The text in LRA Table 3.1.1 (on LRA page 3.1-32) is revised by deletion (stikethfe.gh).

Table 3.1.1 Summary of Aging Management Programs for Reactor Vessel, Internals, and Reactor Coolant System Evaluated in Chapter IV of the GALL Report Item Component/Commodity Aging Effect /

Aging Management IFurther Discussion Number Mechanism Programs Evaluation F

RRecommended 3.1.1-55 Cast austenitic stainless steel Class I pump casings, and valve bodies and bonnets exposed to reactor coolant >250 0C (>4820F)

Loss of fracture toughness due to thermal aging embrittlement Inservice inspection (IWB, IWC, and IWD). Thermal aging susceptibility screening is not necessary, inservice inspection requirements are sufficient for managing these aging effects. ASME Code Case N-481 also provides an alternative for pump casings.

No Consistent with NUREG-1801.

wi4th-exeep..,

The Inservice Inspection (ISI)

Program is credited to manage loss of fracture toughness for CASS pump casings, pump covers, thermal barriers, and valve bodies. The414 Progr-am f nansa exepin.

These deletions were previously made in PLA-639 1.

They are repeated here for consistency.

inch N-12, the Small Bcre Class 1 Piping inspection is credited to manage lass of fractur-e toughness.

Main steam flow elements / flow eticrsformed of CASS are also coprd to this item. The Main Steam Flow Restr-ictor inspection is credited to detect loss of fractur-e toughnfess for: these caomonents.

The text in LRA Table 3.1.2-3 (on LRA page 3.1-90) is revised by addition (bold italics). Note that this line entry was erroneously deleted in PLA-6391 (Reference 4).

Table 3.1.2-3 Aging Management Review Results - Reactor Coolant System Pressure Boundary ComponentMaterial Environment Aging Effect Aging Management NUREG-1801 Table 1 Notes Commodity Function Management Programs Volume 2 Item Item Valve bodies Pressure C

Treated Water Reduction of Inservice Inspection IVC13 3.1.1-55 A

<CASS Fracture (1Sf) ProgramC1

<4in.

Boundary (Internal)

Toughness (I)Prga

Enclosure to PLA-6401 Page 6 of 49 RAI 3.1-6:

The LRA Table 3.1.2-3 contains multiple lines where the components are small bore piping components made of stainless steel, the environment is "treated water (internal),"

the aging effect is cracking, and the AMPs are BWR Water Chemistry Program and Small Bore Class 1 Piping Inspection. For these component, material, environment and aging effect combination, the GALL Report recommends AMP XI.M1 ASME Section XI Inservice Inspection Program, AMP XI.M2 Water Chemistry Program and AMP XI.M35 One-Time Inspection of ASME Code Class 1 Small-bore Piping. Since the AMPs identified in the LRA are not the same as the AMPs recommended in the GALL Report for this component, material, environment and aging effect combination, please provide technical justification that the AMPs listed in the LRA provide adequate management of the aging effect during the period of extended operation and justify why note A is appropriate for these AMR results lines.

PPL Response:

The LRA Table 3.1.2-3 AMR result lines where the components are small bore piping components made of stainless steel, the environment is "treated water (internal)," the aging effect is cracking, and the AMPs are BWR Water Chemistry Program and Small Bore Class 1 Piping Inspection are revised to also credit the Inservice Inspection (ISI)

Program. Also, the line entry for stainless steel tubing in LRA Table 3.1.2-3 is revised to also credit both the Inservice Inspection (ISI) Program and the Small Bore Class 1 Piping Inspection, as previously addressed in the response to RAI 3.1-4.

In total, there are 6 AMR line entries, covering stainless steel condensing chambers, flow orifices, piping and fittings < 4 in., tubing and valves exposed to treated water, subject to cracking, and compared to GALL line item IV.C1-1. By crediting ISI for these entries, and ISI and small bore inspection for the tubing, the credited programs are consistent with GALL line item IV.C 1-1. Note A is applicable because the ISI Program is consistent with GALL, as detailed in the response to RAI B.2.1-5 in PLA-6383 (Reference 3).

The LRA is amended to make the necessary changes. The changes to LRA Table 3.1.1,

.Item 3.1.1-48, also include the change required by the response to RAI 3.1-07, regarding carbon steel piping components.

Enclosure to PLA-6401 Page 7 of 49 The text in LRA Table 3.1.1 (on LRA page 3.1-28) is revised by addition (bold italics) and deletion (s.ri*kedhu).

Table 3.1.1 Summary of Aging Management Programs for Reactor Vessel, Internals, and Reactor Coolant System Evaluated in Chapter IV of the GALL Report Item Component/Commodity Aging Effect /

Aging Management Further Discussion Number Mechanism Programs Evaluation Recommended 3.1.1-48 Steel and stainless steel Class I piping, fittings and branch connections < NPS 4 exposed to reactor coolant Cracking due to stress corrosion cracking, intergranular stress corrosion cracking (for stainless steel only),

and thermal and mechanical loading Inservice Inspection (1WB, IWC, and IWD), Water chemistry, and One-Time Inspection of ASME Code Class 1 Small-bore Piping No Consistent with NUREG-1801.

A combination of the Inservice Inspection (ISI) Program, the BWR Water Chemistry Program, and the Small Bore Class 1 Piping Inspection is credited to manage cracking of stainless steel piping components, including tubing.

In addition, stainless Steel tubing is ineluded under-this item and credits the BWR Water-Chemistry Progr-am alone to manage cr-aeking.

A combination of the Inservice Inspection (ISI) Program and the Small Bore Class 1 Piping Inspection is credited to manage cracking of carbon steel piping components due to thermal and mechanical loading.

This addition is discussed in the response to RAI 3.1-7.

It is shown here to provide a single, complete entry that shows all of the changes for this item.

Enclosure to PLA-6401 Page 8 of 49

> The text in LRA Table 3.1.2-3 (on LRA pages 3.1-74, 3.1-76, 3.1-80, 3.1-84, 3.1-89, and 3.1-90) is revised by addition (bold italics) and deletion (sPkethreugh).

Table 3.1.2-3 Aging Management Review Results - Reactor Coolant System Pressure Boundary Component /

Intended TAging Effect Aging Management NUREG-1801 Table 1 Commodit Intin Material Environment Requiring ProgranItE m

I Notes Commodity Function Management Programs Volume 2 Item Item Inservice Inspection (ISI) Program Condensing Pressure Stainless Treated Water Cracking BWR Water Chemistry IV.Cbi 3.1.1-48 A

Chamber Boundary Steel (Internal)

Program Small Bore Class 1 Piping Inspection Inservice Inspection (ISI) Program Flow oifice Pressure Flow orifice Boundary Stainless Treated Water Cracking BWR Water Chemistry IV.Cl-1 3.1.1-48 A

< 4 in.

Steel (Internal)

Program

i.

Throttling Small Bore Class 1 Piping Inspection Inservice Inspection (ISI) Program Piping &

Fittings Pressure Stainless Treated Water Cracking BWR Water Chemistry IV.C1-1 3.1.1-48 A

Boundary Steel (Internal)

Program

<4 in.

Small Bore Class I Piping Inspection

Enclosure to PLA-6401 Page 9 of 49 Table 3.1.2-3 Aging Management Review Results - Reactor Coolant System Pressure Boundary Component /

Intended Aging Effect Aging Management NUREG-1801 Table 1 CommodityMaterial Environment Requiring Programs Volume 2 Item Item Notes Commdity FuncionManagement Inservice Inspection (ISI) Program Tubing Pressure Stainless Treated Water Cracking BWR Water Chemistry IV.C1-1 3.1.1-48

-E-A Boundary Steel (Internal)

Program Small Bore Class 1 Piping Inspection Inservice Inspection (ISI) Program Valve bodies Pressure Stainless Treated Water Cracking BWR Water Chemistry IV.C 1 - 1 3.1.1-48 A

< 4 in.

Boundary Steel (Internal)

Program Small Bore Class I Piping Inspection Inservice Inspection (ISI) Program Valve'bodies Pressure CASS Treated Water Cracking BWR Water Chemistry IV.CI 3.1.1-48 A

< 4 in.

Boundary (Internal)

Program Small Bore Class I Piping Inspection

Enclosure to PLA-6401 Page 10 of 49 RAI 3.1-7:

Two AMR result lines in the LRA Table 3.1.2-3 for piping & fittings <4 inch and for valve bodies <4 inch show the material is carbon steel, the environment is "treated water (internal)," the aging effect is cracking and the AMP is the Small Bore Class 1 Piping Inspection. The component, material, environment and aging effect combination for these lines appears to be the same as in the GALL Report line IV.C 1-1 (where the material is stainless steel or steel). Please explain why SSES used note H for these lines when note H means that the aging effect is not in the GALL Report for the specified component, material and environment combination. Also, please justify that the AMP specified by Susquehanna Steam Electric Station (SSES) for these components provides satisfactory aging management, comparable to the AMPs recommended in the GALL Report line IV.C 1 - 1.

PPL Response:

GALL item IV.C 1-1 is appropriate for comparison in the AMR result lines in the LRA Table 3.1.2-3 for piping & fittings < 4 inch and for valve bodies < 4 inch, for which the material is carbon steel, the environment is "treated water (internal)," and the aging effect is cracking (due to thermal and mechanical loading).

The AMR results are consistent with GALL item IV.C 1-1 for the material (steel),

environment (reactor coolant) and aging effect (cracking). The LRA is revised to credit the Inservice Inspection (ISI) Program, in addition to the Small Bore Class 1 Piping Inspection, to manage cracking for the components. While GALL item IV.C 1-1 also credits Water Chemistry, it is not applicable here, since cracking due to stress corrosion is not an aging effect for steel components. Therefore, crediting ISI and Small Bore Class 1 Piping Inspection to manage cracking due to thermal and mechanical loading is considered to be consistent with the recommendations of GALL item IV.C 1-1. However, since PPL is crediting only two of the three programs that are listed in the GALL item, a note E, instead of A, is used for the comparison to GALL.

The LRA is amended to make the necessary changes to LRA Table 3.1.1, Item 3.1.1-48, and LRA Table 3.1.2-3. The change to LRA Table 3.1.1, Item 3.1.1-48 for this RAI is shown along with the changes necessary for RAI 3.1-6, as provided with the response to RAI 3.1-6, above.

Enclosure to PLA-6401 Page 11 of 49

> The text in LRA Table 3.1.2-3 (on LRA pages 3.1-79 and 3.1-88) is revised by addition (bold italics) and deletion (sike.hfe..gh).

Table 3.1.2-3 Aging Management Review Results - Reactor Coolant System Pressure Boundary Component /

Intended Aging Effect Aging Management NUREG-1801 Table 1 Commodity Function Material Environment Requiring Programs Volume 2 Item Item Notes Commodity Funcion Management Piping &

Inservice Inspection Fittings Pressure Treated Water (ISI) Program N/A N/A 4-,

Fitigorsunay Creotel (nernl Cracking

-t4-E

<4in.

Boundary Car(Internal)

Small Bore Class I IV.CI.1 3.1.1-48

< 4 in.

Piping Inspection Inservice Inspection Valve bodies Pressure Treated Water (ISI) Program N/A N-A Prsue Carbon Steel TetdWer Cracking 4-H-

< 4 in.

Boundary C

(Internal)

Small Bore Class 1 IV.CJ-1 3.1.1-48 Piping Inspection

Enclosure to PLA-6401 Page 12 of 49 RAI 3.1-8:

For multiple AMR results lines in the LRA Table 3.1.2-1, the recommended AMP is the BWR Water Chemistry Program, alone, and Note H is used indicating that for this component, material, environment combination, the aging effect is not included in the GALL Report. For these lines the material is low alloy steel with stainless steel cladding, the environment is "treated water (internal)," and the aging effect is "cracking - SSC (cladding)." Since the BWR Water Chemistry Program does not include an inspection activity to confirm effectiveness of the program to mitigate the aging effect, please provide technical justification for not including a confirmatory AMP, such as the Water Chemistry Effectiveness Inspection, for these components.

PPL Response:

Confirmation of the effectiveness of the BWR Water Chemistry Program to mitigate loss of material during the period of extended operation is needed. The SSES LRA Sections A. 1.2.11, A. 1.2.12, B.2.2, and B.2.22 state that the BWR Water Chemistry Program is supplemented by the Chemistry Program Effectiveness Inspection to provide verification of the effectiveness of the BWR Water Chemistry Program in mitigating the aging effects of loss of material and cracking.

The LRA Table 3.1.2-1 is revised to credit the Chemistry Program Effectiveness Inspection in addition to the BWR Water Chemistry Program for the AMR result lines addressing stainless steel cladding in treated water (external) with an aging effect of "cracking - SSC (cladding)."

The affected LRA Sections and Tables are revised, as detailed in the Attachment, to show the necessary changes.

RAI 3.2-1:

In the LRA Tables 3.2.2-2 and 3.2.2-4 there are AMR results for stainless steel tubing in a treated water environment and with an aging effect of cracking. The AMP specified in the LRA for these lines is the BWR Water Chemistry Program. The LRA does not provide an AMP to confirm effectiveness of the BWR Water Chemistry Program in preventing cracking in these components. Please provide a technical justification as to why confirmation of effectiveness of the BWR Water Chemistry Program is not needed for these components. Also, please justify the use of Note A.

Enclosure to PLA-6401 Page 13 of 49 PPL Response:

For the AMR results listed in LRA Tables 3.2.2-2 and 3.2.2-4 for stainless steel tubing in a treated water environment and with an aging effect of cracking, verification of the effectiveness of the BWR Water Chemistry Program is needed. The Chemistry Program Effectiveness Inspection provides confirmation of the effectiveness of the BWR Water Chemistry Program in managing the effects of aging, including cracking of susceptible materials. Also, as discussed below, the use of Note A is not appropriate.

These AMR results are compared to NUREG-1801, Volume 2, Item V.D2-29, for which the AMP is identified as Chapter XJ.M7, "BWR Stress Corrosion Cracking," and Chapter XI.M2, "Water Chemistry," for BWR water. As described in plant-specific note 0207, the BWR Stress Corrosion Cracking progrdim is applicable only to stainless steel piping

(> 4"), pump casings, valve bodies, and reactor vessel attachments containing reactor coolant at > 2000F. Therefore, the BWR Stress Corrosion Cracking program is not credited with managing cracking of stainless steel tubing exposed to treated water in the RCIC and HPCI systems. Instead, the BWR Water Chemistry Program and the Chemistry Program Effectiveness Inspection are credited, and Note E is used instead of Note A.

LRA Tables 3.2.1, 3.2.2-2, and 3.2.2-4, and the plant-specific note 0207 for the tables in LRA Section 3.2, are revised to reflect these results.

Enclosure to PLA-6401 Page 14 of 49 Table 3.2.1 Summary of Aging Management Programs for Engineered Safety Features Evaluated in Chapter V of the GALL Report

> The text in Table 3.2.1 for Item 3.2.1-18 (on LRA page 3.2-22) is revised by addition (bold italics) and deletion (si*ke fhifou

).

Item Component/Commodity Aging Effect/

Aging Management Further Discussion Number Mechanism Programs Evaluation Recommended 3.2.1-18 Stainless steel piping, piping Cracking due to BWR Stress Corrosion No Consistent with NUREG-1801.

components, and piping stress corrosion Cracking and Water The BWR Water Chemistry elements exposed to treated cracking and Chemistry Program in association with water >600C (>1400F) intergranular stress the Chemistry Program corrosion cracking Effectiveness Inspection is credited to manage cracking of stainless steel tubing in ESF systems. Only tubing in ESF systems was identified as meeting the >140°F criteria for cracking to occur. Note E is used.

The BWR Stress Corrosion Cracking Program is applicable only to stainless steel piping

(> 4"), pump casings, valve bodies, and reactor vessel attachments containing reactor coolant at > 2000F.

Enclosure to PLA-6401 Page 15 of 49 Table 3.2.2-2 Aging Management Review Results - Reactor Core Isolation Cooling System The text for the Table 3.2.2-2 line item for stainless steel tubing exposed to treated water (internal)

(on LRA page 3.2-58) is revised by addition (bold italics) and deletion (stfke 4wough).

Aging Effect Aging NUREG-1801 Component Intended Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item BWR Water Chemistry Pressure Stainless Treated Water Program

-A-E, Tubing Boundary Steel (Internal)

Cracking Chemistry V.D229 3.2.1-18 0207 Program Effectiveness Inspection Table 3.2.2-4 Aging Management Review Results - High Pressure Coolant Injection System The text for the Table 3.2.2-4 line item for stainless steel tubing exposed to treated water (internal)

(on LRA page 3.2-75) is revised by addition (bold italics) and deletion (Stfike-flOU g).

Component Intended Aging Effect Aging NUREG-1801 Commodity Function Material Environment Requiring Management Volume 2 Table 1 Item Notes Management Programs Item BWR Water Chemistry Pressure Stainless Treated Water Program-A-E, Tubing Boundary Steel (Internal)

Cracking Chemistry V.D229 3.2.1-18 0207 Program Effectiveness Inspection

Enclosure to PLA-6401 Page 16 of 49 Plant-Specific Notes for Tables 3.2.2-x The text for the plant-specific note 0207 (on LRA page 3.2-105) is revised by addition (bold italics) and deletion (strike. i-oeuigh).

0207 Applies only to stainless steel tubing in the steam supply to RCIC/HPCI pump turbine up to the steam admission valves that are maintained at > 140'F. The BWR Water Chemistry Program in association with the Chemistry Program Effectiveness Inspection manages the aging effect of stress corrosion cracking. all applicable aging eff,,ts; -4he Since the BWR Stress Corrosion Cracking program is applicable only to stainless steel piping (- 4"), pump casings, valve bodies, and reactor vessel attachments containing reactor coolant at > 2000F, it is not credited here, and Note E is used.

Enclosure to PLA-6401 Page 17 of 49 RAI 3.2-2:

In the LRA Tables 3.2.2-1, 3.2.2-2, 3.2.2-3 and 3.2.2-4, there are multiple AMR result lines that reference to the LRA Table 1 items 3.2.1-27, 3.2.1-28 or 3.2.1-29. For all of these lines, the aging effect is loss of material. For all of these lines the GALL Report recommends using AMP XI.M21 Closed-Cycle Cooling Water System for aging management of the applicable component, material, environment and aging effect combinations. The GALL Report AMP XI.M21 includes both preventive measures to mitigate the aging process and component inspections and functional testing to confirm the effectiveness of the preventive measures. The LRA states that aging management will be accomplished using the BWR Water Chemistry Program, which provides measures to prevent or mitigate aging effects, but no component inspections to detect aging effects. Please justify why an inspection is not performed to verify the effectiveness of the water chemistry program and confirm that loss of material is not occurring in these components.

PPL Response:

For the AMR results listed in LRA Tables 3.2.2-1, 3.2.2-2, 3.2.2-3 and 3.2.2-4 that reference the LRA Table 1 items 3.2.1-27, 3.2.1-28 or 3.2.1-29, verification of the effectiveness of the BWR Water Chemistry Program is needed. The Chemistry Program Effectiveness Inspection will provide confirmation of the effectiveness of the BWR Water Chemistry Program in managing the effects of aging, including loss of material.

LRA Tables 3.2.1, 3.2.2-1, 3.2.2-2, 3.2.2-3, and 3.2.2-4 are revised to reflect these results.

Enclosure to PLA-6401 Page 18 of 49 Table 3.2.1 Summary of Aging Management Programs for Engineered Safety Features Evaluated in Chapter V of the GALL Report The text of Table 3.2.1 (on LRA page 3.2-24) is revised by addition (bold italics).

Item Component/Commodity Aging Effect/

Aging Management Further Discussion Number Mechanism Programs Evaluation Recommended 3.2.1-27 Steel heat exchanger Loss of material due Closed-Cycle Cooling No The BWR Water Chemistry components exposed to closed to general, pitting, Water System Program in association with cycle cooling water crevice, and the Chemistry Program galvanic corrosion Effectiveness Inspection is credited to manage the loss of material for steel heat exchanger components that are exposed to treated water. Note E is used.

3.2.1-28 Stainless steel piping, piping Loss of material due Closed-Cycle Cooling No The BWR Water Chemistry components, piping elements, to pitting and crevice Water System Program in association with and heat exchanger components corrosion the Chemistry Program exposed to closed-cycle cooling Effectiveness Inspection is water credited to manage the loss of material for stainless steel piping, piping components, and heat exchanger components that are exposed to treated water. Note E is used.

3.2.1-29 Copper alloy piping, piping Loss of material due Closed-Cycle Cooling No The BWR Water Chemistry components, piping elements, to pitting, crevice, Water System Program in association with and heat exchanger components and galvanic the Chemistry Program exposed to closed cycle cooling corrosion Effectiveness Inspection is water credited to manage the loss of material for copper alloy piping, piping components, and heat exchanger components that are exposed to treated water. Note E is used.

Enclosure to PLA-6401 Page 19 of 49 Table 3.2.2-1 Aging Management Review Results - Residual Heat Removal System The text for Table 3.2.2-1 (on LRA pages 3.2-33, 34, and 43) is revised by addition (bold italics).

Component Intended Aging Effect Aging NUREG-1801 Commodity Function Material Environment Requiring Management Volume 2 Table I Item Notes Management Programs Item BWR Water Heat Chemistry Exchnger Caron SeelProgram Exchangers Pressure Treated Water Loss of E,

(1/2E205A/B),

Boundary Carbon Steel (Internal)

Material Chemistry V.D2-7 3.2.1-27 0201 Shells and Program Shell Covers Effectiveness Inspection BWR Water Chemistry Heat Program Exchangers Pressure Carbon Steel Treated Water Loss of V.D2-7 3.2.1-27 E,

(1/2E205A/B),

Boundary (External)

Material 0201 Tubesheets Program Effectiveness Inspection BWR Water Chemistry Heat Pressure Copper Alloy Program Exchangers

Boundary, (Copper-(External)

Material Chemistry V.D2-3 3.2.1-29 E

(1T/2E205AB),

Heat Transfer Nickel)

Program Tubes Effectiveness Inspection BWR Water Chemistry Piping and Structural Treated Water Loss of

ProgramE, Piping Integrity CopperAlloy (Internal)

Material Chemistry V.D2-21 3.2.1-29 0211 Components Program Effectiveness Inspection

Enclosure to PLA-6401 Page 20 of 49 Table 3.2.2-2Aging Management Review Results - Reactor Core Isolation Cooling System

)

The text for Table 3.2.2-2 (on LRA pages 3.2-53 through 56) is revised by addition (bold italics).

Component /

Intended Aging Effect Aging NUREG-1801 Commodity Function Material Environment Requiring Management Volume 2 Table 1 Item Notes Management Programs Item BWR Water RCIC Turbine Chemistry Lube Oil Pressure Copper Alloy Treated Water Loss of Program Cooler

Boundary, (Admiralty (Internal)

Material Chemistry V.D2-3 3.2.1-29 E

(1 E212),

Heat Transfer Brass)

Program Tubes Effectiveness Inspection BWR Water RCIC Turbine Chemistry Lube Oil Pressure Stainless Treated Water Loss of Program Cooler

Boundary, Steel (Internal)

Material Chemistry V.D2-5 3.2.1-28 E

(2E212),

Heat Transfer Program Tubes Effectiveness Inspection BWR Water RCIC Turbine Chemistry Lube Oil Pressure Copper Alloy Treated Water Loss of Program (1E212),

Boundary (Bronze)

(Internal)

Material Chemistry V.D2-3 3.2.1-29 E

(11 E12),Program Tubesheet Effectiveness Inspection BWR Water RCIC Turbine Chemistry Lube Oil Pressure Stainless Treated Water Loss of Program Cooler Ceity VD-3.128E (2E212),

Boundary Steel (Internal)

Material Chemistry V.D25 3.2.1-28 Tubesheet Effectiveness Inspection

Enclosure to PLA-6401 Page 21 of 49 Component Intended

• Aging Effect Aging NUREG-1801 Commodity Function Material Environment Requiring Management Volume 2 Table 1 Item Notes C i nManagement Programs Item BWR Water RCIC Turbine Chemistry Lube Oil Pressure Copper Alloy Treated Water Loss of Program (1E212),

Boundary (Bronze)

(Internal)

Material Chemistry V.D2-3 3.2.1-29 E

(1 E12),Program Channel Effectiveness Inspection BWR Water RCIC Turbine Chemistry Lube Oil Pressure Stainless Treated Water Loss of Program Cooler Ceity VD-3.128E (2E212),

Boundary Steel (Internal)

Material Chemistry V.D2-5 3.2.1-28 (2E12)

Program Channel Effectiveness Inspection Table 3.2.2-3 Aging Management Review Results - Core Spray System The text for Table 3.2.2-3 (on LRA page 3.2-68) is revised by addition (bold italics).

Component /

Intended Aging Effect Aging NUREG-1801 Commodity /

Function Material Environment Requiring Management Volume 2 Table 1 Item Notes CFManagement Programs Item BWR Water Chemistry Piping and Structural Treated Water Loss of Program E,

Piping Integrity Copper Alloy (Internal)

Material Chemistry V.D2-21 3.2.1-29 0211 Components Program Effectiveness Inspection

Enclosure to PLA-6401 Page 22 of 49 Table 3.2.2-4 Aging Management Review Results - High Pressure Coolant Injection System The text for Table 3.2.2-4 (on LRA pages 3.2-79 and 80) is revised by addition (bold italics).

Component Intended Aging Effect Aging NUREG-1801 Commodity Function Material Environment Requiring Management Volume 2 Table 1 Item Notes Management Programs Item BWR Water Chemistry Coolers, Lube Pressure Copper Alloy Treated Water Loss of Program (1/2E213),

Boundary, (Admiralty (Internal)

Material Chemistry V.D2-3 3.2.1-29 E

Tubes Heat Transfer Brass)

Program Effectiveness Inspection BWR Water Coolers, Lube Chemistry Oil Cooler Pressure Copper Alloy Treated Water Loss of Program (1/2E213),

Boundary (Bronze)

(Internal)

Material Chemistry V.D2-3 3.2.1-29 Tubesheets Program Effectiveness Inspection BWR Water Chemistry Coolers, Lube Program Oil Cooler Pressure Copper Alloy Treated Water Loss of Program (1/2E213),

Boundary (Bronze)

.(Internal)

Material Chemistry V.D23 3.2.1-29 Channels Program Effectiveness Inspection

Enclosure to PLA-6401 Page 23 of 49 RAI 3.2-3:

For five AMR results lines in LRA Tables 3.2.2-1, 3.2.2-3, 3.3.2-25, and 3.4.2-3, where the material is copper alloy, the environment is treated water (internal) and the aging effect is cracking, the AMP specified in the LRA is the BWR Water Chemistry Program.

Please provide a technical justification as to why an inspection program such as the Chemistry Program Effectiveness Inspection is not needed to confirm that the BWR Water Chemistry Program is effective in preventing the aging effect of cracking in the listed components. Also for the components in the Condensate Transfer and Storage System, please provide additional clarification as to why Note G, rather than Note H, is appropriate for this AMR result.

PPL Response:

For the five AMR results lines listed in LRA Tables 3.2.2-1, 3.2.2-3, 3.3.2-3, 3.3.2-25, and 3.4.2-3, where the material is copper alloy, the environment is treated water (internal), and the aging effect is cracking, verification of the effectiveness of the BWR Water Chemistry Program is needed. The Chemistry Program Effectiveness Inspection will provide confirmation of the effectiveness of this program in managing the effects of aging, including cracking of susceptible materials.

Additionally, because the five AMR results lines are all for the same component, material, environment, and aging effect, the Note G used for the AMR result reported for the Condensate Transfer and Storage System in Table 3.4.2-3 is changed to Note H to be consistent with the other results.

LRA Tables 3.2.2-1, 3.2.2-3, 3.3.2-3, 3.3.2-25, and 3.4.2-3 are revised to reflect these results.

Enclosure to PLA-6401 Page 24 of 49 Table 3.2.2-1 Aging Management Review Results - Residual Heat Removal System The text for Table 3.2.2-1 (on LRA page 3.2-43) is revised by addition (bold italics).

Component Intended Aging Effect Aging NUREG-1801 Commonnty /Fnctind Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item BWR Water Chemistry Piping and Structural Treated Water

ProgramH, Piping Integrity Copper Alloy (internal)

Cracking Chemistry N/A N/A 0216 Components Program Effectiveness Inspection Table 3.2.2-3 Aging Management Review Results - Core Spray System The text for Table 3.2.2-3 (on LRA page 3.2-68) is revised by addition (bold italics).

Component Intended Aging Effect Aging NUREG-1801 Commonnty Functind Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item BWR Water Chemistry Piping and Structural Treated Water Program H,

Piping Copper Alloy Cracking Chemistry N/A N/A 0216 Components Integrity (Internal)

Program Effectiveness Inspection

Enclosure to PLA-6401 Page 25 of 49 Table 3.3.2-3 Aging Management Review Results - Control Rod Drive Hydraulics System The text for Table 3.3.2-3 (on LRA page 3.3-109) is revised by addition (bold italics).

SI Aging Effect Aging NUREG-1801 Component Funten Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item BWR Water Chemistry Piping and Structural Treated Water H,

Piping Integrity Copper Alloy (Internal)

Cracking Chemistry N/A N/A 0347 Components Program Effectiveness Inspection Table 3.3.2-25 Aging Management Review Results - Reactor Water Cleanup System

)

The text for Table 3.3.2-25 (on LRA page 3.3-317) is revised by addition (bold italics).

Component Intended T

Effect Aging NUREG-1801 Commodity Function Material Environment Requiring Management Volume 2 Table 1 Item Notes C

IManagement Programs Item BWR Water Chemistry Piping and Structural Treated Water Program H,

Piping Integrity Copper Alloy (Internal)

Cracking Chemistry N/A N/A 0347 Components Program Effectiveness Inspection

Enclosure to PLA-6401 Page 26 of 49 Table 3.4.2-3 Aging Management Review Results - Condensate Transfer and Storage System The text for Table 3.4.2-3 (on LRA page 3.4-46) is revised by addition (bold italics) and by deletion (sike -fough).

Component Intended Aging Effect Aging NUREG-1801 Commodity Function Material Environment Requiring Management Volume 2 Table 1 Item Notes Management Programs Item BWR Water Chemistry Piping and Structural Treated Water Program-G-H, Piping Copper Alloy Cracking Chemistry N/A N/A 0414 Components Integrity (Internal)

Program Effectiveness Inspection

Enclosure to PLA-6401 Page 27 of 49 RAI 3.3-1:

On page 3.5-83 of the LRA, there is an AMR result line for Spent Fuel Rack Neutron Absorbers where the material is Boral. For this component the environment is exposed to treated water, the aging effect is loss of material, and the AMP specified in the LRA is the BWR Water Chemistry Program. The GALL Report states that a plant specific AMP is to be evaluated for this combination of component, material, environment and aging effect. Section 3.3.3.2.6 of the Standard Review Plan for License Renewal (SRP-LR) requires that an adequate program will be in place to manage the reduction of neutron absorbing capability and loss of material due to general corrosion of the neutron-absorbing sheets in spent fuel storage racks. Section 3.3.2.2.6 of the LRA states that Boral does not degrade as a result of long-term exposure to radiation, and that based on plant-specific operating experience and testing results of Boral sample coupons, reduction of neutron-absorbing capability and loss of material due to general corrosion are not aging effects requiring management for the SSES spent fuel rack neutron absorbers. Please provide a technical justification as to why an inspection program such as the Chemistry Program Effectiveness Inspection is not needed to confirm that age-related degradation of the component is not occurring. If the technical justification is based on the result of a sample coupon test, then please provide addition details of the testing. Include the range of water chemistry conditions used in the test and whether the test duration was adequate to ensure that the aging effects progression is very slowly or if testing requiring a long incubation period would have manifest results more indicative of the period of extended operation.

PPL Response:

The technical justification of the Boral neutron-absorbing capability aging assessment is based on plant-specific and industry operating experience. Loss of material of aluminum in treated water due to general corrosion is not an aging effect requiring management consistent with GALL (e.g., VII.A4-5), but loss of material due to crevice and pitting corrosion is an aging effect requiring management and is managed by the BWR Water Chemistry Program as indicated in LRA Section 3.3.2.2.6 and Table 3.5.2-2.

Industry Experience:

Potential aging effects resulting from sustained irradiation of Boral have been previously evaluated by the staff in NUREG-1787, Safety Evaluation Report Related to the License Renewal of the Virgil C. Summer Nuclear Station. NUREG-1787 states on page 3-406 the applicant asserts that Boral does not degrade as a result of long-term exposure to radiation, and there are no aging effects applicable to Boral neutron-absorbing sheets in the spent fuel storage racks of VCSNS. The potential aging effects resulting from sustained irradiation of Boral were previously evaluated by the staff (BNLNUREG-25582, dated January 1979) and determined to be insignificant. Therefore, the staff finds the applicant's AMR conclusions to be acceptable."

Enclosure to PLA-6401 Page 28 of 49 A search of industry experience (INPO EPIX database) revealed the same conclusion that no instances of reduction of Boral neutron-absorbing capability have been experienced by other nuclear plants.

SSES plant-specific operating experience:

Half of the SSES Boral sample coupons are non-vented, simulating the expected condition at the racks. These have not shown any blistering, pitting corrosion or loss of neutron-absorbing capability. The other half of the SSES Boral coupons are vented, simulating a portion of the fuel rack having a bad weld, allowing water into the area with the Boral plates. These vented samples have shown blistering near the edges of the plate due to the porous nature of the cut edge of the plate, where water interacts with the Boron matrix and radiation to generate gases that blister the plate. This effect has, in some cases, caused the outer metal layer of the Boral plate (sample) to blister out and press flat against the outer tube that contains it. This contact in a demineralized water environment has shown no signs of galvanic or other corrosion. Neutron attenuation testing has shown that these plates still retain the required design properties for neutron attenuation.

Weighing of the samples has shown no loss of material, although some minor gains in weight (post drying) may be related to the water intrusion / interaction with decay products.

The most recent Boral coupon tests (year 20 coupon test) for Units 1 and 2 were performed by independent testing facilities in 2003 and 2005 respectively. The range of water chemistry conditions which the Boral coupons were subjected to are within the fuel pool chemistry specification limits as delineated in the Susquehanna Chemistry Manual.

The chemistry specifications are as follows:

SSES Fuel Pool Chemistry Specifications Name Units Parameter Value' Conductivity Microsiemens per centimeter

<1.2 (gtS/cm)

Anions by Ion Chromatography Parts-per-billion (ppb)

<5 (IC), Chloride, Sulfate Total Organic Carbon (TOC)

Parts-per-billion (ppb)

<50 Silica Parts-per-billion (ppb)

<40 Turbidity Nephelometric Turbidity Units

<0.2 (NTU) 1 - Expected values for chemistry parameters. Ninety percent of the SSES data for these parameters fell within these values during the period January 1991 through May 1996.

Enclosure to PLA-6401 Page 29 of 49 Two Boral coupon capsules, one vented to the pool water and one sealed, are shipped from the spent fuel pool of the Susquehanna Station to Northeast Technology Corp's (NETCO) laboratory. Four coupons each are housed in two square, four-sided capsules.

The four-sided capsules replicated a short section of a fuel rack storage cell.

After the capsules are opened, the coupons in the vented capsule are rinsed in deionized water to remove transferable radioactive contamination. The following tests are then performed:

• Visual examination and high resolution photography -

Inspect each coupon and note any anomalies such as corrosion films or pitting, blisters, discolorations. Record depth, extent and location of anomalies.

" Dry coupon weight -

Weigh coupon and record dry weight.

" Drying and subsequent weighing -

Dry coupon until no further weight loss is observed.

" Thickness measurement at 5 locations on each coupon -

Check calibration of measuring instrument with certified gage blocks. Measure the coupon thickness.

" Neutron attenuation testing for B-10 areal density (5 locations) -

Expose Boral sample to neutron beam and generate sample's areal density results.

The acceptance criteria of Boral neutron attenuation from the FSAR is Keff of <0.95 which corresponds to a B-10 areal density of 0.0233 g/cm 2. The table below lists the historical test results of the SSES spent fuel pool Boral average B-10 areal density.

SSES Spent Fuel Pool Boral Average B-10 Areal Density Results' Unit 1 / Date Unit 2 / Date 0.0251 g/cm2 /Jul 1985 0.0285 g/cm2 / Jul 1988 0.0252 g/cm 2 / Aug 1988 0.0247 g/cm2 / Feb 1991 0.0265 g/cm 2 / Nov 1993 0.0258 g/cm 2 / Jul 1995 0.0289 g/cm 2 / Jun 1999 0.0260 g/cm 2 / Nov 2000 0.0256 g/cm2 / Dec 2004 0.0257 g/cm2 / Nov 2005 Projected at next test date -

Projected at next test date -

0.0254 g/cm2 /2013 0.0263 g/cm2 /2015 1 - Acceptance criteria of B 10 Areal Density is >0.0233 g/cm 2

Enclosure to PLA-6401 Page 30 of 49 The B-10 neutron attenuation test results for the past 20 years at SSES were within acceptance limits and did not show an adverse trend. This indicates that the aging progression of neutron-absorbing capability is not significant. Boral sample coupons are removed from the fuel pool periodically for testing and are evaluated for corrosion or other degradation of the neutron absorber by comparing various physical characteristics of the test coupons to baseline measurements taken when the coupons were installed.

Additional Boral coupons are scheduled to be removed from the spent fuel storage pool and analyzed at years 30 and 40 under a current licensing commitment per FSAR Section 9.1.2.3.3. The scheduled Boral sample coupon testing is a verification of effectiveness of the credited BWR Water Chemistry Program. Identification of any adverse conditions on the Boral sample coupons, including blistering, pitting corrosion or neutron-absorbing capability, is entered into the Corrective Action Program for further evaluation.

As indicated in LRA Section 3.3.2.2.6 and Table 3.5.2-2, although Boral does not require aging management for the period of extended operation for its neutron-absorbing function, aging management for loss of material of its aluminum constituent is required.

Loss of material due to crevice and pitting can affect the aluminum constituent in Boral; the BWR Water Chemistry Program is credited for aging management. Based on SSES plant-specific experience of Boral coupon inspections and testing (i.e., no signs of blistering, pitting corrosion in the non-vented Boral coupons, or loss of neutron-absorbing capability), the loss of material aging effect has been and will continue to be adequately managed by the BWR Water Chemistry Program.

RAI 3.3-2:

Page 3.3-103 of the LRA includes an AMR result for accumulator (pistons) made of aluminum in a treated water environment with an aging effect of cracking. The AMP identified in the LRA is the BWR Water Chemistry Program, which provides an aging mitigation (preventive) function, and Note H is used indicating that for this component, material, environment combination, the aging effect is not included in the GALL Report.

The AMR line item in the LRA refers to the GALL Report item VII.E3-7, which has the same material and environment, but has the aging effect of loss of material due to pitting and crevice corrosion. The LRA reference to GALL item VII.E.3-7 appears to be inconsistent with use of Note H, and the LRA does not identify an AMP to confirm effectiveness of the BWR Water Chemistry Program in mitigating this aging effect of cracking in this component. Please reconcile or justify the apparent inconsistency between reference to a specific GALL Report item and the use of Note H. Also, please provide technical justification for not including a confirmatory AMP, such as the Water Chemistry Effectiveness Inspection, for managing the aging effect of cracking in these components.

Enclosure to PLA-6401 Page 31 of 49 PPL Response:

For the AMR results item listed on page 3.3-103 of the LRA for accumulator (pistons) made of aluminum in a treated water environment with an aging effect of cracking, Note H is the appropriate generic note because the aging effect, cracking, is not in NUREG-1801 Volume 2 for aluminum exposed to treated water. However, because GALL Report item VII.E3-7 is for loss of material, the NUREG-1801 Volume 2 Item and the Table 1 Item for this line item should have been identified in the LRA as "N/A".

For this AMR results item, verification of the effectiveness of the BWR Water Chemistry Program is needed to confirm that cracking is not occurring in these components.

The Chemistry Program Effectiveness Inspection will detect and characterize the condition of materials managed by the BWR Water Chemistry Program. Implementation of the Chemistry Program Effectiveness Inspection will provide confirmation of the effectiveness of this program in managing the effects of aging, including cracking of susceptible materials.

The affected LRA Tables are revised as follows:

Enclosure to PLA-6401 Page 32 of 49 Table 3.3.2-3 Aging Management Review Results - Control Rod Drive Hydraulics System The following line item (on LRA page 3.3-103) is revised by addition (bold italics) and deletion (stfike -flusgh).

Component Intended Aging Effect Aging NUREG-1801 Commodnty Funteond Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item BWR Water Chemistry Accumulators Pressure Treated Water Program (piston)

Boundary (Internal)

Chemistry.

Program Effectiveness Inspection

Enclosure to PLA-6401 Page 33 of 49 Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL Report

)

The following line items (on LRA page 3.3-63) are revised by deletion (s)tfike.hfe*gh).

3.3.1-24 Stainless steel and aluminum piping, piping components, and piping elements exposed to treated water Loss of material due to pitting and crevice corrosion Water Chemistry and One-Time Inspection Yes, detection of aging effects is to be evaluated Consistent with NUREG-1801.

The BWR Water Chemistry Program and the Chemistry Program Effectiveness Inspection are credited to manage loss 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).

Tho BWR W\\Alater 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.

Further evaluation is documented in Section 3.3.2.2.10.2.

Enclosure to PLA-6401 Page 34 of 49 RAI 3.3-3:

Multiple AMR result lines in the LRA Section 3.3 refer to the GALL Report item VII.E3-16, where the AMP recommended in the GALL Report is XI.M25, BWR Reactor Water Cleanup System. In Table B-1, the LRA states that SSES does not credit a BWR Reactor Water Cleanup System program for aging management. In lieu of the BWR Reactor Water Cleanup System program, SSES proposes to use the BWR Water Chemistry Program for aging management of these components. The GALL Report's AMP BWR Reactor Water Cleanup System, is both a preventive and a monitoring program.

However, the BWR Water Chemistry program is only a preventive program. Since SSES is crediting the water chemistry program, please justify why an inspection is not performed to verify the effectiveness of the water chemistry program and confirm that cracking is not occurring in these components.

PPL Response:

For the AMR results identified in LRA Section 3.3 (Tables 3.3.2-3, 3.3.2-24, 3.3.2-25, 3.3.2-27, and 3.3.2-34) that refer to GALL Report item VII.E3-16, verification of the effectiveness of the BWR Water Chemistry Program is needed to confirm that cracking is not occurring in these components.

The Chemistry Program Effectiveness Inspection will detect and characterize the condition of materials managed by the BWR Water Chemistry Program. Implementation of the Chemistry Program Effectiveness Inspection will provide confirmation of the effectiveness of this program in managing the effects of aging, including cracking of susceptible materials.

The affected LRA Tables are revised to explicitly credit the Chemistry Program Effectiveness Inspection in conjunction with the BWR Water Chemistry Program as follows:

Enclosure to PLA-6401 Page 35 of 49 Table 3.3.2-3Aging Management Review Results - Control Rod Drive Hydraulics System The following line items (on LRA pages 3.3-102, 104, 106, and 108) are revised by addition (bold italics).

Component /

Intended Aging Effect Aging NUREG-1801 Commodity Function Material Environment Requiring Management Volume 2 Table 1 Item Notes C m t u iManagement Programs Item BWR Water Chemistry Accumulators Pressure Stainless Treated Water Program (cylinder, end Steel (Internal)

Cracking Chemistry VII.E3-16 3.3.1.37 E

caps)

BProgram Effectiveness Inspection BWR Water Chemistry Pressure Stainless Treated Water Program Filters

Boundary, Steel (Internal)

Cracking Chemistry VII.E3-16 3.3.1-37 E

Filtration Program Effectiveness Inspection BWR Water Chemistry Pressure Stainless Treated Water Program Piping Boundary Steel (Internal)

Cracking Chemistry VII.E316 3.3.1-37 E

Program Effectiveness Inspection BWR Water Chemistry Pressure Stainless Treated Water Program Valve Bodies Boundary Steel (internal)

Cracking Chemistry VII.E3-16 3.3.1-37 E

Program Effectiveness Inspection

Enclosure to PLA-6401 Page 36 of 49 Table 3.3.2-24 Aging Management Review Results - Reactor Nonnuclear Instrumentation System The following line items (on LRA pages 3.3-308 and 309) are revised by addition (bold italics).

Component Intended Aging Effect Aging NUREG-1801 Commodity Funten Material Environment Requiring Management Volume 2 Table 1 Item Notes Management Programs Item BWR Water Chemistry Pressure Stainless Treated Water Program Piping Boundary Steel (Internal)

Cracking Chemistry VII.E316 3.3.1-37 E

Program Effectiveness Inspection BWR Water Chemistry Pressure Stainless Treated Water Program Tubing Boundary Steel (Internal)

Cracking Chemistry VII.E316 3.3.1-37 Program Effectiveness Inspection BWR Water Chemistry Program Pressure Stainless Treated Water ValveBoundary Steel (Internal)

Cracking Chemistry VII.E3-16 3.3.1-37 E

Program Effectiveness Inspection

Enclosure to PLA-6401 Page 37 of 49 Table 3.3.2-25 Aging Management Review Results - Reactor Water Cleanup System The following line items (on LRA pages 3.3-310, 312, and 318) are revised by addition (bold italics).

Component /

Intended Aging Effect Aging NUREG-1801 Commonnty Functind Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item BWR Water Chemistry Pressure Stainless Treated Water Program Orifices

Boundary, Steel (Internal)

Cracking Chemistry VII.E3-16 3.3.1-37 E

Throttling Program Effectiveness Inspection BWR Water Chemistry Pressure Stainless Treated Water Program Tubing Boundary Steel (Internal)

Cracking Chemistry VII.E3-16 3.3.1-37 E

Program Effectiveness Inspection BWR Water Chemistry Piping and Structural Stainless Treated Water Program E,

Piping Integrity Steel (Internal)

Cracking Chemistry VII.E3-16 3.3.1-37 0357 Components Program Effectiveness Inspection

Enclosure to PLA-6401 Page 38 of 49 Table 3.3.2-27 Aging Management Review Results - Sampling System The following line items (on LRA page 3.3-333) are revised by addition (bold italics).

Aging Effect Aging NUREG-1801 Component y Intended Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item BWR Water Chemistry Piping and Structural Stainless Treated Water

ProgramE, Piping Integrity Steel (internal)

Cracking Chemistry VII.E3-16 3.3.1-37 0357 Components Program Effectiveness Inspection

Enclosure to PLA-6401 Page 39 of 49 Table 3.3.2-34 Aging Management Review Results - Reactor Vessel and Auxiliaries System (NSAS Portions)

The following line items (on LRA page 3.3-345) are revised by addition (bold italics).

Component Intended Aging Effect Aging NUREG-1801 Commodity /Fnctind Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item BWR Water Chemistry Piping and Structural Stainless Treated Water Program E,

Piping Cracking Chemistry VII.E3-16 3.3.1-37 0357 Components Integrity Steel (Internal) rgam Program Effectiveness Inspection

Enclosure to PLA-6401 Page 40 of 49 Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL Report

>" The following line items (on LRA page 3.3-72) are revised by addition (bold italics).

Item Component/Commodity Aging Effect/

Aging Management Further Discussion Number Mechanism Programs Evaluation Recommended 3.3.1-37 Stainless steel piping, piping Cracking due to BWR Reactor Water No The BWR Water Chemistry components, and piping stress corrosion Cleanup System Program in conjunction with elements exposed to treated

cracking, the Chemistry Program water >60 0C (>1400F) intergranular stress Effectiveness Inspection is corrosion cracking credited to manage cracking for stainless steel components of the Reactor Water Cleanup System, such as tubing and orifices, that are exposed to treated water at elevated temperatures (i.e.,

above 1400F). This item is also applied for cracking of stainless steel components in the Control Rod Drive Hydraulics, Reactor Vessel and Auxiliaries, Sampling, and Reactor Nonnuclear Instrumentation systems that are exposed to treated water at elevated temperatures. Note E is used.

The stainless steel components in these systems are less than 4" diameter, whereas GL 88-01 (and thereby the sited NUREG-1801 program) is focused on stainless steel components 4" diameter or larger.

Enclosure to PLA-6401 Page 41 of 49 RAI 3.3-4:

In the LRA Table 3.3.2-13 there are three AMR result lines where the aging effect is cracking, the AMP is designated as the Fuel Oil Chemistry Program, and Note B is used.

Note B means that the AMR result is consistent with the GALL Report for component, material, environment, and aging effect, but the AMP takes some exceptions to the GALL Report. However, in the GALL Report the AMPs recommended for this-component, material, environment and aging effect combination is XI.M26 Fire Protection Program and the Fuel Oil Chemistry Program. Please justify use of Note B for these AMR result lines. Also, please explain how effectiveness of the Fuel Oil Chemistry Program is confirmed for these components and clarify whether piping and/or tubing associated with this material and environment combination is included in the AMR results in the LRA.

PPL Response:

There are no line items in the LRA for Susquehanna that credit the Fuel Oil Chemistry Program for managing cracking and use a Note B.

Fire Protection and Fuel Oil Chemistry are recommended in combination for GALL item VII.G-21 which is for steel piping and piping components in fuel oil and subject to loss of material. The SSES LRA uses GALL item VII.G-21 in only one instance for the diesel oil day tank (0T508) in Table 3.3.2-13. Notes B and 0321 are used. In this case the use of Note B is inappropriate and Note E should be used. Plant-specific Note 0321 indicates that the Fire Protection Program is not required for aging management, but provides opportunities for detection of degradation during periodic activities. Plant-specific Note 0321 is only used in this one instance in the LRA.

As submitted under PLA-6296 (Reference 5), LRA Table 3.3.2-13 was modified to include additional component types as subject to aging management review. Two of those component types were compared to GALL item VII.G-21, filter bodies and valve bodies formed of carbon steel and subject to an internal fuel oil environment. The credited aging management program was the Fuel Oil Chemistry Program. Notes B and 0321 were applied in both cases.

In order to verify the effectiveness of the Fuel Oil Chemistry Program, the Chemistry Program Effectiveness Inspection is also be credited for the day tank, filter bodies, and valve bodies line items.

The Chemistry Program Effectiveness Inspection will detect and characterize the condition of materials managed by the Fuel Oil Chemistry Program. Implementation of the Chemistry Program Effectiveness Inspection will provide confirmation of the effectiveness of this program in managing the effects of aging, including loss of material for susceptible materials.

Enclosure to PLA-6401 Page 42 of 49 The material and environment combination for the diesel oil day tank (0T508), the filter body, and the valve bodies is carbon steel and fuel oil. There is no piping identified for the fuel oil environment in LRA Table 3.3.2-13, including the changes made under PLA-6296. The tubing subject to the fuel oil environment in Table 3.3.2-13 is copper, and a combination of the Fuel Oil Chemistry Program and the Chemistry Program Effectiveness Inspection is credited for aging management. The tubing is used for the fuel supply line between the diesel oil day tank and diesel engine.

The affected LRA Section and Tables are revised as follows:

Enclosure to PLA-6401 Page 43 of 49 Table 3.3.2-13 Aging Management Review Results - Fire Protection System The following line items (on LRA page 3.3-243) are revised by addition (bold italics) and deletion (st-ike hf gh).

Component Intended Aging Effect Aging NUREG-1801 Commodity /

Function Material Environment Requiring Management Volume 2 Table 1 Item Notes C

I.Management Programs Item Fuel Oil Chemistry Tank, Diesel Pressure Fuel Oil Loss of Program

-B-E, Oil Day Tank Boundary Carbon Steel (Internal)

Material Chemistry VII.G-21 3.3.1-64 0321 (0T508)

Program Effectiveness Inspection The following line items, added to LRA Table 3.3.2-13 under PLA-6296, are revised by addition (bold italics) and deletion (tri.ke

.... g)

Component Intended Aging Effect Aging NUREG-1801 Commodity Function Material Environment Requiring Management Volume 2 Table 1 Item Notes CFManagement Programs Item Fuel Oil Chemistry Pressure Carbon Steel Fuel Oil Loss of Program

-B-E, Filter BodyiesBoundary (Internal)

Material Chemistry VII.G21 3.3.1-64 0321 Program Effectiveness Inspection Fuel Oil Chemistry Pressure Carbon Steel Fuel Oil Loss of Program

-B-E, Valve Bodies Boundary (Internal)

Material Chemistry VIIG21 3.3.1-64 0321 Program Effectiveness Inspection

Enclosure to PLA-6401 Page 44 of 49 Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL Report The following line item (on LRA page 3.3-83) is revised by addition (bold italics).

Item Component/Commodity Aging Effect I Aging Management Further Discussion Number Mechanism Programs Evaluation Recommended 3.3.1-64 Steel piping, piping Loss of material Fire Protection and No The Fuel Oil Chemistry Program components, and piping due to general, Fuel Oil Chemistry in conjunction with the elements exposed to fuel oil pitting, and crevice Chemistry Program corrosion Effectiveness Inspection is credited to manage loss of material for steel fuel oil day tank and piping components that is are exposed to fuel oil.

Though not credited, the Fire Protection Program provides indirect confirmation of whether degradation of these components has occurred, and that the component intended function is maintained.

Enclosure to PLA-6401 Page 45 of 49 LRA Section B.2.22 Chemistry Program Effectiveness Inspection

> The following text under the Scope of Program element (on LRA page B-69) is revised by addition (bold italics).

Fuel Oil - Fire Protection (diesel engine-driven fire pump fuel oil tank and piping components supply) and Diesel Fuel Oil systems RAI 3.3-5:

In the LRA Table 3.3.2-7 there are seven AMR results lines where the aging effect is cracking, the AMP is designated as the Fuel Oil Chemistry Program, and note H is used.

Note H indicates that this aging effect is not in the GALL Report for this component, material and environment combination. Since the Fuel Oil Chemistry Program does not include a component inspection activity to confirm that the aging effect is not occurring in potentially affected components, please explain how the effectiveness of the Fuel Oil Chemistry Program is confirmed for these components, or provide justification that the Fuel Oil Chemistry Program's effectiveness is not needed.

PPL Response:

For the seven AMR results lines listed in LRA Table 3.3.2-7 where the aging effect is cracking, the AMP is designated as the Fuel Oil Chemistry Program, and note H is used, verification of the effectiveness of the Fuel Oil Chemistry Program is needed to confirm that cracking is not occurring in these components.

The Chemistry Program Effectiveness Inspection will detect and characterize the condition of materials managed by the Fuel Oil Chemistry Program. Implementation of the Chemistry Program Effectiveness Inspection will provide confirmation of the effectiveness of this program in managing the effects of aging, including cracking of susceptible materials.

The affected LRA Table is revised as follows:

Enclosure to PLA-6401 Page 46 of 49 Table 3.3.2-7 Aging Management Review Results - Diesel Fuel Oil System The following line items (on LRA pages 3.3-150, 151, 153, 164, 165, 166, and 167) are revised by addition (bold italics).

Aging Effect Aging NUREG-1801 Component Intended Material Environment Requiring Management Volume 2 Table 1 Item Notes Commodity Function Management Programs Item Fuel Oil Chemistry Level Gauges Pressure Copper Alloy Fuel Oil Program (Day Tank)

Boundary (Brass)

(Internal)

Cracking Chemistry N/A N/A H

Program Effectiveness Inspection Fuel Oil Chemistry Level Gauges Pressure Copper Alloy Fuel Oil Program (Day Tank)

Boundary (Bronze)

(Internal)

Cracking Chemistry N/A N/A H

Program Effectiveness Inspection Fuel Oil Chemistry PressurePrga Orifices

Boundary, Copper Alloy Fuel Oil Program Throung (Brass)

(Internal)

Cracking Chemistry N/A N/A H

Throttling Program Effectiveness Inspection Fuel Oil Chemistry Tubing (and Pressure Copper Alloy Fuel Oil Program Fittings)

Boundary (Brass)

(Internal)

Cracking Chemistry N/A N/A H

Program Effectiveness Inspection

Enclosure to PLA-6401 Page 47 of 49 Component Intended Aging Effect Aging NUREG-1801 Commodity Function Material Environment Requiring Management Volume 2 Table 1 Item Notes CManagement Programs Item Fuel Oil Chemistry Tubing (and Pressure Copper Alloy Fuel Oil Cracking Program Fittings)

Boundary (Bronze)

(Internal)

Chemistry N/A N/A H

Program Effectiveness Inspection Fuel Oil Chemistry Pressure Copper Alloy Fuel Oil Program Valve Bodies Boundary (Brass)

(Internal)

Chemistry Program Effectiveness Inspection Fuel Oil Chemistry Pressure Copper Alloy Fuel Oil Program ValveBoundary (Bronze)

(Internal)

Cracking Chemistry N/A H

Program Effectiveness Inspection

Enclosure to PLA-6401 Page 48 of 49 RAI 3.3.2.2.9.1-1:

In the SRP-LR, Section 3.3.2.2.9.1 identifies the aging effects of loss of material due to general, pitting, crevice, and microbiologically induced corrosion and fouling that could occur for steel piping, piping components, piping elements, and tanks exposed to fuel oil.

However, the LRA Section 3.3.2.2.9.1 states that "fouling is not identified as an aging effect for fuel oil."

Please provide a technical basis or explanation for the statement in the LRA that, "fouling is not identified as an aging effect for fuel oil."

PPL Response:

Fouling is not identified as an aging effect for fuel oil at SSES for the following reasons:

The quality of fuel oil is verified upon receipt and before it is delivered to the plant' s fuel oil storage tanks, and introduced into the fuel oil systems, to ensure that it does not contain contaminants, such as sediment, that could cause fouling. The potential for water contamination in the fuel oil during transfer and storage is, however, assumed.

Therefore, the only foulants that would be expected in the fuel oil would be those that result from corrosion of steel piping and components, i.e., corrosion products. By managing loss of material due to general, pitting, crevice, and microbiologically induced corrosion, corrosion products will be controlled, and fouling will not occur. Therefore, fouling is not identified as an aging effect for fuel oil at SSES.

RAI 3.4.2.2.7.1-1:

In the LRA Section 3.4.2.2.7.1 states, "There are no aging effects identified for aluminum piping components subject to aging management review in the Steam and Power Conversion System." The meaning and intention of this statement in the LRA is unclear to the staff.

a)

Are there aluminum piping components that are in scope for license renewal and that are in a treated water environment in the Steam and Power Conversion System?

b)

If so, then provide your technical basis for claiming that there are no aging effects applicable for these components, and revise the LRA to include this ARM result in the appropriate AMR Results table.

Enclosure to PLA-6401 Page 49 of 49 PPL Response:

The following response is provided to clarify the meaning and intent of the statement in LRA Section 3.4.2.2.7.1.

a) As stated in the discussion in LRA Table 3.4.1, Item 3.4.1-15, there are no aluminum piping components that are in scope for license renewal and that are exposed to a treated water environment in the Steam and Power Conversion Systems for SSES.

The only aluminum piping components that are in scope for license renewal and that are in the Steam and Power Conversion Systems are valve bodies in the Main Steam System. These valve bodies are exposed internally to a dry air-gas environment and externally to an indoor air environment, as indicated in LRA Table 3.4.2-6.

b) Based on the above response, no revision to the LRA is required as a result of this RAI.

Attachment to PLA-6401 LRA Revisions in Response to RAls 3.1-1 and 3.1-8 I

Attachment to PLA-6401 Page 1 of 1 I

)

The text in LRA Section 3.1.2.2.2.1 (on LRA page 3.1-8) is revised by addition (bold italics) and deletion (sti*kehfeiugh).

3.1.2.2.2.1 BWR Top Head and Top Head Nozzles, PWR Steam Generator Shell Assembly The BWR Water Chemistry Program is supplemented by the Inservice Inspection (ISI)

Program for managing loss of material due to general, pitting, and crevice corrosion for the steel reactor vessel upper head and the top head nozzles exposed to reactor coolant. A one-time inspection is not credited.

The BWR Water Chemistry Program in association with the Small Boc* Class 1 Piping

... peotiO, Chemistry Program Effectiveness Inspection manages loss of material due to general, pitting, and crevice corrosion for reactor vessel nozzles (except N6 and N7), safe ends, flanges, main steam flow elements, and steel piping and valves less than 4 inches exposed to reactor coolant. The Small Borc Class 1 Pipig

,.,eGtRo,,

Chemistry Program Effectiveness Inspection is a one-time inspection.

Loss of material for a steam generator shell assembly is only applicable to PWRs.

Note: The Small Bore Class 1 Piping Inspection was previously replaced with the Chemistry Program Effectiveness Inspection (2 places above) in PLA-6391,. Those changes are repeated here for consistency. The reactor vessel nozzles, safe ends, flanges, and main steam flow elements were added here to address RAIs 3.1-1 and 3.1-8.

Attachment to PLA-6401 Page 2 of 11 The text in LRA Section 3.1.2.2.2.3 (on LRA page 3.1-9) is revised by addition (bold italics) and deletion (stikethfetigh).

3.1.2.2.2.3 Flanges, Nozzles, Penetrations, Pressure Housings, Safe Ends, and Vessel Shells, Heads, and Welds The BWR Water Chemistry Program is supplemented by the Inservice Inspection (ISI)

Program for managing loss of material due to crevice and pitting corrosion for the steel reactor vessel upper head closure flange and shell closure flange with stainless steel cladding exposed to reactor coolant. A one-time inspection is not credited.

The BWR Water Chemistry Program aIeOe in association with the Chemistry Program Effectiveness Inspection is credited for managing loss of material due to crevice and pitting corrosion of the steel reactor vessel shell rings, ID attachments and welds, bottom head, nozzles, safe ends, and CRD stub tubes and housings with stainless steel cladding exposed to reactor coolant. A one-time in*pect*in 6. not GFedoted.

The BWR Water Chemistry Program in association with the Small Bore Class 1 P!ping

.... eptiOn Chemistry Program Effectiveness Inspection or the Inservice Inspection (ISI) Program manages loss of material due to pitting and crevice corrosion for stainless steel components of the reactor coolant system (RCS) pressure boundary exposed to reactor coolant. The Small Bore Class 1 Piping Ins.pectio Chemistry Program Effectiveness Inspection is a one-time inspection.

The BWR Water Chemistry Program in association with the BWR Vessel Internals Program manages loss of material for stainless steel or nickel alloy reactor vessel internals and thermal sleeves exposed to reactor coolant.

Note: The Small Bore Class 1 Piping Inspection was previously replaced with the Chemistry Program Effectiveness Inspection (in two places in the third paragraph above) in PLA-6391, Attachment 3. Those changes are repeated here for consistency.

Attachment to PLA-6401 Page 3 of 11 The text in LRA Table 3.1.1 (on LRA page 3.1-16) is revised by addition (bold italics) and deletion (&HfkePfe*+gh).

Table 3.1.1 Summary of Aging Management Programs for Reactor Vessel, Internals, and Reactor Coolant System Evaluated in Chapter IV of the GALL Report Item Component/Commodity Aging Effect /

Aging Management Further Discussion Number Mechanism Programs Evaluation Recommended 3.1.1-11 Steel top head enclosure (without Loss of material due to Water Chemistry and One-Yes, detection of The BWR Water Chemistry Program cladding) top head nozzles (vent, general, pitting and Time Inspection aging effects is to in association with the Inservice top head spray or RCIC, and spare) crevice corrosion be evaluated Inspection (ISI) Program is credited to exposed to reactor manage loss of material for the reactor coolant vessel upper head dome and closure flange, top head nozzles N6 and N7, and piping and valves > 4 inches.

The BWR Water Chemistry Program eno in association with the Chemistry Program Effectiveness Inspection is credited to manage loss of material for nozzles (except N6 and N7), safe ends, and flanges, and also for main steam flow elements.

This was changed in PLA-639 1, Attachment 3.

The BWR Water Chemistry Program Change is repeated here for consistency.

in association with the Small rBee Class 1 Piping.. spe.tien Chemistry Program Effectiveness Inspection is.

credited to manage loss of material for piping and valves < 4 inches.

Refer to Section 3.1.2.2.2.1 for further information.

Attachment to PLA-6401 Page 4 of 11 V

The text in LRA Table 3.1.1 (on LRA page 3.1-18) is revised by addition (bold italics) and deletion (&nfkethfeugh).

Table 3.1.1 Summary of Aging Management Programs for Reactor Vessel, Internals, and Reactor Coolant System Evaluated in Chapter IV of the GALL Report Item Component/Commodity Aging Effect /

Aging Management Further Discussion Number Mechanism Programs Evaluation Recommended 3.1.1-14 Stainless steel, nickel-alloy, and Loss of material due to Water Chemistry and One-Yes, detection of The BWR Water Chemistry Program steel with nickel-alloy or stainless pitting and crevice Time Inspection aging effects is to in association with the Inservice steel cladding reactor vessel flanges, corrosion be evaluated Inspection (ISI) Program is credited to nozzles, penetrations, safe ends, manage loss of material for the vessel shells, heads and welds stainless steel clad reactor vessel upper head flange and shell closure flange.

The BWR Water Chemistry Program alone in association with the Chemistry Program Effectiveness Inspection is credited to manage loss of material for stainless steel, nickel alloy, or stainless steel clad reactor vessel shell rings, ID attachments and welds, bottom heads, nozzles, safe ends, and CRD stud tubes and housings.

Loss of material for stainless steel or nickel alloy reactor vessel internals and thermal sleeves is included under this item and credit the BWR Water Chemistry Program in association with the BWR Vessel Internals Program for management.

Refer to Section 3.1.2.2.2.3 for further information.

Attachment to PLA-6401 Page 5 of 11

)

The text in LRA Table 3.1.2-1 (on LRA pages 3.1-38 through 3.1-48 and 3.1-52 through 3.1-54) is revised by addition (bold italics) and deletion (stikethfeugh).

Table 3.1.2-1 Aging Management Review Results - Reactor Pressure Vessel Component Intended Aging Effect Aging Management NUREG-1801 Table 1 Commodity Function Material Environment Requiring Programs Volume 2 Item Item k otes Management I

Reactor Low Alloy BWR Water Chemistry Vessel Upper with Steel Treated Water Cracking -

Program with SS clad SCC Chemistry Program N/A N/A H

Closure Boundary on mating (Internal)

(cladding)

Effectiveness Flange surface Inspection Reactor BWR Water Chemistry Vessel Shell Pressure Low Alloy Treated Water Cracking -

Program Boundary Steel SCC Chemistry Program N/A N/A H

Closure with SS clad (Internal)

(cladding)

Effectiveness Flange Inspection BWR Water Chemistry Loss of Program Material Chemistry Program IV.A1 -8 3.1.1-14 A -E-(cladding)

Effectiveness Reactor Low Alloy Treated Water Inspection Vessel Shell Pressure Steel ShelllRingsl Boundary wthSl (Internal)

BWR Water Chemistry Shell Rings w ith SS clad C a k n r g a Cracking -

Program SCC Chemistry Program N/A N/A H

(cladding)

Effectiveness Inspection

Attachment to PLA-6401 Page 6 of 11 Table 3.1.2-1 Aging Management Review Results - Reactor Pressure Vessel ComponentMaterial Environment Aging Effect Aging Management NUREG-1801 Table 1 otes Commodity Function aRequiring Programs Volume 2 Item Item Management BWR Water Chemistry Loss of Program Material Chemistry Program IV.A1-8 3.1.1-14 A -E-(cladding)

Effectiveness 95Rel Pressure LoeAl Treated Water Inspection Vessel Steel Bottom Head Boundary with SS clad (Internal)

BWR Water Chemistry Cracking -

Program SCC Chemistry Program N/A N/A H

(cladding)

Effectiveness Inspection Nozzles BWR Water Chemistry N1 Reactor Loss of Program Recirculation Material Chemistry Program IV.A1-8 3.1.1-14 A -E-Outlets (cladding)

Effectiveness N2 Reactor Pressure Low Alloy Treated Water Inspection Recirculation Boundary Steel Inlets with SS clad (Internal)

BWR Water Chemistry N5 Core Cracking -

Program Spray SCC Chemistry Program N/A N/A H

(cladding)

Effectiveness N8 Jet Pump Inspection Instruments BWR Water Chemistry Nozzles Pressure Low Alloy Treated Water Loss of Program N3 Main Boundary Steel (Internal)

Material Chemistry Program IV.A1-11 3.1.1-11 C-E-Steam unclad Effectiveness Inspection BWR Water Chemistry Nozzles Pressure Low Alloy Treated Water Loss of Program N4 Feedwater Boundary Steel (Internal)

Material Chemistry Program IV.A1-11 3.1.1-11 C-E-a unclad Effectiveness Inspection

Attachment to PLA-6401 Page 7 of 11 Table 3.1.2-1 Aging Management Review Results - Reactor Pressure Vessel Component /

Intended Aging Effect Aging Management NUREG-1801 Table 1 Commodity Function Material Environmen Requiring Programs Volume 2 Item Item ComdtjFnto ManagementI BWR Water Chemistry Nozzle Pressure Low Alloy Treated Water Loss of Program N9 CRD Boundary Steel (internal)

Material Chemistry Program IV.A1-8 3.1.1-14 A-E return with SS clad (cladding)

Effectiveness Inspection BWR Water Chemistry Cracking -

Program Nozzle SCC Chemistry Program N/A N/A H

N10 (cladding)

Effectiveness Core DP-SLC Inspection Pressure Nickel Based Treated Water BWR Water Chemistry N11, N12, Boundary Alloy (Internal)

Program N16 Loss of rIV.A1-8 3.1.1-14 A-E Instrument-Material Chemistry ProgramIVA

-3.1-4 A -E atrion Effectiveness Inspection Nozzle BWR Water Chemistry NozzleProgram N13 RV Pressure Nickel Based Treated Water Loss of Program Flange leak Boundary Alloy (Internal)

Material Chemistry Program IV.A1-8 3.1.1-14 A-E detection Effectiveness detection

~~~~Inspection___________

Attachment to PLA-6401 Page 8 of I I Table 3.1.2-1 Aging Management Review Results - Reactor Pressure Vessel Component /

Intended Aging Effect Aging Management NUREG-1801 Table 1 Commodity Function Material Environment Requiring Programs Volume 2 Item Item otes BWR Water Chemistry Loss of Program Material Chemistry Program IV.A1 -11 3.1.1-11 C -E-Effectiveness Inspection Low Alloy BWR Water Chemistry Nozzle Pressure Steel Treated Water Loss of Program N15 Drain Boundary with partial (Internal)

Material Chemistry Program IV.A1-8 3.1.1-14 A-F SS clad (cladding)

Effectiveness Inspection BWR Water Chemistry Cracking -

Program SCC Chemistry Program N/A N/A H

(cladding)

Effectiveness Inspection Safe Ends N1 safe end Ni B and N2J Stainless BWR Water Chemistry weld overlays Pressure Steel or Treated Water Loss of Program Unit 1 only Boundary Nickel Based (Internal)

Material Chemistry Program IV.A1-8 3.1.1-14 A -FE N2 safe end Alloy Effectiveness N5 safe end N8 safe end BWR Water Chemistry Cap Pressure Nickel Based Treated Water Loss of Program N9 cap Boundary Alloy (Internal)

Material Chemistry Program IV.A1-8 3.1.1-14 A -E-Effectiveness Inspection

Attachment to PLA-6401 Page 9 of 11 Table 3.1.2-1 Aging Management Review Results - Reactor Pressure Vessel Component IEIntended 1e1uAging Effect Aging Management NUREG-1801 Table 1 4otes Commodity Function Material Environment Requiring Programs Volume 2 Item Item BWR Water Chemistry Safe End Pressure Stainless Treated Water Loss of Program N10 safe end Boundary Steel (Internal)

Material Chemistry Program IV.A1-8 3.1.1-14 A-F=

Effectiveness Inspection Safe Ends and flanges and flangees BWR Water Chemistry N3Carbon Steel Program Nil, N12, Pressure CabnSelTreated Water Loss ofPrga N1 sf Boury or Low Alloy (Internal)

Material Chemistry Program IV.A1-11 3.1.1-11 C -E-N16 safe Boundary Steelo Effectiveness ends Inspection N6, N7 flanges BWR Water Chemistry Safe Ends Pressure Carbon Steel Treated Water Loss of Program N4 safe ends Boundary SS cl (Internal)

Material Chemistry Program IV.A1-11 3.1.1-11 C-E-r SS clad Effectiveness Inspection

Attachment to PLA-6401 Page 10 of 11 Table 3.1.2-1 Aging Management Review Results - Reactor Pressure Vessel Component Intended Aging Effect Aging Management UREG-1801 Table 1 Componet!

Inten Material Environment Requiring Programs Vtolume 2 Item Item Glotes Commodity Function Management Programs

_olume 2_ItemItem Reactor Vessel ID Attachments and Welds shroud support ring pad shroud support feet pads jet pump riser pads core spray brackets steam dryer holddown brackets guide rod brackets surveillance specimen brackets steam dryer support brackets feedwater support brackets Support Stainless Steel and Nickel Based Alloy Treated Water (Internal)

Loss of Material BWR Water Chemistry Program Chemistry Program Effectiveness Inspection IV.A1-8 3.1.1-14

Attachment to PLA-6401 Page 11 of 11 I)

Table 3.1.2-1 Aging Management Review Results - Reactor Pressure Vessel Component /

Intended AgingAging Management UREG-1801 Table 1 Commodity Function Material Environment Requiring PArog ramas Volume 2 Item Item 1 lotes Management

[

BWR Water Chemistry CRD stub Pressure Nickel Based Treated Water Loss of Program tubes Boundary Alloy (Internal)

Material Chemistry Program IV.A1-8 3.1.1-14 C-EF Effectiveness Inspection BWR Water Chemistry CRD Pressure Stainless Treated Water Loss of Program Housings Boundary Steel (Internal)

Material Chemistry Program IV.A1-8 3.1.1-14 C-E-Effectiveness Inspection BWR Water Chemistry Incore Flux StainlessPrga Mnitor Fl Pressure Steel or Treated Water Loss of Program Monitor Boundary Nickel Based (Internal)

Material Chemistry Program IV.A1-8 3.1.1-14 C-E-Housings Alloy Effectiveness Inspection