Disposition of Public Comments and

Technical Bases for Changes in the 

License Renewal Guidance Documents 

NUREG-1801 and NUREG-1800

Office of Nuclear Reactor Regulation

NUREG-1950
Disposition of Public Comments and 

Technical Bases for Changes in the 

License Renewal Guidance Documents 

NUREG-1801and NUREG-1800 

Manuscript Completed: April 2011 

Date Published: April 2011 

 

NUREG-1950 
April 2011 iii NUREG-1950

ABSTRACT

This document is a knowledge management and knowledge transfer document associated with 

Revision 2 of NUREG-1801, “Generic Aging Lessons Learned (GALL) Report,” and Revision 2 

to NUREG-1800, “Standard Review Plan for Review of License Renewal Applications for 

Nuclear Power Plants.” This document updates and combines NUREG-1832, “Analysis of 

Public Comments on the Revised License Renewal Guidance Documents,” and NUREG-1833, 

“Technical Bases for Revision to the License Renewal Guidance Documents,” (both published 

in 2005) into a single document. The NRC has decided to combine these two documents 

because their subject matter is so closely related that there was considerable redundancy when 

they were two separate documents. 

This document fulfills two purposes. Firstly, the technical changes that were made when 

revising the guidance contained in NUREG-1801 are captured in this document, along with the 

technical basis for the changes. Changes to NUREG-1800, many of which derive from the 

changes to NUREG-1801, are also discussed in this document. Consequently, this document 

provides the underlying rationale that the NRC used to develop the current revisions to these 

guidance documents.

Secondly, this document contains the NRC staff’s analysis of the public comments received on 

the Revision 2 drafts of NUREG-1801 and NUREG-1800. Public comment drafts of the GALL 

Report and the Standard Review Plan for License Renewal (SRP-LR) were published on May 

14, 2010, with the public comment period expiring on July 2, 2010. The disposition of comments 

that were accepted by the NRC staff and used as the basis for instituting a change to either the 

GALL Report or the SRP-LR are detailed in this document. In addition, the public comments that 

did not result in a change to either NUREG are also dispositioned, and a technical basis for the 

staff’s disagreement with these comments is presented.
NUREG-1950 iv April 2011
April 2011 v NUREG-1950

TABLE OF CONTENTS

Page

Abstract ....................................................................................................................................iii

List of Tables...........................................................................................................................vii

Executive Summary.................................................................................................................xi

List of Contributors................................................................................................................xiii

Abbreviations........................................................................................................................xvii

I Introduction ................................................................................................................... I-1

I.1 Purpose and Organization of the Document ........................................................... I-1

I.2 Overview of Generic Changes from Revision 1 to Revision 2 ................................. I-2

I.3 Incorporation of Previously Approved NRC Staff Technical Positions ..................... I-4

I.4 Operating Experience ............................................................................................. I-5

II Revision 2 Changes to GALL Report, Rev. 1 and their Technical Bases ..................II-1

II.1 New AMR Items in Revision 2 of the GALL Report .................................................II-4

II.2 Changes to Existing AMR Items in Revision 2 of the GALL Report.........................II-4

II.3 Chapter IX – Definitions..........................................................................................II-9

II.4 Chapter X – Time-Limited Aging Analyses (TLAAs)................................................II-9

II.5 Chapter XI – Aging Management Programs (AMPs).............................................II-10

II.6 Overview of Changes to GALL Chapter 1, Rev. 1 – Application of the 

ASME Code..........................................................................................................II-12

II.7 Explanation of Tables II-1 through II-13 ................................................................II-12

II.8 Explanation of Tables II-14 through II-25 ..............................................................II-12

III Revision 2 Changes to SRP-LR, Rev. 1 and their Technical Bases..........................III-1

III.1 Chapter 1 – Administrative Information..................................................................III-1

III.2 Chapter 2 – Scoping and Screening Methodology .................................................III-1

III.3 Chapter 3 – Aging Management Reviews (AMRs) Rollup Tables ..........................III-2

III.4 Chapter 4 – Time-Limited Aging Analyses (TLAAs) ...............................................III-3

III.5 SRP-LR Appendices A.1, A.2, and A.3 ..................................................................III-3

IV Analysis and Disposition of Public Comments on May 2010 Public 

Comment Draft, Revision 2......................................................................................... IV-1

IV.1 Public Comment Solicitation and Management..................................................... IV-1
NUREG-1950 vi April 2011

IV.2 Disposition of Public Comments on the May 2010 Draft GALL Report, 

Rev. 2...................................................................................................................IV-2

IV.3 Disposition of Public Comments on the May 2010 Draft SRP-LR, Rev. 2 ............. IV-2

References ....................................................................................................................... IV-339

APPENDIX A: Crosswalk and Staff Technical Positions ............................................. A-1

A.1 GALL Report 2000-2005-2010 Crosswalk ............................................................. A-1

A.2 Staff Technical Positions...................................................................................... A-79
April 2011 vii NUREG-1950

LIST OF TABLES

Page

Table I-1. Crosswalk Between the Summary of Changes, Technical Bases, and Public 

Comment Tables in NUREG-1950 ..................................................................................... I-2

Table II-1. New AMR Items Added in Revision 2 of the GALL Report, Chapter II...................II-14

Table II-2. New AMR Items Added in Revision 2 of the GALL Report, Chapter III..................II-18

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV..................II-28

Table II-4. New AMR Items Added in Revision 2 of the GALL Report, Chapter V...................II-61

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII.................II-69

Table II-6. New AMR Items Added in Revision 2 of the GALL Report, Chapter VIII..............II-106

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor 

Vessel, Internals, and Reactor Coolant and Their Technical Bases................................II-117

Table II-8. Changes to Existing GALL Report Rev. 1 Chapter V AMR Items for 

Engineered Safety Systems and Their Technical Bases ................................................II-180

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and 

Their Technical Bases....................................................................................................II-199

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam 

and Power Conversion Systems and Their Technical Bases..........................................II-233

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for 

Containment and Their Technical Bases ........................................................................II-261

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for 

Structures and Component Supports and Their Technical Bases...................................II-350

Table II-13. Changes to Existing GALL Report Rev. 1 Chapter VI AMR Items for 

Electrical Systems and Their Technical Bases ...............................................................II-382

Table II-14. Chapter IX.B - Revision 2 Differences from Chapter IX, GALL Report, Rev. 1 

and Their Technical Bases.............................................................................................II-404

Table II-15. Chapter IX.C - Revision 2 Differences from Chapter IX, GALL Report, Rev. 1 

and Their Technical Bases.............................................................................................II-406

Table II-16. Chapter IX.D - Revision 2 Differences from Chapter IX, GALL Report, Rev. 1 

and Their Technical Bases.............................................................................................II-409

Table II-17. Chapter IX.E - Revision 2 Differences from Chapter IX, GALL Report, Rev. 1 

and Their Technical Bases.............................................................................................II-411

Table II-18. Chapter IX.F - Revision 2 Differences from Chapter IX, GALL Report, Rev. 1 

and Their Technical Bases.............................................................................................II-414
NUREG-1950 viii April 2011

Table II-19. Chapter IX.G - Revision 2 Differences from Chapter IX, GALL Report, Rev. 1 

and Their Technical Bases.............................................................................................II-417

Table II-20. Revision 2 Differences from Chapter X, Time-Limited Aging Analyses, GALL 

Report, Rev. 1 and Their Technical Bases .....................................................................II-418

Table II-21. Revision 2 Differences from Chapter XI, Mechanical Aging Management 

Programs, GALL Report, Rev. 1 and Their Technical Bases..........................................II-420

Table II-22. Revision 2 Differences from Chapter XI, Structural Aging Management 

Programs, GALL Report, Rev. 1 and Their Technical Bases..........................................II-446

Table II-23. Revision 2 Differences from Chapter XI, Electrical Aging Management 

Programs, GALL Report, Rev. 1 and Their Technical Bases..........................................II-453

Table II-24. Revision 2 Chapter I Differences from GALL Report, Rev. 1 and Their 

Technical Bases.............................................................................................................II-456

Table II-25. Revision 2 General BWR Vessel Internals Aging Management Programs 

Differences from GALL Report, Rev. 1 and Technical Bases .........................................II-457

Table III-1. Revision 2 Chapter 1 Differences from SRP-LR, Rev. 1 and Their Technical 

Bases................................................................................................................................III-4

Table III-2. Revision 2 Chapter 2 Differences from SRP-LR, Rev. 1 and Their Technical 

Bases................................................................................................................................III-4

Table III-3. Revision 2 Chapter 3.0 Differences from SRP-LR, Rev. 1 and Their 

Technical Bases................................................................................................................III-5

Table III-4. Revision 2 Chapter 3.1 (Reactor Vessels, Internals, Coolant System) 

Differences from SRP-LR, Rev. 1 and Their Technical Bases ...........................................III-6

Table III-5. Revision 2 Chapter 3.2 (Engineered Safety Features) Differences from SRPLR, Rev. 1 and Their Technical Bases ..............................................................................III-6

Table III-6. Revision 2 Chapter 3.3 (Auxiliary Systems) Differences from SRP-LR, Rev. 1 

and Their Technical Bases................................................................................................III-6

Table III-7. Revision 2 Chapter 3.4 (Steam and Power Conversion Systems) Differences 

from SRP-LR, Rev. 1 and Their Technical Bases..............................................................III-7

Table III-8. Revision 2 Chapter 3.5 (Structures and Components) Differences from SRPLR, Rev. 1 and Their Technical Bases ..............................................................................III-7

Table III-9. Revision 2 Chapter 3.6 (Electrical and Instrumentation Controls) Differences 

from SRP-LR, Rev. 1 and Their Technical Bases..............................................................III-7

Table III-10. Revision 2 Chapter 4.1 (Identification of TLAA) Differences from SRP-LR, 

Rev. 1 and Their Technical Bases.....................................................................................III-8

Table III-11. Revision 2 Chapter 4.2 (Neutron Irradiation Embrittlement) Differences from 

SRP-LR, Rev. 1 and Their Technical Bases......................................................................III-8
April 2011 ix NUREG-1950

Table III-12. Revision 2 Chapter 4.3 (Metal Fatigue, Piping, and Components) 

Differences from SRP-LR, Rev. 1 and Their Technical Bases .........................................III-10

Table III-13. Revision 2 Chapter 4.4 (Environmental Qualification of Electrical 

Equipment) Differences from SRP-LR, Rev. 1 and Their Technical Bases ......................III-11

Table III-14. Revision 2 Chapter 4.5 (Concrete Tendon Prestress) Differences from SRPLR, Rev. 1 and Their Technical Bases ............................................................................III-12

Table III-15. Revision 2 Chapter 4.6 (Metal Containment, Liner Plate, Penetrations 

Fatigue) Differences from SRP-LR, Rev. 1 and Their Technical Bases ...........................III-12

Table III-16. Revision 2 Chapter 4.7 (Plant-Specific TLAA) Differences from SRP-LR, 

Rev. 1 and Their Technical Bases...................................................................................III-12

Table III-17. Revision 2 Appendix Differences from SRP-LR, Rev. 1 and Their Technical 

Bases..............................................................................................................................III-12

Table IV-1. Identification of Public Comments on May 2010 Draft GALL Report, Rev. 2, 

Originator, and ADAMS Accession Number ..................................................................... IV-3

Table IV-2. Analysis and Disposition of Public Comments on Chapter I, May 2010 Public 

Comment Draft GALL Report, Rev. 2 ............................................................................. IV-22

Table IV-3. Analysis and Disposition of Public Comments on Chapter II, May 2010 Public 

Comment Draft GALL Report, Rev. 2 ............................................................................. IV-23

Table IV-4. Analysis and Disposition of Public Comments on Chapter III, May 2010 

Public Comment Draft GALL Report, Rev. 2 .................................................................. IV-26

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 

Public Comment Draft GALL Report, Rev. 2 .................................................................. IV-30

Table IV-6. Analysis and Disposition of Public Comments on Chapter V, May 2010 

Public Comment Draft GALL Report, Rev. 2 .................................................................. IV-60

Table IV-7. Analysis and Disposition of Public Comments on Chapter VI, May 2010 

Public Comment Draft GALL Report, Rev. 2 .................................................................. IV-65

Table IV-8. Analysis and Disposition of Public Comments on Chapter VII, May 2010 

Public Comment Draft GALL Report, Rev. 2 .................................................................. IV-68

Table IV-9. Analysis and Disposition of Public Comments on Chapter VIII, May 2010 

Public Comment Draft GALL Report, Rev. 2 .................................................................. IV-82

Table IV-10. Analysis and Disposition of Public Comments on Chapter IX, May 2010 

Public Comment Draft GALL Report, Rev. 2 .................................................................. IV-83

Table IV-11. Analysis and Disposition of Public Comments on Chapter X TLAAs, May 

2010 Public Comment Draft GALL Report, Rev. 2.......................................................... IV-86

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical 

AMPs, May 2010 Public Comment Draft GALL Report, Rev. 2....................................... IV-91
NUREG-1950 x April 2011

Table IV-13. Analysis and Disposition of Public Comments on Chapter XI Structural 

AMPs, May 2010 Public Comment Draft GALL Report, Rev. 2..................................... IV-277

Table IV-14. Analysis and Disposition of Public Comments on Chapter XI Electrical 

AMPs, May 2010 Public Comment Draft GALL Report, Rev. 2..................................... IV-296

Table IV-15. Analysis and Disposition of Public Comments on General BWR Vessel 

Internals Aging Management Programs, May 2010 Public Comment Draft GALL 

Report, Rev. 2.............................................................................................................. IV-305

Table IV-16. Analysis and Disposition of Chapter 1 Public Comments on May 2010 

Public Comment Draft SRP-LR, Rev. 2 ........................................................................ IV-309

Table IV-17. Analysis and Disposition of Chapter 2 Public Comments on May 2010 

Public Comment Draft SRP-LR, Rev. 2 ........................................................................ IV-310

Table IV-18. Analysis and Disposition of Chapter 3 Public Comments on May 2010 

Public Comment Draft SRP-LR, Rev. 2 ........................................................................ IV-314

Table IV-19. Analysis and Disposition of Chapter 4 Public Comments on May 2010 

Public Comment Draft SRP-LR, Rev. 2 ........................................................................ IV-325

Table IV-20. Analysis and Disposition of Appendices Public Comments on May 2010 

Public Comment Draft SRP-LR, Rev. 2 ........................................................................ IV-338

Table A-1. Relationship of Containment Structures IDs in GALL Report, Chapter II................ A-2

Table A-2. Relationship of Structures and Component Supports IDs in GALL Report, 

Chapter III ......................................................................................................................... A-6

Table A-3. Relationship of Reactor Vessel, Internals, and Reactor Coolant (RCS) 

System IDs in GALL Report, Chapter IV.......................................................................... A-22

Table A-4. Relationship of Engineered Safety Features (ESF) System IDs in GALL 

Report, Chpt. V ............................................................................................................... A-32

Table A-5. Relationship of Electrical Components System IDs in GALL Report, Chapter 

VI .................................................................................................................................... A-44

Table A-6. Relationship of Auxiliary System IDs in GALL Report, Chpt. VII........................... A-45

Table A-7. Relationship of Steam and Power Conversion (SPC) System IDs in GALL 

Report, Chpt VIII ............................................................................................................. A-68

Table A-8. Summary of Changes to the Updated License Renewal Documents as a 

Result of License Renewal Interim Staff Guidance (LR-ISG)........................................... A-79
April 2011 xi NUREG-1950

EXECUTIVE SUMMARY

Public Comment Overview

On May 18, 2010 (75 FR 27838), the Nuclear Regulatory Commission (NRC) announced the 

issuance and availability of the following license renewal guidance documents (LRGDs) for 

public comment:

 Draft “Standard Review Plan for Review of License Renewal [SRP-LR] Applications for 

Nuclear Power Plants” (NUREG-1800), Revision 2

 Draft “Generic Aging Lessons Learned (GALL) Report” (NUREG-1801), Revision 2

These LRGDs described methods acceptable to the staff for implementing the license renewal 

rule, Title 10 of the Federal Code of Regulations (CFR)(10 CFR Part 54), as well as techniques 

used by the staff in evaluating applications for nuclear power plant (NPP) license renewals. The 

draft revisions incorporated changes that reflected past precedents and other lessons learned 

since Revision 1 of the LRGDs, published in 2005.

In addition to issuing the draft revisions of these LRGDs for formal public comment, the staff 

held several public meetings with stakeholders to discuss the content of the draft LRGDs and 

subsequent comments on these draft documents.

The staff took into consideration the comments received as a result of the formal solicitation 

described above and incorporated its dispositions into the December 2010 versions of the 

LRGDs. This report, NUREG-1950, provides the evaluation and disposition of public comments 

received by the NRC on the draft revisions of the LRGDs. 

Technical Bases Overview

This report, NUREG-1950, provides a summary of changes and a synopsis of the bases for 

these changes made as part of Revision 2 to the SRP-LR, and Revision 2 to the GALL Report. 

These changes include those that were initiated by NRC staff as well as the changes made in 

response to public comments, as appropriate. This document provides the underlying rationale 

that the NRC used in developing the Revision 2 LRGDs. Furthermore, Appendix A of this 

document includes a one-to-one correlation between the Aging Management Review (AMR)

line-items in GALL Rev. 0, Rev.1, and Rev. 2 for easy cross-reference. 

April 2011 xiii NUREG-1950

LIST OF CONTRIBUTORS

Division of License Renewal, Office of Nuclear Reactor Regulation

B. Holian

M. Galloway

Division Director

Deputy Division Director

S. Lee Deputy Division Director 

L. Lund Deputy Division Director 

R. Auluck Branch Chief

J. Dozier Branch Chief

D. Pelton Branch Chief

A. Hiser Senior Level 

R. Gramm Team Leader

H. Ashar Structural Engineering

M. Banic Mechanical Engineering

A. Buford Structural Engineer

C. Cho Administrative Assistant

J. Davis Materials Engineering

C. Doutt Electrical Engineering

B. Elliot Materials Engineering

A. Erickson General Engineer

S. Figueroa Licensing Assistant

B. Fu Materials Engineering

J. Gavula Mechanical Engineering

W. Holston Mechanical Engineering

E. Keegan Project Manager

I. King Licensing Assistant

R. Li Electrical Engineering

J. Medoff Mechanical Engineering

S. Min Materials Engineering

D. Nguyen Electrical Engineering

V. Perin Mechanical Engineering

A. Prinaris Mechanical Engineering

L. Regner Project Manager

S. Sakai Project Manager

B. Rogers Reactor Engineer

A. Sheikh Structural Engineering

W. Smith Mechanical Engineering

R. Sun Mechanical Engineering

R. Vaucher Mechanical Engineering

A. Wong Mechanical Engineering
NUREG-1950 xiv April 2011

C.Y. Yang Materials Engineering

L. Yee Administrative Assistant

O. Yee Mechanical Engineering

M. Yoo General Engineer

Office of Nuclear Reactor Regulation

G. Casto Branch Chief

T. Chan Branch Chief

M. Khanna Branch Chief

A. Klein Branch Chief

T. Lupold Branch Chief

M. Mitchell Branch Chief

R. Taylor Branch Chief

G. Wilson Branch Chief

R. Hardies Senior Level – Materials Engineering

K. Karwoski Senior Level – Steam Generators

K. Manoly Senior Level – Structural Engineering

D. Alley Materials Engineering

J. Bettle Mechanical Engineering

T. Cheng Structural Engineering

G. Cheruvenki Materials Engineering

J. Collins Mechanical Engineering

R. Davis Materials Engineering

S. Gardocki Mechanical Engineering

M. Hartzman Materials Engineering

K. Hoffman Mechanical Engineering

N. Iqbal Fire Protection Engineering

A. Johnson Mechanical Engineering

S. Jones Mechanical Engineering

B. Lee Mechanical Engineering

R. Mathew Electrical Engineering

P. Patniak Mechanical Engineering

G. Purciarello Mechanical Engineering

A. Tsirigotis Mechanical Engineering

M. Yoder Chemical Engineering

E. Wong Chemical Engineering
April 2011 xv NUREG-1950

Region I

G. Meyer Mechanical Engineering

M. Modes Mechanical Engineering

Office of Nuclear Regulatory Research

A. Csontos

M. Gavrilas

Branch Chief

Branch Chief

T. Koshy Branch Chief

M. Salley Branch Chief

R. Tregoning Senior Level – Materials Engineering

S. Aggarwal Electrical Engineering

J. Burke Mechanical Engineering

G. Carpenter Materials Engineering

H. Graves Structural Engineering

A. Hull Materials Engineering

B. Lin Structural Engineering

L. Ramadan

G. Stevens

Electrical Engineering

Materials Engineering

D. Stroup Fire Protection Engineering

G. Wang Mechanical Engineering

Advanced Technologies and Laboratories International, Inc. (ATL)

K. Makeig Project Manager

K. Chang Mechanical Engineering

O. Chopra Materials Engineering

W. Jackson Mechanical Engineering

D. Jones Programming (Project Enhancement Corp.)

M. May Mechanical Engineering 

A. Ouaou Structural Engineering 

E. Patel Mechanical Engineering

J. Davis Materials Engineering

R. Royal Electrical Engineering

T. Brake Technical Editing
 
April 2011 xvii NUREG-1950

ABBREVIATIONS

ACAR aluminum conductor aluminum alloy reinforced

ACSR aluminum conductor steel reinforced

ACI American Concrete Institute

AE/AM Aging effect/aging mechanism

AERM aging effect requiring management

AISC American Institute of Steel Construction

AMP aging management program

AMR aging management review

ANSI American National Standards Institute

AOG advanced off-gas

ASME American Society of Mechanical Engineers

ASTM American Society for Testing and Materials

BAC boric acid corrosion

BVPS Beaver Valley Power Station

BWR boiling water reactor

BWRVIP Boiling Water Reactor Vessel and Internals Project

B&PV boiler and pressure vessel (ASME entity)

CASS cast austenitic stainless steel

CE Combustion Engineering

CEA control element assembly

CFR Code of Federal Regulations

CLB current licensing basis

CNS Cooper Nuclear Station

CRD control rod drive

CRDRL control rod drive return line

CRGT control rod guide tube

CUF cumulative usage factor

DAEC Duane Arnold Energy Center

DLR Division of License Renewal (NRC)

ECCS emergency core cooling system

ECP electrochemical corrosion potential

EOL end of life

EPDM ethylene-propylene diene monomer

EPR ethylene-propylene rubber

EPRI Electric Power Research Institute

EQ environmental qualification
NUREG-1950 xviii April 2011

ESF engineered safety features

EVT enhanced visual testing

FAC flow-accelerated corrosion

FER further evaluation required

FERC Federal Energy Regulatory Commission

FSAR Final Safety Analysis Report

F/E further evaluation

GALL Generic Aging Lessons Learned

GL Generic Letter

HDPE high density polyethylene

HMWPE high molecular weight polyethylene

HPCI high-pressure coolant injection

HVAC heating, ventilation, and air conditioning

IAEA International Atomic Energy Agency

IASCC irradiation-assisted stress corrosion cracking

IC isolation condenser

IGSCC intergranular stress corrosion cracking

ILRT integrated leak rate testing

IN information notice

IR insulation resistance

IRS Incident Reporting System (database)

ISG Interim Staff Guidance

ISI inservice inspection

JAFNPP James A. FitzPatrick Nuclear Power Plant

LER licensee event report

LP low pressure

LR-ISG license renewal interim staff guidance

LRA license renewal application

LRGD license renewal guidance document

LTCP low temperature crack propagation

MEAP material, environment, aging effect and aging management program

MEB metal enclosed bus

MIC microbiologically-influenced corrosion
April 2011 xix NUREG-1950

MRP Materials Reliability Program

NACE National Association of Corrosion Engineers

NDE nondestructive examination

NEA Nuclear Energy Agency

NEI Nuclear Energy Institute

NFPA National Fire Protection Association

NPP nuclear power plant

NPS nominal pipe size

NRC Nuclear Regulatory Commission

NSAC Nuclear Safety Analysis Center

NSSS nuclear steam supply system

OCCW open-cycle cooling water

OCNGS Oyster Creek Nuclear Generating Station

ODSCC outer diameter stress corrosion cracking

OECD Organisation for Economic Co-operation and Development

OE operating experience

PH precipitation-hardened

PT penetrant testing

P/T pressure temperature

PVC polyvinyl chloride

PWR pressurized water reactor

PWSCC primary water stress corrosion cracking

QA quality assurance

RCCA rod control cluster assembly

RCPB reactor coolant pressure boundary

RCS reactor coolant system

RCSC Research Council on Structural Connections

RG Regulatory Guide

RIS regulatory information summary

RVI reactor vessel internals

S&P steam and power

SAW submerged arc weld

SBO station blackout
NUREG-1950 xx April 2011

SCC stress corrosion cracking

SER safety evaluation report

SFP spent fuel pool

SG steam generator

S/G Standards and guides

SPC steam and power conversion system

SR silicone rubber

SRP-LR standard review plan for license renewal

SS stainless steel

SSC systems, structures, and components

SSES Susquehanna Steam Electric Station

TGSCC transgranular stress corrosion cracking

TLAA time-limited aging analysis

TMI Three-Mile Island

USE upper-shelf energy

UT ultrasonic testing

UV ultraviolet

VYNPS Vermont Yankee Nuclear Power Station

WCGS Wolf Creek Generating Station

XLPE cross-linked polyethylene
April 2011 I-1 NUREG-1950

I INTRODUCTION

NUREG-1950, “Disposition of Public Comments and Technical Bases for Changes in the 

License Renewal Guidance Documents NUREG-1801 and NUREG-1800,” establishes the 

changes that constitute Revision 2 of NUREG-1801, “Generic Aging Lessons Learned (GALL) 

Report,” and Revision 2 of NUREG-1800, “Standard Review Plan for Review of License 

Renewal Applications for Nuclear Power Plants” (SRP-LR). These two license renewal guidance 

documents (LRGDs) were published in December, 2010. NUREG-1950 is a knowledge 

management transfer document.

NUREG-1950 provides (1) an evaluation and technical justification for the disposition of all 

public comments received by the NRC during a 45-day comment period that ended on July 2, 

2010 regarding the two LRGDs, and (2) a summary of notable technical changes and the 

technical bases for the changes made to Revision 1 of these two LRGDs. 

Many public comments resulted in changes to the GALL Report and the SRP-LR. Some of the 

changes to the SRP-LR were derived from the changes to the GALL Report. Consequently, 

NUREG-1950 provides the underlying rationale that the NRC used to develop the current 

revisions of NUREG-1800 and -1801. 

I.1 Purpose and Organization of the Document

NUREG-1950 contains the significant changes to Revision 1 and the technical bases for the 

disposition of all public comments, both those that led to revisions to the documents and those 

that did not. Previously, for Revision 1 of NUREG-1800 and -1801, the information was 

contained in two separate LRGDs, NUREG-1832 and NUREG-1833. The NRC’s desire to 

streamline its guidance resulted in the combination of all the information into a single document,

NUREG-1950.

This document is organized into four sections followed by references and an appendix. Section I 

contains background and overview information. Section II summarizes the changes to the GALL 

Report and the technical bases of these changes. Section III presents similar information for the 

SRP-LR. Section IV summarizes the analysis and disposition of all public comments received 

on the Revision 2 draft of the GALL Report and the SRP-LR during the public comment period. 

Appendix A includes a crosswalk between the Rev.0/Rev.1/Rev.2 versions of the GALL Report 

as well as the staff technical positions as reflected in the License Renewal Interim Staff 

Guidance (LR-ISGs). 

Tables are used to summarize technical materials whenever possible. Generic changes are 

discussed in the text at the beginning of each subsection of Sections II and III, followed by 

tables showing changes to the documents. Tables in Section IV show each comment that was 

received from the public, the disposition of the comment, and the technical basis supporting the 

action that was taken. 

Table I-1 helps the reader navigate between the tables that summarize the notable technical 

changes and their technical bases and the tables that present the public comments and their 

dispositions. 
NUREG-1950 I-2 April 2011

Table I-1. Crosswalk Between the Summary of Changes, Technical Bases, and Public 

Comment Tables in NUREG-1950

Source Document and Chapter

Tables with Change 

Summaries and Technical 

Bases

Associated Tables with 

Related Public Comments

New AMRs – Mechanical

GALL Chapters IV, V, VII, and VIII Table II-3 through Table II-6 Table IV-5, Table IV-6, Table 

IV-8, Table IV-9 

New AMRs – Structural

GALL Chapters II and III Table II-1 and Table II-2 Table IV-3 and Table IV-4 

New AMRs – Electrical

GALL Chapter VI N/A N/A

Revised AMRs – Mechanical

GALL Chapters IV, V, VII, and VIII Table II-7 through Table II-10 Table IV-5, Table IV-6, Table 

IV-8, Table IV-9 

Revised AMRs – Structural

GALL Chapters II and III Table II-11 and Table II-12 Table IV-3 and Table IV-4 

Revised AMRs – Electrical

GALL Chapter VI Table II-13 Table IV-7 

GALL Chapter IX - Definitions Table II-14 through Table II-19 Table IV-10

GALL Chapter X - TLAAs Table II-20 Table IV-11

GALL Chapter XI – Mechanical Table II-21 Table IV-12

GALL Chapter XI – Structural Table II-22 Table IV-13

GALL Chapter XI - Electrical Table II-23 Table IV-14

GALL Chapter I – American 

Society of Mechanical Engineers 

(ASME) Code

Table II-24 Table IV-2 

GALL General BWR Vessel 

Internals AMP Comments Table II-25 Table IV-15

SRP-LR Chapter 1 Table III-1 Table IV-16 

SRP-LR Chapter 2 Table III-2 Table IV-17 

SRP-LR Chapter 3 Table III-3 through Table III-9 Table IV-18 

SRP-LR Chapter 4 Table III-10 through Table III-16 Table IV-19 

SRP-LR Appendices Table III-17 Table IV-20

I.2 Overview of Generic Changes from Revision 1 to Revision 2

Changes to the GALL Report and the SRP-LR (the LRGDs) fall into the following categories: 

 Additions of new Aging Management Review (AMR) line-items in the GALL Report

 Revisions to or deletions of AMR line-items in the GALL Report

 Revisions to or deletion of Aging Management Programs (AMPs) in the GALL Report
April 2011 I-3 NUREG-1950

 Addition of new materials and new combinations of component/material/environment to 

the AMR line items referenced in the SRP-LR

 Incorporation of Volume 1 and Volume 2 of the GALL Report, Rev. 1 into a single 

volume for Rev. 2

 Changes in roll-up methodology, resulting in changes to tables in the SRP-LR

 NRC positions previously approved in other documents, such as safety evaluation 

reports and approved interim staff guidance

 Lessons learned

 New operating experience 

 Technical clarifications or corrections 

 Clarifications to the audit and review process (SRP-LR only) 

Many sections in this document begin with a discussion of generic and overarching changes to 

a chapter of the guidance documents, followed by detailed descriptions of changes, revisions, 

additions, or disposition of public comments, along with the technical rationale supporting these 

decisions. 

Sometimes there will be slight variation in terminology between NUREG-1950 and NUREGs1800 and -1801. For example, NUREG-1950 uses the convention “AMR Item” and AMR LineItem” interchangeably. Note also that SRP-LR is used interchangeably with SRP or NUREG1800 and that GALL Report is used interchangeably with NUREG-1800. The GALL Report is 

used interchangeably with the shorthand nomenclature of GALL. An AMP (found in Chapter XI 

of GALL) may be simply referred to as AMP XI.M- (referencing mechanical systems).

Section II.1, “New AMR Items in Revision 2 of the GALL Report,” documents the creation and 

justification for new AMR entries. Section II.2, “Changes to Existing AMR Items in Revision 2 of 

the GALL Report,” documents the changes in the existing AMR items and the technical bases 

for these changes. These revisions of the LRGDs describe methods to the staff for 

implementing the license renewal rule (10 CFR Part 54) as well as techniques used by the staff 

to evaluate applications for license renewal. The draft revisions incorporated changes that 

reflect past precedents and other lessons learned since Revision 1, which was published in 

2005.

Some explanation as to what constitutes a “change” is in order. Changes that are captured in 

this guidance document consist of notable technical changes. These include: 

(1) For AMPs - changes in the scope, methods, or measuring techniques, frequencies, codes or 

standards, boundary conditions, or other aspects of license renewal that would result in a 

change to the way an applicant conducts its AMPs based on this guidance, 

(2) For AMRs - changes in materials, aging effects or aging mechanisms, aging management 

programs credited, further evaluation required, additional materials and environment. 

Changes such as moving paragraphs from one section to another, deleting superfluous 

material, making editorial changes, updating citations, AMP title changes, clarifications, etc. are 

not considered notable technical changes and are not documented in the tables contained in 

NUREG-1950.

The numerous tables throughout this document have consistent naming protocol and content. 

Comment or reference numbers are built from a database containing changes made to the 

GALL Report or the SRP-LR. The “Comment Number” is a unique number that is generated

automatically by this database and is given to each public comment. A reference number is
NUREG-1950 I-4 April 2011

assigned to each public comment that allows it to be located in the public comment submittal. 

For instance, “Comment XI.M2-3” means that the public comment was called “XI.M2-3” by the 

commenter. Table IV-1 shows the public comments and their associated reference numbers 

and ADAMS Accession Numbers.

Many tables in Section IV contain a column with the heading “Location in Document and 

Commenter Reference No.” This refers to the place in the document where the change can be 

found, such as a chapter, subchapter, section title, AMR item number, or the like. 

Another column in many tables in Section III is entitled “Summary of the Change.” This column 

summarizes the technical changes that were made to a specific portion of the SRP-LR, either as 

the result of a staff-accepted public comment or because of a need identified by NRC staff. 

Every notable technical change that was made to the GALL Report, Rev. 1 or the SRP-LR, Rev.

1 is documented in the tables in Sections II and III of NUREG-1950. 

If a notable technical change has been made, the technical basis for that change is documented 

in these tables as well. The technical basis may be a citation of a standard or code, the update 

of a standard or code, citation of new NRC Interim Staff Guideline (ISG), operating experience, 

or other technical justification. In addition, public comments that were received during the public 

comment period but were found by NRC staff not to justify a technical change to the GALL 

Report or SRP-LR are also provided with a technical basis as to why the comment was not 

accepted. These bases are found in the tables of Section IV.

Changes that were made to the GALL Report or SRP-LR that were the result of public 

comments, but did not incorporate notable technical changes, are not captured in the tables in 

Sections II or III of this document. The changes that are shown in these tables are limited to 

notable technical changes and do not reflect the changes resulting from typographical errors, 

editorial changes, or clarifications.

I.3 Incorporation of Previously Approved NRC Staff Technical Positions

The GALL Report, Rev. 2 incorporates specific technical changes. These technical changes are 

based on the incorporation of NRC-approved positions established in past precedents from 

approved license renewal Safety Evaluation Reports (SERs), final license renewal interim staff 

guidance (LR-ISG), and more recent operating experience. NUREG-1950 Appendix A.2 (Table 

A-8) summarizes the technical changes made to the GALL Report to reflect the NRC staff 

positions in the LR-ISGs issued since the release of NUREG-1801, Revision 1 in 2005. These 

specific technical changes introduce new technical content to the updated documents. Section 

II, “Revision 2 Changes to GALL Report, Rev.1 and Their Technical Bases,” provides a listing of 

each new or existing AMR line-items that incorporates a technical change and provides a 

specific basis for this change. 

The NRC drew largely upon three sources of information: (a) previous NRC staff comments for 

improving the license renewal process (collected since the issuance of Revision 1 of the GALL 

Report and the SRP-LR), (b) the collection of approved SERs, and (c) suggested changes from 

the Nuclear Energy Institute (NEI). Previous license renewal SERs were reviewed to identify 

instances where changes to the LRGDs should be made to improve the technical accuracy and 

consistency of the license renewal process. The NEI also suggested a number of changes 

based upon the review of prior applications. A large number of items were collected from these 

three information sources and each was reviewed for its applicability, value, and technical 

adequacy as part of the NRC review process.

Numerous changes were made to the AMPs to reflect input from the NRC staff’s review of NRC 

positions previously approved or as necessitated by new operating experience. Section II.5 
April 2011 I-5 NUREG-1950

provides a listing of each new or existing AMP that incorporates notable technical changes and 

provides the bases for those changes. 

In addition, the GALL Report tables were updated to include new material, environment, aging 

effect and aging management program (MEAP) combinations that are common to most license 

renewal applications (LRAs), including those that have already been reviewed. In letters dated 

September 14, 2009 and July 1, 2010, NEI proposed adding a number of new AMR line-items. 

NRC staff reviewed these items to identify whether the SERs had been accepted with the 

proposed MEAP combinations in previous LRAs or whether the MEAP combinations were 

technically appropriate to add. If a previous NRC staff position was identified or the MEAP 

combination was found technically appropriate, the staff evaluated whether the MEAP 

combination was sufficiently generic to warrant including this item in the revised LRGD. If so, it 

was added either in its proposed or in a modified form. Section II.1 of this document further 

discusses these new AMR line-items.

I.4 Operating Experience

Extended operation of nuclear reactors necessitates a thorough analysis of existing experience. 

An operating experience review was performed to identify necessary additions or modifications 

to the GALL Report. Both domestic and foreign operating experience was reviewed.

The staff from the Division of License Renewal (DLR) analyzed operating experience 

information during a screening review of domestic operating experience, foreign operating 

experience from the international Incident Reporting System (IRS) database, and NRC generic 

communications. The information reviewed included operating experience from January 2004 to 

approximately April 2009. 

Domestic Operating Experience: The NRC Office of Research provided a listing of Licensee 

Event Reports (LERs) related to failures, cracking, degradation, etc. of passive components. 

These results were reviewed by NRC staff. The operating experience review identified a number 

of examples where vibration-induced fatigue caused cracking of plant components. The staff 

subsequently modified GALL AMP XI.M35, “One-time Inspection of ASME Code Class 1 Smallbore Piping,” to address these concerns. In addition, the operating experience elements of 

numerous AMPs were updated to reflect relevant operating experience identified by the review.

Foreign Operating Experience: The international IRS, jointly operated by the International 

Atomic Energy Agency (IAEA) and the Nuclear Energy Agency (NEA), is used to compile and 

analyze information on nuclear power plant (NPP) events and also promotes a systematic 

approach to collecting and disseminating the lessons learned from international operating 

experience. Events of safety significance and events from which lessons can be learned are 

reported to the IRS. The main objective of the IRS is to enhance the safety of NPPs by reducing 

the frequency and severity of safety significant unusual events at NPPs. NRC staff also 

reviewed international operating experience from: (a) the Organization for Economic Cooperation and Development (OECD) OECD/NEA Piping Failure Data Exchange database 

(including the data from 1970 to 2009) and (b) the OECD/NEA Stress Corrosion Cracking and 

Cable Aging database. 

The foreign operating experience databases were queried for reports relating to aging effects in 

passive components. The identified reports were analyzed to determine if there were any 

revisions necessary for either AMR line-items or AMP content. Many of the reports identified 

MEAP combinations that were already addressed by the GALL Report. Some of the items were 

specific to foreign plants and not generically applicable to U.S. pressurized water reactors 

(PWRs) and boiling water reactors (BWRs). The IRS identified that stainless steel components 

are subject to chloride-induced stress corrosion cracking (SCC) when they are exposed to the 
NUREG-1950 I-6 April 2011

air-outdoor environment that involves a salt-laden atmospheric condition or salt water spray. 

Based on this review result, relevant SRP-LR chapters were added and further evaluation is 

now recommended for those environmental conditions.
April 2011 II-1 NUREG-1950

II REVISION 2 CHANGES TO GALL REPORT, REV. 1 AND THEIR TECHNICAL BASES

Some technical changes to the GALL Report, Rev. 1 were made to clarify or improve the 

guidance provided in Revision 1. NRC staff believes that these changes make the GALL Report 

more useful to the applicant and to NRC staff reviewing the safety aspects of applications for 

license renewal. Additional changes have been made as a result of public comments received 

during the public comment period that ended July 2, 2010. The final version of NUREG-1801, 

Rev. 2 incorporates both of these types of technical changes. 

Below is a summary of the notable technical changes that were made in Revision 2 of the GALL 

Report. General and generic changes include:

 Eliminating Volume 1 of the GALL Report by moving Volume 1 information into the SRPLR and GALL Report. 

 Revising Chapter I for the Application of the ASME Code using the applicable 2004 

Edition or other editions and addenda allowed as per a new generic footnote in the 

GALL Report (Section I). 

 Revising the AMR line-item-numbering system to include subchapters (e.g., II.A1.CP33). 

 Revising Chapters II and III to split AMR line-items between accessible and inaccessible 

concrete, where applicable. 

 Revising Chapters IV.B2, B3, and B4 to incorporate aspects of the MRP-227, “Materials 

Reliability Program for PWR Internals Inspection and Evaluation Guidelines”. 

 Revising a number of AMR items from a further evaluation required of “Yes” to “No”. 

 Combining aging management using both AMPs XI.M2, “Water Chemistry,” and XI.M32, 

“One-Time Inspection”. 

 Combining aging management using both AMPs XI.M39, “Lubricating Oil Analysis,” and 

XI.M32, “One-Time Inspection”. 

 Combining aging management using both AMPs XI.M30, “Fuel Oil Chemistry,” and 

XI.M32, “One-Time Inspection”. 

 Developing a new AMP XI.M41, “Buried and Underground Piping and Tanks,” to address 

buried and underground piping and tanks.

 Developing a new AMP XI.M40, “Monitoring of Neutron-Absorbing Materials Other than 

Boraflex," to address neutron-absorbing materials other than Boraflex. 

 Including ground water chemistry in the structural AMPs so that further evaluation is not 

recommended for structural AMRs. 

 Using the new AMP XI.M16A, “PWR Vessel Internals” to manage aging effects where 

the GALL Report, Rev. 1 recommended a license commitment for PWR internals. The 

revised GALL Report refers to MRP-227 as supplemented by the technical aspects that 

the staff deems appropriate.

 Using the new AMP XI.M11B, “Cracking of Nickel-Alloy Components and Loss of 

Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary 

Components (PWRs only)” to manage aging effects where the GALL Report, Rev. 1 

recommended a license commitment for nickel-alloy components. 

 The sampling methodology in AMP XI.M32, “One-Time Inspection,” and AMP XI.M33, 

“Selective Leaching,” were revised.
NUREG-1950 II-2 April 2011

 The Time-Limited Aging Analyses (TLAA), X.M1, “Fatigue Monitoring,” was revised to 

include specific guidance for calculating environmentally-adjusted cumulative usage 

factor (CUF) for nickel alloys (NUREG/CR-6909), and the need to confirm that the 

NUREG/CR-6260 locations have been evaluated for the effects of the reactor coolant 

environment on fatigue usage to ensure that they bound plant-specific locations exposed 

to water environment that may be more limiting than those considered in NUREG/CR6260. 

 Removing structural bolting from the scope of mechanical AMP XI.M18, “Bolting 

Integrity” and including it in the scope of structural AMPs; creating separate AMR lines to 

address structural bolting. 

 AMP XI.M3, “Reactor Head Closure Stud Bolting,” was revised to clarify the term "stable 

lubricants" by drawing attention to molybdenum disulfide (MoS2). 

 AMP XI.M9, “BWR Vessel Internals,” added the thermal aging and neutron irradiation 

embrittlement of PH martensitic stainless steel (PH 17-4 and 15-5 SS) and martensitic 

stainless steel, and the irradiation embrittlement of X-750 alloy.

 For steam generator divider plates the effectiveness of the chemistry control program 

should be verified to ensure that cracking due to Primary Water Stress Corrosion 

Cracking (PWSCC) is not occurring. 

 For steam generator tube-to-tubesheet welds exposed to reactor coolant with Alloy 

600/82/182 tubesheet cladding, a plant-specific AMP is evaluated, along with the 

primary water chemistry program, on a case-by-case basis to ensure that an adequate 

program will be in place for the management of cracking due to PWSCC,

 AMP XI.M35, “One-time Inspection of ASME Code Class 1 Small Bore-Piping,” the

program scope was clarified to include socket welds. The AMP is applicable for plants 

that have not experienced cracking, or that have effectively mitigated cracking through 

design changes, otherwise a plant specific program is needed. Included alternative to 

use opportunistic destructive examination (on a sample basis) for socket welds, and 

clarified socket weld volumetric examinations. 

 AMP XI.S1, “ASME Section XI, Subsection IWE,” was revised to incorporate aspects 

related to monitoring MK1 drywell corrosion and augment ASME Code IWE 

requirements to include surface examination of components that are subject to cyclic 

loading but have no current licensing basis fatigue analysis.

 AMP XI.S5, “Masonry Walls,” revised to specify an inspection frequency of once every 

five years. 

 AMP XI.S6, “Structures Monitoring,” was revised to include recommended frequency of 

inspection for the in-scope structures, settlement monitoring, and inspection of 

inaccessible below grade concrete. Also included provisions for monitoring of ground 

water chemistry. And clarified the use of relevant codes and standards, and 

incorporated monitoring criteria for structural bolting, and elastomeric vibration isolation 

elements. 

 AMP XI.E3, “Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental 

Qualification Requirements,” was revised to go down to 480v cables. The inspection 

frequency for manholes was revised and includes event driven inspections. Revised to 

include energized and de-energized cables. Cable testing frequency revised to not 

exceed 6 years. 
April 2011 II-3 NUREG-1950

 Adding, as appropriate, additional materials, such as asbestos cement piping, high 

density polyethylene (HDPE), fiberglass, superaustenitic or precipitation-hardened 

stainless steel, titanium, and flamastic fire-proofing to AMR items and to the scope of the 

AMPs. 

 Changing many recommendations for plant-specific AMPs in the GALL Report, Rev. 1 to 

generic AMPs in Rev. 2; these include:

o Stainless steel components exposed to condensation, diesel exhaust, or outdoorair are now managed by AMPs XI.M36, “External Surfaces Monitoring of 

Mechanical Components,” or XI.M38, “Inspection of Internal Surfaces in 

Miscellaneous Piping and Ducting Components” 

o Aluminum and copper alloy components exposed to condensation are now 

managed by the AMP XI.M38, “Inspection of Internal Surfaces in Miscellaneous 

Piping and Ducting Components” 

o Elastomeric components in all environments are now managed by AMPs XI.M36, 

“External Surfaces Monitoring of Mechanical Components,” XI.M38, “Inspection 

of Internal Surfaces in Miscellaneous Piping and Ducting Components,” XI.M26, 

“Fire Protection,” XI.S1, “ASME Section XI, Subsection IWE,” XI.S4, “10 CFR 

Part 50, Appendix J,” or XI.E4, “Metal Enclosed Bus,” depending on the 

components. Manual manipulation of polymeric materials is included.

o Neutron-absorbing materials other than Boraflex are now managed by the AMP

XI.M40, “Monitoring of Neutron-Absorbing Materials Other than Boraflex“ 

o Piping and tanks exposed to soil are now managed by the AMP XI.M41, “Buried 

and Underground Piping and Tanks” 

Other generic changes to the GALL Report include:

 Relevant operational experience since the issuance of the GALL Report, Rev. 1 was 

added to Rev. 2. 

 References were updated to reflect changes that have occurred since Revision 1. 

 The AMP content was aligned more closely with the 10-element template for AMPs per 

guidance in the SRP-LR, Appendix A.1. 

 Relevant information from recent license renewal applications and precedents was 

added to Rev. 2. 

Chapter XI, Aging Management Programs, was the focus of significant revisions and additions. 

Changes to Chapter XI include:

 AMP XI.M21, “Closed-Cycle Cooling Water Systems,” is renamed AMP XI.M21A, 

“Closed Treated Water Systems” due to extensive changes to the program in Revision 2. 

 AMP XI.M11A, “Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel 

Closure Heads of PWRs,” became a new AMP, AMP XI.11B, “Cracking of Nickel-Alloy 

Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor 

Coolant Pressure Boundary Components” (PWRs only). 

 The AMP XI.M13, “Thermal Aging and Neutron Irradiation Embrittlement of [Cast 

Austenitic Stainless Steel] CASS,” is subsumed by AMP XI.M9, “BWR Vessel Internals.” 

In addition, AMP XI.M16A, “PWR Vessel Internals,” also addresses thermal aging and 

neutron irradiation embrittlement of CASS. 
NUREG-1950 II-4 April 2011

 AMP XI.M28, “Buried Piping and Tank Surveillance,” and AMP XI.M34, “Buried Piping 

and Tanks Inspection” are combined into a new AMP XI.M41, “Buried and Underground 

Piping and Tanks”. 

 AMP XI.M40, “Monitoring of Neutron-Absorbing Materials Other than Boraflex,“ was 

developed to address neutron absorbing materials other than Boraflex. 

A more detailed summary of these changes along with associated technical bases for making 

the changes are summarized in Section II of this document. 

II.1 New AMR Items in Revision 2 of the GALL Report

As a result of the addition of new materials and environments or the regrouping of components 

or structures, new AMR items have been added to Revision 2. These additions, along with the 

technical bases for the additions, are presented for GALL Report Chapters II, III, IV, V, VII, and 

VIII in Table II-1 through Table II-6 below. (There were no new AMR items added in Revision 2 

of the GALL Report, Chapter VI.) The technical bases for these new items also can be found in 

these tables. 

II.2 Changes to Existing AMR Items in Revision 2 of the GALL Report

Table II-7 through Table II-13 present the changes to the AMR items that have been made in 

the GALL Report, Rev. 2. The following describes the information presented in each column of 

these tables, consistent also with the format in Table II-1 through Table II-6 for new AMR line 

items. 

Column Heading Description

New AMR Item No. Identifies the item number in GALL Chapters II through VIII 

presenting the detailed information summarized by this row. 

Using II.B1.2.CP-114 as an example: The first Roman 

numeral presents the GALL Chapter (II) which is followed by 

the subchapter (B2.1). The following letter identifies the 

discipline(s) that the precedent (P) is associated with (i.e., 

“A” for Auxiliary Systems, “E” for Engineered Safety 

Features Systems, “L” for Electrical Systems, R” for Reactor 

Coolant Systems, “T” for “Structures and Component 

Supports, “S” for Steam and Power Conversion Systems, 

and “C” for Containment Structures). The second letter “P” 

identifies that there is a precedent for the MEAP 

combination. This nomenclature convention is found 

throughout NUREGs-1800 and -1801.

Structure and/or 

Component

Identifies the NPP structure or components to which the row 

(aka AMR line-item) applies

Material Identifies the material of construction for the structure or 

components to which the row applies

Environment Identifies the environmental conditions for the structure or 

components to which the row applies

Aging Effect/ 

Mechanism (AE/AM)

Identifies the applicable aging effect and mechanism(s). See 

Chapter IX of the GALL Report for more information.

Aging Management 

Programs (AMP)

Identifies the time limited aging analysis or aging 

management program found acceptable for properly 

managing the effects of aging. See Chapter X and XI of the 

GALL Report.
April 2011 II-5 NUREG-1950

Technical Basis for 

Change

Provides background on the source of NRC positions 

previously approved (such as pertinent SERs in response to 

earlier LRAs) that provides further information on this 

evaluation. 

A summary of the revisions to mechanical AMR items is presented in Table II-7 through Table 

II-10. The revisions to structural AMR items are summarized in Table II-11 and Table II-12. The 

revisions to electrical AMR items are summarized in Table II-13. Those cells that have been 

changed are shown in bold.

Note: In Table II-7, changed cells are not shown in bold for Revision 2 AMR item numbers with 

prefixes IV.B2, IV.B3, and IV.B4. These are AMR items related to PWR reactor vessel internals 

for Westinghouse, Combustion Engineering, and Babcock and Wilcox reactors, respectively. 

For these AMR items, changes were made based on the staff’s review of recommendations in 

MRP-227, “Materials Reliability Program, Pressurized Water Reactor Internals Inspection and 

Evaluation Guidelines,” Revision 0. These changes typically affected the Structure and/or 

Component, Aging Management Program, and Aging Effect/Mechanism fields to varying 

extents, and no benefit was obtained by showing these fields in bold.

II.2.1 Overview of Changes to Mechanical GALL Tables (Chapters IV, V, VII, and VIII)

The AMR items in Revision 2 of the GALL Report Chapters IV, V, VII, and VIII are divided into 

three categories:

1. AMR items where the MEAP combination has not changed from an equivalent item in 

Revision 1 of the GALL Report and there is also no change in the recommendation 

regarding further evaluation.

2. AMR items where there is some change from Revision 1 of the GALL Report with regard 

to the MEAP combination or the recommendation regarding further evaluation. However, 

there is a clear relationship between the Revision 2 AMR item and a related AMR item in 

Revision 1 of the GALL Report. The changes and the bases for these changed AMR 

items are provided in Table II-7 through Table II-10. 

3. AMR items that are new in Revision 2 of the GALL Report. For these items, there is not 

a clear relationship with a similar item in the same chapter of Revision 1 of the GALL 

Report. The new AMR items and the bases for their addition are provided in Table II-3 

through Table II-6. 

II.2.2 Retired Mechanical AMR Items (GALL Report Chapters IV, V, VII, and VIII)

In addition, a limited number of AMR items that were in the GALL Report, Rev. 1 were retired

(deleted), without being replaced by a related item. These are tracked in NUREG-1950 

Appendix A. For Chapters IV, V, VII, and VIII, the deleted items are as follows:

Chapter IV: A number of AMR items were retired without replacement.
NUREG-1950 II-6 April 2011

Table IV.B1 AMR item IV.B1-12(R-102) was retired and not replaced. This was an AMR item

for stainless steel BWR jet-pump sensing lines (internal to the vessel) exposed 

to reactor coolant, with an aging effect of cracking due to cyclic loading. The 

recommended AMP was previously identified as a plant-specific AMP. The staff 

has previously accepted applicant evaluations showing that this component is 

not in scope for license renewal and a plant-specific AMP is not needed. On this 

basis, the AMR item IV.B1-12(R-102) has not been needed to support license 

renewal applications. 

Table IV.B2, 

VI.B3, and 

VI.B4

A number of AMR items in Tables IV.B2, B3, and B4 were retired without 

replacement when recommendations for aging management of PWR internals 

were added consistent with recommendations in MRP-227, “Materials Reliability 

Program: Pressurized Water Reactor Internals Inspection and Evaluation 

Guidelines,” Revision 0. For some existing lines, a clear relationship based on 

similarity of component description, material, and aging effect was identified 

between GALL Report Revision 1 AMR items and GALL Report Revision 2 

AMR items based on MRP-227 component, material and aging effect 

descriptions. These items are shown in Table II-7, changes to existing items in 

Chapter IV. However, for a number of existing lines, there was sufficient 

difference in component nomenclature and AMR items between Revision 1 

items and Revision 2 items in the GALL Report that no benefit was obtained by 

attempting to relate a Revision 2 item to a retired Revision 1 item. New items 

were created and are shown in Table II-3. Consequently, the Revision 1 item 

was treated as “deleted” (retired without replacement). The following Revision 1 

AMR items were retired without replacement: 

IV.B2-11(R-144); IV.B2-13(R-145); IV.B2-15(R-134); IV.B2-19(R-131); IV.B2-

2(R-123); IV.B2-23(R-139); IV.B2-25(R-136); IV.B2-27(R-119); IV.B2-29(R117); IV.B2-3(R-127); IV.B2-30(R-116); IV.B2-35(R-110); IV.B2-36(R-109); 

IV.B2-37(R-111); IV.B2-38(R-114); IV.B2-39(R-113); IV.B2-4(R-126); IV.B2-

41(R-107); IV.B2-42(R-106); IV.B2-5(R-129); and IV.B2-7(R-121)

IV.B3-1(R-153); IV.B3-10(R-164); IV.B3-11(R-159); IV.B3-12(R-161); IV.B3-

13(R-160); IV.B3-14(R-158); IV.B3-16(R-157); IV.B3-18(R-171); IV.B3-19(R168); IV.B3-20(R-169); IV.B3-21(R-166); IV.B3-26(R-148); IV.B3-27(R-147); 

IV.B3-28(R-146); IV.B3-3(R-152); IV.B3-4(R-151); IV.B3-5(R-150); and IV.B3-

6(R-154)

IV.B4-10(R-193); IV.B4-11(R-195); IV.B4-14(R-197); IV.B4-17(R-187); IV.B4-

18(R-185); IV.B4-19(R-192); IV.B4-2(R-180); IV.B4-20(R-186); IV.B4-22(R209); IV.B4-23(R-211); IV.B4-24(R-212); IV.B4-26(R-213); IV.B4-27(R-208); 

IV.B4-28(R-206); IV.B4-29(R-202); IV.B4-3(R-182); IV.B4-30(R-204); IV.B4-

33(R-207); IV.B4-34(R-172); IV.B4-35(R-174); IV.B4-36(R-173); IV.B4-39(R215); IV.B4-40(R-214); IV.B4-41(R-216); IV.B4-43(R-176); IV.B4-44(R-175); 

IV.B4-45(R-177); IV.B4-46(R-178); IV.B4-5(R-181); IV.B4-6(R-184); IV.B4-8(R199); and IV.B4-9(R-201)
April 2011 II-7 NUREG-1950

Table IV.C1 AMR Item IV.C1-13(R-29) was retired and not replaced. This was an AMR item

for stainless steel or steel pump and valve seal flange closure bolting in an 

environment of “system temperature up to 288oC (550oF),” with an aging effect 

of loss of material due to wear. The recommended AMP was previously 

identified as GALL AMP XI.M18, “Bolting Integrity.” This item is very similar to 

GALL Report Revision 1 AMR Item IV.C1-12(R-26), which was retired and 

replaced with a more encompassing component, material, and environment 

description. Consequently, IV.C1-13(R-29) became redundant to Item 

IV.C1.RP-42, which replaced IV.C1-12(R-26), and VI.C1-13(R-29) was retired 

without being replaced.

Chapter V: No AMR items were retired without replacement.

Chapter VI: AMR Item VI.A-6(LP-03) was retired; however, GALL Rev. 2 Item VI.A.LP-33 

encompasses the retired item.

Chapter VII: No AMR items were retired without replacement.

Chapter VIII: As part of a simplification effort, the reactor type descriptions were deleted after 

the words “Water Chemistry” in AMR items where the “Water Chemistry” 

program was a recommended AMP. The change resulted in some AMR items

becoming identical, where in Revision 1 of the GALL Report the difference 

between two items was caused only by the reactor type description. In Table 

VIII.A, item VIII.A-13(SP-46) became identical to VIII.A-12(SP-43) and was 

retired without replacement; also VIII.A-16(S-06) became identical to VIII.A15(S-04) and was retired without replacement. In Table VIII.C, item VIII.C-4(S06) became identical to VIII.C-3(S-04) and was retired without replacement; 

also item VIII.C-7(S-10) became identical to VIII.C-6(S-09) and was retired 

without replacement. In Table VIII.E, item VIII.E-34(S-10) became identical to 

VIII.E-33(S-09) and was retired without replacement; VIII.E-31(SP-19) also 

became identical to VIII.E-30(SP-17) and was retired without replacement

II.2.2.1 AMR Items for Chapter IV - Reactor Vessel, Internals, and Reactor Coolant 

System 

The public comments that led to the technical changes shown in Table II-7 can be found in 

Table IV-5. 

II.2.2.2 AMR Items for Chapter V - Engineered Safety Systems

The public comments that led to the technical changes shown in Table II-8 can be found in

Table IV-6. 

II.2.2.3 AMR Items for Chapter VII - Auxiliary Systems

The public comments that led to the technical changes shown in Table II-9 can be found in 

Table IV-8. 

II.2.2.4 AMR Items for Chapter VIII - Steam and Power Conversion Systems

The public comments that led to the technical changes shown in Table II-10 can be found in

Table IV-9. 
NUREG-1950 II-8 April 2011

II.2.3 Overview of Changes to Structural GALL Tables (Chapters II-III)

II.2.3.1 General Changes

The AMR items in Revision 2 of the GALL Report Chapters II and III are divided into three 

categories:

1. AMR items where the MEAP combination has not changed from an equivalent item in 

Revision 1 of the GALL Report and there is also no change in the recommendation 

regarding further evaluation.

2. AMR items where there is some change from Revision 1 of the GALL Report with regard 

to the MEAP combination or the recommendation regarding further evaluation. However, 

there is a clear relationship between the Revision 2 AMR item and a related AMR item in 

Revision 1 of the GALL Report. The changes and the basis for these changed AMR 

items are provided in Table II-11 and Table II-12. 

3. AMR items that are new in Revision 2 of the GALL Report. For these lines, there is not a 

clear relationship with a similar item in the same chapter of Revision 1 of the GALL 

Report. The new AMR items and the basis for their addition are provided in Table II-1 

and Table II-2. 

II.2.3.2 AMR Items for Chapter II - Containment Structures

The public comments that led to the technical changes shown in Table II-11 can be found in

Table IV-3. 

II.2.3.3 AMR Items for Chapter III - Structures and Component Supports

The public comments that led to the technical changes shown in Table II-12 can be found in

Table IV-4. 

II.2.4 Overview of Changes to Electrical GALL Tables (Chapter VI)

II.2.4.1 AMR Items for Chapter VI - Electrical Systems

One AMR item was retired without being replaced by a related item. This was an AMR item for 

fuse holder insulation exposed to an adverse localized environment caused by heat, radiation, 

or moisture in the presence of oxygen or >60-year service limiting temperature with an aging 

effect of embrittlement, cracking, melting, discoloration, swelling, or loss of dielectric strength 

leading to reduced insulation resistance (IR); electrical failure/degradation 

(thermal/thermoxidative) of organics/thermoplastics, radiation-induced oxidation, moisture 

intrusion, and ohmic heating. The recommended AMP was previously identified as XI.E1. The 

staff has determined that GALL Rev. 2, item VI.A.LP-33 includes fuse holder insulation under 

electrical cables and connections, which is managed by the same AMP, XI.E1. Therefore, since 

insulation for fuse holders is included under insulation for cable and cable connections, there is 

no need to list fuse holder insulation as a separate item, since it is redundant. 

There were three instances where changes from Revision 1 of the GALL Report relative to new 

MEAP combinations caused new AMR items; notwithstanding, there is a clear relationship 

between the Revision 2 AMR item and its related AMR item in Revision 1 of the GALL Report. 

The changes and the basis for these changed AMR items are provided in Table II-13. 

The public comments that led to the technical changes shown in Table II-13 can be found in

Table IV-7. 
April 2011 II-9 NUREG-1950

II.3 Chapter IX – Definitions

II.3.1 General Changes

Changes are made to Chapter IX to include new structures and components, materials, 

environments, and aging effects/mechanisms, and to help standardize expressions. Changes 

are also made to clarify some of the definitions that were included in Revision 1. Specific 

changes to the definitions for subchapters IX.B through IX.G are summarized in Table II-14

through Table II-19. The public comments that led to the technical changes shown in Table II-14

through Table II-19 can be found in Table IV-10. 

II.4 Chapter X – Time-Limited Aging Analyses (TLAAs) 

Revisions to the TLAAs for mechanical, structural, and electrical analyses are discussed in 

subsections II.4.1 through II.4.3, respectively. A summary of the changes to these analyses is 

shown in Table II-20. Public comments associated with these changes are found in Table IV-11. 

II.4.1 Mechanical TLAA (X.M1) 

 Program Description was updated relative to background basis, assumptions, 

background information on how the program is applied and basis for environmental 

fatigue calculations. 

 Program Description now specifies that formulae for calculating the environmental 

fatigue life correction factors are contained in NUREG/CR-5704 for stainless steel, in 

NUREG/CR-6583 for carbon and low alloy steels, and in NUREG/CR-6909 for carbon 

and low alloy steel, stainless steel, and nickel alloys.

 Scope of Program now specifies that for a set of sample reactor coolant system 

components, the program includes fatigue usage calculations that consider the effects of 

the reactor water environment.

 Preventive Actions was revised to clarify that tracking design basis transients is

considered to be a preventive activity for the TLAA. 

 Detection of Aging Effects was revised to provide a clear basis on how the tracking of 

the cycles (the preventive parameter) would be used to ensure the validity of current 

design basis cumulative usage factor (CUF) fatigue analysis values.

 Monitoring and Trending now clarifies how the program trends the CUF values for ASME 

Code Class 1 reactor coolant pressure boundary components. 

 Operating Experience criteria was updated to include recommendations for fatigue 

analyses in NRC Regulatory Information Summary (RIS) 2008-30.

II.4.2 Structural TLAA (X.S1)

 Monitoring and Trending was revised to include the NRC Regulatory Guide (RG) 1.35.1 

for guidance on trend lines.

 Acceptance Criteria was revised to provide more details on evaluating ASME Code 

inspection results.

II.4.3 Electrical TLAA (X.E1)

In X.E1, the Program Description was revised to clarify that the 60-year environmental 

qualification reanalysis is performed prior to entering the period of extended operation and 

includes 10 CFR 50.49(j) criteria on how the qualification records are maintained for audit 

purposes, and that reanalysis results are verified accordingly.
NUREG-1950 II-10 April 2011

II.5 Chapter XI – Aging Management Programs (AMPs)

II.5.1 Mechanical AMPs (XI.M Series of AMPs) 

Three new AMPs were added to Revision 2:

 XI.M16A, “PWR Vessel Internals”

 XI.M40, “Monitoring of Neutron-Absorbing Materials Other than Boraflex” 

 XI.M41, “Buried and Underground Piping and Tanks”

Two AMPs were eliminated from Revision 2 due to lack of relevance and very limited previous 

usage in submitted LRAs: 

 XI.M14, “Loose Part Monitoring” 

 XI.M15, “Neutron Noise Monitoring”

Three AMPs were eliminated because they are now subsumed by another program: 

 XI.M13, “Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic 

Stainless Steel (CASS),” is subsumed by XI.M9, “BWR Vessel Internals”

 XI.M28, “Buried Piping and Tanks Surveillance,” and XI.M34, “Buried Piping and Tanks 

Inspection,” are subsumed by the new XI.M41, “Buried and Underground Piping and 

Tanks”

Six AMPs were essentially rewritten:

 XI.11B, “Cracking of Nickel-Alloy Components and Loss of Material Due to Boric AcidInduced Corrosion in Reactor Coolant Pressure Boundary Components (PWRs Only)”

 XI.M21A, “Closed Treated Water Systems”

 XI.M31, “Reactor Vessel Surveillance” 

 XI.M35, “One-Time Inspection of ASME Code Class 1 Small-Bore Piping”

 XI.M36, “External Surfaces Monitoring of Mechanical Components” 

 XI.M38, “Inspection of Internal Surfaces in Miscellaneous Piping and Ducting 

Components” 

There are some generic changes made in the mechanical AMPs in the GALL Report, Rev. 2, 

including:

 AMPs were revised to reference the 2004 edition of ASME Code Section XI. In addition, 

a footnote was added referring to the GALL Report, Chapter I, which clarifies the use of 

alternate editions and addenda of the code. The changes, in general, were not changes 

of technical intent. The ASME Code Section XI edition referenced was updated to the 

latest version currently endorsed in 10 CFR 50.55a, and the addition of the footnote 

provides flexibility to accommodate future endorsed editions/addenda of the code.

 Superfluous or redundant information was deleted and some paragraphs were relocated 

from one element to another. There was no change in technical intent. It was revised to 

make the elements consistent with the guidelines of SRP-LR Appendix A.1.2.3 (Aging 

Management Program Elements). 

 Operating Experience and References were updated to include additional information 

available since the issue of GALL Report Revision 1.
April 2011 II-11 NUREG-1950

 A preamble was added to Chapter XI to provide guidance on use of later 

editions/revisions of various industry documents, and to aid applicants in the 

development of their license renewal applications.

 Preventive Actions for all condition monitoring programs that recommend maintenance 

of water chemistry were revised to ensure consistency between AMPs.

A summary of specific changes to the 36 mechanical AMPs is shown in Table II-21, along with 

their technical bases. The public comments that resulted in these changes are found in Table 

IV-12. 

II.5.2 Structural AMPs (XI.S Series of AMPs) 

There are some generic changes made in the structural AMPs in the GALL Report, Rev. 2, 

including:

 Structural and high-strength structural bolting was removed from the scope of AMP 

XI.M18, “Bolting Integrity,” and included in the scope of the XI.S1, XI.S3, XI.S6 and 

XI.S7 AMPs, along with the appropriate recommendations from preventive actions and 

detection of aging elements.

 AMR items for structural and high-strength structural bolting associated with AMPs 

XI.S1, XI.S3, XI.S6, and XI.S7 were included in a manner similar to pressure-retaining 

bolting associated with the XI.M18 AMP.

 AMPs were revised to reference the 2004 edition of ASME Code Section XI. In addition, 

a footnote was added referring to the GALL Report, Chapter I, which clarifies the use of 

alternate editions and addenda of the code. The changes, in general, were not changes 

of technical intent. The ASME Code Section XI edition referenced was updated to the 

latest version currently endorsed in 10 CFR 50.55a, and the addition of the footnote 

provides flexibility to accommodate future endorsed editions/addenda of the code.

 Superfluous material was deleted and some paragraphs were relocated from one 

element to another. There was no change in technical intent. It was revised to make the 

elements consistent with the guidelines of SRP-LR Appendix A.1.2.3 (Aging 

Management Program Elements).

 Operating Experience and References were updated to include additional information 

available since the issue of GALL Report Revision 1.

 A preamble was added to Chapter XI to provide guidance on use of later 

editions/revisions of various industry documents, and to aid applicants in the 

development of their license renewal applications.

A summary of specific changes to the eight structural AMPs and their technical bases is shown 

in Table II-22. The public comments that resulted in these changes are found in Table IV-13. 

II.5.3 Electrical AMPs (XI.E Series of AMPs) 

There are some generic changes made in the electrical AMPs in the GALL Report, Rev. 2, 

including:

 Superfluous material was deleted and some paragraphs were relocated from one 

element to another. There was no change in technical intent. It was revised to make the 

elements consistent with the guidelines of SRP-LR Appendix A.1.2.3 (Aging 

Management Program Elements). 
NUREG-1950 II-12 April 2011

 Definitions and terminology were clarified for consistency within each AMP as applicable 

and with the other electrical AMPs.

 Operating Experience and References were updated to include additional information 

available since the issue of GALL Report Revision 1.

 A preamble was added to Chapter XI to provide guidance on use of later 

editions/revisions of various industry documents, and to aid applicants in the 

development of their license renewal applications.

A summary of the specific technical changes to the six electrical AMPs and their technical bases 

is presented in Table II-23. The public comments that resulted in these changes are found in

Table IV-14. 

II.6 Overview of Changes to GALL Chapter 1, Rev. 1 – Application of the ASME Code 

A summary of changes to Chapter I of the GALL Report and their technical bases is shown in

Table II-24. The public comments that resulted in these changes are found in Table IV-2. 

II.7 Explanation of Tables II-1 through II-13

Table II-1 through Table II-13 present the new AMR items that were added and the existing 

AMR items that were changed in the GALL Report, Rev. 2. The first column in Table II-1 

through Table II-6, “New AMR Item No.”, represents the chapter, subchapter, and AMR line-item 

number assigned to each new item that was developed as a result of either a public comment or 

NRC staff recommendations. The last column is labeled “Comment No.” This is a unique, 

automatically generated 3- to 4-digit number that corresponds to an entry in the public 

comments database that the NRC used to manage public comments. The number is useful in 

that it corresponds to a unique line in a table in Section IV of NUREG-1950 that presents the 

public comment that inspired the new AMR item. If the new item was not a result of a public 

comment, the corresponding cell in the Comment No. column will show “N/A.” If the NRC did 

NOT agree with the public comment, as shown in NUREG-1950 Section IV, then that comment 

did not affect the evolution of the new AMR line-item; the corresponding cell in the Comment 

No. column will again show “N/A.” 

Other than the last two columns “Technical Basis for Addition” and “Comment No.”, the tables 

appear as they do in the GALL Report, Rev. 2, with columns 2 through 7 of NUREG-1950 

presenting the same information as columns 3 through 8 of GALL (NUREG-1801). 

A similar protocol holds true for Table II-7 through Table II-13. These tables present changes to 

AMR items that existed in the Rev. 1 version of the GALL Report. The tables show the cells that 

were revised in bold. The first column represents the Rev. 2 AMR item numbers, and also 

references a chapter and subchapter associated with the item. All AMR items that have been 

retired (deleted) as a result of staff recommendations are discussed in Section II.2.2 of this 

document, along with the technical bases for their retirement, and their retirement is not 

presented in these tables. The public comments that inspired the revisions to these items are 

presented in Section IV of this NUREG. As provided, public comments that resulted in AMR 

line-items being retired are also included in Section IV of NUREG-1950.

II.8 Explanation of Tables II-14 through II-25

Table II-14 through Table II-25 summarize the differences between Revision 1 and Revision 2 

for various chapters (such as IX, X, and XI) in the GALL Report. Also see the preceding Section 

II.6. The table title specifies the chapter being discussed. The far right column contains a 

comment number if the change was triggered by a public comment. Otherwise, this column will 

show “N/A” if the change is only the result of staff recommendations. As with previous tables, 

the associated public comments are shown in Section IV of this document. The technical bases 
April 2011 II-13 NUREG-1950

for the changes are presented for each notable technical change in the document. Minor 

changes that have insignificant technical impacts or changes that result from editorial or 

typographical errors in Revision 1 or that constitute rearrangement of technical material are not 

presented in these tables but have been made in the Revision 2 document.

GALL Report, Rev. 2, AMP XI.M41 requires further explanation. Since this AMP is newlygenerated for Revision 2, there are no changes that were made to Revision 1. However, a draft 

of this AMP was issued for public comment and several sets of comments were received, 

resulting in several revisions to the May 2010 draft. The NRC solicited public comments on all 

drafts of this AMP. Section IV catalogues all public comments received on all versions of 

XI.M41. 
NUREG-1950 II-14 April 2011

Table II-1. New AMR Items Added in Revision 2 of the GALL Report, Chapter II

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Basis 

II.B1.2.CP114

II.B2.1.CP114

II.B2.2.CP114

Steel 

elements 

(inaccessible 

areas): 

support skirt

Steel Concrete None None No

The support skirt is 

embedded in concr

located in air-indoo

and not subject to a

chemical attack. Th

and AMP of none a

with GALL Rev.1, I

II.A3.CP-148

II.B4.CP-148

Pressureretaining 

bolting

Steel

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.S1, 

“ASME 

Section XI, 

Subsection 

IWE”

No

Pressure-retaining 

bolting is identified 

component for con

mechanical system

effects/mechanism

are appropriate for 

material/environme

and found within th

Report. XI.S1, “AS

Subsection IWE,” a

containment pressu

bolting. 

II.A3.CP-150

II.B4.CP-150

Pressureretaining 

bolting

Any Any 

environment

Loss of 

preload due 

to selfloosening

XI.S1, 

“ASME 

Section XI, 

Subsection 

IWE,” and 

XI.S4, 

“10 CFR 

Part 50, 

Appendix J”

No

Pressure-retaining 

bolting is identified 

component for con

mechanical system

effects/mechanism

are appropriate for 

material/environme

and found within th

Report. XI.S1, “AS

Subsection IWE,” a

containment pressu

bolting.
April 2011 II-15 NUREG-1950

Table II-1. New AMR Items Added in Revision 2 of the GALL Report, Chapter II

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Basis 

II.A3.CP-152

II.B4.CP-152

Service Level 

I coatings Coatings Air – indoor, 

uncontrolled 

Loss of 

coating 

integrity due 

to blistering, 

cracking, 

flaking, 

peeling, 

physical

damage

XI.S8, 

“Protective 

Coating 

Monitoring 

and 

Maintenance”

No

Service Level I coa

in areas inside the 

containment where 

failure could advers

operation of post-a

systems and thereb

shutdown. The ma

requires that licens

the effectiveness o

for protective coatin

scope (as discrete 

components or as 

system, structure o

(SSC)), or demons

performance or con

effectively controlle

performance of app

preventive mainten

accordance with 10 

50.65(a)(1) or (a)(2

appropriate.

RG 1.54, “Quality A

Requirements for P

Coatings Applied to 

Nuclear Power Pla

issued to describe 

method for comply

NRC's quality assu

requirements with r

protective coatings 

ferritic steels, stain

coated (galvanized

concrete, or mason

water-cooled nucle
NUREG-1950 II-16 April 2011

Table II-1. New AMR Items Added in Revision 2 of the GALL Report, Chapter II

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Basis 

plants. The presum

protective coatings 

guidelines would no

over the design life 

However, operating 

shown that undesir

degradation, detac

other types of failur

have occurred as d

NRC Bulletin 96-03

Letter (GL) 04-02. 

coatings from the s

are transported to e

core cooling system 

structures may ma

systems unable to 

requirement in 10 C

50.46(b)(5) to prov

cooling. Monitoring 

Level I Coatings in 

with RG 1.54 Revis

Level I, II, and III P

Coating Applied to 

Plants,” Regulatory 

provides reasonab

that coating failure 

detected and corre

there is an adverse 

safety function of th

accident fluid syste
April 2011 II-17 NUREG-1950

Table II-1. New AMR Items Added in Revision 2 of the GALL Report, Chapter II

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Basis 

II.B1.1.CP44

Steel 

elements: 

drywell 

support skirt

Steel Concrete None None No

The support skirt is 

embedded in concr

located in Air - indo

environment and n

aggressive chemic

aging effect and AM

consistent with GA

VII.J-21 (AP-3). 
NUREG-1950 II-18 April 2011

Table II-2. New AMR Items Added in Revision 2 of the GALL Report, Chapter III

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Recommended

Technical B

Additio

III.A3.TP-219

Steel 

components: 

piles

Steel Ground 

water/soil

Loss of 

material due 

to corrosion

XI.S6, 

“Structures 

Monitoring”

No

The environment 

groundwater/soil 

loss of material d

corrosion in steel 

such as piles; the

Structures Monito

Program is recom

monitor the aging 

III.A6.TP-221 Structural 

bolting Steel

Air – indoor, 

uncontrolled 

or Air – 

outdoor or 

Water – 

flowing or 

standing

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.S7, “RG

1.127, 

Inspection of 

WaterControl 

Structures 

Associated 

with Nuclear 

Power 

Plants,” or 

the Federal 

Energy 

Regulatory 

Commission 

(FERC)/ US 

Army Corp of 

Engineers 

dam 

inspections 

and 

maintenance 

programs.

No

Structural bolting 

as a separate com

consistency with 

systems. The agi

effects/mechanis

AMPs are approp

material/environm

combination and 

NUREG-1801.

III.A6.TP-223

Group 6: 

Wooden 

Piles; 

Wood

Air – outdoor 

or Water – 

flowing or 

Loss of 

material; 

change in 

XI.S7, “RG

1.127, 

Inspection of 

No

An approved prec

for the material/e

aging effect, and 
April 2011 II-19 NUREG-1950

Table II-2. New AMR Items Added in Revision 2 of the GALL Report, Chapter III

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Recommended

Technical B

Additio

sheeting standing or 

Ground 

water/soil

material 

properties 

due to 

weathering, 

chemical 

degradation, 

insect 

infestation, 

repeated 

wetting and 

drying, and 

fungal decay

WaterControl 

Structures 

Associated 

with Nuclear 

Power 

Plants,” or 

the FERC/US 

Army Corps 

of Engineers’ 

dam 

inspections 

and 

maintenance 

programs.

combination. As d

in OCGS SER Se

3.0.3.2.2.6, AMP 

acceptable for ma

wood aging effec

period of extende

III.B1.1.TP-226

III.B1.2.TP-226

III.B1.3.TP-226

Structural 

bolting Steel Air – indoor, 

uncontrolled 

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.S3, 

“ASME 

Section XI, 

Subsection 

IWF”

No

Structural bolting 

as a separate com

consistency with 

systems. The agi

effects/mechanis

AMP are appropr

material/environm

combination and 

the GALL Report

III.B1.1.TP-229

III.B1.2.TP-229

III.B1.3.TP-229

Structural 

bolting Any Any 

environment

Loss of 

preload due 

to selfloosening

XI.S3, 

“ASME 

Section XI, 

Subsection 

IWF”

No

Structural bolting 

as a separate com

consistency with 

systems. The agi

effects/mechanis

AMP are appropr

material/environm

combination and 

the GALL Report
NUREG-1950 II-20 April 2011

Table II-2. New AMR Items Added in Revision 2 of the GALL Report, Chapter III

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Recommended

Technical B

Additio

III.B1.1.TP-232

III.B1.2.TP-232

III.B1.3.TP-232

Structural 

bolting

Stainless 

steel Treated water

Loss of 

material due 

to pitting 

and crevice 

corrosion

XI.M2, 

“Water 

Chemistry,” 

and 

XI.S3, 

“ASME 

Section XI, 

Subsection 

IWF”

No

Structural bolting 

as a separate com

consistency with 

systems. The agi

effects/mechanis

AMP are appropr

material/environm

combination and 

the GALL Report

III.B1.1.TP-235

III.B1.2.TP-235

III.B1.3.TP-235

Structural 

bolting

Steel; 

galvanized 

steel

Air – outdoor

Loss of 

material due 

to pitting 

and crevice 

corrosion

XI.S3, 

“ASME 

Section XI, 

Subsection 

IWF”

No

Structural bolting 

as a separate com

consistency with 

systems. The agi

effects/mechanis

AMP are appropr

material/environm

combination and 

the GALL Report

III.A1.TP-248

III.A2.TP-248

III.A3.TP-248

III.A4.TP-248

III.A5.TP-248

III.A6.TP-248

III.A7.TP-248

III.A8.TP-248

III.A9.TP-248

III.B2.TP-248

III.B3.TP-248

III.B4.TP-248

III.B5.TP-248

Structural 

bolting Steel Air – indoor, 

uncontrolled 

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.S6, 

“Structures 

Monitoring”

No

Structural bolting 

as a separate com

consistency with 

systems. The agi

effects/mechanis

AMP are appropr

material/environm

combination and 

the GALL Report
April 2011 II-21 NUREG-1950

Table II-2. New AMR Items Added in Revision 2 of the GALL Report, Chapter III

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Recommended

Technical B

Additio

III.A1.TP-261

III.A2.TP-261

III.A3.TP-261

III.A4.TP-261

III.A5.TP-261

III.A6.TP-261

III.A7.TP-261

III.A8.TP-261

III.A9.TP-261

III.B2.TP-261

III.B3.TP-261

III.B4.TP-261

III.B5.TP-261

Structural 

bolting Any Any 

environment

Loss of 

preload due 

to selfloosening

XI.S6, 

“Structures 

Monitoring”

No

Structural bolting 

as a separate com

consistency with 

systems. The agi

effects/mechanis

AMP are appropr

material/environm

combination and 

within the GALL R

III.A1.TP-274

III.A2.TP-274

III.A3.TP-274

III.A4.TP-274

III.A5.TP-274

III.A7.TP-274

III.A8.TP-274

III.A9.TP-274

III.B2.TP-274

III.B3.TP-274

III.B4.TP-274

III.B5.TP-274

Structural 

bolting

Steel; 

galvanized 

steel

Air – outdoor

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.S6, 

“Structures 

Monitoring”

No

Structural bolting 

as a separate com

consistency with 

systems. The agi

effects/mechanis

AMP are appropr

material/environm

combination and 

within the GALL R

III.A1.TP-300

III.A2.TP-300

III.A3.TP-300

III.A4.TP-300

III.A5.TP-300

III.A7.TP-300

High-strength 

structural 

bolting

Low-alloy 

steel, 

actual 

measured 

yield 

strength 

≥150 ksi 

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Cracking 

due to SCC

XI.S6, 

“Structures 

Monitoring”

No

High-strength stru

bolting was monit

XI.M18, “Bolting I

Rev. 1 of GALL o

Rev.2 of GALL, th

added to the scop
NUREG-1950 II-22 April 2011

Table II-2. New AMR Items Added in Revision 2 of the GALL Report, Chapter III

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Recommended

Technical B

Additio

III.A8.TP-300

III.A9.TP-300

III.B2.TP-300

III.B3.TP-300

III.B4.TP-300

III.B5.TP-300

(1,034 

MPa)

“Structures Monit

III.A4.TP-301 Service Level 

I coatings Coatings Air – indoor, 

uncontrolled 

Loss of 

coating 

integrity due 

to blistering, 

cracking, 

flaking, 

peeling, 

physical 

damage

XI.S8, 

“Protective 

Coating 

Monitoring 

and 

Maintenance”

No

Service Level I co

used in areas ins

reactor containme

the coating failure 

adversely affect t

of post-accident f

and thereby impa

shutdown. The m

rule requires that 

monitor the effect

maintenance for p

coatings within its 

discrete systems 

components or as 

SSC), or demons

their performance 

is being effectivel

through the perfo

appropriate preve

maintenance, in a

with 10 CFR 50.6

(a)(2), as appropr

RG 1.54, “Quality 

Requirements for 

Coatings Applied 

Cooled Nuclear P

Plants,” was issue
April 2011 II-23 NUREG-1950

Table II-2. New AMR Items Added in Revision 2 of the GALL Report, Chapter III

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Recommended

Technical B

Additio

describe an acce

method for comp

NRC's quality ass

requirements with 

protective coating

ferritic steels, sta

zinc-coated (galv

steel, concrete, o

surfaces of water

nuclear power pla

presumption was 

protective coating

these guidelines w

degrade over the 

of the plant. Howe

operating history 

that undesirable d

detachment, and 

of failures of coat

occurred as desc

Bulletin 96-03, an

Detached coating

substrate that are 

to emergency cor

system intake str

make those syste

to satisfy the requ

10 CFR 50.46(b)(

long-term cooling

of the Service Lev

Coatings in accor

RG 1.54 Revision 

Level I, II, and III 

Coating Applied t
NUREG-1950 II-24 April 2011

Table II-2. New AMR Items Added in Revision 2 of the GALL Report, Chapter III

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Recommended

Technical B

Additio

Power Plants,” Re

Position C.4 prov

reasonable assur

coating failure wil

detected and corr

there is an advers

the safety functio

post-accident fluid 

III.A4.TP-304 Concrete: all Concrete Soil

Cracking 

and 

distortion 

due to 

increased 

stress levels 

from 

settlement

XI.S6, 

“Structures 

Monitoring.” 

If a dewatering 

system is 

relied upon 

for control of 

settlement, 

then the 

licensee is to 

ensure 

proper 

functioning of 

the dewatering 

system 

through the 

period of 

extended 

operation.

Yes, if a dewatering system 

is relied upon to 

control 

settlement

Further evaluatio

only if a de-water

is relied upon to c

settlement; otherw

evaluation is not 

because AMP XI.

monitoring concre

cracking including 

distortion due to i

stress levels from 

III.A4.TP-305

Concrete 

(inaccessible 

areas): 

exterior 

above- and Concrete

Water – 

flowing

Increase in 

porosity and 

permeability; 

loss of 

strength due 

Further 

evaluation is 

required to 

determine if a 

plant-specific 

Yes, if leaching 

is observed in 

accessible 

areas that 

impact intended 

ACI 201.2R was d

after some plants 

constructed. Thos

were constructed 
April 2011 II-25 NUREG-1950

Table II-2. New AMR Items Added in Revision 2 of the GALL Report, Chapter III

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Recommended

Technical B

Additio

below-grade; 

foundation

to leaching 

of calcium 

hydroxide 

and 

carbonation

aging 

management 

program is 

needed to 

manage 

increase in 

porosity, and 

permeability 

due to 

leaching of 

calcium 

hydroxide 

and 

carbonation 

of concrete in 

Inaccessible 

Areas. A 

plant-specific 

aging 

management 

program is 

not required if 

(1) There is 

evidence in 

the 

accessible 

areas that the 

flowing water 

has not 

caused 

leaching and 

carbonation, 

or (2) 

Evaluation 

function accordance with A

which provided th

requirements for 

construction of re

concrete structure

included factors f

cement mix propo

slump, aggregate

mixer, mixing time

temperature for d

concrete, which w

addressed in ACI 

Thus, concrete st

constructed to eit

or 201.2R are exp

durable. Since the

standards were u

accessible and in

concrete, it is rea

conclude that lea

calcium hydroxide 

carbonation in ac

areas subject to f

water represents 

condition in inacc

areas.
NUREG-1950 II-26 April 2011

Table II-2. New AMR Items Added in Revision 2 of the GALL Report, Chapter III

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Recommended

Technical B

Additio

determined 

that the 

observed 

leaching of 

calcium 

hydroxide 

and 

carbonation 

in accessible 

areas has no 

impact on the 

intended 

function of 

the concrete 

structure.

III.A5.TP-34 Masonry 

walls: all

Concrete 

block Air – outdoor

Loss of 

material 

(spalling, 

scaling) and 

cracking due 

to freezethaw

XI.S5, 

“Masonry 

Walls”

No

As explained in th

Power Research 

(EPRI) Report 10

“Aging Effects for 

and Structural Co

(Structural Tools)

1, masonry block 

constructed from 

concrete blocks, g

mortar, and may 

be reinforced. Th

effects/mechanis

masonry block wa

generally the sam

of concrete walls. 

walls in this envir

susceptible to los

and cracking due 

thaw. Inspections 
April 2011 II-27 NUREG-1950

Table II-2. New AMR Items Added in Revision 2 of the GALL Report, Chapter III

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Recommended

Technical B

Additio

in accordance wit

masonry wall AM

loss of material a

thus, a further eva

not required.
NUREG-1950 II-28 April 2011

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

IV.D2.RP-162

Steam 

generator

(SG): tube 

bundle 

wrapper and 

associated 

supports and 

mounting 

hardware

Steel

Secondary 

feedwater or 

steam

Loss of 

material 

due to 

erosion, 

general, 

pitting, and 

crevice 

corrosion

XI.M19, 

“Steam 

Generators,” 

and 

XI.M2, 

“Water 

Chemistry”

No

Component and 

combination wa

previously in GA

Need to manage 

component and 

combination has 

identified by NR

IV.A1.RP-165

Top head 

enclosure: 

closure studs 

and nuts

Highstrength, 

low-alloy 

steel

Air with 

reactor 

coolant 

leakage

Loss of 

material 

due to 

general, 

pitting, and 

crevice 

corrosion or 

wear

XI.M3, 

“Reactor 

Head Closure 

Stud Bolting”

No

Added for BWR

Revision 1 item 

material due to 

and crevice corr

viable aging me

low alloy steel in 

reactor water le

environment an

identified by BW

(e.g., Hope Cree

Station).

IV.C2.RP-166 Closure 

bolting Steel Air – indoor, 

uncontrolled

Loss of 

material 

due to 

general, 

pitting, and 

crevice 

corrosion

XI.M18, 

"Bolting 

Integrity"

No

This aging effec

component has 

previously Inclu

external surface

consistency with 

Report sub-chap

been added as 

Item

IV.C2.RP-167 Closure 

bolting Steel

Air with 

borated water 

leakage

Loss of 

material 

due to boric 

acid 

XI.M10, 

“Boric Acid 

Corrosion”

No

This aging effec

component has 

previously includ

external surface
April 2011 II-29 NUREG-1950

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

corrosion consistency with 

Report sub-chap

been added as 

item

IV.B1.RP-182

Reactor 

vessel 

internals 

components

PH 

martensitic 

stainless 

steel (17-

4PH and 

15-5PH); 

martensitic

stainless 

steel (SS 

403, 410, 

431, etc.)

Reactor 

coolant 

>250°C 

(>482°F) and 

neutron flux

Loss of 

fracture 

toughness 

due to 

thermal 

aging, 

neutron 

irradiation 

embrittlement

XI.M9, "BWR 

Vessel 

Internals"

No

Precipitation-ha

martensitic stain

and martensitic 

components are 

loss of fracture t

to thermal aging 

irradiation embr

reactor water en

The staff finds A

acceptable to m

aging effect dur

of extended ope

IV.B1.RP-200

Reactor 

vessel 

internals 

components

X-750 

alloy

Reactor 

coolant and 

neutron flux

Loss of 

fracture 

toughness

due to 

neutron 

irradiation 

embrittlement

XI.M9, "BWR 

Vessel 

Internals"

No

Some X-750 rea

components wil

significant end o

neutron fluence

irradiation embr

occur. To addre

irradiation effect

concerns, the B

Reactor Vessel 

Project (BWRVI

new testing prog

X-750 materials

program require

750 will be revis

the results of thi

X-750 jet pump 

managed by BW
NUREG-1950 II-30 April 2011

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

BWRVIP-138. M

repair hardware 

by the repair ve

IV.A1.RP-201

Top head 

enclosure: 

closure studs 

and nuts

Highstrength, 

low-alloy 

steel

Air with 

reactor 

coolant 

leakage

Cumulative 

fatigue 

damage 

due to fatigue

Fatigue is a 

TLAA to be 

evaluated for 

the period of 

extended 

operation. 

See the SRP, 

Chapter 4.3, 

“Metal 

Fatigue,” for 

acceptable 

methods for 

meeting the 

requirements 

of 10 CFR 

54.21(c)(1).

Yes, TLAA

Added for BWR

Revision 1 item 

for PWRs. Cum

damage due to 

reactor top head 

and nuts has be

by BWR applica

aging effect man

(e.g., Hope Cree

Station).

IV.B4.RP-236

Reactor 

vessel 

internal 

components 

with no 

additional 

measures 

Stainless 

steel; 

nickel alloy

Reactor 

coolant and 

neutron flux

Cracking due 

to SCC and 

irradiationassisted 

stress 

corrosion 

cracking

(IASCC)

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M16A, 

“PWR Vessel 

Internals” 

Note: 

Components 

with no 

additional 

measures are 

not uniquely 

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

was added to ge

identify compon

not have aging e

require aging m

accordance with 

described in MR
April 2011 II-31 NUREG-1950

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

identified in 

GALL tables. 

- 

Components 

with no 

additional 

measures are 

defined in 

Section 3.3.1 

of MRP-227, 

"Materials 

Reliability 

Program: 

Pressurized 

Water 

Reactor 

Internals 

Inspection 

and 

Evaluation 

Guidelines"

IV.B4.RP-237

Reactor 

vessel 

internal 

components 

with no 

additional 

measures

Stainless 

steel; 

nickel alloy

Reactor 

coolant and 

neutron flux

Loss of 

fracture 

toughness 

due to 

neutron 

irradiation 

embrittlement

; 

change in 

dimension 

due to void 

swelling; 

XI.M16A, 

“PWR Vessel 

Internals” 

Note: 

Components 

with no 

additional 

measures are 

not uniquely 

identified in 

GALL tables. 

Components 

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

was added to ge

identify compon

not have aging e

require aging m

accordance with 

described in MR
NUREG-1950 II-32 April 2011

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

loss of 

preload 

due to 

thermal and 

irradiation 

enhanced 

stress 

relaxation; 

loss of 

material due 

to wear

with no 

additional 

measures are 

defined in 

Section 3.3.1 

of MRP-227. 

IV.B4.RP-238

Reactor 

vessel 

internal 

components 

(inaccessible 

locations)

Stainless 

steel; 

nickel alloy

Reactor 

coolant and 

neutron flux

Cracking due 

to SCC and 

IASCC

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M16A, 

“PWR Vessel 

Internals”

Yes, if 

accessible 

Primary, 

Expansion, or 

Existing program 

components 

indicate aging 

effects that need 

management

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

IV.B4.RP-239

Reactor 

vessel 

internal 

components 

(inaccessible 

locations)

Stainless 

steel; 

nickel alloy

Reactor 

coolant and 

neutron flux

Loss of 

fracture 

toughness 

due to 

neutron 

irradiation 

embrittlement

; 

change in 

dimension 

due to void 

swelling; 

loss of 

XI.M16A, 

“PWR Vessel 

Internals”

Yes, if 

accessible 

Primary, 

Expansion, or 

Existing program 

components 

indicate aging 

effects that need 

management

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati
April 2011 II-33 NUREG-1950

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

preload 

due to 

thermal and 

irradiation 

enhanced

stress 

relaxation; 

loss of 

material 

due to wear

IV.B2.RP-265

Reactor 

vessel 

internal 

components 

with no 

additional 

measures

Stainless 

steel; 

nickel alloy

Reactor 

coolant and 

neutron flux

Cracking due 

to SCC and 

IASCC

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M16A, 

“PWR Vessel 

Internals” 

Note: 

Components 

with no 

additional 

measures are 

not uniquely 

identified in 

GALL tables. 

Components 

with no 

additional 

measures are 

defined in 

Section 3.3.1 

of MRP-227. 

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

item was added 

identify compon

not have aging e

require aging m

accordance with 

described in MR
NUREG-1950 II-34 April 2011

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

IV.B2.RP-267

Reactor 

vessel 

internal 

components 

with no 

additional

measures 

Stainless 

steel; 

nickel alloy

Reactor 

coolant and 

neutron flux

Loss of 

fracture 

toughness 

due to 

neutron 

irradiation 

embrittlement

; 

change in 

dimension 

due to void 

swelling; 

loss of 

preload

due to 

thermal and 

irradiation 

enhanced

stress 

relaxation; 

loss of 

material due 

to wear

XI.M16A, 

“PWR Vessel 

Internals” 

Note: 

Components 

with no 

additional 

measures are 

not uniquely 

identified in 

GALL tables.

Components 

with no 

additional 

measures are 

defined in 

Section 3.3.1 

of MRP-227. 

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

item was added 

identify compon

not have aging e

require aging m

accordance with 

described in MR

IV.B2.RP-268

Reactor 

vessel 

internal 

components 

(inaccessible 

locations)

Stainless 

steel; 

nickel alloy

Reactor 

coolant and 

neutron flux

Cracking due 

to SCC and 

IASCC

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M16A, 

“PWR Vessel 

Internals” 

Yes, if 

accessible 

Primary, 

Expansion, or 

Existing program 

components 

indicate aging 

effects that need 

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati
April 2011 II-35 NUREG-1950

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

management

IV.B2.RP-269

Reactor 

vessel 

internal 

components 

(inaccessible 

locations)

Stainless 

steel; 

nickel alloy

Reactor 

coolant and 

neutron flux

Loss of 

fracture 

toughness 

due to 

neutron 

irradiation 

embrittlement

; 

change in 

dimension 

due to void 

swelling; 

loss of 

preload 

due to 

thermal and 

irradiation 

enhanced

stress 

relaxation; 

loss of 

material 

due to wear

XI.M16A, 

“PWR Vessel 

Internals” 

Yes, if 

accessible 

Primary, 

Expansion, or 

Existing program 

components 

indicate aging 

effects that need 

management

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

IV.B2.RP-296

Control rod 

guide tube 

(CRGT) 

assemblies: 

CRGT guide 

plates (cards)

Stainless 

steel

Reactor 

coolant and 

neutron flux

Loss of 

material due 

to wear

XI.M16A, 

“PWR Vessel 

Internals” 

Primary 

Components 

(identified in 

the "Structure 

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati
NUREG-1950 II-36 April 2011

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

and 

Components" 

column) 

(For 

expansion 

components, 

see AMR line 

item 

IV.B2.RP386)

IV.B2.RP-297

Control rod 

guide tube 

(CRGT) 

assemblies: 

CRGT lower 

flange welds 

(accessible)

Stainless 

steel

Reactor 

coolant and 

neutron flux

Loss of 

fracture 

toughness 

due to 

thermal aging 

and neutron 

irradiation 

embrittlement

XI.M16A, 

“PWR Vessel 

Internals” 

Primary 

components 

(identified in 

the "Structure 

and 

Components" 

column) 

(for 

Expansion 

components 

see AMR 

Items 

IV.B2.RP-290 

and 

IV.B2.RP292)

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati
April 2011 II-37 NUREG-1950

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

IV.B2.RP-302

Thermal 

shield 

assembly: 

thermal 

shield 

flexures 

Stainless 

steel

Reactor 

coolant and 

neutron flux

Cracking due 

to fatigue; 

loss of 

material due 

to wear

XI.M16A, 

“PWR Vessel 

Internals” 

Primary 

components 

(identified in 

the "Structure 

and 

Components" 

column) 

no Expansion 

components

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

IV.B3.RP-306

Reactor 

vessel 

internal 

components 

with no 

additional 

measures

Stainless 

steel; 

nickel alloy

Reactor 

coolant and

neutron flux

Cracking due 

to SCC and 

IASCC

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M16A, 

“PWR Vessel 

Internals” 

Note: 

Components 

with no 

additional 

measures are 

not uniquely 

identified in 

GALL tables. 

Components 

with no 

additional 

measures are 

defined in 

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

item was added 

identify compon

not have aging e

require aging m

accordance with 

described in MR
NUREG-1950 II-38 April 2011

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

Section 3.3.1 

of MRP-227. 

IV.B3.RP-307

Reactor 

vessel 

internal 

components 

with no 

additional 

measures

Stainless 

steel; 

nickel alloy

Reactor 

coolant and 

neutron flux

Loss of 

fracture 

toughness 

due to 

neutron 

irradiation 

embrittlement

; 

change in 

dimension 

due to void 

swelling; 

loss of 

preload 

due to 

thermal and 

irradiation 

enhanced 

stress 

relaxation; 

loss of 

material 

due to wear

XI.M16A, 

“PWR Vessel 

Internals” 

Note: 

Components 

with no 

additional 

measures are 

not uniquely 

identified in 

GALL tables . 

Components 

with no 

additional 

measures are 

defined in 

Section 3.3.1 

of MRP-227. 

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

item was added 

identify compon

not have aging e

require aging m

accordance with 

described in MR

IV.B3.RP-309

Reactor 

vessel 

internal 

components 

(inaccessible 

locations)

Stainless 

steel; 

nickel alloy

Reactor 

coolant and 

neutron flux

Cracking due 

to SCC and 

IASCC

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M16A, 

“PWR Vessel 

Internals” 

Yes, if 

accessible 

Primary, 

Expansion, or 

Existing program 

components 

indicate aging 

effects that need 

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati
April 2011 II-39 NUREG-1950

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

management

IV.B3.RP-311

Reactor 

vessel 

internal 

components 

(inaccessible 

locations)

Stainless 

steel; 

nickel alloy

Reactor 

coolant and 

neutron flux

Loss of 

fracture 

toughness 

due to 

neutron 

irradiation 

embrittlement

; 

change in 

dimension 

due to void 

swelling; 

loss of 

preload 

due to 

thermal and 

irradiation 

enhanced 

stress 

relaxation; 

loss of

material 

due to wear

XI.M16A, 

“PWR Vessel 

Internals” 

Yes, if 

accessible 

Primary, 

Expansion, or 

Existing program 

components 

indicate aging 

effects that need 

management

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

IV.B3.RP-313

Control 

Element 

Assembly 

(CEA): 

shroud 

assemblies: 

remaining 

instrument 

guide tubes 

Stainless 

steel

Reactor 

coolant and 

neutron flux

Cracking due 

to SCC and 

fatigue

XI.M2, 

"Water 

Chemistry," 

and 

XI.M16A, 

"PWR Vessel 

Internals" 

Expansion 

components 

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati
NUREG-1950 II-40 April 2011

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

in CEA 

assemblies

(identified in 

the "Structure 

and 

Components" 

column) 

(for Primary 

components 

see AMR 

Item 

IV.B3.RP312)

IV.B3.RP-322

Core shroud 

assembly (for 

welded core 

shrouds in 

two vertical 

sections): 

Core shroud 

plate-former 

plate weld (a) 

The axial and 

horizontal 

weld seams 

at the core 

shroud reentrant 

corners as 

visible from 

the core side 

of the shroud, 

within six 

inches of the 

central flange 

Stainless 

steel

Reactor 

coolant and 

neutron flux

Cracking due 

to IASCC

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M16A, 

“PWR Vessel 

Internals” 

Primary 

components 

(identified in 

the "Structure 

and 

Components" 

column) 

(for 

Expansion 

components 

see AMR 

Item 

IV.B3.RP323)

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati
April 2011 II-41 NUREG-1950

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

and 

horizontal 

stiffeners, 

and (b) the 

horizontal 

stiffeners in 

shroud plateto-formerplate weld

IV.B3.RP-323

Core shroud 

assembly (for 

welded core 

shrouds in 

two vertical 

sections): 

remaining 

axial welds in 

shroud plateto-formerplate

Stainless 

steel

Reactor 

coolant and 

neutron flux

Cracking due 

to IASCC

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M16A, 

“PWR Vessel 

Internals” 

Expansion 

components 

(identified in 

the "Structure 

and 

Components" 

column) 

(for Primary 

components 

see AMR 

Item 

IV.B3.RP322)

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

IV.B3.RP-324

Core shroud 

assembly (for 

welded core 

Stainless 

steel

Reactor 

coolant and 

neutron flux

Cracking due 

to IASCC

XI.M2, 

“Water 

Chemistry,” 

No

This AMR item i

staff’s review of 

Rev. 0, for this c
NUREG-1950 II-42 April 2011

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

shrouds with 

full-height 

shroud 

plates): axial 

weld seams 

at the core 

shroud reentrant 

corners, at 

the core midplane (+3 feet 

in height) as 

visible from 

the core side 

of the shroud 

and 

XI.M16A, 

“PWR Vessel 

Internals” 

Primary 

components 

(identified in 

the "Structure 

and 

Components" 

column) 

(for 

Expansion 

components 

see AMR 

Item 

IV.B3.RP325)

material, environ

effect combinati

IV.B3.RP-325

Core shroud 

assembly (for 

welded core 

shrouds with 

full-height 

shroud 

plates): 

remaining 

axial welds, 

ribs, and 

rings

Stainless 

steel

Reactor 

coolant and 

neutron flux

Cracking due 

to IASCC

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M16A, 

“PWR Vessel 

Internals” 

Expansion 

components 

(identified in 

the "Structure 

and 

Components" 

column) 

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati
April 2011 II-43 NUREG-1950

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

(for Primary 

components 

see AMR 

Item 

IV.B3.RP324)

IV.B3.RP-326

Core shroud 

assembly (for 

welded core 

shrouds in 

two vertical 

sections): 

gap between 

the upper and 

lower plates

Stainless 

steel

Reactor 

coolant and 

neutron flux

Change in 

dimension 

due to void 

swelling

XI.M16A, 

"PWR Vessel 

Internals" 

Primary 

components 

(identified in 

the "Structure 

and 

Components" 

column) 

no Expansion 

components 

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

IV.B3.RP-331

Lower 

support 

structure: 

core support 

column bolts

Stainless 

steel

Reactor 

coolant and 

neutron flux

Loss of 

fracture 

toughness 

due to 

neutron 

irradiation 

embrittlement

XI.M16A, 

“PWR Vessel 

Internals” 

Expansion 

components 

(identified in 

the "Structure 

and 

Components" 

column) 

(for Primary 

components 

see AMR 

Item 

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati
NUREG-1950 II-44 April 2011

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

'IV.B3.RP315)

IV.B3.RP-333

Core support 

barrel 

assembly: 

lower flange 

weld, if 

fatigue life 

cannot be 

demonstrated 

by TLAA

Stainless 

steel

Reactor 

coolant and 

neutron flux

Cracking due 

to fatigue

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M16A, 

“PWR Vessel 

Internals” 

Primary 

components 

(identified in 

the "Structure 

and 

Components" 

column) 

no Expansion 

components

Yes, evaluate to 

determine the 

potential 

locations and 

extent of fatigue 

cracking

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

addressed in the 

basis and furthe

required column

based on the sta

MRP-227, which 

examination cov

determined by t

specific fatigue 

IV.B3.RP-338

Upper 

internals 

assembly: 

fuel 

alignment 

plate 

(applicable to 

plants with 

core shrouds 

assembled 

with full 

height shroud 

plates), if 

fatigue life 

Stainless 

steel

Reactor 

coolant and 

neutron flux

Cracking due 

to fatigue

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M16A, 

“PWR Vessel 

Internals” 

Primary 

components 

(identified in 

the "Structure 

and 

Components" 

Yes, evaluate to 

determine the 

potential 

locations and 

extent of fatigue 

cracking

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

addressed in the 

basis and furthe

required column

based on the sta

MRP-227, which 

examination cov

determined by t

specific fatigue 
April 2011 II-45 NUREG-1950

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

cannot be 

demonstrated 

by TLAA

column) 

no Expansion 

components

IV.B3.RP-342

Lower 

support 

structure: 

deep beams 

(applicable 

assemblies 

with full 

height shroud 

plates)

Stainless 

steel

Reactor

coolant and 

neutron flux

Cracking due 

to SCC, 

IASCC, and 

fatigue

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M16A, 

“PWR Vessel 

Internals” 

Primary 

components 

(identified in 

the "Structure 

and 

Components" 

column) 

no Expansion 

components

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

IV.B3.RP-343

Lower 

support 

structure: 

core support 

plate 

(applicable to 

plants with a 

core support 

plate), if 

fatigue life 

cannot be 

demonstrated 

by TLAA

Stainless 

steel

Reactor 

coolant and 

neutron flux

Cracking 

due to fatigue

XI.M2, 

“Water 

Chemistry”, 

and 

XI.M16A, 

“PWR Vessel 

Internals” 

Primary 

components 

(identified in 

the "Structure 

and 

Yes, evaluate to 

determine the 

potential 

locations and 

extent of fatigue 

cracking

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

addressed in the 

basis and furthe

recommendatio

item is based on 

review of MRP-2

indicates that ex

coverage is to b

by the plant-spe
NUREG-1950 II-46 April 2011

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

Components" 

column) 

no Expansion 

components 

analysis.

IV.B2.RP-345

Core barrel 

assembly: 

core barrel 

flange

Stainless 

steel

Reactor 

coolant and 

neutron flux

Loss of 

material due 

to wear

XI.M16A, 

“PWR Vessel 

Internals” 

Existing 

Program 

components 

(identified in 

the "Structure 

and 

Components" 

column)

no Expansion 

components

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

IV.B2.RP-346

Upper 

internals 

assembly: 

upper support 

ring or skirt

Stainless 

steel

Reactor 

coolant and 

neutron flux

Cracking due 

to SCC and 

fatigue

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M16A, 

“PWR Vessel 

Internals” 

Existing 

Program 

components 

(identified in 

the "Structure 

and 

Components" 

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati
April 2011 II-47 NUREG-1950

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

column) 

no Expansion 

components 

IV.B4.RP-352

Upper grid 

assembly: 

alloy X-750 

dowel-toupper fuel 

assembly 

support pad 

welds (all 

plants except 

Davis-Besse)

Nickel 

alloy

Reactor 

coolant and 

neutron flux

Cracking 

due to SCC

 XI.M2, 

“Water 

Chemistry,” 

and 

XI.M16A, 

“PWR Vessel 

Internals” 

Expansion 

components 

(identified in 

the "Structure 

and 

Components" 

column) 

(for Primary 

components 

see AMR 

Item 

IV.B4.RP261)

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

IV.B2.RP-354

Baffle-toformer 

assembly: 

baffle-edge 

bolts (all 

plants with 

baffle-edge 

bolts)

Stainless 

steel

Reactor 

coolant and 

neutron flux

Loss of 

fracture 

toughness 

due to 

neutron 

irradiation 

embrittlement

; 

change in 

XI.M16A, 

“PWR Vessel 

Internals” 

Primary 

components 

(identified in 

the "Structure 

and 

Components" 

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati
NUREG-1950 II-48 April 2011

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

dimension 

due to void 

swelling; 

loss of 

preload 

due to 

thermal and 

irradiation 

enhanced

stress 

relaxation

column) 

no Expansion 

components

IV.B2.RP-355

Control rod 

guide tube 

assemblies: 

guide tube 

support pins

Nickel 

alloy

Reactor 

coolant and 

neutron flux

Cracking due 

to SCC and 

fatigue

A plantspecific aging 

management 

program is to 

be evaluated

Yes, plantspecific

MRP-227, Rev. 

that the aging ef

be managed for 

components. Ho

227 does not ide

program to man

effect(s) for thes

Therefore, a pla

program is nece

IV.B2.RP-356

Control rod 

guide tube 

assemblies: 

guide tube 

support pins

Nickel 

alloy

Reactor 

coolant and 

neutron flux

Loss of 

material due 

to wear

A plantspecific aging 

management 

program is to 

be evaluated

Yes, plantspecific

MRP-227, Rev. 

that the aging ef

be managed for 

components. Ho

227 does not ide

program to man

effect(s) for thes

Therefore, a pla

program is nece

IV.B3.RP-357

Incore 

instrumentati

on (ICI): ICI 

thimble tubes 

Zircaloy-4 

Reactor 

coolant and 

neutron flux

Loss of 

material due 

to wear

A plantspecific aging 

management 

program is to 

Yes, plantspecific

MRP-227, Rev. 

that the aging ef

be managed for 

components. Ho
April 2011 II-49 NUREG-1950

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

- lower be evaluated 227 does not ide

program to man

effect(s) for thes

Therefore, a pla

program is nece

IV.B3.RP-358

Core shroud 

assemblies 

(for bolted 

core shroud 

assemblies): 

(a) shroud 

plates and (b) 

former plates

Stainless 

steel

Reactor 

coolant and 

neutron flux

Cracking due 

to IASCC

XI.M2, 

“Water

Chemistry,” 

and 

XI.M16A, 

“PWR Vessel 

Internals” 

Expansion 

components 

(identified in 

the "Structure 

and 

Components" 

column) 

(for Primary 

component 

see AMR 

Line Item 

IV.B3.RP314)

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

IV.B3.RP-359

Core shroud 

assemblies 

(welded): 

(shroud 

plates and (b) 

former plates

Stainless 

steel

Reactor 

coolant and 

neutron flux

Loss of 

fracture 

toughness

due to 

neutron 

irradiation 

embrittlement

XI.M16A, 

“PWR Vessel 

Internals,” 

Primary 

components 

(identified in 

the "Structure 

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati
NUREG-1950 II-50 April 2011

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

; change in 

dimension 

due to void 

swelling

and 

Components" 

column) 

no 

Expansion 

components

IV.B3.RP-360

Core shroud 

assembly (for 

welded core 

shrouds with 

full-height 

shroud 

plates): axial 

weld seams 

at the core 

shroud reentrant 

corners, at 

the core midplane (+3 feet 

in height) as 

visible from 

the core side 

of the shroud 

Stainless 

steel

Reactor 

coolant and 

neutron flux

Loss of 

fracture 

toughness 

due to 

neutron 

irradiation 

embrittlement

XI.M16A, 

"PWR Vessel 

Internals" 

Primary 

components 

(identified in 

the "Structure 

and 

Components" 

column) 

(for 

Expansion 

components 

see AMR 

Items 

IV.B3.RP361)

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

IV.B3.RP-361

Core shroud 

assembly (for 

welded core 

shrouds with 

full-height 

shroud 

plates): 

remaining 

axial welds, 

Stainless 

steel

Reactor 

coolant and 

neutron flux

Loss of 

fracture 

toughness 

due to 

neutron 

irradiation 

embrittlement

XI.M16A, 

"PWR Vessel 

Internals" 

Expansion 

components 

(identified in 

the "Structure 

and 

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati
April 2011 II-51 NUREG-1950

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

ribs, and 

rings

Components" 

column) 

(for Primary 

components 

see AMR 

Items 

IV.B3.RP360)

IV.B3.RP-362

Core support 

barrel 

assembly: 

lower cylinder 

welds

Stainless 

steel

Reactor 

coolant and 

neutron flux

Loss of 

fracture 

toughness 

due to 

neutron 

irradiation 

embrittlement

XI.M16A, 

"PWR Vessel 

Internals" 

Expansion 

components 

(identified in

the "Structure 

and 

Components" 

column) 

(for Primary 

components 

see AMR 

Items 

IV.B3.RP327) 

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

IV.B3.RP-363

Lower 

support 

structure: 

core support 

column

Stainless 

steel

Reactor 

coolant and 

neutron flux

Loss of 

fracture 

toughness 

due to 

neutron 

irradiation 

embrittlement

XI.M16A, 

"PWR Vessel 

Internals" 

Expansion 

components 

(identified in 

the "Structure 

and 

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati
NUREG-1950 II-52 April 2011

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

Components"

column) 

(for Primary 

components 

see AMR 

Items 

IV.B3RP-327) 

IV.B3.RP-364

Lower 

support 

structure: 

core support 

column

Cast 

austenitic 

stainless 

steel

Reactor 

coolant and 

neutron flux

Loss of 

fracture 

toughness 

due to 

neutron 

irradiation 

and thermal 

embrittlement

XI.M16A, 

"PWR Vessel 

Internals" 

Expansion 

components 

(identified in 

the "Structure 

and 

Components" 

column) 

(for Primary 

components 

see AMR 

Items 

IV.B3RP-327) 

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

IV.B3.RP-365

Lower 

support 

structure: 

core support 

plate

Stainless 

steel

Reactor 

coolant and 

neutron flux

Loss of 

fracture 

toughness 

due to 

neutron 

irradiation 

embrittlement

XI.M16A, 

"PWR Vessel 

Internals" 

Primary 

component 

(identified in 

the "Structure 

and 

Components" 

column) 

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati
April 2011 II-53 NUREG-1950

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

no 

Expansion 

components

IV.B3.RP-366

Lower 

support 

structure: 

deep beams 

(applicable 

assemblies 

with full 

height shroud 

plates)

Stainless 

steel

Reactor 

coolant and 

neutron flux

Loss of 

fracture 

toughness 

due to 

neutron 

irradiation 

embrittlement

XI.M16A, 

“PWR Vessel 

Internals” 

Primary 

components 

(identified in 

the "Structure 

and 

Components" 

column) 

no Expansion 

components

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

IV.D1.RP-372

Steam 

generator 

components: 

shell 

assembly

Steel

Secondary 

feedwater or 

steam

Loss of 

material 

due to 

general, 

pitting, and 

crevice 

corrosion

XI.M2, 

“Water 

Chemistry” 

and 

XI.M32, 

“One-Time 

Inspection”

No

Component and 

combination wa

previously in GA

Need to manage 

component and 

combination has 

identified by NR

IV.B4.RP-375

Core barrel 

assembly: 

internal 

baffle-tobaffle bolts

Stainless 

steel

Reactor 

coolant and 

neutron flux

Cracking due 

to fatigue

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M16A, 

“PWR Vessel 

Internals” 

Expansion 

components 

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati
NUREG-1950 II-54 April 2011

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

(identified in 

the "Structure 

and 

Components" 

column) 

(for Primary 

components 

see AMR 

Item 

IV.B4.RP241)

IV.B4.RP-376

Reactor 

vessel 

internal 

components

Stainless 

steel; 

nickel alloy

Reactor 

coolant and 

neutron flux

Reduction in 

ductility and 

fracture 

toughness 

due to 

neutron 

irradiation

Ductility - 

Reduction in 

Fracture 

Toughness is 

a TLAA 

(BAW-2248A) 

to be 

evaluated for 

the period of 

extended 

operation. 

See the SRPLR Chapter

4.7, "Other 

Plant-Specific 

TLAAs," for 

acceptable 

methods for 

meeting the 

requirements 

of 10 CFR 

54.21(c)(1).

Yes, TLAA

Ductility - Reduc

Fracture Toughn

in accordance w

2248A, Chapter 
April 2011 II-55 NUREG-1950

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

IV.B1.RP-377

Reactor 

vessel 

internals 

components: 

Jet pump 

wedge 

surface

Stainless 

steel

Reactor 

coolant

Loss of 

material due 

to wear

XI.M9, "BWR 

Vessel 

Internals"

No

AMP XI.M9 also 

with managing a

component, mat

environment an

combination.

IV.E.RP-378

Piping, piping 

components, 

and piping 

elements

Nickel 

alloy

Air with 

borated water 

leakage

None None No

GALL Report in

stainless steel m

with borated wa

“None-None.” N

resistant to bora

environment. Al

previously acce

that nickel alloy 

borated water le

environment has 

effects requiring 

IV.B1.RP-381

Reactor 

vessel 

internals 

components

X-750 

alloy

Reactor 

coolant and 

neutron flux

Cracking due 

to 

intergranular 

stress 

corrosion 

cracking

(IGSCC) 

XI.M9, “BWR 

Vessel 

Internals” for 

core plate, 

and 

XI.M2, 

“Water 

Chemistry”

No

X-750 alloy has 

components for 

repair and is sus

IGSCC in a BW

(ADAMS ML091

therefore, aging 

for this material, 

and aging effect 

IV.C2.RP-383

Pressurizer 

relief tank: 

tank shell and 

heads; 

flanges; 

nozzles (nonStainless 

steel; steel 

with 

stainless 

steel 

cladding

Treated 

borated water 

>60°C 

(>140°F)

Cracking due 

to SCC

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M32, 

“One-Time 

No

The staff has pr

the combination 

Chemistry” and 

Inspection” adeq

management of 

pressurizer spra
NUREG-1950 II-56 April 2011

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

ASME 

Section XI 

components)

Inspection” is also a non-AS

class componen

material, environ

aging effect.

IV.D1.RP-385 Tube-to-tube 

sheet welds

Nickel 

alloy

Reactor 

coolant

Cracking due 

to primary 

water stress 

corrosion 

cracking

(PWSCC)

XI.M2, 

“Water 

Chemistry” 

A plantspecific 

program is to 

be evaluated; 

the 

effectiveness 

of the water 

chemistry 

program 

should be 

verified to 

ensure 

cracking is 

not occurring

Yes, plant 

specific 

Added to provid

for tube-to-tube 

recirculating SG

with that for OTS

evaluation is ne

autogenous wel

associated with 

associated weld 

(Alloy 600 SG tu

Alloy 600 tubesh

due to chromium 

below that of All

associated weld 

staff has determ

further evaluatio

specific program 

See precedent i

and Palo Verde 

IV.B2.RP-386

Control rod 

guide tube 

(CRGT) 

assemblies: 

C-tubes and 

sheaths

Stainless 

steel

Reactor 

coolant and 

neutron flux

Loss of 

material due 

to wear

XI.M16A, 

“PWR Vessel 

Internals” 

Expansion 

components 

(identified in 

the "Structure 

and 

Components" 

column) are 

only the 

No

This AMR line-it

based on Note 2 

of MRP-227, Re

component, mat

environment, ag

combination (pr

defense-in-dept
April 2011 II-57 NUREG-1950

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

components 

associated 

with a 

primary 

component 

that 

exceeded the 

acceptance 

limit. 

(for Primary 

components 

see AMR 

Item 

IV.B2.RP296)

IV.B2.RP-387

Core barrel 

assembly: 

core barrel 

axial welds

Stainless 

steel

Reactor 

coolant and 

neutron flux

Cracking 

due to SCC, 

and IASCC 

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M16A, 

“PWR Vessel 

Internals” 

Expansion 

components 

(identified in 

the "Structure 

and 

Components" 

column) 

(for Primary 

components 

see AMR 

No

This AMR result 

the staff’s review 

Rev. 0, for this c

material, environ

effect combinati

defense-in-dept
NUREG-1950 II-58 April 2011

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

Item 

IV.B2.RP276)

IV.B2.RP-388

Core barrel 

assembly: 

core barrel 

axial welds

Stainless 

steel

Reactor 

coolant and 

neutron flux

Loss of 

fracture 

toughness 

due to 

neutron 

irradiation 

embrittlement

XI.M16A, 

“PWR Vessel 

Internals” 

Expansion 

components 

(identified in 

the "Structure 

and 

Components" 

column) 

(for Primary 

components 

see AMR 

Item 

IV.B2.RP276)

No

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

defense-in-dept

IV.B3.RP-389

Core support 

barrel 

assembly: 

lower flange 

weld (if 

fatigue 

analysis 

exists)

Stainless 

steel

Reactor 

coolant and 

neutron flux

Cumulative 

fatigue 

damage due 

to fatigue

Fatigue is a

TLAA to be 

evaluated for 

the period of 

extended 

operation. 

See the SRP, 

Chapter 4.3 

“Metal 

Fatigue,” for 

acceptable 

methods for 

meeting the 

Yes, TLAA

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

in MRP-227 ide

as an acceptabl

which is alternat

inspection recom

MRP-227 for the 

of the aging effe
April 2011 II-59 NUREG-1950

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

requirements 

of 10 CFR 

54.21(c)(1).

IV.B3.RP-390

Lower

support 

structure: 

core support 

plate 

(applicable to 

plants with a 

core support 

plate), if 

fatigue 

analysis 

exists

Stainless 

steel

Reactor 

coolant and 

neutron flux

Cumulative 

fatigue 

damage due 

to fatigue

Fatigue is a 

TLAA to be 

evaluated for 

the period of 

extended 

operation. 

See the SRP, 

Chapter 4.3 

“Metal 

Fatigue,” for 

acceptable 

methods for 

meeting the 

requirements 

of 10 CFR 

54.21(c)(1).

Yes, TLAA

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

in MRP-227 ide

as an acceptabl

which is alternat

inspection recom

MRP-227 for the 

of the aging effe

IV.B3.RP-391

Upper 

internals 

assembly: 

fuel 

alignment 

plate 

(applicable to 

plants with 

core shrouds 

assembled 

with full 

height shroud 

plates), if 

fatigue 

Stainless 

steel

Reactor 

coolant and 

neutron flux

Cumulative 

fatigue 

damage due 

to fatigue

Fatigue is a 

TLAA) to be 

evaluated for 

the period of 

extended 

operation. 

See the SRP, 

Chapter 4.3 

“Metal 

Fatigue,” for 

acceptable 

methods for 

meeting the 

requirements 

Yes, TLAA

This AMR item i

staff’s review of 

Rev. 0, for this c

material, environ

effect combinati

in MRP-227 ide

as an acceptabl

which is alternat

inspection recom

MRP-227 for the 

of the aging effe
NUREG-1950 II-60 April 2011

Table II-3. New AMR Items Added in Revision 2 of the GALL Report, Chapter IV

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

analysis 

exists

of 10 CFR 

54.21(c)(1).
April 2011 II-61 NUREG-1950

Table II-4. New AMR Items Added in Revision 2 of the GALL Report, Chapter V

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical 

Addit

V.B.EP-103

V.C.EP-103

V.D1.EP-103

V.D2.EP-103

Piping, piping 

components, 

and piping 

elements; 

tanks

Stainless 

steel Air – outdoor Cracking 

due to SCC

XI.M36, 

"External 

Surfaces 

Monitoring of 

Mechanical 

Components"

Yes, 

environmental 

conditions need to 

be evaluated

Cracking due to 

occur in stainles

components exp

outdoor air if the 

contains sufficie

(primarily chlorid

Additional detail

SRP-LR discuss

item in SRP-LR 

3.2.2.2.6.

V.B.EP-107

V.C.EP-107

V.D1.EP-107

V.D2.EP-107

Piping, piping 

components, 

and piping 

elements; 

tanks

Stainless 

steel Air – outdoor

Loss of 

material due 

to pitting 

and crevice 

corrosion

XI.M36, 

"External 

Surfaces 

Monitoring of 

Mechanical 

Components"

Yes, 

environmental 

conditions need to 

be evaluated

Loss of material 

and crevice corr

occur in stainles

components exp

outdoor air if the 

contains sufficie

(primarily chlorid

Additional detail

SRP-LR discuss

item in SRP-LR 

3.2.2.2.3.2.

V.E.EP-114

Piping, piping 

components, 

and piping 

elements

Aluminu

m 

Air - outdoor

Loss of 

material due 

to pitting 

and crevice 

corrosion

XI.M36, 

"External 

Surfaces 

Monitoring of 

Mechanical 

Components"

No

GALL Report inc

stainless steel a

alloy piping, pipi

components, an

elements in air o

environment. Sin

nuclear plants a

aluminum piping

components, an

elements in this 

aluminum should 

added. The GAL
NUREG-1950 II-62 April 2011

Table II-4. New AMR Items Added in Revision 2 of the GALL Report, Chapter V

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical 

Addit

provides a prece

because electric

structures comp

chapters VI and 

aluminum mater

components in a

environment. XI

revised to includ

components.

V.F.EP-115

Piping, piping 

components, 

and piping 

elements

Nickel 

alloy

Air with 

borated water 

leakage

None None No

GALL Report inc

stainless steel m

with borated wat

“None-None.” N

material is also r

borated water en

Also, staff has p

accepted in SER

alloy in air with b

leakage environ

aging effects req

management. 

V.E.EP-116 Bolting Copper 

alloy

Any 

environment

Loss of 

preload due 

to thermal 

effects, 

gasket 

creep, and 

selfloosening

XI.M18, 

"Bolting 

Integrity"

No

The GALL Repo

steel and stainle

material; howeve

preload would a

applicable aging 

copper alloy and 

materials. Enviro

specified as "any 

environment" be

aging effect is no

on the external e

to which the bolt
April 2011 II-63 NUREG-1950

Table II-4. New AMR Items Added in Revision 2 of the GALL Report, Chapter V

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical 

Addit

exposed.

V.E.EP-117 Bolting Nickel 

alloy

Any 

environment

Loss of 

preload due 

to thermal 

effects, 

gasket 

creep, and 

selfloosening

XI.M18, 

"Bolting 

Integrity"

No

The GALL Repo

steel and stainle

material; howeve

preload would a

applicable aging 

copper alloy and 

materials. Enviro

specified as "any 

environment" be

aging effect is no

on the external e

to which the bolt

exposed.

V.E.EP-118 Bolting

Steel; 

stainless 

steel

Air – outdoor 

(External)

Loss of 

preload due 

to thermal 

effects, 

gasket 

creep, and 

selfloosening

XI.M18, 

"Bolting 

Integrity"

No

Loss of preload 

effect that is not 

on the external e

Gasket creep an

loosening can oc

connections in a

environment. AM

already exist for 

environment of 

This AMR item i

include the outd

environment. 

V.E.EP-119 Bolting

Steel; 

stainless 

steel

Raw water

Loss of 

preload due 

to thermal 

effects, 

gasket 

creep, and 

XI.M18, 

"Bolting 

Integrity"

No

Various applican

identified steel o

steel bolting in a 

environment. AM

credited to mana

preload in all en
NUREG-1950 II-64 April 2011

Table II-4. New AMR Items Added in Revision 2 of the GALL Report, Chapter V

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical 

Addit

selfloosening

V.E.EP-120 Bolting Stainless 

steel

Treated 

borated water

Loss of 

preload due 

to thermal 

effects, 

gasket 

creep, and 

selfloosening

XI.M18, 

"Bolting 

Integrity"

No

Various applican

identified stainle

bolting in a treat

water environme

XI.M18 is credite

loss of preload i

environments.

V.E.EP-121 Bolting

Steel; 

stainless 

steel

Fuel oil

Loss of 

preload due 

to thermal 

effects, 

gasket 

creep, and 

selfloosening

XI.M18, 

"Bolting 

Integrity"

No

Various applican

identified steel o

steel bolting in a 

environment. AM

credited to mana

preload in all en

V.E.EP-122 Bolting

Steel; 

stainless 

steel

Treated water

Loss of 

preload due 

to thermal 

effects, 

gasket 

creep, and 

selfloosening

XI.M18, 

"Bolting 

Integrity"

No

Various applican

identified steel o

steel bolting in a 

environment. AM

credited to mana

preload in all en

V.E.EP-123

Underground 

piping, piping 

components, 

and piping 

elements

Steel; 

stainless 

steel

Air-indoor, 

uncontrolled 

(External) or 

condensation 

(External)

Loss of 

material due 

to general 

(steel only), 

pitting and 

crevice 

XI.M41, 

“Buried and 

Underground 

Piping and 

Tanks”

No

GALL AMP XI.M

underground pip

defined in GALL 

Chapter IX.B as 

“Underground p

tanks are below 
April 2011 II-65 NUREG-1950

Table II-4. New AMR Items Added in Revision 2 of the GALL Report, Chapter V

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical 

Addit

corrosion are contained w

or vault such tha

contact with air a

located where a

inspection is res

V.F.EP-65 Piping 

elements Glass

Air with 

borated water 

leakage

None None No

No failure due to 

effect of glass co

environments fre

hydrofluoric acid

hot water have b

in industry at the 

temperatures or 

periods of conce

extended operat

Precedent exists 

Valley SER, Sec

3.3.2.3.3, where 

accepted that fo

and environmen

aging effect requ

management du

period of extend

V.F.EP-66 Piping 

elements Glass

Condensation 

(Internal/Exter

nal)

None None No

No failure due to 

effect of glass co

environments fre

hydrofluoric acid

hot water have b

in industry at the 

temperatures or 

periods of conce

extended operat

Precedent exists 

Valley SER, Sec
NUREG-1950 II-66 April 2011

Table II-4. New AMR Items Added in Revision 2 of the GALL Report, Chapter V

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical 

Addit

3.3.2.3.5, where 

accepted that fo

and environmen

aging effect requ

management du

period of extend

V.F.EP-67 Piping 

elements Glass Gas None None No

No failure due to 

effect of glass co

environments fre

hydrofluoric acid

hot water have b

in industry at the 

temperatures or 

periods of conce

extended operat

Report items VII

and VIII.I-15 add

stainless steel, c

and steel materi

environment wit

effects identified

V.F.EP-68 Piping 

elements Glass Closed-cycle 

cooling water None None No

No failure due to 

effect of glass co

environments fre

hydrofluoric acid

hot water have b

in industry at the 

temperatures or 

periods of conce

extended operat

Precedent exists 

Valley SER, Sec

3.3.2.3.6, where 
April 2011 II-67 NUREG-1950

Table II-4. New AMR Items Added in Revision 2 of the GALL Report, Chapter V

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical 

Addit

accepted that fo

and environmen

aging effect requ

management du

period of extend

V.F.EP-82

Piping, piping 

components, 

and piping 

elements

Stainless 

steel

Air – indoor, 

uncontrolled 

(Internal)

None None No

The same MEAP 

exists in the GA

item VII.J-15. Th

difference in this 

proposed item is 

internal instead 

The location of t

environment has 

on aging effects 

is the same. Thi

is also based on 

stainless steels 

resistant to corro

atmospheres in 

of corrosive spe

would be reflect

uncontrolled air) 

Metals Handboo

(p. 65) and 13 (p

Edition, America

Metals Internatio

and 1987. Comp

not subject to m

dry air environm

indoor uncontrol

have limited hum

condensation).

V.F.EP-87 Piping Glass Air – outdoor None None No No failure due to 
NUREG-1950 II-68 April 2011

Table II-4. New AMR Items Added in Revision 2 of the GALL Report, Chapter V

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical 

Addit

elements effect of glass co

environments fre

hydrofluoric acid

and hot water ha

recorded in indu

experience. The 

accepted that fo

and environmen

aging effect requ

management du

period of extend
April 2011 II-69 NUREG-1950

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

VII.J.AP-123

Piping, piping 

components, 

and piping 

elements

Stainless 

steel

Air – indoor, 

uncontrolled 

(Internal/Exter

nal)

None None No

GALL Rev. 

virtually equ

new item in 

combination

difference b

GALL Rev. 

new item is 

internal/exte

external. Th

environment 

on aging eff

material is th

conclusion is 

the fact that 

are highly re

corrosion in 

in the absen

species (wh

reflective of 

uncontrolled 

Metals Hand

3 (p. 65) and 

Ninth Edition

Society for M

Internationa

1987. Comp

subject to m

air environm

uncontrolled 

limited humi

condensatio

VII.J.AP-134 Piping, piping 

components, 

Aluminum Air – dry 

(Internal/ None None No Aluminum hresistance to 
NUREG-1950 II-70 April 2011

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

and piping 

elements

External) air environm

surface fres

then expose

oxide film is 

nanometers 

highly effect

the aluminum 

(Hollingswor

Hunsicker 1

conclusion is 

based on cu

research an

experience, 

will not resu

will be of co

period of ext

operation. T

aluminum ex

air environm

have any ap

effect. Refer

Hollingswort

Hunsicker, H

“Corrosion R

Aluminum a

Alloys,” Met

Ninth Edition

Properties a

Nonferrous A

Metals, pp. 2
April 2011 II-71 NUREG-1950

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

VII.J.AP-135

Piping, piping 

components, 

and piping 

elements

Aluminum

Air – indoor, 

uncontrolled 

(Internal/Exter

nal)

None None No

This MEAP 

exists in the 

item V.F-2. A

consistency 

VII.J.AP-144

Piping, piping 

components, 

and piping 

elements

Copper alloy

Air – indoor, 

uncontrolled 

(Internal/Exter

nal)

None None No

This MEAP 

consistent w

Rev. 1, item 

which is for 

surfaces. Ad

consistency 

internal/exte

VII.G.AP-149 Fire Hydrants Steel Air – outdoor

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.M27, "Fire 

Water 

System"

No

This recomm

specific to th

surfaces of 

fire water sy

steel, outdoo

and loss of m

combination 

with other id

environment

effects comb

component 

in the GALL 

VII.I, “Extern

Components 

Miscellaneo

XI.M27, “Fir

System,” the 

recommend

inspections 

surfaces of f
NUREG-1950 II-72 April 2011

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

VII.G.AP-150

Halon/carbon 

dioxide fire 

suppression 

system 

piping, piping 

components, 

and piping 

elements

Steel

Air – indoor, 

uncontrolled 

(External)

Loss of 

material 

due to 

general, 

pitting, and 

crevice 

corrosion

XI.M26, "Fire 

Protection" No

This recomm

specific to th

surfaces of 

carbon dioxi

suppression 

components

indoor air (e

loss of mate

is consistent 

identical ma

environment

effects comb

component 

in the GALL 

VII.I, “Extern

Components 

Miscellaneo

Fire Protecti

revised to re

inspection o

dioxide pipin

performance 

system.
April 2011 II-73 NUREG-1950

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

VII.J.AP-151

Heat 

exchanger 

components

Titanium

Air – indoor, 

uncontrolled or 

Air – outdoor

None None No

The corrosio

titanium to in

air environm

of the forma

continuous, 

adherent pro

layer on the 

The metal its

reactive, wit

for oxygen, 

damage to t

instantaneou

film on titani

alloys provid

barrier to att

gases in we

conditions, i

nitrogen, NH

H2S. This pr

to temperatu

300oF. The o

resistance o

titanium allo

marine, and 

atmospheric 

been docum

Handbook, N

Volume 13, 

pages 676, 

American So

Internationa

An approved 
NUREG-1950 II-74 April 2011

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

exists for ad

material, env

effect, and p

combination 

Report. As s

Creek SER 

page 3-370, 

accepted the 

titanium in a

environment 

effects that 

managemen

VII.C1.AP-152

Heat 

exchanger 

components 

Titanium 

(American 

Society for 

Raw water None None No

Titanium ha

corrosion re

properties, s
April 2011 II-75 NUREG-1950

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

other than 

tubes 

Testing and 

Materials 

(ASTM) 

Grades 1,2, 

7, 11, or 12 

that 

contains >

5% 

aluminum or 

more than 

0.20% 

oxygen or 

any amount 

of tin)

chlorine-con

with tempera

160°F. The 

resistance o

result of the 

continuous, 

adherent pro

layer on the 

Titanium an

fully resistan

waters (raw, 

or salt water

reasons, los

to general, p

crevice corro

considered a

of titanium a

considered a

water or bra

systems if th

is not ASTM 

11, or 12 an

than 5% alu

than 0.20% 

amount of ti

References: 

Handbook, N

Volume 13, 

page 674, V

“Properties a

Stainless St

Materials an

Purpose Me

and Volume 
NUREG-1950 II-76 April 2011

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

Analysis and 

pages 223-2

Society of M

Internationa

VII.C1.AP-153 Heat 

exchanger 

tubes

Titanium Raw water

Reduction of 

heat transfer 

due to 

fouling

XI.M20, 

"Open-Cycle 

Cooling Water 

System"

No

Instances of 

typically occ

service life o

and are corr

before the e

license perio

macrofouling 

mechanism 

of metals ex

water if ther

for recurrenc

macrofouling 

to be an app

mechanism 

titanium allo

potential for 

the raw wate

and flow vel

than 5 ft/s.

VII.H2.AP-154

Heat 

exchanger 

tubes

Aluminum Lubricating oil

Reduction of 

heat transfer 

due to 

fouling

XI.M39, 

"Lubricating 

Oil Analysis," 

and 

XI.M32, “OneTime 

Inspection”

No

Fouling is an 

mechanism 

heat transfe

exchangers 

oil environm

GALL line V

has been ad

for an additi

exchanger m

susceptible 
April 2011 II-77 NUREG-1950

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

heat transfe

As shown in 

SER Section 

Lubricating O

program and 

Inspection p

consistent w

XI.M32 to ve

effectivenes

Lubricating O

program are 

manage the 

reduction of 

VII.C1.AP-155

Piping, piping 

components, 

and piping 

elements

Reinforced 

concrete, 

asbestos 

cement

Raw water

Cracking 

due to 

aggressive 

chemical 

attack and 

leaching; 

changes in 

material 

properties

due to 

aggressive 

chemical 

attack

XI.M20, 

"Open-Cycle 

Cooling Water 

System"

No

Reinforced c

asbestos ce

pipe/compon

mechanical 

raw water ha

aging effects 

concrete. An 

precedent e

this material

aging effect

combination 

Report. As s

SER page 3

accepted the 

cracking, los

and change

properties fo

concrete an

cement pipe

a raw water 

be managed 
NUREG-1950 II-78 April 2011

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

Cycle Coolin

(XI.M20).

VII.C1.AP-156

Piping, piping 

components, 

and piping 

elements

Reinforced 

concrete, 

asbestos 

cement

Air – outdoor

Cracking 

due to 

aggressive 

chemical 

attack and 

leaching; 

Changes in 

material 

properties

due to 

aggressive 

chemical 

attack

XI.M36, 

"External 

Surfaces 

Monitoring of 

Mechanical 

Components"

No

Reinforced c

asbestos ce

pipe/compon

mechanical 

an outdoor a

have the sam

as structura

approved pr

for adding th

environment

and program 

the GALL R

in Harris SE

the staff acc

position that 

material, an

material pro

reinforced c

asbestos ce

pipe/compon

outdoor air e

be managed 

Ref: ASTM C

Specification 

Cement Pip

VII.C1.AP-157

Piping, piping 

components, 

and piping 

elements

Reinforced 

concrete, 

asbestos 

cement

Soil or 

concrete

Cracking 

due to 

aggressive 

chemical 

XI.M41, 

"Buried and 

Underground 

Piping and 

No

Reinforced c

asbestos ce

pipe/compon

mechanical 
April 2011 II-79 NUREG-1950

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

attack and 

leaching; 

Changes in 

material 

properties

due to 

aggressive 

chemical 

attack

Tanks" buried in a s

have the sam

as structura

approved pr

for adding th

environment

effect comb

GALL Repo

Harris SER 

staff accepte

that cracking

material, an

material pro

appropriate 

reinforced c

asbestos ce

pipe/compon

soil environm

Ref: ASTM C

Specification 

Cement Pip

VII.I.AP-159

Piping, piping 

components, 

and piping 

elements

Copper alloy Air – outdoor 

(External)

Loss of 

material 

due to 

pitting and 

crevice 

corrosion

XI.M36, 

"External 

Surfaces 

Monitoring of 

Mechanical 

Components"

No

An approved 

exists for ad

material, env

effect, and p

combination 

Report. As s

Mile Island (

Section 3.3.

accepted the 

copper alloy 

environment 

of material a
NUREG-1950 II-80 April 2011

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

accepted GA

to manage t

The GALL A

include more 

materials be

VII.J.AP-160

Piping, piping 

components, 

and piping 

elements

Titanium

Air – indoor, 

uncontrolled or 

Air – outdoor

None None No

The corrosio

titanium to in

air environm

of the forma

continuous, 

adherent pro

layer on the 

The metal its

reactive, wit

for oxygen, 

damage to t

instantaneou

film on titani

alloys provid

barrier to att

gases in we

conditions, i

nitrogen, NH

H2S. This pr

to temperatu

300oF. The o

resistance o

titanium allo

marine, and 

atmospheric 

been docum

Handbook, N

Volume 13, 

pages 676, 
April 2011 II-81 NUREG-1950

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

American So

Internationa

An approved 

exists for ad

material, env

effect, and p

combination 

Report. As s

Creek SER 

page 3-370, 

accepted the 

titanium in a

environment 

effects that 

managemen

VII.C1.AP-161

Piping, piping 

components, 

and piping 

elements

Titanium 

(ASTM 

Grades 1,2, 

7, 11, or 12 

that contains 

> 5% 

aluminum or 

more than 

0.20% 

oxygen or 

any amount 

of tin)

Raw water None None No

Titanium ha

corrosion re

properties, s

chlorine-con

with tempera

160°F. The 

resistance o

result of the 

continuous, 

adherent pro

layer on the 

Titanium an

fully resistan

waters (raw, 

or salt water

reasons, los

to general, p

crevice corro
NUREG-1950 II-82 April 2011

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

considered a

of titanium a

considered a

water or bra

systems if th

is not ASTM 

11, or 12 an

than 5% alu

than 0.20% 

amount of ti

References: 

Handbook, N

Volume 13, 

page 674, V

“Properties a

Stainless St

Materials an

Purpose Me

and Volume 

Analysis and 

pages 223-2

Society of M

Internationa

VII.H2.AP-162

Piping, piping 

components, 

and piping 

elements

Aluminum Lubricating oil

Loss of 

material 

due to 

pitting and 

crevice 

corrosion

XI.M39, 

"Lubricating 

Oil Analysis," 

and 

XI.M32, “OneTime 

Inspection”

No

Loss of mate

applicable a

lubricating o

as noted by 

VIII.G-19. A

been added 

an additiona

material sus

of material. A

Beaver Valle
April 2011 II-83 NUREG-1950

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

3.3.2.3.15, L

Analysis pro

One-Time In

program con

GALL AMP 

the effective

Lubricating O

program are 

manage the 

loss of mate

VII.J.AP-166 Piping 

elements Glass Closed-cycle 

cooling water None None No

No failure du

effect of glas

in environme

hydrofluoric 

hot water ha

recorded in 

temperature

periods of co

extended op

Precedent e

Valley SER 

3.3.2.3.6, wh

accepted tha

exists for thi

and no agin

program is r

VII.J.AP-167 Piping 

elements Glass Air – outdoor None None No

No failure du

effect of glas

in an outdoo

environment 

recorded in 

temperature
NUREG-1950 II-84 April 2011

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

VII.C1.AP-171

Piping, piping 

components, 

and piping 

elements

Titanium Soil or 

concrete

Loss of 

material due 

to pitting 

and crevice 

corrosion

XI.M41, 

"Buried and 

Underground 

Piping and 

Tanks"

No

An approved 

exists for ad

material, env

effect, and p

combination 

Report. As s

Susquehann

Station (SSE

3.3.2.3.2, th

the position 

soil environm

adequately m

Buried and U

Piping and T

VII.C1.AP-172

Piping, piping 

components, 

and piping 

elements

Super 

austenitic

Soil or 

concrete

Loss of 

material due 

to pitting 

and crevice 

corrosion

XI.M41, 

"Buried and 

Underground 

Piping and 

Tanks"

No

Super auste

steel is more 

austenitic st

pitting and c

However, a 

available lite

“Super-aust

Piping and T

Applications

Technical R

July 2004) in

pitting and c

can still occu

exposed to p

environment

Therefore, lo

due to pitting 

corrosion ne

managed fo
April 2011 II-85 NUREG-1950

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

VII.C1.AP-173

Piping, piping 

components, 

and piping 

elements

Aluminum Soil or 

concrete

Loss of 

material 

due to 

pitting and 

crevice 

corrosion

XI.M41, 

"Buried and 

Underground 

Piping and 

Tanks"

No

Aluminum p

to pitting and 

corrosion in 

environment

water (e.g., 

Item VII.G.A

moisture typ

controlled in 

environment

piping will al

pitting and c

and loss of m

pitting and c

must also be 

aluminum pi

a soil enviro

VII.C1.AP-174

Piping, piping 

components, 

and piping 

elements

Copper 

Alloy

Soil or 

concrete

Loss of 

material due 

to pitting 

and crevice 

corrosion

XI.M41, 

"Buried and 

Underground 

Piping and 

Tanks"

No

Included in S

The materia

from copper 

to be consis

copper alloy 

VII.C1.AP-175

Piping, piping 

components, 

and piping 

elements

HDPE Soil or 

concrete

Cracking, 

blistering, 

change in 

color due to 

water 

absorption

XI.M41, 

"Buried and 

Underground 

Piping and 

Tanks"

No

Applicants h

material to r

pipe or have 

material in b

environment

been revised 

aging mana

material.

VII.C1.AP-176 Piping, piping 

components, 

and piping 

Fiberglass Soil or 

concrete

Cracking, 

blistering, 

change in 

XI.M41, 

"Buried and 

Underground 

No

Applicants h

material to r

pipe or have 
NUREG-1950 II-86 April 2011

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

elements color due to 

water 

absorption

Piping and 

Tanks"

material in b

environment

been revised 

aging mana

material.

VII.C1.AP-177

Piping, piping 

components, 

and piping 

elements

Concrete 

cylinder 

piping

Soil or 

concrete

Cracking, 

spalling, 

corrosion of 

rebar due to 

exposure of 

rebar

XI.M41, 

"Buried and 

Underground 

Piping and 

Tanks"

No

Applicants h

material to r

pipe or have 

material in b

environment

been revised 

aging mana

material.

VII.C1.AP-178

Piping, piping 

components, 

and piping 

elements

Concrete Soil or 

concrete

Cracking, 

spalling, 

corrosion of 

rebar due to 

exposure of 

rebar

XI.M41, 

"Buried and 

Underground 

Piping and 

Tanks"

No

Applicants h

material to r

pipe or have 

material in b

environment

been revised 

aging mana

material.

VII.C1.AP-209

VII.C2.AP-209

VII.C3.AP-209

VII.D.AP-209

VII.E1.AP-209

VII.E4.AP-209

VII.F1.AP-209

VII.F2.AP-209

VII.F4.AP-209

VII.G.AP-209

VII.H1.AP-209

Piping, piping 

components, 

and piping 

elements; 

tanks

Stainless 

steel Air – outdoor Cracking 

due to SCC

XI.M36, 

"External 

Surfaces 

Monitoring of 

Mechanical 

Components"

Yes, 

environmental 

conditions need 

to be evaluated

Cracking du

occur in stai

components 

outdoor air i

contains suf

(primarily ch

Additional d

SRP-LR dis

item.
April 2011 II-87 NUREG-1950

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

VII.H2.AP-209

VII.C1.AP-221

VII.C2.AP-221

VII.C3.AP-221

VII.D.AP-221

VII.E1.AP-221

VII.E4.AP-221

VII.F1.AP-221

VII.F2.AP-221

VII.F4.AP-221

VII.G.AP-221

VII.H1.AP-221

VII.H2.AP-221

Piping, piping 

components, 

and piping 

elements; 

tanks

Stainless 

steel Air – outdoor

Loss of 

material 

due to 

pitting and 

crevice 

corrosion

XI.M36, 

"External 

Surfaces 

Monitoring of 

Mechanical 

Components"

Yes, 

environmental 

conditions need 

to be evaluated

Loss of mate

pitting and c

could occur 

components 

outdoor air i

contains suf

(primarily ch

Additional d

SRP-LR dis

item.

VII.C1.AP-237

Piping, piping 

components, 

and piping 

elements

Asbestos 

cement pipe

Soil or 

concrete

Cracking, 

spalling, 

corrosion of 

rebar due to 

exposure of 

rebar

XI.M41, 

"Buried and 

Underground 

Piping and 

Tanks"

No

The new AM

“Buried and 

Piping and T

asbestos ce

its scope be

susceptible 

spalling and 

rebar in a so

environment

was added t

Report to be 

AMP XI.M41

VII.C1.AP-238

Piping, piping 

components, 

and piping 

elements

Fiberglass Raw water 

(internal)

Cracking, 

blistering, 

change in 

color due to 

water 

absorption

XI.M20, 

“Open-Cycle 

Cooling Water 

System”

No

Applicants h

material to r

pipe or have 

material in b

environment

been revised 
NUREG-1950 II-88 April 2011

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

aging mana

material.

VII.C1.AP-239

Piping, piping 

components, 

and piping 

elements

HDPE Raw water 

(internal)

Cracking, 

blistering, 

change in 

color due to 

water 

absorption

XI.M20, 

“Open-Cycle 

Cooling Water 

System”

No

Applicants h

material to r

pipe or have 

material in b

environment

been revised 

aging mana

material.

VII.D.AP-240

Piping, piping 

components, 

and piping 

elements

Copper alloy Condensation

Loss of 

material 

due to 

general, 

pitting, and 

crevice 

corrosion

XI.M24, 

“Compressed 

Air Monitoring”

No

GALL Repo

VII.D-4 (AP-

loss of mate

steel expose

condensatio

which is ma

XI.M24. Co

susceptible 

material due 

the condens

environment 

Salem LRA 

a consistent 

GALL Repo

VII.D-4 (AP-

XI.M24 is ad

manage the 

copper alloy

VII.I.AP-241 Bolting Steel Soil

Loss of 

material due 

to general, 

pitting, and 

XI.M41, 

"Buried and 

Underground 

Piping and 

No

AMP XI.M41 

managing th

for this comp

environment 
April 2011 II-89 NUREG-1950

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

crevice 

corrosion

Tanks"

VII.I.AP-242 Bolting Steel Soil Loss of 

preload

XI.M18, 

"Bolting 

Integrity "

No

AMP XI.M18 

managing th

for this comp

environment 

VII.I.AP-243 Bolting Stainless 

Steel Soil

Loss of 

material due 

to pitting 

and crevice 

corrosion

XI.M41, 

"Buried and 

Underground 

Piping and 

Tanks"

No

AMP XI.M41 

managing th

for this comp

environment 

VII.I.AP-244 Bolting Stainless 

Steel Soil Loss of 

preload

XI.M18, 

"Bolting 

Integrity "

No

AMP XI.M18 

managing th

for this comp

environment 

VII.C1.AP-248

Piping, piping 

components, 

and piping 

elements

Concrete; 

cementitious

material

Raw Water

Cracking 

due to 

settling

XI.M20, 

"Open-Cycle 

Cooling Water 

System"

No

Concrete, ce

material was 

GALL Repo

environment 

surface (see 

therefore, th

environment 

item should 

VII.C1.AP-249

Piping, piping 

components, 

and piping 

elements

Concrete; 

cementitious

material

Raw Water

Loss of 

material due 

to abrasion, 

cavitation, 

aggressive 

chemical 

attack, and 

leaching

XI.M20, 

"Open-Cycle 

Cooling Water 

System"

No

Concrete, ce

material was 

GALL Repo

environment 

surface (see 

therefore, th

environment 

item should 
NUREG-1950 II-90 April 2011

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

VII.C1.AP-250

Piping, piping 

components, 

and piping 

elements

Concrete; 

cementitious

material

Raw Water

Changes in 

material 

properties 

due to 

aggressive 

chemical 

attack

XI.M20, 

"Open-Cycle 

Cooling Water 

System"

No

Concrete, ce

material was 

GALL Repo

environment 

surface (see 

therefore, th

environment 

item should 

VII.C1.AP-251

Piping, piping 

components, 

and piping 

elements

Concrete; 

cementitious

material

Air - outdoor

Cracking 

due to 

settling

XI.M36, 

"External 

Surfaces 

Monitoring of 

Mechanical 

Components"

No

Concrete, ce

material was 

GALL Repo

environment

air-outdoor e

environment 

VII.C1.AP-252

Piping, piping 

components, 

and piping 

elements

Concrete; 

cementitious

material

Air - outdoor

Loss of 

material due 

to abrasion, 

cavitation, 

aggressive 

chemical 

attack, and 

leaching

XI.M36, 

"External 

Surfaces 

Monitoring of 

Mechanical 

Components"

No

Concrete, ce

material was 

GALL Repo

environment

air-outdoor e

environment 

VII.C1.AP-253

Piping, piping 

components, 

and piping 

elements

Concrete; 

cementitious

material

Air - outdoor

Changes in 

material 

properties 

due to 

aggressive 

chemical 

attack

XI.M36, 

"External 

Surfaces 

Monitoring of 

Mechanical 

Components"

No

Concrete, ce

material was 

GALL Repo

environment

air-outdoor e

environment 

VII.C2.AP-254 Piping, piping 

components, 

and piping 

Aluminum Closed-cycle 

cooling water

Loss of 

material due 

to pitting 

XI.M21A, 

"Closed 

Treated Water 

No

The GALL R

stainless ste

copper alloy 
April 2011 II-91 NUREG-1950

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

elements and crevice 

corrosion

Systems" same aging 

AMP. Alumi

should also 

same aging 

mechanism 

included for 

material in tr

environment 

therefore, va

cycle cooling 

environment

VII.H2.AP-255

Piping, piping 

components, 

and piping 

elements

Aluminum Closed-cycle 

cooling water

Loss of 

material 

due to 

pitting and 

crevice 

corrosion

XI.M21A, 

"Closed 

Treated Water 

Systems"

No

The GALL R

stainless ste

copper alloy 

same aging 

AMP. Alumi

should also 

same AE/AM 

aluminum m

water enviro

therefore, va

cycle cooling 

environment

VII.I.AP-256

Piping, piping 

components, 

and piping 

elements

Aluminum Air - outdoor

Loss of 

material 

due to 

pitting and 

crevice 

corrosion

XI.M36, 

"External 

Surfaces 

Monitoring of 

Mechanical 

Components"

No

The GALL R

steel, stainle

copper alloy 

piping comp

piping eleme

outdoor env

therefore, al

also be adde

electrical an

component 
NUREG-1950 II-92 April 2011

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

III include al

components 

outdoor env

M36 was rev

all metallic c

VII.C2.AP-257

Piping, piping 

components, 

and piping 

elements

Aluminum Treated water

Loss of 

material due 

to pitting 

and crevice 

corrosion

XI.M2, “Water 

Chemistry,” 

and 

XI.M32, “OneTime 

Inspection”

No

The GALL R

this MEAP c

several syst

this MEAP c

be added to 

VII.H2. Ther

existing line 

VIII.E.SP-90

VII.H2.AP-258

Piping, piping 

components, 

and piping 

elements

Aluminum Treated water

Loss of 

material due 

to pitting 

and crevice 

corrosion

XI.M2, “Water 

Chemistry,” 

and 

XI.M32, “OneTime 

Inspection”

No

The GALL R

this MEAP c

several syst

this MEAP c

be added to 

VII.H2. Ther

existing line 

VIII.E.SP-90

VII.C2.AP-259 Elastomer 

seals and 

components

Elastomers Closed-cycle 

cooling water

Hardening 

and loss of 

strength due 

to elastomer 

degradation

XI.M38, 

"Inspection of 

Internal 

Surfaces in 

Miscellaneous 

Piping and 

Ducting 

Components"

No

Elastomers 

the GALL R

water and ra

environment

added for cl

cooling wate

is acceptabl

closed-cycle 

environment

VII.J.AP-260 Piping, piping 

components, Nickel alloy Air with borated water None None No The GALL Rstainless ste
April 2011 II-93 NUREG-1950

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

and piping 

elements

leakage with borated 

as “None-No

material is a

borated wat

Also, staff h

accepted in 

alloy in air w

water leakag

has no aging 

requiring ma

VII.I.AP-261 Bolting Copper alloy Any 

environment

Loss of 

preload due 

to thermal 

effects, 

gasket 

creep, and 

selfloosening

XI.M18, 

"Bolting 

Integrity"

No

The GALL R

steel and sta

material; how

preload wou

applicable a

copper alloy 

materials. E

specified as 

environment

aging effect 

on the exter

to which the 

exposed.

VII.I.AP-262 Bolting Nickel alloy Any 

environment

Loss of 

preload due 

to thermal 

effects, 

gasket 

creep, and 

selfloosening

XI.M18, 

"Bolting 

Integrity"

No

The GALL R

steel and sta

material; how

preload wou

applicable a

copper alloy 

materials. E

specified as 

environment

aging effect 
NUREG-1950 II-94 April 2011

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

on the exter

to which the 

exposed.

VII.I.AP-263 Bolting

Steel; 

stainless 

steel

Air – outdoor 

(External)

Loss of 

preload due 

to thermal 

effects, 

gasket 

creep, and 

selfloosening

XI.M18, 

"Bolting 

Integrity"

No

Loss of prelo

effect that is 

on the exter

Gasket cree

loosening ca

bolted conne

environment

already exis

environment 

air. This add

an outdoor e

VII.I.AP-264 Bolting

Steel; 

stainless 

steel

Raw water

Loss of 

preload due 

to thermal 

effects, 

gasket 

creep, and 

selfloosening

XI.M18, 

"Bolting 

Integrity"

No

Various app

identified ste

steel bolting 

environment

credited to m

preload in a

VII.I.AP-265 Bolting Stainless 

steel

Treated 

borated water

Loss of 

preload due 

to thermal 

effects, 

gasket 

creep, and 

selfloosening

XI.M18, 

"Bolting 

Integrity"

No

Various app

identified sta

bolting in a t

water enviro

XI.M18 is cr

manage loss 

environment

VII.I.AP-266 Bolting Steel; 

stainless Fuel oil Loss of preload due 

XI.M18, 

"Bolting No Various appidentified ste
April 2011 II-95 NUREG-1950

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

steel to thermal 

effects, 

gasket 

creep, and 

selfloosening

Integrity" steel bolting 

environment

credited to m

preload in a

VII.I.AP-267 Bolting

Steel; 

stainless 

steel

Treated water

Loss of 

preload due 

to thermal 

effects, 

gasket 

creep, and 

selfloosening

XI.M18, 

"Bolting 

Integrity"

No

Various app

identified ste

steel bolting 

water enviro

XI.M18 is cr

manage loss 

environment

VII.J.AP-268

Piping, piping 

components, 

and piping 

elements

PVC Air – indoor, 

uncontrolled None None No

The staff ha

AMR result 

Section 3.3.

states that th

indication in 

PVC or ther

exposed to a

air environm

aging effects 

managemen

low operatin

and historica

resistance d

components

a lack of his

operating ex

indicate that 

to experienc

degradation 
NUREG-1950 II-96 April 2011

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

nonaggress

PVC materia

corrosion ra

but rather re

resistance to 

environment

are exposed

based on ind

experience a

assumption 

and applicat

material, the 

PVC piping 

exposed to a

air environm

aging effects 

managemen

of extended 

VII.J.AP-269

Piping, piping 

components, 

and piping 

elements

PVC Condensation 

(Internal) None None No

The staff ha

AMR result 

Section 3.3.

states that th

indication in 

PVC or ther

exposed to a

air environm

aging effects 

managemen

low operatin

and historica

resistance d

components

a lack of his

operating ex
April 2011 II-97 NUREG-1950

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

indicate that 

to experienc

degradation 

nonaggress

PVC materia

corrosion ra

but rather re

resistance to 

environment

are exposed

based on ind

experience a

assumption 

and applicat

material, the 

PVC piping 

exposed to a

air environm

aging effects 

managemen

of extended 

VII.E5.AP-270

Piping, piping 

components, 

and piping 

elements

Steel; 

stainless 

steel

Raw water 

(potable)

Loss of 

material due 

to general 

(steel only), 

pitting, and 

crevice 

corrosion

XI.M38, 

"Inspection of 

Internal 

Surfaces in 

Miscellaneous 

Piping and 

Ducting 

Components"

No

Potable wat

acceptable f

purposes. A 

environment 

nonsafety-re

scope for 10 

and potable 

considered a 

water (see G

IX). 

GALL AMP 

revised to in
NUREG-1950 II-98 April 2011

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

materials in 

in the scope 

staff finds th

is adequate 

aging effect 

material for 

material, env

aging effect 

VII.E5.AP-271

Piping, piping 

components, 

and piping 

elements

Copper alloy Raw water 

(potable)

Loss of 

material due 

to pitting 

and crevice 

corrosion

XI.M38, 

"Inspection of 

Internal 

Surfaces in 

Miscellaneous 

Piping and 

Ducting 

Components"

No

Potable wat

acceptable f

purposes. A 

environment 

nonsafety-re

scope for 10 

and potable 

considered a 

water (see G

IX). 

GALL AMP 

revised to in

materials in 

in the scope 

staff finds th

is adequate 

aging effect 

material for 

material, env

aging effect 

VII.E5.AP-272

Piping, piping 

components, 

and piping 

elements

Copper alloy Waste water

Loss of 

material due 

to pitting, 

crevice, and 

microbiologi

XI.M38, 

"Inspection of 

Internal 

Surfaces in 

Miscellaneous 

No

The waste w

related com

nonsafety-re

could spatia

safety-relate
April 2011 II-99 NUREG-1950

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

callyinfluenced 

corrosion

(MIC)

Piping and 

Ducting 

Components"

may be in sc

renewal in a

10 CFR 54.4

GALL AMP 

revised to in

materials in 

in the scope 

The staff fin

AMP XI.M38 

manage the 

loss of mate

component, 

environment 

combination

VII.E5.AP-273

Piping, piping 

components, 

and piping 

elements

Stainless 

steel

Condensation 

(Internal)

Loss of 

material due 

to pitting, 

crevice, and 

MIC

XI.M38, 

"Inspection of 

Internal 

Surfaces in 

Miscellaneous 

Piping and 

Ducting 

Components"

No

An approved 

exists for ac

Inspection o

Surfaces in 

Piping and D

Components 

shown in WC

Section 3.3.

staff has acc

position that 

of Internal S

Miscellaneo

Ducting Com

program con

GALL AMP 

adequate to 

aging effect 

material bec

inspections 
NUREG-1950 II-100 April 2011

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

on internal s

surveillance 

maintenance 

XI.M38 is re

other materi

steel.

VII.E5.AP-274

Piping, piping 

components, 

and piping 

elements

Nickel alloy Condensation 

(Internal)

Loss of 

material due 

to pitting, 

crevice, and 

MIC

XI.M38, 

"Inspection of 

Internal 

Surfaces in 

Miscellaneous 

Piping and 

Ducting 

Components"

No

Because co

properties o

similar to sta

nickel alloy i

condensatio

will have an 

loss of mate

stainless ste

in AP-273. A

several SER

accepted the 

GALL AMP 

adequate to 

component, 

environment 

combination

has been re

other materi

steel.

VII.E5.AP-275 Heat 

exchanger 

components

Stainless 

steel Waste Water

Loss of 

material 

due to 

pitting, 

crevice, and 

MIC

XI.M38, 

"Inspection of 

Internal 

Surfaces in 

Miscellaneous 

Piping and 

Ducting 

Components"

No

The waste w

related com

nonsafety-re

could spatia

safety-relate

may be in sc

renewal in a

10 CFR 54.4
April 2011 II-101 NUREG-1950

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

shown in se

staff has acc

position that 

XI.M38 is ad

manage this 

material, env

aging effect 

AMP XI.M38 

revised to in

materials in 

VII.E5.AP-276 Heat 

exchanger 

components

Nickel alloy Waste Water

Loss of 

material due 

to pitting, 

crevice, and 

MIC

XI.M38, 

"Inspection of 

Internal 

Surfaces in 

Miscellaneous 

Piping and 

Ducting 

Components"

No

The waste w

related com

nonsafety-re

could spatia

safety-relate

may be in sc

renewal in a

10 CFR 54.4

shown in se

staff has acc

position that 

XI.M38 is ad

manage this 

material, env

aging effect 

AMP XI.M38 

revised to in

materials in 

VII.J.AP-277

Piping, piping 

components, 

and piping 

elements

Glass Waste Water None None No

The staff ha

accepted tha

water enviro

have an agin
NUREG-1950 II-102 April 2011

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

VII.E5.AP-278

Piping, piping 

components, 

and piping 

elements; 

tanks

Stainless 

steel Waste Water

Loss of 

material due 

to pitting, 

crevice, and 

MIC

XI.M38, 

"Inspection of 

Internal 

Surfaces in 

Miscellaneous 

Piping and 

Ducting 

Components"

No

The waste w

related com

nonsafety-re

could spatia

safety-relate

may be in sc

renewal in a

10 CFR 54.4

shown in se

staff has acc

position that 

XI.M38 is ad

manage this 

material, env

aging effect 

AMP XI.M38 

revised to in

materials in 

VII.E5.AP-279

Piping, piping 

components, 

and piping 

elements; 

tanks

Nickel alloy Waste water

Loss of 

material due 

to pitting, 

crevice, and 

MIC

XI.M38, 

"Inspection of 

Internal 

Surfaces in 

Miscellaneous 

Piping and 

Ducting 

Components"

No

The waste w

related com

nonsafety-re

could spatia

safety-relate

may be in sc

renewal in a

10 CFR 54.4

shown in se

staff has acc

position that 

XI.M38 is ad

manage this 

material, env

aging effect 
April 2011 II-103 NUREG-1950

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

AMP XI.M38 

revised to in

materials in 

VII.E5.AP-280

Piping, piping 

components, 

and piping 

elements; 

tanks

Steel Condensation 

(Internal)

Loss of 

material due 

to pitting, 

crevice, and 

MIC

XI.M38, 

"Inspection of 

Internal 

Surfaces in 

Miscellaneous 

Piping and 

Ducting 

Components"

No

GALL Repo

components 

condensatio

with the sam

such as A-0

several SER

accepted the 

GALL AMP 

adequate to 

component, 

environment 

combination

has been re

other materi

steel.

VII.E5.AP-281

Piping, piping 

components, 

and piping 

elements; 

tanks

Steel Waste water

Loss of 

material due 

to general, 

pitting, 

crevice, and 

MIC

XI.M38, 

"Inspection of 

Internal 

Surfaces in 

Miscellaneous 

Piping and 

Ducting 

Components"

No

The waste w

related com

nonsafety-re

could spatia

safety-relate

may be in sc

renewal in a

10 CFR 54.4

shown in se

staff has acc

position that 

XI.M38 is ad

manage this 

material, env

aging effect 
NUREG-1950 II-104 April 2011

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

AMP XI.M38 

revised to in

materials in 

VII.I.AP-284

Underground 

piping, piping 

components, 

and piping 

elements

Steel;

stainless 

steel; 

copper alloy; 

aluminum

Air-indoor, 

uncontrolled 

(External) or 

condensation 

(External)

Loss of 

material due 

to general 

(steel only), 

pitting and 

crevice 

corrosion

XI.M41, 

“Buried and 

Underground 

Piping and 

Tanks”

No

GALL AMP 

underground 

defined in G

IX.B as “Und

and tanks a

but are cont

tunnel or va

are in conta

are located w

inspection is 

VII.J.AP-96 Piping 

elements Glass

Air with 

borated water 

leakage

None None No

No failure du

effect of glas

in environme

hydrofluoric 

hot water ha

recorded in 

temperature

time periods 

extended op

Precedent e

Valley SER, 

3.3.2.3.5, wh

accepted tha

effects exist 

environment 

managemen

required.

VII.J.AP-97 Piping 

elements Glass Condensation 

(Internal/Exter None None No No failure dueffect of glas
April 2011 II-105 NUREG-1950

Table II-5. New AMR Items Added in Revision 2 of the GALL Report, Chapter VII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technic

Ad

nal) in environme

hydrofluoric 

hot water ha

recorded in 

temperature

time periods 

extended op

Precedent e

Valley SER, 

3.3.2.3.5, wh

accepted tha

effects exist 

environment 

managemen

required.

VII.J.AP-98 Piping 

elements Glass Gas None None No

No failure du

effect of glas

in environme

hydrofluoric 

hot water ha

recorded in 

temperature

time periods 

extended op

GALL Repo

VIII 1-3, and 

stainless ste

and steel ma

environment 

effects ident

aging effects
NUREG-1950 II-106 April 2011

Table II-6. New AMR Items Added in Revision 2 of the GALL Report, Chapter VIII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

VIII.I.SP-104

Piping, piping 

components, 

and piping 

elements

Copper 

alloy 

(≤15% Zn 

and ≤8% 

Al)

Air with 

borated water 

leakage

None None No

The same MEA

exists in the GA

items V.F-5 an

addition of the 

considered edi

the Al limitation 

Revision 1 of th

Report, Table I

VIII.I.SP-108 Piping 

elements Glass Air – outdoor None None No

No failure due 

effect of glass 

an air-outdoor 

have been reco

at the temperat

the time period

extended opera

VIII.BI.SP-110

VIII.B2.SP-110

Piping, piping 

components, 

and piping 

elements

Stainless 

steel

Condensation

(Internal)

Loss of 

material 

due to pitting 

and crevice 

corrosion

XI.M38, 

"Inspection of 

Internal 

Surfaces in 

Miscellaneous 

Piping and 

Ducting 

Components"

No

An approved p

for accepting In

Internal Surfac

Miscellaneous 

Ducting Compo

As shown in W

Section 3.3.2.2

has accepted t

the Inspection 

Surfaces in Mis

Piping and Duc

Components p

consistent with 

XI.M38 is adeq

the aging effec

material becau

inspections are 

internal surface
April 2011 II-107 NUREG-1950

Table II-6. New AMR Items Added in Revision 2 of the GALL Report, Chapter VIII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

surveillance tes

maintenance a

XI.M38 is revis

other materials 

VIII.I.SP-111 Piping 

elements Glass

Condensation 

(Internal/Exter

nal)

None None No

No failure due 

effect of glass 

environments f

hydrofluoric ac

hot water have 

in industry at th

or during the tim

concern for ext

operation. Prec

Beaver Valley 

3.3.2.3.3, wher

accepted that n

exists for this e

no aging mana

program is req

VIII.G.SP-113

Heat 

exchanger 

components 

and tubes

Aluminum Lubricating oil

Reduction of 

heat transfer 

due to fouling

XI.M39, 

"Lubricating 

Oil Analysis," 

and 

XI.M32, “OneTime 

Inspection”

No

An approved p

for accepting O

Inspection prog

verification of e

the Lubricating 

program. As sh

SER, Section 3

staff has accep

that a One-Tim

program consis

AMP XI.M32 is 

verify the effec

Lubricating Oil 

program.
NUREG-1950 II-108 April 2011

Table II-6. New AMR Items Added in Revision 2 of the GALL Report, Chapter VIII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

VIII.G.SP-114

Piping, piping 

components, 

and piping 

elements

Aluminum Lubricating oil

Loss of 

material due 

to pitting and 

crevice 

corrosion

XI.M39, 

"Lubricating 

Oil Analysis," 

and 

XI.M32, “OneTime 

Inspection”

No

An approved p

for accepting O

Inspection prog

verification of e

the Lubricating 

program. As sh

SER, Section 3

staff has accep

that a One-Tim

program consis

AMP XI.M32 is 

verify the effec

Lubricating Oil 

program.

VIII.E.SP-115

VIII.G.SP-115 Tanks Steel Soil or 

Concrete

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.M29, 

“Aboveground 

Metallic 

Tanks”

No

GALL AMP XI.

“Aboveground 

addresses corr

storage tanks a

locations, such 

bottoms suppo

or concrete fou

lines are propo

the aging mana

corrosion of ste

bottoms noted 

VIII.A.SP-118

VIII.B1.SP-118

VIII.B2.SP-118

VIII.C.SP-118

VIII.D1.SP-118

VIII.D2.SP-118

VIII.E.SP-118

Piping, piping 

components, 

and piping 

elements; 

tanks

Stainless 

steel Air – outdoor Cracking due 

to SCC

XI.M36, 

"External 

Surfaces 

Monitoring of 

Mechanical 

Components"

Yes, 

environmental 

conditions need 

to be evaluated

Cracking due to 

occur in stainle

components ex

outdoor air if th

contains suffici

(primarily chlor

details are in th
April 2011 II-109 NUREG-1950

Table II-6. New AMR Items Added in Revision 2 of the GALL Report, Chapter VIII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

VIII.F.SP-118

VIII.G.SP-118

discussion of th

VIII.A.SP-127

VIII.B1.SP-127

VIII.B2.SP-127

VIII.C.SP-127

VIII.D1.SP-127

VIII.D2.SP-127

VIII.E.SP-127

VIII.F.SP-127

VIII.G.SP-127

Piping, piping 

components, 

and piping 

elements; 

tanks

Stainless 

steel Air – outdoor

Loss of 

material due 

to pitting and 

crevice 

corrosion

XI.M36, 

"External 

Surfaces 

Monitoring of 

Mechanical 

Components"

Yes, 

environmental 

conditions need 

to be evaluated

Loss of materia

and crevice co

occur in stainle

components ex

outdoor air if th

contains suffici

(primarily chlor

details are in th

discussion of th

VIII.E.SP-137 Tanks Stainless 

steel

Soil or 

Concrete

Loss of 

material due 

to pitting, and 

crevice 

corrosion

XI.M29, 

“Aboveground 

Metallic 

Tanks”

No

AMP XI.M29 w

include other m

well as steel ta

material is an a

effect to above

stainless steel 

to soil or concr

VIII.E.SP-138 Tanks Stainless 

Steel

Air – outdoor 

(External)

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.M29, 

“Aboveground 

Metallic 

Tanks”

No

AMP XI.M29 w

include other m

well as steel ta

material is an a

effect to above

stainless steel 

to air - outdoor

VIII.E.SP-139 Tanks Aluminum Soil or 

Concrete

Loss of 

material due 

to pitting, and 

crevice 

corrosion

XI.M29,

“Aboveground 

Metallic 

Tanks”

No

AMP XI.M29 w

include other m

well as steel ta

material is an a

effect to above

aluminum tank
NUREG-1950 II-110 April 2011

Table II-6. New AMR Items Added in Revision 2 of the GALL Report, Chapter VIII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

soil or concrete

VIII.E.SP-140 Tanks Aluminum Air – outdoor 

(External)

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.M29, 

“Aboveground 

Metallic 

Tanks”

No

AMP XI.M29 w

include other m

well as steel ta

material is an a

effect to above

aluminum tank

- outdoor.

VIII.H.SP-141 Bolting Steel Soil

Loss of 

material due 

to general, 

pitting and 

crevice 

corrosion

XI.M41, 

"Buried and 

Underground 

Piping and 

Tanks"

No

AMP XI.M41 in

managing this 

this componen

environment co

VIII.H.SP-142 Bolting Steel Soil Loss of 

preload

XI.M18, 

"Bolting 

Integrity"

No

AMP XI.M18 in

managing this 

this componen

environment co

VIII.H.SP-143 Bolting Stainless 

Steel Soil

Loss of 

material due 

to pitting and 

crevice 

corrosion

XI.M41, 

"Buried and 

Underground 

Piping and 

Tanks"

No

AMP XI.M41 in

managing this 

this componen

environment co

VIII.H.SP-144 Bolting Stainless 

Steel Soil Loss of 

preload

XI.M18, 

"Bolting 

Integrity"

No

AMP XI.M18 in

managing this 

this componen

environment co

VIII.H.SP-147 Piping, piping 

components, 

and piping 

Aluminum Air - outdoor

Loss of 

material due 

to pitting and 

crevice 

XI.M36, 

"External 

Surfaces 

Monitoring of 

No

The GALL Rep

steel, stainless 

copper alloy pi

components an
April 2011 II-111 NUREG-1950

Table II-6. New AMR Items Added in Revision 2 of the GALL Report, Chapter VIII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

elements corrosion Mechanical 

Components"

elements in air 

environment; a

also be added. 

and structures 

chapters VI and 

aluminum mate

components in 

environment. X

revised to inclu

components.

VIII.I.SP-148

Piping, piping 

components, 

and piping 

elements

Nickel 

alloy

Air with 

borated water 

leakage

None None No

The GALL Rep

stainless steel 

with borated wa

“None-None.” N

material is also 

borated water e

Also, staff has 

accepted in SE

alloy in air with 

leakage enviro

aging effects re

management. 

VIII.H.SP-149 Bolting Copper 

alloy

Any 

environment

Loss of 

preload 

due to 

thermal 

effects, 

gasket creep, 

and selfloosening

XI.M18, 

"Bolting 

Integrity"

No

The GALL Rep

steel and stain

material; howe

preload would 

applicable agin

copper alloy an

materials. Envi

specified as "a

because this a

dependent on t

environment to 
NUREG-1950 II-112 April 2011

Table II-6. New AMR Items Added in Revision 2 of the GALL Report, Chapter VIII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

bolting is expos

VIII.H.SP-150 Bolting Nickel 

alloy

Any 

environment

Loss of 

preload due 

to thermal 

effects, 

gasket creep, 

and selfloosening

XI.M18, 

"Bolting 

Integrity"

No

The GALL Rep

steel and stain

material; howe

preload would 

applicable agin

copper alloy an

materials. Envi

specified as "a

because this a

dependent on t

environment to 

bolting is expos

VIII.H.SP-151 Bolting

Steel; 

stainless 

steel

Air – outdoor 

(External)

Loss of 

preload due 

to thermal 

effects, 

gasket creep, 

and selfloosening

XI.M18, 

"Bolting 

Integrity"

No

Loss of preload 

effect that is no

the external en

Gasket creep a

loosening can o

connections in 

environment. A

already exist, w

environment be

This adds AMR 

outdoor environ

VIII.I.SP-152

Piping, piping 

components, 

and piping 

elements

PVC Air – indoor, 

uncontrolled None None No

The staff has a

AMR result in V

Section 3.3.2.3

states that ther

indication in the 

PVC or thermo

exposed to an 

air environmen
April 2011 II-113 NUREG-1950

Table II-6. New AMR Items Added in Revision 2 of the GALL Report, Chapter VIII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

aging effects re

management. T

low operating t

and historical g

resistance data 

components, c

lack of historic 

operating expe

that PVC is not 

experience any 

from the nonag

air. PVC mater

display corrosio

metals do, but 

chemical resist

environments t

are exposed. T

on industry exp

assumption of 

and application 

the staff finds t

components ex

interior indoor a

exhibit no agin

requiring mana

period of exten

VIII.I.SP-153

Piping, piping 

components, 

and piping 

elements

PVC Condensation 

(Internal) None None No

PVC materials 

corrosion rates 

but rather rely o

resistance to th

to which they a

Therefore, bas

experience and 

assumption of 
NUREG-1950 II-114 April 2011

Table II-6. New AMR Items Added in Revision 2 of the GALL Report, Chapter VIII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

and application 

the staff finds t

components ex

condensation e

exhibit no agin

requiring mana

period of exten

VIII.H.SP-161

Underground 

piping, piping 

components, 

and piping 

elements

Steel;

stainless

steel;

copper 

alloy;

aluminum

Air-indoor

uncontrolled or

condensation

(external)

Loss of 

material due 

to general 

(steel only), 

pitting and 

crevice 

corrosion

XI.M41, 

“Buried and 

Underground 

Piping and 

Tanks”

No

GALL AMP XI.

underground p

defined in GAL

as “Undergroun

tanks are below 

contained withi

vault such that 

contact with air 

located where 

inspection is re

VIII.I.SP-67 Piping 

elements Glass

Air with 

borated water 

leakage

None None No

No failure due 

effect of glass 

environments f

hydrofluoric ac

hot water has b

industry at the 

during the time 

concern for ext

operation. Prec

Beaver Valley 

3.3.2.3.3, wher

accepted that n

exist for this en

no aging mana

program is req
April 2011 II-115 NUREG-1950

Table II-6. New AMR Items Added in Revision 2 of the GALL Report, Chapter VIII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

VIII.I.SP-68 Piping 

elements Glass Condensation None None No

No failure due 

effect of glass 

condensation e

been recorded 

the temperatur

time periods of 

extended opera

exists in Beave

Section 3.3.2.3

staff has accep

aging effects e

environment an

management p

required.

VIII.I.SP-69 Piping 

elements Glass Gas None None No

No failure due 

effect of glass 

gas environme

recorded in ind

temperatures o

time periods of 

extended opera

exists in Beave

Section 3.3.2.3

staff has accep

aging effects e

environment an

management p

required.

VIII.I.SP-70 Piping 

elements Glass Closed-cycle 

cooling water None None No

No failure due 

effect of glass 

closed-cycle en

been recorded 

the temperatur
NUREG-1950 II-116 April 2011

Table II-6. New AMR Items Added in Revision 2 of the GALL Report, Chapter VIII

New AMR 

Item No.

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Technical Bas

time periods of 

extended opera

exists in Beave

Section 3.3.2.3

staff has accep

aging effects e

environment an

management p

required.

VIII.I.SP-86

Piping, piping 

components, 

and piping 

elements

Stainless 

steel

Air – indoor, 

uncontrolled 

(Internal)

None None No

The same MEA

exists in the GA

item VII.J-15. T

difference in th

proposed item 

internal instead 

The location of 

environment ha

aging effects if 

and environme

same.

VIII.I.SP-93

Piping, piping 

components, 

and piping 

elements

Aluminum

Air – indoor, 

uncontrolled 

(Internal/

External)

None None No

This MEAP com

in the GALL Re

V.F-2. Added h

consistency in 
April 2011 II-117 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

IV.D2.RP153IV.D2-

8(R-224) 

Steam generator 

components: 

shell assembly

Steel

Secondary 

feedwater or 

steam

Loss of material 

due to general, 

pitting, and 

crevice 

corrosion

XI.M2, “Water 

Chemistry,” and 

XI.M32, “OneTime 

Inspection”

No

Fu

wa

"Ye

app

exi

“On

pro

ver

effe

“W

pro

TM

Se

sta

pos

Tim

pro

wit

ade

effe

“W

pro

IV.A2.RP154

IV.A2-

1(RP-13)

Bottommounted 

instrument 

guide tube 

(external to 

bottom head)

Stainless 

steel Reactor coolant Cracking due to

SCC

A plant-specific 

aging 

management 

program is to be 

evaluated

Yes, plantspecific

Th

des

rev

wo

bot

cha

cla

pre

com
NUREG-1950 II-118 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

des

no 

con

IV.B1.RP155

IV.B1-

16(RP18) Steam dryers Stainless 

steel Reactor coolant

Cracking due to 

flow-induced 

vibration

XI.M9, "BWR 

Vessel 

Internals"

No

AM

fro

wit

to A

furt

BW

Dry

Fla

Gu

iss

the 

XI.

IV.C2.RP156

IV.C2-

24(RP22)

Pressurizer 

surge and steam 

space nozzles; 

welds

Nickel alloy Reactor coolant 

or steam

Cracking due to 

PWSCC

XI.M1, “ASME 

Section XI 

Inservice 

Inspection, 

Subsections 

IWB, IWC, and 

IWD,” for Class 

1 components, 

XI.M2, “Water 

Chemistry,” and 

XI.M11B, 

“Cracking of 

Nickel-Alloy 

Components 

and Loss of 

No

Th

has 

inc

XI.

has 

XI.

ren

rep

rec

com

Fin

Re

sup

this 
April 2011 II-119 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

Material Due to 

Boric AcidInduced 

Corrosion in 

RCPB [reactor 

coolant 

pressure 

boundary] 

Components 

(PWRs Only)"

IV.A1.RP157

IV.A1-

8(RP-25)

Reactor Vessel: 

flanges; nozzles; 

penetrations; 

safe ends; 

vessel shells, 

heads and welds

Steel (with 

stainless 

steel or 

nickel-alloy 

cladding); 

stainless 

steel; 

nickel alloy

Reactor coolant

Loss of material 

due to pitting 

and crevice 

corrosion

XI.M2, “Water 

Chemistry,” and 

XI.M32, “OneTime 

Inspection”

No

Fu

Ch

to "

pre

acc

Tim

pro

effe

“W

pro

Pilg

Sta

3.1

acc

tha

Ins

con

AM

cap

the 

this 
NUREG-1950 II-120 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

IV.C1.RP158

IV.C1-

14(RP27)

Reactor coolant 

pressure 

boundary 

components

Steel (with 

stainless 

steel or 

nickel-alloy 

cladding); 

stainless 

steel; 

nickel alloy

Reactor coolant

Loss of material 

due to pitting 

and crevice 

corrosion

XI.M2, “Water 

Chemistry,” and 

XI.M32, “OneTime Inspection”

No

Fu

Ch

to "

pre

acc

Tim

pro

effe

“W

pro

Pilg

Sta

3.1

acc

tha

Ins

con

AM

cap

the 

this 

IV.C2.RP159

IV.C2-

13(RP31)

Piping, piping 

components, 

and piping 

elements

Nickel alloy Reactor coolant 

or steam

Cracking due to 

primary water 

stress corrosion 

cracking

XI.M1, “ASME 

Section XI 

Inservice 

Inspection, 

Subsections 

IWB, IWC, and 

IWD,” for Class 

1 components, 

XI.M2, “Water 

Chemistry,” and 

No

Th

has 

inc

XI.

has 

XI.

ren

rep

rec

com
April 2011 II-121 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

XI.M11B, 

“Cracking of 

Nickel-Alloy 

Components 

and Loss of 

Material Due to 

Boric AcidInduced 

Corrosion in 

RCPB [reactor 

coolant 

pressure 

boundary] 

Components 

(PWRs Only)"

Fin

Re

sup

this 

IV.D1.RP161

IV.D1-

9(RP-16)

Steam 

generator: 

Tube bundle 

wrapper and 

associated 

supports and 

mounting 

hardware

Steel

Secondary 

feedwater or 

steam

Loss of material 

due to erosion, 

general, pitting, 

and crevice 

corrosion

XI.M19, “Steam 

Generators,” and 

XI.M2, “Water 

Chemistry”

No

Th

Str

s fi

bec

AM

exp

the

com

Ad

cha

AM

IV.D2.RP185 IV.D2-

4(R-35) 

Tube-to-tube 

sheet welds

Nickel 

alloy Reactor coolant Cracking due 

to PWSCC

XI.M2, “Water 

Chemistry” A 

plant-specific 

program is to 

be evaluated; 

Yes, plantspecific

Ad

AM

tub

wa

IV.
NUREG-1950 II-122 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

the 

effectiveness of 

the water 

chemistry 

program should 

be verified to 

ensure cracking 

is not occurring

dis

“Fu

Ye

Fu

nee

aut

ass

600 

we

600 

Allo

cla

chr

bel

690 

we

sta

tha

of a 

pro

Se

Ke

Ve

IV.A2.RP186

IV.A2-

9(R-75)

Control rod drive

(CRD) head 

penetration: 

nozzle welds

Nickel alloy Reactor coolant Cracking due to 

PWSCC

XI.M1, “ASME 

Section XI 

Inservice 

Inspection, 

Subsections 

IWB, IWC, and 

IWD,” for Class 

1 components, 

No

AM

fro

XI.

has 

all 

com

inc

pre
April 2011 II-123 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

XI.M2, “Water 

Chemistry,” and 

XI.M11B, 

“Cracking of 

Nickel-Alloy 

Components 

and Loss of 

Material Due to 

Boric AcidInduced 

Corrosion in 

RCPB 

Components 

(PWRs Only)"

IV.B1.RP219

IV.B1-

11(R101)

Jet pump 

assemblies: 

castings

Cast 

austenitic 

stainless 

steel

Reactor coolant 

>250°C 

(>482°F) and 

neutron flux

Loss of fracture 

toughness due 

to thermal 

aging, neutron 

irradiation 

embrittlement

XI.M9, "BWR 

Vessel 

Internals"

No

AM

fro

XI.

Ma

agi

com

the 

IV.B1.RP220

IV.B1-

9(R-103)

Fuel supports 

and CRD

assemblies: 

orificed fuel 

support

Cast 

austenitic 

stainless 

steel

Reactor coolant 

>250°C 

(>482°F) and 

neutron flux

Loss of fracture 

toughness due 

to thermal 

aging, neutron 

irradiation 

embrittlement

XI.M9, "BWR 

Vessel 

Internals"

No

AM

fro

XI.

Ma

agi

com

the 

IV.C2.RP221

IV.C2-

14(RPPiping, piping 

components, 

Steel Closed-cycle 

cooling water

Loss of material 

due to general, 

XI.M21A, 

"Closed Treated No AM

cha
NUREG-1950 II-124 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

10) and piping 

elements

pitting, and 

crevice 

corrosion

Water Systems" inc

the 

IV.C2.RP222

IV.C2-

11(RP11)

Piping, piping 

components, 

and piping 

elements

Copper 

alloy

Closed-cycle 

cooling water

Loss of material 

due to pitting, 

crevice, and 

galvanic 

corrosion

XI.M21A, 

"Closed Treated 

Water Systems"

No

AM

cha

inc

the 

IV.D1.RP225

IV.D1-

15(RP15)

Steam generator 

structural: Ubend supports 

including antivibration bars

Steel;

chrome 

plated 

steel; 

stainless 

steel; 

nickel alloy

Secondary 

feedwater or 

steam

Loss of material 

due to fretting

XI.M19, “Steam 

Generators” No

Re

wa

AM

and 

AM

in R

AM

XI.

226

agi

fret

affe

Ch

RP

me

cor

affe

Ch

ma

bec

ben

ma
April 2011 II-125 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

IV.D1.RP226

IV.D1-

15(RP15)

Steam 

generator 

structural: Ubend supports 

including antivibration bars

Steel; 

chrome 

plated 

steel; 

stainless 

steel; 

nickel 

alloy

Secondary 

feedwater or 

steam

Loss of 

material due to 

general (steel 

only), pitting, 

and crevice 

corrosion

XI.M19, “Steam 

Generators,” 

and 

XI.M2, “Water 

Chemistry”

No

Re

wa

AM

and 

AM

in R

AM

XI.

226

agi

fret

affe

Ch

RP

me

cor

affe

Ch

add

bec

ben

ma

IV.A1.RP227

IV.A1-

14(R-63)

Vessel shell 

(including 

applicable 

beltline) 

components: 

shell; shell 

plates or 

forgings; shell 

welds; nozzle 

Steel (with 

or without 

cladding)

Reactor coolant 

and neutron flux

Loss of fracture 

toughness due 

to neutron 

irradiation 

embrittlement

XI.M31, “Reactor 

Vessel 

Surveillance”

Yes, plantspecific or 

integrated 

surveillance 

program

Ch

“Co

des

cla

is n

Ch

pro

gen

and 
NUREG-1950 II-126 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

plates or 

forgings; 

nozzle welds 

not 

typ

ma

“Fu

cor

inc

exi

GA

SR

Item 

of t

IV.A2.RP228

IV.A2-

17(R-82)

Nozzles: inlet; 

outlet; safety 

injection

Steel (with 

or without 

cladding)

Reactor coolant 

and neutron flux

Loss of fracture 

toughness due 

to neutron 

irradiation 

embrittlement

XI.M31, “Reactor 

Vessel 

Surveillance”

Yes, plantspecific or 

integrated 

surveillance 

program

Ch

pro

gen

and 

not 

typ

ma

“Fu

cor

inc

exi

GA

SR

Item 

of t

IV.A2.RP229

IV.A2-

24(R-86)

Vessel shell: 

upper shell; 

intermediate 

shell; lower shell 

(including 

Steel (with 

or without 

cladding)

Reactor coolant 

and neutron flux

Loss of fracture 

toughness due 

to neutron 

irradiation 

embrittlement

XI.M31, “Reactor 

Vessel 

Surveillance”

Yes, plantspecific or 

integrated 

surveillance 

program

Ch

pro

gen

and 

not 
April 2011 II-127 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

beltline welds) typ

ma

“Fu

cor

inc

exi

GA

SR

Item 

of t

IV.C1.RP230

IV.C1-

1(R-03)

Class 1 piping, 

fittings and 

branch 

connections < 

nominal pipe 

size (NPS) 4 

Steel; 

stainless 

steel

Reactor coolant

Cracking due 

to SCC, IGSCC 

(for stainless 

steel only), and 

thermal, 

mechanical, 

and vibratory 

loading

XI.M1, “ASME 

Section XI 

Inservice 

Inspection, 

Subsections 

IWB, IWC, and 

IWD,” for Class 1 

components, 

XI.M2, “Water 

Chemistry,” 

XI.M35, "OneTime Inspection 

of ASME Code 

Class 1 Smallbore Piping"

No

Ch

effe

inc

loa

wit

Sco

IV.C2.RP231

IV.C2-

22(R-14)

Pressurizer relief 

tank: tank shell 

and heads; 

flanges; nozzles

Stainless 

steel; steel 

with 

stainless 

steel 

Treated borated 

water >60°C 

(>140°F)

Cracking due to 

SCC

XI.M1, “ASME 

Section XI 

Inservice 

Inspection, 

Subsections 

No

Re

des

"AS

com

tha
NUREG-1950 II-128 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

cladding IWB, IWC, and 

IWD,” for ASME 

Code 

components,

XI.M2, “Water 

Chemistry”

com

Pre

com

are 

com

not 

com

IV.D1.RP232

IV.D1-

1(R-07)

Steam 

generator: 

primary 

nozzles; nozzle 

to safe end 

welds; 

manways; 

flanges

Stainless 

steel; steel 

with 

stainless 

steel 

cladding

Reactor coolant Cracking due to 

SCC

XI.M1, “ASME 

Section XI 

Inservice 

Inspection, 

Subsections 

IWB, IWC, and 

IWD,” for Class 1 

components, 

XI.M2, “Water 

Chemistry”

No

Fo

07 

Cla

pip

(fitt

ass

IV.

noz

and 

ass

IV.

pro

dis

com

par

sys

com

par

gen

IV.D1.RP233

IV.D2.RP233

IV.D1-

24(R-49)

IV.D2-

18(R-49)

Tubes and 

sleeves Nickel alloy

Secondary 

feedwater or 

steam

Loss of material 

due to fretting 

and wear

XI.M19, “Steam 

Generators” No

Th

rev

XI.

Ch

mit
April 2011 II-129 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

me

IV.A2.RP234

IV.A2-

15(R-83)

Nozzle safe 

ends and welds: 

inlet; outlet; 

safety injection

Stainless 

steel; 

nickel-alloy 

welds 

and/or 

buttering

Reactor coolant Cracking due to 

SCC, PWSCC

XI.M1, “ASME 

Section XI 

Inservice 

Inspection, 

Subsections 

IWB, IWC, and 

IWD,” for Class 

1 components, 

XI.M2, “Water 

Chemistry,” and 

XI.M11B,

“Cracking of 

Nickel-Alloy 

Components 

and Loss of 

Material Due to 

Boric AcidInduced 

Corrosion in 

RCPB 

Components 

(PWRs Only)" 

for nickel-alloy 

components 

No

Th

has 

add 

Th

app

XI.

ma

nic

com

rea

pre

IV.C2.RP235

IV.C2-

1(R-02)

Class 1 piping, 

fittings, and 

branch 

connections 

< NPS 4

Stainless 

steel; steel 

with 

stainless 

steel 

Reactor coolant

Cracking due 

to SCC, IGSCC

(for stainless 

steel only), and 

thermal, 

XI.M1, “ASME 

Section XI 

Inservice 

Inspection, 

Subsections 

No

Ch

effe

inc

loa

wit
NUREG-1950 II-130 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

cladding mechanical, 

and vibratory 

loading

IWB, IWC, and 

IWD,” for Class 1 

components, 

XI.M2, “Water 

Chemistry,” 

and XI.M35, 

"One-Time 

Inspection of

ASME Code 

Class 1 Smallbore Piping"

Sco

IV.B4.RP240

IV.B4-

1(R-128)

Core barrel 

assembly: 

baffle/former 

assembly: (a) 

accessible 

baffle-to-former 

bolts and 

screws; (b) 

accessible 

locking devices 

(including welds) 

of baffle-toformer bolts

Stainless 

steel

Reactor coolant 

and neutron flux

Loss of fracture 

toughness due 

to neutron 

irradiation 

embrittlement; 

loss of preload 

due to thermal 

and irradiation 

enhanced stress 

relaxation; loss 

of material 

due to wear

XI.M16A, “PWR 

Vessel Internals.” 

Primary 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Expansion 

components, see 

AMR Item 

IV.B4.RP-243.)

No

Th

bas

rev

Re

com

env

effe

IV.B4.RP241

IV.B4-

7(R-125)

Core barrel 

assembly: 

baffle/former 

assembly: (a) 

accessible 

baffle-to-former 

Stainless 

steel

Reactor coolant 

and neutron flux

Cracking due to 

SCC, IASCC

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals” 

Primary 

Components 

No

Th

bas

rev

Re

com

env
April 2011 II-131 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

bolts and 

screws; (b) 

accessible 

locking devices 

(including welds) 

of baffle-toformer bolts

(identified in the 

"Structure and 

Components" 

column) 

(for Expansion 

components see 

AMR Items 

IV.B4.RP-244 

and IV.B4.RP375)

effe

IV.B4.RP242

IV.B4-

4(R-183)

Control rod 

guide tube 

(CRGT) 

assembly: 

accessible 

surfaces at four 

screw locations 

(every 90 

degrees) for 

CRGT spacer 

castings

Cast 

austenitic 

stainless 

steel

Reactor coolant 

and neutron flux

Loss of fracture 

toughness due 

to thermal aging 

embrittlement

XI.M16A, “PWR 

Vessel Internals” 

Expansion 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Primary 

components see 

AMR Items 

IV.B4.RP-253 

and IV.B4.RP258)

No

Th

bas

rev

Re

com

env

effe

IV.B4.RP243

IV.B4-

1(R-128)

Core barrel 

assembly; (a) 

external baffleto-baffle bolts; 

(b) core barrelto-former bolts; 

Stainless 

steel

Reactor coolant 

and neutron flux

Loss of fracture 

toughness due 

to neutron 

irradiation 

embrittlement; 

loss of preload 

XI.M16A, "PWR 

Vessel Internals" 

Expansion 

components 

(identified in the 

"Structure and 

No

Th

bas

rev

Re

com

env
NUREG-1950 II-132 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

(c) locking 

devices 

(including welds) 

of external 

baffle-to-baffle 

bolts and core 

barrel-to-former 

bolts; (d) internal 

baffle-to-baffle 

bolts

due to thermal 

and irradiation 

enhanced stress 

relaxation; 

loss of material 

due to wear

Components" 

column) 

(for Primary 

components see 

AMR Item 

IV.B4.RP-240)

effe

IV.B4.RP244

IV.B4-

7(R-125)

Core barrel 

assembly; (a) 

external baffleto-baffle bolts; 

(b) core barrelto-former bolts; 

(c) locking 

devices 

(including welds) 

of external 

baffle-to-baffle 

bolts and core 

barrel-to-former 

bolts

Stainless 

steel

Reactor coolant 

and neutron flux

Cracking due to 

IASCC 

XI.M2, "Water 

Chemistry," and 

XI.M16A, "PWR 

Vessel Internals" 

Expansion 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Primary 

components see 

AMR Item 

IV.B4.RP-241)

No

Th

bas

rev

Re

com

env

effe

IV.B4.RP245

IV.B4-

13(R194)

Core barrel 

assembly: (a) 

upper thermal 

shield bolts; (b) 

surveillance 

specimen holder 

Stainless 

steel; 

nickel alloy

Reactor coolant 

and neutron flux

Cracking due to 

SCC

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals” 

Expansion 

No

Th

bas

rev

Re

com

env
April 2011 II-133 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

tube bolts 

(Davis-Besse, 

only); (c) 

surveillance 

specimen tube 

holder studs, 

and nuts (Crystal 

River Unit 3, 

only)

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Primary 

components see 

AMR Items 

IV.B4.RP-247 

and IV.B4.RP248)

effe

IV.B4.RP246

IV.B4-

12(R196)

Lower grid 

assembly: 

lower thermal 

shield (LTS) 

bolts 

Stainless 

steel; 

nickel alloy

Reactor coolant 

and neutron flux

Cracking due to 

SCC

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals” 

Expansion 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Primary 

components see 

AMR Items 

IV.B4.RP-247 

and IV.B4.RP248)

No

Th

bas

rev

Re

com

env

effe

IV.B4.RP247

IV.B4-

13(R194)

Core barrel 

assembly: 

accessible lower 

Stainless 

steel; 

Reactor coolant 

and neutron flux

Cracking

due to SCC

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

No

Th

bas

rev
NUREG-1950 II-134 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

core barrel 

(LCB) bolts and 

locking devices

nickel alloy Vessel Internals” 

Primary 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Expansion 

components see 

AMR Items

IV.B4.RP-245, 

IV.B4.RP-246, 

IV.B4.RP-254, 

and IV.B4.RP256)

Re

com

env

effe

IV.B4.RP248

IV.B4-

12(R196)

Core support 

shield (CSS) 

assembly: 

accessible upper 

core barrel 

(UCB) bolts and 

locking devices

Stainless 

steel; 

nickel alloy

Reactor coolant 

and neutron flux

Cracking

due to SCC

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals” 

Primary 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Expansion 

components see 

AMR Items 

IV.B4.RP-245, 

IV.B4.RP-246, 

No

Th

bas

rev

Re

com

env

effe
April 2011 II-135 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

IV.B4.RP-254, 

IV.B4.RP-247, 

and IV.B4.RP256)

IV.B4.RP249

IV.B4-

12(R196)

Core barrel 

assembly: baffle 

plate accessible 

surfaces within 

one inch around 

each baffle plate 

flow and bolt 

hole 

Stainless 

steel

Reactor coolant 

and neutron flux

Loss of fracture 

toughness due 

to neutron 

irradiation 

embrittlement

XI.M16A, “PWR 

Vessel Internals” 

Primary 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Expansion 

components see 

AMR Item 

IV.B4.RP-250)

No

Th

bas

rev

Re

com

env

effe

IV.B4.RP250

IV.B4-

12(R196)

Core barrel 

assembly: core 

barrel cylinder 

(including 

vertical and 

circumferential 

seam welds); 

former plates

Stainless 

steel

Reactor coolant 

and neutron flux

Loss of fracture 

toughness due 

to neutron 

irradiation 

embrittlement

XI.M16A, “PWR 

Vessel Internals” 

Expansion 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Primary 

components see 

AMR Item 

IV.B4.RP-249)

No 

Th

bas

rev

Re

com

env

effe

IV.B4.RP- IV.B4-

15(R- Core support Stainless Reactor coolant Loss of material XI.M16A, “PWR No Th
NUREG-1950 II-136 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

251 190) shield (CSS) 

assembly: CSS 

top flange; 

plenum cover 

assembly: 

plenum cover 

weldment rib 

pads and 

plenum cover 

support flange

steel and neutron flux due to wear Vessel Internals” 

Primary 

component 

(identified in the 

"Structure and 

Components" 

column) 

No Expansion 

components

bas

rev

Re

com

env

effe

IV.B4.RP252

IV.B4-

16(R188)

Core support 

shield (CSS) 

assembly: (a) 

CSS vent valve 

disc shaft or 

hinge pin (b) 

CSS vent valve 

top retaining ring 

(c) CSS vent 

valve bottom 

retaining ring

Stainless 

steel

Reactor coolant 

and neutron flux

Loss of fracture 

toughness due 

to thermal aging 

embrittlement

XI.M16A, “PWR 

Vessel Internals” 

Primary 

components 

(identified in the 

"Structure and 

Components" 

column) 

No Expansion 

components

No

Th

bas

rev

Re

com

env

effe

IV.B4.RP253

IV.B4-

21(R191)

Core support 

shield (CSS) 

assembly: (a) 

CSS cast outlet 

nozzles (Oconee 

Unit 3 and 

Davis-Besse, 

only); (b) CSS 

vent valve discs

Cast 

austenitic 

stainless 

steel

Reactor coolant 

and neutron flux

Loss of fracture 

toughness due 

to thermal aging 

embrittlement

XI.M16A, “PWR 

Vessel Internals” 

Primary 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Expansion 

No

Th

bas

rev

Re

com

env

effe
April 2011 II-137 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

components see 

ARM Line Item 

IV.B4.RP-242)

IV.B4.RP254

IV.B4-

25(R210)

Lower grid 

assembly: 

alloy X-750 

lower grid shock 

pad bolts and 

locking devices 

(TMI-1, only)

Nickel alloy Reactor coolant 

and neutron flux

Cracking due to

SCC

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals,” 

Expansion 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Primary 

components see 

ARM Line Items 

IV.B4.RP-247 

and IV.B4.RP248)

No

Th

bas

rev

Re

com

env

effe

IV.B4.RP256

IV.B4-

25(R210)

Flow distributor 

assembly: flow 

distributor bolts 

and locking 

devices 

Stainless 

steel; 

nickel alloy

Reactor coolant 

and neutron flux

Cracking due to 

SCC

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals,” 

Expansion 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Primary 

No

Th

bas

rev

Re

com

env

effe
NUREG-1950 II-138 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

components see 

ARM Line Items 

IV.B4.RP-247 

and IV.B4.RP248)

IV.B4.RP258

IV.B4-

4(R-183)

Incore 

Monitoring 

Instrumentation 

(IMI) guide tube 

assembly: 

accessible top 

surfaces of IMI 

Incore guide 

tube spider 

castings 

Cast 

austenitic 

stainless 

steel

Reactor coolant 

and neutron flux

Loss of fracture 

toughness 

due to thermal 

aging, neutron 

irradiation 

embrittlement

XI.M16A, “PWR 

Vessel Internals” 

Primary 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Expansion 

components see 

Line Item 

IV.B4.RP-242)

No

Th

bas

rev

Re

com

env

effe

IV.B4.RP259

IV.B4-

31(R205)

Incore 

Monitoring 

Instrumentation 

(IMI) guide tube 

assembly: 

accessible top 

surfaces of IMI 

guide tube 

spider-to-lower 

grid rib sections 

welds 

Stainless 

steel; 

nickel alloy

Reactor coolant 

and neutron flux

Loss of fracture 

toughness 

due to thermal 

aging, neutron 

irradiation

embrittlement

XI.M16A, “PWR 

Vessel Internals” 

Primary 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Expansion 

components see 

Line Item 

IV.B4.RP-260)

No

Th

bas

rev

Re

com

env

effe
April 2011 II-139 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

IV.B4.RP260

IV.B4-

31(R205)

Lower grid 

assembly: (a) 

accessible pads; 

(b) accessible 

pad-to-rib 

section welds; 

(c) accessible 

alloy X-750 

dowels, cap 

screws and 

locking devices

Stainless 

steel; 

nickel alloy

Reactor coolant 

and neutron flux

Loss of fracture 

toughness due 

to neutron 

irradiation 

embrittlement

XI.M16A, “PWR 

Vessel Internals" 

Expansion 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Primary 

components see 

AMR Item 

IV.B4.RP-259)

No

Th

bas

rev

Re

com

env

effe

IV.B4.RP261

IV.B4-

32(R203)

Lower grid 

assembly: alloy 

X-750 dowel-toguide block 

welds

Nickel alloy Reactor coolant 

and neutron flux

Cracking due to 

SCC

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals” 

Primary 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Expansion 

components see 

AMR Item 

IV.B4.RP-262 

and IV.B4.RP352)

No

Th

bas

rev

Re

com

env

effe

IV.B4.RP- IV.B4-

32(R- Lower grid Nickel alloy Reactor coolant Cracking due to XI.M2, “Water No Th
NUREG-1950 II-140 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

262 203) assembly: 

accessible alloy 

X-750 dowel-tolower fuel 

assembly 

support pad 

welds

and neutron flux SCC Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals” 

Expansion 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Primary 

components see 

AMR Item 

IV.B4.RP-261)

bas

rev

Re

com

env

effe

IV.B2.RP270

IV.B2-

1(R-124)

Baffle-to-former 

assembly: baffle 

and former 

plates

Stainless 

steel

Reactor coolant 

and neutron flux

Change in 

dimension due 

to void swelling

XI.M16A, “PWR 

Vessel Internals” 

Primary 

components 

(identified in the 

"Structure and 

Components" 

column) 

no Expansion 

components

No

Th

bas

rev

Re

com

env

effe

IV.B2.RP271

IV.B2-

10(R125)

Baffle-to-former 

assembly: 

accessible 

baffle-to-former 

bolts 

Stainless 

steel

Reactor coolant 

and neutron flux

Cracking due to 

IASCC and 

fatigue

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals” 

Primary 

components 

No

Th

bas

rev

Re

com

env
April 2011 II-141 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

(identified in the 

"Structure and 

Components" 

column) 

(for Expansion 

components see 

AMR Items 

IV.B2.RP-273 

and IV.B2.RP286)

effe

IV.B2.RP272

IV.B2-

6(R-128)

Baffle-to-former 

assembly: 

accessible 

baffle-to-former 

bolts 

Stainless 

steel

Reactor coolant 

and neutron flux

Loss of fracture 

toughness due 

to neutron 

irradiation 

embrittlement; 

change in 

dimension due 

to void swelling; 

loss of preload 

due to thermal 

and irradiation 

enhanced stress 

relaxation

XI.M16A, “PWR 

Vessel Internals” 

Primary 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Expansion 

components see 

AMR Items 

IV.B2.RP-274 

and IV.B2.RP287)

No

Th

bas

rev

Re

com

env

effe

IV.B2.RP273

IV.B2-

10(R125)

Baffle-to-former 

assembly: 

barrel-to-former 

bolts 

Stainless 

steel

Reactor coolant 

and neutron flux

Cracking due to 

IASCC and 

fatigue

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals” 

Expansion 

No

Th

bas

rev

Re

com

env
NUREG-1950 II-142 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Primary 

components see 

AMR Item 

IV.B2.RP-271)

effe

IV.B2.RP274 

IV.B2-

6(R-128)

Baffle-to-former 

assembly: 

barrel-to-former 

bolts 

Stainless 

steel

Reactor coolant 

and neutron flux

Loss of fracture 

toughness due 

to neutron 

irradiation 

embrittlement; 

change in 

dimension due 

to void swelling; 

loss of preload 

due to thermal 

and irradiation 

enhanced stress 

relaxation

XI.M16A, “PWR 

Vessel Internals” 

Expansion 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Primary 

components see 

AMR Item 

IV.B2.RP-272)

No

Th

bas

rev

Re

com

env

effe

IV.B2.RP275

IV.B2-

6(R-128)

Baffle-to-former 

assembly: baffleedge bolts (all 

plants with 

baffle-edge 

bolts)

Stainless 

steel

Reactor coolant 

and neutron flux

Cracking due to 

IASCC cracking 

and fatigue

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals” 

Primary 

components 

(identified in the 

"Structure and 

No

Th

bas

rev

Re

com

env

effe
April 2011 II-143 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

Components" 

column) 

no Expansion 

components

IV.B2.RP276

IV.B2-

8(R-120)

Core barrel 

assembly: upper 

core barrel 

flange weld

Stainless 

steel

Reactor coolant 

and neutron flux

Cracking due 

SCC and 

IASCC 

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals”

Primary 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Expansion 

components, see 

AMR Items 

IV.B2.RP-278, 

IV.B2.RP-280, 

IV.B2.RP-282, 

IV.B2.RP-294, 

IV.B2.RP-295, 

IV. B4.RP-281, 

IV.B2.RP-387, 

and IV.B2.RP288)

No

Th

bas

rev

Re

com

env

effe

IV.B2.RP278

IV.B2-

8(R-120)

Core barrel 

assembly: core 

barrel outlet 

Stainless 

steel

Reactor coolant 

and neutron flux

Cracking due to 

SCC and fatigue

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

No

Th

bas

rev

Re
NUREG-1950 II-144 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

nozzle welds Vessel Internals” 

Expansion 

component 

(identified in the 

"Structure and 

Components" 

column) 

(for Primary 

components see 

AMR Item 

IV.B2.RP-276)

com

env

effe

IV.B2.RP280

IV.B2-

8(R-120)

Core barrel 

assembly: lower 

core barrel 

flange weld

Stainless 

steel 

Reactor coolant 

and neutron flux

Cracking due to 

SCC and 

IASCC

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals”

Expansion 

component 

(identified in the 

"Structure and 

Components" 

column) 

(for Primary 

components see 

AMR Item 

IV.B2.RP-276)

No

Th

bas

rev

Re

com

env

effe

IV.B2.RP281

IV.B2-

9(R-122)

Core barrel 

assembly: lower 

core barrel 

flange weld

Stainless 

steel

Reactor coolant 

and neutron flux

Loss of fracture 

toughness due 

to neutron 

irradiation 

XI.M16A, “PWR 

Vessel Internals” 

Expansion 

Components 

No

Th

bas

rev

Re
April 2011 II-145 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

embrittlement (identified in the 

"Structure and 

Components" 

column) 

(for Primary 

components see 

AMR Item 

IV.B2.RP-276)

com

env

effe

IV.B2.RP282

IV.B2-

8(R-120)

Core barrel 

assembly: core 

barrel flange

Stainless 

steel

Reactor coolant 

and neutron flux

Cracking due to 

SCC and fatigue

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals” 

Expansion 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Primary 

components see 

AMR Item 

IV.B2.RP-276)

No

Th

bas

rev

Re

com

env

effe

IV.B2.RP284

IV.B2-

12(R143)

Bottom mounted 

instrument 

system: flux 

thimble tubes

Stainless 

steel (with 

or without 

chrome 

plating)

Reactor coolant 

and neutron flux

Loss of material 

due to wear

XI.M16A, “PWR 

Vessel Internals” 

Existing Program 

components 

(identified in the 

"Structure and 

Components" 

No

Th

bas

rev

Re

com

env

effe

add
NUREG-1950 II-146 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

column) 

No expansion 

components; and 

XI.M37, "Flux 

Thimble Tube 

Inspection"

cre

this 

com

IV.B2.RP285

IV.B2-

14(R137)

Lower internals 

assembly: clevis 

insert bolts

Nickel alloy Reactor coolant 

and neutron flux

Loss of material 

due to wear

XI.M16A, “PWR 

Vessel Internals” 

Existing Program 

components 

(identified in the 

"Structure and 

Components" 

column) 

no Expansion 

components

No

Th

bas

rev

Re

com

env

effe

IV.B2.RP286

IV.B2-

16(R133)

Lower support 

assembly: lower 

support column 

bolts

Stainless 

steel; 

nickel alloy

Reactor coolant 

and neutron flux

Cracking due to 

IASCC and 

fatigue

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals” 

Expansion 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Primary 

components see 

AMR Item 

No

Th

bas

rev

Re

com

env

effe
April 2011 II-147 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

IV.B2.RP-271)

IV.B2.RP287

IV.B2-

17(R135)

Lower support 

assembly: lower 

support column 

bolts

Stainless 

steel; 

nickel alloy

Reactor coolant 

and neutron flux

Loss of fracture 

toughness 

due to neutron 

irradiation 

embrittlement; 

loss of preload 

due to thermal 

and irradiation 

enhanced stress 

relaxation

XI.M16A, “PWR 

Vessel Internals” 

Expansion 

component 

(identified in the 

"Structure and 

Components" 

column) 

(for Primary 

components see 

AMR Item 

IV.B2.RP-272)

No

Th

bas

rev

Re

com

env

effe

IV.B2.RP288

IV.B2-

18(R132)

Lower internals 

assembly: lower 

core plate and 

extra-long (XL) 

lower core plate

Stainless 

steel

Reactor coolant 

and neutron flux

Loss of fracture 

toughness due 

to neutron 

irradiation 

embrittlement; 

loss of material 

due to wear

XI.M16A, “PWR 

Vessel Internals” 

Existing Program 

components 

(identified in the 

"Structure and 

Components" 

column) 

no Expansion 

components

No

Th

bas

rev

Re

com

env

effe

IV.B2.RP289

IV.B2-

20(R130)

Lower internals 

assembly: lower 

core plate and 

extra-long (XL) 

lower core plate

Stainless 

steel

Reactor coolant 

and neutron flux

Cracking due to 

IASCC and 

fatigue

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals” 

Existing Program 

components 

No

Th

bas

rev

Re

com

env
NUREG-1950 II-148 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

(identified in the 

"Structure and 

Components" 

column) 

no Expansion 

components 

effe

IV.B2.RP290

IV.B2-

21(R140)

Lower support 

assembly: lower 

support column 

bodies (cast) 

Cast 

austenitic 

stainless 

steel

Reactor coolant 

and neutron flux

Loss of fracture 

toughness due 

to thermal aging 

and neutron 

irradiation 

embrittlement

XI.M16A, “PWR 

Vessel Internals” 

Expansion 

components 

(identified in the 

"Structure and 

Components" 

column)

(for Primary 

components see 

AMR Item 

IV.B2.RP-297)

No

Th

bas

rev

Re

com

env

effe

IV.B2.RP291

IV.B2-

24(R138)

Lower support 

assembly: lower 

support column 

bodies (cast) 

Cast 

austenitic 

stainless 

steel

Reactor coolant 

and neutron flux

Cracking 

due to IASCC

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals” 

Expansion 

components 

(identified in the 

"Structure and 

Components" 

column)

(for Primary 

No

Th

bas

rev

Re

com

env

effe
April 2011 II-149 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

components see 

AMR Item 

IV.B2.RP-298)

IV.B2.RP292

IV.B2-

21(R140)

Bottom-mounted 

instrumentation 

system: bottommounted 

instrumentation 

(BMI) column 

bodies 

Stainless 

steel

Reactor coolant 

and neutron flux

Loss of fracture 

toughness due 

to neutron 

irradiation 

embrittlement

XI.M16A, “PWR 

Vessel Internals” 

Expansion 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Primary 

components see 

AMR Item 

IV.B2.RP-297)

No

Th

bas

rev

Re

com

env

effe

IV.B2.RP293

IV.B2-

24(R138)

Bottom-mounted 

instrumentation 

system: bottommounted 

instrumentation 

(BMI) column 

bodies 

Stainless 

steel

Reactor coolant 

and neutron flux

Cracking due to 

fatigue

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals” 

Expansion 

components 

(identified in the 

"Structure and 

Components" 

column)

(for Primary 

components see 

AMR Item 

IV.B2.RP-298)

No

Th

bas

rev

Re

com

env

effe
NUREG-1950 II-150 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

IV.B2.RP294

IV.B2-

24(R138)

Lower support 

assembly: lower 

support column 

bodies (noncast)

Stainless 

steel

Reactor coolant 

and neutron flux

Cracking due to 

IASCC

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals” 

Expansion 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Primary 

components see 

AMR Item 

IV.B2.RP-276)

No

Th

bas

rev

Re

com

env

effe

IV.B2.RP295

IV.B2-

22(R141)

Lower support 

assembly: lower 

support column 

bodies (noncast)

Stainless 

steel

Reactor coolant 

and neutron flux

Loss of fracture 

toughness due 

to neutron 

irradiation 

embrittlement

XI.M16A, “PWR 

Vessel Internals” 

Expansion 

Components 

(identified in the 

"Structure and 

Components" 

column) 

(for Primary 

components see 

AMR Item 

IV.B2.RP-276)

No

Th

bas

rev

Re

com

env

effe

IV.B2.RP298

IV.B2-

28(R118)

Control rod 

guide tube 

(CRGT) 

Stainless 

steel

Reactor coolant 

and neutron flux

Cracking due to 

SCC and fatigue

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

No

Th

bas

rev
April 2011 II-151 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

assemblies: 

CRGT lower 

flange welds 

(accessible)

Vessel Internals” 

Primary 

components 

(identified in the 

"Structure and 

Components" 

column)

(for Expansion 

components see 

AMR Items 

IV.B2.RP-291 

and IV.B2.RP293)

Re

com

env

effe

IV.B2.RP299

IV.B2-

34(R115)

Alignment and 

interfacing 

components: 

upper core plate 

alignment pins

Stainless 

steel

Reactor coolant 

and neutron flux

Loss of material 

due to wear

XI.M16A, “PWR 

Vessel Internals” 

Existing Program 

components 

(identified in the 

"Structure and 

Components" 

column) 

no Expansion 

components

No

Th

bas

rev

Re

com

env

effe

IV.B2.RP300

IV.B2-

33(R108)

Alignment and 

interfacing 

components: 

internals hold 

down spring

Stainless 

steel

Reactor coolant 

and neutron flux

Loss of preload 

due to thermal 

and irradiation 

enhanced stress 

relaxation; 

loss of material 

XI.M16A, “PWR 

Vessel Internals” 

Primary 

components 

(identified in the 

"Structure and 

No

Th

bas

rev

Re

com

env
NUREG-1950 II-152 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

due to wear Components" 

column) 

no Expansion 

components

effe

IV.B2.RP301

IV.B2-

40(R112)

Alignment and 

interfacing 

components: 

upper core plate 

alignment pins

Stainless 

steel

Reactor coolant 

and neutron flux

Cracking due to 

SCC

XI.M2, “Water

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals” 

Existing Program 

components 

(identified in the 

"Structure and 

Components" 

column) 

no Expansion 

components 

No

Th

bas

rev

Re

com

env

effe

IV.B2.RP303

IV.B2-

31(R-53)

Reactor vessel 

internal 

components

Stainless 

steel; 

nickel alloy

Reactor coolant 

and neutron flux

Cumulative 

fatigue damage 

due to fatigue

Fatigue is a 

TLAA to be 

evaluated for the

period of 

extended 

operation. See 

the SRP Chapter

4.3, “Metal 

Fatigue,” for 

acceptable 

methods for 

meeting the 

requirements of 

10 CFR 

Yes, TLAA

Th

bas

rev

Re

com

env

effe
April 2011 II-153 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

54.21(c)(1).

IV.B3.RP312

IV.B3-

2(R-149)

CEA: shroud 

assemblies: 

instrument guide 

tubes in 

peripheral CEA 

assemblies

Stainless 

steel

Reactor coolant 

and neutron flux

Cracking due to 

SCC and fatigue

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals” 

Primary 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Expansion 

components see 

AMR Item 

IV.B3.RP-313)

No

Th

bas

rev

Re

com

env

effe

IV.B3.RP314

IV.B3-

9(R-162)

Core shroud 

assemblies (for 

bolted core 

shroud 

assemblies): 

core shroud 

bolts 

(accessible)

Stainless 

steel

Reactor coolant 

and neutron flux

Cracking due to 

IASCC and 

fatigue

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals” 

Primary 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Expansion 

components see 

AMR Items 

IV.B3.RP-316, 

No

Th

bas

rev

Re

com

env

effe
NUREG-1950 II-154 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

IV.B3.RP-330, 

and IV.B3.RP358)

IV.B3.RP315

IV.B3-

7(R-165)

Core shroud 

assemblies (for 

bolted core 

shroud 

assemblies): 

core shroud 

bolts 

(accessible)

Stainless 

steel

Reactor coolant 

and neutron flux

Loss of preload 

due to thermal 

and irradiation 

enhanced stress 

relaxation; 

loss of fracture 

toughness 

due to neutron 

irradiation 

embrittlement; 

change in 

dimension 

due to void 

swelling

XI.M16A, “PWR 

Vessel Internals,” 

Primary 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Expansion 

components see 

AMR Items 

IV.B3.RP-317, 

and IV.B3.RP331)

No

Th

bas

rev

Re

com

env

effe

IV.B3.RP316

IV.B3-

9(R-162)

Core shroud 

assemblies (for 

bolted core 

shroud 

assemblies): 

barrel-shroud 

bolts with 

neutron 

exposures 

greater than 3 

dpa

Stainless 

steel

Reactor coolant 

and neutron flux

Cracking due to 

IASCC

XI.M2, "Water 

Chemistry," and 

XI.M16A, "PWR 

Vessel Internals" 

Expansion 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Primary 

components see 

No

Th

bas

rev

Re

com

env

effe
April 2011 II-155 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

AMR Item 

IV.B3.RP-314)

IV.B3.RP317

IV.B3-

7(R-165)

Core shroud 

assemblies (for 

bolted core 

shroud 

assemblies): 

barrel-shroud 

bolts with 

neutron 

exposures 

greater than 3 

dpa

Stainless 

steel; 

nickel alloy

Reactor coolant 

and neutron flux

Loss of preload 

due to thermal 

and irradiation 

enhanced stress 

relaxation; 

loss of fracture 

toughness 

due to neutron 

irradiation 

embrittlement

XI.M16A, "PWR 

Vessel Internals" 

Expansion 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Primary 

components see 

AMR Item 

IV.B3.RP-315)

No

Th

bas

rev

Re

com

env

effe

IV.B3.RP318

IV.B3-

8(R-163)

Core shroud 

assemblies (for 

bolted core 

shroud 

assemblies): (a) 

shroud plates 

and (b) former 

plates

Stainless 

steel

Reactor coolant 

and neutron flux

Loss of fracture 

toughness 

due to neutron 

irradiation 

embrittlement; 

change in 

dimension 

due to void 

swelling

XI.M16A, "PWR 

Vessel Internals" 

Primary 

components 

(identified in the 

"Structure and 

Components" 

column) 

no Expansion 

components 

No

Th

bas

rev

Re

com

env

effe

IV.B3.RP319

IV.B3-

9(R-162)

Core shroud 

assemblies (all 

plants): guide 

lugs and guide 

lug insert bolts

Stainless 

steel

Reactor coolant 

and neutron flux

Loss of material 

due to wear; 

Loss of preload 

due to thermal 

XI.M16A, "PWR 

Vessel Internals" 

Existing Program 

components 

(identified in the 

No

Th

bas

rev

Re

com
NUREG-1950 II-156 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

and irradiation 

enhanced stress 

relaxation

"Structure and 

Components" 

column) 

no Expansion 

components 

env

effe

IV.B3.RP320

IV.B3-

9(R-162)

Core shroud 

assemblies (all 

plants): guide 

lugs and guide 

lug insert bolts

Stainless 

steel

Reactor coolant 

and neutron flux

Cracking due to 

fatigue

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals” 

Existing Program 

components 

(identified in the 

"Structure and 

Components" 

column) 

no Expansion 

components

No

Th

bas

rev

Re

com

env

effe

IV.B3.RP327

IV.B3-

15(R155)

Core support 

barrel assembly: 

upper core 

support barrel 

flange weld 

(accessible 

surfaces)

Stainless 

steel

Reactor coolant 

and neutron flux

Cracking due to 

SCC

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals” 

Primary 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Expansion 

components see 

No

Th

bas

rev

Re

com

env

effe
April 2011 II-157 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

AMR Items 

IV.B3.RP-329, 

IV.B3.RP-335, 

IV.B3.RP-362, 

IV.B3.RP-363, 

IV.B3.RP-364)

IV.B3.RP328

IV.B3-

15(R155)

Core support 

barrel assembly: 

surfaces of the 

lower core barrel 

flange weld 

(accessible 

surfaces)

Stainless 

steel

Reactor coolant 

and neutron flux

Cracking due to 

SCC and fatigue

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals” 

Primary 

components 

(identified in the 

"Structure and 

Components" 

column) 

no Expansion 

components

No

Th

bas

rev

Re

com

env

effe

IV.B3.RP329

IV.B3-

15(R155)

Core support 

barrel assembly: 

lower cylinder 

welds and 

remaining core 

barrel assembly 

welds

Stainless 

steel

Reactor coolant 

and neutron flux

Cracking due to 

SCC

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals” 

Expansion 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Primary 

No

Th

bas

rev

Re

com

env

effe
NUREG-1950 II-158 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

components see 

AMR Item 

IV.B3.RP-327)

IV.B3.RP330

IV.B3-

23(R167)

Lower support 

structure: core 

support column 

bolts

Stainless 

steel

Reactor coolant 

and neutron flux

Cracking due to 

IASCC and 

fatigue

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals” 

Expansion 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Primary 

components see 

AMR Item 

'IV.B3.RP-314)

No

Th

bas

rev

Re

com

env

effe

IV.B3.RP332

IV.B3-

17(R156)

Core support 

barrel assembly: 

upper core 

barrel flange

Stainless 

steel

Reactor coolant 

and neutron flux

Loss of material 

due to wear

XI.M16A, “PWR 

Vessel Internals” 

Existing Program 

components 

(identified in the 

"Structure and 

Components" 

column) 

no Expansion 

components

No

Th

bas

rev

Re

com

env

effe

IV.B3.RP334

IV.B3-

23(RLower support 

structure: A286 

Stainless 

steel

Reactor coolant 

and neutron flux

Cracking due to 

IASCC and 

XI.M2, “Water 

Chemistry,” and No Th

bas
April 2011 II-159 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

167) fuel alignment 

pins (all plants 

with core shroud 

assembled with 

full-height 

shroud plates)

fatigue XI.M16A, “PWR 

Vessel Internals” 

Existing Program 

components 

(identified in the 

"Structure and 

Components" 

column) 

no Expansion 

components

rev

Re

com

env

effe

IV.B3.RP335

IV.B3-

23(R167)

Lower support 

structure: core 

support column 

welds, 

applicable to all 

plants except 

those 

assembled with 

full-height 

shroud plates

Stainless 

steel

Reactor coolant 

and neutron flux

Cracking due to 

SCC, IASCC, 

and fatigue

XI.M2, “Water 

Chemistry,” and 

XI.M16A, “PWR 

Vessel Internals” 

Expansion 

components 

(identified in the 

"Structure and 

Components" 

column) 

(for Primary 

components see 

AMR Item 

IV.B3.RP-327)

No

Th

bas

rev

Re

com

env

effe

IV.B3.RP336

IV.B3-

22(R170)

Lower support 

structure: A286 

fuel alignment 

pins (all plants 

with core shroud 

Stainless 

steel

Reactor coolant 

and neutron flux

Loss of material 

due to wear; 

loss of fracture 

toughness due 

to neutron 

XI.M16A, “PWR 

Vessel Internals” 

Existing Program 

components 

(identified in the 

No

Th

bas

rev

Re

com
NUREG-1950 II-160 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

assembled in 

two vertical 

sections)

irradiation 

embrittlement; 

loss of preload 

due to thermal 

and irradiation 

enhanced stress 

relaxation

"Structure and 

Components" 

column) 

no Expansion 

components

env

effe

IV.B3.RP339

IV.B3-

24(R-53)

Reactor vessel 

internal 

components

Stainless 

steel; 

nickel alloy

Reactor coolant 

and neutron flux

Cumulative 

fatigue damage 

due to fatigue

Fatigue is a 

TLAA to be 

evaluated for the 

period of 

extended 

operation. See 

the SRP 4.3, 

“Metal Fatigue,” 

for acceptable 

methods for 

meeting the 

requirements of 

10 CFR 

54.21(c)(1).

Yes, TLAA

Th

bas

rev

Re

com

env

effe

IV.C2.RP344

IV.C2-

2(R-07)

Class 1 piping, 

piping 

components, 

and piping 

elements

Stainless 

steel; steel 

with 

stainless 

steel 

cladding

Reactor coolant Cracking due to 

SCC

XI.M1, “ASME 

Section XI 

Inservice 

Inspection, 

Subsections

IWB, IWC, and 

IWD,” for Class 1 

components, 

XI.M2, “Water 

No

Fo

in t

pip

ele

flan

Ch

prim

end

ass

IV.
April 2011 II-161 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

Chemistry” pro

dis

com

par

sys

com

par

gen

IV.E.RP353

IV.E6(RP-01)

Piping, piping 

components, 

and piping 

elements

Steel Concrete None

None, provided 

that

(1) attributes of 

the concrete are 

consistent with 

ACI 318 or ACI 

349 (low waterto-cement ratio, 

low 

permeability, 

and adequate 

air entrainment) 

as cited in 

NUREG-1557 

and 

(2) plant OE 

indicates no 

degradation of 

the concrete

No, if 

conditions are 

met.

Th

bee

des

con

con

nee

“no

con

inc

“Co

Mis

Ma

Co

(su

suc

AM

AM

bec

are 

deg

the 

com

its 
NUREG-1950 II-162 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

for 

per

IV.D1.RP36

IV.D2.RP36

IV.D1-

4(R-01)

IV.D2-

2(R-01)

Instrument 

penetrations and 

primary side 

nozzles; safe 

ends; welds

Steel (with 

nickel-alloy 

cladding); 

nickel alloy

Reactor coolant Cracking due to 

PWSCC

XI.M1, “ASME 

Section XI 

Inservice 

Inspection, 

Subsections 

IWB, IWC, and 

IWD,” for Class 

1 components, 

XI.M2, “Water 

Chemistry,” and 

XI.M11B, 

“Cracking of 

Nickel-Alloy 

Components 

and Loss of 

Material Due to 

Boric AcidInduced 

Corrosion in 

RCPB 

Components 

(PWRs Only)"

No

Th

app

XI.

ren

rep

rec

com

FS

rela

Item

IV.D1.RP367

IV.D1-

6(RP-21)

Primary side 

components: 

divider plate

Steel (with 

nickel-alloy 

cladding); 

nickel alloy

Reactor coolant Cracking due to 

PWSCC

XI.M2, “Water 

Chemistry” 

For nickel-alloy 

divider plate 

assemblies and 

associated 

Yes, detection 

of aging effects 

is to be 

evaluated

AM

inc

nic

pla

ass

ma
April 2011 II-163 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

welds made of 

Alloy 600, 

effectiveness of 

the chemistry 

control program 

should be 

verified to 

ensure that 

cracking due to

PWSCC is not 

occurring.

Fu

wa

"No

on 

exp

has 

furt

pla

ma

IV.D1.RP368

IV.D1-

12(R-34)

Steam 

generator 

components: 

upper and 

lower shell; 

transition cone; 

new transition 

cone closure 

weld

Steel

Secondary 

feedwater or 

steam

Loss of material 

due to general, 

pitting, and 

crevice 

corrosion

XI.M1, “ASME 

Section XI 

Inservice 

Inspection, 

Subsections 

IWB, IWC, and 

IWD,” for Class 

2 components, 

XI.M2, “Water 

Chemistry” 

As noted in 

NRC IN 90-04, if 

general and 

pitting 

corrosion of the 

shell exists, 

XI.M1 methods 

may not be 

sufficient to 

detect general 

Yes, detection of 

aging effects is to 

be evaluated

Str

cha

tra

we

cha

new 

app

rep

gen

has 

for 

com

effe

ma

AM
NUREG-1950 II-164 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

and pitting 

corrosion (and 

the resulting 

corrosionfatigue 

cracking), and 

additional 

inspection 

procedures are 

to be 

developed. This 

issue is limited 

to 

Westinghouse 

Model 44 and 51 

Steam 

Generators 

where a high 

stress region 

exists at the 

shell to 

transition cone 

weld. The new 

transition is 

only applicable 

to replacement 

recirculating 

steam 

generators.

IV.A1.RP369IV.A1-

5(R-69)

Penetrations: 

CRD stub 

Stainless 

steel; Reactor coolant Cracking due to SCC, IGSCC, 

XI.M8, “BWR 

Penetrations,” No Pebot
April 2011 II-165 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

tubes; in core 

monitor 

housings; jet 

pump 

instrument; 

standby liquid 

control; flux 

monitor

nickel alloy cyclic loading and 

XI.M2, “Water 

Chemistry”

are 

IV.

the

AM

XI.

IV.C2.RP37

IV.C2-

21(R-06)

Pressurizer 

instrumentation 

penetrations; 

heater sheaths 

and sleeves; 

heater bundle 

diaphragm plate; 

manways and 

flanges

Nickel 

alloy; 

nickel-alloy 

cladding

Reactor coolant Cracking due to 

PWSCC

XI.M1, “ASME 

Section XI 

Inservice 

Inspection, 

Subsections 

IWB, IWC, and 

IWD,” for Class 

1 components, 

XI.M2, “Water 

Chemistry,” and 

XI.M11B, 

“Cracking of 

Nickel-Alloy 

Components 

and Loss of 

Material Due to 

Boric AcidInduced 

Corrosion in 

RCPB 

Components 

(PWRs Only)"

No

Th

has 

inc

XI.

app

XI.

ren

rep

rec

com

FS

rela

line
NUREG-1950 II-166 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

IV.A1.RP371

IV.A1-

5(R-69) Penetrations: 

drain line

Stainless 

steel; 

nickel alloy

Reactor coolant

Cracking due to 

SCC, IGSCC, 

cyclic loading

XI.M1, “ASME 

Section XI 

Inservice 

Inspection, 

Subsections 

IWB, IWC, and 

IWD,” and 

XI.M2, “Water 

Chemistry”

No

Th

Item 

Re

wh

com

wit

com

wit

AM

IV.A2.RP379

IV.A2-

13(R-17)

External 

surfaces: 

reactor vessel 

top head and 

bottom head

Steel Air with borated 

water leakage

Loss of material 

due to boric acid 

corrosion

XI.M10, "Boric 

Acid 

Corrosion," and 

XI.M11B, 

"Cracking of 

Nickel-Alloy 

Components 

and Loss of 

Material Due to 

Boric AcidInduced 

Corrosion in 

RCPB 

Components 

(PWRs Only)"

No

Sco

XI.

to i

los

ste

nea

RC

Th

rea

bot

pip

dis

IV.C2.RP380

IV.C2-

9(R-17)

External 

surfaces: 

reactor coolant 

pressure 

boundary 

piping or 

Steel Air with borated 

water leakage

Loss of material 

due to boric acid 

corrosion

XI.M10, "Boric 

Acid 

Corrosion," and 

XI.M11B, 

"Cracking of 

Nickel-Alloy 

No

Sco

XI.

to i

los

ste

nea
April 2011 II-167 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

components 

adjacent to 

dissimilar metal 

(Alloy 82/182) 

welds

Components 

and Loss of 

Material Due to 

Boric AcidInduced 

Corrosion in 

RCPB 

Components 

(PWRs Only)"

RC

Th

rea

bot

pip

dis

IV.B2.RP382

IV.B3.RP382

IV.B4.RP382

IV.B2-

26(R142)

IV.B3-

22(R170)

IV.B4-

42(R179)

Reactor vessel 

internals: core 

support 

structure

Stainless 

steel; 

nickel 

alloy; cast 

austenitic 

stainless 

steel

Reactor coolant 

and neutron flux

Cracking, or 

oss of material l

due to wear

XI.M1, “ASME 

Section XI 

Inservice 

Inspection, 

Subsections 

IWB, IWC, and 

IWD”

No

AS

352

rele

tha

for 

par

cor

Ge

not 

ma

PW

Th

app

con

cou

cra

PW

IV.D1.RP384

IV.D1-

14(RP14)

Steam 

generator 

structural: Ubend supports 

including antiSteel; 

chrome 

plated 

steel; 

stainless 

Secondary 

feedwater or 

steam

Cracking due 

to SCC or 

other 

mechanism(s)

XI.M19, “Steam 

Generators,” and 

XI.M2, “Water 

Chemistry”

No

Ste

ma

cra

fou

com
NUREG-1950 II-168 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

vibration bars steel; 

nickel 

alloy

me

ide

typ

app

IV.C1.RP39

IV.C1-

6(R-16)

Isolation 

condenser 

components

Steel; 

stainless 

steel

Reactor coolant

Loss of 

material due to 

general (steel 

only), pitting, 

and crevice 

corrosion

XI.M1, “ASME 

Section XI 

Inservice 

Inspection, 

Subsections 

IWB, IWC, and 

IWD,” and 

XI.M2, “Water 

Chemistry”

No

Fu

Ch

to "

pre

cre

ver

effe

“W

pro

Cre

3.1

XI.

of e

wa

Dre

3.1

cre

ver

effe

“W

IV.C2.RP40

IV.C2-

17(R-24) Pressurizer: 

spray head

Nickel 

alloy Reactor coolant Cracking due to 

SCC, PWSCC

XI.M2, “Water 

Chemistry,” and 

XI.M32, “OneTime 

Inspection”

No

Re

AM

Item

sta

oth

De

eva
April 2011 II-169 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

rela

com

Se

two 

bec

are 

nic

sta

app

exi

“On

pro

ver

effe

“W

pro

SE

IV.C2.RP41

IV.C2-

17(R-24) Pressurizer: 

spray head

Stainless 

Steel Reactor coolant Cracking due 

to SCC

XI.M2, “Water 

Chemistry,” and 

XI.M32, “OneTime Inspection”

No

Se

two 

bec

are 

nic

sta

De

eva

rela

ass

allo

IV.C1.RP42

IV.C1-

12(R-26) Closure bolting

Steel; 

stainless 

steel

Air with reactor 

coolant 

leakage

Loss of 

material due to 

general (steel 

XI.M18, "Bolting 

Integrity" No

Co

cha

and 
NUREG-1950 II-170 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

only), pitting, 

and crevice 

corrosion or 

wear

bol

bol

cha

"St

En

cha

rea

lea

env

mo

agi

ma

AE

to l

me

"ge

pitt

cor

to “

des

gen

Bo

sta

ste

IV.C1.RP43

IV.C1-

10(R-27) Closure bolting

Steel; 

stainless 

steel

Air

Loss of preload 

due to thermal 

effects, gasket 

creep, and selfloosening

XI.M18, "Bolting 

Integrity" No

Co

cha

and 

bol

bol

cha

"St
April 2011 II-171 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

En

cha

tem

288

Clo

mo

des

pre

bot

sta

En

for 

oth

env

IV.C1.RP44

IV.C1-

11(R-28) Pump and valve 

closure bolting

Steel; 

stainless 

steel

System 

temperature up 

to 288°C 

(550°F)

Cumulative 

fatigue damage 

due to fatigue

Fatigue is a 

TLAA evaluated 

for the period of 

extended 

operation; check 

ASME Code 

limits for 

allowable cycles 

(<7000 cycles) of 

thermal stress 

range.(SRP Sec 

4.3, “Metal 

Fatigue,” for 

acceptable 

methods to 

comply with 10 

CFR 54.21(c)(1))

Yes, TLAA

Ma

to i

ste

agi

for 

pum

clo
NUREG-1950 II-172 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

IV.D1.RP46

IV.D2.RP46

IV.D1-

10(R-32)

IV.D2-

6(R-32)

Closure bolting

Steel; 

stainless 

steel

Air – indoor, 

uncontrolled 

(External)

Loss of preload 

due to thermal 

effects, gasket 

creep, and selfloosening

XI.M18, "Bolting 

Integrity" No

Ma

to i

ste

cha

of p

wit

sta

En

rev

ind

(ex

En

cha

con

bol

IV.D2.RP47

IV.D2-

4(R-35)

Primary side 

components: 

upper and 

lower heads, 

and tube sheet 

welds exposed 

to reactor 

coolant

Steel (with 

stainless 

steel or 

nickel-alloy 

cladding)

Reactor coolant Cracking due to 

SCC, PWSCC

XI.M1, “ASME 

Section XI 

Inservice 

Inspection, 

Subsections 

IWB, IWC, and 

IWD,” for Class 

1 components, 

XI.M2, “Water 

Chemistry”

No

AM

rev

com

rela

pre

com

rea

pen

and 

com

des

cla

res

nic

wh

allo
April 2011 II-173 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

bou

the

add

rela

pre

ma

nee

IV.D1.RP48

IV.D1-

16(R-41)

Steam generator 

structural: tube 

support lattice 

bars

Steel

Secondary 

feedwater or 

steam

Wall thinning 

due to flowaccelerated 

corrosion 

(FAC) and 

general 

corrosion

XI.M19, “Steam 

Generators,” 

and 

XI.M2, “Water 

Chemistry”

No

AE

to a

gen

AM

cha

Ge

Inte

Ge

the 

exp

mo

gen

IV.D1.RP49

IV.D1-

26(R-51)

Upper assembly 

and separators, 

including: 

feedwater inlet 

ring and support

Steel

Secondary 

feedwater or 

steam

Wall thinning 

due to flowaccelerated 

corrosion

XI.M19, “Steam 

Generators,” 

and 

XI.M2, “Water 

Chemistry”

No

AM

fro

“XI

“Fu

wa

"Ye

sco

wa

the

and 

this 

me
NUREG-1950 II-174 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

IV.A1.RP50

IV.A1-

11(R-59)

Top head 

enclosure 

(without 

cladding): top 

head; nozzles 

(vent, top head 

spray or RCIC, 

and spare)

Steel Reactor coolant

Loss of material 

due to general, 

pitting, and 

crevice 

corrosion

XI.M2, “Water 

Chemistry,” and 

XI.M32, “OneTime 

Inspection”

No

“Fu

cha

"No

pre

acc

Tim

pro

effe

“W

pro

Pilg

Sta

3.1

acc

tha

Ins

con

AM

cap

the 

this 

IV.A1.RP51

IV.A1-

9(R-60)

Top head 

enclosure: 

closure studs 

and nuts

Highstrength, 

low-alloy 

steel

Air with reactor 

coolant leakage

Cracking due to 

SCC, IGSCC 

XI.M3, “Reactor 

Head Closure 

Stud Bolting”

No

“Ma

to d

rela

ten

NU

1.6

sta

rec

act

stre
April 2011 II-175 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

stre

bol

exc

(15

pot

IGS

rec

hig

ma

AM

the

rep

Item

IV.A2.RP52

IV.A2-

2(R-71) Closure head: 

stud assembly

Highstrength, 

low-alloy 

steel

Air with reactor 

coolant leakage

Cracking due to 

SCC

XI.M3, “Reactor 

Head Closure 

Stud Bolting”

No

“Ma

to d

rela

ten

NU

1.6

sta

rec

act

stre

stre

bol

exc

(15

pot

IGS

rec

hig
NUREG-1950 II-176 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

ma

AM

the

rep

Item

IV.A2.RP53

IV.B4.RP53

IV.A2-

3(R-72) Closure head: 

stud assembly

Highstrength, 

low-alloy 

steel

Air with reactor 

coolant leakage

Loss of 

material due to 

general, 

pitting, and 

crevice 

corrosion or 

wear

XI.M3, “Reactor 

Head Closure 

Stud Bolting”

No

In N

RG 

the 

rec

act

stre

stre

bol

exc

(15

pot

IGS

rec

hig

ma

AM

the

rep

Item

effe

dep

yie

bol

Th

agi

los
April 2011 II-177 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

the

hav

pre

and 

the 

ass

eva

for 

Se

IV.A2.RP54

IV.A2-

4(R-73) Closure head: 

stud assembly

Highstrength, 

low-alloy 

steel

Air with reactor 

coolant leakage

Cumulative 

fatigue damage 

due to fatigue

Fatigue is a 

TLAA to be 

evaluated for the 

period of 

extended 

operation. See 

the SRP, 4.3, 

“Metal Fatigue,” 

for acceptable 

methods for 

meeting the 

requirements of 

10 CFR 

54.21(c)(1).

Yes, TLAA

“Ma

cha

wo

Ma

ma

cal

cha

con

clo

ass

IV.A2.RP55

IV.A2-

11(R-76)

CRD head 

penetration: 

pressure 

housing

Stainless 

steel; 

nickel alloy

Reactor coolant Cracking due to 

SCC, PWSCC

XI.M1, “ASME 

Section XI 

Inservice 

Inspection, 

Subsections 

IWB, IWC, and 

IWD,” for Class 

1 components, 

No

AM

XI.

ade

ma

com

pre

an 

com
NUREG-1950 II-178 April 2011

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

XI.M2, “Water 

Chemistry”

lon

XI.

app

sta

IV.A2.RP57

IV.A2-

12(R-88)

Core support 

pads; core guide 

lugs

Nickel alloy Reactor coolant Cracking due to

PWSCC

XI.M1, “ASME 

Section XI 

Inservice 

Inspection, 

Subsections 

IWB, IWC, and 

IWD,” for Class 

1 components, 

and

XI.M2, “Water 

Chemistry” 

No

Th

has 

del

com

not 

rea

inte

IV.A2.RP59

IV.A2-

19(R-89)

Penetrations: 

instrument tubes 

(bottom head)

Nickel alloy Reactor coolant Cracking due to 

PWSCC

XI.M1, “ASME 

Section XI 

Inservice 

Inspection, 

Subsections 

IWB, IWC, and 

IWD,” for Class 

1 components, 

XI.M2, “Water 

Chemistry,” and 

XI.M11B, 

“Cracking of 

Nickel-Alloy 

Components 

and Loss of 

No

Th

has 

inc

Th

app

XI.

ren

rep

rec

com

FS

rela

Item
April 2011 II-179 NUREG-1950

Table II-7. Changes to Existing GALL Report Rev. 1 Chapter IV AMR Items for Reactor Vessel, Internals, 

Their Technical Bases (cells where changes have been made are shown in bold –except for items prefix

(refer to the note in Section II.2), see Table II-14 for new definitions related to MRP-227 component categ

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

Material Due to 

Boric AcidInduced 

Corrosion in 

RCPB 

Components 

(PWRs Only)"
NUREG-1950 II-180 April 2011

Table II-8. Changes to Existing GALL Report Rev. 1 Chapter V AMR Items for Engineered Safety System

Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tec

V.A.EP100

V.A11(EP39)

Heat exchanger 

tubes Copper alloy Closed-cycle 

cooling water

Reduction of 

heat transfer 

due to 

fouling

XI.M21A, 

"Closed 

Treated Water 

Systems"

No

AMP 

chang

was e

encom

close

enviro

V.D1.EP101

V.D2-

18(EP2)

Piping, piping 

components, and 

piping elements

Aluminum Air with borated 

water leakage

Loss of 

material due 

to boric acid 

corrosion

XI.M10, “Boric 

Acid Corrosion” No

This 

previo

18(EP

origin

been 

subch

Exce

assig

conte

not ch

V.B.EP111

V.B9(E42)

Piping, piping 

components, and 

piping elements

Steel (with 

coating or 

wrapping)

Soil or 

concrete

Loss of 

material due 

to general, 

pitting, 

crevice, and 

MIC

XI.M41, 

"Buried and 

Underground 

Piping and 

Tanks"

No

“Mate

"with 

"with" 

wrapp

XI.M4

issue

to ste

wrapp

defini

or co

enviro

AMP 

furthe

requi
April 2011 II-181 NUREG-1950

Table II-8. Changes to Existing GALL Report Rev. 1 Chapter V AMR Items for Engineered Safety System

Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tec

V.F.EP112

V.F17(EP5)

Piping, piping 

components, and 

piping elements

Steel Concrete None

None, 

provided that

(1) attributes 

of the 

concrete are 

consistent 

with ACI 318 

or ACI 349 

(low water-tocement ratio, 

low 

permeability, 

and adequate 

air 

entrainment) 

as cited in

NUREG-1557 

and 

(2) plant OE 

indicates no 

degradation of 

the concrete

No, if 

conditions are 

met.

The A

been 

descr

of the 

need

“none

to allo

“Com

Misce

Mate

Comb

(subc

such 

line-it

requi

effect

expec

the a

struct

to pe

functi

exten

opera

V.D2.EP113

V.D2-

1(E04)

Drywell and 

suppression 

chamber spray 

system (internal 

surfaces): flow 

orifice; spray 

nozzles

Steel

Air – indoor, 

uncontrolled 

(Internal)

Loss of 

material 

due to 

general 

corrosion; 

fouling that 

leads to 

corrosion

A plant-specific 

aging 

management 

program is to 

be evaluated

Yes, plantspecific

AERM 

"fouli

corro

clarifi

can b

contr

but d

cause 
NUREG-1950 II-182 April 2011

Table II-8. Changes to Existing GALL Report Rev. 1 Chapter V AMR Items for Engineered Safety System

Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tec

V.B.EP58

V.B4(E06)

Elastomer seals 

and components Elastomers

Air – indoor, 

uncontrolled 

(Internal)

Hardening 

and loss of 

strength 

due to 

elastomer 

degradation

XI.M38, 

"Inspection of 

Internal 

Surfaces in 

Miscellaneous 

Piping and

Ducting 

Components"

No

AMP 

"plan

XI.M3

surfa

evalu

chang

"No." 

appro

mana

comb

the sc

XI.M3

includ

mana

elasto

V.B.EP59

V.B4(E06)

Elastomer seals 

and components Elastomers

Air – indoor, 

uncontrolled 

(External)

Hardening 

and loss of 

strength due 

to elastomer 

degradation

XI.M36, 

"External 

Surfaces 

Monitoring of

Mechanical 

Components"

No

AMP 

"plant

XI.M3

surfa

evalu

chang

"No." 

XI.M3

includ

mana

elasto

V.D2.EP60

V.D2-

33(E08)

Piping, piping 

components, and 

piping elements

Steel Treated water

Loss of 

material due 

to general, 

pitting, and 

crevice 

XI.M2, “Water 

Chemistry,” 

and 

XI.M32, “OneNo

Text 

was r

evalu

chang

"No." 
April 2011 II-183 NUREG-1950

Table II-8. Changes to Existing GALL Report Rev. 1 Chapter V AMR Items for Engineered Safety System

Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tec

corrosion Time 

Inspection”

prece

accep

Inspe

verific

effect

Chem

show

Secti

staff h

positi

Time 

progr

GALL 

adeq

effect

“Wate

progr

V.D2.EP61

V.D2-

35(E14)

Piping, piping 

components, and 

piping elements 

(Internal 

surfaces)

Stainless 

steel

Condensation 

(Internal)

Loss of 

material due 

to pitting and 

crevice 

corrosion

XI.M38, 

"Inspection of 

Internal 

Surfaces in 

Miscellaneous 

Piping and 

Ducting 

Components"

No

AMP 

"plan

XI.M3

Evalu

chang

"No." 

prece

accep

Intern

Misce

and D

Comp

as ve

effect
NUREG-1950 II-184 April 2011

Table II-8. Changes to Existing GALL Report Rev. 1 Chapter V AMR Items for Engineered Safety System

Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tec

Chem

show

Arnol

SER, 

3.2.2

has a

positi

“Insp

Surfa

Misce

and D

Comp

consi

AMP 

adeq

the a

of ma

visua

perfo

surfa

surve

maint

AMP 

to inc

mate

V.C.EP62

V.C6(E31)

Containment 

isolation piping 

and components 

(Internal 

surfaces)

Steel Treated water

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.M2, “Water 

Chemistry,” 

and 

XI.M32, “OneTime 

Inspection”

No

Text 

was r

evalu

chang

"No." 

prece
April 2011 II-185 NUREG-1950

Table II-8. Changes to Existing GALL Report Rev. 1 Chapter V AMR Items for Engineered Safety System

Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tec

accep

Inspe

verific

effect

Chem

show

Secti

staff h

positi

Time 

progr

GALL 

adeq

effect

“Wate

progr

V.C.EP63

V.C4(E33)

Containment 

isolation piping 

and components 

(Internal 

surfaces)

Stainless 

steel Treated water

Loss of 

material due 

to pitting and 

crevice 

corrosion

XI.M2, “Water 

Chemistry,” 

and 

XI.M32, “OneTime 

Inspection”

No

Text 

was r

evalu

chang

"No." 

prece

accep

Inspe

verific

effect

Chem

show

Secti

staff h

positi
NUREG-1950 II-186 April 2011

Table II-8. Changes to Existing GALL Report Rev. 1 Chapter V AMR Items for Engineered Safety System

Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tec

Time 

progr

GALL 

adeq

effect

“Wate

progr

V.E.EP64

V.E1(EP1) Bolting

Steel; 

stainless 

steel

Air – outdoor 

(External)

Loss of 

material 

due to 

general 

(steel only), 

pitting, and 

crevice 

corrosion

XI.M18, 

"Bolting 

Integrity"

No

“Mate

from 

stainl

was c

"due 

only)

than 

corro

gene

not a

steel 

enviro

may b

stainl

aging 

mech

applic

enviro

V.E.EP69

V.E5(EP24) Closure bolting

Steel; 

stainless 

steel

Air – indoor, 

uncontrolled 

(External)

Loss of 

preload due 

to thermal 

effects, 

gasket 

creep, and 

XI.M18, 

"Bolting 

Integrity"

No

“Mate

from 

stainl

prelo

both s

steel 
April 2011 II-187 NUREG-1950

Table II-8. Changes to Existing GALL Report Rev. 1 Chapter V AMR Items for Engineered Safety System

Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tec

selfloosening

V.E.EP70

V.E4(EP25) Closure bolting

Steel; 

stainless 

steel

Air – indoor, 

uncontrolled 

(External)

Loss of 

material 

due to 

general 

(steel only), 

pitting, and 

crevice 

corrosion

XI.M18, 

"Bolting 

Integrity"

No

“Mate

from 

stainl

was c

"due 

only)

than 

corro

gene

not a

steel 

enviro

may b

stainl

aging 

mech

applic

enviro

V.D2.EP71

V.D2-

19(EP26)

Piping, piping 

components, and 

piping elements

Aluminum Treated water

Loss of 

material due 

to pitting and 

crevice 

corrosion

XI.M2, “Water 

Chemistry,” 

and 

XI.M32, “OneTime 

Inspection”

No

Text 

was r

evalu

chang

"No." 

prece

accep

Inspe

verific

effect

Chem
NUREG-1950 II-188 April 2011

Table II-8. Changes to Existing GALL Report Rev. 1 Chapter V AMR Items for Engineered Safety System

Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tec

show

Secti

staff h

positi

Time 

progr

GALL 

adeq

effect

“Wate

progr

V.D1.EP72

V.D2.EP72

V.D1-

26(EP31)

V.D2-

27(EP31)

Piping, piping 

components, and 

piping elements

Stainless 

steel

Soil or 

concrete

Loss of 

material due 

to pitting and 

crevice 

corrosion

XI.M41, 

"Buried and 

Underground 

Piping and 

Tanks"

No

New 

issue

piping 

includ

concr

No Fu

need

V.D2.EP73

V.D2-

28(EP32)

Piping, piping 

components, and 

piping elements

Stainless 

steel Treated water

Loss of 

material due 

to pitting and 

crevice 

corrosion

XI.M2, “Water 

Chemistry,” 

and 

XI.M32, “OneTime 

Inspection”

No

Text 

was r

evalu

from 

appro

exists 

“One

progr

of eff

“Wate

progr

DAEC 

3.2.2
April 2011 II-189 NUREG-1950

Table II-8. Changes to Existing GALL Report Rev. 1 Chapter V AMR Items for Engineered Safety System

Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tec

has a

positi

Time 

progr

GALL 

adeq

effect

“Wate

progr

V.A.EP74

V.D2.EP74

V.A16(EP34)

V.D2-

13(EP34)

Heat exchanger 

tubes

Stainless 

steel Treated water

Reduction of 

heat transfer 

due to 

fouling

XI.M2, “Water 

Chemistry,” 

and 

XI.M32, “OneTime 

Inspection”

No

Text 

was r

evalu

chang

"No." 

prece

accep

Inspe

verific

effect

Chem

show

Secti

staff h

positi

Time 

progr

GALL 

adeq

effect

“Wate

progr
NUREG-1950 II-190 April 2011

Table II-8. Changes to Existing GALL Report Rev. 1 Chapter V AMR Items for Engineered Safety System

Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tec

V.A.EP75

V.D1.EP75

V.D2.EP75

V.A17(EP40)

V.D1-

12(EP40)

V.D2-

14(EP40)

Heat exchanger 

tubes Steel Lubricating oil

Reduction of 

heat transfer 

due to 

fouling

XI.M39, 

"Lubricating 

Oil Analysis," 

and 

XI.M32, “OneTime 

Inspection”

No

Text 

was r

evalu

chang

"No." 

prece

accep

Inspe

verific

effect

“Lubr

Analy

show

Secti

staff h

positi

Time 

progr

GALL 

adeq

effect

“Lubr

Analy

V.A.EP76

V.D1.EP76

V.D2.EP76

V.A21(EP45)

V.D1-

19(EP45)

V.D2-

22(EP45)

Piping, piping 

components, and 

piping elements

Copper alloy Lubricating oil

Loss of 

material due 

to pitting and 

crevice 

corrosion

XI.M39, 

"Lubricating 

Oil Analysis," 

and 

XI.M32, “OneTime 

Inspection” 

No

Text 

was r

evalu

chang

"No." 

prece

accep

Inspe
April 2011 II-191 NUREG-1950

Table II-8. Changes to Existing GALL Report Rev. 1 Chapter V AMR Items for Engineered Safety System

Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tec

verific

effect

“Lubr

Analy

show

Secti

staff h

positi

Time 

progr

GALL 

adeq

effect

“Lubr

Analy

V.A.EP77

V.D1.EP77

V.D2.EP77

V.A25(EP46)

V.D1-

28(EP46)

V.D2-

30(EP46)

Piping, piping 

components, and 

piping elements

Steel Lubricating oil

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.M39, 

"Lubricating 

Oil Analysis," 

and 

XI.M32, “OneTime 

Inspection”

No

Text 

was r

evalu

chang

"No." 

prece

accep

Inspe

verific

effect

“Lubr

Analy

show

Secti

staff h

positi
NUREG-1950 II-192 April 2011

Table II-8. Changes to Existing GALL Report Rev. 1 Chapter V AMR Items for Engineered Safety System

Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tec

Time 

progr

GALL 

adeq

effect

“Lubr

Analy

V.A.EP78

V.D1.EP78

V.D2.EP78

V.A12(EP47)

V.D1-

8(EP47)

V.D2-

9(EP47)

Heat exchanger 

tubes Copper alloy Lubricating oil

Reduction of 

heat transfer 

due to 

fouling

XI.M39, 

"Lubricating 

Oil Analysis," 

and 

XI.M32, “OneTime 

Inspection”

No

Text 

was r

evalu

chang

"No." 

prece

accep

Inspe

verific

effect

“Lubr

Analy

show

Secti

staff h

positi

Time 

progr

GALL 

adeq

effect

“Lubr

Analy

V.A.EP- V.A- Heat exchanger Stainless Lubricating oil Reduction of XI.M39, No Text 
April 2011 II-193 NUREG-1950

Table II-8. Changes to Existing GALL Report Rev. 1 Chapter V AMR Items for Engineered Safety System

Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tec

79

V.D1.EP79

V.D2.EP79

14(EP50)

V.D1-

10(EP50)

V.D2-

11(EP50)

tubes steel heat transfer 

due to 

fouling

"Lubricating 

Oil Analysis," 

and 

XI.M32, “OneTime 

Inspection”

was r

evalu

chang

"No." 

prece

accep

Inspe

verific

effect

“Lubr

Analy

show

Secti

staff h

positi

Time 

progr

GALL 

adeq

effect

“Lube 

progr

V.D1.EP80

V.D1-

24(EP51)

Piping, piping 

components, and 

piping elements

Stainless 

steel Lubricating oil

Loss of 

material due 

to pitting and 

crevice 

corrosion

XI.M39, 

"Lubricating 

Oil Analysis," 

and 

XI.M32, “OneTime 

Inspection”

No

Text 

was r

Evalu

chang

"No." 

prece

accep

Inspe

verific
NUREG-1950 II-194 April 2011

Table II-8. Changes to Existing GALL Report Rev. 1 Chapter V AMR Items for Engineered Safety System

Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tec

effect

“Lubr

Analy

show

Secti

staff h

positi

Time 

progr

GALL 

adeq

effect

“Lubr

Analy

V.A.EP81

V.D1.EP81

V.A26(EP53)

V.D1-

29(EP53)

Piping, piping 

components, and 

piping elements 

(Internal 

surfaces); tanks

Stainless 

steel

Condensation 

(Internal)

Loss of 

material due 

to pitting and 

crevice 

corrosion

XI.M38, 

"Inspection of 

Internal 

Surfaces in 

Miscellaneous 

Piping and 

Ducting 

Components"

No

AMP 

"plan

XI.M3

evalu

chang

"No." 

prece

accep

Intern

Misce

and D

Comp

as ve

effect

Chem

show

Secti
April 2011 II-195 NUREG-1950

Table II-8. Changes to Existing GALL Report Rev. 1 Chapter V AMR Items for Engineered Safety System

Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tec

staff h

positi

“Insp

Surfa

Misce

and D

Comp

consi

AMP 

adeq

the a

of ma

visua

perfo

surfa

surve

maint

AMP 

to inc

mate

V.A.EP90

V.D1.EP90

V.D2.EP90

V.A10(E18)

V.D1-

7(E18)

V.D2-

8(E18)

Heat exchanger 

components Steel Raw water

Loss of 

material 

due to 

general, 

pitting, 

crevice, 

and MIC; 

fouling that 

leads to 

corrosion

XI.M20, "OpenCycle Cooling 

Water System"

No

AERM 

say "f

to cor

clarifi

can b

contr

but d

cause 

V.A.EP- V.A- Heat exchanger Stainless Raw water Loss of XI.M20, "Open- No AERM 
NUREG-1950 II-196 April 2011

Table II-8. Changes to Existing GALL Report Rev. 1 Chapter V AMR Items for Engineered Safety System

Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tec

91

V.D1.EP91

V.D2.EP91

8(E20)

V.D1-

5(E20)

V.D2-

6(E20)

components steel material 

due to 

pitting, 

crevice, 

and MIC; 

fouling that 

leads to 

corrosion

Cycle Cooling 

Water System"

say "f

to cor

clarifi

can b

contr

but d

cause 

V.A.EP92

V.D1.EP92

V.D2.EP92

V.A9(E17)

V.D1-

6(E17)

V.D2-

7(E17)

Heat exchanger 

components Steel Closed-cycle 

cooling water

Loss of 

material due 

to general, 

pitting, 

crevice, and 

galvanic 

corrosion

XI.M21A, 

"Closed 

Treated Water 

Systems"

No

AMP 

chang

was e

encom

close

enviro

V.A.EP93

V.D1.EP93

V.D2.EP93

V.A7(E19)

V.D1-

4(E19)

V.D2-

5(E19)

Heat exchanger 

components

Stainless 

steel

Closed-cycle 

cooling water

Loss of 

material due 

to pitting and 

crevice 

corrosion

XI.M21A, 

"Closed 

Treated Water 

Systems"

No

AMP 

chang

was e

encom

close

enviro

V.A.EP94

V.D1.EP94

V.D2.EP94

V.A5(EP13)

V.D1-

2(EP13)

V.D2-

3(EPHeat exchanger 

components Copper alloy Closed-cycle 

cooling water

Loss of 

material due 

to pitting, 

crevice, and 

galvanic 

corrosion

XI.M21A, 

"Closed 

Treated Water 

Systems"

No

AMP 

chang

was e

encom

close

enviro
April 2011 II-197 NUREG-1950

Table II-8. Changes to Existing GALL Report Rev. 1 Chapter V AMR Items for Engineered Safety System

Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tec

13)

V.A.EP95

V.C.EP95

V.D1.EP95

V.D2.EP95

V.A23(EP33)

V.C7(EP33)

V.D1-

22(EP33)

V.D2-

25(EP33)

Piping, piping 

components, and 

piping elements

Stainless 

steel

Closed-cycle 

cooling water

Loss of 

material due 

to pitting and 

crevice 

corrosion

XI.M21A, 

"Closed 

Treated Water 

Systems"

No

AMP 

chang

was e

encom

close

enviro

V.A.EP96

V.D1.EP96

V.D2.EP96

V.A13(EP35)

V.D1-

19(EP35)

V.D2-

10(EP35)

Heat exchanger 

tubes

Stainless 

steel

Closed-cycle 

cooling water

Reduction of 

heat transfer 

due to 

fouling

XI.M21A, 

"Closed 

Treated Water 

Systems"

No

AMP 

chang

was e

encom

close

enviro

V.A.EP97

V.B.EP97

V.D1.EP97

V.D2.EP97

V.A20(EP36)

V.B6(EP36)

V.D1-

17(EP36)

V.D2-

21(EP36)

Piping, piping 

components, and 

piping elements

Copper alloy Closed-cycle 

cooling water

Loss of 

material due 

to pitting, 

crevice, and 

galvanic 

corrosion

XI.M21A, 

"Closed 

Treated Water 

Systems"

No

AMP 

chang

was e

encom

close

enviro
NUREG-1950 II-198 April 2011

Table II-8. Changes to Existing GALL Report Rev. 1 Chapter V AMR Items for Engineered Safety System

Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment

Aging 

Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tec

V.A.EP98

V.C.EP98

V.D1.EP98

V.D2.EP98

V.A24(EP44)

V.C8(EP44)

V.D1-

23(EP44)

V.D2-

26(EP44)

Piping, piping 

components, and 

piping elements

Stainless 

steel

Closed-cycle 

cooling water 

>60°C (>140°F)

Cracking 

due to SCC

XI.M21A, 

"Closed 

Treated Water 

Systems"

No

AMP 

chang

was e

encom

close

enviro

V.C.EP99

V.C9(EP48)

Piping, piping 

components, and 

piping elements

Steel Closed-cycle 

cooling water

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.M21A, 

"Closed 

Treated Water 

Systems"

No

AMP 

chang

was e

encom

close

enviro
April 2011 II-199 NUREG-1950

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

VII.A3.AP100

VII.A3-

1(A-15) Elastomers, 

linings Elastomers Treated borated 

water

Hardening 

and loss of 

strength due 

to elastomer 

degradation

XI.M38, 

"Inspection of 

Internal 

Surfaces in 

Miscellaneous 

Piping and 

Ducting 

Components"

No

AMP 

revis

man

“hard

stren

com

VII.A4.AP101

VII.A4-

1(A-16) Elastomers, 

linings Elastomers Treated water

Hardening 

and loss of 

strength due 

to elastomer 

degradation

XI.M38, 

"Inspection of 

Internal 

Surfaces in 

Miscellaneous 

Piping and 

Ducting 

Components"

No

AMP 

revis

man

“hard

stren

com

VII.F1.AP102

VII.F2.AP102

VII.F3.AP102

VII.F4.AP102

VII.F1-

7(A-17)

VII.F2-

7(A-17)

VII.F3-

7(A-17)

VII.F4-

6(A-17)

Elastomer: seals 

and components Elastomers

Air – indoor, 

uncontrolled 

(Internal/External)

Hardening 

and loss of 

strength due 

to elastomer 

degradation

XI.M36, 

"External 

Surfaces 

Monitoring of 

Mechanical 

Components"

No

AMP 

revis

man

“hard

stren

com

can 

exte

elast

inter

the e

sam

and 

VII.F1.AP103VII.F1-

6(A-18)

Elastomer: seals 

and components Elastomers Air – indoor, 

uncontrolled 

Loss of 

material 

XI.M38, 

"Inspection of No AMP 

inclu
NUREG-1950 II-200 April 2011

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

VII.F2.AP103

VII.F3.AP103

VII.F4.AP103

VII.F2-

6(A-18)

VII.F3-

6(A-18)

VII.F4-

5(A-18)

(Internal) due to wear Internal 

Surfaces in 

Miscellaneous 

Piping and 

Ducting 

Components"

man

elast

The 

visua

phys

to de

mate

VII.H2.AP

-104

VII.H2-

2(A-27)

Piping, piping 

components, and 

piping elements, 

diesel engine 

exhaust

Steel; 

stainless 

steel

Diesel exhaust

Loss of 

material due 

to general 

(steel only), 

pitting, and 

crevice 

corrosion

XI.M38, 

"Inspection of 

Internal 

Surfaces in 

Miscellaneous 

Piping and 

Ducting 

Components"

No

An a

exist

“Insp

Surf

Misc

and 

Com

As s

SER 

3.3.2

acce

that 

Inter

Misc

and 

Com

cons

AMP 

adeq

the a

XI.M

inclu

mate

VII.H1.AP

-105

VII.H1-

10(APiping, piping 

components, and Steel Fuel oil Loss of material due 

XI.M30, “Fuel 

Oil Chemistry,” No An a

exist
April 2011 II-201 NUREG-1950

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

VII.H2.AP

-105

30)

VII.H2-

24(A30)

piping elements; 

tanks

to general, 

pitting, 

crevice, and 

MIC; fouling 

that leads to 

corrosion

and 

XI.M32, “OneTime 

Inspection”

“One

prog

of ef

Oil C

As s

SER 

3.3.2

acce

that 

Insp

cons

AMP 

adeq

effec

“Fue

prog

VII.E3.AP106

VII.E4.AP106

VII.E3-

18(A35)

VII.E4-

17(A35)

Piping, piping 

components, and 

piping elements

Steel Treated water

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.M2, “Water 

Chemistry,” 

and 

XI.M32, “OneTime 

Inspection”

No

An a

exist

“One

prog

of ef

“Wa

prog

JAFN

FitzP

Pow

Sect

staff 

posit

Time 

prog

GAL
NUREG-1950 II-202 April 2011

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

adeq

effec

“Wa

prog

VII.A3.AP107

VII.A3-

9(A-39)

Piping, piping 

components, and 

piping elements

Steel (with 

elastomer 

lining)

Treated water

Loss of 

material due 

to pitting and 

crevice 

corrosion 

(only for steel 

after 

lining/cladding 

degradation)

XI.M2, “Water 

Chemistry,” 

and 

XI.M32, “OneTime 

Inspection”

No

An a

exist

“One

prog

of ef

“Wa

prog

CNS 

Stati

3.3.2

has 

posit

Time 

prog

GAL

adeq

effec

“Wa

prog

VII.A4.AP108

VII.A4-

12(A40)

Piping, piping 

components, and 

piping elements

Steel (with 

elastomer 

lining or 

stainless 

steel 

cladding)

Treated water

Loss of 

material due 

to pitting and 

crevice 

corrosion 

(only for steel 

after 

lining/cladding 

degradation)

XI.M2, “Water 

Chemistry,” 

and 

XI.M32, “OneTime 

Inspection”

No

An a

exist

“One

prog

of ef

“Wa

As s

Sect

the s
April 2011 II-203 NUREG-1950

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

the p

Time 

prog

GAL

adeq

effec

“Wa

prog

VII.F1.AP109

VII.F2.AP109

VII.F3.AP109

VII.F4.AP109

VII.F1-

16(A46)

VII.F2-

14(A46)

VII.F3-

16(A46)

VII.F4-

12(A46)

Piping, piping 

components, and 

piping elements

Copper alloy Condensation 

(External)

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.M36, 

"External 

Surfaces 

Monitoring of 

Mechanical 

Components"

No

An a

exist

GAL

the m

agin

alloy

WCG

3.3.2

has 

posit

Exte

Mon

Mec

Com

cons

AMP 

adeq

the a

of m

VII.A4.AP110

VII.E3.AP110

VII.E4.APVII.A4-

11(A58)

VII.E3-

15(A58)

Piping, piping 

components, and 

piping elements

Stainless 

steel Treated water

Loss of 

material due 

to pitting and 

crevice 

corrosion

XI.M2, “Water 

Chemistry,” 

and 

XI.M32, “OneTime 

No

An a

exist

“One

prog

of ef
NUREG-1950 II-204 April 2011

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

110 VII.E4-

14(A58)

Inspection” “Wa

prog

CNS 

3.3.2

has 

posit

Time 

prog

GAL

adeq

effec

“Wa

prog

VII.A4.AP111

VII.A4-

2(A-70) Heat exchanger 

components

Stainless 

steel; steel 

with 

stainless 

steel 

cladding

Treated water

Loss of 

material due 

to pitting and 

crevice 

corrosion

XI.M2, “Water 

Chemistry,” 

and 

XI.M32, “OneTime 

Inspection”

No

An a

exist

“One

prog

of ef

“Wa

prog

Pilgr

3.3.2

has 

posit

Time 

prog

GAL

adeq

effec

“Wa

prog

VII.E3.AP- VII.E3- Heat exchanger Stainless Treated water Cracking due XI.M2, “Water No An a
April 2011 II-205 NUREG-1950

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

112 3(A-71) components steel; steel 

with 

stainless 

steel 

cladding

>60°C (>140°F) to SCC Chemistry,” 

and 

XI.M32, “OneTime 

Inspection”

exist

“One

prog

of ef

“Wa

prog

CNS 

3.3.2

acce

that 

Insp

cons

AMP 

adeq

effec

“Wa

prog

VII.F1.AP113

VII.F2.AP113

VII.F3.AP113

VII.F4.AP113

VII.F1-

5(A-73)

VII.F2-

5(A-73)

VII.F3-

5(A-73)

VII.F4-

4(A-73)

Elastomer: seals 

and components Elastomers

Air – indoor, 

uncontrolled 

(External)

Loss of 

material due 

to wear

XI.M36, 

"External 

Surfaces 

Monitoring of 

Mechanical 

Components"

No

AMP 

inclu

man

elast

The 

visua

phys

to de

mate

VII.E1.AP114

VII.E1-

7(A-76) High-pressure 

pump, casing

Stainless 

steel

Treated borated 

water >60°C 

(>140°F)

Cracking due 

to SCC

XI.M2, “Water 

Chemistry,” 

and 

XI.M32, “OneTime 

No

An a

exist

“One

prog

of ef

“Wa
NUREG-1950 II-206 April 2011

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

Inspection” prog

WCG

3.3.2

acce

that 

Insp

cons

AMP 

adeq

effec

“Wa

prog

VII.E1.AP115

VII.E1-

5(A-76) High-pressure 

pump, casing

Stainless 

steel

Treated borated 

water

Cracking due 

to cyclic 

loading

XI.M1, "ASME 

Section XI 

Inservice 

Inspection, 

Subsections 

IWB, IWC, and 

IWD"

No

“Wat

not m

due 

VII.G.AP116

VII.G27(A82)

Reactor coolant 

pump oil 

collection 

system: tanks

Steel Lubricating oil

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.M39, 

"Lubricating 

Oil Analysis," 

and 

XI.M32, “OneTime 

Inspection”

No

An a

exist

“One

prog

of ef

“Lub

Anal

show

Sect

staff 

posit

Time 

prog
April 2011 II-207 NUREG-1950

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

GAL

adeq

effec

“Lub

Anal

VII.G.AP117

VII.G26(A83)

Reactor coolant 

pump oil 

collection 

system: piping, 

tubing, valve 

bodies

Steel Lubricating oil

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.M39, 

"Lubricating 

Oil Analysis," 

and 

XI.M32, “OneTime 

Inspection”

No

An a

exist

“One

prog

of ef

“Lub

Anal

show

Sect

staff 

posit

Time 

prog

GAL

adeq

effec

“Lub

Anal

VII.E1.AP118

VII.E1-

5(A-84) Heat exchanger 

components

Stainless 

steel

Treated borated 

water >60°C 

(>140°F)

Cracking due 

to SCC

XI.M2, “Water 

Chemistry,” 

and 

XI.M32, “OneTime 

Inspection”

No

An a

exist

“One

prog

of ef

“Wa

prog

WCG

3.3.2
NUREG-1950 II-208 April 2011

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

acce

that 

Insp

cons

AMP 

adeq

effec

“Wa

prog

VII.E1.AP119

VII.E1-

5(A-84)

Heat exchanger 

components and 

tubes

Stainless 

steel

Treated borated 

water >60°C 

(>140°F)

Cracking due 

to cyclic 

loading

XI.M1, "ASME 

Section XI 

Inservice 

Inspection, 

Subsections 

IWB, IWC, and 

IWD"

No

Wate

man

cycli

VII.E3.AP120

VII.E3-

19(A85)

Regenerative 

heat exchanger 

components

Stainless 

steel

Treated water 

>60°C (>140°F)

Cracking due 

to SCC

XI.M2, “Water 

Chemistry,” 

and 

XI.M32, “OneTime 

Inspection”

No

An a

exist

“One

prog

of ef

“Wa

prog

CNS 

3.3.2

acce

that 

Insp

cons

AMP 

adeq

effec
April 2011 II-209 NUREG-1950

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

“Wa

prog

VII.D.AP121

VII.D1(A103) Closure bolting

Steel; 

stainless 

steel

Condensation

Loss of 

material due 

to general 

(steel only), 

pitting, and 

crevice 

corrosion

XI.M18, "Bolting 

Integrity" No

Bolti

stee

this 

the a

effec

of th

state

VII.E1.AP122

VII.E1-

8(A104)

High-pressure 

pump, closure 

bolting

Steel, highstrengthAir with steam or 

water leakage

Cracking due 

to SCC; 

cyclic loading

XI.M18, 

"Bolting 

Integrity"

No

XI.M

revis

reco

high

VII.I.AP124

VII.I5(AP26) Closure bolting

Steel; 

stainless 

steel

Air – indoor, 

uncontrolled 

(External)

Loss of 

preload due to 

thermal 

effects, 

gasket creep, 

and selfloosening

XI.M18, "Bolting 

Integrity" No

“Los

occu

and 

bolts

VII.I.AP125

VII.I4(AP27) Closure bolting

Steel; 

stainless 

steel

Air – indoor, 

uncontrolled 

(External)

Loss of 

material due 

to general 

(steel only), 

pitting, and 

crevice 

corrosion

XI.M18, "Bolting 

Integrity" No

Bolti

stee

this 

the a

effec

of th

state

VII.I.AP126

VII.I1(AP28)

Bolting

Steel; 

stainless 

steel

Air – outdoor 

(External)

Loss of 

material due 

to general 

XI.M18, "Bolting 

Integrity" No

Bolti

stee

this 
NUREG-1950 II-210 April 2011

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

(steel only), 

pitting, and 

crevice 

corrosion

the a

effec

of th

state

VII.C1.AP

-127

VII.C2.AP

-127

VII.E1.AP127

VII.E4.AP127

VII.F1.AP127

VII.F2.AP127

VII.F3.AP127

VII.F4.AP127

VII.G.AP127

VII.H2.AP

-127

VII.C1-

17(AP30)

VII.C2-

13(AP30)

VII.E1-

19(AP30)

VII.E4-

16(AP30)

VII.F1-

19(AP30)

VII.F2-

17(AP30)

VII.F3-

19(AP30)

VII.F4-

15(AP30)

VII.G22(AP30)

VII.H2-

20(AP30)

Piping, piping 

components, and 

piping elements

Steel Lubricating oil

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.M39, 

"Lubricating 

Oil Analysis," 

and 

XI.M32, “OneTime 

Inspection”

No

An a

exist

“One

prog

of ef

“Lub

Anal

show

Sect

staff 

posit

Time 

prog

GAL

adeq

effec

“Lub

Anal

VII.H2.AP

-128

VII.H2-

1(APDiesel engine 

exhaust piping, Stainless Diesel exhaust Cracking due XI.M38, 

"Inspection of No An a

exist
April 2011 II-211 NUREG-1950

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

33) piping 

components, and 

piping elements

steel to SCC Internal 

Surfaces in 

Miscellaneous 

Piping and 

Ducting 

Components"

“Insp

Surf

Misc

and 

Com

As s

SER 

3.3.2

acce

that 

Inter

Misc

and 

Com

cons

AMP 

revis

stee

adeq

the a

beca

insp

perfo

surfa

surv

main

VII.H1.AP

-129

VII.H2.AP

-129

VII.H1-

1(AP35)

VII.H2-

7(AP35)

Piping, piping 

components, and 

piping elements

Aluminum Fuel oil

Loss of 

material due 

to pitting, 

crevice, and 

MIC

XI.M30, “Fuel 

Oil Chemistry,” 

and 

XI.M32, “OneTime 

Inspection”

No

An a

exist

“One

prog

of ef

Oil C
NUREG-1950 II-212 April 2011

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

As s

SER 

3.3.2

has 

posit

Time 

prog

GAL

adeq

effec

“Fue

prog

VII.A4.AP130

VII.E3.AP130

VII.E4.AP130

VII.A4-

5(AP38)

VII.E3-

7(AP38)

VII.E4-

4(AP38)

Piping, piping 

components, and 

piping elements

Aluminum Treated water

Loss of 

material due 

to pitting and 

crevice 

corrosion

XI.M2, “Water 

Chemistry,” 

and 

XI.M32, “OneTime 

Inspection”

No

An a

exist

“One

prog

of ef

“Wa

prog

CNS 

3.3.2

has 

posit

Time 

prog

GAL

adeq

effec

“Wa

prog

VII.H2.AP

-131

VII.H2-

5(APHeat exchanger 

components Steel Lubricating oil Loss of 

material due 

XI.M39, 

"Lubricating No An a

exist
April 2011 II-213 NUREG-1950

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

39) to general, 

pitting, 

crevice, and 

MIC; fouling 

that leads to 

corrosion

Oil Analysis," 

and 

XI.M32, “OneTime 

Inspection”

“One

prog

of ef

“Lub

Anal

show

Sect

staff 

posit

Time 

prog

GAL

adeq

effec

“Lub

Anal

VII.G.AP132

VII.H1.AP

-132

VII.H2.AP

-132

VII.G10(AP44)

VII.H1-

3(AP44)

VII.H2-

9(AP44)

Piping, piping 

components, and 

piping elements

Copper alloy Fuel oil

Loss of 

material due 

to general, 

pitting, 

crevice, and 

MIC

XI.M30, “Fuel 

Oil Chemistry,” 

and 

XI.M32, “OneTime 

Inspection”

No

An a

exist

“One

prog

of ef

Oil C

As s

SER 

3.3.2

has 

posit

Time 

prog

GAL

adeq

effec
NUREG-1950 II-214 April 2011

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

“Fue

prog

VII.C1.AP

-133

VII.C2.AP

-133

VII.E1.AP133

VII.E4.AP133

VII.G.AP133

VII.H2.AP

-133

VII.C1-

8(AP47)

VII.C2-

5(AP47)

VII.E1-

12(AP47)

VII.E4-

6(AP47)

VII.G11(AP47)

VII.H2-

10(AP47)

Piping, piping 

components, and 

piping elements

Copper alloy Lubricating oil

Loss of 

material due 

to pitting and 

crevice 

corrosion

XI.M39, 

"Lubricating 

Oil Analysis," 

and 

XI.M32, “OneTime 

Inspection”

No

An a

exist

“One

prog

of ef

“Lub

Anal

show

Sect

the s

the p

Time 

prog

GAL

adeq

effec

“Lub

Anal

VII.G.AP136

VII.H1.AP

-136

VII.H2.AP

-136

VII.G17(AP54)

VII.H1-

6(AP54)

VII.H2-

16(AP54)

Piping, piping 

components, and 

piping elements

Stainless 

steel Fuel oil

Loss of 

material due 

to pitting, 

crevice, and 

MIC

XI.M30, “Fuel 

Oil Chemistry,” 

and 

XI.M32, “OneTime 

Inspection”

No

An a

exist

“One

prog

of ef

Oil C

As s

SER 

3.3.2

has 

posit

Time 
April 2011 II-215 NUREG-1950

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

prog

GAL

adeq

effec

“Fue

prog

VII.C1.AP

-137

VII.C3.AP

-137

VII.G.AP137

VII.H1.AP

-137

VII.H2.AP

-137

VII.C1-

16(AP56)

VII.C3-

8(AP56)

VII.G20(AP56)

VII.H1-

7(AP56)

VII.H2-

19(AP56)

Piping, piping 

components, and 

piping elements

Stainless 

steel Soil or concrete

Loss of 

material 

due to pitting 

and crevice 

corrosion

XI.M41, 

"Buried and 

Underground 

Piping and 

Tanks"

No

An a

exist

“Bur

Tank

prog

of m

stee

envi

in TM

3.3.2

has 

posit

Pipin

Insp

cons

AMP 

adeq

this a

GAL

inclu

besid

“Bur

Tank

and 

Pipin

Insp
NUREG-1950 II-216 April 2011

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

com

“Bur

Und

and 

VII.C1.AP

-138

VII.C2.AP

-138

VII.E1.AP138

VII.E4.AP138

VII.G.AP138

VII.H2.AP

-138

VII.C1-

14(AP59)

VII.C2-

12(AP59)

VII.E1-

15(AP59)

VII.E4-

12(AP59)

VII.G18(AP59)

VII.H2-

17(AP59)

Piping, piping 

components, and 

piping elements

Stainless 

steel Lubricating oil

Loss of 

material due 

to pitting, 

crevice, and 

MIC

XI.M39, 

"Lubricating 

Oil Analysis," 

and 

XI.M32, “OneTime 

Inspection”

No

An a

exist

“One

prog

of ef

“Lub

Anal

show

Sect

the s

the p

Time 

prog

GAL

adeq

effec

“Lub

Anal

VII.A4.AP139

VII.E3.AP139

VII.A4-

4(AP62)

VII.E3-

6(AP62)

Heat exchanger 

tubes

Stainless 

steel Treated water

Reduction of 

heat transfer 

due to fouling

XI.M2, “Water 

Chemistry,” 

and 

XI.M32, “OneTime 

Inspection”

No

An a

exist

“One

prog

of ef

“Wa

prog

VYN

3.3.2

acce
April 2011 II-217 NUREG-1950

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

that 

Insp

cons

AMP 

adeq

effec

“Wa

prog

VII.A4.AP140

VII.E3.AP140

VII.E4.AP140

VII.A4-

7(AP64)

VII.E3-

9(AP64)

VII.E4-

7(AP64)

Piping, piping 

components, and 

piping elements

Copper alloy Treated water

Loss of 

material due 

to general, 

pitting, 

crevice, and 

galvanic 

corrosion

XI.M2, “Water 

Chemistry,” 

and 

XI.M32, “OneTime 

Inspection”

No

An a

exist

“One

prog

of ef

“Wa

prog

VYN

3.3.2

acce

that 

Insp

cons

AMP 

adeq

effec

“Wa

prog

VII.E2.AP141

VII.E2-

1(AP73)

Piping, piping 

components, and 

piping elements

Stainless 

steel

Sodium 

pentaborate 

solution

Loss of 

material due 

to pitting and 

crevice 

corrosion

XI.M2, “Water 

Chemistry,” 

and 

XI.M32, “OneTime 

No

An a

exist

“One

prog

of ef

“Wa
NUREG-1950 II-218 April 2011

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

Inspection” prog

VYN

3.3.2

has 

posit

Time 

prog

GAL

adeq

effec

“Wa

prog

VII.F1.AP142

VII.F2.AP142

VII.F3.AP142

VII.F4.AP142

VII.F1-

14(AP74)

VII.F2-

12(AP74)

VII.F3-

14(AP74)

VII.F4-

10(AP74)

Piping, piping 

components, and 

piping elements

Aluminum Condensation 

(Internal)

Loss of 

material due 

to pitting and 

crevice 

corrosion

XI.M38, 

"Inspection of 

Internal 

Surfaces in 

Miscellaneous 

Piping and 

Ducting 

Components"

No

An a

exist

“Insp

Surf

Misc

and 

Com

As s

SER 

3.3.2

has 

posit

“Insp

Surf

Misc

and 

Com

cons

AMP 

adeq
April 2011 II-219 NUREG-1950

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

the a

of m

visua

perfo

surfa

surv

main

AMP 

to in

mate

VII.G.AP143

VII.G9(AP78)

Piping, piping 

components, and 

piping elements

Copper alloy Condensation 

(Internal)

Loss of 

material due

to general, 

pitting, and 

crevice 

corrosion

XI.M38, 

"Inspection of 

Internal 

Surfaces in 

Miscellaneous 

Piping and 

Ducting 

Components"

No

An a

exist

Insp

Surf

Misc

and 

Com

As s

SER 

3.3.2

has 

posit

“Insp

Surf

Misc

and 

Com

cons

AMP 

adeq

the a

of m
NUREG-1950 II-220 April 2011

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

visua

perfo

surfa

surv

main

AMP 

to in

mate

VII.C1.AP

-179

VII.C1-

3(A-65) Heat exchanger

components Copper alloy Raw water

Loss of 

material due 

to general, 

pitting, 

crevice, 

galvanic, and 

MIC; fouling 

that leads to 

corrosion

XI.M20, "OpenCycle Cooling 

Water System"

No

Agin

“foul

“foul

corro

caus

Foul

corro

caus

VII.G.AP180

VII.G8(AP83)

Piping, piping 

components, and 

piping elements

Aluminum Raw water

Loss of 

material due 

to pitting and 

crevice 

corrosion

XI.M27, "Fire 

Water System" No

Erro

the G

corre

colu

from 

Prot

“Fire 

VII.E2.AP181

VII.E2-

2(A-59)

Piping, piping 

components, and 

piping elements

Stainless 

steel

Sodium 

pentaborate 

solution >60°C 

(>140°F)

Cracking due 

to SCC

XI.M2, “Water 

Chemistry,” 

and 

XI.M32, “OneTime 

Inspection”

No

The 

“One

prog

GAL

acce

effec

“Wa
April 2011 II-221 NUREG-1950

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

prog

agin

adeq

VII.C1.AP

-183

VII.C1-

5(A-64) Heat exchanger 

components Steel Raw water

Loss of 

material due 

to general, 

pitting, 

crevice, 

galvanic, and 

MIC; fouling 

that leads to 

corrosion

XI.M20, "OpenCycle Cooling 

Water System"

No

Agin

“foul

“foul

corro

caus

Foul

corro

caus

VII.C2.AP

-186

VII.E3.AP186

VII.E4.AP186

VII.C2-

11(AP60)

VII.E3-

13(AP60)

VII.E4-

11(AP60)

Piping, piping 

components, and 

piping elements

Stainless 

steel

Closed-cycle 

cooling water 

>60°C (>140°F)

Cracking due 

to SCC

XI.M21A, 

"Closed 

Treated Water 

Systems"

No

AMP 

chan

was 

enco

close

envi

VII.C2.AP

-188

VII.E3.AP188

VII.E4.AP188

VII.C2-

3(AP63)

VII.E3-

5(AP63)

VII.E4-

3(AP63)

Heat exchanger 

tubes

Stainless 

steel

Closed-cycle 

cooling water

Reduction of 

heat transfer 

due to fouling

XI.M21A, 

"Closed 

Treated Water 

Systems"

No

AMP 

chan

was 

enco

close

envi

VII.A3.AP- VII.A3- Heat exchanger Steel Closed-cycle Loss of XI.M21A, No AMP 
NUREG-1950 II-222 April 2011

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

189

VII.A4.AP189

VII.C2.AP

-189

VII.E1.AP189

VII.E3.AP189

VII.E4.AP189

VII.F1.AP189

VII.F2.AP189

VII.F3.AP189

VII.F4.AP189

3(A-63)

VII.A4-

3(A-63)

VII.C2-

1(A-63)

VII.E1-

6(A-63)

VII.E3-

4(A-63)

VII.E4-

2(A-63)

VII.F1-

11(A63)

VII.F2-

9(A-63)

VII.F3-

11(A63)

VII.F4-

8(A-63)

components cooling water material due 

to general, 

pitting, 

crevice, and 

galvanic 

corrosion

"Closed 

Treated Water 

Systems"

chan

was 

enco

close

envi

VII.E3.AP191

VII.E4.AP191

VII.E3-

1(A-67)

VII.E4-

1(A-67)

Heat exchanger 

components

Stainless 

steel; steel 

with 

stainless 

steel 

cladding

Closed-cycle 

cooling water

Loss of 

material due 

to MIC

XI.M21A, 

"Closed 

Treated Water 

Systems"

No

AMP 

chan

was 

enco

close

envi

VII.E3.AP192

VII.E3-

2(A-68) Heat exchanger 

components

Stainless 

steel; steel 

with 

stainless 

steel 

Closed-cycle 

cooling water 

>60°C (>140°F)

Cracking due 

to SCC

XI.M21A, 

"Closed 

Treated Water 

Systems"

No

AMP 

chan

was 

enco

close
April 2011 II-223 NUREG-1950

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

cladding envi

VII.H2.AP

-193

VII.H2-

11(AP45)

Piping, piping 

components, and 

piping elements

Copper alloy Raw water

Loss of 

material due 

to general, 

pitting, 

crevice, and 

MIC

XI.M20, "OpenCycle Cooling 

Water System"

No

As d

Inter

Hand

editio

“Cor

– 62

expo

wate

whic

seaw

and 

wate

loss 

gene

crev

VII.C1.AP

-194

VII.C3.AP

-194

VII.H2.AP

-194

VII.C1-

19(A38)

VII.C3-

10(A38)

VII.H2-

22(A38)

Piping, piping 

components, and 

piping elements

Steel (with 

coating or 

lining)

Raw water

Loss of 

material due 

to general, 

pitting, 

crevice, and 

MIC; fouling 

that leads to 

corrosion; 

lining/coatin

g 

degradation

XI.M20, "OpenCycle Cooling 

Water System"

No

As d

Inter

Hand

editio

“Cor

– 62

expo

wate

whic

seaw

and 

wate

loss 

gene

crev
NUREG-1950 II-224 April 2011

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

VII.C3.AP

-195

VII.C3-

2(A-43)

Piping, piping 

components, and 

piping elements

Copper alloy Raw water

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.M20, "OpenCycle Cooling 

Water System"

No

As d

Inter

Hand

editio

“Cor

– 62

expo

wate

whic

seaw

and 

wate

loss 

gene

crev

VII.C1.AP

-196

VII.C1-

9(A-44)

Piping, piping 

components, and 

piping elements

Copper alloy Raw water

Loss of 

material due 

to general, 

pitting, 

crevice, and 

MIC; fouling 

that leads to 

corrosion

XI.M20, "OpenCycle Cooling 

Water System"

No

As d

Inter

Hand

editio

“Cor

– 62

expo

wate

whic

seaw

and 

wate

loss 

gene

crev

VII.G.AP197

VII.G12(APiping, piping 

components, and Copper alloy Raw water Loss of 

material due XI.M27, "Fire No As d

Inter
April 2011 II-225 NUREG-1950

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

45) piping elements to general, 

pitting, 

crevice, and 

MIC; fouling 

that leads to 

corrosion

Water System" Hand

editio

“Cor

– 62

expo

wate

whic

seaw

and 

wate

loss 

gene

crev

VII.C1.AP

-198

VII.C3.AP

-198

VII.G.AP198

VII.H1.AP

-198

VII.C1-

18(A01)

VII.C3-

9(A-01)

VII.G25(A01)

VII.H1-

9(A-01)

Piping, piping 

components, and 

piping elements

Steel (with 

coating or 

wrapping)

Soil or concrete

Loss of 

material due 

to general, 

pitting, 

crevice, and 

MIC

XI.M41, 

"Buried and 

Underground 

Piping and 

Tanks"

No

“Mat

"with 

"with

wrap

XI.M

and 

with 

wrap

defin

or co

envi

AMP 

furth

requ

AMP 

Pipin

Surv

XI.M

and 
NUREG-1950 II-226 April 2011

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

were 

XI.M

Und

and 

VII.A3.AP199

VII.A4.AP199

VII.C2.AP

-199

VII.E1.AP199

VII.E3.AP199

VII.E4.AP199

VII.F1.AP199

VII.F2.AP199

VII.F3.AP199

VII.F4.AP199

VII.H1.AP

-199

VII.H2.AP

-199

VII.A3-

5(AP12)

VII.A4-

6(AP12)

VII.C2-

4(AP12)

VII.E1-

11(AP12)

VII.E3-

8(AP12)

VII.E4-

5(AP12)

VII.F1-

15(AP12)

VII.F2-

13(AP12)

VII.F3-

15(AP12)

VII.F4-

11(AP12)

VII.H1-

2(APPiping, piping 

components, and 

piping elements

Copper alloy Closed-cycle 

cooling water

Loss of 

material due 

to general, 

pitting, 

crevice, and 

galvanic 

corrosion

XI.M21A, 

"Closed 

Treated Water 

Systems"

No

AMP 

chan

was 

enco

close

envi
April 2011 II-227 NUREG-1950

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

12)

VII.H2-

8(AP12)

VII.C2.AP

-202

VII.F1.AP202

VII.F2.AP202

VII.F3.AP202

VII.F4.AP202

VII.H2.AP

-202

VII.C2-

14(A25)

VII.F1-

20(A25)

VII.F2-

18(A25)

VII.F3-

20(A25)

VII.F4-

16(A25)

VII.H2-

23(A25)

Piping, piping 

components, and 

piping elements; 

tanks

Steel Closed-cycle 

cooling water

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.M21A, 

"Closed 

Treated Water 

Systems"

No

AMP 

chan

was 

enco

close

envi

VII.E1.AP203

VII.F1.AP203

VII.F3.AP203

VII.E1-

2(AP34)

VII.F1-

8(AP34)

VII.F3-

8(AP34)

Heat exchanger 

components Copper alloy Closed-cycle 

cooling water

Loss of 

material due 

to general, 

pitting, 

crevice, and 

galvanic 

corrosion

XI.M21A, 

"Closed 

Treated Water 

Systems"

No

AMP 

chan

was 

enco

close

envi

VII.F1.AP204

VII.F2.AP204

VII.F1-

13(AP77)

VII.F2-

Heat exchanger 

tubes Steel Closed-cycle 

cooling water

Reduction of 

heat transfer 

due to fouling

XI.M21A, 

"Closed 

Treated Water 

No

AMP 

chan

was 
NUREG-1950 II-228 April 2011

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

VII.F3.AP204

VII.F4.AP204

11(AP77)

VII.F3-

13(AP77)

VII.F4-

9(AP77)

Systems" enco

close

envi

VII.C2.AP

-205

VII.F1.AP205

VII.F2.AP205

VII.F3.AP205

VII.C2-

2(AP80)

VII.F1-

12(AP80)

VII.F2-

10(AP80)

VII.F3-

12(AP80)

Heat exchanger 

tubes Copper Alloy Closed-cycle 

cooling water

Reduction of 

heat transfer

due to fouling

XI.M21A, 

"Closed 

Treated Water 

Systems"

No

AMP 

chan

was 

enco

close

envi

VII.C1.AP

-206

VII.C3.AP

-206

VII.C1-

13(AP53)

VII.C3-

6(AP53)

Piping, piping 

components, and 

piping elements

Nickel alloy Raw water

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

Chapter XI.M20, 

"Open-Cycle 

Cooling Water 

System"

No

Mista

gene

agin

was 

and 

AMR 

not h

VII.G.AP234

VII.G21(A28)

Piping, piping 

components, and 

piping elements

Steel Fuel oil

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.M30, "Fuel 

Oil Chemistry", 

and 

XI.M32, "OneTime 

No

Rem

AMP 

man

XI.M

XI.M

the s
April 2011 II-229 NUREG-1950

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

Inspection" Fuel 

One

AMP

mate

ing e

VII.A2.AP235

VII.A2-

5(A-88)

Spent fuel 

storage racks: 

neutronabsorbing sheets 

(PWR)

Boral; 

boron steel 

and other 

materials 

(excluding 

Boraflex)

Treated borated 

water

Reduction of 

neutronabsorbing 

capacity; 

change in 

dimensions 

and loss of 

material due 

to effects of 

a spent fuel 

pool (SFP) 

environment

XI.M40, 

"Monitoring of 

NeutronAbsorbing 

Materials other 

than Boraflex"

No

New 

Bora

mate

VII.A2.AP236

VII.A2-

3(A-89)

Spent fuel 

storage racks: 

neutronabsorbing sheets 

(BWR)

Boral; 

boron steel 

and other 

materials 

(excluding 

Boraflex)

Treated water

Reduction of 

neutronabsorbing 

capacity; 

change in 

dimensions 

and loss of 

material due 

to effects of 

SFP 

environment

XI.M40, 

"Monitoring of 

NeutronAbsorbing 

Materials other 

than Boraflex"

No

New 

Bora

mate

VII.J.AP282

VII.J21(AP3)

Piping, piping 

components, and 

piping elements

Steel Concrete None

None, provided 

that

(1) attributes of 

No, if 

conditions are 

met.

The 

been 

desc
NUREG-1950 II-230 April 2011

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

the concrete 

are consistent 

with ACI 318 or 

ACI 349 (low 

water-tocement ratio, 

low 

permeability, 

and adequate 

air 

entrainment) 

as cited in 

NUREG-1557 

and 

(2) plant OE 

indicates no 

degradation of 

the concrete

of th

need

“non

to al

“Com

Misc

Mate

Com

(sub

such 

line-

requ

effec

to de

the s

com

its in

the e

oper

VII.E3.AP283

VII.E3-

16(A60)

Piping, piping 

components, and 

piping elements

Stainless 

steel

Treated water 

>60°C (>140°F) 

Cracking due 

to SCC, 

IGSCC

XI.M2, "Water 

Chemistry," 

and 

XI.M25, “BWR 

Reactor Water 

Cleanup 

System”

No

The 

prog

mitig

"BW

Clea

prog

dete

effec

SCC 

AMP 

revis

XI.M

AMP 
April 2011 II-231 NUREG-1950

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

agin

chan

with 

XI.M

VII.F1.AP99

VII.F2.AP99

VII.F3.AP99

VII.F1-

1(A-09)

VII.F2-

1(A-09)

VII.F3-

1(A-09)

Ducting and 

components

Stainless 

steel Condensation

Loss of 

material due 

to pitting and 

crevice 

corrosion

XI.M38, 

"Inspection of 

Internal 

Surfaces in 

Miscellaneous 

Piping and 

Ducting 

Components"

No

An a

exist

Insp

Surf

Misc

and 

Com

As s

SER 

3.3.2

has 

posit

“Insp

Surf

Misc

and 

Com

cons

AMP 

adeq

the a

of m

visua

perfo

surfa

surv

main

AMP 
NUREG-1950 II-232 April 2011

Table II-9. Changes to Existing Rev. 1 Chapter VII AMR Items for Auxiliary Systems and Their Technical 

changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Te

to in

mate
April 2011 II-233 NUREG-1950

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

VIII.E.SP100

VIII.F.SP100

VIII.G.SP100

VIII.E10(SP58)

VIII.F7(SP-58)

VIII.G10(SP58)

Heat 

exchanger 

tubes

Copper 

alloy

Treated 

water

Reduction of heat 

transfer due to 

fouling

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M32, 

“One-Time 

Inspection”

No

An app

preced

for acc

“One-T

Inspec

progra

verifica

effectiv

“Water 

progra

shown 

SER S

3.3.2.2

staff ha

the pos

“One-T

Inspec

progra

consist

GALL A

XI.M32 

adequa

the effe

of the “

Chemi

progra

VIII.A.SP101

VIII.F.SP101

VIII.A5(SP-61)

VIII.F15(SP61)

Piping, piping 

components, 

and piping 

elements

Copper 

alloy

Treated 

water

Loss of material 

due to pitting and 

crevice corrosion

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M32, 

“One-Time 

No

An app

preced

for acc

“One-T

Inspec

progra
NUREG-1950 II-234 April 2011

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

Inspection” verifica

effectiv

“Water 

progra

shown 

SER S

3.3.2.2

staff ha

the pos

“One-T

Inspec

progra

consist

GALL A

XI.M32 

adequa

the effe

of the “

Chemi

progra

VIII.G.SP102

VIII.G12(SP62)

Heat 

exchanger 

tubes

Stainless 

steel

Lubricating 

oil

Reduction of heat 

transfer due to 

fouling

XI.M39, 

"Lubricating 

Oil 

Analysis," 

and 

XI.M32, 

“One-Time 

Inspection” 

No

An app

preced

for acc

“One-T

Inspec

progra

verifica

effectiv

“Lubric

Analys

progra

shown 
April 2011 II-235 NUREG-1950

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

SER S

3.3.2.2

staff ha

the pos

“One-T

Inspec

progra

consist

GALL A

XI.M32 

adequa

the effe

of the “

Oil Ana

progra

VIII.G.SP103

VIII.G15(SP63)

Heat 

exchanger 

tubes

Steel Lubricating 

oil

Reduction of heat 

transfer due to 

fouling

XI.M39, 

"Lubricating 

Oil 

Analysis," 

and 

XI.M32, 

“One-Time 

Inspection” 

No

An app

preced

for acc

“One-T

Inspec

progra

verifica

effectiv

“Lubric

Analys

progra

shown 

SER S

3.3.2.2

staff ha

the pos

“One-T
NUREG-1950 II-236 April 2011

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

Inspec

progra

consist

GALL A

XI.M32 

adequa

the effe

of the “

Oil Ana

progra

VIII.E.SP117

VIII.F.SP117

VIII.G.SP117

VIII.E3(S-26)

VIII.F2(S-26)

VIII.G4(S-26)

Heat 

exchanger 

components

Stainless 

steel Raw water

Loss of material 

due to general, 

pitting, crevice, 

galvanic, and 

MIC; fouling that 

leads to 

corrosion

XI.M20, 

"Open-Cycle 

Cooling Water 

System"

No

Aging m

of “fou

revised 

that lea

corrosi

could c

of mate

Fouling 

without 

is not r

cause 

materia

VIII.G.SP136

VIII.G36(S-12)

Steel Piping, 

piping 

components, 

and piping 

elements 

exposed to 

Raw water

Steel Raw water

Loss of material 

due to general, 

pitting, crevice, 

galvanic, and 

MIC; fouling that 

leads to 

corrosion

XI.M38, 

"Inspection of 

Internal 

Surfaces in 

Miscellaneous 

Piping and 

Ducting 

Components"

No

Aging m

of “fou

revised 

that lea

corrosi

could c

of mate

Fouling 

without 

is not r
April 2011 II-237 NUREG-1950

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

cause 

materia

VIII.E.SP145

VIII.G.SP145

VIII.E1(S-01)

VIII.G1(S-01)

Piping, piping 

components, 

and piping 

elements; 

tanks

Steel 

(with 

coating 

or 

wrapping)

Soil or 

concrete

Loss of material 

due to general, 

pitting, crevice, 

and MIC

XI.M41, 

"Buried and 

Underground 

Piping and 

Tanks"

No

AMR X

include

manag

this co

materia

environ

aging e

combin

VIII.E.SP146

VIII.F.SP146

VIII.G.SP146

VIII.E6(S-24)

VIII.F5(S-24)

VIII.G7(S-24)

Heat 

exchanger 

components

Steel Raw water

Loss of material 

due to general, 

pitting, crevice, 

galvanic, and 

MIC; fouling that 

leads to 

corrosion

XI.M20, 

"Open-Cycle 

Cooling Water 

System"

No

Aging m

of “fou

specific 

materia

VIII.I.SP154

VIII.I14(SP-2)

Piping, piping 

components, 

and piping 

elements

Steel Concrete None

None, 

provided that

(1) attributes 

of the 

concrete are 

consistent 

with ACI 318 

or ACI 349 

(low waterto-cement 

ratio, low 

permeability, 

and 

adequate air 

No, if 

conditions are 

met.

The AM

has be

to desc

conditi

concre

needed 

a “none

conclu
NUREG-1950 II-238 April 2011

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

entrainment) 

as cited in 

NUREG-1557 

and 

(2) plant OE 

indicates no 

degradation 

of the 

concrete

VIII.A.SP155

VIII.B1.SP155

VIII.B2.SP155

VIII.A12(SP43)

VIII.B1-

3(SP-43)

VIII.B2-

2(SP43)

Piping, piping 

components, 

and piping 

elements

Stainless 

steel Steam

Loss of material 

due to pitting and 

crevice corrosion

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M32, 

“One-Time 

Inspection”

No

The GA

recomm

of AMP 

verify t

effectiv

AMP X

mitigat

materia

pitting 

corrosi

compo

materia

environ

treated 

(e.g., S

Tables 

VIII.D1

VIII.D2

steam 

environ

this AM

steam 

treated 
April 2011 II-239 NUREG-1950

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

same c

of AMP

be use

manag

effect.

VIII.B1.SP157

VIII.B1-

1(SP-18)

Piping, piping 

components, 

and piping 

elements

Nickel 

alloy Steam

Loss of material 

due to pitting and 

crevice corrosion

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M32, 

“One-Time 

Inspection”

No

The GA

recomm

of AMP 

verify t

effectiv

AMP X

mitigat

materia

pitting 

corrosi

compo

stainle

an env

treated 

(e.g., S

Tables 

VIII.D1

VIII.D2

corrosi

propert

nickel-

are sim

stainle

becaus

steam 

environ

this AM
NUREG-1950 II-240 April 2011

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

steam 

treated 

same c

of AMP

conser

used to 

this ag

for this 

compo

materia

environ

combin

VIII.B2.SP160

VIII.B2-

3(S-05)

Piping, piping 

components, 

and piping 

elements

Steel Steam

Loss of material 

due to general, 

pitting, and crevice 

corrosion

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M32, 

“One-Time 

Inspection”

No

In GAL

VIII.A a

item S

provide

results 

same c

materia

environ

aging e

71 cred

XI.M2 t

with AM

The AM

in this 

revised 

AMP X

verify 

effectiv

the "W

Chemi
April 2011 II-241 NUREG-1950

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

progra

mainta

consist

GALL i

VIII.A.SP71

VIII.B1.SP71

VIII.C.SP71

VIII.A15(S-04)

VIII.B1-

8(S-07)

VIII.C3(S-04)

Piping, piping 

components, 

and piping 

elements

Steel Steam

Loss of material 

due to general, 

pitting, and crevice 

corrosion

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M32, 

“One-Time 

Inspection”

No

An app

preced

for acc

“One-T

Inspec

progra

verifica

effectiv

“Water 

progra

shown 

SER S

3.3.2.2

staff ha

the pos

“One-T

Inspec

progra

consist

GALL A

XI.M32 

adequa

the effe

of the “

Chemi

progra

VIII.B2.SP73VIII.B2-

6(S-09)

Piping, piping 

components, 

Steel Treated 

water

Loss of material 

due to general, 

XI.M2, 

“Water No An app

preced
NUREG-1950 II-242 April 2011

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

VIII.C.SP73

VIII.D2.SP73

VIII.E.SP73

VIII.C6(S-09)

VIII.D2-

7(S-09)

VIII.E33(S-09)

and piping 

elements

pitting, and crevice 

corrosion

Chemistry,” 

and 

XI.M32, 

“One-Time 

Inspection”

for acc

“One-T

Inspec

progra

verifica

effectiv

“Water 

progra

shown 

SER S

3.3.2.2

staff ha

the pos

“One-T

Inspec

progra

consist

GALL A

XI.M32 

adequa

the effe

of the “

Chemi

progra

VIII.B1.SP74

VIII.D1.SP74

VIII.F.SP74

VIII.G.SP74

VIII.B1-

11(S-10)

VIII.D1-

8(S-10)

VIII.F25(S-10)

VIII.G38(S-10)

Piping, piping 

components, 

and piping 

elements

Steel Treated 

water 

Loss of material 

due to general, 

pitting, and crevice 

corrosion

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M32, 

“One-Time 

Inspection”

No

An app

preced

for acc

“One-T

Inspec

progra

verifica

effectiv
April 2011 II-243 NUREG-1950

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

“Water 

progra

shown 

SER S

3.3.2.2

staff ha

the pos

“One-T

Inspec

progra

consist

GALL A

XI.M32 

adequa

the effe

of the “

Chemi

progra

VIII.E.SP75

VIII.G.SP75

VIII.E40(S-13)

VIII.G41(S-13)

Tanks

Steel; 

stainless 

steel

Treated 

water

Loss of material 

due to general 

(steel only), pitting, 

and crevice 

corrosion

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M32, 

“One-Time 

Inspection”

No

An app

preced

for acc

“One-T

Inspec

progra

verifica

effectiv

“Water 

progra

shown 

SER S

3.3.2.2

staff ha
NUREG-1950 II-244 April 2011

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

the pos

“One-T

Inspec

progra

consist

GALL A

XI.M32 

adequa

the effe

of the “

Chemi

progra

VIII.G.SP76

VIII.G6(S-17)

Heat 

exchanger 

components

Steel Lubricating 

oil

Loss of material 

due to general, 

pitting, crevice, 

and MIC

XI.M39, 

"Lubricating 

Oil 

Analysis," 

and 

XI.M32, 

“One-Time 

Inspection” 

No

An app

preced

for acc

“One-T

Inspec

progra

verifica

effectiv

“Lubric

Analys

progra

shown 

SER S

3.3.2.2

staff ha

the pos

“One-T

Inspec

progra

consist
April 2011 II-245 NUREG-1950

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

GALL A

XI.M32 

adequa

the effe

of the “

Oil Ana

progra

VIII.E.SP77

VIII.E7(S-18)

Heat 

exchanger 

components

Steel Treated 

water

Loss of material 

due to general, 

pitting, crevice, 

and galvanic 

corrosion

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M32, 

“One-Time 

Inspection”

No

An app

preced

for acc

“One-T

Inspec

progra

verifica

effectiv

“Water 

progra

shown 

SER S

3.3.2.2

staff ha

the pos

“One-T

Inspec

progra

consist

GALL A

XI.M32 

adequa

the effe

of the “

Chemi
NUREG-1950 II-246 April 2011

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

progra

VIII.E.SP78

VIII.F.SP78

VIII.E37(S-19)

VIII.F28(S-19)

PWR heat 

exchanger 

components

Steel Treated 

water

Loss of material 

due to general, 

pitting, and crevice 

corrosion

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M32, 

“One-Time 

Inspection”

No

An app

preced

for acc

“One-T

Inspec

progra

verifica

effectiv

“Water 

progra

shown 

SER S

3.3.2.2

staff ha

the pos

“One-T

Inspec

progra

consist

GALL A

XI.M32 

adequa

the effe

of the “

Chemi

progra

VIII.G.SP79

VIII.G3(S-20)

Heat 

exchanger 

components

Stainless 

steel

Lubricating 

oil

Loss of material 

due to pitting, 

crevice, and MIC

XI.M39, 

"Lubricating 

Oil 

Analysis," 

and 

No

An app

preced

for acc

“One-T

Inspec
April 2011 II-247 NUREG-1950

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

XI.M32, 

“One-Time 

Inspection” 

progra

verifica

effectiv

“Lubric

Analys

progra

shown 

SER S

3.3.2.2

staff ha

the pos

“One-T

Inspec

progra

consist

GALL A

XI.M32 

adequa

the effe

of the “

Oil Ana

progra

VIII.E.SP80

VIII.E4(S-21)

Heat 

exchanger 

components 

and tubes

Stainless 

steel

Treated 

water

Loss of material 

due to pitting and 

crevice corrosion

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M32, 

“One-Time 

Inspection”

No

An app

preced

for acc

“One-T

Inspec

progra

verifica

effectiv

“Water 

progra
NUREG-1950 II-248 April 2011

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

shown 

SER S

3.3.2.2

staff ha

the pos

“One-T

Inspec

progra

consist

GALL A

XI.M32 

adequa

the effe

of the “

Chemi

progra

VIII.E.SP81

VIII.F.SP81

VIII.E36(S-22) 

VIII.F27(S-22)

PWR heat 

exchanger 

components

Stainless 

steel

Treated 

water

Loss of material 

due to pitting and 

crevice corrosion

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M32, 

“One-Time 

Inspection”

No

An app

preced

for acc

“One-T

Inspec

progra

verifica

effectiv

“Water 

progra

shown 

SER S

3.3.2.2

staff ha

the pos

“One-T
April 2011 II-249 NUREG-1950

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

Inspec

progra

consist

GALL A

XI.M32 

adequa

the effe

of the “

Chemi

progra

VIII.H.SP82

VIII.H1(S-32) Bolting

Steel; 

stainless 

steel

Air – outdoor 

(External)

Loss of material 

due to general 

(steel only), 

pitting, and 

crevice corrosion

XI.M18, 

"Bolting 

Integrity"

No

Bolting 

either s

stainle

these a

aging e

mecha

the sta

environ

VIII.H.SP83

VIII.H5(S-33) Closure 

bolting

Steel; 

stainless 

steel

Air – indoor, 

uncontrolled 

(External)

Loss of preload 

due to thermal 

effects, gasket 

creep, and selfloosening

XI.M18, 

"Bolting 

Integrity"

No

“Loss o

can oc

both st

stainle

bolts.

VIII.H.SP84

VIII.H4(S-34) Closure 

bolting

Steel; 

stainless 

steel

Air – indoor, 

uncontrolled 

(External)

Loss of material 

due to general 

(steel only), 

pitting, and 

crevice corrosion

XI.M18, 

"Bolting 

Integrity"

No

Bolting 

either s

stainle

these a

aging e

mecha

the sta

environ
NUREG-1950 II-250 April 2011

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

VIII.F.SP85

VIII.F3(S-39)

Heat 

exchanger 

components

Stainless 

steel

Treated 

water >60°C 

(>140°F)

Cracking due to 

SCC

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M32, 

“One-Time 

Inspection”

No

An app

preced

for acc

“One-T

Inspec

progra

verifica

effectiv

“Water 

progra

shown 

SER S

3.3.2.2

staff ha

the pos

“One-T

Inspec

progra

consist

GALL A

XI.M32 

adequa

the effe

of the “

Chemi

progra

VIII.B1.SP87

VIII.C.SP87

VIII.D1.SP87

VIII.D2.SPVIII.B1-

4(SP-16)

VIII.C1(SP-16)

VIII.D1-

4(SP-16)

VIII.D2-

Piping, piping 

components, 

and piping 

elements

Stainless 

steel

Treated 

water

Loss of material 

due to pitting and 

crevice corrosion

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M32, 

“One-Time 

No

An app

preced

for acc

“One-T

Inspec

progra
April 2011 II-251 NUREG-1950

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

87

VIII.E.SP87

VIII.F.SP87

VIII.G.SP87

4(SP-16)

VIII.E29(SP16)

VIII.F23(SP16)

VIII.G32(SP16)

Inspection” verifica

effectiv

“Water 

progra

shown 

SER S

3.3.2.2

staff ha

the pos

“One-T

Inspec

progra

consist

GALL A

XI.M32 

adequa

the effe

of the “

Chemi

progra

VIII.B1.SP88

VIII.C.SP88

VIII.D1.SP88

VIII.E.SP88

VIII.F.SP88

VIII.G.SP88

VIII.B1-

5(SP-17)

VIII.C2(SP-17)

VIII.D1-

5(SP-17)

VIII.E30(SP17)

VIII.F24(SP17)

VIII.G33(SPPiping, piping 

components, 

and piping 

elements

Stainless 

steel

Treated 

water >60°C 

(>140°F)

Cracking due to

SCC

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M32, 

“One-Time 

Inspection”

No

An app

preced

for acc

“One-T

Inspec

progra

verifica

effectiv

“Water 

progra

shown 

SER S
NUREG-1950 II-252 April 2011

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

17) 3.3.2.2

staff ha

the pos

“One-T

Inspec

progra

consist

GALL A

XI.M32 

adequa

the effe

of the “

Chemi

progra

VIII.D1.SP90

VIII.D2.SP90

VIII.E.SP90

VIII.F.SP90

VIII.G.SP90

VIII.D1-

1(SP-24)

VIII.D2-

1(SP-24)

VIII.E15(SP24)

VIII.F12(SP24)

VIII.G17(SP24)

Piping, piping 

components, 

and piping 

elements

Aluminum Treated 

water

Loss of material 

due to pitting and 

crevice corrosion

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M32, 

“One-Time 

Inspection”

No

An app

preced

for acc

“One-T

Inspec

progra

verifica

effectiv

“Water 

progra

shown 

SER S

3.3.2.2

staff ha

the pos

“One-T

Inspec

progra
April 2011 II-253 NUREG-1950

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

consist

GALL A

XI.M32 

adequa

the effe

of the “

Chemi

progra

VIII.A.SP91

VIII.D1.SP91

VIII.D2.SP91

VIII.E.SP91

VIII.G.SP91

VIII.A14(SP25)

VIII.D1-

6(SP-25)

VIII.D2-

5(SP-25)

VIII.E32(SP25)

VIII.G35(SP25)

Piping, piping 

components, 

and piping 

elements

Steel Lubricating 

oil

Loss of material 

due to general, 

pitting, and crevice 

corrosion

XI.M39, 

"Lubricating 

Oil 

Analysis," 

and 

XI.M32, 

“One-Time 

Inspection” 

No

An app

preced

for acc

“One-T

Inspec

progra

verifica

effectiv

“Lubric

Analys

progra

shown 

SER S

3.3.2.2

staff ha

the pos

“One-T

Inspec

progra

consist

GALL A

XI.M32 

adequa

the effe
NUREG-1950 II-254 April 2011

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

of the “

Oil Ana

progra

VIII.A.SP92

VIII.D1.SP92

VIII.D2.SP92

VIII.E.SP92

VIII.G.SP92

VIII.A3(SP-32)

VIII.D1-

2(SP-32)

VIII.D2-

2(SP-32)

VIII.E17(SP32)

VIII.G19(SP32)

Piping, piping 

components, 

and piping 

elements

Copper 

alloy

Lubricating 

oil

Loss of material 

due to pitting and 

crevice corrosion

XI.M39, 

"Lubricating 

Oil 

Analysis," 

and 

XI.M32, 

“One-Time 

Inspection” 

No

An app

preced

for acc

“One-T

Inspec

progra

verifica

effectiv

“Lubric

Analys

progra

shown 

SER S

3.3.2.2

staff ha

the pos

“One-T

Inspec

progra

consist

GALL A

XI.M32 

adequa

the effe

of the “

Oil Ana

progra

VIII.E.SP94

VIII.E28(SPPiping, piping 

components, 

Stainless 

steel

Soil or 

concrete

Loss of material 

due to pitting and 

XI.M41, 

"Buried and No An app

preced
April 2011 II-255 NUREG-1950

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

VIII.G.SP9437)

VIII.G31(SP37)

and piping 

elements

crevice corrosion Underground 

Piping and 

Tanks"

for acc

“Buried 

Underg

Piping 

Inspec

progra

manag

materia

stainle

piping 

environ

shown 

SER 3

the sta

accept

positio

“Buried 

Underg

Piping 

Inspec

progra

adequa

manag

effect. 

AMP is 

include 

materia

steel. (

AP-137

VIII.A.SP95

VIII.D1.SP95

VIII.A9(SP-38)

VIII.D1-

3(SP-38)

Piping, piping 

components, 

and piping 

Stainless 

steel

Lubricating 

oil

Loss of material 

due to pitting, 

crevice, and MIC

XI.M39, 

"Lubricating 

Oil 

No

An app

preced

for acc
NUREG-1950 II-256 April 2011

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

VIII.D2.SP95

VIII.E.SP95

VIII.G.SP95

VIII.D2-

3(SP-38)

VIII.E26(SP38)

VIII.G29(SP38)

elements Analysis," 

and 

XI.M32, 

“One-Time 

Inspection” 

“One-T

Inspec

progra

verifica

effectiv

“Lubric

Analys

progra

shown 

SER S

3.3.2.2

staff ha

the pos

“One-T

Inspec

progra

consist

GALL A

XI.M32 

adequa

the effe

of the “

Oil Ana

progra

VIII.E.SP96

VIII.F.SP96

VIII.E13(SP40)

VIII.F10(SP40)

Heat 

exchanger 

tubes

Stainless 

steel

Treated 

water

Reduction of heat 

transfer due to 

fouling

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M32, 

“One-Time 

Inspection”

No

An app

preced

for acc

“One-T

Inspec

progra

verifica

effectiv
April 2011 II-257 NUREG-1950

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

“Water 

progra

shown 

SER S

3.3.2.2

staff ha

the pos

“One-T

Inspec

progra

consist

GALL A

XI.M32 

adequa

the effe

of the “

Chemi

progra

VIII.E.SP97

VIII.E38(SP42) Tanks Stainless 

steel

Treated 

water >60°C 

(>140°F)

Cracking due to

SCC

XI.M2, 

“Water 

Chemistry,” 

and 

XI.M32, 

“One-Time 

Inspection”

No

An app

preced

for acc

“One-T

Inspec

progra

verifica

effectiv

“Water 

progra

shown 

SER S

3.3.2.2

staff ha
NUREG-1950 II-258 April 2011

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

the pos

“One-T

Inspec

progra

consist

GALL A

XI.M32 

adequa

the effe

of the “

Chemi

progra

VIII.A.SP98

VIII.B2.SP98

VIII.A11(SP45)

VIII.B2-

1(SP-45)

Piping, piping 

components, 

and piping 

elements

Stainless 

steel Steam Cracking due to 

SCC

XI.M2,

“Water 

Chemistry,” 

and 

XI.M32, 

“One-Time 

Inspection”

No

An app

preced

for acc

“One-T

Inspec

progra

verifica

effectiv

“Lubric

Analys

progra

shown 

SER S

3.3.2.2

staff ha

the pos

“One-T

Inspec

progra

consist
April 2011 II-259 NUREG-1950

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

GALL A

XI.M32 

adequa

the effe

of the “

Oil Ana

progra

VIII.G.SP99

VIII.G8(SP-53)

Heat 

exchanger 

tubes

Copper 

alloy

Lubricating 

oil

Reduction of heat 

transfer due to 

fouling

XI.M39, 

"Lubricating 

Oil 

Analysis," 

and 

XI.M32, 

“One-Time 

Inspection” 

No

An app

preced

for acc

“One-T

Inspec

progra

verifica

effectiv

“Lubric

Analys

progra

shown 

SER S

3.3.2.2

staff ha

the pos

“One-T

Inspec

progra

consist

GALL A

XI.M32 

adequa

the effe

of the “
NUREG-1950 II-260 April 2011

Table II-10. Changes to Existing GALL Report Rev. 1 Chapter VIII AMR Items for Steam and Power Conve

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

Oil Ana

progra
April 2011 II-261 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

II.A1.CP100

II.A1-

4(C-03)

Concrete 

(inaccessible 

areas): 

dome; wall; 

basemat; 

ring girders; 

buttresses

Concrete

Air – indoor, 

uncontrolled 

or Air – 

outdoor or 

Ground 

water/soil

Increase in 

porosity and 

permeability; 

cracking; loss 

of material 

(spalling, 

scaling) 

due to 

aggressive 

chemical 

attack

XI.S2, “ASME 

Section XI, 

Subsection IWL,” 

or 

XI.S6, "Structure 

Monitoring"

No

GALL 

item 

to dif

betw

acce

inacc

areas

“Stru

Moni

progr

revis

moni

aging 

effec

for th

comp

Furth

evalu

requi

II.A1.CP101

II.A1-

5(C-37)

Concrete: 

dome; wall; 

basemat; ring 

girders; 

buttresses

Concrete Soil

Cracking and 

distortion 

due to 

increased 

stress levels 

from 

settlement

XI.S2, “ASME 

Section XI, 

Subsection IWL,” 

or 

XI.S6, "Structure 

Monitoring" 

If a de-watering 

system is relied 

upon for control 

of settlement, 

then the licensee 

is to ensure 

Yes, if a dewatering 

system is 

relied upon to 

control 

settlement

ASM

Subs

or St

Moni

appli

mana

progr

conc

elem

BWR 

conta

The p
NUREG-1950 II-262 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

proper 

functioning of the 

de-watering 

system through 

the period of 

extended 

operation. 

elem

Para

Moni

includ

moni

conc

crack

II.A1.CP102

II.A1-

6(C-02)

Concrete 

(inaccessible 

areas): 

dome; wall; 

basemat; 

ring girders; 

buttresses

Concrete Water – 

flowing 

Increase in 

porosity and 

permeability; 

loss of 

strength 

due to 

leaching of 

calcium 

hydroxide 

and 

carbonation

Further 

evaluation is 

required to 

determine if a 

plant-specific 

aging 

management 

program is 

needed to 

manage increase 

in porosity, and 

permeability due 

to leaching of 

calcium 

hydroxide and 

carbonation of 

concrete in 

Inaccessible 

Areas. A plantspecific aging 

management 

program is not 

required if (1) 

There is evidence 

Yes, if 

leaching is 

observed in 

accessible 

areas that 

impact 

intended 

function

GALL 

Line 

split t

differ

betw

acce

inacc

areas

ACI 2

deve

some 

cons

Thos

were 

in ac

with A

which 

the re

for de

cons

reinfo

conc

struc

318 i
April 2011 II-263 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

in the accessible 

areas that the 

flowing water has 

not caused 

leaching and 

carbonation, or 

(2) Evaluation 

determined that 

the observed 

leaching of 

calcium 

hydroxide and 

carbonation in 

accessible areas 

has no impact on 

the intended 

function of the 

concrete 

structure.

facto

ceme

propo

slum

aggre

of mi

time, 

temp

durab

that w

addre

201.2

conc

struc

cons

eithe

201.2

expe

durab

these 

were 

both 

and i

conc

reaso

conc

leach

calciu

hydro

carbo

acce

subje
NUREG-1950 II-264 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

wate

inacc

areas

cons

ASM

Subs

as au

10CF

50.55

II.A2.CP104

II.A2-

3(C-38)

Concrete 

(inaccessible 

areas): 

basemat

Concrete Any 

environment

Cracking due 

to expansion 

from reaction 

with 

aggregates

Further 

evaluation is 

required to 

determine if a 

plant-specific 

aging 

management 

program is 

needed to 

manage cracking 

and expansion 

due to reaction 

with aggregate of 

concrete in 

Inaccessible 

Areas. A plantspecific aging 

management 

program is not 

required if (1) as 

described in 

NUREG-1557, 

Yes, if 

concrete is not 

constructed as 

stated

GALL 

Line 

split t

differ

betw

acce

inacc

areas

Curre

basis 

plant

requi

aggre

react

on AS

or AS

Delet

year 

C295 

C227 

addit

ASTM 
April 2011 II-265 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

investigations, 

tests, and 

petrographic 

examinations of 

aggregates 

performed in 

accordance with 

ASTM C295 and 

other ASTM 

reactivity tests, 

as required, can 

demonstrate that 

those aggregates 

do not adversely 

react within 

concrete, or (2) 

For potentially 

reactive 

aggregates, 

aggregate 

concrete reaction 

is not significant 

if it is 

demonstrated 

that the in-place 

concrete can 

perform its 

intended 

function.

tests 

altern

acce

techn

for pl

not c

a spe

the s

ASTM 

 

For p

react

aggre

single 

to AC

a bas

react

aggre

signif

not in

provi

conc

struc

cons

acco

ACI 3

201.2

was d

after 

earlie

plant
NUREG-1950 II-266 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

cons

were 

in ac

with A

which 

the re

for de

cons

reinfo

conc

struc

includ

facto

ceme

propo

slum

aggre

of mi

time, 

temp

durab

which 

addre

201.2

appro

prece

in TM

Secti

3.5.2

3.5.2

acce

conc
April 2011 II-267 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

desig

cons

inspe

acco

appli

and A

stand

II.B1.2.CP105

II.B2.2.CP105

II.B3.2.CP105

II.B1.2-

1(C-06)

II.B2.2-

1(C-06)

II.B3.2-

1(C-06)

Concrete 

elements, all Concrete Soil

Cracking and 

distortion due 

to increased 

stress levels 

from 

settlement

XI.S2, “ASME 

Section XI, 

Subsection IWL,” 

or 

XI.S6, "Structures 

Monitoring" 

If a de-watering 

system is relied 

upon for control 

of settlement, 

then the licensee 

is to ensure 

proper 

functioning of the 

de-watering 

system through 

the period of 

extended 

operation. 

Yes, if a dewatering 

system is relied 

upon to control 

settlement

ASM

Subs

or St

Moni

appli

mana

progr

conc

elem

BWR 

conta

The p

Elem

param

moni

includ

moni

conc

crack

II.B1.2.CP106

II.B2.2.CP106

II.B1.2-

5(C-26)

II.B2.2-

5(C-26)

Concrete: 

containment; 

wall; basemat

Concrete

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Increase in 

porosity and 

permeability; 

cracking; loss 

XI.S2, “ASME 

Section XI, 

Subsection IWL,” 

or 

No

GALL 

AMR 

split t

differ
NUREG-1950 II-268 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

of material 

(spalling, 

scaling) 

due to 

aggressive 

chemical 

attack

XI.S6, "Structure 

Monitoring"

betw

acce

inacc

areas

Inspe

acce

perfo

acco

IWL w

the p

incre

poros

perm

crack

mate

scalin

aggre

chem

Thus

evalu

requi

acce

Mark 

3 bas

enclo

the re

build

and g

are n

II.B2.1.CP107

II.B2.1-

3(C-44) Suppression 

pool shell

Steel; 

stainless 

Air – indoor, 

uncontrolled 

Cracking due 

to cyclic 

XI.S1, “ASME 

Section XI, No

GALL 

AMR 
April 2011 II-269 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

steel; 

dissimilar 

metal welds

or Treated 

Water

loading 

(current 

licensing 

basis (CLB) 

fatigue 

analysis does 

not exist)

Subsection IWE,” 

and 

XI.S4, “10 CFR 

Part 50, Appendix 

J”

split t

supp

shell 

from 

down

Unbr

down

not in 

of XI

XI.S1 

appli

XI.S1 

includ

augm

inspe

detec

by su

exam

There

evalu

chan

Yes t

II.B3.2.CP108

II.B3.2-

2(C-33)

Concrete: 

dome; wall; 

basemat

Concrete

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Reduction of 

strength and 

modulus due 

to elevated 

temperature 

(>150°F 

general; 

>200°F local)

Plant-specific 

aging 

management 

program 

The 

implementation of 

10 CFR 50.55a 

and ASME 

Section XI, 

Yes, if 

temperature 

limits are 

exceeded

As in

ACI 3

susta

expo

conc

eleva

temp

caus

mech
NUREG-1950 II-270 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

Subsection IWL 

would not be able 

to identify the 

reduction of 

strength and 

modulus of 

elasticity due to 

elevated 

temperature. 

Thus, for any 

portions of 

concrete 

containment that 

exceed specified 

temperature 

limits, further 

evaluations are 

warranted. 

Subsection CC3400 of ASME 

Section III, 

Division 2, 

specifies the 

concrete 

temperature 

limits for normal 

operation or any 

other long-term 

period. The 

temperatures 

shall not exceed 

150°F except for 

prope

(mod

elast

stren

resul

The r

stren

modu

elast

acce

engin

calcu

term, 

allow

repla

“desi

calcu

beca

“desi

allow

spec

ACI C

“desi

calcu

perfo

deter

the p

cond

acce

again

“desi

allow
April 2011 II-271 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

local areas, such 

as around 

penetrations, 

which are not 

allowed to exceed 

200°F. If 

significant 

equipment loads 

are supported by 

concrete at 

temperatures 

exceeding 150°F, 

an evaluation of 

the ability to 

withstand the 

postulated design 

loads is to be 

made. 

Higher 

temperatures 

than given above 

may be allowed in 

the concrete if 

tests and/or 

calculations are 

provided to 

evaluate the 

reduction in 

strength and 

modulus of 

elasticity, and 

these reductions 

There

term 

calcu

used 

locat

Repo
NUREG-1950 II-272 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

are applied to the 

design 

calculations.

II.B1.1.CP109

II.B1.1-

2(C-19)

Steel 

elements: 

torus ring 

girders; 

downcomers;

Steel

Air – indoor, 

uncontrolled 

or Treated 

water

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.S1, “ASME 

Section XI, 

Subsection IWE” 

Plant-specific 

aging 

management 

program is 

required if plant 

operating 

experience 

identified 

significant 

corrosion of the 

torus ring girders 

and downcomers. 

If protective 

coating is 

credited for 

preventing 

corrosion of the 

torus shell, the 

coating should be 

included in scope 

of license renewal 

and subject to 

aging 

management 

review.

Yes, if 

corrosion is 

significant 

Torus 

and d

are n

conta

press

boun

in the 

CFR 

Appe

XI.S4 

appli

Secti

Subs

XI.S1 

appli

mana

progr
April 2011 II-273 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

II.B1.2.CP110

II.B2.2.CP110

II.B1.2-

6(C-31)

II.B2.2-

6(C-31)

Concrete 

(inaccessible 

areas): 

containment; 

wall; 

basemat

Concrete Water – 

flowing

Increase in 

porosity and 

permeability; 

loss of 

strength due 

to leaching 

of calcium 

hydroxide 

and 

carbonation

Further 

evaluation is 

required to 

determine if a 

plant-specific 

aging 

management 

program is 

needed to 

manage increase 

in porosity, and 

permeability due 

to leaching of 

calcium 

hydroxide and 

carbonation of 

concrete in 

Inaccessible 

Areas. A plantspecific aging 

management 

program is not 

required if (1) 

There is evidence 

in the accessible 

areas that the 

flowing water has 

not caused 

leaching and 

carbonation, or 

(2) Evaluation 

determined that 

Yes, if 

leaching is 

observed in 

accessible 

areas that 

impact 

intended 

function

GALL 

AMR 

split t

differ

betw

acce

inacc

areas

 

ACI 2

deve

some 

cons

Thos

were 

in ac

with A

which 

the re

for de

cons

reinfo

conc

struc

318 i

facto

ceme

propo

slum

aggre

of mi
NUREG-1950 II-274 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

the observed 

leaching of 

calcium 

hydroxide and 

carbonation in 

accessible areas 

has no impact on 

the intended 

function of the 

concrete 

structure.

time, 

temp

durab

which 

addre

201.2

conc

struc

cons

eithe

201.2

expe

durab

these 

were 

both 

and i

conc

reaso

conc

leach

calciu

hydro

carbo

acce

subje

- wat

repre

cond

inacc

areas

cons
April 2011 II-275 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

ASM

Subs

as au

10 C

50.55

II.B3.1.CP113

II.B3.1-

8(C-19)

Steel 

elements 

(inaccessible 

areas): 

drywell shell; 

drywell head; 

and drywell 

shell in sand 

pocket 

regions

Steel

Air – indoor, 

uncontrolled 

or Concrete

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.S1, “ASME 

Section XI, 

Subsection IWE,” 

and 

XI.S4, “10 CFR 

Part 50, Appendix 

J”

Yes, if 

corrosion is 

indicated from 

the IWE 

examinations

GALL 

AMR 

split t

betw

acce

inacc

areas 

sepa

comp

locat

differ

envir

those 

conta

press

boun

ring g

down

dryw

skirt 

conta

press

boun

10 C

Appe

appli
NUREG-1950 II-276 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

comp

addre

sepa

the a

aging 

mana

progr

is ide

ECC

Head

remo

list be

evalu

ECC

syste

perm

The b

furthe

is no

II.B1.2.CP117

II.B2.1.CP117

II.B2.2.CP117

II.B1.2-

8(C-46)

II.B2.1-

1(C-46)

II.B2.2-

10(C-46)

Steel 

elements: 

downcomer 

pipes

Steel

Air – indoor, 

uncontrolled 

or Treated 

water

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.S1, “ASME 

Section XI, 

Subsection IWE”

No

ASM

Subs

is the 

aging 

mana

progr

comp

not c

press

boun

are n

of 10 
April 2011 II-277 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

50 Ap

II.B3.2.CP121

II.B3.2-

4(C-40)

Concrete 

(inaccessible 

areas): 

dome; wall; 

basemat

Concrete Any 

environment

Cracking due 

to expansion 

from reaction 

with 

aggregates

Further 

evaluation is 

required to 

determine if a 

plant-specific 

aging 

management 

program is 

needed to 

manage cracking 

and expansion 

due to reaction 

with aggregate of 

concrete in 

Inaccessible 

Areas. A plantspecific aging 

management 

program is not 

required if (1) As 

described in 

NUREG-1557, 

investigations, 

tests, and 

petrographic 

examinations of 

aggregates 

performed in 

accordance with 

ASTM C295 and 

Yes, if 

concrete is not 

constructed as 

stated

GALL 

AMR 

split t

differ

betw

acce

inacc

areas

Curre

basis 

plant

requi

aggre

react

on AS

or AS

C227

the y

ASTM 

ASTM 

the a

other 

react

provi

acce

techn

for pl

not c

a spe

the s
NUREG-1950 II-278 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

other ASTM 

reactivity tests, 

as required, can 

demonstrate that 

those aggregates 

do not adversely 

react within 

concrete, or (2) 

For potentially 

reactive 

aggregates, 

aggregate 

concrete reaction 

is not significant 

if it is 

demonstrated 

that the in-place 

concrete can 

perform its 

intended 

function.

ASTM 

For p

react

aggre

single 

to AC

a bas

react

aggre

signif

not in

provi

conc

struc

cons

acco

ACI 3

201.2

was d

after 

earlie

plant

cons

were 

in ac

with A

which 

the re

for de

cons

reinfo

conc
April 2011 II-279 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

struc

includ

facto

ceme

propo

slum

aggre

of mi

time, 

temp

durab

which 

addre

201.2

appro

prece

in TM

Secti

3.5.2

3.5.2

acce

conc

desig

cons

inspe

acco

appli

and A

stand

II.B3.2.CP122

II.B3.2-

6(C-32) Concrete 

(inaccessible Concrete Water – 

flowing 

Increase in 

porosity and 

Further 

evaluation is 

Yes, if 

leaching is 

GALL 

AMR 
NUREG-1950 II-280 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

areas): 

dome; wall; 

basemat

permeability; 

loss of 

strength due 

to leaching of 

calcium 

hydroxide 

and 

carbonation

required to 

determine if a 

plant-specific 

aging 

management 

program is 

needed to 

manage increase 

in porosity, and 

permeability due 

to leaching of 

calcium 

hydroxide and 

carbonation of 

concrete in 

Inaccessible 

Areas. A plantspecific aging 

management 

program is not 

required if (1) 

There is evidence 

in the accessible 

areas that the 

flowing water has 

not caused 

leaching and 

carbonation, or 

(2) Evaluation 

determined that 

the observed 

leaching of 

observed in 

accessible 

areas that 

impact 

intended 

function

split t

differ

betw

acce

inacc

areas

 

ACI 2

deve

some 

cons

Thos

were 

in ac

with A

which 

the re

for de

cons

reinfo

conc

struc

318 i

facto

ceme

propo

slum

aggre

of mi

time, 

temp
April 2011 II-281 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

calcium 

hydroxide and 

carbonation in 

accessible areas 

has no impact on 

the intended 

function of the 

concrete 

structure.

durab

which 

addre

201.2

conc

struc

cons

eithe

201.2

expe

durab

these 

were 

both 

and i

conc

reaso

conc

leach

calciu

hydro

carbo

acce

subje

- wat

repre

cond

inacc

areas

cons

ASM

Subs
NUREG-1950 II-282 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

as au

10 C

50.55

II.B3.2.CP135

II.B3.2-

3(C-29)

Concrete 

(inaccessible 

areas): dome; 

wall; basemat

Concrete

Air – outdoor 

or Ground 

water/soil

Loss of 

material 

(spalling, 

scaling) and 

cracking due 

to freezethaw

Further 

evaluation is 

required for 

plants that are 

located in 

moderate to 

severe 

weathering 

conditions 

(weathering index 

>100 day-inch/yr) 

(NUREG-1557) to 

determine if a 

plant-specific 

aging 

management 

program is 

needed. A plantspecific aging 

management 

program is not 

required if 

documented 

evidence 

confirms that the 

existing concrete 

had air 

entrainment 

Yes, for plants 

located in 

moderate to 

severe 

weathering 

conditions 

GALL 

Item 

to dif

betw

acce

inacc

areas

incre

conte

to 8% 

acce

on AC

and A

Table 

Grou

is ap

the w

base
April 2011 II-283 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

content (as per 

Table CC-2231-2 

of the ASME 

Section III 

Division 2), and 

subsequent 

inspections of 

accessible areas 

did not exhibit 

degradation 

related to freezethaw. Such 

inspections 

should be 

considered a part 

of the evaluation. 

If this condition is 

not satisfied, then 

a plant-specific 

aging 

management 

program is 

required to 

manage loss of 

material (spalling, 

scaling) and 

cracking due to 

freeze-thaw of 

concrete in 

inaccessible 

areas. 

The weathering 
NUREG-1950 II-284 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

index for the 

continental U.S. 

is shown in ASTM 

C33-90, Fig. 1.

II.B2.1.CP142

II.B2.1-

3(C-44) Unbraced 

downcomers

Steel; 

stainless 

steel; 

dissimilar 

metal welds

Air – indoor, 

uncontrolled 

or Treated 

water

Cracking due 

to cyclic 

loading 

(CLB fatigue 

analysis does 

not exist)

XI.S1, “ASME 

Section XI, 

Subsection IWE”

No

GALL 

AMR 

split t

supp

shell 

from 

down

Unbr

down

not in 

XI.S4 

XI.S1 

appli

XI.S1 

includ

augm

inspe

detec

by su

exam

There

evalu

chan

Yes t

II.A1.CP147

II.A1-

2(C-01)

Concrete 

(inaccessible 

areas): 

Concrete

Air – 

outdoor or 

Ground 

Loss of 

material 

(spalling, 

Further 

evaluation is 

required for 

Yes, for plants 

located in 

moderate to 

GALL 

Item 

to dif
April 2011 II-285 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

dome; wall; 

basemat; 

ring girders; 

buttresses

water/soil scaling) and 

cracking due 

to freezethaw

plants that are 

located in 

moderate to 

severe 

weathering 

conditions 

(weathering index 

>100 day-inch/yr) 

(NUREG-1557) to 

determine if a 

plant-specific 

aging 

management 

program is 

needed. A plantspecific aging 

management 

program is not 

required if 

documented 

evidence 

confirms that the 

existing concrete 

had air 

entrainment 

content (as per 

Table CC-2231-2 

of the ASME 

Section III 

Division 2), and 

subsequent 

inspections of 

severe 

weathering 

conditions 

betw

acce

inacc

areas

incre

conte

to 8% 

acce

on AC

and A

Table 
NUREG-1950 II-286 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

accessible areas 

did not exhibit 

degradation 

related to freezethaw. Such 

inspections 

should be 

considered a part 

of the evaluation. 

If this condition is 

not satisfied, then 

a plant-specific 

aging 

management 

program is 

required to 

manage loss of 

material (spalling, 

scaling) and 

cracking due to 

freeze-thaw of 

concrete in 

inaccessible 

areas. 

The weathering 

index for the 

continental U.S. 

is shown in ASTM 

C33-90, Fig. 1.

II.A2.CP155II.A2-

6(C-30)

Concrete 

(accessible Concrete Water – 

flowing 

Increase in 

porosity and 

XI.S2, “ASME 

Section XI, No GALL 

AMR 
April 2011 II-287 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

areas): 

basemat

permeability; 

loss of 

strength 

due to 

leaching of 

calcium 

hydroxide 

and 

carbonation

Subsection IWL” corre

remo

acce

beca

base

to “W

flowin

envir

shou

inacc

 

ACI 2

deve

some 

cons

Thos

were 

in ac

with A

which 

the re

for de

cons

reinfo

conc

struc

318 i

facto

ceme

propo

slum
NUREG-1950 II-288 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

aggre

of mi

time, 

temp

durab

which 

addre

201.2

conc

struc

cons

eithe

201.2

expe

durab

these 

were 

both 

and i

conc

reaso

conc

leach

calciu

hydro

carbo

acce

subje

- wat

repre

cond

inacc
April 2011 II-289 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

areas

cons

ASM

Subs

as au

10 C

50.55

item 

acce

inacc

areas

II.B3.1.CP156

II.B3.1-

3(C-30)

Concrete 

(accessible 

areas): 

basemat

Concrete Water – 

flowing 

Increase in 

porosity and 

permeability; 

loss of 

strength due 

to leaching of 

calcium 

hydroxide 

and 

carbonation

XI.S2, “ASME 

Section XI, 

Subsection IWL”

No

GALL 

AMR 

corre

remo

acce

beca

base

to “w

flowin

envir

shou

inacc

 

ACI 2

deve

some 

cons

Thos

were 

in ac
NUREG-1950 II-290 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

with A

which 

the re

for de

cons

reinfo

conc

struc

318 i

facto

ceme

propo

slum

aggre

of mi

time, 

temp

durab

which 

addre

201.2

conc

struc

cons

eithe

201.2

expe

durab

these 

were 

both 

and i
April 2011 II-291 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

conc

reaso

conc

leach

calciu

hydro

carbo

acce

subje

- wat

repre

cond

inacc

areas

cons

ASM

Subs

as au

10 C

50.55

item 

acce

inacc

areas

II.B3.1.CP158

II.B3.1-

8(C-19)

Steel 

elements: 

suppression 

chamber 

shell (interior 

surface)

Steel

Air – indoor, 

uncontrolled 

or Treated 

water

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.S1, “ASME 

Section XI, 

Subsection IWE” 

Plant-specific 

aging management 

program is 

required if plant

Yes, if corrosion 

is significant 

Torus 

and d

are n

conta

press

boun

in the 
NUREG-1950 II-292 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

operating 

experience 

identified 

significant 

corrosion. If 

protective coating 

is credited for 

preventing 

corrosion, the 

coating should be 

included in scope 

of license renewal 

and subject to 

aging management 

review.

CFR 

Appe

XI.S4 

appli

Secti

Subs

XI.S1 

appli

mana

progr

II.A1.CP31

II.A1-

2(C-01)

Concrete 

(accessible 

areas): 

dome; wall; 

basemat; 

ring girders; 

buttresses

Concrete Air – outdoor

Loss of 

material 

(spalling, 

scaling) and 

cracking due 

to freezethaw

XI.S2, “ASME 

Section XI, 

Subsection IWL”

No

GALL 

AMR 

split t

differ

betw

acce

inacc

areas

Inspe

acce

perfo

acco

IWL w

the p

loss o

(spal
April 2011 II-293 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

and c

to fre

Thus

evalu

requi

acce

II.A1.CP32

II.A1-

6(C-02)

Concrete 

(accessible 

areas): 

dome; wall; 

basemat; 

ring girders; 

buttresses

Concrete Water – 

flowing 

Increase in 

porosity and 

permeability; 

loss of 

strength due 

to leaching 

of calcium 

hydroxide 

and 

carbonation

XI.S2, “ASME 

Section XI, 

Subsection IWL”

No

GALL 

AMR 

split t

differ

betw

acce

inacc

areas

Inspe

acce

perfo

acco

IWL w

the p

incre

poros

perm

to lea

calciu

hydro

carbo

Thus

evalu

requi

acce
NUREG-1950 II-294 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

II.A1.CP33

II.A1-

3(C-04)

Concrete 

(accessible 

areas): 

dome; wall; 

basemat; 

ring girders; 

buttresses 

Concrete Any 

environment

Cracking due 

to expansion 

from reaction 

with 

aggregates

XI.S2, “ASME 

Section XI, 

Subsection IWL”

No

GALL 

Line 

split t

differ

betw

acce

inacc

areas

Inspe

acce

perfo

acco

IWL w

the p

surfa

due t

from 

aggre

Thus

evalu

requi

II.A1.CP34

II.A1-

1(C-08)

Concrete: 

dome; wall; 

basemat; ring 

girders; 

buttresses

Concrete

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Reduction of 

strength and 

modulus due 

to elevated 

temperature 

(>150°F 

general; 

>200°F local)

Plant-specific 

aging 

management 

program. 

The 

implementation of 

10 CFR 50.55a 

and ASME 

Section XI, 

Yes, if 

temperature 

limits are 

exceeded

As in

ACI 3

susta

expo

conc

eleva

temp

caus

mech

prope
April 2011 II-295 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

Subsection IWL 

would not be able 

to identify the 

reduction of 

strength and 

modulus of 

elasticity due to 

elevated 

temperature. 

Thus, for any 

portions of 

concrete 

containment that 

exceed specified 

temperature 

limits, further 

evaluations are 

warranted. 

Subsection CC3400 of ASME 

Section III, 

Division 2, 

specifies the 

concrete 

temperature 

limits for normal 

operation or any 

other long-term 

period. The 

temperatures 

shall not exceed 

150°F except for 

(mod

elast

stren

resul

The r

stren

modu

elast

acce

engin

calcu

term, 

allow

repla

“desi

calcu

beca

“desi

allow

spec

ACI C

“desi

calcu

perfo

deter

the p

cond

acce

again

“desi

allow

There
NUREG-1950 II-296 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

local areas, such 

as around 

penetrations, 

which are not 

allowed to exceed

200°F. If 

significant 

equipment loads 

are supported by 

concrete at 

temperatures 

exceeding 150°F, 

an evaluation of 

the ability to 

withstand the 

postulated design 

loads is to be 

made. 

 

Higher 

temperatures 

than given above 

may be allowed in 

the concrete if

tests and/or 

calculations are 

provided to 

evaluate the 

reduction in 

strength and 

modulus of 

term 

calcu

used 

locat

Repo
April 2011 II-297 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

elasticity, and 

these reductions 

are applied to the 

design 

calculations.

II.A1.CP35

II.A2.CP35

II.B3.2.CP35

II.A1-

11(C-09)

II.A2-

9(C-09)

II.B3.2-

9(C-09)

Steel 

elements 

(accessible 

areas): liner; 

liner 

anchors; 

integral 

attachments

Steel Air – indoor, 

uncontrolled

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.S1, “ASME 

Section XI, 

Subsection IWE,” 

and 

XI.S4, “10 CFR 

Part 50, Appendix 

J”

No

GALL 

AMR 

split t

differ

betw

acce

inacc

areas

Inspe

acce

perfo

acco

IWE 

Part 

J will 

prese

of ma

gene

and c

corro

a furt

evalu

requi

II.A3.CP36

II.B4.CPII.A3-

1(C-12)

II.B4-

Penetration 

sleeves

Steel; 

dissimilar 

metal welds

Air – indoor, 

uncontrolled 

or Air – 

Loss of 

material due 

to general, 

XI.S1, “ASME 

Section XI, 

Subsection IWE,” 

No 

Rem

abou

recom
NUREG-1950 II-298 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

36 1(C-12) outdoor pitting, and 

crevice 

corrosion

and

XI.S4, “10 CFR 

Part 50, Appendix 

J” 

IWE 

exam

dissim

welds 

XI.S1 

augm

includ

recom

The p

the a

inspe

detec

stain

pene

sleev

dissim

welds 

bello

subje

loadi

no cu

licens

fatigu

II.A3.CP37

II.B4.CP37

II.A3-

3(C-14)

II.B4-

3(C-14)

Penetration 

sleeves; 

penetration 

bellows

Steel; 

stainless 

steel; 

dissimilar 

metal welds

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Cracking due 

to cyclic 

loading 

(CLB fatigue 

analysis does 

not exist)

XI.S1, “ASME 

Section XI, 

Subsection IWE,” 

and 

XI.S4, “10 CFR 

Part 50, Appendix 

J”

No

The 2

of AS

XI, S

IWE, 

VT-3 

for co

press

boun
April 2011 II-299 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

comp

includ

stain

and d

meta

stain

bello

scop

of IW

scop

Part 

J. VT

exam

not d

crack

occu

of cy

and s

pene

sleev

bello

desig

for a 

press

(Type 

are o

press

as pa

conta

A Inte

Rate 

The f
NUREG-1950 II-300 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

Type 

every 

and c

exten

to 15 

licens

imple

Optio

perfo

base

acco

10 C

Appe

ILRT 

thus 

provi

detec

crack

that c

actio

to pre

prima

conta

tightn

Secti

Subs

(XI.S

there

augm

requi

exam

detec
April 2011 II-301 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

crack

the p

exten

opera

recom

GALL 

line it

II.A3.CP38

II.B4.CP38

II.A3-

2(C-15)

II.B4-

2(C-15)

Penetration 

sleeves; 

penetration 

bellows

Stainless 

steel; 

dissimilar 

metal welds

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Cracking due 

to SCC

XI.S1, “ASME 

Section XI, 

Subsection IWE,” 

and 

XI.S4, “10 CFR 

Part 50, Appendix 

J”

Yes, detection 

of aging effects 

is to be 

evaluated

Trans

Stres

crack

(TGS

conc

dissim

welds

case 

asse

may 

effec

partic

mate

shield

corro

envir

2004 

ASM

Subs

spec

exam

conta

press

boun
NUREG-1950 II-302 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

comp

includ

stain

and d

meta

Exam

stain

bello

scop

in sco

CFR 

Appe

exam

not d

crack

occu

of SC

TGSC

some 

sleev

bello

desig

for a 

press

(Type 

are o

press

as pa

conta

A tes

Leak 

(ILRT
April 2011 II-303 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

frequ

Type 

every 

and c

exten

to 15 

licens

imple

Optio

perfo

base

acco

10 C

Appe

ILRT 

thus 

provi

detec

crack

that c

actio

to pre

prima

conta

tightn

Secti

Subs

(XI.S

there

augm

requi

exam
NUREG-1950 II-304 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

detec

crack

the p

exten

opera

II.A3.CP39

II.B4.CP39

II.A3-

5(C-17)

II.B4-

5(C-17)

Personnel 

airlock, 

equipment 

hatch, CRD

hatch: locks, 

hinges, and 

closure 

mechanisms

Steel

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Loss of leak 

tightness due 

to mechanical 

wear of locks, 

hinges and 

closure 

mechanisms

XI.S1, “ASME 

Section XI, 

Subsection IWE,” 

and 

XI.S4, “10 CFR 

Part 50, Appendix 

J”

No

The r

“Plan

Spec

delet

AMP 

beca

Tech

Spec

not a

mana

progr

Tech

Spec

provi

acce

criter

Appe

testin

state

II.A3.CP40

II.B4.CP40

II.A3-

7(C-18)

II.B4-

7(C-18)

Moisture 

barriers 

(caulking, 

flashing, and 

other 

sealants)

Elastomers, 

rubber, and 

other 

similar 

materials

Air – indoor, 

uncontrolled

Loss of 

sealing due 

to wear, 

damage, 

erosion, 

tear, surface 

cracks, or 

XI.S1, “ASME 

Section XI, 

Subsection IWE”

No

GALL 

AMR 

split t

comp

cove

Gask

in sco
April 2011 II-305 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

other 

defects

Secti

Subs

Prog

AE/A

seali

wear

erosi

surfa

other 

spec

ASM

Subs

for th

barrie

II.A3.CP41

II.B4.CP41

II.A3-

7(C-18)

II.B4-

7(C-18)

Seals and 

gaskets

Elastomers, 

rubber, and 

other 

similar 

materials

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Loss of 

sealing due 

to wear, 

damage, 

erosion, 

tear, surface 

cracks, or 

other 

defects

XI.S4, “10 CFR 

Part 50, Appendix 

J "

No

GALL 

AMR 

split t

comp

in sco

The s

2004 

ASM

Subs

as ap

10 C

does 

seals 

gask

and g

cove

of 10 
NUREG-1950 II-306 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

50 Ap

Thus

CFR 

Appe

the a

aging 

mana

progr

II.B1.1.CP43

II.B3.1.CP43

II.B1.1-

2(C-19)

II.B3.1-

8(C-19)

Steel 

elements 

(accessible 

areas): 

drywell shell; 

drywell head

Steel Air – indoor, 

uncontrolled

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.S1, “ASME 

Section XI, 

Subsection IWE,” 

and 

XI.S4, “10 CFR 

Part 50, Appendix 

J”

No

GALL 

AMR 

split t

betw

acce

inacc

areas

girde

down

dryw

skirt 

conta

press

boun

10 C

Appe

appli

comp

addre

sepa

the a

aging 

mana
April 2011 II-307 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

progr

is ide

ECC

Head

remo

list be

evalu

ECC

syste

perm

II.B1.2.CP46

II.B2.1.CP46

II.B2.2.CP46

II.B1.2-

8(C-46)

II.B2.1-

1(C-46)

II.B2.2-

10(C-46)

Steel 

elements 

(accessible 

areas): 

suppression 

chamber; 

drywell; 

drywell head; 

embedded 

shell; region 

shielded by 

diaphragm 

floor (as 

applicable)

Steel

Air – indoor, 

uncontrolled 

or Treated 

water

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.S1, “ASME 

Section XI, 

Subsection IWE,” 

and 

XI.S4, “10 CFR 

Part 50, Appendix 

J”

No

GALL 

AMR 

split t

differ

betw

acce

inacc

areas

Down

pipes

supp

not a 

press

boun

10 C

Appe

appli

comp

addre

sepa

the a
NUREG-1950 II-308 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

aging 

mana

progr

is ide

II.B1.1.CP48

II.B1.1-

2(C-19)

Steel 

elements: 

torus shell

Steel

Air – indoor, 

uncontrolled 

or Treated 

water

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.S1, “ASME 

Section XI, 

Subsection IWE,” 

and 

XI.S4, “10 CFR 

Part 50, Appendix 

J” 

License renewal 

applicants are 

advised to 

address their 

plant-specific 

operating 

experience 

related to torus 

shell corrosion. If 

the identified 

corrosion is 

significant, a 

plant-specific 

aging 

management 

program is 

required. If 

protective coating 

is credited for 

preventing 

Yes, if 

corrosion is 

significant 

Recoating of 

the torus is 

recommended.

Furth

evalu

torus 

corro

warra

resul

ident

IN 88

other 

wide 

expe

ident

numb

incide

torus 

There

recoa

need
April 2011 II-309 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

corrosion of the 

torus shell, the 

coating should be 

included in scope 

of license renewal 

and subject to 

aging 

management 

review.

II.B1.1.CP49

II.B1.1-

3(C-20)

Steel 

elements: 

torus; vent 

line; vent 

header; vent 

line bellows; 

downcomers

Steel; 

stainless 

steel

Air – indoor, 

uncontrolled

Cracking due 

to cyclic 

loading 

(CLB fatigue 

analysis does 

not exist)

XI.S1, “ASME 

Section XI, 

Subsection IWE,” 

and 

XI.S4, “10 CFR 

Part 50, Appendix 

J”

No

ASM

Subs

is au

requi

exam

detec

these 

comp

durin

of ex

opera

II.B1.1.CP50

II.B1.1-

5(C-22)

Steel 

elements: vent 

line bellows

Stainless 

steel

Air – indoor, 

uncontrolled

Cracking due 

to SCC

XI.S1, “ASME 

Section XI, 

Subsection IWE,” 

and 

XI.S4, “10 CFR 

Part 50, Appendix 

J”

No

ASM

Subs

Elem

augm

requi

exam

detec

these 

comp

durin

of ex
NUREG-1950 II-310 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

opera

20 w

elem

Oper

Expe

II.A2.CP51

II.A2-

2(C-28)

Concrete 

(accessible 

areas): 

basemat

Concrete Air – outdoor

Loss of 

material 

(spalling, 

scaling) and 

cracking due 

to freezethaw

XI.S2, “ASME 

Section XI, 

Subsection IWL”

No

GALL 

AMR 

split t

differ

betw

acce

inacc

areas

Inspe

acce

perfo

acco

IWL w

the p

loss o

(spal

and c

to fre

Thus

evalu

requi

acce

II.B3.2.CP52

II.B3.2-

3(C-29)

Concrete 

(accessible 

areas): 

dome; wall; 

Concrete

Air – outdoor 

or Ground 

water/soil

Loss of 

material 

(spalling, 

scaling) and 

XI.S2, “ASME 

Section XI, 

Subsection IWL”

No

GALL 

item 

to dif

betw
April 2011 II-311 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

basemat cracking due 

to freezethaw

acce

inacc

areas

Inspe

acce

perfo

acco

IWL w

the p

loss o

(spal

and c

to fre

Thus

evalu

requi

acce

II.A2.CP53

II.B3.1.CP53

II.A2-

6(C-30)

II.B3.1-

3(C-30)

Concrete 

(inaccessible 

areas): 

basemat

Concrete Water – 

flowing 

Increase in 

porosity and 

permeability; 

loss of 

strength due 

to leaching of 

calcium 

hydroxide 

and 

carbonation

Further 

evaluation is 

required to 

determine if a 

plant-specific 

aging 

management 

program is 

needed to 

manage increase 

in porosity, and 

permeability due 

to leaching of 

calcium 

Yes, if 

leaching is 

observed in 

accessible 

areas that 

impact 

intended 

function

GALL 

AMR 

corre

remo

acce

beca

base

to “W

flowin

envir

shou

inacc

 

ACI 2
NUREG-1950 II-312 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

hydroxide and 

carbonation of 

concrete in 

Inaccessible 

Areas. A plantspecific aging 

management 

program is not 

required if 

(1) There is 

evidence in the 

accessible areas 

of adjacent 

structures that 

the flowing water 

has not caused 

leaching and 

carbonation, or 

(2) Evaluation 

determined that 

the observed 

leaching of 

calcium 

hydroxide and 

carbonation in 

accessible areas 

has no impact on 

the intended 

function of the 

concrete 

structure.

deve

some 

cons

Thos

were 

in ac

with A

which 

the re

for de

cons

reinfo

conc

struc

318 i

facto

ceme

propo

slum

aggre

of mi

time, 

temp

durab

which 

addre

201.2

conc

struc

cons

eithe

201.2
April 2011 II-313 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

expe

durab

these 

were 

both 

and i

conc

reaso

conc

leach

calciu

hydro

carbo

acce

subje

- wat

repre

cond

inacc

areas

cons

ASM

Subs

as au

10 C

50.55

II.B1.2.CP54

II.B2.2.CP54

II.B1.2-

6(C-31)

II.B2.2-

6(C-31)

Concrete 

(accessible 

areas): 

containment; 

wall; 

Concrete Water – 

flowing 

Increase in 

porosity and 

permeability; 

loss of 

strength due 

XI.S2, “ASME 

Section XI, 

Subsection IWL”

No

GALL 

AMR 

split t

differ

betw
NUREG-1950 II-314 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

basemat to leaching 

of calcium 

hydroxide 

and 

carbonation

acce

inacc

areas

Inspe

acce

perfo

acco

IWL w

the p

incre

poros

perm

to lea

calciu

hydro

carbo

Thus

evalu

requi

acce

II.B3.2.CP55

II.B3.2-

6(C-32)

Concrete 

(accessible 

areas): 

dome; wall; 

basemat

Concrete Water – 

flowing 

Increase in 

porosity and 

permeability; 

loss of 

strength due 

to leaching 

of calcium 

hydroxide 

and 

carbonation

XI.S2, “ASME 

Section XI, 

Subsection IWL”

No

GALL 

AMR 

split t

differ

betw

acce

inacc

areas

Inspe

acce

perfo
April 2011 II-315 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

acco

IWL w

the p

incre

poros

perm

to lea

calciu

hydro

carbo

Thus

evalu

requi

acce

II.B1.2.CP57

II.B2.2.CP57

II.B1.2-

3(C-35)

II.B2.2-

3(C-35)

Concrete: 

containment; 

wall; basemat

Concrete

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Reduction of 

strength and 

modulus due 

to elevated 

temperature 

(>150°F 

general; 

>200°F local)

Plant-specific 

aging 

management 

program 

 

The 

implementation of 

10 CFR 50.55a 

and ASME 

Section XI, 

Subsection IWL 

would not be able 

to identify the 

reduction of 

strength and 

modulus due to 

elevated 

Yes, if 

temperature 

limits are 

exceeded

As in

ACI 3

susta

expo

conc

eleva

temp

caus

mech

prope

(mod

elast

stren

resul

The r

stren

modu
NUREG-1950 II-316 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

temperature. 

Thus, for any 

portions of 

concrete 

containment that 

exceed specified 

temperature 

limits, further 

evaluations are 

warranted. 

Subsection CC3400 of ASME 

Section III, 

Division 2, 

specifies the 

concrete 

temperature 

limits for normal 

operation or any 

other long-term 

period. The 

temperatures 

shall not exceed 

150°F except for 

local areas, such 

as around 

penetrations, 

which are not 

allowed to exceed 

200°F. If 

significant 

equipment loads 

elast

acce

engin

calcu

term, 

allow

repla

“desi

calcu

beca

“desi

allow

spec

ACI C

“desi

calcu

perfo

deter

the p

cond

acce

again

“desi

allow

There

term 

calcu

used 

locat

Repo
April 2011 II-317 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

are supported by 

concrete at 

temperatures 

exceeding 150°F, 

an evaluation of 

the ability to 

withstand the 

postulated design 

loads is to be 

made. 

Higher 

temperatures 

than given above 

may be allowed in 

the concrete if 

tests and/or 

calculations are 

provided to 

evaluate the 

reduction in 

strength and 

modulus of 

elasticity, and 

these reductions 

are applied to the 

design 

calculations.

II.A2.CP58

II.A2-

3(C-38)

Concrete 

(accessible 

areas): 

basemat

Concrete Any 

environment

Cracking due 

to expansion 

from reaction 

with 

XI.S2, “ASME 

Section XI, 

Subsection IWL”

No

GALL 

AMR 

split t

differ
NUREG-1950 II-318 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

aggregates betw

acce

inacc

areas

Inspe

acce

perfo

acco

IWL w

the p

surfa

due t

from 

aggre

Thus

evalu

requi

II.B1.2.CP59

II.B2.2.CP59

II.B1.2-

4(C-39)

II.B2.2-

4(C-39)

Concrete 

(accessible 

areas): 

containment; 

wall; 

basemat

Concrete Any 

environment

Cracking due 

to expansion 

from reaction 

with 

aggregates

XI.S2, “ASME 

Section XI, 

Subsection IWL”

No

GALL 

AMR 

split t

differ

betw

acce

inacc

areas

Inspe

acce

perfo

acco

IWL w

the p
April 2011 II-319 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

surfa

due t

from 

aggre

Thus

evalu

requi

II.B3.2.CP60

II.B3.2-

4(C-40)

Concrete 

(accessible 

areas): 

dome; wall; 

basemat

Concrete Any 

environment

Cracking due 

to expansion 

from reaction 

with 

aggregates

XI.S2, “ASME 

Section XI, 

Subsection IWL”

No

GALL 

AMR 

split t

differ

betw

acce

inacc

areas

Inspe

acce

perfo

acco

IWL w

the p

surfa

due t

from 

aggre

Thus

evalu

requi

II.B1.2.CP63

II.B2.1.CPII.B1.2-

8(C-46)

II.B2.1-

Steel 

elements 

(inaccessible 

Steel

Air – indoor, 

uncontrolled 

or Treated 

Loss of 

material due 

to general, 

XI.S1, “ASME 

Section XI, 

Subsection IWE” 

Yes, if 

corrosion is 

indicated from 

GALL 

AMR 

split t
NUREG-1950 II-320 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

63

II.B2.2.CP63

1(C-46)

II.B2.2-

10(C-46)

areas): 

suppression 

chamber; 

drywell; 

drywell head; 

embedded 

shell; region 

shielded by 

diaphragm 

floor (as 

applicable)

water pitting, and 

crevice 

corrosion

and 

 

XI.S4, “10 CFR 

Part 50, Appendix 

J” 

 

Additional plantspecific activities 

are warranted if 

loss of material 

due to corrosion 

is significant for 

inaccessible 

areas (embedded 

containment steel 

shell or liner).

Loss of material 

due to corrosion 

is not significant 

if the following 

conditions are 

satisfied: 

(1) Concrete 

meeting the 

requirements of 

ACI 318 or 349 

and the guidance 

of 201.2R was 

used for the 

concrete in 

the IWE 

examinations

differ

betw

acce

inacc

areas

basis 

evalu

chan
April 2011 II-321 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

contact with the 

embedded 

containment shell 

or liner.

(2) The moisture 

barrier, at the 

junction where 

the shell or liner 

becomes 

embedded, is 

subject to aging 

management 

activities in 

accordance with 

ASME Section XI, 

Subsection IWE 

requirements.

(3) The concrete 

is monitored to 

ensure that it is 

free of 

penetrating 

cracks that 

provide a path for 

water seepage to 

the surface of the 

containment shell 

or liner.

(4) Borated water 

spills and water 

ponding on the 
NUREG-1950 II-322 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

concrete floor are 

common and 

when detected 

are cleaned up or 

diverted to a 

sump in a timely 

manner. 

Operating 

experience has 

identified 

significant 

corrosion in 

some plants.

If any of the 

above conditions 

cannot be 

satisfied, then a 

plant-specific 

aging 

management 

program for 

corrosion is 

necessary.

II.B2.2.CP64

II.B2.2-

13(C-47)

Steel 

elements: vent 

header; 

downcomers

Steel; 

stainless 

steel

Air – indoor, 

uncontrolled 

or Treated 

water

Cracking due 

to cyclic 

loading 

(CLB fatigue 

analysis does 

not exist)

XI.S1, “ASME 

Section XI, 

Subsection IWE”

No

XI.S4 

appli

beca

comp

not in 

ASM

Subs

Elem
April 2011 II-323 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

augm

requi

exam

detec

these 

comp

durin

of ex

opera

II.B3.1.CP65

II.B3.1-

4(C-50)

Concrete: 

basemat, 

concrete fill-in 

annulus

Concrete

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Reduction of 

strength and 

modulus due 

to elevated 

temperature 

(>150°F 

general; 

>200°F local)

Plant-specific 

aging 

management 

program 

 

The 

implementation of 

10 CFR 50.55a 

and ASME 

Section XI, 

Subsection IWL 

would not be able 

to identify the 

reduction of 

strength and 

modulus of 

elasticity due to 

elevated 

temperature. 

Thus, for any 

portions of 

concrete 

Yes, if 

temperature 

limits are 

exceeded

As in

ACI 3

susta

expo

conc

eleva

temp

caus

mech

prope

(mod

elast

stren

resul

The r

stren

modu

elast

acce

engin

calcu

term, 
NUREG-1950 II-324 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

containment that 

exceed specified 

temperature 

limits, further 

evaluations are 

warranted. 

Subsection CC3400 of ASME 

Section III, 

Division 2, 

specifies the 

concrete

temperature 

limits for normal 

operation or any 

other long-term 

period. The 

temperatures 

shall not exceed 

150°F except for 

local areas, such 

as around 

penetrations, 

which are not 

allowed to exceed 

200°F. If 

significant 

equipment loads 

are supported by 

concrete at 

temperatures 

exceeding 150°F, 

allow

repla

“desi

calcu

beca

“desi

allow

spec

ACI C

“desi

calcu

perfo

deter

the p

cond

acce

again

“desi

allow

There

term 

calcu

used 

locat

Repo
April 2011 II-325 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

an evaluation of 

the ability to 

withstand the 

postulated design 

loads is to be 

made. 

Higher 

temperatures 

than given above 

may be allowed in 

the concrete if 

tests and/or 

calculations are 

provided to 

evaluate the 

reduction in 

strength and 

modulus of 

elasticity and 

these reductions 

are applied to the 

design 

calculations.

II.B3.1.CP66

II.B3.1-

5(C-51)

Concrete 

(accessible 

areas): 

basemat, 

concrete fillin annulus

Concrete Any 

environment

Cracking due 

to expansion 

from reaction 

with 

aggregates

XI.S2, “ASME 

Section XI, 

Subsection IWL”

No

GALL 

AMR 

split t

differ

betw

acce

inacc

areas
NUREG-1950 II-326 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

Inspe

acce

perfo

acco

IWL w

the p

surfa

due t

from 

aggre

Thus

evalu

requi

II.A1.CP67

II.A1-

3(C-04)

Concrete 

(inaccessible 

areas): 

dome; wall; 

basemat; 

ring girders; 

buttresses

Concrete Any 

environment

Cracking due 

to expansion 

from reaction 

with 

aggregates

Further 

evaluation is 

required to 

determine if a 

plant-specific 

aging 

management 

program is 

needed to 

manage cracking 

and expansion 

due to reaction 

with aggregate of 

concrete in 

Inaccessible 

Areas. A plantspecific aging 

management 

Yes, if 

concrete is not 

constructed as 

stated

GALL 

AMR 

split t

differ

betw

acce

inacc

areas

Curre

basis 

plant

requi

aggre

react

on AS

or AS

Delet

year 
April 2011 II-327 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

program is not 

required if (1) As 

described in 

NUREG-1557, 

investigations, 

tests, and 

petrographic 

examinations of 

aggregates 

performed in 

accordance with 

ASTM C295 and 

other ASTM 

reactivity tests, 

as required, can 

demonstrate that 

those aggregates 

do not adversely 

react within 

concrete, or (2) 

For potentially 

reactive 

aggregates, 

aggregate 

concrete reaction 

is not significant 

if it is 

demonstrated 

that the in-place 

concrete can 

perform its 

intended 

C295 

C227 

addit

ASTM 

tests 

altern

acce

techn

for pl

not c

a spe

the s

ASTM 

For p

react

aggre

single 

to AC

a bas

react

aggre

signif

not in

provi

conc

struc

cons

acco

ACI 3

201.2

was d

after 
NUREG-1950 II-328 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

function. earlie

plant

cons

were 

in ac

with A

which 

the re

for de

cons

reinfo

conc

struc

includ

facto

ceme

propo

slum

aggre

of mi

time, 

temp

durab

which 

addre

201.2

appro

prece

in TM

Secti

3.5.2

3.5.2
April 2011 II-329 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

acce

conc

desig

cons

inspe

acco

appli

and A

stand

II.A1.CP68

II.A1-

7(C-05)

Concrete 

(accessible 

areas): 

dome; wall; 

basemat; 

ring girders; 

buttresses; 

reinforcing 

steel

Concrete; 

steel

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Cracking; 

loss of bond; 

and loss of 

material 

(spalling, 

scaling) due 

to corrosion 

of embedded 

steel

XI.S2, “ASME 

Section XI, 

Subsection IWL”

No

GALL 

AMR 

split t

differ

betw

acce

inacc

areas

Inspe

acce

perfo

acco

IWL w

the p

surfa

loss o

loss o

(spal

due t

of em

steel

furthe
NUREG-1950 II-330 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

is no

II.A2.CP69

II.B3.1.CP69

II.A2-

5(C-36)

II.B3.1-

2(C-36)

Concrete: 

basemat Concrete Soil

Cracking and 

distortion due 

to increased 

stress levels 

from 

settlement

XI.S2, “ASME 

Section XI, 

Subsection IWL,” 

or 

XI.S6, "Structure 

Monitoring" 

If a de-watering 

system is relied 

upon for control 

of settlement, 

then the licensee 

is to ensure 

proper 

functioning of the 

de-watering 

system through 

the period of 

extended 

operation. 

Yes, if a dewatering 

system is 

relied upon to 

control 

settlement

ASM

Subs

or St

Moni

appli

mana

progr

conc

elem

BWR 

conta

The p

Elem

Para

Moni

includ

moni

conc

crack

II.A2.CP70

II.A2-

2(C-28)

Concrete 

(inaccessible 

areas): 

basemat

Concrete

Air – outdoor 

or Ground 

water/soil

Loss of 

material 

(spalling, 

scaling) and 

cracking due 

to freezethaw

Further 

evaluation is 

required for 

plants that are 

located in 

moderate to 

severe 

weathering 

conditions 

(weathering index 

Yes, for plants 

located in 

moderate to 

severe 

weathering 

conditions 

GALL 

Item 

to dif

betw

acce

inacc

areas

incre

conte

to 8% 
April 2011 II-331 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

>100 day-inch/yr) 

(NUREG-1557) to 

determine if a 

plant-specific 

aging 

management 

program is 

needed. A plantspecific aging 

management 

program is not 

required if 

documented 

evidence 

confirms that the 

existing concrete 

had air 

entrainment 

content (as per 

Table CC-2231-2 

of the ASME 

Section III 

Division 2), and 

subsequent 

inspections of 

accessible areas 

did not exhibit 

degradation 

related to freezethaw. Such 

inspections 

should be 

acce

on AC

and A

Table 
NUREG-1950 II-332 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

considered a part 

of the evaluation. 

If this condition is 

not satisfied, then 

a plant-specific 

aging 

management 

program is 

required to 

manage loss of 

material (spalling, 

scaling) and 

cracking due to 

freeze-thaw of 

concrete in 

inaccessible 

areas. 

The weathering 

index for the 

continental U.S. 

is shown in ASTM 

C33-90, Fig. 1.

II.A2.CP71

II.B3.1.CP71

II.A2-

4(C-25)

II.B3.1-

1(C-25)

Concrete 

(inaccessible 

areas): 

basemat

Concrete Ground 

water/soil

Increase in

porosity and 

permeability; 

cracking; loss 

of material 

(spalling, 

scaling) due 

to aggressive 

chemical 

XI.S2, “ASME 

Section XI, 

Subsection IWL,” 

or 

XI.S6, "Structures 

Monitoring“

No

GALL 

AMR 

split t

differ

betw

acce

inacc

areas

“Stru
April 2011 II-333 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

attack Moni

progr

revis

moni

aging 

mech

this c

XI.S2 

used 

moni

conta

base

Furth

evalu

requi

II.A2.CP72

II.B3.1.CP72

II.A2-

4(C-25)

II.B3.1-

1(C-25)

Concrete 

(accessible 

areas): 

basemat

Concrete Ground 

water/soil

Increase in 

porosity and 

permeability; 

cracking; loss 

of material 

(spalling, 

scaling) due 

to aggressive 

chemical 

attack

XI.S2, “ASME 

Section XI, 

Subsection IWL,” 

or 

XI.S6, "Structures 

Monitoring"

No

GALL 

Line 

split t

differ

betw

acce

inacc

areas

Inspe

acce

perfo

acco

IWL w

the p

incre

poros
NUREG-1950 II-334 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

perm

crack

mate

scalin

aggre

chem

Thus

evalu

requi

acce

II.B3.2.CP73

II.B3.2-

5(C-27)

Concrete 

(inaccessible 

areas): 

dome; wall; 

basemat

Concrete

Air – indoor, 

uncontrolled 

or Air – 

outdoor or 

Ground 

water/soil

Increase in 

porosity and 

permeability; 

cracking; loss 

of material 

(spalling, 

scaling) due 

to aggressive 

chemical 

attack

XI.S2, “ASME 

Section XI, 

Subsection IWL,” 

or XI.S6,

"Structures 

Monitoring"

No

GALL 

AMR 

split t

differ

betw

acce

inacc

areas

evalu

for a 

spec

is no

AMP 

been 

addre

wate

II.A2.CP74 

II.B3.1.CP74

II.A2-

7(C-43)

II.B3.1-

6(C-43)

Concrete 

(accessible 

areas): 

basemat; 

reinforcing 

Concrete; 

steel

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Cracking; 

loss of bond; 

and loss of 

material 

(spalling, 

XI.S2, “ASME 

Section XI, 

Subsection IWL”

No

GALL 

AMR 

split t

differ

betw
April 2011 II-335 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

steel scaling) due 

to corrosion 

of embedded 

steel

acce

inacc

areas

Inspe

acce

perfo

acco

IWL w

the p

surfa

loss o

loss o

(spal

due t

of em

steel

furthe

is no

II.A2.CP75

II.B3.1.CP75

II.A2-

7(C-43)

II.B3.1-

6(C-43)

Concrete 

(inaccessible 

areas): 

basemat; 

reinforcing 

steel

Concrete; 

steel

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Cracking; 

loss of bond; 

and loss of 

material 

(spalling, 

scaling) due 

to corrosion 

of embedded 

steel

XI.S2, “ASME 

Section XI, 

Subsection IWL,” 

or 

XI.S6, "Structures 

Monitoring"

No

GALL 

AMR 

split t

differ

betw

acce

inacc

areas

AMP 

groun

moni

II.B1.2.CP79II.B1.2-

2(C-41)

Concrete 

(accessible 

Concrete; 

steel

Air – indoor, 

uncontrolled 

Cracking; 

loss of bond; 

XI.S2, “ASME 

Section XI, No GALL 

AMR 
NUREG-1950 II-336 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

II.B2.2.CP79

II.B2.2-

2(C-41) areas): 

basemat; 

reinforcing 

steel

or Air – 

outdoor

and loss of 

material 

(spalling, 

scaling) due 

to corrosion 

of embedded 

steel

Subsection IWL” split t

differ

betw

acce

inacc

areas

Inspe

acce

perfo

acco

IWL w

the p

surfa

loss o

loss o

(spal

due t

of em

steel

furthe

is no

II.B1.2.CP80

II.B2.2.CP80

II.B1.2(C41)

II.B2.2-

2(C-41)

Concrete 

(inaccessible 

areas): 

basemat; 

reinforcing 

steel

Concrete; 

steel

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Cracking; 

loss of bond; 

and loss of 

material 

(spalling, 

scaling) due 

to corrosion 

of embedded 

steel

XI.S6, "Structures 

Monitoring" No

GALL 

AMR 

split t

differ

betw

acce

inacc

areas

AMP 

groun
April 2011 II-337 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

moni

Furth

evalu

chan

Yes t

II.B3.1.CP83

II.B3.1-

5(C-51)

Concrete 

(inaccessible 

areas): 

basemat, 

concrete fillin annulus

Concrete Any 

environment

Cracking 

due to 

expansion 

from reaction 

with 

aggregates

Further 

evaluation is 

required to 

determine if a 

plant-specific 

aging 

management 

program is 

needed to 

manage cracking 

and expansion 

due to reaction 

with aggregate of 

concrete in 

Inaccessible 

Areas. A plantspecific aging 

management 

program is not 

required if (1) As 

described in 

NUREG-1557, 

investigations, 

tests, and 

petrographic 

examinations of 

Yes, if 

concrete is not 

constructed as 

stated

GALL 

AMR 

split t

differ

betw

acce

inacc

areas

 

Curre

basis 

plant

requi

aggre

react

on AS

or AS

Delet

year 

C295 

C227 

addit

ASTM 

tests 

altern

acce
NUREG-1950 II-338 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

aggregates 

performed in 

accordance with 

ASTM C295 and 

other ASTM 

reactivity tests, 

as required, can 

demonstrate that 

those aggregates 

do not adversely 

react within 

concrete, or (2) 

For potentially 

reactive 

aggregates,

aggregate 

concrete reaction 

is not significant 

if it is 

demonstrated 

that the in-place 

concrete can 

perform its 

intended 

function.

techn

for pl

not c

a spe

the s

ASTM 

For p

react

aggre

single 

to AC

a bas

react

aggre

signif

not in

provi

conc

struc

cons

acco

ACI 3

201.2

was d

after 

earlie

plant

cons

were 

in ac

with A

which 
April 2011 II-339 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

the re

for de

cons

reinfo

conc

struc

includ

facto

ceme

propo

slum

aggre

of mi

time, 

temp

durab

which 

addre

201.2

appro

prece

in TM

Secti

3.5.2

3.5.2

acce

conc

desig

cons

inspe

acco

appli
NUREG-1950 II-340 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

and A

stand

II.B3.2.CP84

II.B3.2-

5(C-27)

Concrete 

(accessible 

areas): 

dome; wall;

basemat

Concrete

Air – indoor, 

uncontrolled 

or Air – 

outdoor or 

Ground 

water/soil

Increase in 

porosity and 

permeability; 

cracking; loss 

of material 

(spalling, 

scaling) due 

to aggressive 

chemical 

attack

XI.S2, “ASME 

Section XI, 

Subsection IWL,” 

or 

XI.S6, "Structure 

Monitoring"

No

GALL 

AMR 

split t

differ

betw

acce

inacc

areas

Inspe

acce

perfo

acco

IWL w

the p

incre

poros

perm

crack

mate

scalin

aggre

chem

Thus

evalu

requi

acce

AMP 

chan

addre
April 2011 II-341 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

wate

II.A1.CP87

II.A1-

4(C-03)

Concrete 

(accessible 

areas): 

dome; wall; 

basemat; 

ring girders; 

buttresses

Concrete

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Increase in 

porosity and 

permeability; 

cracking; loss 

of material 

(spalling, 

scaling) due 

to aggressive 

chemical 

attack

XI.S2, “ASME 

Section XI, 

Subsection IWL”

No

GALL 

AMR 

split t

differ

betw

acce

inacc

areas

Inspe

acce

perfo

acco

IWL w

the p

incre

poros

perm

crack

mate

scalin

aggre

chem

Thus

evalu

requi

acce

II.B3.2.CP88

II.B3.2-

7(C-42)

Concrete 

(accessible 

areas): 

dome; wall; 

Concrete; 

steel

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Cracking; 

loss of bond; 

and loss of 

material 

XI.S2, “ASME 

Section XI, 

Subsection IWL”

No

GALL 

AMR 

split t

differ
NUREG-1950 II-342 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

basemat; 

reinforcing 

steel

(spalling, 

scaling) due 

to corrosion 

of embedded 

steel

betw

acce

inacc

areas

Inspe

acce

perfo

acco

IWL w

the p

surfa

loss o

loss o

(spal

due t

of em

steel

furthe

is no

II.B3.2.CP89

II.B3.2-

7(C-42)

Concrete 

(inaccessible 

areas): 

dome; wall; 

basemat; 

reinforcing 

steel

Concrete; 

steel

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Cracking; 

loss of bond; 

and loss of 

material 

(spalling, 

scaling) due 

to corrosion 

of embedded 

steel

XI.S2, “ASME 

Section XI, 

Subsection IWL,” 

or 

XI.S6, "Structures 

Monitoring"

No

GALL 

AMR 

split t

differ

betw

acce

inacc

areas

AMP 

groun

moni

Furth
April 2011 II-343 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

evalu

chan

Yes t

II.A1.CP97

II.A1-

7(C-05)

Concrete 

(inaccessible 

areas): 

dome; wall; 

basemat; 

ring girders; 

buttresses; 

reinforcing 

steel

Concrete; 

steel

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Cracking; 

loss of bond; 

and loss of 

material 

(spalling, 

scaling) due 

to corrosion 

of embedded 

steel

XI.S2, “ASME 

Section XI, 

Subsection IWL,” 

or 

XI.S6, "Structure 

Monitoring"

No

GALL 

AMR 

split t

differ

betw

acce

inacc

areas

AMP 

groun

moni

II.A1.CP98

II.A2.CP98

II.B3.2.CP98

II.A1-

11(C-09)

II.A2-

9(C-09)

II.B3.2-

9(C-09)

Steel 

elements 

(inaccessible 

areas): liner; 

liner 

anchors; 

integral 

attachments

Steel Air – indoor, 

uncontrolled

Loss of 

material due 

to general, 

pitting, and 

crevice 

corrosion

XI.S1, “ASME 

Section XI, 

Subsection IWE” 

and 

XI.S4, “10 CFR 

Part 50, Appendix 

J” 

Additional plantspecific activities 

are warranted if 

loss of material 

due to corrosion 

is significant for 

inaccessible 

areas (embedded 

containment steel 

Yes, if 

corrosion is 

indicated from 

the IWE 

examinations

GALL 

AMR 

split t

differ

betw

acce

inacc

areas

basis 

evalu

chan
NUREG-1950 II-344 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

shell or liner).

Loss of material 

due to corrosion 

is not significant 

if the following 

conditions are 

satisfied: 

(1) Concrete 

meeting the 

requirements of 

ACI 318 or 349 

and the guidance 

of 201.2R was 

used for the 

containment 

concrete in 

contact with the 

embedded 

containment shell 

or liner.

(2) The moisture 

barrier, at the 

junction where 

the shell or liner 

becomes 

embedded, is 

subject to aging 

management 

activities in 

accordance with 

ASME Section XI, 
April 2011 II-345 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

Subsection IWE 

requirements.

(3) The concrete 

is monitored to 

ensure that it is 

free of 

penetrating 

cracks that 

provide a path for 

water seepage to 

the surface of the 

containment shell 

or liner.

(4) Borated water 

spills and water 

ponding on the 

concrete floor are 

common and 

when detected 

are cleaned up or 

diverted to a 

sump in a timely 

manner. 

Operating 

experience has 

identified 

significant 

corrosion in 

some plants.

If any of the 

above conditions 
NUREG-1950 II-346 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

cannot be 

satisfied, then a 

plant-specific 

aging 

management 

program for 

corrosion is 

necessary.

II.B1.2.CP99

II.B2.2.CP99

II.B1.2-

4(C-39)

II.B2.2-

4(C-39)

Concrete 

(inaccessible 

areas): 

containment; 

wall; 

basemat

Concrete Any 

environment

Cracking due 

to expansion 

from reaction 

with 

aggregates

Further 

evaluation is 

required to 

determine if a 

plant-specific 

aging 

management 

program is 

needed to 

manage cracking 

and expansion 

due to reaction 

with aggregate of 

concrete in 

Inaccessible 

Areas. A plantspecific aging 

management 

program is not 

required if (1) As 

described in 

NUREG-1557, 

investigations, 

Yes, if 

concrete is not 

constructed as 

stated

GALL 

AMR 

split t

differ

betw

acce

inacc

areas

Curre

basis 

plant

requi

aggre

react

on AS

or AS

Delet

year 

C295 

C227 

addit

ASTM 

tests 
April 2011 II-347 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

tests, and 

petrographic 

examinations of 

aggregates 

performed in 

accordance with 

ASTM C295 and 

other ASTM 

reactivity tests, 

as required, can 

demonstrate that 

those aggregates 

do not adversely 

react within 

concrete, or (2) 

For potentially 

reactive 

aggregates, 

aggregate 

concrete reaction 

is not significant 

if it is 

demonstrated 

that the in-place 

concrete can 

perform its 

intended 

function.

altern

acce

techn

for pl

not c

a spe

the s

ASTM 

For p

react

aggre

single 

to AC

a bas

react

aggre

signif

not in

provi

conc

struc

cons

acco

ACI 3

201.2

was d

after 

earlie

plant

cons

were 

in ac
NUREG-1950 II-348 April 2011

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

with A

which 

the re

for de

cons

reinfo

conc

struc

includ

facto

ceme

propo

slum

aggre

of mi

time, 

temp

durab

which 

addre

201.2

appro

prece

in TM

Secti

3.5.2

3.5.2

acce

conc

desig

cons

inspe
April 2011 II-349 NUREG-1950

Table II-11. Changes to Existing GALL Report Rev. 1 Chapter II AMR Items for Containment and Their Te

where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Tech

for 

acco

appli

and A

stand
NUREG-1950 II-350 April 2011

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

III.A6.TP104

III.A6-

1(T-18)

Concrete 

(inaccessible 

areas): all

Concrete

Air – indoor, 

uncontrolled 

or Air – 

outdoor or 

Ground 

water/soil

Cracking; loss 

of bond; and 

loss of 

material 

(spalling, 

scaling) due 

to corrosion 

of embedded 

steel

XI.S6, 

"Structures 

Monitoring"

No

GALL R

item T-1

differen

between 

and inac

areas. R

AMP inc

ground 

monitor

evaluati

from Ye

"Reinfor

concrete

changed 

"Concre

consiste

Chapter 

Ground 

environ

applicab

compon

aging ef

mechan

applicab

consiste

212.

III.A6.TP107

III.A6-

3(T-19)

Concrete 

(inaccessible 

areas): all

Concrete Ground 

water/soil

Increase in 

porosity and 

permeability; 

cracking; loss 

of material 

(spalling, 

XI.S6, 

"Structures 

Monitoring"

No

GALL R

item T-1

differen

between 

and inac

areas. A
April 2011 II-351 NUREG-1950

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

scaling) due 

to aggressive 

chemical 

attack

is revise

ground 

monitor

III.A1.TP108

III.A2.TP108

III.A3.TP108

III.A5.TP108

III.A7.TP108

III.A8.TP108

III.A9.TP108

III.A1-

6(T-01)

III.A2-

6(T-01)

III.A3-

6(T-01)

III.A5-

6(T-01)

III.A7-

5(T-01)

III.A8-

5(T-01)

III.A9-

5(T-01)

Concrete 

(inaccessible 

areas): 

foundation

Concrete Air – outdoor

Loss of 

material 

(spalling, 

scaling) and 

cracking due 

to freezethaw

Further 

evaluation is 

required for 

plants that are 

located in 

moderate to 

severe 

weathering 

conditions 

(weathering 

index >100 

day-inch/yr) 

(NUREG-1557) 

to determine if 

a plant-specific 

aging 

management 

program is 

needed. A 

plant-specific 

aging 

management 

program is not 

required if 

documented 

evidence

confirms that 

the existing 

Yes, for plants 

located in 

moderate to 

severe 

weathering 

conditions 

GALL R

Item T-0

differen

between 

and inac

areas. T

in air co

accepta

on ACI-

ACI 301

304(b). 

concrete

changed 

"Concre

consiste

Chapter 
NUREG-1950 II-352 April 2011

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

concrete had 

air entrainment 

content (as per 

Table CC-2231-

2 of the ASME 

Section III 

Division 2), 

and 

subsequent 

inspections of 

accessible 

areas did not 

exhibit 

degradation 

related to 

freeze-thaw. 

Such 

inspections 

should be 

considered a 

part of the 

evaluation. If 

this condition 

is not satisfied, 

then a plantspecific aging 

management 

program is 

required to 

manage loss of 

material 

(spalling, 

scaling) and 
April 2011 II-353 NUREG-1950

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

cracking due 

to freeze-thaw 

of concrete in 

inaccessible 

areas. 

The weathering 

index for the 

continental 

U.S. is shown 

in ASTM C33-

90, Fig. 1.

III.A6.TP109

III.A6-

6(T-16)

Concrete 

(inaccessible 

areas): 

exterior 

above- and 

below-grade; 

foundation; 

interior slab

Concrete Water – 

flowing

Increase in 

porosity and 

permeability; 

loss of 

strength due 

to leaching 

of calcium 

hydroxide 

and 

carbonation

Further 

evaluation is 

required to 

determine if a 

plant-specific 

aging 

management 

program is 

needed to 

manage

increase in 

porosity, and 

permeability 

due to leaching 

of calcium 

hydroxide and 

carbonation of 

concrete in 

Inaccessible 

Areas. A plantspecific aging 

Yes, if 

leaching is 

observed in 

accessible 

areas that 

impact 

intended 

function

GALL R

Item T-1

differen

between 

and inac

areas.

 

ACI 201

develop

some p

construc

plants w

construc

accorda

ACI 318

provided 

requirem

design a

construc

reinforc

structur
NUREG-1950 II-354 April 2011

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

management 

program is not 

required if (1) 

There is 

evidence in the 

accessible 

areas that the 

flowing water 

has not caused 

leaching and 

carbonation, or 

(2) Evaluation 

determined 

that the 

observed 

leaching of 

calcium 

hydroxide and 

carbonation in 

accessible 

areas has no 

impact on the 

intended 

function of the 

concrete 

structure.

included 

water-ce

proporti

aggrega

mixer, m

and tem

durable 

which w

address

201.2R-

concrete 

construc

either A

201.2R 

expecte

durable

these st

were us

accessi

inacces

concrete

reasona

conclud

leaching 

hydroxid

carbona

accessi

subject 

water re

the cond

inacces

III.A6.TP110III.A6-

5(T-15) Concrete Concrete Air – outdoor Loss of Further Yes, for plants GALL R
April 2011 II-355 NUREG-1950

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

(inaccessible 

areas): 

exterior 

above- and 

below-grade; 

foundation; 

interior slab

material 

(spalling, 

scaling) and 

cracking 

due to freezethaw

evaluation is 

required for 

plants that are 

located in 

moderate to 

severe 

weathering 

conditions 

(weathering 

index >100 

day-inch/yr) 

(NUREG-1557) 

to determine if

a plant-specific 

aging 

management 

program is 

needed. A 

plant-specific 

aging 

management 

program is not 

required if 

documented 

evidence 

confirms that 

the existing 

concrete had 

air entrainment 

content (as per 

Table CC-2231-

2 of the ASME 

Section III 

located in 

moderate to 

severe 

weathering 

conditions 

Item T-1

differen

between 

and inac

areas. E

air conte

on ASM

ACI-201

ACI 301

304(b). 

concrete

changed 

"Concre

consiste

Chapter 
NUREG-1950 II-356 April 2011

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

Division 2), 

and 

subsequent 

inspections of 

accessible 

areas did not 

exhibit 

degradation 

related to 

freeze-thaw. 

Such 

inspections 

should be 

considered a 

part of the 

evaluation. If 

this condition 

is not satisfied, 

then a plantspecific aging 

management 

program is 

required to 

manage loss of 

material 

(spalling, 

scaling) and 

cracking due 

to freeze-thaw 

of concrete in 

inaccessible 

areas. The 

weathering 
April 2011 II-357 NUREG-1950

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

index for the 

continental 

U.S. is shown 

in ASTM C33-

90, Fig. 1.

III.A1.TP114

III.A2.TP114

III.A3.TP114

III.A4.TP114

III.A5.TP114

III.A1-

1(T-10)

III.A2-

1(T-10)

III.A3-

1(T-10)

III.A4-

1(T-10)

III.A5-

1(T-10)

Concrete: all Concrete Air – indoor, 

uncontrolled

Reduction of 

strength and 

modulus due 

to elevated 

temperature 

(>150°F 

general; 

>200°F local)

Plant-specific 

aging 

management 

program 

 

Subsection 

CC-3400 of 

ASME 

Section III, 

Division 2, and 

Appendix A of 

ACI 349 

specifies the 

concrete 

temperature 

limits for 

normal 

operation or 

any other longterm period. 

The 

temperatures 

shall not 

exceed 150°F 

except for local 

areas, such as 

around 

Yes, if 

temperature 

limits are 

exceeded

As indic

349, sus

exposur

concrete 

elevated 

tempera

cause a 

mechan

properti

of elasti

strength

in crack

reductio

strength 

modulus 

elasticit

accepte

enginee

calculat

term, “d

allowab

replaced 

“design 

calculat

because 

“design 

are spe
NUREG-1950 II-358 April 2011

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

penetrations, 

where the 

temperatures 

are not allowed 

to exceed 

200°F. If 

significant 

equipment 

loads are 

supported by 

concrete at 

temperatures 

exceeding 

150°F, an 

evaluation of 

the ability to 

withstand the 

postulated 

design loads is 

to be made. 

Higher 

temperatures 

than those 

given above 

may be 

allowed in the 

concrete if 

tests and/or 

calculations 

are provided to 

evaluate the 

reduction in 

strength and 

ACI Cod

“design 

calculat

perform

determi

plant co

accepta

the “des

allowab

Therefo

“design 

calculat

used at 

location

Report 
April 2011 II-359 NUREG-1950

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

modulus of 

elasticity and 

these 

reductions are 

applied to the 

design 

calculations.

III.A1.TP204

III.A2.TP204

III.A3.TP204

III.A4.TP204

III.A5.TP204

III.A7.TP204

III.A8.TP204

III.A9.TP204

III.A1-

2(T-03)

III.A2-

2(T-03)

III.A3-

2(T-03)

III.A4-

2(T-03)

III.A5-

2(T-03)

III.A7-

1(T-03)

III.A8-

1(T-03)

III.A9-

1(T-03)

Concrete 

(inaccessible 

areas): all

Concrete Any 

environment

Cracking due 

to expansion 

from reaction 

with 

aggregates

Further 

evaluation is 

required to 

determine if a 

plant-specific 

aging 

management 

program is 

needed to 

manage 

cracking and 

expansion due 

to reaction 

with aggregate 

of concrete in 

Inaccessible 

Areas. A plantspecific aging 

management 

program is not 

required if (1) 

As described 

in NUREG1557, 

investigations, 

Yes, if 

concrete is not 

constructed as 

stated

GALL R

Item T-0

differen

between 

and inac

areas. 

Current 

basis of 

plants m

require 

aggrega

based o

C295 or 

C227. D

the yea

C295 an

C227 an

addition 

ASTM r

tests pro

alternat

accepta

technica

plants th

committ
NUREG-1950 II-360 April 2011

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

tests, and 

petrographic 

examinations 

of aggregates 

performed in 

accordance 

with ASTM 

C295 and other 

ASTM 

reactivity tests, 

as required, 

can 

demonstrate 

that those 

aggregates do 

not adversely 

react within 

concrete, or (2) 

For potentially 

reactive 

aggregates, 

aggregate 

concrete 

reaction is not 

significant if it 

is 

demonstrated 

that the inplace concrete 

can perform its 

intended 

function.

specific 

standar

C227.

For pote

reactive 

the sing

to ACI 2

basis w

with agg

not sign

not inclu

provisio

concrete 

construc

accorda

ACI 318

201.2R 

was dev

after ma

earlier n

plants w

construc

were co

accorda

ACI 318

provided 

requirem

design a

construc

reinforc

structur

included 

for wate
April 2011 II-361 NUREG-1950

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

mix pro

slump, a

type of 

mixing t

tempera

durable 

which w

address

201.2R. 

approve

exists in 

Section

and 3.5

acceptin

designe

construc

inspecte

accorda

applicab

ASTM s

III.A1.TP212

III.A2.TP212

III.A3.TP212

III.A5.TP212

III.A7.TP212

III.A8.TP212

III.A9.TPIII.A1-

4(T-05)

III.A2-

4(T-05)

III.A3-

4(T-05)

III.A5-

4(T-05)

III.A7-

3(T-05)

III.A8-

3(T-05)

III.A9-

Concrete 

(inaccessible 

areas): 

below-grade 

exterior; 

foundation

Concrete Ground 

water/soil

Cracking; loss 

of bond; and 

loss of 

material 

(spalling, 

scaling) due 

to corrosion 

of embedded 

steel

XI.S6, 

"Structures 

Monitoring"

No

GALL R

item T-0

differen

between 

and inac

areas. R

AMP inc

ground 

monitor

evaluati

from Ye

"Reinfor
NUREG-1950 II-362 April 2011

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

212 3(T-05) concrete

changed 

"Concre

consiste

Chapter 

III.A6.TP220

III.A6-

2(T-17)

Concrete 

(inaccessible 

areas): all

Concrete Any 

environment

Cracking due 

to expansion 

from reaction 

with 

aggregates

Further 

evaluation is 

required to 

determine if a 

plant-specific 

aging 

management 

program is 

needed to 

manage 

cracking and 

expansion due 

to reaction 

with aggregate 

of concrete in 

Inaccessible 

Areas. A plantspecific aging 

management 

program is not 

required if (1) 

As described 

in NUREG1557, 

investigations, 

tests, and 

petrographic 

Yes, if 

concrete is not 

constructed as 

stated

GALL R

Item T-1

differen

between 

and inac

areas. 

Current 

basis of 

plants m

require 

aggrega

based o

C295 or 

C227. D

the yea

C295 an

C227 an

addition 

ASTM r

tests pro

alternat

accepta

technica

plants th

committ

specific 

standar
April 2011 II-363 NUREG-1950

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

examinations 

of aggregates 

performed in 

accordance 

with ASTM 

C295 and other 

ASTM 

reactivity tests, 

as required, 

can 

demonstrate 

that those 

aggregates do 

not adversely 

react within 

concrete, or (2) 

For potentially 

reactive 

aggregates, 

aggregate 

concrete 

reaction is not 

significant if it 

is 

demonstrated 

that the inplace concrete 

can perform its 

intended 

function.

C227.

For pote

reactive 

the sing

to ACI 2

basis w

with agg

not sign

not inclu

provisio

concrete 

construc

accorda

ACI 318

201.2R 

was dev

after ma

earlier n

plants w

construc

were co

accorda

ACI 318

provided 

requirem

design a

construc

reinforc

structur

included 

for wate

mix pro

slump, a
NUREG-1950 II-364 April 2011

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

type of 

mixing t

tempera

durable 

which w

address

201.2R. 

approve

exists in 

Section

and 3.5

acceptin

designe

construc

inspecte

accorda

applicab

ASTM s

III.A1.TP23

III.A2.TP23

III.A3.TP23

III.A5.TP23

III.A7.TP23

III.A8.TP23

III.A9.TP23

III.A1-

6(T-01)

III.A2-

6(T-01)

III.A3-

6(T-01)

III.A5-

6(T-01)

III.A7-

5(T-01)

III.A8-

5(T-01)

III.A9-

5(T-01)

Concrete 

(accessible 

areas): 

exterior 

above- and 

below-grade; 

foundation

Concrete Air – outdoor

Loss of 

material 

(spalling, 

scaling) and 

cracking due 

to freezethaw

XI.S6, 

"Structures 

Monitoring"

No 

GALL R

Item T-0

differen

between 

and inac

areas. I

of acces

perform

accorda

structur

monitor

will indic

presenc

materia
April 2011 II-365 NUREG-1950

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

scaling) 

cracking 

freeze-t

a furthe

is not re

accessi

areas."R

Concret

changed 

"Concre

consiste

Chapter 

III.A1.TP24

III.A2.TP24

III.A3.TP24

III.A5.TP24

III.A7.TP24

III.A8.TP24

III.A9.TP24

III.A1-

7(T-02)

III.A2-

7(T-02)

III.A3-

7(T-02)

III.A5-

7(T-02)

III.A7-

6(T-02)

III.A8-

6(T-02)

III.A9-

6(T-02)

Concrete 

(accessible 

areas): 

exterior 

above- and 

below-grade; 

foundation

Concrete Water – 

flowing

Increase in 

porosity and 

permeability; 

loss of 

strength due 

to leaching of 

calcium 

hydroxide and 

carbonation

XI.S6, 

"Structures 

Monitoring"

No

GALL R

item T-0

differen

between 

and inac

areas. I

of acces

perform

accorda

structur

monitor

will indic

presenc

increase 

permea

leaching 

hydroxid

carbona

a furthe

is not re
NUREG-1950 II-366 April 2011

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

accessi

III.A1.TP25

III.A2.TP25

III.A3.TP25

III.A4.TP25

III.A5.TP25

III.A7.TP25

III.A8.TP25

III.A9.TP25

III.A1-

2(T-03)

III.A2-

2(T-03)

III.A3-

2(T-03)

III.A4-

2(T-03)

III.A5-

2(T-03)

III.A7-

1(T-03)

III.A8-

1(T-03)

III.A9-

1(T-03)

Concrete 

(accessible 

areas): all

Concrete Any 

environment

Cracking due 

to expansion 

from reaction 

with 

aggregates

XI.S6, 

"Structures 

Monitoring"

No

GALL R

item T-0

differen

between 

and inac

areas. I

of acces

perform

accorda

structur

monitor

will indic

presenc

cracking 

expansi

reaction 

aggrega

further e

not requ

III.A1.TP26

III.A2.TP26

III.A3.TP26

III.A4.TP26

III.A5.TP26

III.A7.TP26

III.A9.TPIII.A1-

9(T-04)

III.A2-

9(T-04)

III.A3-

9(T-04)

III.A4-

3(T-04)

III.A5-

9(T-04)

III.A7-

8(T-04)

III.A9-

Concrete 

(accessible 

areas): 

interior and 

above-grade 

exterior

Concrete

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Cracking; loss 

of bond; and 

loss of 

material 

(spalling, 

scaling) due 

to corrosion 

of embedded 

steel

XI.S6, 

"Structures 

Monitoring"

No

XI.S6, “

Monitor

program 

to requi

monitor

aging 

effect/m

for this c

Further 

is not re

"Reinfor

concrete
April 2011 II-367 NUREG-1950

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

26 8(T-04) changed 

"Concre

consiste

Chapter 

III.A1.TP27

III.A2.TP27

III.A3.TP27

III.A5.TP27

III.A7.TP27

III.A8.TP27

III.A9.TP27

III.A1-

4(T-05)

III.A2-

4(T-05)

III.A3-

4(T-05)

III.A5-

4(T-05)

III.A7-

3(T-05)

III.A8-

3(T-05)

III.A9-

3(T-05)

Concrete 

(accessible 

areas): 

below-grade 

exterior; 

foundation

Concrete Ground 

water/soil

Cracking; loss 

of bond; and 

loss of 

material 

(spalling, 

scaling) due 

to corrosion 

of embedded 

steel

XI.S6, 

"Structures 

Monitoring"

No

GALL R

item T-0

differen

between 

and inac

areas. I

of acces

perform

accorda

structur

monitor

will indic

presenc

cracking

bond, a

materia

scaling) 

corrosio

embedd

Thus, a 

evaluati

required

"Reinfor

concrete

changed 

"Concre

consiste

Chapter 
NUREG-1950 II-368 April 2011

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

III.A1.TP28

III.A2.TP28

III.A3.TP28

III.A4.TP28

III.A5.TP28

III.A7.TP28

III.A9.TP28

III.A1-

10(T06)

III.A2-

10(T06)

III.A3-

10(T06)

III.A4-

4(T-06)

III.A5-

10(T06)

III.A7-

9(T-06)

III.A9-

9(T-06)

Concrete: 

interior; 

above-grade 

exterior

Concrete

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Increase in 

porosity and 

permeability; 

cracking; loss 

of material 

(spalling, 

scaling) due 

to aggressive 

chemical 

attack

XI.S6, 

"Structures 

Monitoring"

No

XI.S6, “

Monitor

program 

to requi

monitor

aging 

effect/m

for this c

Further 

is not re

"Reinfor

concrete

changed 

"Concre

consiste

Chapter 

III.A1.TP29

III.A2.TP29

III.A3.TP29

III.A5.TP29

III.A7.TP29

III.A8.TP29

III.A9.TP29

III.A1-

5(T-07)

III.A2-

5(T-07) 

III.A3-

5(T-07)

III.A5-

5(T-07)

III.A7-

4(T-07)

III.A8-

4(T-07)

III.A9-

4(T-07)

Concrete 

(inaccessible 

areas): 

below-grade 

exterior; 

foundation

Concrete Ground 

water/soil

Increase in 

porosity and 

permeability; 

cracking; loss 

of material 

(spalling, 

scaling) due 

to aggressive 

chemical 

attack

XI.S6, 

"Structures 

Monitoring"

No

“Reinfor

concrete

changed 

"Concre

consiste

Chapter 

AMP inc

ground 

monitor

evaluati

from “Ye

III.A1.TP30III.A1-

3(T-08) Concrete: all Concrete Soil Cracking and

distortion due 

XI.S6, 

“Structures 

Yes, if a dewatering 

“Reinfor

concrete
April 2011 II-369 NUREG-1950

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

III.A2.TP30

III.A3.TP30

III.A5.TP30

III.A6.TP30

III.A7.TP30

III.A8.TP30

III.A9.TP30

III.A2-

3(T-08)

III.A3-

3(T-08)

III.A5-

3(T-08)

III.A6-

4(T-08)

III.A7-

2(T-08)

III.A8-

2(T-08)

III.A9-

2(T-08)

to increased 

stress levels 

from 

settlement

Monitoring” 

If a de-watering 

system is relied 

upon for control 

of settlement, 

then the 

licensee is to 

ensure proper 

functioning of 

the de-watering 

system through 

the period of 

extended 

operation. 

system is 

relied upon to 

control 

settlement

changed 

"Concre

consiste

Chapter 

evaluati

required 

de-wate

is relied 

control s

otherwis

evaluati

required 

AMP XI

monitor

for crac

includin

and dist

to increa

levels fr

settleme

III.A1.TP302

III.A2.TP302

III.A3.TP302

III.A4.TP302

III.A5.TP302

III.A7.TP302

III.A8.TPIII.A1-

12(T11)

III.A2-

12(T11)

III.A3-

12(T11)

III.A4-

5(T-11)

III.A5-

12(T11)

Steel 

components: 

all structural 

steel

Steel

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Loss of 

material due 

to corrosion

XI.S6, 

“Structures 

Monitoring” 

If protective 

coatings are 

relied upon to 

manage the 

effects of aging, 

the structures 

monitoring 

program is to 

include 

No

XI.S6, “

Monitor

program 

to requi

monitor

aging ef

mechan

compon

evaluati

required
NUREG-1950 II-370 April 2011

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

302 III.A7-

10(T11)

III.A8-

8(T-11)

provisions to 

address 

protective 

coating 

monitoring and 

maintenance.

III.A1.TP31

III.A2.TP31

III.A3.TP31

III.A5.TP31

III.A6.TP31

III.A7.TP31

III.A8.TP31

III.A9.TP31

III.A1-

8(T-09)

III.A2-

8(T-09)

III.A3-

8(T-09)

III.A5-

8(T-09)

III.A6-

8(T-09)

III.A7-

7(T-09)

III.A8-

7(T-09)

III.A9-

7(T-09)

Concrete: 

foundation; 

subfoundation

Concrete; 

porous 

concrete

Water – 

flowing under 

foundation

Reduction in 

foundation 

strength, 

cracking due 

to differential 

settlement, 

erosion of 

porous 

concrete 

subfoundation

XI.S6, 

“Structures 

Monitoring” 

If a de-watering 

system is relied 

upon for control 

of settlement, 

then the 

licensee is to 

ensure proper 

functioning of 

the de-watering 

system through 

the period of 

extended 

operation. 

Yes, if a dewatering 

system is 

relied upon to 

control 

settlement

Reinforc

concrete 

changed 

"concre

consiste

Chapter 

concrete

incorpo

design o

foundat

of found

included 

scope o

structur

monitor

program

III.A4.TP35

III.A4-

6(T-13)

Sliding 

surfaces: 

radial beam 

seats in 

BWR drywell

Lubrite; 

Fluorogold; 

Lubrofluor

Air – indoor, 

uncontrolled

Loss of 

mechanical 

function due 

to corrosion, 

distortion, 

dirt, 

overload, 

wear

XI.S6, 

"Structures 

Monitoring"

No

Deleted 

support 

PWR w

support

generat

XI.S3 .T

compon

classifie

Class 1 

support
April 2011 II-371 NUREG-1950

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

evaluate

Rev. 1, 

III.B1.1-

added m

were ide

alternat

in previo

III.A6.TP36

III.A6-

5(T-15)

Concrete 

(accessible 

areas): 

exterior 

above- and 

below-grade; 

foundation

Concrete Air – outdoor

Loss of 

material 

(spalling, 

scaling) and 

cracking due 

to freezethaw

XI.S7, “RG

1.127, 

Inspection of 

Water-Control 

Structures 

Associated 

with Nuclear 

Power Plants,” 

or the FERC/ 

US Army Corp 

of Engineers’ 

dam 

inspections 

and 

maintenance 

programs.

No

GALL R

item T-1

differen

between 

and inac

areas. I

of acces

perform

accorda

RG. 1.1

FERC/U

Corp of 

dam ins

and ma

program

indicate 

presenc

materia

scaling) 

cracking 

freeze-t

a furthe

is not re

accessi

"Reinfor
NUREG-1950 II-372 April 2011

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

concrete

changed 

"Concre

consiste

Chapter 

III.A6.TP37

III.A6-

6(T-16)

Concrete 

(accessible 

areas): 

exterior 

above- and 

below-grade; 

foundation; 

interior slab

Concrete Water – 

flowing

Increase in 

porosity and 

permeability; 

loss of 

strength due 

to leaching 

of calcium 

hydroxide 

and 

carbonation

XI.S7, RG

1.127, 

“Inspection of 

Water-Control 

Structures 

Associated 

with Nuclear 

Power Plants,” 

or the FERC / 

US Army Corp 

of Engineers 

dam 

inspections 

and 

maintenance 

programs.

No

GALL R

item T-1

differen

between 

and inac

areas. I

of acces

perform

accorda

RG 1.12

“Inspect

Water-C

Structur

Associa

Nuclear 

Plants,” 

FERC /

Corp of 

dam ins

and ma

program

indicate 

presenc

increase 

permea

leaching 

hydroxid
April 2011 II-373 NUREG-1950

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

carbona

a furthe

is not re

accessi

III.A6.TP38

III.A6-

1(T-18)

Concrete 

(accessible 

areas): all

Concrete

Air – indoor, 

uncontrolled 

or Air – 

outdoor or 

Ground 

water/soil

Cracking; loss 

of bond; and 

loss of 

material 

(spalling, 

scaling) due 

to corrosion 

of embedded 

steel

XI.S7, RG

1.127, 

“Inspection of 

Water-Control 

Structures 

Associated 

with Nuclear 

Power Plants,” 

or the FERC/ 

US Army Corp 

of Engineers 

dam 

inspections 

and 

maintenance 

programs.

No

GALL R

item T-1

differen

between 

and inac

areas. I

of acces

perform

accorda

RG 1.12

“Inspect

Water-C

Structur

Associa

Nuclear 

Plants,” 

FERC /

Corp of 

dam ins

and ma

program

indicate 

presenc

cracking

bond, a

materia

scaling) 

corrosio
NUREG-1950 II-374 April 2011

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

embedd

Thus, a 

evaluati

required

"Reinfor

concrete

changed 

"Concre

consiste

Chapter 

Ground 

environ

applicab

compon

aging ef

mechan

applicab

consiste

212.

III.B1.1.TP41III.B1.1-

3(T-27)

Highstrength 

structural 

bolting

Low-alloy 

steel, 

actual 

measured 

yield 

strength ≥ 

150 ksi 

(1,034 MPa)

Air – indoor, 

uncontrolled 

Cracking due 

to SCC

XI.S3, “ASME 

Section XI, 

Subsection 

IWF”

No

Change

compon

High-str

structur

be more 

and cov

strength 

used fo

Class 1

MC com

support

strength 

bolting w
April 2011 II-375 NUREG-1950

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

scope o

"Bolting 

AMP in 

the GAL

For Rev

GALL, h

strength 

bolting a

with AS

Compon

support

to the sc

XI.S3, "

Section 

Subsec

The IWF 

examina

augmen

require 

examina

high-str

bolting t

cracking 

required 

Bolting 

program 

III.B1.1.TP42

III.B1.2.TP42

III.B1.3.TP42

III.B2.TPIII.B1.1-

1(T-29)

III.B1.2-

1(T-29)

III.B1.3-

1(T-29)

III.B2-

Building 

concrete at 

locations of 

expansion 

and grouted 

anchors; 

Concrete; 

grout

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Reduction in 

concrete 

anchor 

capacity due 

to local 

concrete 

XI.S6, 

"Structures 

Monitoring"

No

The sco

XI.S6, “

Monitor

program 

monitor

compon
NUREG-1950 II-376 April 2011

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

42

III.B3.TP42

III.B4.TP42

III.B5.TP42

1(T-29)

III.B3-

1(T-29)

III.B4-

1(T-29)

III.B5-

1(T-29)

grout pads for 

support base 

plates

degradation/ 

serviceinduced 

cracking or 

other 

concrete 

aging 

mechanisms

further e

not requ

"Reinfor

concrete

changed 

"Concre

consiste

Chapter 

III.B2.TP43

III.B3.TP43

III.B4.TP43

III.B5.TP43

III.B2-

10(T30)

III.B3-

7(T-30)

III.B4-

10(T30)

III.B5-

7(T-30)

Support 

members; 

welds; bolted 

connections; 

support 

anchorage to 

building 

structure

Steel

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Loss of 

material due 

to general 

and pitting 

corrosion

XI.S6, 

"Structures 

Monitoring"

No

The sco

“Structu

Monitor

program 

monitor

compon

further e

not requ

III.B4.TP44

III.B4-

12(T31)

Vibration 

isolation 

elements

Nonmetallic 

(e.g., 

rubber)

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Reduction or 

loss of 

isolation 

function due 

to radiation 

hardening, 

temperature, 

humidity, 

sustained 

vibratory 

loading

XI.S3, “ASME 

Section XI, 

Subsection 

IWF”

No

The sco

“Structu

Monitor

program 

monitor

compon

further e

not requ

III.B1.1.TP45

III.B1.2.TPIII.B1.1-

5(T-32)

III.B1.2-

Sliding 

surfaces

Lubrite®; 

graphitic 

Air – indoor, 

uncontrolled 

Loss of 

mechanical 

XI.S3, “ASME 

Section XI, No Fatigue 

vibrator
April 2011 II-377 NUREG-1950

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

45

III.B1.3.TP45

3(T-32)

III.B1.3-

3(T-32)

tool steel; 

Fluorogold; 

Lubrofluor

or Air –

outdoor

function due 

to corrosion, 

distortion, 

dirt, debris, 

overload, 

wear

Subsection 

IWF”

thermal 

remove

aging ef

mechan

because 

codes d

require 

conside

sliding s

Excessi

debris a

can pre

of the s

required 

Fluorog

Lubroflu

identifie

previous 

as slidin

materia

III.B2.TP46

III.B4.TP46

III.B2-

2(TP-1)

III.B4-

2(TP-1)

Sliding 

support 

bearings; 

sliding 

support 

surfaces

Lubrite®; 

graphitic 

tool steel; 

Fluorogold; 

Lubrofluor

Air – indoor, 

uncontrolled

Loss of 

mechanical 

function due 

to corrosion, 

distortion, 

dirt, debris, 

overload, 

wear

XI.S6, 

"Structures 

Monitoring"

No

Fatigue 

vibrator

thermal 

remove

aging ef

mechan

because 

codes d

require 

conside

sliding s

Excessi
NUREG-1950 II-378 April 2011

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

debris a

can pre

of the s

required 

Fluorog

Lubroflu

identifie

previous 

as slidin

materia

III.B2.TP47

III.B4.TP47

III.B2-

3(TP-2)

III.B4-

3(TP-2)

Sliding 

support 

bearings; 

sliding 

support 

surfaces

Lubrite®; 

graphitic 

tool steel; 

Fluorogold; 

Lubrofluor

Air – outdoor

Loss of 

mechanical 

function due 

to corrosion, 

distortion, 

dirt, debris, 

overload, 

wear

Chapter XI.S6, 

"Structures 

Monitoring"

No

Fatigue 

vibrator

thermal 

remove

aging ef

mechan

because 

codes d

require 

conside

sliding s

Excessi

debris a

can pre

of the s

required 

Fluorog

Lubroflu

identifie

previous 

as slidin

materia
April 2011 II-379 NUREG-1950

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

III.A1.TP67

III.A2.TP67

III.A3.TP67

III.A5.TP67

III.A7.TP67

III.A8.TP67

III.A9.TP67

III.A1-

7(T-02)

III.A2-

7(T-02)

III.A3-

7(T-02)

III.A5-

7(T-02)

III.A7-

6(T-02)

III.A8-

6(T-02)

III.A9-

6(T-02)

Concrete 

(inaccessible 

areas): 

exterior 

above- and 

below-grade; 

foundation

Concrete Water – 

flowing

Increase in 

porosity and 

permeability; 

loss of 

strength due 

to leaching of 

calcium 

hydroxide and 

carbonation

Further 

evaluation is 

required to 

determine if a 

plant-specific 

aging 

management 

program is 

needed to 

manage 

increase in 

porosity, and 

permeability 

due to leaching 

of calcium 

hydroxide and 

carbonation of 

concrete in 

Inaccessible 

Areas. A plantspecific aging 

management 

program is not 

required if (1) 

There is 

evidence in the 

accessible 

areas that the 

flowing water 

has not caused 

leaching and 

carbonation, or 

(2) Evaluation 

Yes, if 

leaching is 

observed in 

accessible 

areas that 

impact 

intended 

function

GALL R

Item T-0

differen

between 

and inac

areas.

ACI 201

develop

some p

construc

plants w

construc

accorda

ACI 318

provided 

requirem

design a

construc

reinforc

structur

included 

water-ce

proporti

aggrega

mixer, m

and tem

durable 

which w

address

201.2R-

concrete 

construc
NUREG-1950 II-380 April 2011

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

determined 

that the 

observed 

leaching of 

calcium 

hydroxide and 

carbonation in 

accessible 

areas has no 

impact on the 

intended 

function of the 

concrete 

structure.

either A

201.2R 

expecte

durable

these st

were us

accessi

inacces

concrete

reasona

conclud

leaching 

hydroxid

carbona

accessi

subject 

water in

areas.

III.B1.1.TP8 

 

III.B1.2.TP8 

 

III.B1.3.TP8 

 

III.B1.1-

6 (TP-8)

III.B1.1-

7(TP11) 

III.B1.1-

9(TP-5)

III.B1.2-

4(TP-8)

III.B1.2-

5(TP11)

III.B1.2-

7(TP-5)

III.B1.3-

4(TP-8)

III.B1.3-

5(TPSupport 

members; 

welds; bolted 

connections; 

support 

anchorage to 

building 

structure

Aluminum; 

galvanized 

steel; 

stainless 

steel

Air – indoor, 

uncontrolled None None No

TP-5 fo

steel an

galvaniz

were de

the mat

combine

8, alum
April 2011 II-381 NUREG-1950

Table II-12. Changes to Existing GALL Report Rev. 1 Chapter III AMR Items for Structures and Compone

Their Technical Bases (cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item No.

Rev. 1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management 

Program

Further 

Evaluation 

Required

Techn

for C

III.B2.TP-8

III.B3.TP-8 

III.B4.TP-8 

III.B5.TP-8 

11) 

III.B1.3-

7(TP-5)

III.B2-

4(TP-8) 

III.B2-

5(TP11)

III.B2-

8(TP-5)

III.B3-

2(TP-8) 

III.V3-

3(TP11)

III.B3-

5(TP-5)

III.B4-

4(TP-8) 

III.B4-

5(TP11)

III.B4-

8(TP-5)

III.B5-

2(TP-8) 

III.B5-

3(TP11)

III.B5-

5(TP-5)
NUREG-1950 II-382 April 2011

Table II-13. Changes to Existing GALL Report Rev. 1 Chapter VI AMR Items for Electrical Systems and T

(cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management

Program

Further 

Evaluation 

Required

VI.A.LP23

VI.A8(LP01)

Fuse holders 

(not part of 

active 

equipment): 

metallic clamps

Various 

metals used 

for electrical 

connections

Air – indoor, 

uncontrolled

Increased resistance 

of connection 

due to chemical 

contamination, 

corrosion, and 

oxidation (in an air, 

indoor controlled 

environment, 

increased resistance 

of connection due to 

chemical 

contamination, 

corrosion and 

oxidation do not 

apply); 

fatigue 

due to ohmic 

heating, thermal 

cycling, electrical 

transients

XI.E5, "Fuse 

Holders" No
April 2011 II-383 NUREG-1950

Table II-13. Changes to Existing GALL Report Rev. 1 Chapter VI AMR Items for Electrical Systems and T

(cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management

Program

Further 

Evaluation 

Required
NUREG-1950 II-384 April 2011

Table II-13. Changes to Existing GALL Report Rev. 1 Chapter VI AMR Items for Electrical Systems and T

(cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management

Program

Further 

Evaluation 

Required

VI.A.LP24

VI.A7(LP02)

Fuse holders 

(not part of 

active 

equipment): 

insulation 

material

Insulation 

material: 

bakelite; 

phenolic 

melamine or 

ceramic; 

molded 

polycarbonate; 

other

Air – indoor, 

controlled or 

uncontrolled

None None No
April 2011 II-385 NUREG-1950

Table II-13. Changes to Existing GALL Report Rev. 1 Chapter VI AMR Items for Electrical Systems and T

(cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management

Program

Further 

Evaluation 

Required

VI.A.LP25

VI.A11(LP04)

Metal enclosed 

bus (MEB): 

bus/connections

Various 

metals used 

for electrical 

bus and 

connections

Air – indoor, 

controlled or 

uncontrolled 

or Air – 

outdoor

Increased resistance 

of connection due to 

the loosening of 

bolts caused by 

thermal cycling and 

ohmic heating

XI.E4, "Metal 

Enclosed Bus" No
NUREG-1950 II-386 April 2011

Table II-13. Changes to Existing GALL Report Rev. 1 Chapter VI AMR Items for Electrical Systems and T

(cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management

Program

Further 

Evaluation 

Required

VI.A.LP26

VI.A14(LP05)

Metal enclosed 

bus: insulation; 

insulators

Porcelain; 

xenoy; thermoplastic organic 

polymers

Air – indoor, 

controlled or 

uncontrolled 

or Air – 

outdoor

Reduced insulation

resistance due to 

thermal/thermoxidati

ve degradation of 

organics/thermoplas

tics, radiationinduced oxidation, 

moisture/debris 

intrusion, and ohmic 

heating

XI.E4, "Metal 

Enclosed Bus" No
April 2011 II-387 NUREG-1950

Table II-13. Changes to Existing GALL Report Rev. 1 Chapter VI AMR Items for Electrical Systems and T

(cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management

Program

Further 

Evaluation 

Required
NUREG-1950 II-388 April 2011

Table II-13. Changes to Existing GALL Report Rev. 1 Chapter VI AMR Items for Electrical Systems and T

(cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management

Program

Further 

Evaluation 

Required

VI.A.LP28

VI.A9(LP07) High-voltage 

insulators

Porcelain;

malleable iron; 

aluminum; 

galvanized 

steel; cement

Air – outdoor

Reduced insulation 

resistance due to 

presence of salt 

deposits or surface 

contamination

A plant-specific 

aging 

management 

program is to 

be evaluated for 

plants located 

such that the 

potential exists 

for salt deposits 

or surface 

contamination 

(e.g., in the 

vicinity of salt 

water bodies or 

industrial 

pollution)

Yes, plantspecific

VI.A.LP29

VI.A12(LP10)

Metal enclosed 

bus: enclosure 

assemblies

Elastomers

Air – indoor, 

controlled or 

uncontrolled 

or Air – 

outdoor

Surface cracking, 

crazing, scuffing, 

dimensional change 

(e.g., “ballooning” 

and “necking”), 

shrinkage, 

discoloration, 

hardening and loss 

of strength due to 

elastomer 

degradation

XI.E4, "Metal 

Enclosed 

Bus," or 

XI.M38, 

"Inspection of 

Internal 

Surfaces in 

Miscellaneous 

Piping and 

Ducting 

Components"

No
April 2011 II-389 NUREG-1950

Table II-13. Changes to Existing GALL Report Rev. 1 Chapter VI AMR Items for Electrical Systems and T

(cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management

Program

Further 

Evaluation 

Required

VI.A.LP30

VI.A1(LP12)

Cable 

connections 

(metallic parts)

Various metals 

used for 

electrical 

contacts

Air – indoor, 

controlled or 

uncontrolled 

or Air – 

outdoor

Increased resistance 

of connection due to 

thermal cycling, 

ohmic heating, 

electrical transients, 

vibration, chemical 

contamination, 

XI.E6, 

"Electrical 

Cable 

Connections 

Not Subject to 

10 CFR 50.49 

Environmental 

No
NUREG-1950 II-390 April 2011

Table II-13. Changes to Existing GALL Report Rev. 1 Chapter VI AMR Items for Electrical Systems and T

(cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management

Program

Further 

Evaluation 

Required

corrosion, and 

oxidation

Qualification 

Requirements"

VI.A.LP31

VI.A8(LP01)

Fuse holders 

(not part of 

active 

equipment): 

metallic clamps

Various 

metals used 

for electrical 

connections

Air – indoor, 

controlled or 

uncontrolled

Increased resistance 

of connection due to 

fatigue caused by 

frequent 

manipulation or 

vibration

XI.E5, "Fuse 

Holders" 

No aging 

management 

program is 

required for 

those 

applicants 

No
April 2011 II-391 NUREG-1950

Table II-13. Changes to Existing GALL Report Rev. 1 Chapter VI AMR Items for Electrical Systems and T

(cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management

Program

Further 

Evaluation 

Required

who can 

demonstrate 

these fuse 

holders are 

located in an 

environment 

that does not 

subject them 

to 

environmental 

aging 

mechanisms 

or fatigue 

caused by 

frequent 

manipulation 

or vibration

VI.A.LP32

VI.A10(LP11)

High-voltage 

insulators

Porcelain; 

malleable iron; 

aluminum; 

galvanized 

steel; cement

Air – outdoor

Loss of material due 

to mechanical wear 

caused by wind 

blowing on 

transmission 

conductors

A plant-specific 

aging 

management 

program is to 

be evaluated

Yes, plantspecific

VI.A.LP33

VI.A2(L01)

Insulation 

material for 

electrical 

cables and 

connections 

(including 

terminal blocks, 

Various 

organic 

polymers (e.g., 

ethylenepropylene 

rubber (EPR), 

silicon rubber 

Adverse 

localized 

environment 

caused by 

heat, 

radiation, or 

moisture

Reduced insulation 

resistance due to 

thermal/thermoxidati

ve degradation of 

organics, radiolysis, 

and photolysis (UV 

sensitive materials 

XI.E1, 

"Insulation 

Material for 

Electrical 

Cables and 

Connections 

Not Subject to 

No
NUREG-1950 II-392 April 2011

Table II-13. Changes to Existing GALL Report Rev. 1 Chapter VI AMR Items for Electrical Systems and T

(cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management

Program

Further 

Evaluation 

Required

fuse holders, 

etc.)

(SR), 

ethylenepropylene

diene 

monomer

(EPDM), 

cross-linked 

polyethylene 

(XLPE)

only) of organics; 

radiation-induced 

oxidation; 

moisture intrusion

10 CFR 50.49 

Environmental 

Qualification 

Requirements
April 2011 II-393 NUREG-1950

Table II-13. Changes to Existing GALL Report Rev. 1 Chapter VI AMR Items for Electrical Systems and T

(cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management

Program

Further 

Evaluation 

Required
NUREG-1950 II-394 April 2011

Table II-13. Changes to Existing GALL Report Rev. 1 Chapter VI AMR Items for Electrical Systems and T

(cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management

Program

Further 

Evaluation 

Required

VI.A.LP34

VI.A3(L02)

Insulation 

material for 

electrical 

cables and 

connections 

used in 

instrumentation 

circuits that are 

sensitive to 

reduction in 

conductor 

insulation 

resistance (IR)

Various 

organic 

polymers (e.g., 

EPR, SR, 

EPDM, XLPE)

Adverse 

localized 

environment 

caused by 

heat, 

radiation, or 

moisture

Reduced insulation 

resistance 

due to 

thermal/thermoxidati

ve degradation of 

organics, radiolysis, 

and photolysis (UV 

sensitive materials 

only) of organics; 

radiation-induced 

oxidation; 

moisture intrusion

XI.E2, 

"Insulation 

Material for 

Electrical 

Cables and 

Connections 

Not Subject to 

10 CFR 50.49 

Environmental 

Qualification 

Requirements 

Used in 

Instrumentatio

n Circuits"

No
April 2011 II-395 NUREG-1950

Table II-13. Changes to Existing GALL Report Rev. 1 Chapter VI AMR Items for Electrical Systems and T

(cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management

Program

Further 

Evaluation 

Required

VI.A.LP35

VI.A4(L03)

Conductor 

insulation for 

inaccessible 

Various 

organic 

polymers (e.g., 

Adverse 

localized 

environment 

Reduced insulation 

resistance due to 

moisture

XI.E3, 

"Inaccessible 

Power Cables 

No
NUREG-1950 II-396 April 2011

Table II-13. Changes to Existing GALL Report Rev. 1 Chapter VI AMR Items for Electrical Systems and T

(cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management

Program

Further 

Evaluation 

Required

power cables 

greater than or 

equal to 400 

volts 

(e.g., installed 

in conduit or 

direct buried)

EPR, SR, 

EPDM, XLPE)

caused by 

significant 

moisture

Not Subject to 

10 CFR 50.49 

Environmental 

Qualification 

Requirements"
April 2011 II-397 NUREG-1950

Table II-13. Changes to Existing GALL Report Rev. 1 Chapter VI AMR Items for Electrical Systems and T

(cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management

Program

Further 

Evaluation 

Required

VI.A.LP36

VI.A5(L04)

Connector 

contacts for 

electrical 

connectors 

exposed to 

Various metals 

used for 

electrical 

contacts

Air with 

borated water 

leakage

Increased resistance 

of connection 

due to corrosion of 

connector contact 

surfaces caused by 

XI.M10, “Boric 

Acid Corrosion” No
NUREG-1950 II-398 April 2011

Table II-13. Changes to Existing GALL Report Rev. 1 Chapter VI AMR Items for Electrical Systems and T

(cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management

Program

Further 

Evaluation 

Required

borated water 

leakage

intrusion of borated 

water

VI.A.LP38

VI.A16(LP08)

Transmission 

conductors

Aluminum; 

steel Air – outdoor

Loss of conductor 

strength due to 

corrosion

A plantspecific aging 

management 

program is to 

be evaluated 

for Aluminum

Conductor 

Steel 

Reinforced

Yes, plantspecific
April 2011 II-399 NUREG-1950

Table II-13. Changes to Existing GALL Report Rev. 1 Chapter VI AMR Items for Electrical Systems and T

(cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management

Program

Further 

Evaluation 

Required

(ACSR) 

VI.A.LP39

VI.A15(LP09)

Switchyard bus 

and connections

Aluminum; 

copper; 

bronze; 

stainless steel; 

galvanized 

steel

Air – outdoor

Loss of material due 

to wind-induced 

abrasion; 

Increased resistance 

of connection due to 

oxidation or loss of 

pre-load

A plant-specific 

aging 

management 

program is to 

be evaluated

Yes, plantspecific
NUREG-1950 II-400 April 2011

Table II-13. Changes to Existing GALL Report Rev. 1 Chapter VI AMR Items for Electrical Systems and T

(cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management

Program

Further 

Evaluation 

Required

VI.A.LP41

VI.A13(LP06)

Metal enclosed 

bus: external 

surface of 

enclosure 

assemblies

Galvanized 

steel; 

aluminum

Air – indoor, 

controlled or 

uncontrolled

None None No

VI.A.LP42

VI.A13(LP06)

Metal enclosed 

bus: external 

surface of 

enclosure 

assemblies

Galvanized 

steel; 

aluminum

Air – 

outdoor

Loss of material due 

to pitting and 

crevice corrosion

XI.E4, "Metal 

Enclosed 

Bus," or 

XI.S6, 

"Structures 

Monitoring"

No
April 2011 II-401 NUREG-1950

Table II-13. Changes to Existing GALL Report Rev. 1 Chapter VI AMR Items for Electrical Systems and T

(cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management

Program

Further 

Evaluation 

Required

VI.A.LP43

VI.A13(LP06)

Metal enclosed 

bus: external 

surface of 

enclosure 

assemblies

Steel

Air – indoor, 

uncontrolled 

or Air – 

outdoor

Loss of material due 

to general, pitting, 

and crevice 

corrosion

XI.E4, "Metal 

Enclosed 

Bus," or 

XI.S6, 

"Structures 

Monitoring"

No
NUREG-1950 II-402 April 2011

Table II-13. Changes to Existing GALL Report Rev. 1 Chapter VI AMR Items for Electrical Systems and T

(cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management

Program

Further 

Evaluation 

Required

VI.A.LP44

VI.A13(LP06)

Metal enclosed 

bus: external 

surface of 

enclosure 

assemblies

Steel Air – indoor, 

controlled None None No

VI.A.LP46

VI.A16(LP08)

Transmission 

conductors Aluminum Air – outdoor

Loss of conductor 

strength due to 

corrosion

None - for 

Aluminum 

Conductor 

Aluminum 

Alloy 

Reinforced 

(ACAR)

None

VI.A.LP47

VI.A16(LP08)

Transmission 

conductors

Aluminum; 

Steel Air – outdoor

Loss of material due 

to wind-induced 

abrasion

A plantspecific aging 

management 

program is to 

be evaluated 

for ACAR and 

ACSR

Yes, plantspecific

VI.A.LP48

VI.A16(LPTransmission 

connectors

Aluminum; 

steel Air – outdoor Increased resistance 

of connection 

A plant-specific 

aging 

Yes, plantspecific
April 2011 II-403 NUREG-1950

Table II-13. Changes to Existing GALL Report Rev. 1 Chapter VI AMR Items for Electrical Systems and T

(cells where changes have been made are shown in bold)

Rev. 2 

AMR 

Item 

No.

Rev. 

1 

AMR 

Link

Structures 

and/or 

Components

Material Environment Aging Effect/ 

Mechanism

Aging 

Management

Program

Further 

Evaluation 

Required

08) due to oxidation or 

loss of pre-load

management 

program is to 

be evaluated
NUREG-1950 II-404 April 2011

Table II-14. Chapter IX.B - Revision 2 Differences from Chapter IX, GALL Report, Rev. 1 and Their Techn

Defined Term Summary of Significant Changes Technical Basis for Change 

Existing programs

Added the following definition for “Existing 

programs” components: 

Per EPRI MRP-227 guidance on inspection and 

evaluation, PWR vessel internals (AMP XI.M16A) 

were assigned to one of the following four groups: 

Primary, Expansion, Existing Programs, and No 

Additional Measures. 

“Existing Programs” components are those PWR 

internals that are susceptible to the effects of at 

least one of the aging mechanisms addressed by 

MRP-227 and for which generic and plant-specific 

existing AMP elements are capable of managing 

those effects (See MRP-227, Section 3.3)

This term is consistent with the definition as 

in EPRI MRP-227, Revision 0, Section 3.3.1

Expansion components

Added the following definition for “Expansion” 

components:

Per EPRI MRP-227 guidance on inspection and 

evaluation, PWR vessel internals (AMP XI.M16A) 

were assigned to one of the following four groups: 

Primary, Expansion, Existing Programs, and No 

Additional Measures. 

“Expansion” components are those PWR internals 

that are highly or moderately susceptible to the 

effects of at least one of the aging mechanisms 

addressed by MRP-227, but for which functionality 

assessment has shown a degree of tolerance to 

those effects. (See MRP-227, Section 3.3)

This term is consistent with the definition as 

in EPRI MRP-227, Revision 0, Section 3.3.1
April 2011 II-405 NUREG-1950

Table II-14. Chapter IX.B - Revision 2 Differences from Chapter IX, GALL Report, Rev. 1 and Their Techn

Defined Term Summary of Significant Changes Technical Basis for Change 

No Additional 

Measures

A new definition was added for “No Additional 

Measures” components:

Per EPRI MRP-227 guidance on inspection and 

evaluation, PWR vessel internals (AMP XI.M16A) 

were assigned to one of the following four groups: 

Primary, Expansion, Existing Programs, and No 

Additional Measures. Additional components were 

placed in the “No Additional Measures,” group as a 

result of the Failure Mode, Effects, and Criticality 

Analysis and the functionality assessment.

“No Additional Measures” encompasses those 

PWR internals for which the effects of all aging 

mechanisms addressed by MRP-227 (Section 3.3)

are below the screening criteria. Since no further 

action is required by MRP-227 guidelines for 

managing the aging of the “No Additional 

Measures” components, there are no 

corresponding AMR items.

This term is consistent with the definition as 

in EPRI MRP-227, Revision 0, Section 3.3.1

Primary components

A new definition was added for “Primary” 

components:

Per EPRI MRP-227 guidance on inspection and 

evaluation, PWR vessel internals (GALL AMP 

XI.M16A) were assigned to one of the following 

four groups: Primary, Expansion, Existing 

Programs, and No Additional Measures. 

Primary components are those PWR internals that 

are highly susceptible to the effects of at least one 

of the aging mechanisms addressed by MRP-227. 

The Primary group also includes components 

which have shown a degree of tolerance to a 

specific aging degradation effect, but for which no 

highly susceptible component exists or for which no 

highly susceptible component is accessible.

This term is consistent with the definition as 

in EPRI MRP-227, Revision 0, Section 3.3.1
NUREG-1950 II-406 April 2011

Table II-15. Chapter IX.C - Revision 2 Differences from Chapter IX, GALL Report, Rev. 1 and Their Techn

Defined Term Summary of Significant Changes Technical Basis for Change 

Boral, boron steel

The definition of "boral, boron steel" was amended 

to define boron steel as having "boron, with a 

content ranging from one to several percent

Although “boron steel” may, in general, inclu

steel alloy with as little as 0.05 percent boron 

added, the boron steel typically used in spen

pools has boron content in the range of one 

several percent.

Copper alloys The term "Copper alloy <15% Zn" was revised to 

state "Copper alloy (≤15% Zn and ≤8% Al)"

Copper alloys could include zinc or aluminum 

alloy. Also, the definition includes aluminum. 

Galvanized steel

The definition of "galvanized steel" had this 

sentence added to its definition: "In the presence of 

moisture, galvanized steel is classified under the 

category “Steel.”

When moisture is present, galvanized steel c

have an aging effect of loss of material, in wh

case it behaves like steel.

Gray cast iron

The definition of "gray cast iron" had this sentence 

added to its definition: "In the presence of moisture, 

gray cast iron is classified under the category 

“Steel.”

In an environment where gray cast iron is 

susceptible to selective leaching, it is listed 

separately. Otherwise, gray cast iron is inclu

the definition of steel.

Low-alloy steel, yield 

strength > 150ksi

The definition of "low-alloy steel, yield strength > 

150ksi" had this added to its definition:

"Low-alloy steel bolting material, SA 193 Gr. B7, is 

a ferritic, low-alloy steel for high-temperature 

service. High-strength low-alloy (Fe-Cr-Ni-Mo) steel 

bolting materials have a maximum tensile strength 

of <1172 MPa (<170 ksi). They may be subject to 

SCC if the actual measured yield strength, Sy, ≥ 

150 ksi (1034 MPa)."

This change provides clarification with regard 

recommended values for maximum tensile s

and maximum actual measured yield strengt

is consistent with the staff’s NRC position sta

page 13 of NUREG-1339, “Resolution of Ge

Safety Issue 29: Bolting Degradation or Failu

Nuclear Power

Plants.”

Polymers used in 

electrical applications

The following term was modified: "Polymers used 

in electrical applications"

Its definition is: "Polymers used in electrical 

applications include EPR, SR, EPDM, and XLPE. 

XLPE is a cross-linked polyethylene thermoplastic 

resin, such as polyethylene and polyethylene 

copolymers. EPR and EPDM are ethylenepropylene rubbers in the category of thermosetting 

The “"Polymers used in electrical application

simplified to provide clarification. Changed 

“...cross-linked polyethylene in the category 

thermoplastic resins as polyethylene and 

polyethylene copolymers...” to “...cross-linke

polyethylene thermoplastic resin, such as 

polyethylene and polyethylene copolymers...
April 2011 II-407 NUREG-1950

Table II-15. Chapter IX.C - Revision 2 Differences from Chapter IX, GALL Report, Rev. 1 and Their Techn

Defined Term Summary of Significant Changes Technical Basis for Change 

elastomers."

Porcelain

The following term was modified: "Porcelain"

Its definition is: "Hard-quality porcelain is used as 

an insulator for supporting high-voltage electrical 

insulators. Porcelain is a hard, fine-grained ceramic 

that consists of kaolin, quartz, and feldspar fired at 

high temperatures."

The term “Porcelain” was simplified to provid

clarification. Deleted the word “essentially,” w

was between the words “that” and “consists 

Superaustenitic 

stainless steel

The following term was added: "Superaustenitic 

stainless steel"

Its definition states: "Superaustenitic stainless 

steels have the same structure as the common 

austenitic alloys, but they have enhanced levels of 

elements such as chromium, nickel, molybdenum, 

copper, and nitrogen, which give them superior 

strength and corrosion resistance. Compared to 

conventional austenitic stainless steels, 

Superaustenitic materials have a superior 

resistance to pitting and crevice corrosion in 

environments containing halides. Several NPPs 

have installed superaustenitic stainless steel (AL6XN) buried piping."

Super austenitic stainless steel was added to 

XI.M41, "Buried and Underground Piping and 

Tanks," and a definition was added to identif

material.

Titanium

The following term was added: "Titanium"

Its definition states: "The category titanium includes 

unalloyed titanium (ASTM grades 1-4) and various 

related alloys (ASTM grades 5, 7. 9, and 12). The 

corrosion resistance of titanium is a result of the 

formation of a continuous, stable, highly adherent 

protective oxide layer on the metal surface. 

Titanium and titanium alloys may be susceptible to 

crevice corrosion in saltwater environments at 

elevated temperatures (>160°F). Titanium Grades 

5 and 12 are resistant to crevice corrosion in 

seawater at temperatures as high as 500 oF. SCC

Titanium was added to the XI.M41, "Buried a

Underground Piping and Tanks," and a defin

was added to identify this material.
NUREG-1950 II-408 April 2011

Table II-15. Chapter IX.C - Revision 2 Differences from Chapter IX, GALL Report, Rev. 1 and Their Techn

Defined Term Summary of Significant Changes Technical Basis for Change 

of titanium and its alloys is considered applicable in 

sea water or brackish raw water systems if the 

titanium alloy contains more than 5% aluminum or 

more than 0.20% oxygen or any amount of tin. 

ASTM Grades 1, 2, 7, 11, or 12 are not susceptible 

to SCC in seawater or brackish raw water."

Wood

The following term was added: "Wood"

Its definition states: "Wood piles or sheeting 

exposed to flowing or standing water is subject to 

loss of material or changes in material properties 

due to weathering, chemical degradation, insect 

infestation, repeated wetting and drying, or fungal 

decay."

Several LRAs have included “wood” as a ma

of construction for in-scope structures. This c

provides a definition for the material.
April 2011 II-409 NUREG-1950

Table II-16. Chapter IX.D - Revision 2 Differences from Chapter IX, GALL Report, Rev. 1 and Their Techn

Defined Term Summary of Significant Changes Technical Basis for Change 

Adverse localized 

environment

“Adverse localized environment” definition was 

modified to include: “An adverse localized 

environment is an environment limited to the 

immediate vicinity of a component that is hostile to 

the component material, thereby leading to 

potential aging effects.”

The definition also was modified to read: “As 

represented by a specific GALL AMR line item, an 

adverse localized environment can be due to any 

of the following: (1) exposure to significant moisture 

(LP-35) (2) heat, radiation, or moisture (LP-33 or 

LP-34), or (3) heat, radiation, moisture, or voltage 

(L-05).”

Provides appropriate words to define advers

localized environment and the most limiting 

parameter in its boundary envelope. The env

of the adverse environment for the compone

material is determined and bounded by that 

component material's most limiting paramete

specification (heat, radiation or moisture).

Buried and 

underground 

Added this definition consistent with the resolution 

of the scope of the buried components AMP. 

There was no previous definition for buried a

underground. Made definition consistent with 

resolution of the scope of the buried compon

AMP.

Degradation of 

insulator quality This term was deleted.

The term "reduced insulation resistance" mo

accurately defines the aging effect associate

high-voltage insulators. "Reduced insulation 

resistance" is also defined in GALL Table IX

thereby allowing “degradation of insulator qu

to be deleted.

Raw water

Raw water consists of untreated surface or ground 

water, whether fresh, brackish, or saline in nature. 

This includes water for use in open-cycle cooling 

water systems and may include potable water, 

water that is used for drinking or other personal 

use. See also “condensation.”

Revised the definition of raw water to include 

water used in open-cycle cooling water syste

Treated water

The definition of “treated water” was expanded to 

include demineralized water, whose chemistry has 

been altered and is maintained in a state which is 

the base water for all clean systems. 

The previous definition of treated water was 

expanded to include both reactor water and 

water, such as closed cycle cooling water, th

require additional processing to maintain 
NUREG-1950 II-410 April 2011

Table II-16. Chapter IX.D - Revision 2 Differences from Chapter IX, GALL Report, Rev. 1 and Their Techn

Defined Term Summary of Significant Changes Technical Basis for Change 

Treated water generally falls into one of two 

categories. 

(1) The first category is based on demineralized 

water. This water is generally characterized by high 

purity, low conductivity, and very low oxygen 

content. This category of treated water is generally 

used as BWR coolant and PWR primary and 

secondary water. PWR primary water also contains 

boron, a recognized corrosion inhibitor.

(2) The second category may require additional 

processing. This category of treated water is 

generally used in HVAC systems, auxiliary boilers 

and diesel engine cooling systems. Closed-cycle 

cooling water is a subset of this category of treated 

water

appropriate water chemistry.

Waste water

Radioactive, potentially radioactive, or nonradioactive waters that are collected from 

equipment and floor drains. Waste waters may 

contain contaminants, including oil and boric acid, 

depending on location, as well as originally treated 

water that is not monitored by a chemistry program.

Create a new definition for waste water that 

includes radioactive, potentially radioactive, 

radioactive waters that are collected from 

equipment and floor drains. (This was includ

raw water definition in the GALL Report, Rev
April 2011 II-411 NUREG-1950

Table II-17. Chapter IX.E - Revision 2 Differences from Chapter IX, GALL Report, Rev. 1 and Their Techn

Defined Term Summary of Significant Changes Technical Basis for Change 

Increased resistance of 

connection

The definition of "Increased resistance of 

connection" has been deleted and replaced 

with: "Increased resistance of connection in 

electrical transmission conductors due to the 

loosening of bolted bus duct connections can 

be caused by thermal cycling and ohmic 

heating. A connection can exhibit increased 

resistance due to chemical contamination, 

corrosion, and oxidation or fatigue caused by 

ohmic heating, thermal cycling, electrical 

transients, frequent manipulation, or vibration.

The changes are consistent with the following GAL

Chapter VI AMR Line Items “Aging Effects” and 

Mechanisms:

The term “increased resistance of connection” mo

accurately describes the actual aging effect resulti

from:

• thermal cycling and ohmic heating; the aging 

effects apply to both controlled and uncontrolle

(LP-25)

• chemical contamination, corrosion, and oxidatio

Chemical contamination, corrosion, and oxidati

do not cause fatigue. Ohmic heating, thermal 

cycling, electrical transients, frequent manipula

or vibration are aging mechanisms that may ca

fatigue (LP-23)

• frequent manipulation or vibration if the metallic 

clamps of the fuseholders are located in an airindoor controlled or uncontrolled environment (

31) or

• association with connector contacts exposed to 

borated water (LP-36)

Loosening of bolted 

connections This term was deleted.

The term "increased connection resistance" more 

accurately describes the actual aging effect resulti

from a loosening of cable connections. "Increased 

resistance of connection" is also defined in GALL 

Table IX.E, thereby allowing “loosening of bolted 

connections” to be deleted. 

Reduced insulation 

resistance

The changes are consistent with the following 

GALL Chapter VI AMR Items "Aging Effects" 

and Mechanisms.

The term "Reduction of insulation resistance" 

has been added, with the following 

definitions: 

The changes are consistent with the following GAL

Chapter VI AMR Line Items "Aging Effects" and 

Mechanisms.

The term "Reduction of insulation resistance" has 

been added. Reduced insulation resistance may b

due to: 
NUREG-1950 II-412 April 2011

Table II-17. Chapter IX.E - Revision 2 Differences from Chapter IX, GALL Report, Rev. 1 and Their Techn

Defined Term Summary of Significant Changes Technical Basis for Change 

- Reduced insulation resistance due to the 

presence of salt deposits or surface 

contamination (LP-28). This aging 

mechanism (presence of salt deposits or 

surface contamination) may be due to 

temporary, transient environmental 

conditions; the net result may be long-lasting 

and cumulative.

• Reduced insulation resistance also may be 

due to thermal/thermoxidative degradation 

of organics, radiolysis and photolysis (UV 

sensitive materials only) of organics; 

radiation-induced oxidation, and moisture 

intrusion (LP-33 and LP-34). The term 

"embrittlement, cracking, melting, 

discoloration, swelling, or loss of dielectric 

strength leading to reduced insulation 

resistance; electrical failure" should be 

consolidated into the actual aging effect 

reduced insulation resistance for better 

technical clarity. Reduced insulation 

resistance accurately defines the aging 

effect associated with cable and 

connection insulation materials. Electrical 

failure is a loss of intended function 

potentially caused by an aging effect. It is 

not an aging effect and is not a term 

defined in GALL Table IX.E.

• Reduced insulation resistance may also be 

due to thermal/thermoxidative degradation 

of organics/thermoplastics, radiationinduced oxidation, moisture/debris 

intrusion, and ohmic heating (LP-26). The 

term embrittlement, cracking, melting, 

discoloration, swelling, or loss of dielectric 

- the presence of salt deposits or surface 

contamination (LP-28). This aging mechanism 

(presence of salt deposits or surface contaminatio

may be due to temporary, transient environmental 

conditions, the net result may be long-lasting and 

cumulative.

• thermal/thermoxidative degradation of organics

radiolysis and photolysis (UV sensitive material

only) of organics; radiation-induced oxidation, a

moisture intrusion (LP-33 and LP-34). The term 

"embrittlement, cracking, melting, discoloration

swelling, or loss of dielectric strength leading to 

reduced insulation resistance; electrical failure" 

should be consolidated into the actual aging eff

reduced insulation resistance for better technica

clarity. Reduced insulation resistance accuratel

defines the aging effect associated with cable a

connection insulation materials. Electrical failur

a loss of intended function potentially caused b

aging effect. It is not an aging effect and is not 

term defined in GALL Table IX.E.

• thermal/thermoxidative degradation of 

organics/thermoplastics, radiation-induced 

oxidation, moisture/debris intrusion, and ohmic 

heating (LP-26). The terms embrittlement, 

cracking, melting, discoloration, swelling, or los

dielectric strength leading to reduced insulation 

resistance; electrical failure should be consolida

into the actual aging effect reduced insulation 

resistance for better technical clarity. Reduced 

insulation resistance accurately defines the agi

effect associated with MEB insulation and 

insulators.

• moisture (LP-35). To accurately define the agin

effect associated with wetted power cables 
April 2011 II-413 NUREG-1950

Table II-17. Chapter IX.E - Revision 2 Differences from Chapter IX, GALL Report, Rev. 1 and Their Techn

Defined Term Summary of Significant Changes Technical Basis for Change 

strength leading to reduced insulation 

resistance; electrical failure should be 

consolidated into the actual aging effect 

reduced insulation resistance for better 

technical clarity. Reduced insulation 

resistance accurately defines the aging 

effect associated with MEB insulation and 

insulators.

• Reduced insulation resistance may be 

due to moisture (LP-35). To accurately 

define the aging effect associated with 

wetted power cables associated with 

power cables greater than or equal to 400

volts in accordance with GL 2007 

Summary Report - Dated November 12, 

2008.

associated with power cables greater than or e

to 400 volts in accordance with GL 2007 Summ

Report - Dated November 12, 2008.
NUREG-1950 II-414 April 2011

Table II-18. Chapter IX.F - Revision 2 Differences from Chapter IX, GALL Report, Rev. 1 and Their Techni

Defined Term Summary of Significant Changes Technical Basis for Change L

Aggressive chemical 

attack

The definition of "Aggressive chemical attack" 

has been clarified to refer to "concrete"

Aggressive chemical attack was added to the 

GALL Report as an age related degradation 

that could occur for concrete structures, and a 

definition for aggressive chemical attack was 

added specifically for concrete.

N/

Chemical 

contamination

The definition of "Chemical contamination" 

has been replaced with: "Presence of 

chemicals that do not occur under normal 

conditions at concentrations that could result 

in the degradation of the component."

The previous definition addressed the effect 

of chemical contamination. This change 

provides a more appropriate definition of 

“chemical contamination.”

N/

Elevated Temperature

The definition of "Elevated temperature" has 

been clarified to state: "Elevated temperature 

is referenced as an aging mechanism only in 

the context of LWR containments (GALL 

Chapter II)."

If light water reactor containments are 

exposed to elevated temperatures for 

extended periods of time, the concrete 

containment can undergo age related 

degradation, and the definition of elevated 

temperature had to be specified.

N/

Low-temperature crack 

propagation

The term "Low-temperature crack 

propagation" has been added and defined as: 

"Low-temperature crack propagation (LTCP) 

is IGSCC at low temperatures (~130-170o F)."

Low-temperature crack propagation was 

added to the GALL Report for intergranular 

stress corrosion cracking (IGSCC) at 

temperatures lower than previously was 

thought to initiate IGSCC.

N/

Outer diameter stress 

corrosion cracking 

(ODSCC)

The definition of "Outer diameter stress 

corrosion cracking (ODSCC)" has been 

modified to state: "ODSCC is SCC initiating in 

the outer diameter (secondary side) surface 

of steam generator tubes. The secondary 

side is part of the secondary system 

consisting of the shell side of the steam 

generator, high and low pressure turbines, 

moisture/separator reheaters, main electrical 

stages and interconnecting piping. 

This differs from PWSCC, which describes 

This change provides clarification by drawing 

a more detailed distinction between the 

secondary side of the steam generator, where 

ODSCC occurs, and the primary side of the 

steam generator where PWSCC occurs.

N/
April 2011 II-415 NUREG-1950

Table II-18. Chapter IX.F - Revision 2 Differences from Chapter IX, GALL Report, Rev. 1 and Their Techni

Defined Term Summary of Significant Changes Technical Basis for Change L

inner diameter (SG primary side) initiated 

cracking. The primary loop basically consists 

of the reactor vessel, reactor coolant pumps, 

pressurizer steam generator tubes, and 

interconnecting piping."

Stress corrosion 

cracking (SCC)

The definition of " SCC" has been replaced by 

"SCC is the cracking of a metal produced by 

the combined action of corrosion and tensile 

stress (applied or residual), especially at 

elevated temperature. SCC is highly 

chemically specific in that certain alloys are 

likely to undergo SCC only when exposed to 

a small number of chemical environments. 

For PWR internal components, in Chapters 

IV.B2, IV.B3 and IV.B4, SCC includes 

IGSCC, TGSCC, PWSCC, and low 

temperature crack propagation as aging 

mechanisms."

The change provides a more detailed 

explanation of SCC and the relationship of 

corrosion, tensile stress and chemical 

environment. In addition, it provides 

clarification of SCC with regard to PWR 

internal components that is consistent with 

the usage in MRP-227, Rev. 0.

N/

Thermal fatigue

The definition of "Thermal fatigue" has been 

modified to include: "Fatigue is the 

progressive and localized structural damage 

that occurs when a material is subjected to 

cyclic loading. The maximum stress values 

are less than the ultimate tensile stress limit, 

and may be below the yield stress limit of the 

material. Higher temperatures generally 

decrease fatigue strength."

The change provides a better definition based 

on compilation of ASTM Standard Definitions, 

5th Edition, 1982.

N/

Transgranular stress 

corrosion cracking

The term "Transgranular stress corrosion 

cracking" has been added. The definition 

states: "Transgranular stress corrosion 

cracking (TGSCC) is SCC in which cracking 

occurs across the grains"

For IV.B2, B3, and B4, per MRP-227, SCC 

includes the TGSCC. N/

Water trees Deleted the word “continuous” from the Change was made to include all inaccessible N/
NUREG-1950 II-416 April 2011

Table II-18. Chapter IX.F - Revision 2 Differences from Chapter IX, GALL Report, Rev. 1 and Their Techni

Defined Term Summary of Significant Changes Technical Basis for Change L

definition to be consistent with the changes 

implemented in AMP XI.E3 deemphasizing 

voltage stress 

or underground cables down to and including 

400 volts within the scope of LR subject to 

significant moisture. Deemphasized water 

trees and revised to primarily consider water 

intrusion (significant moisture). 
April 2011 II-417 NUREG-1950

Table II-19. Chapter IX.G - Revision 2 Differences from Chapter IX, GALL Report, Rev. 1 and Their Techn

Defined Term Summary of Significant Changes Technical Basis for Change L

References

The following references have been added to 

GALL Report, Chapter IX.G:

EPRI-1016596, EPRI Materials Reliability 

Program: Pressurized Water Reactor 

Internals Inspection and Evaluation 

Guidelines (MRP-227-Rev. 0),” Electric 

Power Research Institute, Palo Alto, CA: 

12/22/2008.

Gillen and Clough, Rad. Phys. Chem. Vol. 18, 

p. 679, 1981.

These references were added because they 

are source documents that had not previously 

been used in developing information 

presented in Chapter IX of the GALL Report.

N/A
NUREG-1950 II-418 April 2011

Table II-20. Revision 2 Differences from Chapter X, Time-Limited Aging Analyses, GALL Report, Rev. 1 a

Bases

Location of Change Summary of Significant Changes Technical Basis for Change 

X.M1 Fatigue Monitoring

Program Description

Scope of Program

Preventive Actions

Detection of Aging 

Effects

Changed the program title from “Metal Fatigue of 

Reactor Coolant Pressure Boundary” to “Fatigue 

Monitoring.” Accordingly modified the scope to 

state that this program includes those components 

that have been identified to have a fatigue TLAA. 

Program description was revised to clarify how to 

calculate environmentally-adjusted Cumulative 

Usage Factor, and which NUREG provides the 

environment correction factors for carbon or lowalloy steel, stainless steel, and nickel-alloys.

Added in Program Description a statement that 

the program also verifies that the severity of the 

monitored transients are bounded by the design 

transient definition for which they are classified.

Deleted last paragraph of program description that 

addresses that this program is an acceptable 

option under 10 CFR 54.21(c)(1)(iii).

Added in Scope of Program a statement that the 

scope includes those components that have been 

identified to have a fatigue TLAA.

Added in Preventive Actions a statement that 

tracking of design basis transients are considered 

preventive activities.

Revised Detection of Aging Effects to indicate 

when updates of the fatigue usage calculations 

need to be performed.

Scope includes more than reactor coolant sys

Therefore, elements are revised accordingly t

remove reactor coolant pressure boundary.

Cumulative fatigue damage exists for far more 

than the reactor coolant pressure boundary 

components as stated in the AMP. Containme

supports, steam generator secondary sides, 

reactor internals, ESF, Auxiliary, and steam a

power (S&P) systems all have cumulative fat

damage entries in the GALL AMR tables. Pro

clear guidance for which NUREG to use for 

calculating Fen for different materials.

Provides additional clarity on transients.

The GALL Report would not contain a detaile

description of a program that was not accepta

Provides guidance on what is included in scop

Provides clear basis how the tracking of the c

would be used to ensure the validity of the CU

fatigue analysis.

X.S1 Concrete Containment Tendon Prestress

No notable technical changes were made to this TLAA

X.E1 Environmental Qualification (EQ) of Electric Components
April 2011 II-419 NUREG-1950

Table II-20. Revision 2 Differences from Chapter X, Time-Limited Aging Analyses, GALL Report, Rev. 1 a

Bases

Location of Change Summary of Significant Changes Technical Basis for Change 

Program Description

Revised to clarify that the 60-year EQ reanalysis 

is performed prior to entering the period of 

extended operation and include 10 CFR 50.49(i) 

criteria on how the qualification records are 

maintained for audit purposes and verified 

accordingly.

Not a technical issue. This clarification, editor

nature, does not require a technical basis. 
NUREG-1950 II-420 April 2011

Table II-21. Revision 2 Differences from Chapter XI, Mechanical Aging Management Programs, GALL Re

Their Technical Bases

Location of Change Summary of Significant Changes Technical Basis for Change 

XI.M1 ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD

General

Preventive Actions

Detection of Aging 

Effects

Revised to include implementing the generic 

changes described in Section II.5.1. The Preventive 

Actions program element was revised to state that 

this program is a monitoring program that does not 

implement preventive actions. The Detection of 

Aging Effects program element was revised to refer 

to ASME Code Section XI examination categories 

and to delete the detailed information that is also 

contained in the code; and the paragraph related to 

NDE techniques for BWRs was revised to eliminate 

reference to some of the BWRVIPs. 

The changes, in general, were not changes in

technical content. Revisions in the Preventive 

Actions program element deleted the previous 

statement about operation within technical 

specification limits, which was not directly relat

aging management. The change in Detection o

Aging Effects eliminated possible future conflic

changes in the code are approved in accordanc

with 10 CFR 50.55a; however, the deleted 

information is still provided in the referenced AS

Code Section XI examination category 

specifications. The paragraph related to BWRV

was changed to eliminate reference to docume

that are more appropriately referenced in other 

AMPs.

XI.M2 Water Chemistry

Program Description

Scope of Program

Preventive Actions

Parameters 

Monitored/ Inspected

Detection of Aging 

Effects

Monitoring and 

Trending

Acceptance Criteria

Revised to include implementing the generic 

changes described in Section II.5.1. The Program 

Description was revised to reference the latest 

revisions of EPRI reactor water chemistry 

guidelines approved by the staff for license renewal 

application; in addition, the previous provision 

related to use of later revisions of the guidelines 

was deleted. Scope of Program was revised to 

more explicitly describe the components within 

scope of the program. Preventive Actions was 

revised to provide additional details with regard to 

impurities and additives. Parameters 

Monitored/Inspected, Monitoring and Trending, and 

Acceptance Criteria were revised to eliminate 

details that are contained in the referenced water 

chemistry guidelines.

The EPRI water chemistry guidelines reference

this AMP are the latest revisions that have bee

reviewed by the staff and approved for use dur

the period of extended operation. In addition, th

staff determined that the previous provision rela

to use of later revisions of EPRI guidelines did 

provide sufficient assurance that appropriate st

review would be obtained prior to implementati

later guideline revisions. However, a new prefa

has been provided in the GALL Report, Chapte

to provide more detailed guidance on the use o

later revisions/editions of various industry 

documents referenced therein.
April 2011 II-421 NUREG-1950

Table II-21. Revision 2 Differences from Chapter XI, Mechanical Aging Management Programs, GALL Re

Their Technical Bases

Location of Change Summary of Significant Changes Technical Basis for Change 

XI.M3 Reactor Head Closure Stud Bolting

Detection of Aging 

Effects

Deleted the surface and volumetric examination of 

studs when removed and clarified the ASME Code 

Section XI, Table IWB-2500-1 providing inspection 

requirements.

The staff has aligned the program element with 

ASME Code provisions that are considered 

sufficient for aging management purposes.

XI.M4 BWR Vessel ID Attachment Welds

Scope of Program

Parameters 

Monitored/ Inspected

Acceptance Criteria

AMP was clarified as an augmented inservice 

inspection program and identified the component to 

which this program focusing on specific 

components. 

Deleted the sentence that states that the applicant 

may use the guidelines of BWRVIP-62 for hydrogen 

water chemistry, provided a relief request has been 

submitted and is approved by NRC staff.

Revised to state that acceptance criteria are given 

in BWRVIP-48-A and ASME Code, Section XI.

Provides the structures/components that are w

the scope of the program.

Reliefs are on a case-by-case basis. While a 

licensee has the right to request inspection relie

under 10 CFR 50.55a(a)(3) for use of hydrogen 

water chemistry, such a relief would only be 

approved for the 10-year interval during which 

was requested. 

Identifies the codes/standard used for acceptan

criteria.

XI.M5 BWR Feedwater Nozzle

Program Description

Corrective Actions

Explicitly identifies NUREG-0619, “BWR Feedwater 

Nozzle and CRD Return Line Nozzle Cracking.” 

Added statement that modifications were completed 

during the initial license period.

Removed reference to IWB-4000 and IWB-7000 

and replaced with IWA-4000.

NUREG-0619 is added because it addresses th

results of analysis of BWR reactor vessel nozz

cracking caused by cycling of water temperatur

systems connected to the vessel. It includes 

stresses caused by thermal stratification, therm

oscillations, and thermal striping. These 

modifications were committed to by the license

their response to NUREG-0619.

Subsections IWB-4000 and IWB-7000 do not e

in ASME Section XI 2004 edition, as they were 

incorporated into Subsection IWA-4000 in a 

previous edition of the code.

XI.M6 BWR Control Rod Drive Return Line Nozzle
NUREG-1950 II-422 April 2011

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Their Technical Bases

Location of Change Summary of Significant Changes Technical Basis for Change 

General

Program Description

Scope of Work

Parameters 

Monitored/ Inspected

Revised to implement generic changes described in 

Section II.5.1.

Added the regulatory framework related to NUREG0619. 

Deleted from program description part (b) that the 

program includes system modifications and 

maintenance programs to mitigate cracking.

Revised to include the different configurations of 

control rod drive return line (CRDRL) nozzles

Revised to establish a link between parameters 

monitored and management of aging effects.

See Section II.5.1 for technical basis.

Adds a discussion on how the NRC’s concerns 

Generic Technical Activity A-10 and 

recommendations in NUREG-0619 relate to the 

program elements for this AMP. The basis in th

GALL Report Revision 1 was clarified.

These are system modifications that were 

completed. They do not need to be part of licen

renewal.

NUREG-0619 was issued as the NRC’s final ba

for establishing what needed to be done to reso

the generic cracking issue for BWR feedwater 

nozzles and CRDRL nozzles in NRC Generic 

Technical Activity A-10. The actions to resolve 

Generic Technical Activity A-10 were dependen

three things: (1) BWR Model type, (2) BWR ves

size, and (3) whether or not a BWR licensee co

demonstrate adequate core re-coverage using 

CRDRL flow only. Thus, the system modificatio

recommendations under NUREG-0619 were no

mandatory for all BWRs, and thus were not the 

same for every BWR in the U.S. fleet of BWRs

The AMP monitors for linear dye penetration 

indications that may indicate a surface-breakin

crack and UT indications that may indicate the 

presence of a planar flaw (crack).

XI.M7 BWR Stress Corrosion Cracking

General

Monitoring and 

Trending, 

Acceptance Criteria

Corrective Actions

Revised to implement generic changes described in 

Section II.5.1.

Deleted reference to Subsections IWB-4000 and 

IWB-7000, IWC-4000 and IWC-7000 or IWD-4000 

and IWD-7000, and ASME Code Case N-504-1. 

See Section II.5.1 for technical basis.

Subsections IWB-4000, IWB-7000, IWC-4000, 

IWC-7000, IWD-4000, and IWD-7000 do not ex

in ASME Section XI 2004 edition, as they were 

incorporated into Subsection IWA-4000 in a 
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Their Technical Bases

Location of Change Summary of Significant Changes Technical Basis for Change 

Replaced with IWA-4000. previous edition of the code.

XI.M8 BWR Penetrations

General

Scope of Program

Parameters 

Monitored/ Inspected

Detection of Aging 

Effects

Corrective Actions

Revised to implement generic changes described in 

Section II.5.1.

Revised to include incore-monitoring housings and 

CRD stub tubes within the scope of this program.

Deleted the sentence that states that the applicant 

may use the guidelines of BWRVIP-62 for hydrogen 

water chemistry provided a relief request has been 

submitted and is approved by the NRC staff.

Removed reference to Categories B-D, B-F, and BJ. Revised to state that these examination 

categories include volumetric examination methods 

(UT or radiography testing), surface examination 

methods (liquid penetrant testing or magnetic 

particle testing for ferritic components), and VT-2 

visual examination methods.

Clarified that repairs in accordance with ASME 

Code are acceptable.

See Section II.5.1 for technical basis.

BWRVIP-47-A addresses these components.

Reliefs are on a case-by-case basis. While a 

licensee has the right to request inspection relie

under 10 CFR 50.55a(a)(3) for use of hydrogen 

water chemistry, such a relief would only be 

approved for the 10-year interval during which 

was requested. 

The BWRVIP reports and ASME Code Section 

as referenced in the GALL Report, provide deta

information for the examination categories; 

therefore, the examination categories do not ne

to be reiterated. 

Inspection methods are summarized. 

Provides the option that repairs performed in 

accordance with ASME Code are also accepta

XI.M9 BWR Vessel Internals
NUREG-1950 II-424 April 2011

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Their Technical Bases

Location of Change Summary of Significant Changes Technical Basis for Change 

General

Program Description

Scope of Program

Parameters 

Monitored/ Inspected

Detection of Aging 

Effects 

Monitoring and 

Trending 

Corrective Actions

Operating 

Experience

Revised to implement generic changes described in 

Section II.5.1.

Revised to include the recommendations of GALL 

AMP XI.M13, “Thermal Aging and Neutron 

Irradiation Embrittlement of Cast Austenitic 

Stainless Steel,” within the scope of this program. 

All elements were accordingly revised to address 

these recommendations, with the following changes 

from XI.M13, Rev.1.

Element 3 is revised to state that the program does 

not directly monitor loss of fracture toughness, but 

the impact is indirectly monitored by visual or 

volumetric techniques to detect cracking. Element 4 

is revised to recommend that initial inspection be 

performed within 5 years of entering the period of 

extended operation, and, if cracking is detected, 

then frequency of reinspection is to be justified. 

Element 5 is revised to provide a fracture 

toughness value to differentiate between 

susceptible and non-susceptible CASS materials.

Added PH martensitic stainless steel, martensitic

stainless steel, and X-750 material in the scope of 

this AMP. Elements 3, 4, 5, and 6 are revised to 

provide recommendations for these materials.

Clarified the SA-351 grades for low molybdenum 

and high molybdenum stainless steels.

Added aging effects of cracking due to fatigue and 

loss of material due to wear.

Deleted BWRVIPs-07, -63 from core shroud 

applicability.

Added BWRVIP-139 for steam dryer components.

Added BWRVIP-74-A for RPV Internals.

See Section II.5.1 for technical basis.

BWRVIPs address thermal aging and neutron 

irradiation embrittlement of CASS. Therefore, 

XI.M13 is deleted and necessary information is 

added into XI.M9.

Acknowledges that loss of fracture toughness 

cannot be directly measured, but can be indirec

managed by visual or volumetric examination to 

monitor for cracking. 

Inspection and/or reinspection frequency was n

addressed in XI.M13, Revision 1. 

Extensive research data indicate that for nonsusceptible CASS materials, the saturated lowe

bound fracture toughness is greater than 255 k

(NUREG/CR-4513, Rev. 1).

IGSCC was identified in Alloy X-750 material in 

upper support location of the tie rod repair. 

Presence of any high stress region that exceed

the threshold limits for IGSCC can cause IGSC

the tie rod repair hardware. Also, BWRVIP-189 

MRP-228 are the technical bases for expandin

scope for thermal embrittlement of X750 and P

steels.

Do not require molybdenum (Mo) verification.

Cracking due to fatigue is added to make the A

consistent with the AMR line IV.B1.RP-155. Ad

new line for loss of material due to wear becau

is a valid aging effect for jet pump wedge surfa

which are in scope of AMP XI.M9. 

BWRVIP-07 and BWRVIP-63 have been 

superseded by BWRVIP-76-A.

BWRVIP-139 has been approved for steam dry
April 2011 II-425 NUREG-1950

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Their Technical Bases

Location of Change Summary of Significant Changes Technical Basis for Change 

Added BWRVIP-183 for top guide in addition to 

BWRVIP-26-A. Deleted the alternative statement 

relative to inspection guidelines for top guide 

locations that are projected to exceed the threshold 

for IASCC after entering the period of extended 

operation. Added reinspection criteria.

Added a sentence to state that aging management 

strategies for repairs are provided by the repair 

designer, not the BWRVIP.

Deleted sentence regarding hydrogen water 

chemistry and relief requests.

Added a sentence to state that BWRVIP program 

requirements provide for inspection of BWR reactor 

internals to manage loss of material and cracking 

using appropriate examination techniques, such as 

visual examinations (e.g., enhanced visual test 

(EVT) -1, visual test (VT)-1) and volumetric 

examinations (e.g., UT). 

Added frequencies and sample sizes for CASS and 

other components’ detection of aging effects.

Added a statement to identify a fracture toughness 

value to distinguish between susceptible and nonsusceptible components.

Add BRVIP-80-A and BWRVIP-99-A to the list of 

BWRVIPs that provide guidance for crack growth.

Added trending information and acceptance criteria 

for PH-martensitic steels, martensitic stainless 

steels, and X-750 alloys to be on a case-by-case 

basis.

Added specific corrective action for top guide if 

cracking is observed.

Added BWRVIP-06R1-A and BWRVIP-25 for the 

This is the parent document for BWR internals. 

Added here for completeness.

Provides guidance for top guide beam inspectio

Most BWRs exceed this threshold in the 4th or 

fuel cycle; therefore, alternative statement does 

apply. Provides guidance for reinspection after 

initial 12-year period after entering period of 

extended operation. 

Added clarification to indicate that BWRVIP do

not provide aging management strategies for 

repairs.

Reliefs are on a case-by-case basis. While a 

licensee has the right to request inspection relie

under 10 CFR 50.55a(a)(3) for use of hydrogen 

water chemistry, such a relief would only be 

approved for the 10-year interval for which it w

requested . 

Provides inspection guidance for internal 

components.

Provides appropriate frequencies to ensure tha

aging is detected prior to loss of intended funct

Extensive research data indicate that for nonsusceptible CASS materials, the saturated lowe

bound fracture toughness is greater than 255 k

(NUREG/CR-4513, Rev. 1).

BWRVIP-80-A provides CGR curves for shroud 

vertical welds. BWRVIP-99-A provides CGR cu

for irradiated stainless steels.

Include recommendations for the added materi

Frequencies and sampling size are established 

based on no cracking being observed. If cracki

observed, increased sampling and more freque
NUREG-1950 II-426 April 2011

Table II-21. Revision 2 Differences from Chapter XI, Mechanical Aging Management Programs, GALL Re

Their Technical Bases

Location of Change Summary of Significant Changes Technical Basis for Change 

core plate assembly.

Clarified that cracking of dry tubes relates to incore 

monitoring dry tubes.

Added operating experience related to vertical core 

shroud welds and core spray pipe.

inspections are performed.

BWRVIP-06R1-A and BWRVIP-25 address the 

safety significance and inspection requirements 

the core plate assembly. Only inspection of cor

plate bolts (for plants without retaining wedges) 

inspection of the retaining wedges is required.

To distinguish from CRD dry tubes.

BWRVIP-18 addresses core spray pipe crackin

XI.M10 Boric Acid Corrosion (BAC)

General

Program Description

Scope of Program

Detection of Aging 

Effects

Corrective Actions

The AMP was revised to implement generic 

changes described in Section II.5.1.

Clarifies that the effects of BAC on RCPB materials 

near nickel-alloy components are managed by the 

AMP XI.M11B.

Added copper alloy >15% Zn.

Added recommendations for detection of leakage 

for components with external insulation surfaces 

and joints under insulation or not visible for direct 

visual examination.

Clarify that 10 CFR 50 Appendix B and guidance in 

GL88-05 are necessary for corrective action.

See Section II.5.1 for basis.

Staff decision to include the effects of BAC on 

RCPB susceptible materials near nickel-alloy 

components in the new XI.M11B program.

Copper alloy > 15% zinc is susceptible to BAC

There are line items in the GALL Report that 

recommend XI.M10 to manage these aging eff

If insulation cannot be removed because of 

inaccessibility, the revised words include provis

to inspect, detect, or monitor boric acid leakage 

inaccessible locations.

To clarify that 10 CFR Part 50, Appendix B 

requirements for performing corrective actions 

acceptable, however, applicant needs to consid

guidance of NRC GL 88-05 as established here

XI.M11B Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reac
April 2011 II-427 NUREG-1950

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Their Technical Bases

Location of Change Summary of Significant Changes Technical Basis for Change 

Boundary Components (PWRs only)

General

This is a general revision that replaces both 

XI.M11, “Nickel Alloy Nozzles and Penetrations,” 

and XI.M11A, “Nickel-Alloy Penetration Nozzles 

Welded to the Upper Reactor Vessel Closure 

Heads of Pressurized Water Reactors,” in 

Revision 1 of the GALL Report. In the GALL 

Report, Revision 1, XI.M11 stated that except for 

the guidance provided in XI.M11A, guidance for 

aging management of other nickel-alloy nozzles is 

provided in the AMR items of Chapter IV, as 

appropriate. 

Removed discussion of the water chemistry 

guidelines and just referred to the GALL water 

chemistry program in Program Description.

Wording was revised to clarify that PWSCC applies 

to nickel-alloy components and BAC applies to 

steel components. PWSCC causes cracking in 

nickel-alloy components, but is not a degradation 

mechanism applicable to steel components. BAC

applies primarily to steel components.

This revised AMP, XI.M11B, combines lessons 

learned from and key strengths of the GALL Report, 

Revision 1, XI.M11, XI.M11A and also NRC 

communications and requirements related to 

examination of nickel-alloy RCPB components. In

addition, it includes provisions for examination of 

steel surfaces near dissimilar metal welds for 

potential effects of reactor coolant leakage and 

BAC. 

This program replaces AMPs XI.M11, “Nickel-A

Nozzles and Penetrations” and XI.M11A, “Nick

Alloy Penetration Nozzles Welded to the Upper 

Reactor Vessel Closure Heads of Pressurized 

Water Reactors.” It addresses the issue of crac

of nickel-alloy components and loss of material 

to BAC in susceptible, safety-related componen

near nickel-alloy reactor coolant pressure boun

components. A final rule (September 2008) in 

updating 10 CFR 50.55a requires the following 

ASME Boiler and Pressure Vessel (B&PV) Cod

Cases: (a) N-722, “Additional Examinations for 

PWR Pressure-Retaining Welds in Class 1 

Components Fabricated with Alloy 600/82/182 

Materials, Section XI, Division 1,” to establish lo

term inspection requirements for the PWR vess

steam generator, pressurizer components, and 

piping if they contain the PWSCC susceptible 

materials designated alloys 600/82/182 and (b) 

729-1, “Alternative Examination Requirements 

PWR Reactor Vessel Upper Heads With Nozzl

Having Pressure-Retaining Partial-Penetration 

Welds, Section XI, Division 1” to establish new 

requirements for the long-term inspection of rea

pressure vessel upper heads. 

In addition, dissimilar metal welds need additio

examinations to provide reasonable assurance 

structural integrity. The NRC issued RIS 2008-2

“Regulatory Approach for Primary Water Stress 

Corrosion Cracking (PWSCC) of Dissimilar Me

Butt Welds in Pressurized Water Reactor Prima

Coolant System Piping” (October 2008), which 

stated the regulatory approach for addressing 
NUREG-1950 II-428 April 2011

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Their Technical Bases

Location of Change Summary of Significant Changes Technical Basis for Change 

PWSCC of dissimilar metal butt welds. The RIS 

documents the NRC’s approach for ensuring th

integrity of primary coolant system piping conta

dissimilar metal butt welds in PWRs, and, in 

conjunction with the mandated inspections of 

ASME Code Case N-722, ensures that augmen

ISI of all nickel-based alloy components and we

in the RCS continue to perform their intended 

functions. 

As stated in this RIS, the NRC has found that M

139, “Primary System Piping Butt Weld Inspect

and Evaluation Guideline” (2005), and MRP int

guidance letters provide adequate protection of 

public health and safety for addressing PWSCC 

dissimilar metal butt welds pending the 

incorporation of ASME Code Case N-770 

containing comprehensive inspection requirem

into 10 CFR 50.55a. It is the intention of the NR

replace MRP-139 by incorporating the requirem

of ASME Code Case N-770 into 10 CFR 50.55

XI.M12 Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)

General

Program Description

Scope of Program

Detection of Aging 

Effects

Revised to implement generic changes described in 

Section II.5.1.

Clarified that aging management for BWR and 

PWR CASS internals is covered in XI.M9 and 

XI.M16A, respectively.

Clarified to distinguish between low molybdenum 

and high-molybdenum cast stainless steels.

States that AMP applies only to Class 1 piping 

components.

Provides additional guidance for flaw tolerance 

evaluation and clarifies that current UT 

methodology cannot detect and size cracks; 

See Section II.5.1 for basis.

Clarifies that this program does not address BW

and PWR internals and identifies where these 

components are addressed.

Clarified to ensure preventive actions should be 

same as other condition monitoring programs. 

Clarified to distinguish between low molybdenu

and high-molybdenum cast stainless steels.

Identifies the components in scope of the progr

Gives a more complete guide for performing 

component-specific flaw tolerance evaluation. 
April 2011 II-429 NUREG-1950

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Their Technical Bases

Location of Change Summary of Significant Changes Technical Basis for Change 

therefore, EVT-1 is used until qualified UT 

methodology for CASS can be established. Also 

identifies that description of EVT-1 is found in 

BWRVIP-03 and MRP-228.

Added a paragraph about detection of reduction in 

fracture toughness.

These documents define EVT-1 for BWR and P

respectively. Use of EVT-1 provides a means o

detecting and sizing cracks. 

Acknowledges that loss of fracture toughness 

cannot be directly measured, but can be indirec

managed by visual or volumetric examination to 

monitor for cracking. 

Inspection and/or reinspection frequency was n

addressed in XI.M13, Revision 1. Extensive 

research data indicate that for non-susceptible 

CASS materials, the saturated lower-bound fra

toughness is greater than 255 kJ/m2 (NUREG/C

4513, Rev. 1).

XI.M16A PWR Vessel Internals

This is a new AMP

This is an entirely new AMP to replace Section 

XI.M16 of the GALL Report, Revision 1, which 

stated, “Guidance for the aging management of 

PWR Vessel Internals is provided in the AMR line 

items of [GALL Report] Chapter IV, as appropriate.” 

The AMR line items for PWR Vessel Internals in the 

GALL Report, Revision 1, Chapter IV, in general, 

stated that no further aging management review 

was necessary if an applicant provided a 

commitment in the FSAR supplement to (1) 

participate in the industry programs for investigating 

and managing aging effects on reactor internals, (2)

evaluate and implement the results on the industry 

programs as applicable to the reactor internals, and 

(3) upon completion of these programs, but not less 

than 24 months before entering the period of 

extended operation, submit an inspection plan for 

reactor internals to the NRC for review and 

approval.

The new AMP is based on the staff’s current re

of EPRI 1016596, “Materials Reliability Program

Pressurized Water Reactor Internals Inspection 

Evaluation Guidelines (MRP-227-Rev. 0).” This 

program is used to manage the effects of agerelated degradation mechanisms that are applic

in general to the PWR RVI components at the 

facility. These aging effects include (a) various 

forms of cracking, including SCC, which also 

encompasses PWSCC, IASCC, or cracking du

fatigue/cyclical loading; (b) loss of material indu

by wear; (c) loss of fracture toughness due to e

thermal aging or neutron irradiation embrittleme

(d) changes in dimension due to void swelling; 

(e) loss of preload due to thermal and irradiatio

enhanced stress relaxation or creep. 

The program applies the guidance in MRP-227 

inspecting, evaluating, and, if applicable, 

dispositioning non-conforming RVI components 
NUREG-1950 II-430 April 2011

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Their Technical Bases

Location of Change Summary of Significant Changes Technical Basis for Change 

the facility. The program conforms to the definit

of a sampling-based condition monitoring progr

as defined by the Branch Technical Position RS

1, with periodic examinations and other inspect

of highly affected internals locations. 

XI.M17 Flow-Accelerated Corrosion

General

Detection of Aging 

Effects

Monitoring and 

Trending

Corrective Actions

The AMP was revised to implement generic 

changes described in Section II.5.1.

Added frequency and sampling information.

Changed “ultrasonic and radiography” to “ultrasonic 

or radiography.”

Added that when measurements show the 

predictions to be non-conservative, the model must 

be recalibrated using the latest field data.

Clarifies that wear rates need to be evaluated with 

respect to power uprate effects.

Added a statement that when susceptible 

components are replaced with resistant materials, 

such as high Cr material, the downstream 

components should be monitored closely to 

mitigate any increased wear.

See Section II.5.1 for basis.

Recommended that sampling is based on most 

susceptible locations and the frequency is in 

accordance with Nuclear Safety Analysis Cent

(NSAC) 202L requirements.

There is no technical basis for requiring that 

radiographic testing is included in the program 

addition to ultrasonic testing. This change allow

the use of either technique. Most, if not all 

applicants, use ultrasonic testing.

It is recognized that CHECWORKS is not alway

conservative in predicting component thickness

The bounding and conservatism aspects are bo

subject to (a) input (parameters) assumptions b

matched (or not being exceeded) in the service 

conditions and (b) uncertainty resulting from th

conditions, as well as from the model.

Ensures that power uprate results are evaluate

operating conditions could change and therefor

impact wear rates.

Addresses “partial” replacements with high-Cr 

in an otherwise susceptible carbon steel line.

XI.M18 Bolting Integrity

General The AMP revision includes implementing the 

generic changes described in Section II.5.1. The 

The change to remove structural and compone

support bolting from this AMP is consistent with 
April 2011 II-431 NUREG-1950

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Their Technical Bases

Location of Change Summary of Significant Changes Technical Basis for Change 

scope of the AMP was changed to address only 

closure bolting for pressure-retaining components. 

Management of aging effects for component 

support and structural bolting was changed to other 

appropriate AMPs. The Program Description was 

revised to list all other AMPs that provide aging 

management for structural or component support 

bolting. Scope of Program was revised consistent 

with the revised scope of the AMP. Preventive 

Actions was revised to include specific 

recommendations with regard to material yield 

strength and use of molybdenum disulfide. 

Parameters Monitored/Inspected was revised to 

include recommendations for monitoring high 

strength closure bolting. Detection of Aging Effects 

was revised to delete recommendations related 

only to structural bolting and to eliminate details of 

examinations specifications that are included in 

referenced documents. Monitoring and Trending, 

Acceptance Criteria, and Corrective Actions were 

revised to eliminate recommendations related only 

to structural or containment support bolting.

staff’s experience reviewing license renewal 

applications since issuance of Revision 1 of the 

GALL Report. The staff has found that for 

management of structural and component supp

bolting, many applicants credit alternative prog

(e.g., AMPs XI.S1, “ASME Section XI, Subsect

IWE”; XI.S3, “ASME Section XI, Subsection IW

XI.S6, “Structures Monitoring”; XI.S7, “RG 1.12

“Inspection of Water-Control Structures Associa

with Nuclear Power Plants”; and XI.M23, 

“Inspection of Overhead Heavy Load and Light 

Load (Related to Refueling) Handling Systems

and the staff has typically found use of these 

alternative program acceptable. The change to 

remove structural and component support bolti

from this AMP aligns the AMP more closely wit

typical industry practice and provides 

recommendations for aging management of 

structural and component support bolting in oth

AMPs that typically are credited for aging 

management of these components. Using bolti

material with maximum yield strength less than 

1,034 MPa (150 ksi) and prohibiting lubricants 

containing molybdenum disulfide both decreas

likelihood of SCC in the bolting material. Monit

of high-strength closure bolting, if used, is 

recommended because such bolting is more 

susceptible to cracking due to SCC.

XI.M19 Steam Generators

General

The title of the AMP was changed, and the AMP 

was substantially rewritten, with changes in the 

Program Description, all of the Program Elements, 

and the References. 

In Revision 1 of the GALL Report, AMP XI.M19

“Steam Generator Tube Integrity” program was 

based on NEI 97-06, Revision 1, “Steam Gene

Program Guidelines.” Since the issuance of 

Revision 1 of the GALL Report, NEI 97-06 has 
NUREG-1950 II-432 April 2011

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Location of Change Summary of Significant Changes Technical Basis for Change 

been substantially revised and updated. NEI 97

Revision 2, has been accepted by the staff as 

providing adequate guidance for aging 

management of steam generator components 

within its scope during the period of extended 

operation. This AMP references a number of 

industry guidelines (e.g., the EPRI PWR Steam 

Generator Examination Guidelines, PWR Prima

to-Secondary Leak Guidelines, PWR Primary W

Chemistry Guidelines, PWR Secondary Water 

Chemistry Guidelines, Steam Generator Integr

Assessment Guidelines, Steam Generator In S

Pressure Test Guidelines) and incorporates a 

balance of prevention, mitigation, inspection, 

evaluation, repair, and leakage monitoring 

measures. NEI 97-06 (a) includes performance 

criteria that are intended to provide assurance 

tube integrity is being maintained consistent wi

the plant’s licensing basis and (b) provides 

guidance for monitoring and maintaining the tu

to provide assurance that the performance crite

are met at all times between scheduled inspect

of the tubes. Steam generator tube integrity ca

affected by degradation of steam generator plu

sleeves, and secondary side internals. Therefo

all these components are addressed by this AM

The NEI 97-06 program has been effective at 

managing the aging effects associated with ste

generator tubes, plugs, sleeves, and secondary 

side internals.

XI.M20 Open-Cycle Cooling Water System (OCCW)

General

AMP XI.M20 was revised to address aging affects 

of asbestos cement, reinforced concrete piping, 

piping components and piping elements in raw 

Adding new materials to AMP better matches t

materials used in existing OCCW systems that 

have previously been approved by the staff. GL 
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Location of Change Summary of Significant Changes Technical Basis for Change 

water managed by M20.

Revised to implement generic changes described in 

Section II.5.1. Materials commonly used in OpenCycle Cooling Water Systems are added (i.e., 

stainless steel, aluminum, copper alloy, polymeric 

linings, and concrete). 

Adds operating experience with MIC. 

New AMR Items are added for titanium exposed to 

raw water causing reduction in heat transfer due to 

fouling; and reinforced concrete or asbestos 

cement exposed to raw water, causing cracking, 

settling, and emphasis placed on loss of material 

relating to recent occurrences of MIC. 

13 and associated applicant’s docketed respon

are the foundation for managing the aging effec

OCCW systems; however, some aspects of 89

are operational and not related to aging 

management. Several plants have experienced 

problems associated with MIC. 

XI.M21AClosed Treated Water Systems

General

Revised to implement generic changes described in 

Section II.5.1. This AMP is expanded from Closed 

Cycle Cooling Water Systems (as defined in GL 89-

13) and includes HVAC, auxiliary boilers, etc. 

Avoids misapplication of this AMP to non-GL 89-13 

systems. Recognizes that water chemistry 

standards are application-specific. Uses changed 

definition of “treated water” from Chapter IX. Adds 

AMR Items for copper alloy exposed to closedcycle cooling water, causing loss of material due to 

general, pitting, crevice, and galvanic corrosion.

A number of treated water systems did not hav

GALL AMP, and applicants took an exception t

XI.M21 to include these systems. The staff 

accepted these exceptions. This AMP applies o

to non-GL 89-13 systems. This AMP manages 

aging for all treated water sources, and differen

sources have different water chemistry standar

A new definition for “treated water” was develo

in Chapter IX and was revised for this AMP. Th

addition of copper alloy reflects materials used 

closed treated water systems, which have been 

approved by the staff in past applications.

XI.M22 Boraflex Monitoring

General Revised to implement generic changes described in 

Section II.5.1.

There was no change in the technical intention 

the recommendations. 

XI.M23 Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems

General Updated AMP to endorse industry standard ASME The industry standard has been used by applic
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Their Technical Bases

Location of Change Summary of Significant Changes Technical Basis for Change 

Scope of Program

Detection of Aging 

Effects

B30.2 - 2005, “Overhead and Gantry Cranes (Top 

Running Bridge, Multiple Girder),” for inspection of 

overhead cranes and light load handling systems 

used for refueling.

Includes managing loss of preload of bolted 

connections consistent with XI.M18.

Clarified to recommend inspection frequency in 

accordance with ASME B30.2 or other appropriate 

standards in ASME B30 series.

in their applications and been accepted by staff 

various SERs.

The bolting is now included in individual AMPs 

therefore, is now in scope of this AMP.

Provided inspection frequency guidance from t

accepted ASME standard. These frequencies w

acceptable to staff in previous SERs.

XI.M24 Compressed Air Monitoring

General

Revised to implement generic changes described in 

Section II.5.1.

In Element 3, erosion is not an aging effect in GALL 

for air systems such that there is no need for 

inspection.

Refocuses AMP content on license renewal 

considerations by deleting operational program 

testing that is not relevant to age-related 

degradation and focusing on environments that are 

relevant for age-related degradation. Program 

focuses on aging management issues, not 

operational issues associated with the current 

licensing term. Emphasizes that the commitments 

to GL 88-14 are not changed by this AMP and that 

this AMP uses only those aspects of GL 88-14 that 

affect aging, primarily the loss of material due to 

corrosion. Corrosion is a result of moisture in the 

system. Operational issues, such as pressure 

decay leak testing, emergency procedures and 

training, were deleted from the AMP. These 

changes were made in Program Description and in 

Elements 1-5.

Revised Elements 3, 4, 5, and 6 to provide specific 

See Section II.5.1 for basis.

Ensures that this AMP only focuses on the agin

management aspects of the systems, not the 

operational activities. The pressure decay leak 

testing is mainly intended to indicate performan

degradation of active components. Visual 

examinations and control of moisture in the sys

including pressure dew point monitoring, provid

reasonable assurance of adequate aging 

management. 

Provides specific recommendations and identif

the use of ANSI/ISA 7.0.01-96 and ASME O/M

Part 17 as standards.

The comment that recommends removing the 

reference to “erosion” is acceptable because 

operating experience indicates corrosion is the 

major mechanism that causes the aging effect 

loss of material in the compressed air system.
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Location of Change Summary of Significant Changes Technical Basis for Change 

recommendations for parameters monitored, 

frequency and sampling recommendations for 

analysis and inspection, and trending 

recommendations for dew point measurements, 

and acceptance criteria for air quality moisture 

limits are established based on accepted industry 

standards.

XI.M25 BWR Reactor Water Cleanup System

Program Description

Parameters 

Monitored/ Inspected

Detection of Aging 

Effects

Included implementing the generic changes 

described in Section II.5.1. Program Description 

was revised to augment the regulatory background 

information. Parameters Monitored/Inspected and 

Detection of Aging Effects were updated to 

acknowledge that all licensees have completed 

implementation of GL 89-10 actions. References 

were updated.

The AMP wording revisions did not change the 

technical intent of previous recommendations. 

Additional regulatory background information w

provided, and parts of the AMP were reworded 

acknowledge that all affected licensees have 

completed the implementation actions describe

GL 89-10.

XI.M26 Fire Protection

General

Scope of Program

Parameters 

Monitored/ Inspected

Detection of Aging 

Effects

Revised to implement generic changes described in 

Section II.5.1.

Deleted diesel-driven fire pump performance test 

and inspection of the fuel oil supply line from the 

scope of the program and from all other elements 

Added other fire barrier material, such as flamastic, 

3M fire wrapping, spray-on fire proofing material, 

intumescent coating, etc.

Added that the AMP manages the aging effects of 

loss of material and cracking, increased hardness, 

shrinkage and loss of strength.

Changed visual inspection of “approximately” 10% 

of each type of seal to “not less than” 10%.

Changed frequency of Halon/carbon dioxide testing 

See Section II.5.1 for basis.

Diesel-driven fire pump fuel oil supply line is 

managed by the Fuel Oil Analysis and the One

Time Inspection Programs. Staff has accepted 

in numerous license renewal SERs.

Applicants have used these materials as fire ba

materials.

Scope of program did not identify what aging 

effects were managed by the program.

Use of the word “approximately” was very vagu

The intent of the GALL frequency is to ensure t

100% of the fire barrier penetration seals are 

inspected over the 20-year period of extended 

operation. Industry standards do not define 

inspection samples for fire barrier penetration s
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Their Technical Bases

Location of Change Summary of Significant Changes Technical Basis for Change 

and inspection to state 6 months or on a schedule 

in accordance with an NRC-approved fire protection 

program.

inspections. The 10% sample was selected so 

over the 20-year period, essentially all penetrat

seals will be inspected.

Halon and CO2 systems are highly reliable, an

current testing practices (in either the Fire 

Protection Plan or plant Technical Specification

have proven to be adequate for the current lice

term. The frequencies for inspections specified 

NUREG-1801 for Halon and CO2 system testin

are much shorter than often practiced. More 

frequent testing will not increase reliability of th

systems. Most applicants use the current licens

basis frequency of refueling outage (18 or 24 

months) for performance testing. However, the 

inspection frequencies are 6 to 12 months with 

review of operating experience as a considerat

for higher intervals.

XI.M27 Fire Water System

Scope of Program

Acceptance Criteria

Clarified that hoses and gaskets can be excluded 

from scope based on prescribed replacement.

Clarified that minimum wall thickness should be 

maintained.

If hoses and gaskets are replaced based on 

prescribed frequency, then these components 

considered short-lived and therefore do not nee

managed.

Provides criteria for acceptance of wall thickne

measurement.

XI.M29 Aboveground Metallic Tanks

Title Change

Preventive Actions

Detection of Aging 

Effects

Corrective Actions

Revised to implement generic changes described in 

Section II.5.1. Title is changed from “Above Ground 

Steel Tanks” to “Above Ground Metallic Tanks.”

The recommendation for coatings is removed 

because it is a design issue.

Specified UT for thickness measurements.

Tanks are constructed from other materials tha

steel, such as aluminum and stainless steel, an

the AMP is also applicable to them.

The use of coatings is a design issue.

Added details that conform to guidance provide

A.1.2.3 for this element.
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Their Technical Bases

Location of Change Summary of Significant Changes Technical Basis for Change 

Revised to state that flaws in the caulking or 

sealant are repaired.

Added details that conform to guidance provide

A.1.2.3 for this element.

XI.M30 Fuel Oil Chemistry

General

Revised to include implementing the generic 

changes described in Section II.5.1. The Program 

Description was revised to provide an updated list 

of ASTM standards. 

Scope of Program was revised to delete the listing 

of ASTM standards and to clarify the description of 

components in scope of the program. 

Preventive Actions was revised to provide 

clarification of the recommended preventive actions 

included in this program. 

Parameters Monitored/Inspected and Detection of 

Aging Effects were revised to provide 

recommendations that focus more clearly on aging 

management, rather than on general operational 

practices and added the aging mechanisms of 

crevice corrosion and fouling that leads to 

corrosion. In addition, Detection of Aging Effects 

was revised to include an explicit recommendation 

with regard to frequency of diesel fuel oil storage 

tanks’ cleaning and inspection. AMP now clarifies

the need for a volumetric inspection. 

Monitoring and Trending, and Acceptance Criteria 

were revised to remove overly prescriptive and 

superfluous information. 

Information related to ASME standards was 

previously listed in several program elements a

was consolidated in the Program Descriptions a

the Acceptance Criteria program element. The 

explicit recommendation regarding frequency fo

cleaning and inspection of diesel fuel oil storag

tanks is based on RG 1.137, “Fuel Oil Systems 

Standby Diesel Generators,” Revision 1, Regul

Position C.2.f. ASTM D0975-04 was added into 

Acceptance Criteria and other standards were 

deleted because the added standard provides 

appropriate guidance with regard to maintaining 

acceptable fuel oil quality during the period of 

extended operation. 

Different designs should be reviewed on a case

case basis to ensure they are either equivalent 

more conservative to multi-level sampling. For 

designs that do not allow for multi-level samplin

the staff has determined that a representative 

sample taken from the bottom of the tank provi

an acceptable alternative to multi-level samplin

Precedents for accepting tank bottom samples 

an alternative to multi-level sampling are 

documented in Oyster Creek and Three Mile Is

Unit 1, license renewal SERs.

A volumetric inspection should be performed to 

further assess the condition if the visual inspec

provided indications of degradation, or, if a visu

inspection is not physically possible.

XI.M31 Reactor Vessel Surveillance
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Their Technical Bases

Location of Change Summary of Significant Changes Technical Basis for Change 

General

The AMP was substantially rewritten, with changes 

in the Program Description and in all elements of 

the program. Clarified that the intention of Element 

5b is to be consistent with Regulatory Position 2 in 

NRC RG 1.99, Revision 2.

Reworded first paragraph to correct the citation to 

ASTM with the current title by replacing "American 

Society for Testing and Materials (ASTM) E 185 

Standard" with "ASTM International Standard 

Practice E 185-82” and to enable an automatic

update to the GALL to include the new provisions 

going into Appendix H within the next year or two. 

Reworded Element 3 to ensure the program uses 

neutron dosimeters to benchmark the neutron 

fluence calculations.

Low melting point elements or eutectic alloys may 

be used as a check on peak specimen

irradiation temperature.

Monitoring and Trending was revised to say, "When 

two or more credible surveillance data sets are 

available, the extent of reactor vessel neutron 

embrittlement for the period of operation may be 

projected according to Regulatory Position 2 in 

NRC RG 1.99, Rev. 2, based on best fit of the 

surveillance data."

Element 5 changed to make it consistent with 

requirements of 10 CFR 50.61 and 10 CFR 50.61a, 

and with RG 1.99.

Element 10, Operating Experience. In Element 10, 

"neutron spectrum" has been changed to "neutron 

fluence" because fluence is tied directly to vessel 

integrity through TLAAs and can be more 

unambiguously monitored and managed than 

The Code of Federal Regulations (CFR), 10 CF

Part 50, Appendix H, requires that peak neutro

fluence at the end of the design life of the vess

will not exceed 1017 n/cm2 (E >1MeV), or that 

reactor vessel beltline materials will be monitor

by a surveillance program to meet the ASTM E 

Standard. The objective of the reactor vessel 

material surveillance program is to provide 

sufficient material data and dosimetry to (a) mo

irradiation embrittlement at the end of the perio

extended operation and (b) determine the need 

operating restrictions on the inlet temperature, 

neutron spectrum, and neutron flux. The progra

a condition-monitoring program that measures 

increase in Charpy V-notch 30 foot-pound (ft-lb

transition temperature and the drop in the uppe

shelf energy as a function of neutron fluence an

irradiation temperature. The data from this 

surveillance program are used to monitor neutr

irradiation embrittlement, and are used in the 

TLAAs that are described in Section 4.2 of the 

SRP-LR. Changes to the AMP were made 

consistent with the objective of implementing th

requirements in 10 CFR 50, Appendix H, during 

period of extended operation.

Monitoring and Trending was revised to make

wording is consistent with what is used in 

Regulatory Position 2 in NRC RG 1.99, Revisio
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Location of Change Summary of Significant Changes Technical Basis for Change 

"neutron spectrum."

Updated the dates associated with the references.

XI.M32 One-Time Inspection

General

Elements 1, 3, 4, 5, 

6, 7, 10

Revised to include implementing the generic 

changes described in Section II.5.1. The Program 

Description was substantially revised to (a) more 

clearly identify the conditions in which use of a onetime inspection is appropriate, (b) explicitly list the 

mitigation AMPs in the GALL Report where a onetime inspection is credited to confirm effectiveness 

of the mitigation actions, and (c) more clearly 

identify conditions where a one-time inspection is 

not appropriate and a periodic inspection is 

recommended. 

Scope of Program was revised to more clearly 

describe components that are within scope of the 

AMP. 

Parameters Monitored/Inspected, and the 

associated table of examples, were revised to add 

surface condition as a parameter to be monitored 

when the aging effect is loss of condition or 

cracking. 

Detection of Aging Effects was revised to add 

specificity with regard to representative sample 

sizes and to provide clarification with regard to 

qualifications for inspectors and examination 

techniques. 

Monitoring and Trending was revised to state that 

for a one-time inspection program, monitoring and 

trending are not applicable. 

Acceptance Criteria was revised to provide 

examples of appropriate source documentation. 

The staff’s experience reviewing and evaluating 

license renewal applications over the past seve

years had identified a need to more clearly des

the conditions in which a one-time inspection 

program is adequate to provide confirmation th

aging effects are not occurring or are occurring 

sufficiently slow rate during the period of exten

operation; the changes in the Program Descrip

provide this clarification. The tabulated exampl

Parameters Monitored/Inspected added surfac

condition to the list of parameters monitored 

because surface condition provides a reliable 

leading indicator for potential loss of material o

surface cracking. The changes in Detection of 

Aging Effects eliminate uncertainty with regard 

adequate sample sizes and provide clearer 

guidance with regard to adequate inspector 

qualifications and examination techniques for n

ASME components.
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Their Technical Bases

Location of Change Summary of Significant Changes Technical Basis for Change 

Corrective Actions was revised to state that such 

actions may include implementation of periodic 

inspections under a different program. 

Operating Experience was revised to state that an 

applicant’s experience with detection of aging 

effects evaluated by this AMP should be included in 

the applicant’s operating experience review.

XI.M33 Selective Leaching of Materials

Scope of Program

Detection of Aging 

Effects

Acceptance Criteria

Revised to implement generic changes described in 

Section II.5.1, Scope of Program, more clearly 

identifies the materials susceptible materials and 

adds additional environments that could cause 

selective leaching (water-contaminated fuel oil and 

water-contaminated lubricating oil). 

Detection of Aging Effects is revised to include 

other mechanical examination techniques, such as 

destructive testing, chipping, or scraping. Detection 

of Aging Effects establishes a sample size of 20 

percent of the population, with a maximum sample 

size of 25 or other technically justified methodology 

and sample size. 

Acceptance Criteria specifies that no visible 

evidence of selective leaching or no more than a 20 

percent decrease in hardness and no noticeable 

change in color for copper alloys containing more 

than 15 percent zinc. AMR items are added for 

steel exposed to soil or concrete, causing loss of 

material due to general, pitting, and crevice 

corrosion (Condensate System and Auxiliary 

Feedwater System).

Bronze is subject to selective leaching in hot br

and steam. The GALL does not include any AM

entries for copper alloys in steam. Aluminum 

bronze is subject to selective leaching in 

hydrofluoric acid and acid chlorides. Neither of 

these environments is expected at a nuclear po

plant. Several applicants have identified these 

applicable environments. They should be adde

avoid unnecessary exceptions to be declared. 

Hardness testing is not always feasible or 

meaningful. Other mechanical testing methods

including destructive testing, provide a means o

detecting selective leaching. It is difficult to get 

random samples of piping to use normal sampl

techniques. Use of 20% with a maximum of 25 

practical compromise to have meaningful samp

size for small populations. Criteria are to 

demonstrate that selective leaching is not prese

Hardness criterion and copper color criterion ar

commonly used.

XI.M35 One-time Inspection of ASME Code Class 1 Small Bore-Piping

Program Description Revised to include implementing the generic Changes in the Program Description are based 
April 2011 II-441 NUREG-1950

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Their Technical Bases

Location of Change Summary of Significant Changes Technical Basis for Change 

Scope of Program

Detection of Aging 

Effects

Monitoring and 

Trending

changes described in Section II.5.1. The Program 

Description was revised to state that the 

recommendations apply for both full penetration 

welds and socket welds; in addition, discussion of 

opportunistic inspections and sampling were 

included. The Program Description also was 

revised to describe the conditions under which this 

one-time inspection program may be used and 

conditions under which a periodic program would 

be more appropriate. 

Monitoring and Trending was revised to update 

EPRI report references. 

Detection of Aging Effects and Monitoring and 

Trending were revised to state that cyclic loading 

(including thermal, mechanical, and vibration 

fatigue) are included in the aging effects managed 

by this program. 

Detection of Aging Effects was revised to provide 

additional recommendations related to examination 

of socket welds and use of a sampling basis for 

examination.

the staff’s review of industry operating experien

related to cracking in small bore piping and the 

staff’s review of license renewal applications du

the past several years. These reviews indicated 

that a recommendation for inspection of socket 

welds needed to be explicitly included in this 

program and that conditions under which period

inspection should be used needed to be more 

clearly described. The updated references in S

of Program are more recent guidelines that the 

has found appropriate for identifying the locatio

potentially susceptible piping. Addition of vibrat

fatigue to the examples of cyclic loading is base

on the staff’s determination that cracking due to 

vibration fatigue is an aging effect that is within 

scope of this AMP. Additional information desc

the conditions under which the staff has found 

of a sampling basis for opportunistic, destructiv

examinations of removed welds to be acceptab

XI.M36 External Surfaces Monitoring of Mechanical Components

Scope of Program

Acceptance Criteria

The AMP was revised to implement generic 

changes described in Section II.5.1. An incorrect 

aging effect was given for polymeric materials. The 

acceptance criteria for polymers were too restrictive 

and were made less restrictive. Scope of Program 

is expanded to include external surfaces of all 

metallic and polymeric materials instead of just 

steel. 

Scope of Program is expanded to include additional 

aging effects, including loss of material (metallic 

materials), cracking (metallic and polymeric 

AMP XI.M36 was revised to address aging affe

of asbestos cement, reinforced concrete piping

piping components and piping elements in soil 

managed by M36. The correct aging effects ne

to be entered. The acceptance criteria for polym

materials are too restrictive, and the NEI sugge

is accepted. Adding new materials to AMP bett

matches the materials used in existing buried a

underground systems that have previously bee

approved by the staff. AMP was revised to inclu

other metals such as stainless steel; polymeric 
NUREG-1950 II-442 April 2011

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Location of Change Summary of Significant Changes Technical Basis for Change 

materials), and change in material properties 

(polymeric materials). Addresses manual 

manipulation of polymeric materials. Includes 

acceptance criteria for non-metallic material. Better 

defines acceptance criteria for metallic materials. . 

material, such as PVC and HDPE; and elastom

materials. Staff has accepted in previous SERs

such as SSES, TMI, Beaver Valley etc., that th

AMP can be credited for metallic, polymers and 

elastomer components using visual inspection 

manipulation where necessary to manage the a

effects of loss of material, cracking, and chang

material properties. 

XI.M37 Flux Thimble Tube Inspection

General Revised to implement generic changes described in 

Section II.5.1.

There was no change in the technical intention 

the recommendations. 

XI.M38 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components

Program Description

Scope of Program

Parameters 

Monitored/Inspected

Detection of Aging 

Effects

Acceptance Criteria

Revised to implement generic changes described in 

Section II.5.1. The reference to repetitive failures 

was revised to make the meaning clear. Program 

description was revised to state that XI.M38 is 

applicable to any water system other than opencycle cooling water system (XI.M20), closed treated 

water system (XI.M21A), and fire water system 

(XI.M27). Scope of Program expands to include 

polymeric materials (rigid and elastomers) and 

additional metallic materials (old scope was steel 

only). Parameters Monitored/Inspected is revised to 

add examples of inspection parameters for metallic 

and polymeric components. Acceptance Criteria is 

revised to provide inspection methods and 

acceptance criteria for each type of material.

The reference to repetitive failures was revised 

make the meaning clear. The staff modified the 

AMP content to more clearly describe situation

where the AMP is appropriate and when a plan

specific program is warranted. The paragraph w

rewritten to address the comment and aligns w

wording used in AMP M35 for similar situations

Several applicants proposed an exception to th

AMP to include polymeric materials, and the sta

approved these exceptions. The original AMP w

only for steel, and since additional metallic and 

polymeric components were added to this AMP

inspection parameters for these additional 

components were added to the Parameters 

Monitored/Inspected program element. The orig

AMP was only for steel and because additional 

metallic and polymeric materials were added to 

AMP, acceptance criteria are provided for each 

type of material. 
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Their Technical Bases

Location of Change Summary of Significant Changes Technical Basis for Change 

XI.M39 Lubricating Oil Analysis

General

Revised to include implementing the generic 

changes described in Section II.5.1. The Program 

Description has been revised to include a 

discussion of how program effectiveness is verified. 

Scope of Program has been revised to more clearly 

identify components within the scope and aging 

effects managed by the program; a statement has 

been added stating that non-water based hydraulic 

fluids are within scope of the program. Parameters 

Monitored/Inspected has been revised to state that 

the program performs a check for moisture and 

particle count to detect evidence of moisture 

contamination and corrosion. Detection of Aging 

Effects has been revised to focus more clearly on 

detections of moisture or corrosion products and to 

recommend sampling following oil changes or 

periodic sampling. Acceptance Criteria has been 

revised to state that water or particle concentrations 

should not exceed manufacturer recommendations 

or industry standards and that phase-separated 

water in any amount is not acceptable. Corrective 

Actions has been revised to delete the previous 

recommendation related to vibration analysis. 

References have been revised to include ASTM D 

6224-02, Standard Practice for InService 

Monitoring of Lubricating Oil for Auxiliary Power 

Plant Equipment.

The staff noted that, as presented in Revision 1 

the GALL Report, this AMP included a number 

recommendations for a robust Lubricating Oil 

Analysis program that were not, in fact, related 

managing aging effects of metal components 

exposed to a lubricating oil environment. In a 

lubricating oil environment that does not experi

water intrusion or contamination, metal compon

are not expected to experience aging effects du

the period of extended operation. The changes 

Program Description, Scope of Program and 

Parameters Monitored/Inspected are made to 

refocus the AMP on monitoring for and prevent

water intrusion or contamination of the lubricati

oil. In addition, the staff has found that the sam

activities related to aging management of 

lubricating oil are also applicable for non-water 

based hydraulic fluid, so this environment was 

added to the scope of the AMP. Corrective Act

was revised to delete recommendation for vibra

analysis, which is a parameter related to 

operational issues but not typically related to ag

management. The staff has reviewed the ASTM 

standard added to the references and has foun

applicable for this program.

XI.M40 Monitoring of Neutron-Absorbing Materials Other than Boraflex

This is a new AMP.

This is a new AMP that provides for monitoring to 

ensure that for neutron absorbing material (other 

than Boraflex) used in spent fuel pools, any agerelated degradation of the material is detected and 

This AMP implements the AMP described in In

Staff Guidance LR-ISG-2009-01, Aging 

Management of Spent Fuel Pool NeutronAbsorbing Materials Other Than Boraflex, 2010
NUREG-1950 II-444 April 2011

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Location of Change Summary of Significant Changes Technical Basis for Change 

corrective actions are taken before results of spent 

fuel pool criticality analysis can be compromised.

XI.M41 Buried and Underground Piping and Tanks

N/A

AMP XI.M41 is new. Comments on the Public 

Comment Draft and several subsequent drafts 

were received from the public on several 

occasions. Piping and tanks exposed to soil are 

now managed by AMP XI.M41

In summary, NRC combined AMPs XI.M28, Buried 

Piping and Tank Surveillance, and XI.M34, Buried 

Piping and Tanks inspection, into a new AMP 

XI.M41, Buried and Underground Piping and 

Tanks. The new AMP incorporates aspects of both 

prior programs. 

Adds additional features. 

Considers Industry Initiative Actions for buried and

underground (in a tunnel or vault), environments. 

Materials that are considered include all metallics, 

polymers, and cementitious materials.

Preventive actions and inspection intervals are 

defined, depending on the environment and type of 

materials. 

The technical basis for combining XI.M28, "Bur

Piping and Tanks Surveillance," and XI.M34, B

Piping and Tanks Inspection," to produce XI.M4

"Buried and Underground Piping and Tanks," is 

make the program more in line with the Industr

Initiative for buried piping and tanks and to rely 

more heavily on industry standards such as the 

NACE International standards.
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Location of Change Summary of Significant Changes Technical Basis for Change 
NUREG-1950 II-446 April 2011

Table II-22. Revision 2 Differences from Chapter XI, Structural Aging Management Programs, GALL Rep

Their Technical Bases

Location of 

Change Summary of Significant Changes Technical Basis for Change 

XI.S1 ASME Section XI, Subsection IWE

General

Program 

Description 

Scope of Program

Parameters 

Monitored/ 

Inspected

Detection of Aging 

Effects 

Monitoring and 

Trending

Acceptance Criteria

Corrective Actions

References 

Revised to implement generic changes described 

in Section II.5.2.

The program attributes are augmented to 

incorporate aging management activities needed 

to address the potential loss of material due to 

corrosion in the inaccessible areas of the boiling 

water reactor (BWR) Mark I steel containment.

The program attributes are augmented to include 

surface examination to detect cracking in stainless 

steel (SS) penetration sleeves and dissimilar metal 

welds. If surface examination is not possible, 

appropriate 10 CFR50 Appendix J test may be 

conducted for pressure boundary components.

Identified that Subsection IWE requires 

examination of coatings that are intended to 

prevent corrosion and recommends AMP XI.S8 to 

ensure Emergency Core Cooling System (ECCS) 

operability.

Deleted containment seals and gaskets.

Deleted the table showing the ASME Code Table 

IWE-2500-1 categories. Defined the parameters to 

be monitored for non-coated surfaces, painted or 

coated surfaces, penetration seals/bellows, 

moisture barriers, and bolting.

Deleted the sentence, “In addition, a general 

visual examination is performed once each 

inspection period.”

Augmented the program to require surface 

examination of steel components that are subject 

to cyclic loading but have no current licensing

See Section II.5.2 for basis.

Incorporate LR-ISG-2006-01.

The 2004 edition of ASME Section XI, Subsec

IWE, specifies VT-3 examination for containme

pressure boundary components, including 

stainless steel and dissimilar metal welds. The

stainless steel bellows are not in scope of ASM

Subsection IWE but are in scope of 10 CFR Pa

50 Appendix J. VT-3 examination may not dete

fine cracks that could occur as a result of cycli

loading, and some penetration sleeves and 

bellows are not designed to allow for a local 

pressure test (Type B test) and are only press

tested as part of the containment Type A 

Integrated Leak Rate Test (ILRT). The frequen

of Type A test is every 10 years and could be 

extended for up to 15 years if a licensee 

implements Option B, performance-based test

accordance with 10 CFR Part 50 Appendix J. T

ILRT frequency thus may not provide for early 

detection of cracking such that corrective actio

are taken to prevent loss of primary containme

leak-tightness. The AMP is therefore augment

to require surface examination for detection of 

cracking during the period of extended operati

Ensures that coatings are properly examined.

The scope of 2004 edition of ASME Section X

Subsection IWE, as approved in 10 CFR 50.55

does not include Seals and Gaskets. Seals an

Gaskets are covered in scope of 10 CFR Part 

Appendix J. Thus XI.S4, “10 CFR Part 50, 
April 2011 II-447 NUREG-1950

Table II-22. Revision 2 Differences from Chapter XI, Structural Aging Management Programs, GALL Rep

Their Technical Bases

Location of 

Change Summary of Significant Changes Technical Basis for Change 

basis fatigue analysis.

Changed IWE-2430 to IWE-2420. Accordingly, the 

requirements based on IWE-2420 are defined, 

which are different from what was defined in 

Revision 1, when IWE-2430 was used.

Added acceptance criteria for cracking of stainless 

steel penetration sleeves, dissimilar metal welds, 

bellows, and steel components that are subject to 

cyclic loading but have no current licensing basis 

fatigue analysis.

Deleted reference to Table-3410-1 and replaced 

with IWE-3500.

Deleted reference to 10 CFR 50.55a(b)(ix)(D).

Appendix J,” is the applicable AMP.

The deletion of the Table IWE-2500-1 categor

eliminates the need for revising GALL Report 

program elements each time the ASME Code 

Edition is issued. The parameters monitored fo

coated surfaces are specified in ASME Section 

Subsection IWE-2310.Components subject to 

cyclic loading are susceptible to cracking 

consistent with the GALL Report.

ASME Section XI, Subsection IWE 2004 editio

Table 2500-1, as incorporated in 10 CFR 50.5

provides the requirements for the extent and 

frequency of examinations. Table 2500-1 requ

no additional general visual examinations each 

inspection period.

VT-3 examination may not detect fine cracks t

could occur as a result of cyclic loading and ar

only pressure-tested as part of the containmen

Type A Integrated Leak Rate Test (ILRT). The 

frequency of Type A test is every 10 years and 

could be extended for up to 15 years if a licens

implements Option B, performance-based test

accordance with 10 CFR Part 50 Appendix J. T

ILRT frequency thus may not provide for early 

detection of cracking such that corrective actio

are taken to prevent loss of primary containme

leak-tightness. The program is therefore 

augmented to require surface examination for 

detection of cracking during the period of exten

operation.

The reference to IWE-2430 is incorrect. The 

paragraph has been replaced by IWE-2420 in 

later edition of ASME Section XI, Subsection IW
NUREG-1950 II-448 April 2011

Table II-22. Revision 2 Differences from Chapter XI, Structural Aging Management Programs, GALL Rep

Their Technical Bases

Location of 

Change Summary of Significant Changes Technical Basis for Change 

The added acceptance criteria provides 

reasonable assurance that identified cracking 

evaluated or corrected prior to a loss of an 

intended function. The criteria are consistent w

provisions of IWE and the requirements of 10 C

Part 50 Appendix B.

Table 3410-1 does not exist in later editions of 

IWE. IWE-3500 specifies the corrective actions 

acceptance standards are not met.

10 CFR 50.55a(b)(ix)(D) does not exist in the 2

issue of the regulation. 10 CFR 50.55a 

(b)(2)(ix)(D) exists but refers to IWE-2430, whi

has been replaced by IWE-2420. 

XI.S2 ASME Section XI, Subsection IWL

General

Preventive Actions

Parameters 

Monitored/ 

Inspected 

Detection of Aging 

Effects

In the program description and in various elements 

as appropriate, added to monitor free water in the 

prestressing tendon anchorage areas. 

Revised to implement generic changes described 

in Section II.5.2.

Clarified for monitoring of prestressing tendon 

corrosion protection medium so that its chemistry 

stays within the limits established in IWL.

Parameters Monitored is revised to include 

additional monitoring of tendons, when removed 

when containment cutout is needed to facilitate 

replacement of steam generator or reactor vessel 

head.

Added monitoring for free water.

Deleted the description of tendon type, and added 

“accessible” to concrete surfaces that require 

visual examination.

Several changes made for consistency with AS

Code Section XI, 2004 edition.

See Section II.5.2 for basis.

Provides mitigation actions.

Tables IWL-2521-1 and 2521-2, referenced in 

Element 3, provide sufficient details for 

examination requirements. Inaccessible concre

surface areas are exempt from visual examina

in accordance with IWL-1220.

VT 3C, VT 1, VT 1C are replaced by General 

Visual and Detailed Visual Examination in IWL

2500 Subsection of 2004 edition of ASME Sec

XI Code years. General Visual Examination an

Detailed Visual Examination are not modified i

CFR 50.55a, except for qualification of person

performing the visual examinations.
April 2011 II-449 NUREG-1950

Table II-22. Revision 2 Differences from Chapter XI, Structural Aging Management Programs, GALL Rep

Their Technical Bases

Location of 

Change Summary of Significant Changes Technical Basis for Change 

Deleted VT-3C, VT-1, and VT-1C visual 

examinations and replaced with General Visual 

and Detailed Visual Examinations.

XI.S3 ASME Section XI, Subsection IWF

General

Scope of Program 

Preventive Actions

Parameters 

Monitored/ 

Inspected 

Detection of Aging 

Effects

Monitoring and 

Trending

Acceptance Criteria

Revised to implement generic changes described 

in Section II.5.2.

Deleted duplicate information that is already 

included in the ASME Code.

Revised to include the components included in the 

scope of the program. Accordingly revised 

Elements 3, 4, and 5 to include recommendations 

for in-scope components.

For structural bolting moved into this program from 

mechanical AMP XI.M18, added a statement that 

for structural bolting consisting of ASTM A325, 

ASTM F1852, and/or ASTM A490 bolts, the 

preventive actions for storage, lubricants, and 

SCC potential discussed in Section 2 of RCSC 

(Research Council for Structural Connections) 

publication “Specification for Structural Joints 

Using ASTM A325 or A490 Bolts” need to be 

used.

Deleted information from Table IWF-2500-1. 

Added parameters to be monitored and inspected 

for each component in scope of program.

Clarified that high-strength structural bolting 

susceptible to SCC is monitored for cracking.

Added guidance for detecting aging effects of all 

components in the scope of the program. VT-3 

examination specified by IWF is supplemented by 

surface, volumetric, or feel for components whose 

Section II.5.2 for basis.

Information existing in ASME Code does not n

to be repeated in the program.

Components were not identified.

High-strength bolting is used for nuclear steam 

supply system (NSSS) and piping support 

components, where these preventive actions a

applicable. A provision of preventive actions fo

other structural bolting recommended using RC

publication.

No need to repeat information from the ASME 

Code.

Not all high-strength bolts are susceptible to S

The supplemental detection requirements are 

added consistent with IWF and to ensure that 

aging effects are detected prior to a loss of 

component- or structure-intended function.

These requirements are specified in ASME Co

Subsection IWL.

Ensure that all components in scope of progra

have acceptance criteria defined.
NUREG-1950 II-450 April 2011

Table II-22. Revision 2 Differences from Chapter XI, Structural Aging Management Programs, GALL Rep

Their Technical Bases

Location of 

Change Summary of Significant Changes Technical Basis for Change 

aging effects cannot be detected by VT-3 

examination alone.

Added trending recommendations based on 

ASME Code.

Specific criteria are provided for unacceptable 

conditions, either based on ASME Code or, if not 

covered by the Code, then unacceptable 

conditions are identified.

XI.S4 10 CFR Part 50, Appendix J

General

Program 

Description

Revised to implement generic changes described 

in Section II.5.2.

Added that “Appendix J requires a general 

inspection of the accessible interior and exterior 

surfaces of the containment structure and 

components be performed prior to any Type A 

test.”

See Section II.5.2 for basis.

The program description does not discuss the 

pretest requirements, such as the structural 

inspection of containment surfaces. It is requir

by 10 CFR Part 50 Appendix J.

XI.S5 Masonry Walls

General

Parameters 

Monitored/ 

Inspected 

Detection of Aging 

Effects

Revised to implement generic changes described 

in Section II.5.2.

Clarified that fire barrier masonry walls are 

covered by the fire protection AMP XI.M26 and 

associated steel supports are covered by 

structures monitoring AMP XI.S6. 

Added cracking, separation, and shrinkage.

Added an inspection frequency of once every 5 

years, or more frequently, in areas where cracking 

is observed.

See Section II.5.2 for basis

Provides an option to use XI.M26 or XI.S6.

As explained in EPRI Report 1002950, Aging 

Effects for Structures and Structural Compone

(Structural Tools) Revision 1, masonry block w

are constructed from lightweight concrete bloc

grout, and mortar, and may or may not be 

reinforced. Thus, the aging effects/mechanism

masonry block walls are generally the same as 

those of concrete walls. Concrete walls in this 

environment are susceptible to loss of materia

and cracking due to freeze-thaw.

Makes it consistent with ACI-349-3R, Edition 
April 2011 II-451 NUREG-1950

Table II-22. Revision 2 Differences from Chapter XI, Structural Aging Management Programs, GALL Rep

Their Technical Bases

Location of 

Change Summary of Significant Changes Technical Basis for Change 

1996.

XI.S6 Structures Monitoring

General

Scope of Program

Parameters 

Monitored/ 

Inspected

Detection of Aging 

Effects

Revised to implement generic changes described 

in Section II.5.2.

Revised to include periodic sampling and testing 

of groundwater and the need to assess the impact 

of any changes in its chemistry on below grade 

concrete structures. 

Clarifies that the scope of this program includes all 

structures, structural components, component 

supports, and structural commodities in the scope 

of license renewal that are not covered by other 

structural AMPs.

Revised to clarify the parameters to be monitored 

for concrete, steel, structural bolting, structural 

sealants, elastomeric vibration isolators, ground 

water chemistry, settlement monitoring, etc.

Revised to include a recommended inspection 

frequency not to exceed 5 years for the in-scope 

structures, settlement monitoring, and monitoring 

of ground water chemistry. Also revised to provide 

recommendations for plants with non-aggressive 

water and for plants with aggressive water.

See Section II.5.2 for basis.

Periodic sampling and testing of ground water 

necessary to establish whether groundwater 

chemistry is aggressive. Its results establish 

whether plant-specific activities are necessary 

ensure that aging effects of concrete in 

inaccessible areas are required. All applicants 

have committed to periodically sample and tes

ground water during the period of extended 

operation.

Provides information on structures and 

components within the scope of the program.

Establishes a link between parameters monito

and the aging effect being addressed

Establishes frequencies. Establishes that for 

plants with aggressive water, a plant-specific 

program needs to be implemented.

XI.S7 RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants

General

Scope of Program

Detection of Aging 

Effects

Revised to implement generic changes described 

in Section II.5.2.

Revised to include steel or wood piles, and 

sheeting required for the stability of embankments 

and channel slopes, and miscellaneous steel, 

such as sluice gates and trash racks. Also added 

See Section II.5.2 for basis

Some applicants have identified these 

components in their scope of water-control 

structures

Periodic sampling and testing of ground water 

necessary to establish if ground water chemist
NUREG-1950 II-452 April 2011

Table II-22. Revision 2 Differences from Chapter XI, Structural Aging Management Programs, GALL Rep

Their Technical Bases

Location of 

Change Summary of Significant Changes Technical Basis for Change 

recommendations for monitoring and inspecting 

and acceptance criteria for these components in 

Elements 3, 4 and 5.

Revised to include ground water monitoring for 

inaccessible, below-grade, and submerged 

concrete structural elements.

aggressive. Its results establish if plant-specific 

activities are necessary to ensure that aging 

effects of concrete in inaccessible areas are 

required. All applicants have committed to 

periodically sample and test ground water duri

the period of extended operation.

XI.S8 Protective Coating Monitoring and Maintenance Program

Program 

Description

Scope of Program

Added ASTM D5163-08 and EPRI Report 

1003102

Revised to include any Service Level I coatings 

that are credited by the licensee for preventing 

loss of material due to corrosion in accordance 

with XI.S1.

The ASTM standard is endorsed by RG 1.54 a

is considered consistent with this program. In 

addition, Electric Power Research Institute (EP

Report 1003102, “Guidelines for Inspection an

Maintenance of Safety-related Protective 

Coatings,” provides additional information on t

ASTM standard guidelines.

As stated in RG 1.54, Service Level I coatings 

used in areas inside the containment where th

coating failure could adversely affect the opera

of post-accident fluid systems and thereby imp

safe shutdown. Thus, the evaluated program 

attributes are for the purpose of effectively 

managing aging effects of coatings to prevent 

degradations that could prevent clogging of EC

suction strainers. Applicants who credit preven

actions of the AMP for managing loss of mater

due to corrosion should provide plant-specific 

operating experience to demonstrate that their 

program is effective.
April 2011 II-453 NUREG-1950

Table II-23. Revision 2 Differences from Chapter XI, Electrical Aging Management Programs, GALL Repo

Their Technical Bases

Changed Program 

Elements Summary of Significant Changes Technical Basis for Change 

XI.E1 Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Quali

Requirements

Title

Program 

Description 

Parameters 

Monitored/ 

Inspected 

Detection of Aging 

Effects

General

The definition for adverse localized 

environment in the Program Description 

was revised. Parameters Monitored and 

Detection of Aging Effects were both 

revised to include new aging effects 

degradation indications. Removed sampling 

discussion and references to sampling 

throughout AMP.

The AMP’s title was changed to provide technical 

accuracy and clarification and to differentiate it from A

XI.E6.

The definition and discussion for adverse localized 

environment in the Program Description was revised 

the purposes of clarification, simplification, and 

consistency. The term “reduced insulation resistance

Parameters Monitored and Detection of Aging Effects 

more accurately defines the aging effect associated w

cable and connection insulation materials and is 

consistent with the terminology in GALL Chapter VI. 

Operating Experience has shown the population of th

affected components to be small enough to eliminate 

sampling and visually inspect “all accessible electrica

cables and connections installed in adverse localized 

environments.”

XI.E2 Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qual

Requirements Used in Instrumentation Circuits

Title

Program 

Description

Preventive Actions 

Corrective Actions

The title of the AMP was changed. 

Consolidated and rearranged the “adverse 

localized environment” discussion in the 

Program Description. Preventive Actions 

and Corrective Actions clarified. 

 

The AMP’s title was changed for technical accuracy a

clarification. The adverse localized environment 

discussion in the Program Description was revised fo

clarification and consistency with AMP XI.E1, “Preven

Actions,” changed from “No actions are taken as part 

this program...” to “This is a performance monitoring 

program and no actions are taken as part of this 

program.” Corrective Actions clarified to include actio

required on when an unacceptable condition or situat

is identified. 

 
NUREG-1950 II-454 April 2011

Table II-23. Revision 2 Differences from Chapter XI, Electrical Aging Management Programs, GALL Repo

Their Technical Bases

Changed Program 

Elements Summary of Significant Changes Technical Basis for Change 

XI.E3 Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements

Title

Program 

Description

Scope of the 

Program

Preventive Actions

Parameters 

Monitored/ 

Inspected

Detection of Aging 

Effects

Operating 

Experience

The title of the AMP was changed and a 

change was made to include all 

inaccessible or underground cables down to 

and including 400 volts within the scope of 

LR subject to significant moisture. 

Deemphasized water trees and revised to 

primarily consider water intrusion 

(significant moisture) in the Program 

Description and Scope of Program. 

Preventive Actions was revised to include 

event driven inspections for water collection 

and the manhole inspection frequency was 

revised to annually. The frequency for 

testing power cables in Detection of Aging 

Effects was revised to at least once every 6 

years.

The change from “Medium Voltage” to “Power” lowere

the voltage range this AMP will be dealing with to ≥ 40

from the traditional medium voltage range (>1 kv to 3

kv) and was made to include 480 volt ECCS motors a

one plant based on a commitment with NEI. Summar

Report: GL 2007-01 supports and justifies the change 

from medium voltage to “Power” and the voltage rang

≥400 v.

Current NRC inspections have identified that ensuring 

operability of dewatering devices prior to any known o

predicted flooding events is key to preventing potenti

cable submergence and that a 2-year manhole inspe

frequency is not adequate to prevent cable 

submergence. Requiring that manhole inspections be 

performed at least annually is consistent with NRC 

Inspection Procedures. Staff revised the testing 

frequency based on Operating Experience but not to 

exceed 6 years. More frequent testing is required to 

monitor the cable performance and the test frequency 

should be adjusted based on test results as determin

through the corrective action process.

XI.E4 Metal Enclosed Bus

Program 

Description

Parameters 

Monitored 

Detection of Aging 

Effects

Acceptance Criteria

Revised Program Description to include the 

three different types of MEB buses. The 

Scope of Program was revised to include 

different AMP options for inspecting 

external surfaces and elastomers. The 

Program Description, Parameters 

Monitored, and Detection of Aging Effects 

were all revised to include a new aging 

effect: increased resistance of connection. 

The Program Description was revised to provide 

clarification on each of the different types of MEB bus

The Program Description and Scope of Program were 

revised to include external surfaces and elastomers w

options to inspect under XI.S6 or XI.M38, as applicab

In addition, the AMR line items for the external surfac

of MEB enclosure assemblies was expanded to inclu

different applicable MEAP combinations. The term 

“increased resistance of connection” more accurately 
April 2011 II-455 NUREG-1950

Table II-23. Revision 2 Differences from Chapter XI, Electrical Aging Management Programs, GALL Repo

Their Technical Bases

Changed Program 

Elements Summary of Significant Changes Technical Basis for Change 

In Parameters Monitored/Inspected, 

Detection of Aging Effects, and Acceptance 

Criteria, the inspection criteria for 

components was revised. In addition, the 

sampling criteria was revised in Detection of 

Aging Effects. 

describes the actual aging effect resulting from therm

cycling and ohmic heating. The sampling criteria in 

Detection of Aging Effects was revised to be consiste

with the criteria approved in XI.M-32, “One-Time 

Inspection.”

XI.E5 Fuse Holders

Program 

Description

Scope of Program 

Parameters 

Monitored 

Added a new purpose statement as the 1st 

paragraph in Program Description. Revised 

the aging stressors as applicable in the 

Program Description, Scope of Program, 

and Parameters Monitored. 

A new Purpose Statement was added to maintain 

consistency with the format established in AMPs XI.E

through XI.E4. Revised Program Description, Scope 

Program, and Parameters Monitored to include the te

increased resistance of connection as it more accura

describes the actual aging effect resulting from chem

contamination, corrosion, and oxidation and maintain 

consistency with GALL Chapter VI. 

XI.E6 Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements

General

Program 

Description

Major change to incorporate Final License 

Renewal Interim Staff Guidance LR-ISG2007-02. Added a new purpose statement 

as the 1st paragraph in Program 

Description. New sampling criteria were 

added in Detection of Aging Effects.

Incorporated Final License Renewal Interim Staff 

Guidance LR-ISG-2007-02, which provides for one-ti

testing. A new Purpose Statement was added to main

consistency with the format established in AMPs XI.E

through XI.E4 and revised to include a 10 CFR 50.49 

reference. Detection of Aging Effects added sampling 

criteria that is consistent with XI.E4 and XI.M32, One 

Time Inspection. 
NUREG-1950 II-456 April 2011

Table II-24. Revision 2 Chapter I Differences from GALL Report, Rev. 1 and Their Technical Bases

Location of Change Summary of Significant Changes Technical Basis for Change 

General Revised to provide guidance when an 

exception is needed in the LRA for ASME 

Code editions.

Revised to state that in some AMPs, 

specific requirements in ASME Section XI 

need to be augmented in order to ensure 

adequate aging management consistent 

with the license renewal rule.

Revised to provide guidance for plants 

whose 10-year ISI term expires and the 

plant updates to a later version of the 

Code during the LRA review process.

Revised to provide guidance for relief 

requests when the ten-year inspection 

period extends into the period of extended 

operation.

To clarify that an exception is to be justified to use an 

ASME Section XI edition or addenda that is (1) earlier 

the 1995 edition, (2) not endorsed in 10 CFR 50.55a, 

(3) not adequate for license renewal as discussed in t

FRN issuing the 10 CFR 50.55a amendment.

The AMP may make additional recommendations for 

managing aging above and beyond the code 

requirements. For example, the code-required VT-1 m

not detect fine cracks, and the AMP is augmented to h

volumetric examination performed.

Ensures that the LRA is updated for those AMPs that 

impacted by the change in edition of the ASME Code.

The approved relief request remains in place until the 

year period ends.
April 2011 II-457 NUREG-1950

Table II-25. Revision 2 General BWR Vessel Internals Aging Management Programs Differences from GA

and Technical Bases

Location of Change Summary of Significant Changes Technical Basis for Change C

General 

The BWRVIP is an active program. It was

recognized that it is not feasible for the SRPLR and GALL Reports to be kept up to date 

with the EPRI BWRVIP program. 

Discrepancies between member utility 

BWRVIP program implementation and the 

program documents and recommendations

cited in the SRP-LR and GALL Report were 

corrected. The BWRVIP maintains that 

license renewal guidance related to program 

implementation focuses on describing 

program elements and the related means of 

NRC oversight.

The staff will continue to use the Interim Staff 

guidance (ISG) process for interim updates to 

the license renewal guidance documents. 

Updated industry guidance can be 

incorporated via an ISG. No changes are 

necessary for the GALL or SRP-LR.

An alternative approach is being adopted 

(preamble to Chapter XI) that will allow use of 

later revisions of industry guidance that have 

been approved by the staff for generic use 

(via ISG, RG, topical report review, 

incorporation into 10 CFR). If only plant 

specific precedent exists for use, then 

applicants may request to use the later 

revision by taking an exception to the GALL 

Report and reference the precedent which 

provides high degree of confidence the 

exception will be acceptable.

The BWRVIP program provides design 

criteria. When accepted by the NRC they are 

incorporated into the GALL. The GALL has 

been revised to reflect that actual plant 

procedures to implement the BWRVIP repair 

and design criteria are plant specific.

91

April 2011 III-1 NUREG-1950

III REVISION 2 CHANGES TO SRP-LR, REV. 1 AND THEIR TECHNICAL BASES

There are many changes that have been made to the NUREG-1800 (SRP-LR), Rev. 1 

document. Some changes are the result of the drafting of the May 2010 Public Comment 

version of Revision 2. Additional changes are the result of public comments that were received 

during the public comment period. The final version of NUREG-1800, Rev. 2 has consolidated 

these changes. This section of NUREG-1950 provides a summary of notable technical changes 

that were made in Revision 2 and provides the technical basis for each change.

Several generic and general changes were made to the SRP-LR, Rev. 1. These include:

 FSAR Supplements for all AMPs are now included as Table 3.0-1 in Chapter 3.0 (Old 

Table 3.X-2). This change provides one location where the FSAR Supplement 

information for each AMP is provided in one table, instead of in Tables in Chapters 3.1, 

3.2, 3.3, 3.4, 3.5, and 3.6.

 Table 3.X-2 now lists the AMPs applicable to that chapter. This table used to show 

FSAR Supplement information. Instead it now identifies only the AMPs, with the titles 

that are applicable to the chapter. 

 In the Chapter 3.X.2, Acceptance Criteria, and Chapter 3.X.3, Review Procedures, 

information related to AMRs and AMPs was separated. AMRs are now included in 

Chapters 3.X.2.1 and 3.X.3.1; AMPs are included in new Chapters 3.X.2.4 and 3.X.3.4.

 Extra columns were added in Table 3.X-1 to identify the GALL Report Rev. 1 and Rev. 2 

AMR item numbers (as “Rev1 Item” and “Rev2 Item”).

 Tables 4.1-2 and 4.1-3 were clarified to distinguish between generic TLAAs and potential 

plant-specific TLAAs.

 Appendix A, Chapter A.1.2. 3 (Aging Management Program Elements) was revised to 

clarify the information in each element. Appropriate information was provided in each 

element. This Appendix was used to ensure that the GALL Report AMPs provided 

recommendations in each element that are consistent with this Appendix.

The specific changes to each SRP-LR chapter are discussed in Sections III.1 through III.4 of 

this document. A summary of the changes to each chapter and their technical bases are 

presented in Table III-1 through Table III-17. The public comments that resulted in these 

changes are found in Table IV-15 through Table IV-19. 

III.1 Chapter 1 – Administrative Information 

There are no major technical changes in Chapter 1 of the SRP-LR. The title of Table 1.1-1 has 

been clarified to indicate that the checklist is used to determine the renewal application’s 

acceptability for docketing. Language in the table has been clarified. Number VII has been 

added to ensure that the conclusions drawn from the completion of the checklist are clearly 

stated in a manner that allows the reviewer to determine whether the application is reasonably 

complete, meets the Acceptance Review Checklist criteria I through V, and is recommended for 

docketing.

III.2 Chapter 2 – Scoping and Screening Methodology

There are no major technical changes to SRP-LR Chapter 2. The references have been 

updated, and the review responsibilities have been changed to “Assigned branch(es)” rather 

than to any particular branch. Some clarification has been made to individual subchapters.
NUREG-1950 III-2 April 2011

III.3 Chapter 3 – Aging Management Reviews (AMRs) Rollup Tables

The AMR items presented in the GALL Report, Rev. 2 tables are combined and grouped 

according to function or material, environment, aging effect and aging management program

(MEAP) to better categorize the aging of certain systems in specific environments and to 

facilitate the review of AMRs when conducting safety reviews at plants applying for license 

renewal. The tables of these groupings are found in the SRP-LR and are referred to as “AMR 

rollup tables.” New MEAP combinations are discussed in Section III.3.1 below. The method for 

combining or “rolling up” these AMRs is discussed in Section III.3.2. 

In addition to a discussion of the rollup tables, this section of NUREG-1950 presents the 

changes that were made in individual subchapters of the SRP-LR and the technical bases for 

these changes. Chapter 3.0 of the SRP-LR provides guidance to the staff conducting safety 

reviews of the AMPs or AMRs. A new table was added to this subchapter to provide a FSAR 

supplement for the aging management of applicable systems. This was formerly found under 

individual subchapters 3.1 through 3.6, but has been consolidated in subchapter 3.0 to make 

the SRP-LR more streamlined. Other changes to subchapter 3.0 are presented in Table III-3. 

Table III-4 through Table III-9 summarize the changes and technical bases for the changes to 

subchapters 3.1 through 3.6, respectively. The public comments associated with these changes 

are found in Table IV-17. 

III.3.1 Discussion of New MEAP Combinations

New MEAP combinations in NUREG-1800, Rev. 2, result from the addition of new AMR items in 

the GALL Report, Chapters II through VIII, as described in Section II.1. New MEAP 

combinations are included in the rollup methodology described in Section III.3.2 and may result 

in new items in the AMR rollup tables or may be included in previously existing items if the new 

combination is closely related to an MEAP combination already in Revision 1 or the GALL 

Report.

III.3.2 AMR Rollup Methodology

The methodology for developing the AMR rollup tables in the SRP-LR is based on a principal of 

grouping together components, materials, and environments in which a single aging effect or a 

small group of closely related aging effects can be adequately managed by an AMP or by a 

combination of programs that is consistent with the AMPs described in Chapter XI of the GALL 

Report. The rollup tables are intended to (a) aid the applicant in preparation of the LRA by 

providing groups of component, material, environment, aging effect, and AMP combinations that 

have been previously reviewed and evaluated by the staff and (b) provide a process roadmap 

for the staff to follow in preparing its safety evaluation of a license renewal application.

The methodology used in the rollup tables is similar, but not identical, for all chapters in the 

GALL Report and the SRP-LR. 

• For AMR items in Chapters V, VI, VII, and VIII, a single rollup methodology is used. 

Within a single GALL chapter, AMR items with identical values for AMP, AERM, further 

evaluation, and further evaluation reference are initially collected together in individual 

groups. The initial rolled-up component description is then reviewed to determine 

whether the initial grouping, based solely on AMP, AERM, and further evaluation, has 

resulted in a grouping in which the individual relationships of component, material, and 

environment are not clearly maintained. If, based on technical review, an initial grouping 

is found to result in an unacceptable rolled-up component description, the initial grouping 

is subdivided into smaller groupings with identical AMP, AERM, and Further Evaluation 

content, but with different component, material, and/or environment descriptions. 
April 2011 III-3 NUREG-1950

• For AMR items in the GALL Chapters II, III, and IV

III.4 Chapter 4 – Time-Limited Aging Analyses (TLAAs)

, the rollup methodology differs from 

that of the previously described chapters by grouping on an AMP description that is 

consistent with, but not directly contained in, the underlying GALL Report AMR items. 

Also, the rolled up component description typically does not include the environment,

and, for some rolled-up lines in Chapter III, the component description encompasses the 

components in the AMR items that are grouped together.

There are six subchapters to the SRP-LR Chapter 4 on generic Time-Limited Aging Analyses 

(TLAAs). Subchapter 4.1 discusses how to recognize when a TLAA may be appropriate, and 

changes to that subchapter are summarized in Table III-10, along with the technical bases for 

these changes. Subchapter 4.2 deals with reactor vessel neutron embrittlement; subchapter 4.3 

covers metal fatigue; subchapter 4.4 discusses the environmental qualification of electrical 

equipment; subchapter 4.5 presents a discussion of concrete containment tendon prestress; 

and subchapter 4.6 discusses inservice local metal containment corrosion analyses. The 

changes and technical bases for these changes are shown in Table III-11 through Table III-16, 

respectively. The public comments associated with these changes are found in Table IV-18. 

III.5 SRP-LR Appendices A.1, A.2, and A.3

Changes to the three appendices in the SRP-LR are summarized in Table III-17, along with the 

technical bases for these changes. These appendices are A.1 – Generic Aging Management 

Reviews, A.2 – Quality Assurance for Aging Management Programs (Branch Technical Position 

IQMB-1), and A.3 – Generic Safety Issues Related to Aging (Branch Technical Position RLSB2). The public comments associated with these changes are found in Table IV-19. 
NUREG-1950 III-4 April 2011

Table III-1. Revision 2 Chapter 1 Differences from SRP-LR, Rev. 1 and Their Technical Bases

Location of Change Summary of the Change Technical Basis for Change 

N/A There are no notable technical changes to Chapter 1 

of the SRP-LR. N/A 

Table III-2. Revision 2 Chapter 2 Differences from SRP-LR, Rev. 1 and Their Technical Bases 

Location of Change Summary of the Change Technical Basis for Change 

2.1.3.1.3

Paragraph 5

Added new final sentence “However, the staff review 

is based on the plant-specific current licensing basis, 

regulatory requirements, and offsite power design 

configurations.” This is similar to Chapter 2.5.2.1.1.

To clarify that for SBO "coping duration" a

"recovery" phase, plant-specific CLB, 

regulatory requirements and offsite powe

design should be considered.

2.5.2.1.1

Third bullet; 

Components Within the 

Scope of SBO (10 CFR 

50.63) 

Clarified that the electrical distribution equipment out 

to the first circuit breaker with the offsite distribution 

system (i.e., equipment in the switchyard) should be 

included within the SBO restoration equipment scope. 

Added new final sentence "However, the staff review 

is based on the plant-specific current licensing basis, 

regulatory requirements, and offsite power design 

configurations."

Identified the scope of SBO restoration 

equipment. Also clarified that plant-specif

CLB, regulatory requirements and offsite 

power design should be considered.
April 2011 III-5 NUREG-1950

Table III-3. Revision 2 Chapter 3.0 Differences from SRP-LR, Rev. 1 and Their Technical Bases 

Location of Change Summary of the Change Technical Basis for Change 

Table 3.0-1 Revised to reflect the changes that were made to the 

AMPs in Chapter XI of the GALL Report.

Table 3.0-1 

XI.E3

The frequency for cable testing was reduced from 

once every 10 years to at least once every 6 years. 

The once every 10 year testing protocol w

based on historical data. However, GL 20

01 provides data on failures to increase th

frequency. Based on plant-specific operat

experience, but not to exceed a maximum 

testing interval of once every 6 years. Cha

to 6 years is consistent with wording in AM

XI.E3.

Table 3.0-1 

XI.E3

The frequency for water collection inspections are

established and performed based on plant-specific 

operating experience with water accumulation in the 

manholes (i.e., operation of dewatering devices 

should be inspected and operation verified prior to any 

known or predicted flooding events). The inspection 

frequency was reduced from once every two (2) years. 

to at least annually. 

All changes incorporated are consistent w

XI.E3.

Table 3.0-1 

XI.S1

The ASME Section XI, Subsection IWE program Code 

edition and addenda information was corrected.

All changes incorporated are consistent w

XI.S1. 
NUREG-1950 III-6 April 2011

Table III-4. Revision 2 Chapter 3.1 (Reactor Vessels, Internals, Coolant System) Differences from SRP-LR

Technical Bases

Location of Change Summary of the Change Technical Basis for Change 

3.1 General

Revised to implement generic changes described

in Section III.

Revised to reflect the changes that were made to 

the AMR items in Chapter IV of the GALL Report.

See Section III for basis for generic changes. 

See Section II for basis of specific AMR line-it

changes.

Table III-5. Revision 2 Chapter 3.2 (Engineered Safety Features) Differences from SRP-LR, Rev. 1 and Th

Location of Change Summary of the Change Technical Basis for Change 

3.2 General

Revised to implement generic changes described 

in Section III.

Revised to reflect the changes that were made to 

the AMR items in Chapter IV of the GALL Report.

See Section III for basis for generic changes. 

See Section II for basis of specific AMR line-it

changes.

Table III-6. Revision 2 Chapter 3.3 (Auxiliary Systems) Differences from SRP-LR, Rev. 1 and Their Techn

Location of Change Summary of the Change Technical Basis for Change 

3.3 General

Revised to implement generic changes described 

in Section III.

The chapters were revised to reflect the changes 

that were made to the AMR items in Chapter IV of 

the GALL Report.

See Section III for basis for generic changes. 

See Section II for basis of specific AMR line-it

changes.
April 2011 III-7 NUREG-1950

Table III-7. Revision 2 Chapter 3.4 (Steam and Power Conversion Systems) Differences from SRP-LR, Re

Technical Bases

Location of Change Summary of the Change Technical Basis for Change 

3.4 General

Revised to implement generic changes described 

in Section III.

Revised to reflect the changes that were made to 

the AMR items in Chapter IV of the GALL Report.

See Section III for basis for generic changes. 

See Section II for basis of specific AMR line-it

changes.

Table III-8. Revision 2 Chapter 3.5 (Structures and Components) Differences from SRP-LR, Rev. 1 and Th

Bases

Location of Change Summary of the Change Technical Basis for Change 

3.5 General Revised to implement generic changes described 

in Section III.

See Section III for basis for generic changes. 

See Section II for basis of specific AMR line-it

changes.

Table III-9. Revision 2 Chapter 3.6 (Electrical and Instrumentation Controls) Differences from SRP-LR, R

Technical Bases

Location of Change Summary of the Change Technical Basis for Change 

3.6 General

3.6.3.2

The SRP was revised to implement generic 

changes described in Section III.

Two of the subchapter titles were revised to reflect 

the changes that were made to the AMR line 

items in Chapter VI of the GALL Report.

See Section III for basis for generic changes. 

The titles for subchapters 3.6.2.2.2 and 3.6.2.

were revised to be in concert with GALL Chap

VI.A AMR Item changes.

See Section II for basis of specific AMR line-it

changes.
NUREG-1950 III-8 April 2011

Table III-10. Revision 2 Chapter 4.1 (Identification of TLAA) Differences from SRP-LR, Rev. 1 and Their T

Location of Change Summary of the Change Technical Basis for Change 

Tables 4.1-2 and 4.1-3 

Removed metal corrosion allowance, inservice

flaw growth analyses that demonstrate structure 

stability for 40 years, and high-energy line-break 

postulation based on fatigue cumulative usage 

factor from Table 4.1-2 and added them to Table 

4.1-3. 

Table 4.1-2 is for generic TLAA. These three 

items are plant-specific TLAAs and are theref

included in Table 4.1-3, which gives examples 

potential plant-specific TLAAs. 

Table III-11. Revision 2 Chapter 4.2 (Neutron Irradiation Embrittlement) Differences from SRP-LR, Rev. 1 

Technical Bases

Location of Change Summary of the Change Technical Basis for Change 

4.2.3.1.1.1

Added a statement that the applicant needs to identify the 

neutron fluence at the expiration of the license renewal 

period, that a staff-approved methodology must be used to 

determine neutron fluence, and that the methodology 

follows the guidance of NRC RG 1.190.

This statement is included in subsect

4.2.3.1.1.2, and is included here for 

consistency. 

4.2.3.1.1.2 Added the statement of Action Item 10 from the staff’s 

SER for BWRVIP-74. 

Specifies the action in addition to 

referencing the action item number. 

4.2.3.1.2.1

Added a statement that the applicant needs to identify the 

neutron fluence at the expiration of the license renewal 

period, that a staff-approved methodology must be used to 

determine neutron fluence, and whether the methodology

followed the guidance in NRC RG 1.190.

This statement is included in subchap

4.2.3.1.2.2, and is included here for 

consistency.

4.2.3.1.2.3 Added C(5) to state and/or Use of the Alternative PTS 

Rule. 

To meet the requirements of 75 FR 2

“Alternative Fracture Toughness 

Requirements for Protection Against 

Pressurized Thermal Shock Events,” 

January 4, 2010.
April 2011 III-9 NUREG-1950

Table III-11. Revision 2 Chapter 4.2 (Neutron Irradiation Embrittlement) Differences from SRP-LR, Rev. 1 

Technical Bases

Location of Change Summary of the Change Technical Basis for Change 

4.2.3.1.3.1 and 

4.2.3.1.3.2

Added a statement that the applicant needs to identify the 

neutron fluence at the expiration of the license renewal 

period, that a staff-approved methodology must be used to 

determine neutron fluence, and that the methodology 

follows the guidance of NRC RG 1.190.

This statement is included in these 

subchapters to make it consistent wit

similar statement for neutron fluence 

subchapters 4.2.3.1.1.1 and 4.2.3.1.1

4.2.3.1.3.3

Added new paragraph for pressure temperature (P/T) 

limits TLAA dispositioned per 10 CFR 54.21(c)(1)(iii) to 

state that updated P-T limits for the period of extended 

operation must be available prior to entering the period of 

extended operation. It also references and specifies 

Renewal Applicant Action Item 9 in the staff’s SER for 

BWRVIP-74 (Letter to C. Terry dated October 18, 2001).

Provides the applicant guidance on h

to disposition this TLAA when catego

(iii) is used to manage aging.

4.2.3.1.4

Deleted existing paragraph. Replaced with a new 

paragraph that provides guidance if an applicant desires 

inspection relief for elimination of circumferential weld 

inspection (BWRs) for the period of extended operation.

Based on this guidance, the applicant 

could disposition the TLAA under 10 

54.21(c)(1)(iii).

4.2.3.1.5 Added the statement of Action Item 12 from the staff’s 

SER for BWRVIP-74. 

Specifies the action in addition to 

referencing the action item number. 

Table 4.2-1 

Revised the FSAR Supplement summary for elimination of 

circumferential weld inspection and analysis of axial welds 

(for BWRs) to include the statement about inspection 

relief, and that the re-submittal under 10 CFR 50.55a(a)(3) 

should be completed before the period of extended 

operation. 

This change is needed based on the 

change made in subsection 4.2.3.1.4
NUREG-1950 III-10 April 2011

Table III-12. Revision 2 Chapter 4.3 (Metal Fatigue, Piping, and Components) Differences from SRP-LR, R

Technical Bases

Location of Change Summary of the Change Technical Basis for Change 

4.3.1

Revised the Areas of Review to specifically identify five 

areas: (1) CUF calculations for Code Class 1 

components designed to ASME Section III 

requirements, (2) B31.1 and ASME Code Class 2 and 3 

components, (3) environmental fatigue calculations for 

ASME Code Class 1 reactor coolant pressure boundary 

components, (4) potential fatigue assessments for BWR 

vessel internals components (potential TLAAs based on 

applicable applicant action items identified in applicable 

BWRVIP reports), and (5) potential fatigue-based flaw 

growth analyses or fatigue-based fracture mechanics 

analyses, including those for high-energy line breaks, 

reactor coolant pump (RCP) flywheels, reactor vessel 

metal bellows, and reactor vessel underclad cracking 

analyses.

This provides a listing of the generic an

potential areas of fatigue as listed in Ta

4.1-2, and 4.1-3. Provides guidance to 

applicants in development of license 

renewal applications.

4.3.2.1.1.3

GALL X.M1 title has been changed to “Fatigue 

Monitoring,” and reference to reactor coolant system 

(RCS) pressure boundary components only has been 

removed.

The staff agrees that more components 

than RCS pressure boundary have cycl

that need monitoring.

4.3.2.1.2 and 4.3.2.1.4

Combined these two sections for Piping Components 

Designed to USAS ANSI B31.1 Requirements and 

ASME Code Class 2 and 3 Components Designed to 

ASME Section III Requirements.

Subsection 4.3.2.1.4 referenced subsec

4.3.2.1.2 in SRP-LR Rev. 1, so it makes 

sense to combine these two subsection

4.3.2.1.2.3

Identified that AMP X.M1 provides an acceptable 

method for accepting implicit fatigue analyses under 

10 CFR 54.21(c)(1)(iii).

If components designed to USAS ANSI 

B31.1 requirements, and ASME Code C

2 and 3 Components Designed to ASM

Section III Requirements have a fatigue 

analysis performed per ASME Code Se

III requirements, then AMP X.M1 is 

acceptable for aging management.

4.3.2.1.3 and 4.3.3.1.3 Deleted 4.3.2.2, Generic Safety Issues. Added new 

subsections to address Environmental Fatigue 

This paragraph has been revised to pro

guidance and options for Fen calculatio
April 2011 III-11 NUREG-1950

Table III-12. Revision 2 Chapter 4.3 (Metal Fatigue, Piping, and Components) Differences from SRP-LR, R

Technical Bases

Location of Change Summary of the Change Technical Basis for Change 

Calculations for Code Class 1 Components. Identified 

the NUREG-CRs appropriate for calculating 

environmental correction factors for carbon and lowalloy steels, stainless steel, and nickel-alloy materials.

for carbon and low-alloy steels, stainles

steel, and nickel-alloy components.

4.3.2.1.4 and 4.3.3.1.4 Added new subsections for Potential Fatigue 

Assessments for BWR Vessel Internals Components. 

Provides clarity and ensures consistenc

The revised information in the elements 

used to provide consistency within each 

AMP for that element. Appropriate 

information is moved from one element 

another to ensure that the element is 

consistent with the revised chapter A.1.

4.3.2.1.5 and 4.3.3.1.5

Added new subsections for Potential Flaw Growth and 

Fracture Mechanics Analysis. It states that Chapter 

X.M1 in the GALL Report may not be used as a basis for 

accepting fatigue-based flaw growth analyses or fracture 

mechanics analyses in accordance with 10 CFR 

54.21(c)(1)(iii).

Provides clarity and ensures consistenc

The revised information in the elements 

used to provide consistency within each 

AMP for that element. Appropriate 

information is moved from one element 

another to ensure that the element is 

consistent with the revised chapter A.1.

Table III-13. Revision 2 Chapter 4.4 (Environmental Qualification of Electrical Equipment) Differences fro

and Their Technical Bases

Location of Change Summary of the Change Technical Basis for Change 

Chapter 4.4

Only programmatic and generic changes were 

made; no notable technical changes incorporated 

in Rev. 2, Chapter 4.4 of the SRP-LR.

N/A 
NUREG-1950 III-12 April 2011

Table III-14. Revision 2 Chapter 4.5 (Concrete Tendon Prestress) Differences from SRP-LR, Rev. 1 and T

Bases

Location of Change Summary of the Change Technical Basis for Change 

Table 4.5-1 Added example of FSAR Supplement summary 

for 10 CFR 54.21(c)(1)(iii). 

Provides an example in case TLAA is 

dispositioned per 10 CFR 54.21(c)(1)(iii). 

Table III-15. Revision 2 Chapter 4.6 (Metal Containment, Liner Plate, Penetrations Fatigue) Differences fr

and Their Technical Bases

Location of Change Summary of the Change Technical Basis for Change 

Chapter 4.6 There are no notable technical changes, only 

clarifications that are editorial in nature. N/A 

Table III-16. Revision 2 Chapter 4.7 (Plant-Specific TLAA) Differences from SRP-LR, Rev. 1 and Their Tec

Location of Change Summary of the Change Technical Basis for Change 

Chapter 4.7 There are no notable technical changes, only 

clarifications that are editorial in nature. N/A 

Table III-17. Revision 2 Appendix Differences from SRP-LR, Rev. 1 and Their Technical Bases

Location of Change Summary of the Change Technical Basis for Change 

Appendix A.1

Appendix A, Chapter A.1.2.3, and AMP Elements 

were revised to clarify the information in each 

element. 

Provides clarity and ensures consistency. The 

revised information in the elements is used to 

provide consistency within each AMP for that 
April 2011 III-13 NUREG-1950

Table III-17. Revision 2 Appendix Differences from SRP-LR, Rev. 1 and Their Technical Bases

Location of Change Summary of the Change Technical Basis for Change 

element. Appropriate information is moved fro

one element to another to ensure that the 

element is consistent with the revised Chapte

A.1.2.3.

Appendix A.2

Appendix A.3

There are no notable technical changes, only 

clarifications that are editorial in nature. N/A 

April 2011 IV-1 NUREG-1950

IV ANALYSIS AND DISPOSITION OF PUBLIC COMMENTS ON MAY 2010 PUBLIC 

COMMENT DRAFT, REVISION 2

IV.1 Public Comment Solicitation and Management

The NRC issued a public comment draft of NUREG-1800 and -1801, Rev. 2 on April 1, 2010. 

The Federal Register Notice (FR Vol. 75, No. 95 page 27838 - 27840), published on May 18, 

2010, began a 45-day public comment period. In addition, the NRC conducted a public 

workshop from May 26-28, 2010 at its Rockville, MD headquarters to initiate a dialogue with the 

public and to introduce them to some of the major changes between Revisions 1 and 2 of the 

guidance documents. The purpose of the workshop was to provide: 

 an opportunity for the staff to inform the public about the draft GALL and SRP-LR 

NUREGs

 an opportunity for an exchange of information about the draft NUREGs

 an opportunity for stakeholders to ask questions about the draft NUREGs

 a forum for stakeholders to provide informal feedback on the drafts

The staff was particularly interested in comments that addressed the safety review, 

effectiveness, and efficiency of the license renewal process. Formal comments on the draft 

NUREGs were to be provided through means identified in the Federal Register Notice (e.g., 

written letter, e-mail, fax, and web forms) and were not accepted during the workshop. The 

workshop was not intended as a forum to resolve comments on the draft NUREGs. The staff 

anticipated that some topics would not be discussed fully due to time limitations. The staff also 

conducted focused public meetings following the close of the comment period for in-depth 

technical discussions of some AMPs, particularly XI.M41.

The staff previously made available to the public a draft preliminary version of portions of the 

guidance documents on December 19, 2009. These preliminary drafts were also discussed at a 

public meeting held from January 4-6, 2010 at NRC headquarters. All public comments were put 

into a public comments database developed specifically for the purpose of managing and 

dispositioning public comments. The database allowed the input of the comments, identification 

of the commenter and their affiliation, acceptance or rejection of comment’s recommended 

actions, and the technical basis of each decision. Each comment in the database received a 

unique comment number related to the document and chapter/subchapter or AMR Item to which 

it applied. This unique number can be used to identify and track comments, their disposition, 

and the resulting changes throughout this guidance document in the appropriate tables. 

Table IV-1 presents a list of commenters, their affiliation, their reference number, and the 

ADAMS Accession Number for each comment. The first column contains a comment number 

that allows each comment to be cross-referenced in various tables throughout this document.

Over 500 public comments were received on the SRP-LR and GALL Report. 

Any changes to the LRGDs that have a technical basis that states that the change is editorial in 

nature, simple clarification, or the correction of typographical errors does not constitute a 

notable technical change and will not be captured in the Tables of Section II or III in this 

document. For a number of public comments, the NRC staff took the liberty to clarify and/or 

paraphrase the comment. Those comments are denoted with a “[...]” around the text which the 

staff clarified and/or paraphrased.
NUREG-1950 IV-2 April 2011

IV.2 Disposition of Public Comments on the May 2010 Draft GALL Report, Rev. 2

All of the public comments on the May 2010 Public Comment Draft, GALL Report, Rev. 2 that 

were received as a result of the public comment period are presented in Table IV-2 through 

Table IV-15 below. The comments are divided by GALL Report chapter; Chapter XI is 

subdivided into mechanical, structural, and electrical AMP comments. Each comment has a 

unique comment number. The comment, along with any rationale or justification provided by the 

commenter, is summarized. The disposition of each comment is provided, particularly whether 

the comment was accepted by NRC staff and resulted in a change to the GALL Report, Rev. 1, 

or whether the comment was rejected and did not cause any changes to the GALL Report. 

Finally, the technical basis for each comment disposition is provided, explaining either why the 

comment was rejected, or why the changes prompted by the comments were implemented.

The summary of the comments for each GALL chapter, their dispositions, and the technical 

basis for the dispositions are presented in Table IV-2 through Table IV-15. 

IV.3 Disposition of Public Comments on the May 2010 Draft SRP-LR, Rev. 2

All of the public comments on the May 2010 Public Comment Draft SRP-LR, Rev. 2 that were 

received as a result of the public comment period are presented in Table IV-16 through Table 

IV-20 below. Each comment has a unique comment number and references the comment 

number provided by the commenter. The comment, along with any rationale or justification 

provided by the commenter, is summarized. The disposition of each comment is provided, 

particularly whether the comment was accepted by NRC staff and resulted in a change to the 

SRP-LR, Rev. 1, or whether the comment was rejected and did not cause any changes to the 

SRP-LR. Finally, the technical basis for each comment disposition is provided, explaining either 

why the comment was rejected or why the changes were implemented.

The summary of the comments for each SRP-LR chapter, their dispositions, and the technical 

basis for the dispositions are presented in Table IV-16 through Table IV-20. 
April 2011 IV-3 NUREG-1950

Table IV-1. Identification of Public Comments on May 2010 Draft GALL Report, 

Rev. 2, Originator, and ADAMS Accession Number

Commenter Ref. No. Comment No. ADAMS Accession No.

Boyd Taylor, Pacific Northwest National Laboratory (PNNL) 6/8/10

1 132 ML101610407

Omesh Chopra 6/10/2010

1 (SRP) 130 ML101660084

2 (SRP) 131 ML101660084

Nuclear Energy Institute 6/30/2010

X.M1-1 133 ML101830328

X.M1-2 134 ML101830328

X.M1-3 135 ML101830328

X.M1-4 136 ML101830328

X.M1-5 137 ML101830328

X.M1-6 138 ML101830328

X.M1-7 139 ML101830328

X.M1-8 140 ML101830328

X.M1-9 895 ML101830328

X.M1-10 142 ML101830328

X.M1-11 143 ML101830328

XI.M2-1 896 ML101830328

XI.M2-2 897 ML101830328

XI.M2-3 1037 ML101830328

XI.M3-1 1036 ML101830328

XI.M4-1 149 ML101830328

XI.M6-1 150 ML101830328

XI.M6-2 151 ML101830328

XI.M6-3 152 ML101830328

XI.M7-1 153 ML101830328

XI.M7-2 154 ML101830328

XI.M9-1 155 ML101830328

XI.M9-2 156 ML101830328

XI.M9-3 157 ML101830328

XI.M9-4 777 ML101830328
NUREG-1950 IV-4 April 2011

Table IV-1. Identification of Public Comments on May 2010 Draft GALL Report, 

Rev. 2, Originator, and ADAMS Accession Number

Commenter Ref. No. Comment No. ADAMS Accession No.

XI.M9-5 778 ML101830328

XI.M9-6 779 ML101830328

XI.M9-7 780 ML101830328

XI.M11B-1 158 ML101830328

XI.M11B-2 159 ML101830328

XI.M11B-3 160 ML101830328

XI.M11B-4 161 ML101830328

XI.M12-1 162 ML101830328

XI.M12-2 163 ML101830328

XI.M12-3 164 ML101830328

XI.M16A-1 165 ML101830328

XI.M16A-2 166 ML101830328

XI.M16A-3 167 ML101830328

XI.M17-1 168 ML101830328

XI.M17-2 169 ML101830328

XI.M18-1 170 ML101830328

XI.M18-2 171 ML101830328

XI.M18-3 172 ML101830328

XI.M18-4 173 ML101830328

XI.M18-5 174 ML101830328

XI.M18-6 175 ML101830328

XI.M19-1 1038 ML101830328

XI.M19-2 1039 ML101830328

XI.M22-1 1035 ML101830328

XI.M24-1 179 ML101830328

XI.M24-2 180 ML101830328

XI.M24-3 181 ML101830328

XI.M26-1 182 ML101830328

XI.M26-2 183 ML101830328

XI.M26-3 184 ML101830328

XI.M26-4 185 ML101830328

XI.M30-1 186 ML101830328

XI.M30-2 187 ML101830328
April 2011 IV-5 NUREG-1950

Table IV-1. Identification of Public Comments on May 2010 Draft GALL Report, 

Rev. 2, Originator, and ADAMS Accession Number

Commenter Ref. No. Comment No. ADAMS Accession No.

XI.M30-3 188 ML101830328

XI.M31-1 189 ML101830328

XI.M32-1 190 ML101830328

XI.M35-1 191 ML101830328

XI.M35-2 192 ML101830328

XI.M35-3 193 ML101830328

XI.M35-4 194 ML101830328

XI.M36-1 971 ML101830328

XI.M36-2 972 ML101830328

XI.M36-4 197 ML101830328

XI.M38-1 198 ML101830328

XI.M39-1 898 ML101830328

XI.M40-1 200 ML101830328

XI.M40-2 201 ML101830328

XI.M40-3 202 ML101830328

XI.S1-1 899 ML101830328

XI.S1-2 900 ML101830328

XI.S1-3 901 ML101830328

XI.S1-4 902 ML101830328

XI.S1-5 903 ML101830328

XI.S1-6 208 ML101830328

XI.S3-1 904 ML101830328

XI.S3-2 210 ML101830328

XI.S3-3 906 ML101830328

XI.S5-1 907 ML101830328

XI.S6-1 908 ML101830328

XI.S6-2 214 ML101830328

XI.S6-3 909 ML101830328

XI.S7-1 910 ML101830328

XI.S7-2 911 ML101830328

XI.S7-3 912 ML101830328

XI.S8-1 913 ML101830328

1 298 ML101830328
NUREG-1950 IV-6 April 2011

Table IV-1. Identification of Public Comments on May 2010 Draft GALL Report, 

Rev. 2, Originator, and ADAMS Accession Number

Commenter Ref. No. Comment No. ADAMS Accession No.

2 299 ML101830328

3 301 ML101830328

4 306 ML101830328

5 311 ML101830328

6 313 ML101830328

7 316 ML101830328

8 318 ML101830328

10 319 ML101830328

11 321 ML101830328

12 326 ML101830328

13 338 ML101830328

14 350 ML101830328

15 351 ML101830328

16 353 ML101830328

17 356 ML101830328

18 (SRP) 358 ML101830328

19 (SRP) 360 ML101830328

20 (SRP) 361 ML101830328

21 (SRP) 362 ML101830328

22 (SRP) 363 ML101830328

23 (SRP) 364 ML101830328

24 (SRP) 365 ML101830328

25 (SRP) 366 ML101830328

4.2.2.1.1.2 (SRP) 511 ML101830328

4.2.2.1.4.1 (SRP) 512 ML101830328

4.2.3.1.1 (SRP) 513 ML101830328

4.2.3.1.1.2 (SRP) 514 ML101830328 

4.2.3.1.3 (SRP) 515 ML101830328

4.2.3.1.3.1 (SRP) 516 ML101830328

4.3.2 (SRP) 517 ML101830328

4.3.1 (SRP) 518 ML101830328

4.3.2.1.1.3 (SRP) 519 ML101830328

4.3.2.1.3 (SRP) 520 ML101830328
April 2011 IV-7 NUREG-1950

Table IV-1. Identification of Public Comments on May 2010 Draft GALL Report, 

Rev. 2, Originator, and ADAMS Accession Number

Commenter Ref. No. Comment No. ADAMS Accession No.

4.3.2.1.4 (SRP) 521 ML101830328

4.3.2.1.5.3 (SRP) 522 ML101830328

4.3.3.1.1.2 (SRP) 523 ML101830328

Nuclear Energy Institute 6/30/2010

VI.A-1 256 ML101830328

VI.A-2 257 ML101830328

VI.A-3 258 ML101830328

XI.E1-1 259 ML101830328

XI.E1-2 260 ML101830328

XI.E1-3 261 ML101830328

XI.E1-4 262 ML101830328

XI.E1-5 263 ML101830328

XI.E1-6 264 ML101830328

XI.E2-1 265 ML101830328

XI.E3-1 266 ML101830328

XI.E3-4 267 ML101830328

XI.E3-5 268 ML101830328

XI.E3-6 269 ML101830328

XI.E3-7 270 ML101830328

XI.E3-8 277 ML101830328

XI.E3-9 278 ML101830328

XI.E3-10 279 ML101830328

XI.E3-13 281 ML101830328

XI.E3-14 282 ML101830328

XI.E4-1 283 ML101830328

XI.E4-2 284 ML101830328

XI.E4-3 285 ML101830328

XI.E4-4 286 ML101830328

XI.E4-5 287 ML101830328

XI.E4-6 288 ML101830328

XI.E4-7 289 ML101830328

XI.E5-1 290 ML101830328
NUREG-1950 IV-8 April 2011

Table IV-1. Identification of Public Comments on May 2010 Draft GALL Report, 

Rev. 2, Originator, and ADAMS Accession Number

Commenter Ref. No. Comment No. ADAMS Accession No.

XI.E5-2 291 ML101830328

XI.E5-3 292 ML101830328

XI.E5-4 293 ML101830328

XI.E6-1 294 ML101830328

XI.E6-2 295 ML101830328

XI.E6-3 296 ML101830328

XI.E6-4 297 ML101830328

SRP 2.1.3-1 241 ML101830328

SRP 2.1.3-2 242 ML101830328

SRP 2.5-1 243 ML101830328

SRP 2.5-2 244 ML101830328

SRP 2.5-3 245 ML101830328

SRP 2.5-4 246 ML101830328

SRP 3.0-1 247 ML101830328

SRP 3.0-2 248 ML101830328

SRP 3.0-3 249 ML101830328

SRP 3.0-4 250 ML101830328

SRP 3.0-5 251 ML101830328

SRP 3.0-14 252 ML101830328

SRP 3.0-16 253 ML101830328

SRP 3.6-1 254 ML101830328

SRP 3.6-2 255 ML101830328

Electric Power Research Institute BWRVIP 6/29/2010

1 916 ML101830255

2 917 ML101830255

3 918 ML101830255

XI.M2-1 920 ML101830255

XI.M2-2 921 ML101830255

XI.M2-3 922 ML101830255

XI.M2-4 923 ML101830255

XI.M4-1 374 ML101830255
April 2011 IV-9 NUREG-1950

Table IV-1. Identification of Public Comments on May 2010 Draft GALL Report, 

Rev. 2, Originator, and ADAMS Accession Number

Commenter Ref. No. Comment No. ADAMS Accession No.

XI.M4-2 375 ML101830255

XI.M4-3 376 ML101830255

XI.M6-1 377 ML101830255

XI.M7-1 378 ML101830255

XI.M7-2 379 ML101830255

XI.M8-1 380 ML101830255

XI.M8-2 381 ML101830255

XI.M8-3 382 ML101830255

XI.M8-4 383 ML101830255

XI.M9-1 384 ML101830255

XI.M9-2 385 ML101830255

XI.M9-3 386 ML101830255

XI.M9-4 387 ML101830255

XI.M9-5A 388 ML101830255

XI.M9-5B 1019 ML101830255

XI.M9-7B 1020 ML101830255

XI.M9-6 389 ML101830255

XI.M9-7A 390 ML101830255

XI.M9-8 391 ML101830255

XI.M9-9 392 ML101830255

XI.M9-10 393 ML101830255

XI.M9-11 394 ML101830255

XI.M9-12 395 ML101830255

XI.M9-13 396 ML101830255

XI.M9-14 397 ML101830255

XI.M9-15 398 ML101830255

XI.M9-16 399 ML101830255

XI.M9-17 400 ML101830255

XI.M9-18A 401 ML101830255

XI.M9-18B 1021 ML101830255

XI.M9-19A 402 ML101830255

XI.M9-19B 1022 ML101830255

XI.M9-19C 1023 ML101830255
NUREG-1950 IV-10 April 2011

Table IV-1. Identification of Public Comments on May 2010 Draft GALL Report, 

Rev. 2, Originator, and ADAMS Accession Number

Commenter Ref. No. Comment No. ADAMS Accession No.

XI.M9-20 403 ML101830255

Pilgrim Watch 7/1/2010

XI.M41-PW1 405 ML101880267

XI.M41-PW2 410 ML101880267

XI.M41-PW3 411 ML101880267

XI.M41-PW4 504 ML101880267

XI.M41-PW5 929 ML101880267

XI.M41-PW6 930 ML101880267

XI.M41-PW7 931 ML101880267

XI.M41-PW8 932 ML101880267

XI.M41-PW9 933 ML101880267

XI.M41-PW10 934 ML101880267

XI.M41-PW11 935 ML101880267

XI.M41-PW12 936 ML101880267

XI.M41-PW13 937 ML101880267

XI.M41-PW14 938 ML101880267

XI.M41-PW15 939 ML101880267

XI.M41-PW16 940 ML101880267

XI.M41-PW17 941 ML101880267

XI.M41-PW18 942 ML101880267

Supplemental Pilgrim Watch 7/1/2010

P1 (Ray Shadis, New 

England Coalition) 

1112 ML102420742

P2 (John H Fitzgerald, III) 1119 ML102420742

PW1 (John H Fitzgerald, III) 1123 ML102420742

P3 (John H Fitzgerald, III) 1125 ML102420742

PW4 (John H Fitzgerald, III) 1128 ML102420742

PW5 (John H Fitzgerald, III) 1126 ML102420742

PW5(2) (John H Fitzgerald, 

III)

1129 ML102420742

PW6 (John H Fitzgerald, III) 1143 ML102420742

P7 (John H Fitzgerald, III) 1146 ML102420742
April 2011 IV-11 NUREG-1950

Nuclear Energy Institute 7/1/2010

1 943 ML101880269

2 944 ML101880269

3 863 ML101880269

4 864 ML101880269

5 945 ML101880269

6 866 ML101880269

7 867 ML101880269

8 868 ML101880269

9 869 ML101880269

10 870 ML101880269

11 871 ML101880269

12 872 ML101880269

13 873 ML101880269

14 874 ML101880269

15 876 ML101880269

16 877 ML101880269

17 946 ML101880269

18 879 ML101880269

19 880 ML101880269

20 947 ML101880269

21 881 ML101880269

22 882 ML101880269

23 883 ML101880269

24 884 ML101880269

25 885 ML101880269

26 886 ML101880269

27 887 ML101880269

28 888 ML101880269

29 948 ML101880269 

30 949 ML101880269

31 950 ML101880269

32 951 ML101880269

33 952 ML101880269

34 953 ML101880269
NUREG-1950 IV-12 April 2011

Table IV-1. Identification of Public Comments on May 2010 Draft GALL Report, 

Rev. 2, Originator, and ADAMS Accession Number

Commenter Ref. No. Comment No. ADAMS Accession No.

35 954 ML101880269

36 955 ML101880269

37 956 ML101880269

38 957 ML101880269

Comment 39 (SRP) 837 ML101880269

Comment 40 (SRP) 958 ML101880269

Comment 41 (SRP) 959 ML101880269

Comment 42 (SRP) 960 ML101880269

Comment 43 (SRP) 961 ML101880269

Comment 44 (SRP) 962 ML101880269

Comment 45 (SRP) 963 ML101880269

Comment 46 (SRP) 964 ML101880269

Comment 47 (SRP) 965 ML101880269

VII.K-x 434 ML101880269

VII.C1-x 505 ML101880269

VII.C1-x 430 ML101880269

VII.C2-x, VII.H2-x 437 ML101880269

VII.C1-x 438 ML101880269

V.E-x, VII.I-x, VIII.H-x 439 ML101880269

VII.C2-x, VII.H2-x, VIII.E-x 442 ML101880269

VII.C1-x 445 ML101880269

VII.C2-x 446 ML101880269

IV.E-x, V.F-x, VII.J-x, VIII.I-x 447 ML101880269

V.E-x, VII.I-x, VIII.H-x 451 ML101880269

V.E-x, VII.I-x, VIII.H-x 454 ML101880269

V.E-x, VII.I-x 457 ML101880269

VII.C1-x, VII.F2-x, VIII.G-x 459 ML101880269

III.B2-x 462 ML101880269

VII.J-x 463 ML101880269

VII.E5 506 ML101880269

IX.D 507 ML101880269

Nuclear Energy Institute 6/7/2010 (Comments on May 2010 draft XI.M41)
April 2011 IV-13 NUREG-1950

Table IV-1. Identification of Public Comments on May 2010 Draft GALL Report, 

Rev. 2, Originator, and ADAMS Accession Number

Commenter Ref. No. Comment No. ADAMS Accession No.

XI.M41-1 889 ML101610406

XI.M41-2 890 ML101610406

XI.M41-3 106 ML101610406

XI.M41-4 891 ML101610406

XI.M41-5 892 ML101610406

XI.M41-6 893 ML101610406

XI.M41-7 894 ML101610406

XI.M41-8 111 ML101610406

XI.M41-9 112 ML101610406

XI.M41-10 113 ML101610406

XI.M41-11 114 ML101610406

XI.M41-12 115 ML101610406

XI.M41-13 116 ML101610406

XI.M41-14 117 ML101610406

XI.M41-15 118 ML101610406

XI.M41-16 119 ML101610406

XI.M41-17 120 ML101610406

XI.M41-18 121 ML101610406

XI.M41-19 122 ML101610406

XI.M41-20 123 ML101610406

Nuclear Energy Institute 7/1/2010 (comments on June 18, 2010 XI.M41 draft)

XI.M41-1 508 ML101880269

XI.M41-2 509 ML101880269

XI.M41-3 966 ML101880269

XI.M41-4 967 ML101880269

XI.M41-5 968 ML101880269

XI.M41-6 969 ML101880269

XI.M41-7 1191 ML101880269

XI.M41-8 1192 ML101880269

XI.M41-9 1193 ML101880269

XI.M41-10 475 ML101880269

XI.M41-11 1194 ML101880269
NUREG-1950 IV-14 April 2011

Table IV-1. Identification of Public Comments on May 2010 Draft GALL Report, 

Rev. 2, Originator, and ADAMS Accession Number

Commenter Ref. No. Comment No. ADAMS Accession No.

XI.M41-12 1195 ML101880269

XI.M41-13 478 ML101880269

XI.M41-14 1196 ML101880269

XI.M41-15 1197 ML101880269

XI.M41-16 1198 ML101880269

XI.M41-17 1199 ML101880269

XI.M41-18 1200 ML101880269

XI.M41-19 970 ML101880269

XI.M41-20 1201 ML101880269

XI.M41-21 1202 ML101880269

XI.M41-22 487 ML101880269

XI.M41-23 488 ML101880269

XI.M41-24 489 ML101880269

XI.M41-25 490 ML101880269

XI.M41-26 491 ML101880269

Nuclear Energy Institute 8/30/2010 (supplemental comments on Aug 2010 XI.M41 draft

ML102320585) 

XI.M41-3 (sup) 1154 ML102420732

XI.M41-23 (sup) 1085 ML102420732

XI.M41-28 (sup) 1087 ML102420732

Electric Power Research Institute PWR Internals 7/1/2010

1 973 ML101880266

2 974 ML101880266

3 975 ML101880266

4 976 ML101880266

5 977 ML101880266

6 978 ML101880266

7 979 ML101880266

8 980 ML101880266

9 981 ML101880266

10 982 ML101880266

11 983 ML101880266
April 2011 IV-15 NUREG-1950

Table IV-1. Identification of Public Comments on May 2010 Draft GALL Report, 

Rev. 2, Originator, and ADAMS Accession Number

Commenter Ref. No. Comment No. ADAMS Accession No.

12 984 ML101880266

13 985 ML101880266

14 986 ML101880266

15 987 ML101880266

16 988 ML101880266

17 989 ML101880266

18 990 ML101880266

19 991 ML101880266

20 992 ML101880266

21 993 ML101880266

22 994 ML101880266

23 995 ML101880266

24 996 ML101880266

25 997 ML101880266

26 998 ML101880266

27 999 ML101880266

28 1000 ML101880266

29 1001 ML101880266

30 1002 ML101880266

31 1003 ML101880266

32 1004 ML101880266

33 1005 ML101880266

34 1006 ML101880266

35 1007 ML101880266

36 1008 ML101880266

37 1009 ML101880266

38 1010 ML101880266

39 1011 ML101880266

40 1012 ML101880266

41 1013 ML101880266

42 1014 ML101880266

43 1015 ML101880266

44 1016 ML101880266
NUREG-1950 IV-16 April 2011

Table IV-1. Identification of Public Comments on May 2010 Draft GALL Report, 

Rev. 2, Originator, and ADAMS Accession Number

Commenter Ref. No. Comment No. ADAMS Accession No.

PWR Owners Group

XI.M31 492 ML101890552

XI.M31-3 493 ML101890552

XI.M31-4 494 ML101890552

XI.M31-5 495 ML101890552

XI.M31-7 496 ML101890552

XI.M31-10 497 ML101890552

XI.M31-REF 498 ML101890552

Yogen Garud 6/30/2010

1 524 ML101880265

2 525 ML101880265

3 526 ML101880265

4 527 ML101880265

Paul Blanch 8/24/2010

XI.M41-1(a) 1152 ML102371265

XI.M41-1(b) 1232 ML102371265

XI.M41-1(c) 1203 ML102371265

XI.M41-1(d) 1204 ML102371265

XI.M41-1(e) 1205 ML102371265

XI.M41-1(f) 1206 ML102371265

XI.M41-2(a) 1153 ML102371265

XI.M41-2(b) 1207 ML102371265

XI.M41-2(c) 1208 ML102371265

XI.M41-2(d) 1209 ML102371265

XI.M41-3(a) 1231 ML102371265

XI.M41-3(b) 1210 ML102371265

XI.M41-3(c) 1211 ML102371265

XI.M41-3(d) 1212 ML102371265

XI.M41-3(e) 1213 ML102371265

XI.M41-3(f) 1214 ML102371265

XI.M41-4(a) 1156 ML102371265
April 2011 IV-17 NUREG-1950

Table IV-1. Identification of Public Comments on May 2010 Draft GALL Report, 

Rev. 2, Originator, and ADAMS Accession Number

Commenter Ref. No. Comment No. ADAMS Accession No.

XI.M41-4(b) 1215 ML102371265

XI.M41-4(c) 1216 ML102371265

XI.M41-5(a) 1159 ML102371265

XI.M41-5(b) 1217 ML102371265

XI.M41-5(c) 1218 ML102371265

XI.M41-6(a) 1161 ML102371265

XI.M41-6(b) 1219 ML102371265

XI.M41-6(c) 1220 ML102371265

XI.M41-7(a) 1221 ML102371265

XI.M41-7(b) 1163 ML102371265

XI.M41-8(a) 1222 ML102371265

XI.M41-8(b) 1164 ML102371265

XI.M41-8(c) 1223 ML102371265

XI.M41-9(a) 1165 ML102371265

XI.M41-9(b) 1229 ML102371265

XI.M41-10 1166 ML102371265

XI.M41-11 1167 ML102371265

XI.M41-12 1168 ML102371265

XI.M41-13 1169 ML102371265

XI.M41-14 1170 ML102371265

XI.M41-15 1171 ML102371265

XI.M41-16(a) 1172 ML102371265

XI.M41-16(b) 1224 ML102371265

XI.M41-17 1173 ML102371265

XI.M41-18 1174 ML102371265

XI.M41-19(a) 1175 ML102371265

XI.M41-19(b) 1225 ML102371265

XI.M41-20(a) 1176 ML102371265

XI.M41-20(b) 1226 ML102371265

XI.M41-21(a) 1177 ML102371265

XI.M41-21(b) 1227 ML102371265

XI.M41-22 1178 ML102371265

XI.M41-23 1179 ML102371265
NUREG-1950 IV-18 April 2011

Table IV-1. Identification of Public Comments on May 2010 Draft GALL Report, 

Rev. 2, Originator, and ADAMS Accession Number

Commenter Ref. No. Comment No. ADAMS Accession No.

XI.M41-24 1180 ML102371265

Paul Blanch 8/30/2010

Comment 1 1181 ML102420706

Comment 2 1182 ML102420706

Comment 3 1183 ML102420706

Comment 4 1184 ML102420706

Comment 5 1185 ML102420706

Comment 6 1186 ML102420706 

Comment 7 1187 ML102420706

Comment 8 1188 ML102420706

Nuclear Energy Institute – Preliminary 8/6/2010

Comment 1 1092 ML102180192

Comment 2 1095 ML102180192

Comment 3 1097 ML102180192

Comment 4 1099 ML102180192

Comment 5 1101 ML102180192

Structural Integrity Associates 8/20/10

Comment 1 1155 ML102350027

Comment 2 1157 ML102350027

Comment 3 1158 ML102350027

Comment 4 1160 ML102350027

Comment 5 1162 ML102350027

Pilgrim Watch 8/24/10

XI.M41-PW1 1079 ML102371274

XI.M41-PW2 1080 ML102371274

XI.M41-PW3 1081 ML102371274

XI.M41-PW4 1083 ML102371274

XI.M41-PW5 1084 ML102371274

XI.M41-PW6 1086 ML102371274

XI.M41-PW7 1088 ML102371274
April 2011 IV-19 NUREG-1950

Table IV-1. Identification of Public Comments on May 2010 Draft GALL Report, 

Rev. 2, Originator, and ADAMS Accession Number

Commenter Ref. No. Comment No. ADAMS Accession No.

XI.M41-PW8 1089 ML102371274

XI.M41-PW8(2) 1090 ML102371274

XI.M41-PW9 1091 ML102371274

XI.M41-PW10 1093 ML102371274

XI.M41-PW11 1094 ML102371274

XI.M41-PW12 1096 ML102371274

XI.M41-PW13 1098 ML102371274

XI.M41-PW14 1100 ML102371274

XI.M41-PW15 1102 ML102371274

XI.M41-PW16 1103 ML102371274

XI.M41-PW17 1105 ML102371274

XI.M41-PW18 1106 ML102371274

XI.M41-PW19 1107 ML102371274

XI.M41-PW20 1108 ML102371274

XI.M41-PW21 1109 ML102371274

XI.M41-PW22 1110 ML102371274

XI.M41-PW23 1111 ML102371274

XI.M41-PW24 1113 ML102371274

XI.M41-PW25 1134 ML102371274

XI.M41-PW26 1115 ML102371274

XI.M41-PW27 1116 ML102371274

XI.M41-PW28 1117 ML102371274

XI.M41-PW29 1118 ML102371274

XI.M41-PW30 1120 ML102371274

XI.M41-PW31 1121 ML102371274

XI.M41-PW32 1122 ML102371274

XI.M41-PW33 1124 ML102371274

XI.M41-PW34 1190 ML102371274

XI.M41-PW35 1127 ML102371274

XI.M41-PW36 1130 ML102371274

XI.M41-PW37 1131 ML102371274

XI.M41-PW38 1132 ML102371274

XI.M41-PW39 1133 ML102371274
NUREG-1950 IV-20 April 2011

Table IV-1. Identification of Public Comments on May 2010 Draft GALL Report, 

Rev. 2, Originator, and ADAMS Accession Number

Commenter Ref. No. Comment No. ADAMS Accession No.

XI.M41-PW40 1114 ML102371274

XI.M41-PW41 1135 ML102371274

XI.M41-PW42 1136 ML102371274

XI.M41-PW43 1137 ML102371274

XI.M41-PW44 1138 ML102371274 

XI.M41-PW45 1139 ML102371274

XI.M41-PW46 1140 ML102371274

XI.M41-PW47 1141 ML102371274

XI.M41-PW48 1142 ML102371274

XI.M41-PW49 1144 ML102371274

XI.M41-PW50 1145 ML102371274

XI.M41-PW51 1147 ML102371274

XI.M41-PW52 1148 ML102371274

XI.M41-PW53 1149 ML102371274

XI.M41-PW54 1150 ML102371274

XI.M41-PW55 1151 ML102371274

Nuclear Energy Institute 8/20/10

XI.M41-1 1051 ML102320585

XI.M41-2 1053 ML102320585

XI.M41-3 1054 ML102320585

XI.M41-4 1055 ML102320585

XI.M41-5 1056 ML102320585

XI.M41-6 1057 ML102320585

XI.M41-7 1058 ML102320585

XI.M41-8 1059 ML102320585

XI.M41-9 1060 ML102320585

XI.M41-10 1061 ML102320585

XI.M41-10(2) 1062 ML102320585

XI.M41-11 1063 ML102320585

XI.M41-12 1064 ML102320585

XI.M41-13 1065 ML102320585

XI.M41-14 1066 ML102320585
April 2011 IV-21 NUREG-1950

Table IV-1. Identification of Public Comments on May 2010 Draft GALL Report, 

Rev. 2, Originator, and ADAMS Accession Number

Commenter Ref. No. Comment No. ADAMS Accession No.

XI.M41-15 1067 ML102320585

XI.M41-16 1068 ML102320585

XI.M41-17 1069 ML102320585

XI.M41-18 1070 ML102320585

XI.M41-19 1071 ML102320585

XI.M41-20 1072 ML102320585

XI.M41-21 1073 ML102320585

XI.M41-22 1074 ML102320585

XI.M41-23 1075 ML102320585

XI.M41-24 1076 ML102320585

XI.M41-25 1077 ML102320585

XI.M41-26 1078 ML102320585

Beyond Nuclear 7/2/2010

XI.M41-1 1228 ML101930270

Structural Integrity Associates, Inc., Steve Biagiotti

XI.M41 1230 ML102500311
NUREG-1950 IV-22 April 2011

Table IV-2. Analysis and Disposition of Public Comments on Chapter I, May 2010 Public Comment Draft G

Rev. 2

Comment 

Number

Location in 

Document 

and/or 

Commenter 

Reference No.

Public Comment NRC Disposition Tech

N/A Chapter I There were no notable technical changes that 

resulted from public comments, only 

clarifications that are editorial in nature.

N/A N/A
April 2011 IV-23 NUREG-1950

Table IV-3. Analysis and Disposition of Public Comments on Chapter II, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Public Comment NRC Disposition Tech

311 II.A3.CP-98

II.B4.CP-98

ML101830328, 

Comment 5

(DELETE) Chapter XI.S1, “ASME Section XI, 

Subsection IWE,” and (KEEP) Chapter XI.S4, 

“10 CFR Part 50, Appendix J”

IWE will not detect loss of leak tightness. 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Though XI.S4 

Appendix J) is 

measuring lea

containment c

XI.S1 (ASME 

Subsection IW

pressure retain

of penetration 

pressure retain

performed for 

tightness.

298 II.A1.CP-101 

ML101830328, 

Comment 1

Chapter XI.S2, “ASME Section XI, Subsection 

IWL,” (ADD) or Chapter XI.S6, “Structure 

Monitoring”

Evidence of degradation due to this aging 

effect can also be identified under Structure 

Monitoring. 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Evidence of de

this aging effe

identified unde

Monitoring). E

Parameters M

monitoring con

GALL Report A

revised to add 

306 II.A1.CP-98 

IIA2.CP-98

II.B1.2.CP-63

II.B2.1.CP-63

II.B2.2.CP-63

ML101830328, 

Comment 4

4. Borated water spills and water ponding on 

the concrete floor are not

(1) Spills are not common. 

common and when 

detected are cleaned up or diverted to a sump 

in a timely manner.

(2) To be consistent with II.B3.2.CP-98.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

OE indicates t

water leakage 

containments 

changes requi

and II.A2.CP-9

299 II.A2.CP-71

II.B3.1.CP-71

ML101830328, 

Chapter XI.S6, “Structures Monitoring,” (ADD) 

or Chapter XI.S2, “ASME Section XI, 

Subsection IWL”

Evidence of degradation due to this aging 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

XI.S2 (ASME 

Subsection IW

monitoring con

GALL Report A
NUREG-1950 IV-24 April 2011

Table IV-3. Analysis and Disposition of Public Comments on Chapter II, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Public Comment NRC Disposition Tech

Comment 2 effect may be identified under IWL. have been made. revised to add 

301 II.A2.CP-69 

II.B1.2.CP-105 

II.B2.2.CP-105 

II.B3.1.CP-69

II.B3.2.CP-105

ML101830328, 

Comment 3

Chapter XI.S2, “ASME Section XI, Subsection 

IWL,” (ADD) or Chapter XI.S6, “Structure 

Monitoring”

Evidence of degradation due to this aging

effect can also be identified under Structure 

Monitoring. 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Evidence of de

this aging effe

identified unde

Monitoring.” 

313 II.A3.CP-152 

II.B4.CP-152

III.A4.TP-301

ML101830328, 

Comment 6

Chapter XI.S8, “Protective Coating Monitoring 

and Maintenance” (ADD) or plant specific 

program in response to GL 98 - 04 for those 

plants not crediting coatings for loss of 

material. 

All plants have developed plant specific 

program in response to GL 98 - 04 to monitor 

and maintain condition of containment 

coatings.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The plant-spec

to be revised (

industry stand

approved by N

316 II.A3.CP-150 

II.B4.CP-150

ML101830328, 

Comment 7

(DELETE) Structural (REPLACE WITH) 

Pressure - retaining bolting in Structures and 

Component column

Chapter XI.S1, “ASME Section XI, Subsection 

IWE” applies to containment pressure - 

retaining bolting only.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Agree that XI.S

XI, Subsection 

pressure-retai

318 II.A3.CP-148 

II.A3.CP-150

ML101830328, 

Comment 8

(DELETE) Structural (REPLACE WITH)

Pressure - retaining bolting in the Structures 

and Component column.

Chapter XI.S1, “ASME Section XI, Subsection 

IWE” applies to containment pressure - 

retaining bolting only.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Agree that XI.S

XI, Subsection 

pressure-retai
April 2011 IV-25 NUREG-1950

Table IV-3. Analysis and Disposition of Public Comments on Chapter II, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Public Comment NRC Disposition Tech

319 II.A3.CP-36 

II.B4.CP-36

ML101830328, 

Comment 10

Chapter XI.S1, “ASME Section XI, Subsection 

IWE” and, Chapter XI.S4, “10 CFR Part 50, 

Appendix J” (Note: IWE examination category 

E-F, surface examination of dissimilar metal 

welds, specified in 1992 edition of ASME 

Code is recommended) 

Examination category E-F does no longer 

exist on latest edition of the ASME Code. If 

augmentation to code requirements is 

necessary they should be addressed in the 

program of Chapter XI.S1, “ASME Section XI, 

Subsection IWE.”

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Agree that cat

exist in ASME 

Element 3 of A

Section XI, Su

augmented to 

for inaccessibl

the vent-line b

A or Type B te
NUREG-1950 IV-26 April 2011

Table IV-4. Analysis and Disposition of Public Comments on Chapter III, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Public Comment NRC Disposition Tech

321 III.A1.TP-114

III.A2.TP-114

III.A3.TP-114

III.A4.TP-114

III.A5.TP-114

ML101830328, 

Comment 11

Plant-specific aging management program. 

(DELETE) The implementation of 10 CFR 

50.55a and ASME Section XI, Subsection IWL 

would not be able to identify the reduction of 

strength and modulus of elasticity due to 

elevated temperature. Thus, for any portions 

of concrete containment that exceed specified 

temperature limits, further evaluations are 

warranted. (KEEP) Subsection CC-3400 of 

ASME Section III, Division 2, specifies the 

concrete temperature limits for normal 

operation or any other long-term period. The 

temperatures shall not exceed 150°F except 

for local areas, such as around penetrations, 

which are not allowed to exceed 200°F. If 

significant equipment loads are supported by 

concrete at temperatures exceeding 150°F, 

an evaluation of the ability to withstand the 

postulated design loads is to be made. 

Higher temperatures than given above may 

be allowed in the concrete if tests and/or 

calculations are provided to evaluate the 

reduction in strength and modulus of elasticity 

and these reductions are applied to the design 

calculations.

IWL does not apply to Group I Structures

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

IWL does not a

Structures.

326 III.A1.TP-300

III.A2.TP-300

III.A3.TP-300

III.A4.TP-300

Delete these line items. These line items are 

not supported by OE and should be removed 

or limited to the specific type of bolting 

material and sizes where cracking has been 

found on NSSS supports. It is not warranted 

The staff disagrees 

with this comment. 

AMR line was not 

deleted; however, 

AMP XI.S6 was 

ASTM A325, A

ASTM A 490 b

used for Civil-s

no OE to sugg

could be susce
April 2011 IV-27 NUREG-1950

Table IV-4. Analysis and Disposition of Public Comments on Chapter III, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Public Comment NRC Disposition Tech

III.A5.TP-300

III.A7.TP-300

III.A8.TP-300

III.A9.TP-300

III.B2.TP-300

III.B3.TP-300

III.B4.TP-300

III.B5.TP-300

ML101830328, 

Comment 12

to generically extend the limited material 

specific OE (which may be partially caused by 

the type of lubricant) to all bolts of 150 ksi and 

over regardless of material and lubricant.

revised to address 

this comment.

Maximum tens

less than 110 

line as it was, 

was revised to 

RCSC guidanc

338 III.A1.TP-287

III.A2.TP-287

III.A3.TP-287

III.A4.TP-287

III.A5.TP-287

III.A7.TP-287

III.A8.TP-287

III.A9.TP-287

III.B2.TP-287

III.B3.TP-287

III.B4.TP-287

III.B5.TP-287

ML101830328, 

Comment 13

Delete these line items. These line items are 

covered under III.A1.TP-248 and III.A1.TP274.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

For loss of ma

high-strength s

considered pa
NUREG-1950 IV-28 April 2011

Table IV-4. Analysis and Disposition of Public Comments on Chapter III, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Public Comment NRC Disposition Tech

350 III.A5.TP-34

ML101830328, 

Comment 14

Delete this line item. The aging effect for the 

block walls are adequately covered under line 

item III.A5.T-12.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Exposure and 

different for T-

351 III.A6.TP-223

ML101830328, 

Comment 15

(ADD) Chapter XI.S6, "Structure Monitoring 

Program" or (KEEP) Chapter XI.S7, “RG

1.127, Inspection of Water-Control Structures 

Associated with Nuclear Power Plants” or the 

FERC / US Army Corp of Engineers dam 

inspections and maintenance programs. 

To maintain option of evaluating wood 

components under Structures Monitoring.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

As wooden pil

parts of water 

RG 1.127 is th

Applicants hav

AMP XI.S7 (R

of Water-Cont

Associated wit

Plants) with AM

Monitoring).

353 III.B1..1.TP-232

III.B1.2.TP-232 

III.B1.3.TP-232

ML101830328, 

Comment 16

Chapter XI.M2, “Water Chemistry,” (DELETE)

for BWR water, (KEEP) and Chapter XI.S3, 

“ASME Section XI, Subsection IWF” 

It is self explanatory without referencing to 

BWR since these line items apply to BWR.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

These items a

356

363

III.B2.TP-41 

III.B3.TP-41

ML101830328, 

Comment 17

Delete these line items. This material does not 

apply to this group (III.B2 and III.B3).

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

This is a duplic

and III.B3.TP-3

462 III.B2.-x 

ML101880269,

Comment III.B2

GALL addresses stainless steel embedded in 

concrete (VII.J-17 & VIII.I-11). An approved 

precedent exists for adding this material, 

environment, aging effect, and program 

combination to the GALL Report. As shown in 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

This item was 

2010. NRC sta

on recent burie

experience. Al

are not stable 
April 2011 IV-29 NUREG-1950

Table IV-4. Analysis and Disposition of Public Comments on Chapter III, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Public Comment NRC Disposition Tech

Browns Ferry SER page 3-322, the staff 

accepted the position that aluminum alloy 

embedded or encased in concrete has no 

aging effect that requires aging management. 

Aluminum has an excellent resistance to 

corrosion. On a surface freshly abraded and 

then exposed to air, the oxide film is only 5 to 

10 nanometer thick but is highly effective in 

protecting the aluminum from corrosion 

(Hollingsworth and Hunsicker 1979). 

Aluminum that is embedded/encased within 

concrete, loss of material is not considered an 

applicable aging effect. The concrete would 

first have to be degraded by other aging 

effects, which reduce the protective cover and 

potentially allow for the intrusion of aggressive 

ions causing a reduction in concrete pH.

Aging management of concrete aging effects 

will manage the corrosion of the 

embedded/encased aluminum protective 

oxide layer. Concrete structures and 

components are designed in accordance with 

ACI standards and constructed using 

materials conforming to ACI and ASTM 

standards which provide fo[r] a good quality, 

dense, well cured, and low permeability 

concrete. Cracking is controlled through 

arrangement and distribution of reinforcing 

bars. 

corrode at high 

environment.
NUREG-1950 IV-30 April 2011

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Public Comment NRC Disposition Tech

863 IV.A1-6 

ML101880269,

Comment 3

Referring to AMR Item IV.A1.RP-227:

(DELETE) Yes, plant specific or integrated 

surveillance program, (ADD) No

The use of an AMP consistent with GALL 

should not require further evaluation.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The Reactor V

Program requi

evaluation bec

specific, depen

such as the co

limiting materia

surveillance ca

projected neut

accordance w

Appendix H, a

its proposed w

for approval pr

implementatio

evaluation is re

renewal.

864 IV.A2-5 

ML101880269,

Comment 4

Referring to AMR Item IV.A2.RP-228:

(DELETE) Yes, plant specific or integrated 

surveillance program,(ADD) No

The use of an AMP consistent with GALL 

should not require further evaluation.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The Reactor V

Program requi

evaluation bec

specific depen

such as the co

limiting materia

surveillance ca

projected neut

accordance w

Appendix H, a

its proposed w

for approval pr

implementatio

evaluation is re

renewal.
April 2011 IV-31 NUREG-1950

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Public Comment NRC Disposition Tech

945 IV.A2-8 

ML101880269,

Comment 5

Referring to AMR Item IV.A2.RP-229:

(DELETE) Yes, plant specific or integrated 

surveillance program,(ADD) No

The use of an AMP consistent with GALL 

should not require further evaluation.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The Reactor V

Program requi

evaluation bec

specific depen

such as the co

limiting materia

surveillance ca

projected neut

accordance w

Appendix H, a

its proposed w

for approval pr

implementatio

evaluation is re

renewal.

866 IV.B2-40

ML101880269,

Comment 6

Referring to AMR Item IV.B2.RP-301:

Delete reference to “no expansion 

components” 

In MRP-227 there are no expansion 

components associated with existing program 

components. This is a generic comment for 

other “existing program component” AMR 

lines that reference “no expansion 

components.”

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The “no expan

for items with e

components is 

the line items a

users, and all 

that the existin

not have Expa

867 IV.B2

ML101880269,

Comment 7

Revise AMR lines that reference AMP XI.M16 

based on the aging effects identified by MRP227 Table 3-3 and the management of 

relevant mechanisms by MRP-227 Table 4-3 

(primary components), MRP-227 Table 4-6 

(expansion components), and MRP-227 Table 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Since Table 3-

aging effects t

screened in, a

retained. The a

must be capab

the aging effec
NUREG-1950 IV-32 April 2011

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Public Comment NRC Disposition Tech

4-9 (existing program components). 

Consistency of AMR lines with MRP-227 

Table 4-3 (primary components), MRP-227 

Table 4-6 (expansion components), and MRP227 Table 4-9 (existing program components).

screened in by 

analyses. 

868 IV.B2-11

ML101880269, 

Comment 8

Referring to AMR Item IV.B2.RP-268:

This AMR line is not required and should be 

deleted. “Reactor vessel internal components 

(inaccessible locations)” are and should be 

handled programmatically by the AMP

XI.M16A, “PWR Vessel Internals.”.

The NRC staff review of MRP-227 should 

address this issue and provide guidance in 

the SE that is to be issued.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

This comment 

items that iden

locations in rea

be eliminated 

handled progra

XI.M16A (PWR 

the staff’s safe

MRP-227. Sin

not assess eac

has an inacces

line items are 

completeness

869 IV.B2-12

ML101880269, 

Comment 9

Referring to AMR Item IV.B2.RP-269:

This AMR line is not required and should be 

deleted. “Reactor vessel internal components 

(inaccessible locations)” are and should be 

handled programmatically by the AMP

XI.M16A, “PWR Vessel Internals.”.

The NRC staff review of MRP-227 should 

address this issue and provide guidance in 

the SE that is to be issued.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

This comment 

items that iden

locations in rea

be eliminated 

handled progra

XI.M16A (PWR 

the staff’s safe

MRP-227. Sin

not assess eac

has an inacces

line items are 

completeness

870 IV.B3-15 Referring to AMR Item IV.B3.RP-309: The staff disagrees This comment 
April 2011 IV-33 NUREG-1950

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Public Comment NRC Disposition Tech

ML101880269, 

Comment 10

This AMR line is not required and should be 

deleted. “Reactor vessel internal components 

(inaccessible locations)” are and should be 

handled programmatically by the AMP

XI.M16A, “PWR Vessel Internals”.

The NRC staff review of MRP-227 should 

address this issue and provide guidance in 

the SE that is to be issued.

with this comment. 

The GALL Report 

has not been 

changed.

items that iden

locations in rea

be eliminated 

handled progra

XI.M16A (PWR 

the staff’s safe

MRP-227. Sin

not assess eac

has an inacces

line items are 

completeness

871 IV.B3-16

ML101880269, 

Comment 11

Referring to AMR Item IV.B3.RP-311: 

This AMR line is not required and should be 

deleted. “Reactor vessel internal components 

(inaccessible locations)” are and should be 

handled programmatically by the AMP

XI.M16A, “PWR Vessel Internals”.

The NRC staff review of MRP-227 should 

address this issue and provide guidance in 

the SE that is to be issued.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

This comment 

items that iden

locations in rea

be eliminated 

handled progra

XI.M16A (PWR 

the staff’s safe

MRP-227. Sin

not assess eac

has an inacces

line items are 

completeness

872 IV.B4-11

ML101880269, 

Comment 12

Referring to AMR Item IV.B4.RP-238: 

This AMR line is not required and should be 

deleted. “Reactor vessel internal components 

(inaccessible locations)” are and should be 

handled programmatically by the AMP

XI.M16A, “PWR Vessel Internals.”.

The NRC staff review of MRP-227 should 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

This comment 

items that iden

locations in rea

be eliminated 

handled progra

XI.M16A (PWR 

the staff’s safe

MRP-227. Sin
NUREG-1950 IV-34 April 2011

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Public Comment NRC Disposition Tech

address this issue and provide guidance in 

the SE that is to be issued.

not assess eac

has an inacces

line items are 

completeness

873 IV.B4-12

ML101880269, 

Comment 13

Referring to AMR Item IV.B4.RP-239: 

This AMR line is not required and should be 

deleted. “Reactor vessel internal components 

(inaccessible locations)” are and should be 

handled programmatically by the AMP

XI.M16A, “PWR Vessel Internals.” 

The NRC staff review of MRP-227 should 

address this issue and provide guidance in 

the SE that is to be issued.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

This comment 

items that iden

locations in rea

be eliminated 

handled progra

XI.M16A (PWR 

the staff’s safe

MRP-227. Sin

not assess eac

has an inacces

line items are 

completeness

874 IV.C1-3 

ML101880269, 

Comment 14

Referring to AMR Item IV.C1.RP-43: 

The environment should be “Air with reactor 

coolant leakage

See AMR line IV.C1.RP-42 on page IV.C1-3 

directly beneath.

.”

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Both RP-42 an

for steel or sta

bolting in BWR 

pressure boun

RP-42, the ag

material due to 

pitting or crevi

RP-43, the ag

preload due to 

gasket creep a

Since coolant 

significant effe

(RP-42) than o

(RP-43), it is n

include “with re
April 2011 IV-35 NUREG-1950

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Public Comment NRC Disposition Tech

leakage” as pa

environment d

876 IV.C2-7 

ML101880269,

Comment 15

Add a new AMR line [related to IV.C1.RP-231]

for “Pressurizer relief tank: tank shell and 

heads; flanges; nozzles” that are outside of 

ASME Section XI ISI boundaries. It is 

suggested that the AMPs used be XI.M2, 

“Water Chemistry,” and XI.M32, “One-Time 

Inspection.”

[Editor's Note: See original document for the 

recommended new AMR line that goes with 

this comment.] 

The pressurizer spray head is also a nonASME Section XI component that is managed 

by the same AMPs (see page IV.C2-8, AMR 

line IV.C2.RP-41) for the same aging effect.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

AMR Item IV.C

added to the G

response to th

staff has previ

combination o

Chemistry” an

Inspection” pro

aging manage

pressurizer sp

also a non-AS

component wit

environment a

877 IV.D1-3 

ML101880269, 

Comment 16

Referring to AMR Item IV.D1.RP-367: 

The AMR line is missing the plant-specific 

AMP referenced in SRP Section 3.1.2.2.11. 

Revise the AMP to XI.M2, “Water Chemistry” 

(ADD) and plant-specific aging management 

program to address SG divider plate cracking.

The AMR line is inconsistent with the SRP 

requirement in Section 3.1.2.2.11.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

AMR item IV.D

April 2010 dra

Report was re

this comment 

discussion of t

into the AMP c

item was incon

SRP-LR requi

3.1.2.2.11. The 

change elimina

inconsistency.

946 IV.D1-7 

ML101880269,

Referring to AMR Item IV.D1.R-44: 

The AMPs refer to “secondary water” when 

the environment is “Reactor coolant.” This is 

The staff agrees with 

this comment and 

associated changes 

AMR item IV.D

in response to 

deleting the ph
NUREG-1950 IV-36 April 2011

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Public Comment NRC Disposition Tech

Comment 17 considered to be a typographical error. 

However, it should be coordinated with 

Comment 1.

[Editor’s Note: Comment 1 is assigned 

Comment Number 943 in NUREG-1950.] 

to the GALL Report 

have been made.

secondary wat

coordinated w

related to desc

Chemistry” pro

Report tables. 

of wording. Th

of technical int

no change in t

IV.D1.R-44 is 

1950 Table II-7 

record. There

does not appe

879 IV.D1-8 

ML101880269,

Comment 18

Referring to AMR Item written “IV.D1-RPXXX” in the April 2010 draft of the GALL 

Report:

This line is a duplicate of IV.D1.RP-372 on 

page IV.D1-3.

See Item IV.D1.RP-372 on page IV.D1-3.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The deleted ite

typographic er

to RP-372 and 

be included in 

GALL Report. 

is shown in Ta

comment affec

the deleted rec

because it has 

the earlier draf

447 IV, V, VII, VIII

ML101880269,

Comment IV.Ex, V.F-x, VII.Jx, VIII.I-x 

[The comment recommends adding a new 

AMR line in GALL Tables IV.E, V.F, VII.J, and 

VIII.I, for nickel-alloy piping, piping 

components, and piping elements in an 

environment of air with borated water leakage, 

and showing an AERM of “None” and AMP of 

“None.”]

The American Welding Society (AWS) 

“Welding Handbook,” (Seventh Edition, 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

New AMR item

V.F.EP-115, V

VIII.I.SP-148 w

recommended 

The GALL Rep

stainless steel 

borated water 

None.” Nickel-

as impervious 
April 2011 IV-37 NUREG-1950

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Public Comment NRC Disposition Tech

Volume 4, 1982, Library of Congress) 

identifies that nickel chromium alloy materials 

that are alloyed with iron, molybdenum, 

tungsten, cobalt or copper in various 

combinations have improved corrosion 

resistance.

The Staff’s evaluation in the Beaver Valley 

SER concluded that nickel-alloy components 

exposed to an external air with borated water 

leakage environment are resistant to the 

phenomena of corrosion and oxidation.

environment. A

previously acc

nickel alloy in 

water leakage 

aging effects r

management. 

973 IV.B2

ML101880266, 

Comment 1

Typographical. Table IV B2, Item IV.B2.RP272, Column 6. Move the first semi-colon 

(after the word “toughness”) to the location 

after the word “embrittlement.” See Item 

IV.B2.RP-354, Item IV.B2.RP-274, and other 

items with the same series of Degradation 

Effects/Mechanisms.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

This was an ad

correction. The

in technical int

272 is shown i

Table II-7 as a 

this comment.

974 IV.B2 

ML101880266, 

Comment 2

Typographical. Table IV B2, Item IV.B2.RP301, Column 2. Change “V.B2-40 (R-112)” to 

“IV.B2-40 (R-112).”

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

This was an ad

correction. The

in technical int

301 is shown i

Table II-7 as a 

this comment. 

975 IV.B2 

ML101880266, 

Comment 3

Technical. Table IV B2, Items IV.B2.RP-301, 

IV.B2.RP-299, IV.B2.RP-284, IV.B2.RP-355, 

IV.B2.RP-356, IV.B2.RP-285, IV.B2.RP-289, 

IV.B2.RP-288, and IV.B2.RP-346, Column 7. 

Eliminate the reference to “no Expansion 

components” since there are never any 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The “no expan

for these items 

because the li

multiple users 

wording provid

existing compo
NUREG-1950 IV-38 April 2011

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

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Document and 

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Reference No.

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Expansion Components associated with 

Existing Program Components.

Expansion Pro

976 IV.B2 

ML101880266, 

Comment 4

Technical. Table IV B2, Item IV.B2.RP-300, 

Column 6. Write the Mechanism/Effect as 

simply “Loss of preload.”

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Table 3-3 of M

that internal ho

primary compo

subject to wea

from loss of pr

inadequate pre

completeness

are identified.

977 IV.B2 

ML101880266, 

Comment 5

Technical. Table IV B2, Items IV.B2.RP-301 

and IV.B2.RP-299. We recommend that Item 

IV.B2.RP-301 be eliminated, with only Item 

IV.B2.RP-299 retained. Although Table 3-3 

(Page 3-24) of MRP-227 shows an “X” for 

both SCC and wear, Table 4-9 (Page 4-69) of 

MRP-227 shows only “Loss of material 

(Wear)” as the Effect (Mechanism) for which 

the Existing Section XI visual examination 

program is credited.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Since Table 3-

identifies SCC 

effects, both it

and -299 will b

978 IV.B2 

ML101880266, 

Comment 6

Technical. Table IV B2, Items IV.B2.RP-272, 

IV.B2.RP-274, and IV.B2.RP-287. We 

recommend that these three items be 

eliminated, with only Items IV.B2.RP271, 

IV.B2.RP-273, and IV.B2.RP286 retained. 

Although Table 3-3 (Page 3-23) of MRP-227 

also shows “P” for IE, VS, and ISR/IC, Table 

4-3 (Page 4-25) of MRP-227 shows only 

Cracking (IASCC and Fatigue), and the 

examination requirements only apply to those 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Since Table 3-

identifies all of 

have been scr

will be retained

XI.M16A, “PW

indicates irrad

thermal embrit

swelling are m

examination to 

Therefore, no 
April 2011 IV-39 NUREG-1950

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

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two Effects (Mechanisms). items IV.B2.RP

is necessary.

979 IV.B2 

ML101880266, 

Comment 7

Typographical. Table IV B2, Items IV.B2.RP275 and IV.B2.RP-354, Column 3. Change 

“Baffle-to-former assembly: barrel-edge bolts 

(all plants with baffle-edge bolts” to “Baffle-toformer assembly: baffle-edge bolts (all plants 

with baffle-edge bolts” for both items.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

This was an ad

correction. The

in technical int

275 and IV.B2

in NUREG-195

Table II-3, resp

record affected 

980 IV.B2 

ML101880266, 

Comment 8

Technical. Table IV B2, Item IV.B2.RP-354. 

We recommend that this item be eliminated 

with only Item IV.B2.RP-275 retained. 

Although Table 3-3 (Page 3-23) of MRP-227 

also shows “P” for IE, VS, and ISR/IC, Table 

4-3 (Page 4-25) of MRP-227 shows only 

Cracking (IASCC and Fatigue), and the 

examination requirements only apply to those 

two Effects (Mechanisms).

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Since Table 3-

identifies all th

have been scr

will be retained

XI.M16A, “PW

indicates irrad

thermal embrit

swelling are m

examination to 

Therefore, no 

IV.B2.RP-354 

981 IV.B2 

ML101880266, 

Comment 9

Technical. Table IV B2, Items IV.B2.RP-298, 

IV.B2.RP-297, IV.B2.RP-291, IV.B2.RP-293, 

IV.B2.RP-290, and IV.B2.RP-292.

First, in Columns 2 and 3 for Items IV.B2.RP298 and IV.B2.RP-297, change “weld” to 

“welds” and “cast austenitic stainless steel” to 

“stainless steel,” since the concern is all of the 

CRGT lower flange welds and Table 3-3 

(Page 3-23) of MRP-227 erroneously lists the 

items as “Lower Flanges” made of CF8, rather 

The staff partially 

agrees with this 

comment (first part), 

but disagrees with 

the remainder of the 

comment. However, 

the comment did 

result in a revision to 

the document for 

clarification.

First: Staff agr

comment and 

accordingly. T

a wording issu

technical inten

change to AM

298 and IV.B2

Second: Staff 

comment. Sinc

MRP-227 iden
NUREG-1950 IV-40 April 2011

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

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Commenter 

Reference No.

Public Comment NRC Disposition Tech

than 304 SS Lower Flange Welds.

Second, we recommend that Item IV.B2.RP297 be eliminated, retaining only Item 

IV.B2.RP-298. Although Table 3-3 (Page 3-

23) of MRP-227 also shows “P” for TE and IE, 

Table 4-3 (Page 4-24) of MRP-227 shows 

only Cracking (SCC and Fatigue), and the 

examination requirements only apply to those 

two Effects (Mechanisms).

Third, we recommend that Item IV.B2.RP-290 

be eliminated, retaining only Item IV.B2.RP291. Although Table 3-3 (Page 3-24) of MRP227 shows “E” for both IASCC and IE, Table 

4-6 (Page 4-34) of MRP-227 shows only 

IASCC, and the examination requirements 

only apply to this Effect (Mechanism).

Fourth, we recommend that Item IV.B2.RP292 be eliminated, retaining only Item 

IV.B2.RP-293. Although Table 3-3 (Page 3-

23) of MRP-227 shows “E” for both Fatigue 

and IE, Table 4-6 (Page 4-34) of MRP-227 

shows only Cracking (Fatigue), and the 

examination requirements only apply to this 

Effect (Mechanism).

effects have b

items will be re

XI.M16A, “PW

indicates irrad

thermal embrit

swelling are m

examination to 

Therefore, no 

297 is necessa

Third: Staff dis

comment. Sinc

MRP-227 iden

effects have b

items will be re

AMP XI.M16A

Internals” indic

embrittlement, 

embrittlement 

are managed 

examination to 

Therefore, no 

290 is necessa

Fourth: Staff d

comment. Sinc

MRP-227 iden

effects have b

items will be re

AMP XI.M16A 

embrittlement, 

embrittlement 

are managed 
April 2011 IV-41 NUREG-1950

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

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Number

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examination to 

Therefore, no 

292 is necessa

982 IV.B2 

ML101880266, 

Comment 10

Typographical. Table IV B2, Item IV.B2.RP355, Column 7. Change “Existngn” to 

“Existing.”

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

This change c

error. Item IV.B

II-3 is shown a

comment; how

subsequent ch

wording affect

983 IV.B2 

ML101880266, 

Comment 11

Technical. Table IV B2, Items IV.B2.RP-276, 

IV.B2.RP-278, IV.B2.RP-280, IV.B2.RP-281, 

IV.B2.RP-282, IV.B2.RP-294, and IV.B2.RP295. 

First, we recommend that IV.B2.RP-276 be 

identified only with SCC, as shown in Table 4-

3 (Page 4-24) of MRP-227, since Table 3-3 

(Page 3-24) of MRP-227 shows a “P” for SCC 

and a “E” for IASCC and the “P” classification 

governs. However, the EVT-1 inspection does 

not distinguish between cracking 

mechanisms.

Second, there is no problem with Item 

IV.B2.RP-278. However, there is a 

discrepancy between Table 3-3 (Page 3-24) 

of MRP-227 and Table 4-6 (Page 4-33) of 

MRP-227 with respect to the Expansion 

Components for the upper core barrel flange 

weld (IV.B2.RP-276). The item listed as “Core 

Barrel Axial Welds” in Table 3-3 should be 

listed as “Lower Core Barrel Flange Weld.” 

The staff partially 

agrees with this 

comment. The 

comment resulted in 

a revision to the 

document for 

clarification.

First: No chan

mechanisms m

a result of the 

examination. T

to the line item

Second: Chan

IV.B2.RP-280 

“Lower Core B

Changed AMR 

to “Core barre

barrel flange,” 

as an aging m

changes are n

error in Table 

IV.B2.RP-282 

IV.B2.RP-281 

because they 

components.

Third: The staf

statement. Ho

change is nece
NUREG-1950 IV-42 April 2011

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

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Then, Items IV.B2.RP-280 and IV.B2.RP-281 

should be eliminated. Item IV.B2.RP-282 

takes their place, except that Column 6 should 

read “Cracking due to SCC and fatigue.”

Third, Item IV.B2.RP-345 is correct, in that 

loss of material due to wear is being managed 

for the core barrel flange by Existing Program 

elements. However, we recommend that a 

new item be added – perhaps IV.B2.RP-280 - 

that identifies the Core Barrel Assembly core 

barrel flange as an Expansion Component 

(see Table 4-6 on Page 4-33 of MRP-227) 

that shows cracking due to SCC and fatigue 

as an Expansion Component linked to Item 

IV.B2.RP-276, similar to Item IV.B2.RP-278 

and the corrected Item IV.B2.RP-282.

Fourth, we recommend that Item IV.B2.RP295 be eliminated, retaining only Item 

IV.B2.RP-294. Although Table 3-3 (Page 3-

24) of MRP-227 shows “E” for both IASCC 

and IE, Table 4-6 (Page 4-33) of MRP-227 

shows only Cracking (IASCC), and the 

examination requirements only apply to this 

Effect (Mechanism).

response to th

comment, the 

item IV.B2.RP

Core barrel as

flange. AMR it

identified as a

component wit

component as 

IV.B2.RP-276.

Fourth: Chang

IV.B2.RP-280 

“Lower Core B

Changed AMR 

to “Core barre

barrel flange,” 

as an aging m

changes are n

error in Table 

AMR item IV.B

replace items 

IV.B2.RP-280 

different comp

984 IV.B2 

ML101880266, 

Comment 12

Typographical. Table IV B2. Occasionally in 

Column 3, “Lower internals assembly” is 

spelled incorrectly as “Lower internal 

assembly.”

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

This change c

error. This cha

a generic (wor

methodology; 

records are no

typographic co

Table II or III.
April 2011 IV-43 NUREG-1950

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

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985 IV.B2 

ML101880266, 

Comment 13

Technical. Table IV B2, Items IV.B2.RP-289 

and IV.B2.RP-288. Item IV.B2.RP-289 is 

correct. However, Column 6 of Item IV.B2.RP288 should not mention IE, since the Existing 

Program elements will be unable to detect the 

degradation, even though IE is cited as “X” in 

Table 3-3 (Page 3-24) of MRP-227.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

No change wa

to this comme

screened in IA

and irradiation 

aging effects/m

lower core pla

core plates, al

effects/mecha

indentified and 

item IV.B2.RP

Since Element 

PWR Vessel I

irradiation emb

embrittlement 

are managed 

examination to 

no change to A

288 is necessa

986 IV.B2 

ML101880266, 

Comment 14

Technical.

First, Section IV.B.2, first sentence. The rod 

control cluster assemblies (RCCAs) were not 

in the scope of the Westinghouse reactor 

internals study. Any reference to rod control 

cluster assemblies should be removed.

Also, following the first paragraph of Section 

IV.B.2, we recommend that this new 

paragraph be added:

“Aging related degradation in the reactor 

internals is managed through an integrated 

program. Specific inspection requirements are 

The staff partially 

agrees with this 

comment and 

associated changes 

to the GALL Report 

have been made.

First: The staff 

comment and 

accordingly. R

was removed 

GALL IV.B2 b

not in scope fo

Since this was 

text, not the A

comment num

Tables II-3 or 

Second: The c

clarification of 

made in the te
NUREG-1950 IV-44 April 2011

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

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Public Comment NRC Disposition Tech

listed in this section. Degradation due to 

changes in material properties (e.g., loss of 

fracture toughness) were considered in the 

determination of inspection recommendations 

and are managed by the requirement to use 

appropriately degraded properties in the 

evaluation of identified defects. These 

requirements are detailed in the aging 

management programs.”

Note that this recommendation is 

accompanied by the suggested removal of 

multiple entries from the following table that 

do not directly correspond to the suggested 

recommendations in the MRP-227 tables.

Second, Section IV.B.3, first sentence. Only 

the CEA shrouds were in the scope of the CE 

(Combustion Engineering) reactor internals 

study. The section “control element assembly 

(CEA) shroud assemblies” should read 

“control element assembly (CEA) shrouds.” It 

is not clear what the reference to “shroud 

assembly” means.

Also, following the first paragraph of Section 

IV.B.3, we recommend that this new 

paragraph be added:

“Aging related degradation in the reactor 

internals is managed through an integrated 

program. Specific inspection requirements are 

listed in this section. Degradation due to 

changes in material properties (e.g., loss of 

fracture toughness) were considered in the 

IV.B3. It was n

technical inten

Tables II-3 or 

change to add 

paragraph and 

AMR items wa

Since Table 3-

identifies all th

have been scr

will be retained

XI.M16A, “PW

indicates irrad

thermal embrit

swelling are m

examination to 

Therefore, the 

recommended 

and IV.B3 are 

However, a pa

the one recom

added to AMP 

Vessel Interna
April 2011 IV-45 NUREG-1950

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

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Commenter 

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determination of inspection recommendations 

and are managed by the requirement to use 

appropriately degraded properties in the 

evaluation of identified defects. These 

requirements are detailed in the aging 

management programs.”

Note that this recommendation is 

accompanied by the suggested removal of 

multiple entries from the following table that 

do not directly correspond to the suggested 

recommendations in the MRP-227 tables.

987 IV.B3 

ML101880266, 

Comment 15

Technical. Table IV B3, Items IV.B3.RP-314, 

IV.B3.RP-315, IV.B3.RP-316, IV.B3.RP-317, 

IV.B3.RP-320, IV.B3.RP-321, IV.B3.RP-330, 

IV.B3.RP-331, and IV.B3.RP-358.

First, we recommend that Item IV.B3.RP-315 

be eliminated, with Item IV.B3.RP-314 

retained. Although Table 3-2 (Page 3-22) of 

MRP-227 shows “P” for IE, VS, and ISR/IC, in 

addition to the “P” for IASCC, Table 4-2 (Page 

4-20) of MRP-227 identifies only the two 

cracking mechanisms (IASCC and Fatigue), 

and the examination requirements apply only 

to those two Effects (Mechanisms).

Second, we recommend that Item IV.B3.RP317 be eliminated with Item IV.B3.RP-316 

retained. However, the information in Column 

3 of Item IV.B3.RP-317 should be moved to 

Column 3 of Item IV.B3.RP-316 (so that the > 

3 dpa exposures apply to IASCC), and “and 

fatigue” needs to be added to Column 6 of 

The staff partially 

agrees with this 

comment. The GALL 

Report has been 

changed as 

described in the 

Technical Basis for 

this comment. 

First: Fatigue w

item IV.B3.RP

in this comme

eliminating AM

315. Since Ta

all these aging 

have been scr

aging effects/m

retained. Elem

“PWR Vessel 

irradiation emb

embrittlement 

are managed 

examination to 

Therefore, no 

IV.B3.RP-315 

Second: Disag

AMR item IV.B

Table 3-3 scre

fracture tough
NUREG-1950 IV-46 April 2011

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

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Item IV.B3.RP-316. 

Third, Items IV.B3.RP-320 and IV.B3.RP-321 

are not Expansion components and instead 

are Existing Program components.

Fourth, we recommend that Item IV.B3.RP331 be eliminated, retaining only Item 

IV.B3.RP-330. Although Table 3-2 (Page 3-

23) of MRP-227 shows “E” for IE, in addition 

to the “E” for IASCC and Fatigue, Table 4-5 

(Page 4-31) of MRP-227 identifies only the 

two cracking mechanisms (IASCC and 

Fatigue), and the examination requirements 

apply only to those two Effects (Mechanisms).

Fifth, we recommend that Item IV.B3.RP-358 

be eliminated. Although Table 3-2 (Page 3-22) 

of MRP-227 shows “E” for IASCC, in addition 

to “P” for IE and VS, the latter two 

designations control, and Item IV.B3.RP- 318 

provides the aging management 

requirements.

irradiation emb

of preload due 

for this compo

changes to co

because it is c

227. However 

added to AMR 

because Table 

does not ident

screened in m

item.

Third: Agree. T

changes recom

comment, the 

were incorpora

Deleted AMR 

(b) Added loss 

item IV.B3.RP

AMR item IV.B

“Existing Prog

(d) Changed A

320 to “Existin

components. (

item IV.B3.RP

expansion com

IV.B3.RP-314. 

item IV.B3.RP

expansion com

IV.B3.RP-315. 

acceptable be

consistent with 
April 2011 IV-47 NUREG-1950

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

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Number

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Fourth: Disagr

identifies that a

effects have b

aging effects/m

retained. Elem

XI.M16A indica

embrittlement, 

embrittlement 

are managed 

examination to 

Therefore, no 

IV.B3.RP-331 

Fifth: Disagree

identifies that a

effects have b

aging effects/m

retained. Elem

XI.M16A indica

embrittlement, 

embrittlement 

are managed 

examination to 

Therefore, no 

IV.B3.RP-358 

988 IV.B3 

ML101880266, 

Comment 16

Technical. Table IV B3, Item IV.B3.RP-319. 

Column 7 should be changed so that the 

words “Primary components (identified in the 

Structure and Components column) existing 

program” is replaced by the words “Existing 

program components (identified in the 

Structure and Components column). Also, 

The staff partially 

agrees with this 

comment and the 

document was 

reworded for clarity.

Changed “Prim

“Existing Prog

This is consist

Disagree with 

expansion com

expansion com

IV.B3.RP-319 
NUREG-1950 IV-48 April 2011

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

Comment 

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eliminate the reference to “no Expansion 

components” since there are never any 

Expansion Components associated with 

Existing Program Components.

because the li

multiple users 

know that exis

not have Expa

Components.

989 IV.B3 

ML101880266, 

Comment 17

Technical. Table IV B3, Item IV.B3.RP-318. 

We recommend that loss of fracture 

toughness due to IE be eliminated from 

Column 6, since the AMP elements are 

intended only to detect the effects of void 

swelling.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

No change wa

to this comme

of MRP-227 in

“Former Plates 

“Shroud Plates 

fracture tough

irradiation emb

swelling are ag

effects/mecha

screened, no c

IV.B3.RP-318 

990 IV.B3 

ML101880266, 

Comment 18

Technical. Table IV B3, Item IV.B3.RP-359. 

We recommend that loss of fracture 

toughness due to IE be eliminated from 

Column 6, since the AMP elements are 

intended only to detect the effects of void 

swelling.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

No change wa

to this comme

of MRP-227 in

“Shroud Plates 

“Former Plates 

irradiation emb

screened in, th

not be deleted 

recommended 

necessary. 

991 IV.B3 

ML101880266, 

Comment 19

Typographical. Table IV B3, Items IV.B3.RP342 and IV.B3.RP-366. Change “Core shroud 

assemblies” in Column 3 to “Lower Support 

Structure” and change “stee” in Column 4 to 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

This change is 

Table 3.2 in M

IV.B3.RP-342 

366 in Table II
April 2011 IV-49 NUREG-1950

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

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Number

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“steel.” have been made. affected by thi

992 IV.B3 

ML101880266, 

Comment 20

Technical. Table IV B3, Items IV.B3.RP-342 

and IV.B3.RP-366. Eliminate the reference to 

SCC and IASCC in Column 6 for Item 

IV.B3.RP-342 and eliminate Item IV.B3.RP366 entirely. Although Table 3-2 (Page 3-21) 

of MRP-227 shows “X” for SCC and IASCC, 

and “P” for Fatigue and IE, Table 4-2 (Page 4-

23) of MRP-227 lists only cracking from 

fatigue. However, the EVT-1 inspection does 

not distinguish between cracking 

mechanisms.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

No change wa

to this comme

of MRP-227 in

effects need m

need to be inc

aging manage

items.

Therefore, IV.B

not be elimina

993 IV.B3 

ML101880266, 

Comment 21

Typographical. Table IV B3, Item IV.B3.RP322. Identify in Column 3 that the component

of interest is the “core shroud plate-former 

plate weld” and correct the last part of Column 

3 to read “...within six inches of central flange 

and horizontal stiffeners.”

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

This is a need

IV.B3.RP-322 

shown as affe

comment.

994 IV.B3 

ML101880266, 

Comment 22

Technical. Table IV B3, Items IV.B3.RP-324, 

IV.B3.RP-360, and Item IV.B3.RP-361. We 

recommend the elimination of Item IV.B3.RP360, retaining only Item IV.B3.RP-324. 

Although Table 3-2 (Page 3-22) of MRP-227 

shows “P” for both IASCC and IE, Table 4-2 

(Page 4-20) of MRP-227 lists only cracking 

from IASCC, and the AMP elements are 

applicable only to that effect. For the same 

reason, we recommend that Item IV.B3.RP361 be eliminated.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

No change wa

to this comme

of MRP-227 in

effects need m

need to be inc

aging manage

items. Therefo

361 should no
NUREG-1950 IV-50 April 2011

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Public Comment NRC Disposition Tech

995 IV.B3 

ML101880266, 

Comment 23

Technical. Table IV B3, Items IV.B3.RP-327, 

IV.B3.RP-328, IV.B3.RP-329, IV.B3.RP-335, 

IV.B3.RP-362, IV.B3.RP-363, and IV.B3.RP364. 

First, although Table 3-2 (Page 3-21) of MRP227 shows “P” for Fatigue and “E” for SCC, 

the lower core barrel flange weld is a Primary 

Component. Table 4-2 (Page 4-22) only 

designates cracking due to fatigue. Therefore, 

Column 7 should be changed from “Existing” 

to “Primary” and Column 6 should only 

reference “Cracking due to fatigue.”

Second, Column 3 of Item IV.B3.RP-335 

should identify applicability to all plants except 

those assembled with full-height shroud 

plates.

Third, we recommend that Item IV.B3.RP-362 

be eliminated, since those welds are already 

included in Item IV.B3.RP-329, and only SCC 

is included in Table 4-5 (Page 4-30) of MRP227.

Fourth, we recommend that Items IV.B3.RP363 and IV.B3.RP-364 be eliminated. The 

welds are not subject to TE, although the core 

support columns are listed in Table 3-2 (Page 

3-21) of MRP-227 as cast austenitic stainless 

steel, and the examination methods specified 

in Table 4-5 (Page 4-31) of MRP-227 are not 

applicable to IE.

The staff partially 

agrees with this 

comment and the 

document was 

reworded for clarity.

First: Agree to 

“Primary” and 

Primary compo

IV.B3.RP-327)

IV.B3.RP-328 

Component” re

IV.B3.RP-327. 

eliminate SCC 

effect/mechan

3-2 of MRP-22

an aging effec

lower core bar

Second: Agree

applicability th

Table 4-5 of M

Third: Disagre

IV.B3.RP-329 

to SCC. Item I

loss of fracture 

neutron irradia

Since both of t

are identified i

227 for “Lower 

irradiation emb

aging effect fo

described in A

362. Therefore

can’t be elimin

“lower cylinder 

column 3 in ite

because items 
April 2011 IV-51 NUREG-1950

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

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Number

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Public Comment NRC Disposition Tech

329 are identif

as the same c

Fourth: Disagr

MRP-227 indic

Support Colum

material loss o

due to therma

embrittlement 

an aging effec

Therefore, the

can’t be elimin

364. Table 3-2 

indicates that f

Columns” with 

material loss o

due to neutron 

embrittlement 

aging effect. T

Table 3-2, wel

from the identi

items IV.B3.RP

Since Table 3-

indicates these 

management, 

included in GA

management r

Therefore, item

and -364 shou

996 IV.B3 

ML101880266, 

Comment 24

Typographical. Table IV B3, Items IV.B3.RP357, IV.B3.RP-336, and IV.B3.RP-334. 

Eliminate the reference to “no Expansion 

The staff disagrees 

with this comment. 

The GALL Report 

No change wa

to this comme

expansion com
NUREG-1950 IV-52 April 2011

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Public Comment NRC Disposition Tech

components” since there are never any 

Expansion Components associated with 

Existing Program Components.

has not been 

changed.

items is neces

line items are 

and all users d

existing compo

Expansion Pro

997 IV.B3 

ML101880266, 

Comment 25

Technical. Table IV B3, Item IV.B3.RP-336. In 

Column 6, eliminate reference to IE or VS. 

Even though Table 3-2 (Page 3-21) of MRP227 shows “X” for IE and ISR/IC, in addition to 

the “X” for IASCC and Fatigue, Table 4-8 

(Page 4-68) of MRP-227 identifies only the 

three cracking mechanisms (SCC, IASCC and 

Fatigue), and the examination requirements 

apply only to those three effects 

(mechanisms).

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

No change wa

to this comme

in MRP-227 fo

with A286 mat

wear, loss of p

relaxation and 

toughness due 

embrittlement 

change in dim

void swelling is 

item IV.B3.RP

be consistent w

since irradiatio

been screened 

eliminated from 

336. 

998 IV.B3 

ML101880266, 

Comment 26

Technical. Table IV B3, Item IV.B3.RP-337. 

We recommend that this entry be deleted, 

since it appears to be a repeat of IV.B3.RP342 and IV.B3.RP-366.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Change was m

with the comm

IV.B3.RP-342 

item IV.B2.RP

IV.B3.RP-337 

response to th

in Tables II or 

999 IV.B4 

ML101880266, 

Table IV B4.

First, NUREG-1801, Revision 1 (2005) lists 

The staff disagrees 

with this comment. 

The comment 

implemented a
April 2011 IV-53 NUREG-1950

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

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Comment 27 the following requirement under AMP in Table 

IV B4:

“Upon completion of these programs, but not 

less than 24 months before entering the 

period of extended operation, submit an 

inspection plan for reactor internals to the 

NRC for review and approval.”

However, the NUREG-1801, Revision 2, draft 

has removed this submittal of an inspection 

plan requirement. Please clarify whether this 

requirement will be withdrawn for all PWR 

plants that have previously made this 

commitment in their license renewal 

applications and/or FSAR. In other words, if 

these PWR plants fulfill the implementation 

requirements listed in the current MRP-227 

Revision 0, Section 7, no inspection plan or 

AMP will be required to be submitted to NRC.

Second, the NUREG-1801, Revision 2 draft 

has removed “XI.M13 THERMAL AGING AND 

NEUTRON IRRADIATION EMBRITTLEMENT 

OF CAST AUSTENITIC STAINLESS STEEL 

(CASS)” that was in NUREG-1801, Revision 1 

(2005). The current draft has added the 

following statement under Section XI.M12 

“THERMAL AGING EMBRITTLEMENT OF 

CAST AUSTENITIC STAINLESS STEEL 

(CASS)”: 

“Aging management of CASS reactor internal 

components of pressurized water reactors 

(PWRs) are discussed in AMP XI.M16 and for 

However, the 

comment did result in 

a revision to the 

document for 

clarification.

However, clari

made in respo

GALL Chapter

IV.B4 were rev

applicant will s

plan for reacto

NRC for review 

the application 

In addition, XI

Vessel Interna

state that an in

implemented b

through an ins

submitted to th

and approval w

for license ren

These change

clarification of 

documentation 

determined is 

aging manage

reactor vessel 

period of exten

The alternative 

management o

internal compo

evaluated in th

MRP-227.

Items IV.B3.R

340, IV.B3.RP

IV.B3.RP-306, 
NUREG-1950 IV-54 April 2011

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Public Comment NRC Disposition Tech

boiling water reactor (BWR) CASS reactor 

internal components in AMP XI.M9.”

By removing Section XI.M13 from the Rev. 2 

draft, NRC has also removed the following 

alternative disposition method afforded in 

GALL Rev. 1 (2005) Section XI.M13, under “4. 

Detection of Aging Effects:” for reactor vessel 

internal CASS components that have a 

neutron fluence of greater than 1017 n/cm2 

(E>1 MeV) or are determined to be 

susceptible to thermal embrittlement:

Alternatively, the applicant may perform a 

component-specific evaluation, including a 

mechanical loading assessment to determine 

the maximum tensile loading on the 

component during ASME Code Level A, B, C, 

and D conditions. If the loading is 

compressive or low enough (<5 ksi) to 

preclude fracture, then supplemental 

inspection of the component is not required. 

Failure to meet this criterion requires 

continued use of the supplemental inspection 

program.

The above alternative disposition method is 

not listed in GALL Rev. 2 draft Section 

XI.M16. Can PWR plants continue to use the 

above alternative disposition method in GALL 

Rev. 1 Section M.13 for the CASS 

components in the reactor internals?

We understand the purpose of including Items 

IV.B3.RP-339, IV.B3.RP-340, IV.B3.RP-309, 

were included 
April 2011 IV-55 NUREG-1950

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

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IV.B3.RP-311, IV.B3.RP-306, and IV.B3.RP307 for completeness.

1000 IV.B4 

ML101880266, 

Comment 28

Typographical. Table IV B4, Item IV.B4.RP245. Add “IV.B4, RP-248” in the AMP column.The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The change co

issue. RP-248 

so, RP-245 sh

RP-248. Item 

Table II-7 is sh

this comment.

1001 IV.B4 

ML101880266, 

Comment 29

Typographical. Table IV B4, IV.B4.RP-241. 

Delete “(c)...” in the Structure & Component 

column and delete “SCC” in the Aging Effect 

column.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The “(c)” comp

IV.B4.RP-241 

baffle bolts.” T

indicates “Inte

bolts” are “exp

and the applic

are wear, fatig

embrittlement 

due to stress r

“internal baffle

deleted from A

241, they were 

IV.B4.RP-243 

of fracture toug

neutron irradia

loss of preload 

relaxation; and 

to wear as agi

effects/mecha

item IV.B4.RP

fatigue as an a

effect/mechan
NUREG-1950 IV-56 April 2011

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Public Comment NRC Disposition Tech

a new line item 

to-baffle bolts 

fatigue as an a

effect/mechan

new line item a

expansion com

IV.B4.RP-241.

1002 IV.B4 

ML101880266, 

Comment 30

Typographical. Table IV B4, Item IV.B4.RP240. Delete “(c)...” in the Structure & 

Component column.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The “(c)” comp

IV.B4.RP-240 

baffle bolts.” S

component dis

Comment 29 (

1001), its disp

as EPRI Comm

Number 1001)

1003 IV.B4 

ML101880266, 

Comment 31

Typographical. Table IV B4, Item IV.B4.RP244. Delete “SCC” in the Aging Effect column.The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Table 3-1 in M

SCC is not an 

these compon

244 in Table II

affected by thi

1004 IV.B4 

ML101880266, 

Comment 32

Typographical. Table IV B4, Item IV.B4.RP248. Add “IV.B4.RP-247” to the AMP column.The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

This is a clarifi

reference to ex

components c

227. Item IV.B

7 is shown as 

comment.

1005 IV.B4 

ML101880266, 

Comment 33

Typographical. Table IV B4, Item IV.B4.RP252. Delete “nickel alloy” in the Material 

column.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

This is a clarifi

materials cons

227. Item IV.B

7 is shown as 
April 2011 IV-57 NUREG-1950

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Public Comment NRC Disposition Tech

have been made. change.

1006 IV.B4 

ML101880266, 

Comment 34

Typographical. Table IV B4, Item IV.B4.RP251. Delete “nickel alloy” in the Material 

column. 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

This is a clarifi

materials cons

227. Item IV.B

7 is shown as 

comment.

1007 IV.B4 

ML101880266, 

Comment 35

Typographical. Table IV B4, Item IV.B4.RP256. Add “IV.B34.RP-248” to the AMP 

column.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

This is a corre

administrative 

to RP-256; so 

refer to RP-24

256 in Table II

affected by thi

1008 IV.B4 

ML101880266, 

Comment 36

Typographical. Table IV B4, Item IV.B4.RP258. Delete “IV.B4.RP-260” in the AMP 

column.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

This corrects a

error. RP-258 

242, but not R

IV.B4.RP-258 

shown as affec

comment.

1009 IV.B4 

ML101880266, 

Comment 37

Typographical. Table IV B4, Item IV.B4.RP254. Add “IV.B4.RP-248” to the AMP column.The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

This corrects a

error. RP-248 

RP-254 should 

Item IV.B4.RP

shown as affec

comment.

1010 IV.B4 

ML101880266, 

Comment 38

Typographical. Table IV B4, Item IV.B4.RP246. Add “IV.B4.RP-248” to the AMP column.The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The change co

administrative 

to RP-246; so 

refer to RP-24

246 in Table II
NUREG-1950 IV-58 April 2011

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Public Comment NRC Disposition Tech

affected by thi

1011 IV.B4 

ML101880266, 

Comment 39

Typographical. Table IV B4, Item IV.B4.RP260. Delete “IV.B4.RP-258” in the AMP 

column.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The change co

administrative 

not refer to RP

should not refe

correct referen

RP-259, only. 

in Table II-7 is 

by this comme

1012 IV.B4 

ML101880266, 

Comment 40

Typographical. Table IV B4, Item IV.B4.RP262. Delete “Stainless-Steel” in the Material 

column.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The change cl

material for thi

accordance w

IV.B4.RP-262 

shown as affec

comment.

1013 IV.B4 

ML101880266, 

Comment 41

Typographical. Table IV B4, Item IV.B4.RP240. Delete “(c)...” in the Structure & 

Component column.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The “(c)” comp

240 is “Interna

bolts.” Since th

component dis

Comment 29 (

Comment Num

disposition is t

Comment 29 (

Comment Num

1014 IV.B4 

ML101880266, 

Comment 42

Typographical. Table IV B4, Item IV.B4.RP241. Delete “(c)...” in the Structure & 

Component column and delete “SCC” in the 

Aging Effect column.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The “(c)” comp

241 is “Interna

bolts.” Since th

component dis

Comment 29 (

Comment Num
April 2011 IV-59 NUREG-1950

Table IV-5. Analysis and Disposition of Public Comments on Chapter IV, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Public Comment NRC Disposition Tech

disposition is t

Comment 29 (

Comment Num

1015 IV.B4 

ML101880266, 

Comment 43

Typographical. Table IV B4, Item IV.B4.RP245. Add “IV.B4.RP-248” to the AMP column.The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The change co

administrative 

refers to RP-2

refer to RP-24

245 in Table II

affected by thi

1016 IV.B4 

ML101880266, 

Comment 44

Technical. Table IV B4, Item IV.B4.RP-53. 

Add “Ductility, reduction in fracture toughness” 

to the Mechanism column and AMP column. 

This is a TLAA from BAW-2248A, Section 2.4, 

along with fatigue.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

This is an agin

identified for B

internals in BA

AMR item IV.B

cumulative fat

fatigue, the sta

item, IV.B4.RP

effect/ mechan

item requires f

a TLAA.
NUREG-1950 IV-60 April 2011

Table IV-6. Analysis and Disposition of Public Comments on Chapter V, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

880 V.B-3 

ML101880269,

Comment 19

Referring to AMR Item V.B.EP-103:

(DELETE) Chapter XI.M1, “ASME Section XI 

Inservice Inspection, Subsections IWB, IWC, 

and IWD” for ASME Code components or 

(KEEP) Chapter XI.M36, “External Surfaces 

Monitoring of Mechanical Components” for 

non-ASME Code components

There is a lack of operating experience to 

support aging effects associated with the 

described material-environment and ISI is not 

adequate to manage component external 

surfaces. This is a generic comment 

applicable to Chapters VII and VIII.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Recommende

changed to X

Surfaces Mon

Components,” 

stainless steel 

non-code stain

components e

air that may co

change is acce

AMP XI.M36 h

include manag

on the externa

steel compone

outdoor air tha

halides. Confo

changes relate

affected AMR 

numbers EP-1

118 in the GAL

V, VII and VIII

881 V.B-3 

ML101880269,

Comment 21

Referring to AMR Items V.B.EP-103 and 

V.B.EP-107: 

A new AMR line item is needed for the 

situation where the evaluated environmental 

conditions (as addressed in the corresponding 

SRP sections) have been determined to be 

benign to stainless steel.

[Editor's Note: Refer to original document 

(ML101880269) for recommended AMR line 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

If the further e

that the outsid

contain halides

should designa

aging effect an

required, and 

specific note in 
April 2011 IV-61 NUREG-1950

Table IV-6. Analysis and Disposition of Public Comments on Chapter V, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

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Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

related to this comment.] 

If the evaluation performed to address FER 

[Further Evaluation Recommendation] 

3.2.2.2.6 determines that the conditions 

described are not applicable then a 

corresponding AMR line is required. This is a 

generic comment applicable to Chapters VII 

and VIII

882 V.B-9 

ML101880269, 

Comment 22

Referring to AMR Item V.B.EP-111:

Revise the material to be consistent with 

GALL Rev.1

Steel (with (ADD- or without) coating or 

wrapping)

AMP XI.M41 manages loss of material for 

steel piping with or without 

coatings/wrappings. This is a generic 

comment applicable to Chapters VII and VIII

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

AMP XI.M41 r

steel pipe expo

environment b

buried steel pi

then it should 

exception in th

appropriate pla

and plant-spec

should be prov

947 V.B-3 

ML101880269,

Comment 20

Referring to AMR Item V.B.EP-107

(DELETE) Chapter XI.M1, “ASME Section XI 

Inservice Inspection, Subsections IWB, IWC, 

and IWD” for ASME Code components or 

(KEEP) Chapter XI.M36, “External Surfaces 

Monitoring of Mechanical Components” for 

non-ASME Code components

There is a lack of operating experience to 

support aging effects associated with the 

described material-environment and ISI is not 

adequate to manage component external 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Recommende

changed to X

Surfaces Mon

Components,” 

stainless steel 

non-code stain

components e

air that may co

is acceptable b

XI.M36 has be

include manag

material on the 
NUREG-1950 IV-62 April 2011

Table IV-6. Analysis and Disposition of Public Comments on Chapter V, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

surfaces. This is a generic comment 

applicable to Chapters VII and VIII.

stainless steel 

exposed to ou

contain halides

generic chang

comment affec

Chapters V, V

439 V.E, VII.I, VIII.H 

ML101880269,

Comment V.Ex, VII.I-x, VIII.H

[The comment recommends adding a new 

AMR line in GALL Tables V.E, VII.I, and 

VIII.H, for aluminum piping, piping 

components, and piping elements in an 

environment of air - outdoor, with an AERM of 

loss of material due to pitting and crevice 

corrosion managed by AMP XI.M36, “External 

Surfaces Monitoring of Mechanical 

Components.”]

Consistent with GALL Rev 1 for aluminum in 

an air-outdoor environment for Supports 

(aluminum, air-outdoor) III.B2-7 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

GALL Report i

stainless steel 

piping, piping c

piping elemen

environment, t

should be also 

electrical and s

component ch

include alumin

components in 

environment. A

revised to inclu

components. N

V.E.EP-114, V

VIII.H.SP-147 

result of this co

451 V.E, VII.I, VIII.H

ML101880269,

Comment V.Ex, VII.I-x, 

VIII.H-x 

[The comment recommends adding new AMR 

lines in GALL Tables IV.E, VII.I, and VIII.H, for 

copper-alloy and nickel-alloy bolting in an 

environment of air – indoors (external), with 

an AERM of loss of preload due to thermal 

effects, gasket creep, and self-loosening 

managed by AMP XI.M18, “Bolting Integrity.”]

GALL addresses loss of preload for steel 

closure bolting in an air-indoor (external) 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

GALL Report a

stainless steel 

loss of pre-loa

applicable agin

alloy and nicke

New AMR item

VII.I.AP-261 a

were added fo

bolting. New it
April 2011 IV-63 NUREG-1950

Table IV-6. Analysis and Disposition of Public Comments on Chapter V, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

environment (V.E-5, VII.I-5 and VIII. H-5) but 

does not address nickel alloy, or copper alloy 

bolting. GALL AMP XI.M18 provides for 

management of loss of pre-load, so this 

program can also be applied here.

VII.I.AP-262, a

were added fo

The environme

“any environm

preload can po

any environme

454 V.E, VII.I, VIII.H

ML101880269,

Comment V.Ex, VII.I-x, 

VIII.H-x 

[The comment recommends adding new AMR 

lines in GALL Tables IV.E, VII.I, and VIII.H, for 

carbon steel or stainless steel bolting in an 

environment of air – outdoor (external), with 

an AERM of loss of preload due to thermal 

effects, gasket creep, and self-loosening 

managed by AMP XI.M18, “Bolting Integrity.”]

GALL addresses loss of preload for steel 

closure bolting in an air-indoor (external) 

environment (V.E-5, VII.I-5 and VIII. H-5) but 

does not address stainless steel bolting or an 

air-outdoor (external) environment. GALL 

AMP XI.M18 provides for management of loss 

of pre-load, so this program can also be 

applied here.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Loss of pre-loa

that is not dep

external enviro

specific bolting 

creep and self

in bolted conn

environment. A

“Bolting Integr

provisions for 

effect. New AM

118, VII.I.AP-2

151 were adde

stainless steel 

environment o

(External).

457 V.E, VII.I

ML101880269,

Comment V.Ex, VII.I-x 

[The comment recommends adding new AMR 

lines in GALL Tables V.E and VII.I for nickel 

alloy, steel or stainless steel bolting in various 

environments (air with borated water leakage, 

raw water, treated borated water, fuel oil), with 

an AERM of loss of preload due to thermal 

effects, gasket creep, and self-loosening 

managed by AMP XI.M18, “Bolting Integrity.”]

GALL addresses loss of preload for steel 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Loss of pre-loa

that is not dep

external enviro

creep and self

in bolted conn

environment. T

previously fou

be acceptable 

preload for var

materials in liq
NUREG-1950 IV-64 April 2011

Table IV-6. Analysis and Disposition of Public Comments on Chapter V, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

closure bolting in an air-indoor (external) 

environment (V.E-5, VII.I-5 and VIII. H-5) but 

does not address other materials and 

environments. GALL AMP XI.M18 provides for 

management of loss of pre-load, so this 

program can also be applied here.

such as raw w

water, fuel oil, 

New AMR item

V.E.EP-120, V

122; and VII.I.

265, VII.I.AP-2

were added fo

steel bolting in 

raw water, trea

fuel oil, or trea

respectively.
April 2011 IV-65 NUREG-1950

Table IV-7. Analysis and Disposition of Public Comments on Chapter VI, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

256 VI.A

ML101830328,

Comment VI.A1 

Page VI A-1, System, Structures and 

Components, Paragraph 2: Remove proposed 

new third sentence beginning "As specified 

in..." Revise to remove reference, start at 

"The electrical distribution..." 

VI.A-1: This section also addresses 

components that are relied upon to meet the 

station blackout (SBO) requirements for 

restoration of offsite power. The offsite power 

system relied upon in the plant-specific 

current licensing basis for compliance with 10 

CFR 50.63, that is used to connect the plant 

to the offsite power source, is included in the 

SBO restoration equipment scope. As 

specified in U.S. Nuclear Regulatory

Commission (NRC) RG (RG) 1.60, 

“Monitoring the Effectiveness of Maintenance 

at Nuclear Power Plants,” The electrical 

distribution equipment out to the first inter-tie 

with the offsite distribution system (i.e., 

equipment in the switchyard) should be 

included within the SBO restoration 

equipment scope. This path typically includes 

the switchyard circuit breakers the first intertie devices

The staff partially 

agrees with this 

comment and some

changes to the GALL 

Report have been 

made.

 that connect to the offsite system 

power transformers (startup transformers), the 

transformers themselves, the intervening 

overhead or underground circuits between 

circuit breaker and transformer and 

transformer and onsite electrical distribution 

system (including bus ducts or cables), and 

This comment 

LR-ISG-2008-

1.160 (mainten

withdrawn and 

as a reference 

in table II since 

1.160 has reta

breakers that c

system are typ
NUREG-1950 IV-66 April 2011

Table IV-7. Analysis and Disposition of Public Comments on Chapter VI, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

associated control circuits and structures. 

However, the staff's review is based on the 

plant-specific current licensing basis, 

regulatory requirements, and offsite power 

design configurations 

257 VI.A

ML101830328,

Comment VI.A2 

Page VI A-1, System Interfaces, Paragraph 1: 

Remove proposed change. Make it consistent 

with Section 3.

VI.A-2 

Electrical cables and connections functionally 

interface with all plant systems that rely on 

electric power or instrumentation and control. 

Electrical cables and connections also 

interface with and are supported by structural 

commodities (e.g., cable trays, conduit, cable 

trenches, cable troughs, duct banks, cable 

vaults, and manholes) that are reviewed, as 

appropriate, in the Systems, Structures, and 

Components section.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

No technical b

incorporate thi

editorial in nat

258 VI.A 

ML101830328,

Comment VI.A3 

Reference paragraphs in VI.A-1. Make 

changes to account for removing the old SBO 

language.

VI.A-3: This section also addresses 

components that are relied upon to meet the 

station blackout (SBO) requirements for 

restoration of offsite power. The offsite power 

system relied upon in the plant-specific 

current licensing basis for compliance with 10 

CFR 50.63, that is used to connect the plant 

to the offsite power source, is included in the 

The staff partially 

agrees with this 

comment and some

changes to the GALL 

Report have been 

made.

No technical b

incorporate thi

editorial in nat

editorial in nat

referencing RG 

(maintenance 

and should no

reference in G

the staff's revie

plant-specific c

basis, regulato
April 2011 IV-67 NUREG-1950

Table IV-7. Analysis and Disposition of Public Comments on Chapter VI, May 2010 Public Comment Draft 

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

SBO restoration equipment scope. As 

specified in U.S. Nuclear Regulatory 

Commission (NRC) RG (RG) 1.60, 

“Monitoring the Effectiveness of Maintenance 

at Nuclear Power Plants,” The electrical 

distribution equipment out to the first inter-tie 

with the offsite distribution system (i.e., 

equipment in the switchyard) should be 

included within the SBO restoration 

equipment scope. This path typically includes 

the switchyard circuit breakers the first intertie devices

and offsite pow

configurations

the circuit brea

the offsite syst

scope.

 that connect to the offsite system 

power transformers (startup transformers), the 

transformers themselves, the intervening 

overhead or underground circuits between 

circuit breaker and transformer and 

transformer and onsite electrical distribution 

system (including bus ducts or cables), and 

associated control circuits and structures.
NUREG-1950 IV-6

8 April 2011

Table IV-8. Analysis and Disposition of Public Comments on Chapter VII, May 2010 Public Comment Draf

Rev. 2 

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

883 VII.A2

ML101880269 

Comment 23

Include other neutron absorbing materials.

Materials: Boral, boron steel, (ADD) 

carborundum, metamic

Inclusion of other neutron absorbing materials 

is consistent with LR-ISG-2009-01 and AMP 

XI.M40

The staff does not 

agree with this 

comment and the 

GALL Report has not 

been changed. 

This AMR item 

information in 

Interim Staff G

01. The additio

considered be

the ISG.

884 VII.A2

ML101880269 

Comment 24

Include other neutron absorbing materials.

Materials: Boral, boron steel, (ADD) 

carborundum, metamic

Inclusion of other neutron absorbing materials 

is consistent with LR-ISG-2009-01 and AMP 

XI.M40

The staff does not 

agree with this 

comment and the 

GALL Report has not 

been changed. 

This AMR item 

information in 

Interim Staff G

01. The additio

considered be

the ISG.

505 VII.C1 

ML101880269, 

Comment 

VII.C1-X 

[The comment recommends adding new AMR 

lines for GALL Table VII.C1 for asbestos 

cement or reinforced concrete piping, piping 

components and piping elements in a raw

water environment with an aging effect of 

Cracking/settling, Loss of material/abrasion, 

cavitation, aggressive chemical attack, or

leaching, changes in material properties due 

to aggressive chemical attack, managed by

Chapter XI.M20, “Open-Cycle Cooling Water 

System.”] 

Reinforced concrete and asbestos cement 

pipe/components are mechanical components 

in raw water [that] have the same aging 

effects as structural concrete. An approved 

precedent exists for adding this material, 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Reinforced co

cement pipe w

GALL Report i

for external su

VII.C1.AP-157

internal enviro

should be add

Also, AMP XI.

include these a
April 2011 IV-69 NUREG-1950

Table IV-8. Analysis and Disposition of Public Comments on Chapter VII, May 2010 Public Comment Draf

Rev. 2 

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

environment, aging effect, and program 

combination to the GALL Report. As shown in 

Harris SER page 3-560, the staff accepted the 

position that cracking, loss of material and 

changes in material properties for reinforced 

concrete and asbestos cement 

pipe/components in a raw water environment 

can be managed with the Open Cycle Cooling 

Water AMP (XI.M20). AMP XI.M20 was 

developed to provide for proper management 

of the aging effects for this MEAP 

combination. 

Ref: ASTM C296, Standard Specification for 

Asbestos-Cement Pipe

430 VII.C1 

ML101880269

Comment 

VII.C1-X 

[The comment recommends adding new AMR 

lines for GALL Table VII.C1 for asbestos 

cement or reinforced concrete piping, piping 

components and piping elements in an airoutdoor environment with an aging effect of 

Cracking/settling, Loss of material/abrasion, 

cavitation, aggressive chemical attack, and 

leaching, changes in material properties due 

to aggressive chemical attack, managed by

Chapter XI.M36, “External Surfaces 

Monitoring of Mechanical Components.”] 

Reinforced concrete and asbestos cement 

pipe/components are mechanical components 

in an outdoor air environment [that] have the 

same aging effects as structural concrete. An 

approved precedent exists for adding this 

material, environment, aging effect, and 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Reinforced co

cement pipe w

GALL Report i

for external su

VII.C1.AP-157

to an air-outdo

to weather con

AMP XI.M36, a

address these 

effects.
NUREG-1950 IV-70 April 2011

Table IV-8. Analysis and Disposition of Public Comments on Chapter VII, May 2010 Public Comment Draf

Rev. 2 

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

program combination to the GALL Report. As 

shown in Harris SER page 3-560, the staff 

accepted the position that cracking, loss of 

material and changes in material properties 

for reinforced concrete and asbestos cement 

pipe/components in an outdoor air 

environment can be managed with the 

External Surfaces AMP (XI.M36). AMP 

XI.M36 was developed to provide for proper 

management of the aging effects for this 

MEAP combination. 

Ref: ASTM C296, Standard Specification for 

Asbestos-Cement Pipe

438 VII.C1

ML101880269 

Comment 

VII.C1-x 

[This comment recommends adding new AMR

lines in GALL Table VII.C1 for asbestos 

cement or reinforced concrete piping, piping 

components and piping elements in a soil

environment with an aging effect of 

Cracking/settling, Loss of material/aggressive 

chemical attack, and leaching, Changes in 

material properties due to aggressive 

chemical attack managed by Chapter XI.M34, 

“Buried Piping and Tanks Inspection.”] 

Reinforced concrete and asbestos cement 

pipe/components are mechanical components 

buried in a soil environment [that] have the 

same aging effects as structural concrete. An 

approved precedent exists for adding this 

material, environment, and aging effect 

combination to the GALL Report. As shown in 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Already includ

Report. See ite

AMP XI.M34 w

replaced by AM
April 2011 IV-71 NUREG-1950

Table IV-8. Analysis and Disposition of Public Comments on Chapter VII, May 2010 Public Comment Draf

Rev. 2 

Comment 

Number

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Reference No.

Comment NRC Disposition Tech

Harris SER page 3-560, the staff accepted the 

position that cracking, loss of material and 

changes in material properties are appropriate 

aging effects for reinforced concrete and 

asbestos cement pipe/components buried in a 

soil environment. 

AMP XI.M34 was developed to provide for 

proper management of the aging effects for 

this MEAP combination. This program 

provides an acceptable means of managing 

aging of these components. The 

implementation of this program provides 

reasonable assurance that the component’s 

intended functions will be maintained within 

the CLB for the period of extended operation.

Ref: ASTM C296, Standard Specification for 

Asbestos-Cement Pipe

445 VII.C1

ML101880269 

Comment 

VII.C!-x 

[This comment recommends adding new AMR

lines in GALL Table VII.C1 for HDPE piping, 

piping components and piping elements in a 

soil environment with no aging effect and no 

AMP.]

HDPE in a soil environment is not expected to 

age. Carbon black is added to HDPE for 

protection from ultraviolet exposure and 

ultraviolet exposure is not an issue for buried 

HDPE pipe. Piping system design 

temperatures are well below the oxidation 

induction temperature requirement of 220C. 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The staff ackn

data exist whic

HDPE pipe is 

absorption of w

data the staff a

that the risk of 

due to water a

blistering and 

changes appe

further acknow

associated wit

in some HDPE 

favorable. The 

however, that 
NUREG-1950 IV-72 April 2011

Table IV-8. Analysis and Disposition of Public Comments on Chapter VII, May 2010 Public Comment Draf

Rev. 2 

Comment 

Number

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Reference No.

Comment NRC Disposition Tech

Slow crack growth is the predominant failure 

mode for HDPE. This failure mode is 

addressed by material testing required by 

ASTM D-3350, Standard Specification for 

Polyethylene Plastics Pipe and Fittings 

Materials. PENT Testing performed under 

ASTM D-3350 measures resistance of HDPE 

to slow crack growth and test results can be 

correlated to material service life. HDPE 

materials used in nuclear safety class 

applications are required to as a minimum 

meet ASTM classification 445574C. PENT 

testing for materials assures that slow crack 

growth is not a failure mode during the design 

life of the piping. Slow crack growth occurs at 

a very slow rate and this condition cannot be 

observed by field inspection.

HDPE does not absorb water according to 

Plastic Pipe Institute technical report PPI TR19, Chemical Resistance of Thermoplastic 

Piping Materials based on testing performed 

at temperatures up to 140 degrees F. HDPE 

is not subject to water absorption and 

subsequent osmotic blistering that can occur 

with other polymeric materials. There is no 

color change in response to water absorption 

with HDPE. 

short term test 

long term nucl

operating expe

exists. Based 

term field expe

materials in th

the staff canno

absence of ag

exposed to so

conclusion, the 

recommendati

management f

soil in AMP XI

items AP-239 

459 VII.C1, VIII.F2, 

VIII.G

ML101880269 

Comment 

[This comment recommends adding new AMR

items in GALL Tables VII.C1, VII.F2, and 

VIII.G for PVC piping, piping components and 

piping elements in an air-indoor controlled 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

The staff has a

position in Vog

3.3.2.3.23, wh

there is no ind
April 2011 IV-73 NUREG-1950

Table IV-8. Analysis and Disposition of Public Comments on Chapter VII, May 2010 Public Comment Draf

Rev. 2 

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Number

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Comment NRC Disposition Tech

VII.C1-x, 

VII.F2-x, VIII.G 

environment or condensation (internal) with 

no aging effect and no AMP.]

As identified in “Engineering Materials 

Handbook – Engineering Plastics,” PVC is 

unaffected by water, concentrated alkalis, 

non-oxidizing acids, oils, ozone, sunlight, or 

humidity changes. Unlike metals, 

thermoplastics do not display corrosion rates, 

and rather than depend on an oxide layer for 

protection, they depend on chemical 

resistance to the environments to which they 

are exposed. Plastic is an impervious material 

and once selected for the environment will not 

have any significant age related degradation. 

No age related industry experience has been 

identified for plastic material in air-indoor or 

condensation (internal) environments. The 

staff’s review in the TMI SER (NUREG-1928) 

found that air-indoor environments on PVC 

materials will not result in aging effects that 

will be of concern during the period of 

extended operation.

have been made. industry that P

thermoplastics 

internal indoor 

have any agin

management. 

operating temp

historically goo

resistance dat

components, c

of historic neg

experience, in

not likely to ex

degradation fro

nonaggressive 

materials do n

rates as metal

on chemical re

environments 

exposed. 

Therefore, bas

experience an

proper design 

the material, th

PVC piping co

to an indoor ai

exhibit no agin

management f

extended oper

Because the a

and the recom

none, the chan
NUREG-1950 IV-74 April 2011

Table IV-8. Analysis and Disposition of Public Comments on Chapter VII, May 2010 Public Comment Draf

Rev. 2 

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

implemented w

items. VII.J.AP

VIII.I.SP-152 a

885 VII.C1

ML101880269 

Comment 25

In addition to concrete and concrete cylinder 

piping, need to add a MEAP for asbestos 

cement piping. See new MEAP comments.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

AMR items VII

VII.C1.AP-155 

asbestos cem

has been adde

XI.M41.

886 VII.C1

ML101880269 

Comment 26

A new GALL line is needed to address 

cracking of fiberglass piping in a raw water 

environment that is managed by AMP XI.M38 

Internal Surfaces.

Complimentary MEAP for Open cycle cooling 

water fiberglass piping in a soil environment.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

An MEAP, VII.

added to the G

fiberglass pipin

environment. A

VII.C1-AP-238

GALL Report t

internal enviro

cooling water. 

VII.C1.AP-238

water system, 

credited.

887 VII.C1

ML101880269 

Comment 27

A new GALL line is needed to address 

cracking of HDPE piping in a raw water 

environment that is managed by AMP XI.M38 

Internal Surfaces.

Complimentary MEAP for Open cycle cooling 

water HDPE piping in a soil environment.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

An MEAP, VII.

added to the G

HDPE piping e

environment. A

VII.C1.AP-239

internal enviro

cooling water. 

VII.C1.AP-239

water system, 

credited.
April 2011 IV-75 NUREG-1950

Table IV-8. Analysis and Disposition of Public Comments on Chapter VII, May 2010 Public Comment Draf

Rev. 2 

Comment 

Number

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Commenter 

Reference No.

Comment NRC Disposition Tech

888 VII.C1

ML101880269 

Comment 28

Revise the material to read copper alloy to be 

consistent with other copper alloy lines:

Material: copper alloy

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The GALL Rep

copper instead 

this has been 

VII.C1.AP-174

437 VII.C2, VII.H2

ML101880269 

Comment 

VII.C2-x, 

VII.H2-x 

[This comment recommends adding new AMR

lines in GALL Tables VII.C2 and VII.H2 for 

aluminum piping, piping components and 

piping elements in a closed-cycle cooling 

water environment with an aging effect of 

Loss of material due to pitting and crevice 

corrosion managed by Chapter XI.M21A2, 

“Closed Treated Water Systems.”] 

Closed-cycle cooling water environment is 

similar to treated water environments in GALL 

Rev. 2. GALL Rev 2 Chapter IX definitions 

acknowledge that closed-cycle cooling water 

is a subset of second category of treated 

water. Aluminum is subject to crevice 

corrosion due to the dependence of Al O2 3 film 

oxide for protection (Ref. Corrosion 

Engineering by Fontana). Aluminum is also 

prone to pitting in treated water systems 

(Metals Handbook)

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

GALL Report i

steel, steel and 

with the same 

AMP. Aluminu

be included. T

included for al

treated water e

therefore, is va

cooling water e

VII.C2.AP-254 

were added.

442 VII.C2, VII.H2, 

VIII.E

ML101880269 

Comment 

VII.C2-x, 

VII.H2-x, VIII.E-

[This comment recommends adding new AMR

lines in GALL Tables VII.C2, VII.H2, and 

VIII.E for aluminum piping, piping components 

and piping elements in a treated water

environment with an aging effect of Loss of 

material due to pitting and crevice corrosion 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

GALL Report i

combination in 

therefore, this 

can be added 

VII.H2. There 

AMR item, VII
NUREG-1950 IV-76 April 2011

Table IV-8. Analysis and Disposition of Public Comments on Chapter VII, May 2010 Public Comment Draf

Rev. 2 

Comment 

Number

Location in 

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Commenter 

Reference No.

Comment NRC Disposition Tech

x managed by Chapter XI.M2, “Water 

Chemistry” and XI.M32, “One-Time 

Inspection.”]

Consistent with GALL Rev. 1 for BWR treated 

water environments:

- Piping (aluminum, treated water) VII.E4-4 

- Piping (aluminum, treated water) VII.E3-7 

VIII.E.SP-90).

446 VII.C2

ML101880269 

Comment 

VII.C2-x 

[This comment recommends adding new AMR 

lines in GALL Table VII.C2 for elastomer seals 

and components in a closed cycle cooling

water environment with an aging effect of

hardening and loss of strength due to

elastomer degradation managed by Chapter

XI.M38, “Inspection of Internal Surfaces in

Miscellaneous Piping and Ducting

Components.”]

Consistent with GALL Rev 1 for elastomers in:

- Treated water (Spent Fuel Pool Cooling & 

Cleanup) VII.A4-1 

- Raw water (Open Cycle Cooling Water) 

VII.C1-1 

In general if the temperature is above 95F, 

then thermal aging may be considered 

significant.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Elastomers ar

GALL Report f

and raw water 

therefore; were 

cycle cooling w

is acceptable t

closed-cycle c

environment. 

948 VII.D

ML101880269 

A new GALL line is needed to address loss of 

material due to general, pitting, and crevice 

corrosion for copper alloy piping/tubing in a 

The staff agrees with 

this comment and 

associated changes 

Item VII.D.AP-

which relies on 
April 2011 IV-77 NUREG-1950

Table IV-8. Analysis and Disposition of Public Comments on Chapter VII, May 2010 Public Comment Draf

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Comment 

Number

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Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

Comment 29 condensation environment that is managed by 

XI.M24 Compressed Air Monitoring

A new GALL line is needed to address copper 

alloy piping/tubing in compressed air systems

to the GALL Report 

have been made.

949 VII.F1

ML101880269 

Comment 30

The AMP for this GALL line should be XI.M36 

External Surfaces AMP to agree with the 

material environment combination being 

managed: that is air-indoor, uncontrolled 

(external)

AMP XI.M38 (internal surfaces) is inconsistent 

with the environment managed (external 

surfaces). This is a generic comment for 

Sections V, VII, and VIII when an external 

environment is specified to be managed by 

AMP XI.M38 Internal Surfaces AMP. 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The incorrect A

for aging effec

surface. VII.F1

changed.

950 VII.F1

ML101880269 

Comment 31

The AMP for this GALL line should be XI.M36 

External Surfaces AMP to agree with the 

material environment combination being 

managed: that is air-indoor, uncontrolled 

(internal/external)

AMP XI.M38 (internal surfaces) is inconsistent 

with the environment managed (external 

surfaces). This is a generic comment for 

Sections V, VII, and VIII when an 

internal/external environment is specified to 

be managed. AMP XI.M36 (External Surfaces 

AMP) can manage the internal and external 

surfaces (see element 1). 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

AMP XI.M36 s

internal and ex

the same envi

XI.M36 can be 

managing the 

both the intern

surfaces. AMP 

have a similar 

VII.F1.AP-102 

951 VII.F1 Add (internal) to the environment for this 

GALL line to agree with the AMP XI.M38 

The staff agrees with 

this comment and 

To be consiste

XI.M38, intern
NUREG-1950 IV-78 April 2011

Table IV-8. Analysis and Disposition of Public Comments on Chapter VII, May 2010 Public Comment Draf

Rev. 2 

Comment 

Number

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Commenter 

Reference No.

Comment NRC Disposition Tech

ML101880269 

Comment 32

(Internal Surfaces AMP):

Condensation (internal

Add (internal) to the environment for this 

GALL line to agree with the AMP XI.M38 

(Internal Surfaces AMP). This is a generic 

comment for Sections V, VII, and VIII when an 

condensation environment is specified to be 

managed by AMP XI.M38 Internal Surfaces 

AMP. See GALL VII.F1.A-08 for consistency. 

) 

associated changes 

to the GALL Report 

have been made.

the AMR item. 

change made 

AMP XI.M38 is 

aging in an en

condensation.

463 VII.J

ML101880269 

Comment VII.Jx 

[This comment recommends adding new AMR

lines in GALL Table VII.J for aluminum piping, 

piping components and piping elements in a 

concrete environment with no aging effect and 

no AMP.]

GALL addresses stainless steel embedded in 

concrete (VII.J-17 & VIII.I-11). An approved 

precedent exists for adding this material, 

environment, aging effect, and program 

combination to the GALL Report. As shown in 

Browns Ferry SER page 3-322, the staff 

accepted the position that aluminum alloy 

embedded or encased in concrete has no 

aging effect that requires aging management. 

Aluminum has an excellent resistance to 

corrosion. On a surface freshly abraded and 

then exposed to air, the oxide film is only 5 to 

10 nanometer thick but is highly effective in 

protecting the aluminum from corrosion 

(Hollingsworth and Hunsicker 1979). 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Recent operat

not confirm thi

aluminum alloy

high pH and co

in a high pH e
April 2011 IV-79 NUREG-1950

Table IV-8. Analysis and Disposition of Public Comments on Chapter VII, May 2010 Public Comment Draf

Rev. 2 

Comment 

Number

Location in 

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Commenter 

Reference No.

Comment NRC Disposition Tech

Aluminum that is embedded/encased within 

concrete, loss of material is not considered an 

applicable aging effect. The concrete would 

first have to be degraded by other aging 

effects, which reduce the protective cover and 

potentially allow for the intrusion of aggressive 

ions causing a reduction in concrete pH. 

Aging management of concrete aging effects 

will manage the corrosion of the 

embedded/encased aluminum protective 

oxide layer. Concrete structures and 

components are designed in accordance with 

ACI standards and constructed using 

materials conforming to ACI and ASTM 

standards which provide fo[r] a good quality, 

dense, well cured, and low permeability 

concrete. Cracking is controlled through 

arrangement and distribution of reinforcing 

bars. 

434 VII.K 

ML101880269 

Comment 

VII.K-x 

[This comment recommends adding new AMR

lines in GALL Table VII.K for Copper alloy, 

stainless steel, or steel piping, piping 

components and piping elements in a potable 

water environment with an aging effect of 

Loss of material due to general (steel only), 

pitting and crevice corrosion managed by

Chapter XI.M38, “Inspection of Internal 

Surfaces in Miscellaneous Piping and Ducting 

Components.”] 

Potable water is water treated for drinking or 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Potable water 

treated for drin

Potable water 

safety related 

10 CFR 54.4(a

considered a s

An approved p

adding this ma

aging effect an

combination to 

As shown in D

Energy Center
NUREG-1950 IV-80 April 2011

Table IV-8. Analysis and Disposition of Public Comments on Chapter VII, May 2010 Public Comment Draf

Rev. 2 

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

other personnel uses. This additional AMR 

line-item is created to consider the aging of 

steel, stainless steel or copper alloy piping 

components in a potable water environment. 

Aging of stainless steel or copper alloy in a 

potable water environment is consistent with 

aging in other treated water environments 

such as demineralized water. The aging effect 

is also consistent with several recent industry 

precedents for aging of stainless steel or 

copper alloys in a potable water environment.

AMP XI.M38 was developed to provide for 

proper management of the aging effects for 

this MEAP combination. This program 

provides an acceptable means of managing 

aging of these components. The 

implementation of this program provides 

reasonable assurance that the component’s 

intended functions will be maintained within 

the CLB for the period of extended operation.

3.3.2.1.20, the 

XI.M38, Inspec

Surfaces in Mi

and Ducting C

manage the ag

material for the

environment. A

revised to inclu

materials in th

This comment 

VII.E5.AP-270 

506 VII

ML101880269,

Comment 

VII.E5

This comment recommends adding a new 

section for waste water systems and 10 new 

AMR Line items in GALL Table VII.E5. 

New lines are proposed to be added to 

NUREG-1801 for aging management review 

of waste water systems. AMP XI.M38, 

“Inspection of Internal Surfaces in 

Miscellaneous Piping and Ducting 

Components”, is proposed for inspections of 

internal surfaces of metal components that 

are not covered by other aging management 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The staff has n

have historica

the Open Cycl

AMP and asso

manage aging 

which are expo

but which do n

definition of op

water. The sta

that many of th

which the Ope
April 2011 IV-81 NUREG-1950

Table IV-8. Analysis and Disposition of Public Comments on Chapter VII, May 2010 Public Comment Draf

Rev. 2 

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

programs. Glass is managed consistent with 

existing GALL lines for glass in raw water in 

the Common Miscellaneous 

Material/Environment section of GALL.

Water AMP we

described as c

water systems

promote both a

efficiency in ev

renewal applic

modified the A

Internal Surfac

Piping and Du

(XI.M38) to inc

system other t

cooling water, 

fire water. The 

created AMR i

consistent with 
NUREG-1950 IV-82 April 2011

Table IV-9. Analysis and Disposition of Public Comments on Chapter VIII, May 2010 Public Comment Dra

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment/Proposed Change and Rationale NRC Disposition Tech

952 VIII.E

ML101880269 

Comment 33

Delete “buried” from the component name.

Buried piping, piping components, piping 

elements, tanks

Delete buried to be consistent with the other 

Structure/Component names for piping 

components in a soil environment.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The term “buri

distinguish it fr

piping and tan

in vaults or tro

953 VIII.I

ML101880269 

Comment 34

Line GALL VIII.I.SP-67 duplicates line 

VIII.I.SP-105. Delete one of the lines.

Editorial correction.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The AMR item

SP-67 was de

954 VIII.I

ML101880269

Comment 35

Line GALL VIII.I.SP-69 duplicates line 

VIII.I.SP-112.

Editorial correction.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The AMR item

SP-112 was d
April 2011 IV-83 NUREG-1950

Table IV-10. Analysis and Disposition of Public Comments on Chapter IX, May 2010 Public Comment Dra

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

955 IX.G

ML101880269 

Comment 36

Revise this definition consistent with the 

resolution of the scope of the buried 

components AMP. Recommend deleting the 

buried component definition as it describes an 

environmental condition. Also recommend 

deleting limited-access and below grade 

components consistent with the AMP M41 

scope definition – the environment for these 

components will be “air - indoor.” 

Revise this definition consistent with the 

resolution of the scope of the buried

components AMP.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

There was no 

for undergroun

956 IX.G

ML101880269 

Comment 37

Expand this definition to include other neutron 

absorbers (metamic & carborundumsteel)

Consistency with LR-ISG-2009-01

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The staff does 

comment. Acc

other neutron 

explicitly ment

The licensee is 

absorbers that 

included. Ther

materials are n

out in the AMP

need to be a d

957 IX.G

ML101880269 

Comment 38

Based on GALL Rev 2 AMR line usage, the 

second part of the treated water definition will 

apply primary or secondary chemistry controls 

to HVAC systems, aux boiler, or diesel cooling 

systems that are currently managed by closed 

cycle cooling water programs. For PWR 

Auxiliary Systems and Steam and Power 

Conversion Systems, either expand the 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed. 

The title of the 

Cooling Water

changed to the 

Water System

could be expa

treated water s
NUREG-1950 IV-84 April 2011

Table IV-10. Analysis and Disposition of Public Comments on Chapter IX, May 2010 Public Comment Dra

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

treated water AMR lines which are managed 

by AMP XI.M21 (Treated Water AMP) or 

create a secondary water 

(condensate/feedwater) environment and 

associated PWR AMR lines that rely on 

secondary water chemistry. 

Resolve inconsistent usage of PWR 

secondary water AMP XI.M2 for Auxiliary 

Systems (HVAC systems, Aux boilers, diesel 

cooling). Depending on the resolution create 

additional GALL AMR lines for treated water 

rather than closed cycle environments for 

systems with demineralized water and 

demineralized water with corrosion inhibitors. 

507 IX.D

ML101880269 

Comment IX.D

Definitions:

Potable Water - (new) Water that is treated for 

dinking or other personnel uses. 

Raw Water - (revised) Raw, untreated fresh, 

salt, or ground water. Water for use in opencycle cooling water systems.

Raw water may contain contaminants, 

including oil and boric acid, depending on the 

location, as well as originally treated water 

that is not monitored by a chemistry program.

Floor drains and 

reactor buildings and auxiliary building sumps 

may be exposed to a variety of untreated 

water that is thus classified as raw water, for 

the determination of aging effects.

Waste Water - (new) Radioactive, potentially 

radioactive, or non-radioactive waters that are 

The staff partially 

agrees with this 

comment and 

associated changes 

to the GALL Report 

have been made.

A separate de

water was not 

AMR Items ref

was added as 

water. 

The definition 

revised to inclu

in open-cycle c

systems. The 

water was add

radioactive, po

or non-radioac

collected from 

drains. This w

raw water defi
April 2011 IV-85 NUREG-1950

Table IV-10. Analysis and Disposition of Public Comments on Chapter IX, May 2010 Public Comment Dra

Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

collected from equipment and floor drains.

Waste waters may contain contaminants, 

including oil and boric acid, depending on 

location, as well as originally treated water 

that is not monitored by a chemistry program

Report, Revisi
NUREG-1950 IV-86 April 2011

Table IV-11. Analysis and Disposition of Public Comments on Chapter X TLAAs, May 2010 Public Comme

Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

133 X.M1

ML101830328

Comment 

X.M1-1 

Change the title to match the SCOPE of the 

program and Sections II through VIII of GALL. 

Cumulative fatigue damage exists for far more 

than the reactor coolant pressure boundary 

components as stated in the AMP. 

Containment, supports, steam generator 

secondary sides, reactor internals, ESF, Aux 

and S&P all have cumulative fatigue damage 

entries in the GALL AMR tables. 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Fatigue damag

than the reacto

boundary com

134 X.M1 

ML101830328

Comment 

X.M1-2 

Remove word “structural” and “reactor coolant 

system” from multiple locations so as not to 

unnecessarily restrict the program scope. 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Scope include

coolant system

defines what is 

135 X.M1 

ML101830328

Comment 

X.M1-3 

The discussion of using NUREG/CR-6909 

needs to be specific, not only in this program 

but also in other portions of GALL Rev 2 and 

NUREG-1800 Rev 2. RG 1.207 and 

NUREG/CR-6909 do not allow use of the 

nickel-alloy Fen from 6909 with a CUF 

calculated from the existing ASME stainless 

steel curve. Assuming the staff wants to 

maintain this requirement, any discussion of 

this should be very specific. Suggest that 

rather than trying to summarize it here, just 

reference NUREGs 5704 and 6583 and 6909. 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

RG 1.207 and 

do not allow us

Fen from 6909 

calculated from 

stainless steel 

Revised to ver

how Fen is to b

carbon and low

stainless steel

materials.

136 X.M1 

ML101830328

Comment 

X.M1-4 

The last paragraph of the program description 

is unnecessary. The GALL report wouldn’t 

contain detailed description of a program that 

wasn’t acceptable.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

The GALL Rep

contain a deta

program that w
April 2011 IV-87 NUREG-1950

Table IV-11. Analysis and Disposition of Public Comments on Chapter X TLAAs, May 2010 Public Comme

Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

Program 

Description

have been made.

137 X.M1 

ML101830328

Comment 

X.M1-5 

As the scope now applies to more than the 

RCS, separate the RCS environmental fatigue 

to a second paragraph in the SCOPE. Include 

some of the words from DETECTION OF 

AGING EFFECTS as they fit better here. 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Scope applies 

coolant system

sentence abou

detection of ag

of work ties in 

used in the sco

Revised to sta

purposes of m

tracking, applic

for a set of sam

system compo

usage calculat

the effects of t

environment. T

should include 

identified in NU

additional plan

component loc

coolant pressu

may be more l

considered in 

138 X.M1 

ML101830328 

Comment 

X.M1-6 

In Detection of Aging Effects need to delete 

the discussion of monitoring specific locations. 

Add some of it in the scope as discussed 

above. Note that this should be an option, as 

it is in PARAMETERS 

MONITORED/INSPECTED, not a 

requirement. Most plants just count cycles 

rather than monitor specific locations. 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Most plants jus

rather than mo

locations.
NUREG-1950 IV-88 April 2011

Table IV-11. Analysis and Disposition of Public Comments on Chapter X TLAAs, May 2010 Public Comme

Report, Rev. 2

Comment 

Number

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139 X.M1 

ML101830328 

Comment 

X.M1-7 

Need to reword MONITORING AND 

TRENDING, ACCEPTANCE CRITERIA, and 

CORRECTIVE ACTIONS to be more concise 

and not to mention the RCS pressure 

boundary. 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Scope include

coolant system

elements need 

accordingly.

140 X.M1 

ML101830328 

Comment 

X.M1-8 

In Program Description recommend add the 

following in the First paragraph - at end: “The 

program also verifies that the severity of the 

monitored transients are bounded by the 

design transient definition for which they are 

classified.” To provide additional clarity on 

transients.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

This change p

and does not c

intent of the A

technical basis 

142 X.M1 

ML101830328 

Comment 

X.M1-10

Scope of program, add: The scope includes 

those components that have been identified to 

have a fatigue TLAA. 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Provides clarif

consistent with 

A.1.2.3.1 and 

technical inten

Therefore, no 

needed.

143 X.M1 

ML101830328 

Comment 

X.M1-11

Preventive Actions: For clarity change to: “The 

program prevents the fatigue TLAAs from 

becoming invalid by assuring that the fatigue 

usage resulting from actual operational 

transients does not exceed the Code design 

limit of 1.0, including environmental effects 

where applicable. This could be caused by the 

numbers of actual plant transients exceeding 

the numbers used in the fatigue analyses or 

by the actual transient severity exceeding the 

bounds of the design transient definitions. 

However, in either of these cases, if the 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

This change p

and does not c

intent of the A

technical basis 
April 2011 IV-89 NUREG-1950

Table IV-11. Analysis and Disposition of Public Comments on Chapter X TLAAs, May 2010 Public Comme

Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

analysis is revised to account for the 

increased number or severity of transients 

such that the CUF value remains below 1.0, 

the program remains effective.” 

895 X.M1 

ML101830328 

Comment 

X.M1-9 

Recommend adding the following in Program 

Description in the last paragraph to provide 

clarification on the use of Fen. “The 

environmentally-adjusted Cumulative Usage 

Factor is calculated by multiplying the 

Cumulative Usage Factor (CUF) by an 

environmental correction factor, Fen. The 

environmental correction factor for carbon or 

low-alloy steel may be computed using the 

equations from either NUREG/CR-6583 or 

NUREG/CR-6909, applied to CUF value 

determined using the applicable ASME 

Section III fatigue curve. The environmental 

correction factor for austenitic stainless steel 

may be computed using the equation from 

NUREG/CR-5704 in conjunction with the CUF 

value determined using the ASME Section III 

fatigue curve. Alternatively, the environmental 

correction factor for austenitic stainless steel 

may be determined using the equation from 

NUREG/CR-6909 in conjunction with the CUF 

value determined using either the 

NUREG/CR-6909 fatigue curve or the ASME 

Section III fatigue curve. The environmental 

correction factor for nickel-based alloys may 

be computed using the equation from 

NUREG/CR-6909 in conjunction with the CUF 

The staff agrees with 

this comment and 

alternative changes 

to the GALL Report 

have been made.

The program d

revised in an a

clarify how to d

environmental 

for various ma

clarifies which 

different mater
NUREG-1950 IV-90 April 2011

Table IV-11. Analysis and Disposition of Public Comments on Chapter X TLAAs, May 2010 Public Comme

Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

value determined using the NUREG/CR-6909 

stainless steel fatigue curve.” 
April 2011 IV-91 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

132 Chapter XI

ML101610407, 

Comment 1 

Document Title: NUREG-1801 Rev2 

Comments: A specific “numbered” sub section 

should be added to AMP descriptions that 

defines a nominal implementation schedule of 

the AMP. Citing a standard or standards upon 

which the applicant can (and NRC for that 

matter) can derive a schedule can lead to 

ambiguity when validating completion of 

commitment.

A nominal implementation schedule should 

indicate. The minimum number of times the 

AMP should be executed in the period of 

extended operation. The earliest and latest 

time the applicant can initiate the first 

implementation and the minimum and 

maximum interval of time between 

implementations during the extended period 

of operations.

Example: Under normal conditions and results 

of previous implementations (if applicable) 

meet expectations. The AMP should be 

implemented 4 times during the period of 

extended operations. The AMP should not be 

executed within the first 2 years of extended 

operation and the interval between 

implementations should not be less than 3 

years or exceed 4 years.

Likewise any applicant proposing a Plant 

Specific or GALL AMP with modifications 

must describe an implementation schedule 

that is “auditable” with the assumption that 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Element 4, De

Effects, in eac

frequency of te

along with the 

as applicable.

For example, i

AMPs, in XI.E

tested at least 

years, which p

points in 20 ye

test being com

period of exten

In mechanical 

frequency in m

by the (1) ISI p

approved BWR

National Fire P

Association (N

(4) plant surve

maintenance p

specifically pre

In structural A

is defined in th

Maintenance R

Therefore, the 

implementatio

adequately de

individual AMP

detection of ag
NUREG-1950 IV-92 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

positive and expected results occur for each 

implementation.

158 XI.M11B

ML101830328 

Comment 

XI.M11B-1 

Removed discussion of the water chemistry 

guidelines and just referred to the GALL water 

chemistry program in Program Description.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

There was no 

intent. This ch

identification o

Chemistry Gui

Report, XI.M2

159 XI.M11B 

ML101830328 

Comment 

XI.M11B-2 

Change element 2 to match element 2 in 

other condition monitoring programs. In 

particular delete the reference to the EPRI 

document and just refer to XI.M2.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

There was no 

intent. This ch

identification o

Chemistry Gui

Report, XI.M2

160 XI.M11B 

ML101830328

Comment 

XI.M11B-3 

Element 3 needs revised because PWSCC 

and BAC never apply to the same component. 

PWSCC applies to nickel-alloy components 

and BAC applies to steel components.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made. 

Wording was r

PWSCC applie

components a

steel compone

cracking in nic

components, b

degradation m

for steel comp

Corrosion is a

primarily applic

components.

161 XI.M11B 

ML101830328 

Comment 

XI.M11B-4 

The discussion of Water Chemistry in Element 

10 sounds like this program includes 

maintaining water chemistry. That discussion 

should be altered to make it clear that XI.M2 

maintains water chemistry.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

This was a cla

change of tech

Therefore, no 

needed.

162 XI.M12 See the comments on XI.M9. CF3, CF3A, The staff agrees with Clarified to dis
April 2011 IV-93 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

ML101830328, 

Comment 

XI.M12-1 

CF8, CF8A should be considered lowmolybdenum steels.this comment and 

associated changes 

to the GALL Report 

have been made.

low molybdenu

molybdenum c

163 XI.M12 

ML101830328 

Comment 

XI.M12-2 

PREVENTIVE ACTIONS should be the same 

as other condition monitoring programs.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Revised to ma

consistent with 

164 XI.M12 

ML101830328 

Comment 

XI.M12-3 

Suggest that the paragraph added to M09 

about detection of reduction in fracture 

toughness also be added to Element 3 of this 

program.

Element 3 Parameters Monitored/Inspected, 

NEI comment XI.M12-3 in packet #4 suggests 

that the following paragraph be added at the 

end of this element:

“The program does not directly monitor for 

loss of fracture toughness that is induced by 

thermal aging; instead, the impact of loss of 

fracture toughness on component integrity is 

indirectly managed by using visual or 

volumetric examination techniques to monitor 

for cracking in the components and by 

applying applicable reduced fracture 

toughness properties in the flaw evaluations if 

cracking is detected in the components and is 

extensive enough to warrant a supplemental 

flaw growth or flaw tolerance evaluation under 

the applicable BWRVIP guidelines or ASME 

The staff partially 

agrees with this 

comment and 

associated changes 

to the GALL Report 

have been made.

Element 3 rev

portion of the c
NUREG-1950 IV-94 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

Code, Section XI requirements.”

165 XI.M16A 

ML101830328 

Comment 

XI.M16A-1 

The program description seems to be overly 

detailed and descriptive for a general 

description when it could more easily just refer 

to MRP-227 for most of the items. Some items 

are also repeated in the 10 elements where 

this detail is appropriate. 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The informatio

response to th

contained in M

the basis docu

There was no 

intent.

166 XI.M16A 

ML101830328 

Comment 

XI.M16A-2 

In element 2 preventive actions there is a 

discussion of applicability limitations for MRP227. These should not be in preventive 

actions but in scope section.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The Preventive 

element was r

information ab

limitations to th

Program. This 

technical inten

moved from th

program elem

appropriate pr

167 XI.M16A 

ML101830328 

Comment 

XI.M16A-3 

In element 1, 3 and 4 there are sentences that 

state there is an administrative action item for 

the applicant to fill in the type of plant and 

vendor. This is not used for any other GALL 

programs and not sure why this needs to be 

written this way. The applicant will develop 

their program based on the GALL program 

requirements depending on the make and 

vintage of his plant. 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Since the MRP

is dependent u

and the design 

additional adm

information in 

are necessary 

this program. 

168 XI.M17 

ML101830328 

Comment 

XI.M17-1 

The flow- accelerated corrosion (FAC) 

program is limited to Rev. 2 or 3 rather than 

“Rev. 2 or later” as recommended by NEI. 

This will create exceptions to later versions. 

Credit for NRC staff review of later versions 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

The staff cann

approval to fut

industry stand

been reviewed 

the staff to ens
April 2011 IV-95 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

and acceptance in a safety evaluation report 

could eliminate exception. 

changed. integrity.

It is necessary 

edition of the N

reviewed by th

renewal becau

have not been 

generic accep

license renewa

preface was a

Report, Chapt

circumstances 

revisions of ind

may be refere

renewal applic

169 XI.M17 

ML101830328 

Comment 

XI.M17-2 

Element 4 states wall thickness 

measurements are performed every outage. 

This may not be true in the future as piping 

replacements reduce the amount and 

frequency of inspections.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The NSAC doe

exact frequenc

licensee deter

needed. 

524 XI.M17

ML101880265 

Comment 1

This comment addresses the “scope of 

program” element of the GALL AMP XI.M17. 

The term carbon steel “lines” seems restrictive 

and not clearly defined in either the GALL 

Report (NUREG 1801) or the SRP document 

(NUREG 1800). 

Considering the context of remainder 

elements in this AMP and the intended aging 

(FAC) covered by the AMP the reviewer 

suggests that the text be revised to include 

the following:

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

SG tube suppo

not part of FAC 

possible inside 
NUREG-1950 IV-96 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

“The FAC program is to assure the structural 

integrity of all carbon steel lines and piping 

components containing high-energy fluids 

(two-phase as well as single-phase) is 

maintained. Valve bodies and other 

components such as the steam generator 

tube supports and internals required for the 

functionality of the high energy systems are 

also covered by the program.”

525 XI.M17

ML101880265 

Comment 2

This comment addresses the “detection of 

aging effects” element of the GALL AMP 

XI.M17. For better clarity the following 

changes to the text are suggested:

“A representative sample of components is 

selected for wall thickness measurements 

based on the most susceptible locations, 

every refueling outage. The extent and 

schedule of the inspections should ensure 

detection of wall thinning before the loss of 

intended function.”

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

"Should" is no

guidance. Say

ensure... remo

"should." 

526 XI.M17

ML101880265 

Comment 3

This comment and concern deal with the 

“monitoring and trending” element of the 

GALL AMP XI.M17. In this element the GALL 

Report states:

“CHECWORKS is acceptable because it 

provides a bounding analysis for FAC. The 

analysis is bounding because in general the 

predicted wear rates and component 

thicknesses are conservative when compared 

to actual field measurements.”

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

It is recognized 

is not always c

predicting com

Therefore whe

show the pred

conservative t

re-calibrated u

data.
April 2011 IV-97 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

The concern is that the analysis may not 

necessarily be bounding in every case and 

the conservatism “in general” may not be 

sufficient to prevent possible impairment prior 

to next scheduled inspection. The bounding 

and conservatism aspects are both subject to 

(a) input (parameters) assumptions being 

matched (or not being exceeded) in the 

service conditions and (b) the uncertainty 

resulting from these conditions as well as from 

the model [Ref. 1]. This concern is also 

supported by (a) the observed spread in 

comparing the predictions versus 

observations [Ref. 2], (b) the lack of bounding 

value of prediction where actual service 

failures have occurred [Ref. 2], and (c) no 

explicit accounting for the input and modeling 

uncertainty in the suggested analysis method.

Therefore, as a minimum, the proper 

accounting of the uncertainty on predicted 

wear rates and thicknesses needs to be part 

of the monitoring and trending activity.

References:

1. Garud, Y. S., “Techniques for Improved 

Reliability of Wall Thinning Estimation,” Paper 

No. PVP2006-ICPVT-11-93414, 2006 ASME 

Pressure Vessel and Piping Conference, 

ASME, NY (July 2006).

2. Garud, Y. S., “Issues and Advances in the 

Assessment of Flow Accelerated Corrosion,” 

Paper No. 203160, presented at the 14th 
NUREG-1950 IV-98 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

International Conference on Environmental 

Degradation of Materials in Nuclear Power 

Systems, Virginia Beach, Virginia, (August 

2009).

527 XI.M17

ML101880265 

Comment 4

This comment and concern deal with the 

“operating experience” (OE) element of the 

GALL AMP XI.M17. The OE section needs to 

cover more recent occurrences such as the 

feedwater heater rupture at Point Beach 1 

[Ref. 3], the feedwater heater leaks at Pilgrim 

and Susquehanna [Ref. 3], the double-ended 

guillotine break of 8-inch line at Callaway [Ref. 

4]. The OE should also include the [latent] 

rupture event, discussed in Ref. 2, even 

though it is from a fossil unit, because of its 

direct relevance and commonality of 

conditions with nuclear systems.

It should be noted that even if one accepts the 

possible administrative errors (such as 

missing the list of components to be 

inspected) as a contributing factor to service 

events, the comparison of actual (observed) 

wear rate versus model prediction (from these 

events) are still valid and demonstrate the 

need to account for uncertainty [Ref. 2].

Other lessons of likely importance suggested 

by more recent field observations and 

assessment [Ref. 2] include (a) some 

cautionary note about “partial” replacements 

with high-Cr parts in an otherwise susceptible 

carbon steel line, and (b) the FAC potential for 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

In recognition 

experience de

commenter, th

XI.M17 referen

the corrective 

include “ when 

components a

resistant mate

Cr materials, t

components s

closely to mitig

wear.” 
April 2011 IV-99 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

locations with higher and lower temperature 

ranges than the previously presumed 

susceptibility range.

References:

2. Garud, Y. S, “Issues and Advances in the 

Assessment of Flow Accelerated Corrosion,” 

Paper No. 203160, presented at the 14th 

International Conference on Environmental 

Degradation of Materials in Nuclear Power 

Systems, Virginia Beach, Virginia, (August 

2009).

3. USNRC, “Rupture of the Shell Side of a 

Feedwater Heater at the Point Beach Nuclear 

Plant,” Information Notice (IN) 99-19, June 23, 

1999.

4. Union Electric, “Manual Reactor Trip Due 

To Heater Drain System Pipe Rupture 

Caused By Flow Accelerated Corrosion, LER 

1999-003-01,” ULNRC-4233, Union Electric 

Co., Callaway Unit 1, May 1 (2000).

[Also, as Event Notification 36015, August 

1999].

170 XI.M18

ML101830328 

Comment 

XI.M18-1 

Revise first paragraph of Program Description 

for clarity.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

This is not a te

format for listin

references wa

Therefore, no 

needed.

171 XI.M18 

ML101830328 

Currently the Program Description says this 

program doesn’t apply to structural bolts and 

the SCOPE says this program doesn’t apply 

The staff agrees with 

this comment and 

associated changes 

The Program D

Scope of Prog

state in both p
NUREG-1950 IV-100 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

Comment 

XI.M18-2 

to the Reactor Vessel closure studs. Both 

exceptions should be listed both places.

to the GALL Report 

have been made.

program does 

structural bolti

closure stud b

has been revis

only to closure 

structural bolti

applies for the 

closure stud b

is consistent w

AMP XI.M18, a

head closure s

AMPs affecting 

(XI.S1, S3, S6

should be iden

program descr

of Program ele

consistency. T

to the commen

changes in ord

consistency be

description an

172 XI.M18 

ML101830328

Comment 3

The third sentence in the first paragraph is 

redundant to the next paragraph. Suggest this 

sentence be deleted.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The program d

rewritten. The 

removal of red

which is not a 

Rewriting of th

Description in 

earlier comme

consideration 

173 XI.M18 In the third paragraph of the program 

description need to include, XI.S6, Structures 

The staff agrees with 

this comment and 

AMPs XI.S6 a

revised to exp
April 2011 IV-101 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

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Number

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Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

ML101830328

Comment 

XI.M18-4 

Monitoring and XI. S7, RG 1.127, Inspection 

of Water-Control Structures Associated with 

Nuclear Power Plants which both manage 

structural bolting.

associated changes 

to the GALL Report 

have been made.

management o

associated wit

managed by th

change in AMP 

consistent with 

XI.S6 and XI.S

updated to ma

bolting and sh

the described 

to provide a co

accurate state

174 XI.M18 

ML101830328

Comment 

XI.M18-5 

In elements 3 and 4, high strength bolts are 

described. In element 2, preventive actions, 

state that use of high strength bolts is 

avoided. Reference to high strength bolting 

should be removed as it is only an issue for 

structural bolting which has been removed. 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Although aging 

structural bolti

relocated to ot

possibility exis

systems high-s

bolting could b

of high-strengt

stated in the P

Monitored/Insp

element shoul

XI.M18 to acco

high-strength b

the scope of th

175 XI.M18 

ML101830328

Comment 

XI.M18-6 

Elements 1, 3, 4, 6 and 7. The main change is 

that all the structural bolting has been pulled 

out of the Bolting Integrity program and 

inserted in IWE, IWF, Structures Monitoring, 

and RG 1.127. Although removing structural 

bolting from the Bolting Integrity program 

would simplify Bolting Integrity (a little bit), it 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Management o

more appropri

structural AMP

shown that a m

LRAs propose 

bolting through 

AMPs, which s
NUREG-1950 IV-102 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

would unnecessarily complicate these others 

AMPS. 

described as s

preventive act

1038 XI.M19

ML101830328 

Comment 

XI.M19-1 

Maintaining water chemistry should be left to 

the Water Chemistry Program, XI.M2, as it 

was in other programs. Revise PREVENTIVE 

ACTIONS accordingly.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

This is a clarifi

clearly state th

managed by th

Program. It is 

technical inten

1039 XIM19 

ML101830328 

Comment 

XI.M19-2 

Program Element 2, Preventive Actions, lists 

chemical cleaning as a secondary side 

maintenance activity. Recommend to remove 

chemical cleaning since it is not done 

routinely since it is very expensive and can 

cause harm to tube materials if not done 

properly. Recommend to leave in sludge 

lancing as a secondary side maintenance 

activity. Recommend to state that secondary 

chemistry programs may be enhanced to add 

chemicals or adjust chemistry as needed to 

minimize deposition onto tubes (i.e., adding a 

dispersant such as polyacrylic acid [PAA]) as 

a preventive action.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The text is inte

examples of s

maintenance a

reference to ch

acceptable. Ho

other cleaning 

option under th

not specifically 

adding the sen

chemistry prog

amount of dep

similar statem

however, use 

dispersant was 

allow a plant to 

determination 

operating expe

896 XI.M2

ML101830328 

Comment 

XI.M2-1 

Program Description – Do not delete the “or 

later revisions” wording that was added during 

Revision 1 of the GALL. The references to 

BWRVIP-190, EPRI 1014986, Rev. 6 & 

1016555, Rev. 7 are good changes and it 

acknowledges the most current industry 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The staff cann

approval to fut

industry stand

been reviewed 

the staff to ens

integrity. Howe
April 2011 IV-103 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

guidance to right now, but these documents 

are revised every few years based on industry 

experience and plants implement the most 

current guidance. Therefore if you remove the 

“or later revisions” wording, the GALL will 

quickly become out of date. Suggest adding 

“(reviewed and accepted by the NRC in a 

safety evaluation report)” to allow versions 

reviewed during inspections that confirm the 

adequacy of the later versions and could 

eliminate exception.

added to GAL

to identify circu

which later rev

documents ma

license renewa

897 XI.M2 

ML101830328 

Comment 

XI.M2-2 

Program Description, Elements1, 2 & 3 - 

Delete the specific parameters that are to be 

monitored and just reference the EPRI water 

chemistry guidelines. In several cases this 

causes contradictions to the guidelines and 

results in exceptions to the program. 

Examples:

(1) Element 3 indicates that hydrogen 

peroxide is monitored to mitigate degradation 

of structural materials. However this 

contradicts the guidance in BWRVIP-190. 

Rapid decomposition of hydrogen peroxide 

makes reliable data difficult to obtain and 

BWRVIP-190 Section 6.3.3, “Water Chemistry 

Guidelines for Power Operation,” does not 

address monitoring for hydrogen peroxide. 

Noble metal chemical application and 

hydrogen addition are generally used to 

mitigate occurrence of IGSCC of structural 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The informatio

reference Wat

Guidelines. It d

repeated in the 
NUREG-1950 IV-104 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

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Number

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Comment NRC Disposition Tech

materials by suppressing the formation of 

hydrogen peroxide. The hydrogen addition 

generally accomplishes an Electrochemical 

Corrosion Potential (ECP) value less than 

-230mV, SHE (Standard Hydrogen Electrode). 

By maintaining a low ECP less than -230mV, 

SHE, the reactor water chemistry minimizes 

the effects from hydrogen peroxide below the 

threshold that prompted the issue raised in 

NUREG 1801. In addition the ISI program 

investigates structural degradation in 

potentially affected locations and provides 

condition monitoring of the reactor vessel, 

reactor internal components and ASME Class 

1 pressure retaining components in 

accordance with ASME Section XI, 

Subsection IWB. Indications and relevant 

conditions detected during examinations are 

evaluated in accordance with ASME Section 

XI Articles IWB-3000, for Class 1. 

(2) Element 3 indicates that dissolved oxygen 

is monitored; however BWRVIP-190 

acknowledges the difficulty with monitoring 

dissolved oxygen and sets limits for 

conductivity, chlorides, sulfates and total 

organic carbon (TOC) as an alternate method 

for ensuring component integrity.

(3) Program Description, Elements1, 2, 3 

indicates that water quality (pH and 

conductivity) is maintained in accordance with 

established guidance. However, BWRVIP-
April 2011 IV-105 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

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Comment NRC Disposition Tech

190, Section 8.3.4.5, indicates pH 

measurement accuracy in most BWR streams 

is unreliable because of the dependence of 

the instrument reading on ionic strength of the 

sample solution. In addition, the monitoring of 

pH is not discussed in BWRVIP-190, 

Appendix E for condensate storage tank, 

demineralized water storage tank, or torus 

water.

920 XI.M2

ML101830255 

Comment 

XI.M2-1 

Some locations within NUREG-1800 and 

NUREG-1801 cite BWRVIP-29 or BWRVIP130. These references should be replaced by 

BWRVIP-190 or, wherever possible, simply 

refer to the “EPRI BWR Water Chemistry 

Guidelines.”

BWRVIP-190 is the current version of the 

EPRI BWR Water Chemistry Guidelines. This 

version represents the present state of 

industry knowledge regarding management of 

BWR water chemistry. As a minimum, all 

references to water chemistry guidance in 

NUREG-1801 should be revised to cite 

BWRVIP-190. However, the EPRI BWR 

Water Chemistry Guidelines are periodically 

revised to incorporate recent operating 

experience and to address new and improved 

mitigation techniques (e.g., online 

noblechemTM[)]. Based on NEI 03-08, owners 

are required to update their programs to the 

latest needed and mandatory guidance 

contained in these guidelines. Therefore, 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Reference to B

appropriate be

most recent BW

Guideline acce

license renewa
NUREG-1950 IV-106 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

when possible, reference should be made to 

the “EPRI BWR Water Chemistry Guidelines.” 

Otherwise, the reference citations for the 

EPRI BWR Water Chemistry Guidelines will 

become out of date relatively soon.

921 XI.M2 

ML101830255 

Comment 

XI.M2-2 

In the context of BWR chemistry, “primary 

water” should be changed to “reactor water.” 

Applicable Section

Program Description

: 

Reactor water is the descriptive term used in 

BWRVIP-190.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The term “reac

appropriate tha

because BWR

primary and se

loops.

922 XI.M2 

ML101830255 

Comment 

XI.M2-3 

The parameters monitored / inspected 

discussion should be simplified for BWRs to 

state that control parameters for reactor water 

include chloride, sulfate, conductivity, and 

ECP. These are the parameters important for 

aging management of the vessel and reactor 

internals. Where applicable, oxygen 

concentrations are also monitored to ensure 

that they remain in an acceptable range to 

address both FAC and SCC concerns. Other 

parameters are either used as diagnostic 

parameters only, or are associated with 

operations issues, not license renewal aging 

management.

BWRVIP-190 lists chloride, sulfate, 

conductivity, and ECP as the control 

parameters for reactor water chemistry. These 

controls are focused on mitigation of corrosion 

and SCC of the reactor internals, vessel 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The staff agree

comment; how

in response to 

(Comment No

wording sugge

comment. So, 

change was m

this comment.
April 2011 IV-107 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

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Number

Location in 

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Reference No.

Comment NRC Disposition Tech

components, and the reactor recirculation 

system. In addition, oxygen concentration is 

monitored for some specific system locations 

to ensure that low oxygen does not contribute 

to FAC of carbon steel components. 

Limits on iron and copper are associated with 

fuel clad performance concerns. Fuel is not 

within the scope of license renewal. As a 

result, these parameters should not be 

included in section XI.M2.

923 XI.M2 

ML101830255 

Comment 

XI.M2-4 

BWRVIP-62 (and the associated NRC Safety 

Evaluation – ML100850009) should be 

referenced within XI.M2 since this document 

provides a technical basis for BWRVIP 

Inspection program modification associated 

with chemistry-based mitigation.

BWRVIP-62 represents an important aspect 

of aging management for BWR vessel and 

internals components by providing a technical 

basis for inspection program modifications for 

plants implementing hydrogen water 

chemistry and noble metal catalyst 

application. Although a “-A” version of 

BWRVIP-62 has not been published at this 

date, BWRVIP-62 has received a safety 

evaluation from NRC (ML100850009). 

BWRVIP-62 and the associated NRC Safety 

Evaluation can and should be referenced in 

Section XI.M2.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

This documen

and cited in th

Chemistry rep

need to call ou

943 XI.M2 The AMR tables inconsistently refer to XI.M2 The staff agrees with This is a word
NUREG-1950 IV-108 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

ML101880269 

Comment 1

as:

- Chapter XI.M2, “Water Chemistry”

- Chapter XI.M2, “Water Chemistry” for BWR 

water

- Chapter XI.M2, “Water Chemistry” for PWR 

primary water

- Chapter XI.M2, “Water Chemistry” for PWR 

secondary water

Revise the AMR tables to simply refer to 

Chapter XI.M2, “Water Chemistry.”

AMP XI.M2 applies to all the environments for 

which a qualifier was added. Therefore, the 

qualifier is redundant.

this comment and 

associated changes 

to the GALL Report 

have been made.

is not a chang

Therefore, it is 

notable techni

II-21.

944 XI.M2 

ML101880269 

Comment 2

The AMR Tables inconsistently add Chapter 

XI.M32, “One-Time Inspection” to the Chapter 

XI.M2, “Water Chemistry” AMP. For example, 

see page V.A-5, Items V.A.EP-41 and V.A.E12 and page VIII.A-3, items VIII.A.SP-44, 

VIII.A.SP-46, and VIII.A.SP-43

Revise the AMR tables to consistently apply 

the grouped programs.

See AMP combination throughout the GALL.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The change el

inconsistency 

recommended 

material, envir

effect combina

noted that for 

Chemistry pro

one-time inspe

adequate agin

treated borate

1037 XI.M2

ML101830328 

Comment 

XI.M2-3 

Element 7 – Remove the “root” in root cause 

identified. In many cases the root cause of the 

unacceptable chemistry results may not be 

able to be identified. The more important 

investigation should be to determine if the 

excursion affected the components. In 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The change w

licensee deter

the results and 

actions progra

the root cause 

determined. T
April 2011 IV-109 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

addition the individual corrective action 

processes should determine if root cause 

identification is required.

application of t

program accep

1035 XI.M22

ML101830328 

Comment 

XI.M22-1 

[In Detection of Aging Effects:] Five years is 

not a frequency. Inserted “once every” before 

“5 years”.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The original w

correct; 5 year

frequency. The 

revised to say

frequency of o

years...." This 

technical inten

does not show 

technical chan

179 XI.M24

ML101830328 

Comment 

XI.M24-1 

Program Description and Element 3, 4 and 5 -

Specifying leak testing and compressor cycle 

time as an aspect of aging management is 

inappropriate since the presence of leakage 

confirms that aging effects have not been 

appropriately managed. In addition, leakage 

testing will normally detect the failure of 

isolation valve leak by and seal failures that 

are not passive components. Confirming the 

presence of moisture and contaminants along 

with visual inspections will confirm the 

effectiveness of aging management. 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The comment 

removing the r

pressure deca

acceptable be

pressure deca

mainly intende

performance d

components a

examinations a

moisture in the 

pressure dew 

provide reason

adequate agin

180 XI.M24 

ML101830328 

Comment 

XI.M24-2 

In element 3 erosion is not an aging effect in 

GALL for air systems such that there is no 

need for inspection.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The comment 

removing the r

“erosion” is ac

operating expe

corrosion is th
NUREG-1950 IV-110 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

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Commenter 

Reference No.

Comment NRC Disposition Tech

that causes th

of material in t

system.

181 XI.M24 

ML101830328 

Comment 

XI.M24-3 

In element 3 the use of the word “all” is 

unclear and implies that every component be 

examined. Recommend rewording to delete 

“all” and include “when available” to ensure 

components are inspected when opened for 

access. 

The staff partially 

agrees with this 

comment and 

associated changes 

to the GALL Report 

have been made.

Agree with rem

understood un

present to sup

than all. Acces

NRC interpreta

ALL surfaces t

However, the c

recommends a

available” is no

because (1) th

described in th

include both p

and opportunis

(2) the wording 

may be interpr

recommendati

only opportuni

Reworded from 

accessible inte

performed...” t

opportunistic i

accessible inte

performed..” to 

components a

opened for acc

182 XI.M26

ML101830328

Element 1 - states that the program manages 

the effects of loss of material and cracking, 

however Increased hardness, shrinkage, and 

The staff agrees with 

this comment and 

associated changes 

This is consist

VII.G.A-91.
April 2011 IV-111 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

XI.M26-1 loss of strength are also addressed for 

elastomer penetration seals in line item 

VII.G.A-91. Need to add these aging effects

to the GALL Report 

have been made.

183 XI.M26 

ML101830328 

XI.M26-2 

Elements 3 and 4 - Since inspections of 

penetration seals are performed in 

accordance with NRC-approved fire protection 

program as added by the revision, it is not 

necessary to specify the quantity of each seal 

type since this value will be defined by the site 

specific NRC approved program. This would 

be consistent with the other changes in the 

program in element 4 that added that the 

frequency of the inspection will be in 

accordance with an NRC approved fire 

protection program. The quantity of seal type 

to be inspected is specified in this NRC 

approved program and does not need to be 

defined. 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The quantity o

not be identifie

NRC approved 

programs. Add

recommendati

less than 10% 

ensures that a

of each type o

inspected by t

of extended op

184 XI.M26 

ML101830328 

XI.M26-3 

Element 4 - Though the option is available to 

use a different frequency, consider removing 

6 month frequency since it was removed from 

Element 3 as requested earlier. Inspections of 

the system are in accordance with NRCapproved fire protection program.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The functional 

not be defined 

NRC-approved 

program; there

recommendati

frequency” pro

frequency, and 

frequency in a

NRC-approved 

program has b

185 XI.M26 

ML101830328 

Element 6 – Typo, remove second “of 

degradation.”

The staff agrees with 

this comment and 

Corrected typo

Since this is no
NUREG-1950 IV-112 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

XI.M26-4 associated changes 

to the GALL Report 

have been made.

technical chan

not referenced 

1036 XI.M3

ML101830328 

Comment 

XI.M3-1 

Suggest rewording PREVENTIVE ACTIONS 

to make each action a bullet, rather than 2 

bullets and 2 actions in the text.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The wording w

accordance w

This is a forma

does not chan

intent. Since th

technical chan

not referenced 

186 XI.M30

ML101830328 

Comment 

XI.M30-1 

Element 1 and Element 3 - state that the 

program is focused on managing the loss of 

material due to general, pitting, and MIC. 

Issue: The program also manages the aging 

mechanisms of crevice corrosion and fouling 

that leads to corrosion. See items 

VII.H1.AP.105 and VII.H2.AP-105 as 

examples.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The AMP is cr

managing loss 

all of the corro

general, pitting

fouling that lea

is consistent w

105 and VII.H2

187 XI.M30 

ML101830328 

Comment 

XI.M30-2 

Element 4 - only allows for periodic multilevel 

tank sampling. Issue: There are numerous 

fuel oil tanks that do not have the capability to 

be sampled using multilevel sampling 

techniques due to their design (e.g., no top 

access). Recommend allowing alternate 

sampling techniques that provide an 

equivalent conservative sample. For example, 

a single point tank drain at the lowest point on 

the tank sample would be considered a more 

conservative sample. This program samples 

for water, sediment, and particulate 

The staff agrees with 

this comment, with 

modifications and 

associated changes 

to the GALL Report 

have been made.

Different desig

reviewed on a 

to ensure they 

equivalent or m

multi-level sam

designs that d

level sampling

determined tha

sample taken 

the tank provid

alternative to m

Precedents fo
April 2011 IV-113 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

contamination. Water, sediment, and 

particulate tend to settle towards the bottom of 

the tank making a true bottom sample more 

conservative. Previously for Oyster Creek and 

TMI bottom samples were considered an 

exception to the program which were 

accepted by the NRC. This change would 

eliminate the need to make this an exception.

bottom sample

to multi-level s

documented in 

TMI, Unit 1, lic

188 XI.M30 

ML101830328 

Comment 

XI.M30-3 

Element 4 - identifies the requirements for 

tank inspections prior to the period of 

extended operation. It requires each tank to 

be drained and cleaned, and the internal 

surfaces visually inspected (if physically 

possible) and volumetrically inspected. Issue: 

The requirement for volumetric inspection 

should only apply if degradation is found 

during visual inspection. If a visual internal 

inspection cannot be performed, then, a 

volumetric examination (from the outside 

looking in) must be performed in lieu of that 

visual. 

The staff agrees with

this comment and 

associated changes 

to the GALL Report 

have been made.

Volumetric exa

needed only if 

indicates that 

be occurring o

of the tank 

A volumetric in

performed to f

situation if the 

provided indica

degradation, o

inspection is n

possible. If vis

not find any in

surface degrad

then loss of m

occurring from 

of the tank. Th

of material from 

surface of the 

separately in A

and Undergrou

Tanks, if the ta

underground a
NUREG-1950 IV-114 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

a visual exami

tank surface is 

visual inspecti

189 XI.M31 

ML101830328 

Comment 

XI.M31-1 

In element 5b consistent with RG 1.99 when 

two or more credible surveillance capsules 

are available then embrittlement may be 

projected using position 2. Suggest rewording.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Clarification is 

intention of thi

consistent with 

2 in NRC RG 1

Monitoring and 

revised to say

credible surve

available, the e

vessel neutron 

the period of o

projected acco

Position 2 in N

2, based on be

surveillance da

wording is con

wording used 

Position 2 in N

Revision 2.

492 XI.M31

ML101890552 

Comment 

XI.M31

Program Description

1. Reword the first sentence in the first 

paragraph to correct the citation to ASTM with 

the current title by replacing “American 

Society for Testing and Materials (ASTM) E 

185 Standard” with “ASTM International 

Standard Practice E 185-82.”

2. Reword the third sentence in the first 

paragraph to add “(current version)” after “10 

The staff partially 

agrees with this 

comment and 

associated changes 

to the GALL Report 

have been made.

Comment 1: T

a more comple

the reference s

Comment 2: T

clarification tha

currently appro

Appendix H.

Comments 3 a

grammar and 
April 2011 IV-115 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

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Reference No.

Comment NRC Disposition Tech

CFR Part 50, Appendix H.” The objective of 

this change is to enable an automatic update 

to the GALL to include the new provisions 

going into Appendix H within the next year or 

two.

3. Reword the first sentence of the second 

paragraph as follows: “The objective of the 

reactor vessel material surveillance program 

is to provide sufficient...”

4. Reword the second sentence of the third 

paragraph as follows: “The data from this 

surveillance program are used to monitor 

neutron irradiation embrittlement and are 

used...” (data is plural in this context) 

5. Reword the last sentence of the third 

paragraph as follows: “It is recommended that 

untested... be maintained for possible future 

insertion or testing.”

clarifications. T

change in tech

Comment 5: T

was added to 

possibility that 

not occur. The 

“recommended

because the c

weaken the cu

the sentence.

493 XI.M31

ML101890552 

Comment 

XI.M31-3 

3. Parameters Monitored/Inspected:

Reword the second and third sentences as 

follows: “The program uses neutron 

dosimeters to benchmark the neutron fluence 

calculations. Low melting point elements or 

eutectic alloys may be used as a check on 

peak specimen irradiation temperature.”

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The proposed 

provided a mo

description an

change of tech

Therefore, no 

needed.

494 XI.M31 

ML101890552 

Comment 

XI.M31-4 

4. Detection of Aging Effects:

1. Reword the first sentence of the second 

paragraph as follows: “... shall have at least 

one capsule with... fluence equal to or 

The staff partially 

agrees with this 

comment and the 

document was 

reworded for clarity.

Comments 1 t

implemented a

comments 1 th

wording chang

technical inten
NUREG-1950 IV-116 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

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Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

exceeding the 60-year...”

2. Delete the last sentence of the second 

paragraph; the meaning of “meaningful.. 

fluence” is explained adequately in the 

preceding sentence.

3. Reword the first sentence of the third 

paragraph as follows: “It is recommended that 

the program retain additional capsules within 

the reactor vessel to support additional testing 

if, for example, the data from the required 

surveillance capsule turn out to be invalid or in 

preparation for operation beyond 60 years.”

4. Delete the second sentence of the third 

paragraph: “These additional capsules may 

be managed in a similar way for future use.”

5. Reword the last sentence of the third 

paragraph as follows (delete 'the'): “... 

untested capsules in storage for future 

reinsertion and/or testing.”

6. Replace the fourth and fifth paragraphs with 

the following: “It is recommended that all 

previously tested samples be retained for 

possible future use (unless already discarded 

before August 31, 2000). It is recommended 

that all surveillance capsules that were 

removed from the reactor vessel be retained 

for possible future use (unless already 

discarded before August 31, 2000).” 

Rationale for change: To retain the tested 

specimens and removed capsules must be 

recommendati

No changes w

response to co

9. For comme

staff did not fin

changes to be 

they affected t

the staff's reco

the Detection o

AMP.
April 2011 IV-117 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

stated as a “recommendation” to be 

consistent with prior NRC guidance. This does 

not change the requirement to submit 

changes to the NRC for approval of 

withdrawal schedule changes.

7. Reword the seventh paragraph as follows: 

“If all surveillance capsules have been 

removed, a licensee may manage aging of the 

vessel using either an alternative surveillance 

program or an alternative neutron fluence 

monitoring program as described in the 

following:”

8. Reword point (a) of the seventh paragraph 

as follows: 

(a) An Alternative Surveillance Program

This program may consist of (1) capsules 

from an integrated surveillance program, (2) 

reconstitution of specimens from tested 

capsules, (3) capsules made using available 

relevant archive materials, or (4) some 

combination of the three previous options. 

This program could be a plant-specific 

program or an integrated surveillance 

program.

9. Reword the eighth paragraph, third 

sentence as follows:” If the reactor vessel 

exposure conditions (neutron flux, irradiation 

temperature, etc.) are altered, then the basis 

for the projection to 60 or more years is 

reviewed and, if deemed significantly different, 

modifications need to be made to the vessel 
NUREG-1950 IV-118 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

integrity projections.

Rationale: There is no way to evaluate the 

effects of likely changes to neutron spectrum 

on vessel embrittlement nor is there a 

conceivable change to core design that would 

change neutron spectrum enough to have an 

effect on vessel embrittlement. There are few 

options to change the reactor vessel 

surveillance program other than to 

recommend a reinserted surveillance capsule. 

The last sentence (submittal to and review by 

NRC of changes) will cover that aspect on a 

case-by-case basis.

495 XI.M31 

ML101890552 

Comment 

XI.M31-5 

Monitoring and Trending

1. In the second paragraph, change “(10 CFR 

50.61 and 10 CFR 50.61a)” to “(10 CFR 50.61 

or 10 CFR 50.61 a)” to clarify that it is not 

necessary to perform the PTS TLAA using 

both rules.

2. In the second paragraph, point (b), first 

sentence, replace “must” with “may,” or add 

the detailed provisions from RG 1.99, 

Revision 2 and from 10 CFR 50.61 with 

regard to application of surveillance data. 

Revision 1 of this document stated it as “may.”

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Changes are c

requirements o

10 CFR 50.61

496 XI.M31 

ML101890552 

Comment 

XI.M31-7 

Corrective Actions

Under (b), replace “neutron spectrum” with 

“neutron fluence” because fluence can be 

effectively monitored and, because it is tied 

directly to the vessel integrity TLAAs, the 

The staff partially 

agrees with this 

comment and 

associated changes 

to the GALL Report 

This comment

applicable bec

mention of neu

Element 7, Co

However, the s
April 2011 IV-119 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

need for monitoring can be unambiguously 

established.

have been made. comment was 

Element 10, O

In Element 10

has been chan

fluence” becau

directly to vess

TLAAs and ca

unambiguousl

managed than 

497 XI.M31 

ML101890552 

Comment 

XI.M31-10

Element 10. Operating Experience: In the 

second paragraph, add after “...Appendix G 

of...” “...10 CFR Part 50 using Appendix K 

of...” to give reference to the current ASME 

Code “equivalent margins analysis” 

procedure.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

This comment

applicable bec

Experience dis

include mentio

The staff also 

Corrective Act

to this comme

determined tha

Element 7 is n

Appendix G of 

does not endo

discussion in C

requires applic

regulatory req

498 XI.M31 

ML101890552 

Comment 

XI.M31-REF

Check the dates of the first, second and fifth 

references.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Dates on the r

changed base

standardizatio

the staff.

190 XI.M32

ML101830328

Element 4 – This section still does not define 

the terms qualified and equivalent such that 

The staff agrees with 

this comment and 

The Detection 

program elem
NUREG-1950 IV-120 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

Comment 

XI.M32-1 

the inspections specified in this program 

would have to be performed by ASME 

qualified inspectors using ASME procedures 

even on non code components. Definitions 

similar to those proposed in XI.M36 External 

Surfaces and M38 could be applied in this 

program such as qualified in accordance with 

site procedures and programs for the type of 

examination being performed. 

associated changes 

to the GALL Report 

have been made.

clarify that use 

inspectors and 

techniques are 

non-code qual

The staff does 

applicant to us

qualified inspe

inspection tech

Code compon

The staff has f

accordance w

and programs 

191 XI.M35 

ML101830328 

Comment 

XI.M35-1 

“Vibratory loading” is used to describe an 

aging mechanism managed by this program in 

elements 1, 4 and 5. In Chapter IX.F, the 

definition of fatigue cites “Vibration is 

generally induced by external equipment 

operation.” By definition, aging induced by 

external equipment operation is not an aging 

mechanism but a design issue that will be 

identified early in plant life and corrected as 

discussed in recent OE discussions with NEI 

and the NRC staff and as presented in this 

program. There is no basis for the claim that 

this is an aging mechanism since it is not 

related to the age of the equipment but the 

impact of external operation. Comment also 

applies to aging management review tables 

citing vibratory loading which should also be 

eliminated. Recommend change to vibration 

fatigue if this must be retained as an aging 

The staff partially 

agrees with this 

comment and some

changes to the GALL 

Report have been 

made.

The staff belie

mechanism ne

maintained an

wording of the 

“...cracking ... 

corrosion or cy

thermal, mech

fatigue) loadin

review of oper

staff has deter

fatigue is an e

loading mecha

cause age-rela

small bore pip
April 2011 IV-121 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

mechanism. 

192 XI.M35 

ML101830328 

Comment 

XI.M35-2 

In element 1 and description there are 

statements regarding program applicability to 

plants that have performed design changes to 

mitigate cracking from vibration. Was the 

intent of this to have a periodic plant specific 

program if the design changes have not 

eliminated the vibration issue such that 

cracking has reoccurred, and if design 

changes have been implemented without 

additional cracking that XI.M35 is to be used? 

If any other cracking other than vibratory has 

occurred XI.M35 is not to be used. See 

recommended changes to add clarification.

The staff partially 

agrees with this 

comment. Therefore, 

the comment did 

result in a revision to 

the document for 

clarification.

The staff partia

comment, but 

total. The staff 

Program Desc

issues related 

changes and o

inspections. W

provide clarific

staff's intention 

program for sy

experienced c

implemented e

changes, but i

intention to lim

design change

eliminate crac

fatigue loading

193 XI.M35 

ML101830328 

Comment 

XI.M35-3 

In element 4 provide clarification of extent of 

opportunistic destructive testing to perform in 

event of a significant piping replacement that 

replaces or eliminates numerous welds.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Element 4, De

Effects, was re

an appropriate 

can be used fo

if multiple weld

staff has previ

appropriate sa

to demonstrate 

AMPs.

194 XI.M35 

ML101830328 

Comment 

In element 5 be clear that the cracking 

identified by One-Time Inspection or OE will 

undergo root cause analysis and that the 

The staff partially 

agrees with this 

comment and 

The staff partia

comment. No 

in Element 5, M
NUREG-1950 IV-122 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

XI.M35-4 need for periodic inspections going forward 

should only apply to the piping configurations 

that are determined to be susceptible to that 

cause. A certain piping loop may have 

vibration issues that other piping in the 

program are confirmed not to have.

associated changes 

to the GALL Report 

have been made.

Trending, in re

comment. How

Description wa

clarification. T

that clarificatio

comment was 

addressed by 

Program Desc

to earlier comm

197 XI.M36 

ML101830328 

Comment 

XI.M36-4 

Element 6 - uses an acceptance criteria of 

“unchanged” for polymeric materials. Use of 

this criteria would result in rejection for even 

very minor changes in color, hardness and 

flexibility which are subjective examinations. 

Suggest using a criteria that any changes in 

these properties will be evaluated for 

continued service in the corrective action 

program to allow a proper and documented 

review of the condition. 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Program revis

materials, phy

evaluated for c

971 XI.M36

ML101830328 

Comment 

XI.M36-1 

Element 1 - Scope discusses cracking of 

stainless steel as an aging effect in polymeric 

components. Appears to be in wrong place. 

Also wrong aging effects are listed for 

polymers in some cases.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The incorrect a

listed for polym

and polymers 

stainless steel 

for polymers w

correct aging e

was given.

972 XI.M36

ML101830328 

Comment 

XI.M36-2 

Element 4 - repeats requirements on 

qualifications and inspections that are not 

needed. Add requirements for the inspections 

of normally inaccessible and underground 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

The requireme

and inspection

requirements f

normally inacc
April 2011 IV-123 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

components to ensure they are appropriately 

identified when appropriate.

have been made. underground c

given. The sec

should be dele

requirements n

be included.

198 XI.M38

ML101830328 

Comment 

XI.M38-1 

In the program description the last paragraph 

is not clear on the limitations of use of the 

program when failures have occurred. 

Recommend that section be reworded to 

clarify that repetitive failures would require 

use of a plant specific program.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The reference 

failures” needs 

make the mea

has modified t

more clearly d

where the AM

when a plant-s

warranted. The 

written to addr

and aligns with 

AMP XI.M35 fo

898 XI.M39 

ML101830328 

Comment 

XI.M39-1 

Delete references to SCC which has no basis 

if water is not present. This program ensures 

the lack of significant moisture that could 

cause cracking. No known OE exists of this 

occurring in an oil environment. Minor text 

changes also provided for clarification in that 

this program monitors for impurities.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The AMP focu

significant moi

in the system. 

moisture, SCC 

occur in an oil 

search of oper

has not identif

SCC in these s

incidences of C

that are identif

addressed by 

actions” and “o

experience” pr

149 XI.M4 The PREVENTIVE ACTIONS element varies The staff agrees with Provides cons
NUREG-1950 IV-124 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

ML101830328 

Comment 

XI.M4-1 

widely among several condition monitoring 

programs (XI.M4, XI.M7, XI.M8, XI.M9, 

XI.M11B, etc.) that have no preventive 

actions, including the discussion of preventive 

actions in the Water Chemistry program. This 

wording should be consistent for all the 

involved programs. See below for suggested 

best wording. Correct corespray to core spray 

in Program Description.

this comment and 

associated changes 

to the GALL Report 

have been made.

condition mon

recommend m

chemistry.

374 XI.M4

ML101830255 

Comment 

XI.M4-1 

The preventive actions section discussion for 

water chemistry should simply refer to 

program XI.M2. 

Specific reference to a version of the EPRI 

BWR Water Chemistry Guidelines and 

discussion regarding control parameter tables 

should be limited to XI.M2 and not be 

repeated in XI.M4.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

AMP XI.M2 is 

and only a refe

necessary in A

this is not a no

change, this co

shown in Table 

375 XI.M4 

ML101830255 

Comment 

XI.M4-2 

The detection of aging affects section 

incorrectly states that the enhanced visual 

examination method is capable of achieving 1 

mil wire resolution. It should state 1/2 mil wire 

resolution.

Section 3.1.2 of BWRVIP-48-A defines 

Enhanced VT-1 as a method capable of 

achieving 1/2 mil wire resolution.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Corrected to re

BWRVIP-48A 

376 XI.M4 

ML101830255 

Comment 

XI.M4-3 

All references to the NRC approved version of 

BWRVIP reports should be “-A.” For example, 

“BWRVIP-48-A,” rather than “BWRVIP-48A.”

This occurs not only throughout the body of 

the program text, but also for other BWRVIP 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Conformance 

reports. This is 

AMPs that refe

that have an “A

document num
April 2011 IV-125 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

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Commenter 

Reference No.

Comment NRC Disposition Tech

reports cited in the references section (e.g., 

BWRVIP-59 and BWRVIP-60).

200 XI.M40

ML101830328 

Comment 

XI.M40-1 

Element 4 - This program as written specifies 

an inspection frequency of 10 years minimum. 

License amendments that have approved the 

use of newer materials may specify different 

frequencies. To prevent conflicts in testing 

frequencies the option of following approved 

SER requirements should be allowed. 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

In the issuance 

the draft GALL 

dated May 18, 

that because t

previously sou

public comme

XI.M40, the sta

further comme

part of this Fed

(FRN). AMP X

AMR items are 

the staff based 

review and pu

different inspe

been approved 

plant-specific S

noted as an ex

recommendati

Report. 

201 XI.M40 

ML101830328 

Comment 

XI.M40-2 

Element 3 - if Boral was to experience a loss 

of material, it would not result in shrinkage. 

Loss of material in Boral is conceptually 

similar to selective leaching, in that the B-10 

would be selectively removed and the Boral 

sheet/coupon would simply become less 

dense without a change in dimension. 

Changes in dimensions are not typically 

shrinkage but increases in thickness as a 

result of the Al cladding separating from the 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Element 3 was 

shrinkage as a

effect. For Bor

dimension typ

in thickness du

shrinkage due 
NUREG-1950 IV-126 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

inner Al-B alloy. The way it reads now, 

“...exposure to wet pool environment may 

cause shrinkage resulting in a loss of 

material...” is somewhat inaccurate for Boral. 

Suggest deleting shrinkage.

202 XI.M40 

ML101830328

Comment 

XI.M40-3 

References - add IE [i.e., IN] Notice 2009-26, 

“Degradation of Neutron-Absorbing Materials 

in the Spent Fuel Pool”

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Included IN200

references. Th

related to the t

is appropriate 

889 XI.M41

ML101610406 

Comment 

XI.M41-1 

Program Description & applicable elements:

Recommend deleting “underground” and 

“limited access” environments. 

“Underground” and “limited access” 

environments are defined as components 

exposed to air and located where access is 

limited. Detection of aging effects for limited 

access components exposed to air 

environments is managed by AMP XI.M36 

External Surfaces Monitoring of Mechanical 

Components (see element 4). Clarification 

has been added to M36. Also, the definition 

of change in material properties needs to be 

added to GALL Chapter IX. 

The staff partially 

agrees with this 

comment and the 

associated changes 

to the GALL Report 

have been made.

The External S

of Mechanical 

more relevant 

access type en

However, base

operating expe

with undergrou

believes that a

management p

described in X

to manage the 

underground p

considered am

along the lines 

adequately ad

piping. The sta

concept due to 

nature of the b

underground p

Underground p

be retained un
April 2011 IV-127 NUREG-1950

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Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

890 XI.M41

ML101610406 

Comment 

XI.M41-2 

Element 1 - Recommend deleting the 

sentence identifying typical systems. The 

buried piping and tanks program manages 

aging of components in a soil environment. 

Identification of systems for this type of AMP 

is not consistent with other GALL AMPs

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The SRP-LR s

systems addre

should be inclu

the AMP. Base

the staff disag

comment. The 

addressed by 

remains uncha

106 XI.M41

ML101610406 

Comment 

XI.M41-3 

Element 1- the last sentence states that aging 

of bolting associated with piping systems 

within the scope of this program are also 

managed by this program. However there are 

no line items for bolting that credit this AMP. 

Recommend adding steel bolting line items for 

loss of material (managed by Buried Piping 

and Tanks) and loss of preload (managed by 

Bolting Integrity AMP) in a soil environment in 

GALL Chapter VIII.H and VII.I, External 

Surfaces of Miscellaneous Components and 

Bolting. 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

AMR items VII

243, VIII.H.SP

143 were adde

stainless steel 

environment a

AMP XI.M41. 

891 XI.M41

ML101610406 

Comment 

XI.M41-4 

Element 2 item 2a –Need to define or give 

examples of materials that are considered 

super austenitic stainless steels. 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made . 

These materia

austenitic stain

stainless steel 

percent iron, w

stainless steel 

percent iron. T

the words, “su

254SMO,” to t

provide examp

austenitic stain
NUREG-1950 IV-128 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

892 XI.M41

ML101610406 

Comment 

XI.M41-5 

Element 2 item 2b – Recommend limiting the 

use of coatings to susceptible metallic piping 

consistent within the scope of NACE Standard 

Practice SP0169-2007 (submerged or 

underground metallic piping). Plants not 

consistent with the requirement of Table 1 of 

NACE Standard Practice SP0169-2007 must 

provide a plant specific justification for an 

alternative coating. 

The size of particles in structural backfill and 

the potential coating impact varies and 

depends on the type of coating used and 

backfill placement/compaction. Recommend 

deleting 49 CFR 195.252 and revising to allow 

structural backfill consistent with plant specific 

specifications. Structural backfill for 

opportunistic and directed inspections should 

have 30% or less of its particles retained on a 

3⁄4 inch sieve or demonstrate that the backfill 

material and placement/compaction methods 

will not result in exposure of piping metallic 

surfaces. Also see addition backfill 

considerations in comment 19.

NRC staff disagrees 

with this comment. 

However, the 

comment did result in 

a revision to the 

document for 

clarification.

Coating will be 

copper alloys, 

piping and tan

must be taken 

staff is aware o

by the imprope

has not chang

recommendati

coating has be

utilize SP0169 

NACE RP0285

of buried pipe 

improve the cl

document, the 

quality is now 

footnotes 5 an

These footnote

must be consis

2007 section 5

additionally sta

considers bac

within 6 inches 

meets ASTM D 

number 67 or 

the footnote) to 

objectives of S

footnotes also 

not meeting th

acceptable if in

the backfill has 

coating.
April 2011 IV-129 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

The commente

backfill meetin

where not mor

backfill materia

retained on a 3⁄4 

not adopted fo

ASTM D1557 

method for det

compaction ch

is not appropri

backfill size dis

not degrade p

second, becau

does not conta

particle size. I

stones, which 

in the proposa

coatings. The 

ASTM D448-0

10 is based on 

D448-08 is an 

standard for us

size of backfill 

size numbers 

been used by 

entities in spec

similar applica

acknowledges

some plants, t

not meet these 

recognizes tha
NUREG-1950 IV-130 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

backfill carries 

causing dama

result, the staf

exception to th

requirements s

meeting the re

acceptable if in

that the backfi

damage to pip

893 XI.M41

ML101610406 

Comment 

XI.M41-6 

Element 2 item 2c – If the environment is 

limited to a soil environment, this item is not 

required (see comment XI.M41 – 1 and 

XI.M41 - 5). Delete the requirement to 

maintain justification for lack of coating on 

materials on site – this is required by NEI 95-

10 for license renewal documentation.

NRC staff partially 

agrees with this 

comment and the 

document was 

reworded for clarity.

It is the staff's 

underground p

piping are to b

AMP. This por

been restructu

reasons, howe

continue to ad

underground a

The staff views 

maintain on sit

lack of coating 

significant. Irre

requirements o

staff considers 

worthy of reten

894 XI.M41

ML101610406 

Comment 

XI.M41-7 

Element 2 item 2d – This section appears to 

require cathodic protection of all buried steel, 

copper, and aluminum components consistent 

with the referenced NACE standards with no 

exceptions. The 2007 and 2002 editions of 

The staff disagrees 

with this comment. 

No changes to the 

GALL Report have 

been made.

It is the staff’s 

preventive act

of coatings, ins

protection, and 

backfill, are an 
April 2011 IV-131 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

the referenced NACE standards were not 

available when cathodic protection systems 

for existing operating plants were built. As 

written, this would require an applicant to 

backfit existing cathodic protection system 

designs to be consistent with NACE Standard 

Practice SP0169-2007 or Recommended 

Practice RP0285-2002 or take exception to 

the requirement. Recommend revising this 

section to focus on installed cathodic 

protection systems. Steel, copper, and 

aluminum components not cathodically 

protected are inspected by paragraph 4.c.

comprehensiv

managing the 

surfaces of bu

underground p

during the agin

review process

determines tha

piping and tan

the preventive 

the staff would 

applicant woul

take action to 

preventive act

period of exten

take an excep

provide a thoro

justification for 

111 XI.M41 

ML101610406 

Comment 

XI.M41-8 

Element 3 – For metallic components, loss of 

material due to all forms of corrosion and 

potentially, cracking due to SCC are 

addressed by this AMP. However, other 

MEAP line items such as polymeric and 

cementitious materials also credit this AMP. 

Examples: VII.C1.AP-175 & 176 credit this 

AMP for cracking, blistering, change in color 

due to water absorption and VII.C1.AP-177 & 

178 credit this AMP for cracking, spalling, 

corrosion of rebar due to exposure of rebar.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

AMP XI.M41 a

material prope

acceptance cr

addresses cra

non-metallic p

and spalling of 

concrete pipin

112 XI.M41 

ML101610406 

Comment 

Element 3 – Clarify this element to indicate 

that the measurement of pipe-to-soil potential 

and the cathodic protection current are 

The staff disagrees 

with this comment. 

The GALL Report 

The monitoring 

as pipe-to-soil 

cathodic prote
NUREG-1950 IV-132 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

XI.M41-9 applicable to steel, copper, and aluminum 

components that are cathodically protected. 

has not been 

changed.

consistent with 

that preventive 

the use of cath

an essential pa

comprehensiv

managing the 

surfaces of bu

underground p

113 XI.M41 

ML101610406 

Comment 

XI.M41-10

Element 4 item c(i) – The requirement for a 

minimum of 5% of the length of all piping can 

require extensive excavation for some plants 

creating a condition that would damage more 

piping than it would provide evidence of the 

piping condition. Recommend replacing the 

5% length requirement with locations that 

consider the NEI 09-14 industry initiative. Six 

locations are proposed as follows:

- At least three high risk locations determined 

by the NEI 09-14 methods for piping within the 

scope of license renewal

- At least three additional locations where the 

potential for pipe degradation is highest based 

on considerations noted in item c.iv. 

Also in the introduction to item c. delete 

reference to paragraphs 2b and 2c to clarify 

applicability of this element to piping that is 

inherently resistant to corrosion and is not 

cathodically protected.

The NRC staff agrees 

with this comment 

and associated 

changes to the GALL 

Report have been 

made.

The staff ackn

excavations ca

damaging the 

exposing. The 

balance that ri

investigate coa

and subseque

which may be 

general in natu

this goal, cons

be inspected. 

stipulates that 

components m

the staff notes 

piping is more 

shutdown, per

environmental 

others are. To 

has modified t

inspections to 

most significan

requirements f

significant pipi
April 2011 IV-133 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

from the previo

AMP. Inspectio

significant pipi

reduced from t

The net result 

provide aging 

buried and und

addition, the n

is dependent u

measures app

tanks.

114 XI.M41 

ML101610406 

Packet 1, 

Comment 

XI.M41-11

Element 4 item c(v) and item e(iii) – Delete 

the requirement for not allowing individual 

inspections of shared piping to be credited for 

more than one unit. This is inconsistent with 

portions of the ASME Section XI code that 

allow credit for similar or shared components. 

Selection of excavations is driven by where 

the risk of degradation is greatest and is not 

based on shared systems. 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The staff ackn

codes allow fo

inspection for 

However, the s

an inspection c

adequate but n

Crediting a sin

more than one 

result in less th

inspections. T

unchanged.

115 XI.M41 

ML101610406 

Comment 

XI.M41-12

Element 4 item vi – Revise to identify 

volumetric examination of wall thickness and 

identify ultrasonic examination as an example 

of a volumetric examination. Field eddy 

current techniques are being developed that 

can also be used for thickness 

measurements. 

The NRC staff agrees 

with this comment 

and associated 

changes to the GALL 

Report have been 

made.

The staff has a

item b.x.B to in

inspections us

examination m

been qualified 

approved by th

acceptable su

examinations 
NUREG-1950 IV-134 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

116 XI.M41 

ML101610406 

Comment 

XI.M41-13

Element 4 item e. - The introduction of this 

item requires two inspections of cathodically 

protected piping. Item e(v) also requires two 

inspections of cathodically protected pipe and 

is redundant to the introduction. Recommend 

deleting item e(v). Consistent with NACE 

Standard Practice SP0169-2007, pipe to soil 

potentials should be used where possible

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

. 

Piping system congestion or other 

considerations may result in unreliable data. 

The requireme

cathodically pr

been revised t

specificity. It m

to obtain accu

measurements 

the intent of th

consistent with 

soil potentials 

buried aluminu

pipe. It is also 

that, if an appl

is not possible 

survey, an exc

the AMP and t

justification be 

such a position

117 XI.M41 

ML101610406 

Comment 

XI.M41-14

Element 4 Item g - Clarify applicability of this 

element to tanks that are not coated (coating 

and backfill characterized by paragraph 2b) 

and not cathodically protected.

The NRC staff agrees 

with this comment 

and associated 

changes to the GALL 

Report have been 

made.

The staff has r

to provide grea

inspection of b

underground t

buried tanks is 

paragraph 4.d

underground t

addressed in p

Reorganizatio

permitted impr

clarity and det

descriptions.

118 XI.M41 Element 4 item i – Revise the introduction to 

this item to be consistent with element 4 item 

The staff disagrees 

with this comment. 

This section of 

revised such t
April 2011 IV-135 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

ML101610406 

Comment 

XI.M41-15

c, item e, and item g. The GALL Report 

has not been 

changed.

may be moot. 

revision to the 

in wording bet

i and element 

intentional. Th

the concept th

measurements 

element 4 item 

repeatedly thro

period prior to 

of extended op

compared to v

which are mad

this period.

119 XI.M41 

ML101610406 

Comment 

XI.M41-16

Element 4 Items g thru j – If this environment 

applicable to this program is limited to buried 

components (soil environment), item i should 

be combined with item g due to identical 

inspection requirements for “each tank.” Item 

h should also be combined with item j due to 

identical inspection requirements for “each 

tank.” The Buried Pipes and Tanks AMP

should only apply to the buried portion of 

tanks for those tanks that are only partially 

buried in a soil environment. Portions of 

partially buried tanks exposed to an air 

environment and not in contact with a soil 

environment should be managed by AMP 

XI.M36 External Surfaces Monitoring of 

Mechanical Components.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Given that the 

it is necessary 

“underground” 

the staff consid

the comment a

buried environ

The staff has r

inspection crite

address this co

unaware of a s

partially buried 

the AMPs are 

tanks, (this AM

ground tanks (

Partially buried 

addressed und

XI.M41) AMP. 
NUREG-1950 IV-136 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

not wish to be 

AMP, an exce

and justificatio

120 XI.M41 

ML101610406 

Comment 

XI.M41-17

Element 4 Items k & l (new) – Recommend 

adding inspection requirements for polymeric 

and cementitious buried components.

The NRC staff agrees 

with this comment 

and associated 

changes to the GALL 

Report have been 

made.

Element 4, det

effects, include

requirements f

cementitious m

121 XI.M41 

ML101610406 

Comment 

XI.M41-18

Element 4 item m (revised from k). – Doubling 

of the sample size seems excessive when 

conditions found and cause evaluations could 

determine that there is no need to expand the 

sample this significantly. Recommend 

increasing the sample (up to doubling) in 

accordance with root cause evaluations. 

Similarly, if significant indication are found in 

the expanded sample, cause evaluations may 

provide justification for not performing a 100% 

inspection of all buried piping. 

The NRC staff 

partially agrees with 

this comment and the 

document was 

reworded for clarity.

Some revision

to this item ba

comment. Rec

experience ind

significant incr

in response to 

inspection res

adequately ma

doubling of sa

retained. The 

subject to subs

has been clari

which the caus

inspection res

to all buried or 

122 XI.M41 

ML101610406 

Comment 

XI.M41-19

Element 4 item m (revised from k) – 

Considering the presence of any coarse 

material within 6 inches of the pipe or tank as 

significant and requiring additional inspections 

should be replaced with consideration of 

conditions that would damage the coating. 

The NRC staff 

partially agrees with 

this comment and the 

document was 

reworded for clarity.

The commente

backfill meetin

where not mor

backfill materia

retained on a 3⁄4 

not adopted fo
April 2011 IV-137 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

Demonstration that backfill will not damage 

the pipe was previously provided in element 

2.b and is based on site specific 

considerations and specifications. Damage 

due to backfill and its impact on the condition 

of the coating is considered as one of the risk 

factors in element 4.c.iv. that is used to select 

inspection locations. Typical site 

specifications for structural backfill require 

backfill to be well graded, dense, and 

consisting of sound durable material capable 

of achieving the required degree of 

compaction. Typical compaction

characteristics such as those in ASTM D1557 

apply to soils that have 30% or less by mass 

of their particles retained on a 3/4inch sieve. 

ASTM D1557 

method for det

compaction ch

is not appropri

backfill size dis

not degrade p

second, becau

does not conta

particle size. I

stones, which 

in the proposa

coatings. The 

ASTM D448-0

10 is based on 

D448-08 is an 

standard for us

size of backfill 

size numbers 

been used by 

entities in spec

similar applica

acknowledges

some plants, t

not meet these 

recognizes tha

backfill carries 

causing dama

result, the staf

exception to th

requirements s

meeting the re

acceptable if in
NUREG-1950 IV-138 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

that the backfi

damage to pip

To improve the 

document, the 

quality is now 

footnotes 5 an

These footnote

must be consis

2007 section 5

additionally sta

considers bac

within 6 inches 

meets ASTM D 

number 67 or 

the footnote) to 

objectives of S

footnotes also 

not meeting th

acceptable if in

the backfill has 

coating.

123 XI.M41 

ML101610406 

Comment 

XI.M41-20

Element 6 – Revised coating damage 

acceptance criteria consistent with element 4 

item m (revised from k) to require repair of 

any coating damage that directly exposes the 

piping or tank to the soil environment. 

Requiring repair of any coating degradation is 

overly restrictive. Minor coating degradation 

can occur that does not cause aging effects 

that result in loss of intended function of the 

The staff partially 

disagrees with this 

comment. The GALL 

Report has not been 

changed.

In the absence 

functioning cat

system, any de

will eventually 

of the coated p

absence of a p

cathodic prote

coatings suffic

as to expose t
April 2011 IV-139 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

piping or tank. environment a

pipe degradati

of cathodic pro

coating damag

difficult to main

of the system. 

criteria, the sta

justification for 

damaged coat

coating damag

expose the pip

requirement to 

coating has be

However, prov

for a NACE qu

determine whe

insignificant.

508 XI.M41 

ML101880269, 

Comment 

XI.M41-1 

Program Description, Element 2 item b (Table 

2b), Element 4 item c (Table 4b), and element 

4 item e. (Table 4d) - Recommend deleting 

“underground” environment and associated 

sections in element 2 and element 4. 

“Underground” environment is defined as 

below grade, but contained within a tunnel or 

vault such that they are in contact with air and 

are located where access for inspection is 

restricted. Detection of aging effects for 

underground components exposed to air 

environments is managed by AMP XI.M36 

External Surfaces Monitoring of Mechanical 

Components (see environments is managed 

The staff partially 

agrees with this 

comment and the 

associated changes 

to the GALL Report 

have been made.

The staff conc

comment to th

External Surfa

Mechanical Co

XI.M36) does 

where access 

also notes tha

primarily desig

systems which 

observable at 

and which do 

adverse indus

experience. G

recent adverse 
NUREG-1950 IV-140 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

by AMP XI.M36 External Surfaces Monitoring 

of Mechanical Components (see element 4) 

which requires that surfaces that are not 

readily visible during plant operations are 

inspected when they are made accessible and 

at such intervals that would ensure the

components intended function is maintained. 

The external surfaces program is the 

appropriate program due to the relatively 

benign environment of air. XI.M41 is not 

appropriate since it is primarily directed at 

components in a soil environment and the 

corresponding inspections are overly 

restrictive and the preventive actions 

regarding coating, cathodic protection and 

backfill are not appropriate. Clarification to be 

added to XI.M36 that requires the 

identification of the underground components, 

their materials, coatings and inspection 

amount and frequencies to ensure intended 

functions are maintained. NOTE: Due to the 

changes required to incorporate this comment 

it is not shown in AMP markup 

experience as

access piping, 

the comment r

applicability of 

limited access 

removed it from 

The staff posit

underground p

There is curre

experience to 

management o

underground p

detailed progra

outlined in AM

and Undergrou

Tanks. While 

move this mat

Surfaces Mon

staff sees no t

doing. Additio

that the subjec

underground p

discussed sim

staff believes t

joint discussio

AMP which ad

subjects is ben

509 XI.M41 

ML101880269, 

Comment 

XI.M41-2 

Program Description – 3rd paragraph:

Add XI.M30 Fuel Oil Chemistry to the list of 

AMPs that manage aging inside the pipe/tank.

The staff agrees with 

this comment and the 

associated changes

to the GALL Report 

Because XI.M

Chemistry is u

aging inside of 

has been adde
April 2011 IV-141 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

have been made. management p

Program Desc

966 XI.M41 

ML101880269, 

Comment 

XI.M41-3 

Element 1. Recommend deleting the sentence 

identifying typical systems. The buried piping 

and tanks program manages aging of 

components in a soil environment. 

Identification of systems for this type of AMP 

is unnecessary and not consistent with other 

GALL AMPs. Also delete the sentence: “Any 

system may contain buried and underground 

piping and tanks” as it does not contribute to 

an understanding of the scope of the AMP 

and is redundant to the first sentence of the 

paragraph.

The staff partially 

agrees with this 

comment. Some

changes have been 

made to the GALL 

Report.

The SRP for th

that such a list 

should be inclu

therefore retai

consistency w

The precise in

comment is un

piping and tan

manages agin

soil environme

program addre

and undergrou

opposed to jus

changes will b

this comment.

The staff conc

comment that 

system may co

underground p

adds little to th

sentence has 

967 XI.M41 

ML101880269, 

Comment 

XI.M41-4 

Element 1

The last sentence states that aging of bolting 

associated with piping systems within the 

scope of this program is also managed by this 

program. However there are no line items for 

bolting that credit this AMP. Recommend 

adding steel bolting line items for loss of 

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

Bolting expose

environment h

the AMP. A sta

added indicati

bolting within t

AMP is addres

while other bo
NUREG-1950 IV-142 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

material (managed by Buried Piping and 

Tanks) and loss of preload (managed by 

Bolting Integrity AMP) in a soil environment in 

GALL Chapter VIII.H and VII.I, External 

Surfaces of Miscellaneous Components and 

Bolting. 

are managed 

Integrity progra

VII.I.Ap-241, V

VIII.H.SP-141, 

were added fo

steel bolting in 

and managed 

968 XI.M41 

ML101880269, 

Comment 

XI.M41-5 

Element 2

Table 2a and Element 4 Table 4a and 

associated notes: HDPE should be listed in 

Element 2 item a as a material that does not 

require aging management in a soil 

environment and be deleted from the tables 

and associated footnotes in Element 2 and 

Element 4. 

Cracking can be caused by chemical aging. 

PE molecular chains may be broken down by 

temperature plus exposure to ozone, 

ultraviolet radiation, or oxidative chemicals. 

Carbon black is added to HDPE for protection 

from ultraviolet radiation. Ultraviolet radiation 

exposure is not an issue for buried HDPE 

pipe. Piping system design temperatures are 

well below the oxidation induction temperature 

requirement of 220C. 

Slow crack growth is the predominant failure 

mode for HDPE. This failure mode is 

addressed by material testing required by 

ASTM D-3350, Standard Specification for 

Polyethylene Plastics Pipe and Fittings 

Materials. PENT Testing performed under 

The staff disagrees 

with this comment 

and the GALL Report 

has not been 

changed.

The staff's pos

not sufficient o

to make this d

staff acknowle

research has b

indicating that 

potential, at so

future, of being 

material, when 

which aging m

required. The 

sufficient oper

under the cond

nuclear power 

not yet availab

determination.
April 2011 IV-143 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

ASTM D-3350 measures resistance of HDPE 

to slow crack growth and test results can be 

correlated to material service life. HDPE 

materials used in nuclear safety class 

applications are required to as a minimum 

meet ASTM classification 445574C. PENT 

testing for materials assures that slow crack 

growth is not a failure mode during the design 

life of the piping. Crack growth occurs at a 

very slow rate and this condition cannot be 

observed by field inspection.

HDPE does not absorb water according to 

Plastic Pipe Institute technical report PPI TR19, Chemical Resistance of Thermoplastic 

Piping Materials based on testing performed 

at temperatures up to 140 degrees F. HDPE 

is not subject to water absorption and 

subsequent osmotic blistering that can occur 

with other polymeric materials. There is no 

color change in response to water absorption 

with HDPE. 

969 XI.M41 

ML101880269, 

Comment 

XI.M41-6 

Element 2

Table 2a footnote 2 and Table 2b footnote 2 – 

Revise footnote2 to reference Table 1 of 

NACE Standard Practice SP0169-2007. For 

consistency with Table 2b footnote 2, also 

include the following sentence in Table 2a 

footnote2: “Other coatings may be used if 

justification is provided in the LRA.”

NRC staff partially 

agrees with this 

comment and the 

document has been 

reworded for clarity.

The staff's pos

reference to T

SP0169-2007 

RP0285-2002 

references.

1191 XI.M41 Element 2 Table 2a footnote 4 – Revise this The staff disagrees The staff notes 
NUREG-1950 IV-144 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

ML101880269, 

Comment 

XI.M41-7 

footnote to be consistent with the referenced 

NACE standards for operation and 

maintenance of the cathodic protection 

system and maintenance rule performance 

monitoring considerations. Specifically the 

effectiveness of the cathodic protection 

system should be monitored by:

- Inspection of applicable impressed current 

protection facilities to minimize in-service 

failures once per refueling cycle. 

- Functional check of impressed current 

sources for evidence of proper functioning 

(e.g., current output, normal power 

consumption, or signal indicating normal 

power operation) once every two months. 

- Evaluation, as applicable, of isolating fittings, 

continuity bonds, and casing isolation once 

per refueling cycle

with this comment. 

The GALL Report 

has not been 

changed.

standard inclu

aspects than t

comment. By i

in the AMP it m

confusion as to 

other aspects 

standard in AM

staff notes tha

consistent with 

in the intervals 

testing is to be 

recommendati

from Section 1

1192 XI.M41 

ML101880269, 

Comment 

XI.M41-8 

Element 2 Table 2a footnote 6 - The size of 

particles in structural backfill and the potential 

coating impact varies and depends on the 

type of coating used and 

backfill/placement/compaction. Recommend 

deleting 49 CFR 195.252 (applicable to 

petroleum or anhydrous ammonia pipelines) 

and revising to allow structural backfill 

consistent with backfill and compaction 

methods that existed when the plants were 

constructed. Typical site specifications for 

structural backfill require backfill to be well 

graded, dense, and consisting of sound 

The staff partially 

agrees with this 

comment and the 

document was 

reworded for clarity. 

The staff agree

CFR 195.252 

here. Since the 

SP0169-2007 

contain similar 

have been refe

staff notes tha

D1557 as a sta

selection or ev

material is not 

counts. First, A

standard whic

measurement 
April 2011 IV-145 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

durable material capable of achieving the 

required degree of compaction. Typical 

compaction characteristics such as those in 

ASTM D1557 apply to soils that have 30% or 

less by mass of their particles retained on a 3⁄4 

inch sieve. Typical structural backfill for 

opportunistic and directed inspections should 

have 30% or less of its particles retained on a 

3⁄4 inch sieve or demonstrate that the backfill 

material and placement/compaction methods 

will not result in exposure of piping metallic 

surfaces. Piping systems without backfill 

documentation or that cannot demonstrate 

backfill and associated placement/compaction 

will minimize expose of piping metallic 

surfaces shall be considered as candidates 

for inspection locations. Backfill installed after

buried component inspections shall have the 

maximum aggregate size or other material 

within six inches of the pipe with 30% or less 

of its particles retained on a 3⁄4 inch sieve. 

Backfill requirements do not apply to piping 

systems that are backfilled with a 

cementitious material (e.g., fillcrete) that 

provides a passivating layer. 

NOTE: Due to the changes required to 

incorporate this comment it is not shown in 

AMP markup

characteristics 

laboratory. It d

the adequacy 

distribution for 

size distributio

comment (30% 

a 3⁄4 inch sieve

distribution for 

method is valid

D1557 does n

maximum acc

size. Given tha

potentially the 

coatings, to be 

standard appli

largest particle

Although there 

standard for ag

distributions us

pipe, a signific

government ag

D448-08, Stan

for Sizes of Ag

and Bridge Co

or somewhat f

ASTM D1557 

with the object

1193 XI.M41 

ML101880269, 

Comment 

Element 2 Table 2a footnote7 - The size of 

particles in structural backfill and the potential 

impact on polymer materials varies and 

The staff agrees with 

the comment and the 

associated changes 

The staff has m

use more appr

recommendati
NUREG-1950 IV-146 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

XI.M41-9 depends on the type of material used for the 

piping system and the 

backfill/placement/compaction methods. 

Recommend adding an additional line on 

Table 2a for HDPE material to be consistent 

with Table 4a. Backfill requirements for other 

polymeric materials such as Fiberglass 

Reinforced Plastic (FRP) or similar 

thermoplastic materials should be consistent

with revisions proposed to footnote 6. 

to the GALL Report 

have been made.

Modifications t

2a (now footno

changes to the 

warranted. In c

specifications 

government en

found no insta

permitted back

polymeric pipe

backfill used a

The staff, there

the proposal to 

requirement fo

other than HD

the new footno

however, conc

specification (n

of sand) was n

distribution for 

been changed 

size number 1

475 XI.M41 

ML101880269, 

Comment 

XI.M41-10

Element 2 Table 2a and Table 2b and 

Element 4 Table 4a and Table 4b – Revise 

cement material to identify cementitious 

materials (asbestos cement, reinforced 

concrete, etc.)

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

The correct tec

“cementitious.

1194 XI.M41 

ML101880269, 

Comment 

XI.M41-11

Element 3 – Revise the last sentence to 

indicate that cathodic protection system 

parameters apply to steel, copper, or 

aluminum materials in a soil environment.

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

The NACE SP

recommends c

for steel, alum

alloy piping.
April 2011 IV-147 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

1195 XI.M41 

ML101880269, 

Comment 

XI.M41-12

Element 4 item b.vi and item c.vi – This 

requirement should be deleted. Not crediting 

shared/common piping systems for multiple 

unit sites will penalize multiple unit sites with 

additional inspections that are not required by 

a single unit site. For example, 14,000 feet of 

buried FRP common fire protection piping (1% 

of length for other polymer piping) at a 3 unit 

site will require 420 feet of pipe to be 

inspected rather than 140 feet at a single unit 

site. 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The staff's pos

counting is not 

staff believes t

preventive act

identified in th

to provide reas

that the safety 

structures, sys

components a

that the enviro

degraded. The 

that there wou

assurance tha

of structures, s

components a

event of a furth

these requirem

occur by “doub

inspection on s

478 XI.M41 

ML101880269, 

Comment 

XI.M41-13

Element 4 item b.viii – Revise this 

requirement allow volumetric techniques that 

are accepted by the industry as qualified 

techniques for detection of degradation.

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

The staff has a

item b.ix.B to i

inspections us

examination m

been qualified 

approved by th

acceptable su

examinations 

Given that guid

do not current

Element 4 item 

guided wave u
NUREG-1950 IV-148 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

important func

locations whic

inspection, the 

changed the te

b.viii.

1196 XI.M41 

ML101880269, 

Comment 

XI.M41-14

Element 4 – Item ix (new) – Retain the 

requirement from the prior draft that allows for 

the substitution of volumetric techniques from 

the inside of the piping in lieu of visual 

examinations. Volumetric exams provide a 

very accurate indication of piping condition 

and would allow detection of degradation in 

areas not excavated for visual exams. This 

will be consistent with the volumetric internal 

inspection instead of excavation for an 

external inspection of buried tanks.

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

Volumetric tec

of piping and t

used to determ

piping and tan

1197 XI.M41 

ML101880269, 

Comment 

XI.M41-15

Element 4 Table 4a and Table 4d – The 

percentage of linear length of piping required 

for inspection is excessive for ASME Code 

Class 3 pipe, hazardous material pipe, and 

other piping categories. Inspection of these 

pipe categories should be consistent with the 

industry Buried Pipe Initiative NEI 09-14. 

Direct or indirect inspection methods should 

be used and are based on providing 

reasonable assurance of the integrity of 100% 

of the high risk buried piping (where risk is 

determined by methods consistent with NEI 

09-14). Minimum inspection quantities would 

apply if there is no high risk piping identified 

for a buried pipe material. NOTE: Due to the 

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

In some cases

inspection was 

requirements h

accordingly. T

the number of 

for consistency 

based on a nu

some instance

based on the p

a given class. 

given number 

required. Alter

inspections wh

of detecting pi

also provided.
April 2011 IV-149 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

changes required to incorporate this comment 

it is not shown in AMP markup.

1198 XI.M41 

ML101880269, 

Comment 

XI.M41-16

Element 4 – Table 4a footnote 2 – Numerical 

visual inspection requirements specified by 

Table 4a footnote 2 are overly prescriptive 

and do not consider:

- Sample requirements of element 4 item b.iii. 

will focus inspections on piping segments 

based on the susceptibility to degradation

- Graded approach to inspection locations 

based on the safety significance of ASME 

Code Class pipe or the environmental impacts 

of Hazardous Material Pipe. 

- Other than the degradation susceptibility 

considerations noted in element 4 item b.iii, 

aging of a specific material of piping in a soil 

environment is not expected to yield different 

aging results. 

Based on these considerations, recommend 

that the numerical visual inspection 

requirements of Table 4a footnote 2 be 

revised to:

- Specify minimum inspection requirements 

- Substitute ASME Code Class Pipe or 

Hazardous Material Pipe inspections for Other 

Pipe category inspections

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

The inspection 

been establish

consideration 

preventive act

piping. Revise

requirements a

material type, 

present and w

Code Class/sa

hazmat piping

category has b

leaks from this 

will not affect t

the plant or im

environment. A

provided for fir

the “as new” re

piping containe

1199 XI.M41 

ML101880269, 

Comment 

Element 4 – Table 4a footnote 3 and footnote 

4 also Table 4b footnote 2 and footnote 3 – 

Clarify each footnote to define “radioactive” 

The staff agrees with 

this comment and the 

associated changes 

The Table 4a f

have been mo

consistent with 
NUREG-1950 IV-150 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

XI.M41-17 consistent with NEI 07-07 (Groundwater 

Protection Initiative). Treat radioactive 

systems with a tritium concentration of 

>20,000 pico-curies/liter as Hazardous 

Materials for purposes of the Buried Piping 

and Tanks AMP.

to the GALL Report 

have been made.

Footnote 5 of T

footnote 4 of T

“Haz Mat pipe 

normal operat

material which

be detrimental 

This includes c

such as diesel 

radioisotopes. 

Haz Mat, conc

radioisotope w

normal operat

established sta

EPA drinking w

the absence o

concentration 

must exceed t

background or 

detection. For 

drinking water 

pCi/L) is used.

1200 XI.M41 

ML101880269, 

Comment 

XI.M41-18

Element 4 – Table 4a footnote 6 – Revise 

operation and maintenance requirements of 

the cathodic protection system to be 

consistent with NACE SP 0169-2007 section 

10. Federal requirements (40 CFR 280 

Subpart C) for underground storage tanks 

(UST) also have similar requirements. 

Documentation may not be available to prove 

that the cathodic protection system has been 

operating 90% of the time since the pipe was 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

While cathodic 

effective in mit

corrosion, its u

damage done 

The 90% avail

contained in th

therefore, an i

the most proba

condition of th

chosen to reta
April 2011 IV-151 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

originally installed even though the system 

has been adequately protecting the piping. 

Operation and maintenance performance of 

the cathodic protection system should be 

determined based on the recommend 

changes to Table 2a footnote4. 

availability crit

added an inter

piping where c

provided but it

less than 90%

for this catego

systems where 

is absent and 

piping with 90% 

protection ava

970 XI.M41

ML101880269,

Comment 

XI.M41-19 

Element 4 Table 4a footnote 6 - Replace the 

requirement for 90% operability since the pipe 

was originally installed or was visually 

inspected with a reference to the proposed 

revision to element 2 Table 2a footnote 4. 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The use of cat

cannot reverse 

before cathodi

applied or for p

cathodic prote

operable for ex

time.

1201 XI.M41 

ML101880269, 

Comment 

XI.M41-20

Element 4 item c.iv. and Table 2b footnote 1 – 

Revise consistent with comment XI.M41 – 16. 

Also, volumetric inspection requirements, as 

applicable, for AMPs that manage internal 

environments should be used to manage 

aging of internal surfaces. Recommend 

revising Table 4b footnote 1 to require 

volumetric inspections to detect internal 

corrosion consistent with AMPs that manage 

aging of internal environments.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

AMPs to mana

material are in 

components in 

renewal. There 

experience to 

underground p

augmentation 

address corros

environments 

adequately ma

1202 XI.M41 

ML101880269, 

Comment 

Element 4 item d.v. and item e.iv. – If the tank 

is volumetrically inspected internally, the 

required number of inspection locations of the 

The staff disagrees 

with this comment. 

The GALL Report 

The term “90/9

used by the st

a given group 
NUREG-1950 IV-152 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

XI.M41-21 tank surface area should be limited to 22 

rather than requiring 90% of the surface of the 

tank. Inspecting 22 locations will provide a 

90/90 assurance level (reference NUREG 

1475 Table T-8).

has not been 

changed.

sufficient samp

to provide a 90

defective com

identified by th

a requirement 

components a

statistics are to 

case of a tank 

should not occ

the appropriate 

“permissible n

should be the 

hole divided by 

(both values b

similar units of 

percentage of 

should be one 

number. It may 

number will be 

90%. Since the 

calculation for 

both the allowa

the size of the 

chosen to emp

test sample wh

with the accep

or the size of t

487 XI.M41 

ML101880269, 

Comment 

XI.M41-22

Element 4 item f – This item is redundant to 

element 6 (acceptance criteria) and element 7 

(corrective actions) and should be deleted 

after incorporation of applicable requirements. 

NRC staff partially 

agrees with this 

comment and the 

document was 

Some of the a

were not in the 

element and h

the proper loca
April 2011 IV-153 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

Recommend including each adverse finding 

as noted below:

- Item f.i. – Entering of cathodic protection 

system adverse indications into the corrective 

action program should be incorporated into 

element 6 item a. Through-wall leakage, wall 

thickness less than minimum, or degraded 

coating that exposes the piping material 

surface will require evaluation and sample 

size to be increased. This requirement should 

be included as element 6 item g. Repair or 

replacement corrective actions for throughwall leakage, wall thickness less than 

minimum, or coating degradation that exposes 

the piping material surface should be 

incorporated into element 7. Backfill 

requirements have been recommended to be 

covered by Table 2a footnote 6. 

- Item f.ii – Include repair or replacement 

requirements in element 7 corrective actions. 

Through-wall leakage, wall thickness less 

than minimum, or coating degradation that 

exposes the piping material surface will 

require repair or replacement. 

- Item f.iii. – Evaluation of the degradation and 

expansion of the sample size are 

recommended to be incorporated into element 

6 item g.

- Item f.iv. - Evaluation of the degradation and 

expansion of the sample size are 

recommended to be incorporated into element 

reworded for clarity.
NUREG-1950 IV-154 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

6 item g. Doubling of the sample size may not 

be possible in many cases and in some cases 

doubling may not be enough. 

488 XI.M41 

ML101880269, 

Comment 

XI.M41-23

Element 5 – The first sentence of element 5 

requires trending to determine the condition of 

the coating system and the effectiveness of 

the cathodic protection system. Trending of 

visual inspection results to estimate remaining 

life is redundant to element 6 requirements to 

determine wall thickness in the affected area 

and determine if the minimum wall thickness 

will be maintained. Recommend deleting 

remaining life calculations since element 6 

requires minimum wall evaluations.

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

Element 5 has 

read: “For pipi

protected by c

systems, pote

current measu

to identify cha

effectiveness o

and/or.”

489 XI.M41 

ML101880269, 

Comment 

XI.M41-24

Element 6 item b. - Revise coating damage 

acceptance criteria to require repair of any 

coating damage that directly exposes the 

piping or tank to the soil environment. 

Requiring repair of any coating degradation is 

overly restrictive. Minor coating degradation 

can occur that does not cause aging effects 

that result in loss of intended function of the 

piping or tank.

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

Coating dama

expose bare m

dispositioned b

action program

has been revis

evaluation of c

NACE certified 

490 XI.M41 

ML101880269, 

Comment 

XI.M41-25

Element 6 item f – Backfill requirements are 

now specified in element 2. Recommend 

deleting item f from element 6 acceptance 

criteria since backfill requirements are site 

specific and depend on the type of coating 

used and backfill/placement/compaction.

NRC staff partially 

agrees with this 

comment and the 

document was 

reworded for clarity.

An acceptance 

for the backfill

that backfill req

addressed in E

they are speci

coating emplo

backfill is an is
April 2011 IV-155 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

an acceptance 

the staff has re

item f to refer t

specifications 

491 XI.M41 

ML101880269, 

Comment 

XI.M41-26

Element 10 – Operating experience 

associated with item d (rupture related to 

Tropical Storm Fay) is an event driven failure, 

is not age related, and should be deleted from 

the operating experience list. Item e (February 

2009 CST leak), item g (diesel leak), and item 

h (June 2009) CST leak should be revised to 

identify the age related failure and its 

associated cause (e.g., coating degradation) 

or be deleted from the operating experience 

list. Corrective action descriptions add little 

value to the OE discussion. OE listed without 

identifying causes is also of questionable 

value.

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

Event-driven fa

included in the 

aging. The ope

items listed in 

been deleted.

405 XI.M41

ML101880267 

Comment 

XI.M41-PW1 

This is a comprehensive program designed to 

manage the aging of the external surfaces of 

buried and underground piping and tanks

PW1.While corrosion from the outer surface of 

buried pipes may be the dominant failure 

mechanism, there have been failures from the 

inside (supply water system e.g.) which simply 

are not covered by other programs which deal 

almost exclusively with maintaining water 

chemistry. It makes no sense of excluding 

internal corrosion and verification of the 

effectiveness of alternate programs

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

This AMP is no

manage aging 

the piping or ta

programs that 

from the inside 

piping, as iden

Description. A

type of progra

Cooling Water 

the buried pipi

redundant, hav

if one train has 

service for rep
NUREG-1950 IV-156 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

It addresses piping and tanks composed of 

any material, including metallic, polymeric and 

cementitious materials. This program 

manages aging through preventive, mitigative 

and inspection activities. It manages all 

applicable aging effects such as loss of 

material, cracking, and changes in material 

properties.

is capable of a

intended funct

required to me

renewal rule. T

structured the 

that the extern

and undergrou

are covered by 

internal surfac

other AMPs as 

Program Desc

cases in which 

surface of a bu

pipe or tank is 

AMP and the c

internal surfac

has, however, 

language used 

the AMP to ac

AMP is used to 

internal inspec

and undergrou

410 XI.M41 

ML101880267 

Comment 

XI.M41-PW2 

It addresses piping and tanks composed of 

any material, including metallic, polymeric and 

cementitious materials. This program 

manages aging through preventive, mitigative 

and inspection activities. It manages all 

applicable aging effects such as loss of 

material, cracking, and changes in material 

properties.

Depending on the material, preventive and 

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

The term, “cor

coatings” has 

reflect the term

NACE SP0169

coatings for ex

control). The te

for external co

now being use

NACE SP0169
April 2011 IV-157 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

mitigative techniques include: the material 

itself, corrosion resistant coatings,

PW2. “Corrosion resistant coatings” is 

incorrect. Coatings do not corrode, they 

deteriorate, whereupon water has access to 

the underlying metal and corrosion can start

and the application of cathodic protection. 

Also, depending on the material, inspection 

activities include electrochemical verification 

of the effectiveness of cathodic protection,

non-destructive evaluation of pipe or tank wall 

thicknesses, and visual inspections of the pipe 

or tank from the exterior as permitted by 

opportunistic or directed excavations.

411 XI.M41 

ML101880267 

Comment 

XI.M41-PW3 

Although this program considers the fluid 

inside the pipe or tank, and certain aspects of 

the program may be carried out from the 

inside of the pipe or tank, this program is 

designed to address only the degradation 

occurring on the outside of the pipe or tank. 

Aging of the inside of the pipe or tank is 

managed by another program (e.g., Open 

Cycle Cooling Water (AMP XI.M20), Treated 

Water (XIM.21A), Internal Inspection of 

Miscellaneous Piping and Ducts XI.MXX) or 

Water Chemistry (XI.M2). Additionally, this 

program does not address selective leaching. 

The selective leaching program (Chapter 

XI.M33) is applied in addition to this program 

for applicable materials and environments.

The terms “buried and underground are fully 

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

The NRC staff 

include underg

AMP.
NUREG-1950 IV-158 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

defined in Chapter IX of the GALL Report. 

Briefly, buried piping and tanks are in direct 

contact with soil or concrete (e.g., a wall 

penetration). Underground piping and tanks 

are below grade, but are contained within a 

tunnel or vault such that they are in contact 

with air and are located where access for 

inspection is restricted. 

PW3: I think it is essential to include 

underground piping - the deterioration evident 

in the tunnels in Indian Point is pretty bad and 

recent experience at EVY’s AOG [advanced 

off-gas] piping

504 XI.M41 

ML101880267 

Comment 

XI.M41-PW4 

Evaluation and Technical Basis

1. Scope of Program: This program is used to 

manage the effects of aging for buried and 

underground piping and tanks constructed of 

any material including metallic, polymeric and 

cementitious materials. The program 

addresses aging effects such as loss of 

material, cracking, and changes in material 

properties. Any system may contain buried 

and underground piping or tanks. Typical 

systems include service water piping and 

components, condensate storage transfer 

lines, fuel oil and lubricating oil lines, fire 

protection piping and piping components (fire 

hydrants), and storage tanks. The aging of 

bolting associated with piping systems within 

the scope of this program is also managed by 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The systems l

Program” sect

those that “typ

piping within th

renewal. Altho

offgas (AOG) s

boiling water r

contains burie

is not typically 

license renewa

10 CFR 54.4, 

associated wit

nonsafety-rela

would only be 

scope of licens

determined tha

piping could p
April 2011 IV-159 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

this program.

PW4 : add piping related to AOG system

related system 

performing its 

This is typicall

929 XI.M41

ML101880267 

Comment 

XI.M41-PW5 

Cathodic protection is in accordance with 

NACE SP0169-2007 or RP0285-2002. 

Attempts to demonstrate that cathodic 

protection is not required as discussed in 

Sections 1.2 and 3 of SP0169-2007 will not be 

considered.

PW5: What does that mean? Does it mean 

that it will not be considered?

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

It is the staff’s 

preventive act

of coatings, ins

protection, and 

backfill, are an 

comprehensiv

managing the 

surfaces of bu

underground p

during the agin

review process

determines tha

piping and tan

the prevent ac

staff would exp

applicant woul

take action to 

preventive act

period of exten

take an excep

provide a thoro

justification for 

930 XI.M41 

ML101880267 

Comment 

XI.M41-PW6 

Backfill is consistent with 49 CFR 195.252. 

Maximum size of aggregate or other material 

within 6 inches of pipe is 1⁄2 inch in diameter or 

less.

PW6: There seems to be a conflict between 6 

The staff disagrees 

with this comment 

and the GALL Report 

has not been 

changed.

The topic of th

addressed in f

table 2a. The 

reference to 49 

favor of ASTM 
NUREG-1950 IV-160 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

and 7. Sand is a lot finer than 1/2 inch. 

Crushed concrete of 1/2 inch diameter (?) can 

be quite jagged and do much damage while 

river bottom pebbles may be harmless. Also 

absent from the discussion on backfill material 

was the degree to which the material retained 

moisture

Corrosion cells develop on a piece of metal 

exposed to different electrolytes and it is a 

particularly common problem on underground 

structures 27. Potential differences develop, 

for example, on a long continuous pipeline 

that passes through different types of soils. 

One portion of the line might be laid in sandy 

loam while another lie in clay. Substantial 

natural pipeline currents (“long-line currents”) 

may occur, which leads to corrosion cells as 

called “long line cells.” In soils of low resistivity 

where such currents exit from the pipeline, 

causing the metal at the exit points is lost by 

anodic dissolution (corrosion). Anodes and 

cathodes may be miles apart.

Particle size for backfill within 6 inches of the 

pipe must not exceed that of sand grains

number 67 (m

(polymeric pip

The staff belie

standard ASTM 

for backfill to b

than either “gr

proposed by th

CFR 195.252. 

evidence of co

performing sat

buried in back

coarse than gr

use of sand siz

therefore cons

931 XI.M41 

ML101880267 

Comment 

XI.M41-PW7 

3. Parameters Monitored/Inspected: The 

aging effects addressed by this AMP are loss 

of material due to all forms of corrosion and, 

potentially, cracking due to SCC. Two 

parameters are monitored to detect and 

manage these aging effects: visual 

appearance of the exterior of the piping or 

The staff disagrees 

with this comment 

and the GALL Report 

has not been 

changed.

Operating exp

that general, p

MIC can be de

inspection. If 

surface or volu

may be require

term “all forms 
April 2011 IV-161 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

tank; and wall thickness of the piping or tank, 

generally as determined by a non-destructive 

examination technique such as ultrasonic 

testing (UT). Two additional parameters, the 

pipe-to-soil potential and the cathodic 

protection current, are monitored to determine 

the effectiveness of cathodic protection 

systems and, thereby, the effectiveness of 

corrosion mitigation. 

PW7: This paragraph is downright primitive. 

“All forms of corrosion” is pretty broad. But 

again, monitoring/inspection is limited to 

visual and UT. One cannot detect cracking 

with these two methods. Pipe to soil potential 

surveys should be done independent of active 

CP as a means to detect “hot spots” on buried 

pipe.

intentionally us

breadth. A var

techniques inc

and phased ar

of detecting cr

routinely used 

The use of pot

independent o

is not required 

necessary con

may or may no

necessary con

present, a pote

used by an ap

to determine a

inspections.

932 XI.M41 

ML101880267 

Comment 

XI.M41-PW8 

4. Detection of Aging Effects: Methods and 

frequencies used for the detection of aging 

effects vary with the material and environment 

of the buried and underground piping and 

tanks. These methods and frequencies are 

outlined below.

a. Opportunistic Inspections

i. All buried and underground piping and 

tanks, regardless of their material of 

construction are opportunistically inspected by 

visual means whenever they become 

accessible for any reason. 

PW8: Opportunistic means that there has 

The staff partially 

agrees with this

comment and

associated changes 

to the GALL Report 

have been made.

The performan

opportunistic i

applicant does 

presence of a 

inspections are 

whenever pipi

uncovered for 

AMP has give

requirements f

must be inspe

While visual in

quantitative, th

effective in det

presence or ab
NUREG-1950 IV-162 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

been a leak that needs to be repaired. Visual 

inspection is “stone age technology” There 

has to be a decision of how much more pipe 

to excavate and at least conduct some 

quantitative examinations.

or coating dam

933 XI.M41 

ML101880267 

Comment 

XI.M41-PW9 

ii. Directed inspections as indicated in Table 

4a will be conducted during each 10 year 

period beginning 10 years prior to the entry 

into the period of extended operation.

PW9: What evidence is there to justify a 10 

year interval. This is the crux. One simply 

cannot squeeze all these situations into the 

same shoe box.

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

The operating 

piping and tan

indication whe

year interval is 

particular pipin

the operating e

that more freq

required, or if t

identify proble

frequent inspe

conducted.

The 10-year in

was selected t

the 10-year ins

interval of Sec

Code. Modifica

may be neces

operating histo

piping system 

934 XI.M41 

ML101880267 

Comment 

XI.M41-PW10

iii. Inspection locations are selected based on 

susceptibility to degradation. Issues such as 

coating type, coating condition, cathodic 

protection efficacy, backfill characteristics and 

soil resistivity are considered

PW10: If in fact there are various degrees of 

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

The operating 

piping and tan

indication whe

year interval is 

particular pipin

the operating e

that more freq
April 2011 IV-163 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

susceptibility should there not also be varying 

degrees of inspection frequencies?

required, or if t

identify proble

frequent inspe

conducted.

Varying degre

are addressed 

extent of inspe

the inspection 

both may be n

operating expe

935 XI.M41 

ML101880267 

Comment 

XI.M41-PW11

vi. At multi-unit sites, individual inspections of 

shared piping may not be credited for more 

than one unit.

PW11: What is this? Is it the pipe that is 

corroding or the Unit? 

The staff disagrees 

with this comment 

and the GALL Report 

has not been 

changed.

This refers to a 

more than one 

plant. An inspe

is shared by m

nuclear power 

credited by mo

nuclear power 

936 XI.M41 

ML101880267 

Comment 

XI.M41-PW12

iii. Inspection locations are selected based on 

susceptibility to degradation. Issues such as 

coating type, coating condition, exact external 

environment, and flow characteristics within 

the pipe, are considered

PW12: It is good to see consideration of 

internal corrosion, but it seems to me the 

document in not consistent

The staff disagrees 

with this comment 

and the GALL Report 

has not been 

changed.

The statement 

comment refer

locations are s

susceptibility t

Issues such as 

coating condit

environment, a

characteristics 

considered” do

imply a discus

corrosion. Con

material in the 

its corrosivity o

address the si
NUREG-1950 IV-164 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

should one oc

937 XI.M41 

ML101880267 

Comment 

XI.M41-PW13

iv. Underground pipes are inspected visually 

to detect external corrosion and by UT to 

detect internal corrosion.

PW13: That's another muddle: UT detects 

both internal and external corrosion – 

Separation is tricky but can be done.

The staff disagrees 

with this comment 

and the GALL Report 

has not been 

changed.

The ultimate g

determining w

nothing more.

938 XI.M41 

ML101880267 

Comment 

XI.M41-PW14

v. Opportunistic examinations may be credited 

toward these direct examinations if the 

location selection criteria in iii, above are met

vi. At multi-unit sites, individual inspections of 

shared piping may not be credited for more 

than one unit.

PW14: This makes no sense.

The staff disagrees 

with this comment 

and the GALL Report 

has not been 

changed.

This refers to a 

more than one 

plant. An inspe

is shared by m

nuclear power 

credited by mo

nuclear power 

This comment 

prohibition at m

conducting a s

shared piping 

two inspection

This comment 

comment No. 

939 XI.M41 

ML101880267 

Comment 

XI.M41-PW15

1. Numerical values under the visual 

inspection heading indicate the percentage in 

linear feet of piping of the category indicated 

which is to be inspected using visual and 

ultrasonic techniques, i.e., if stainless steel 

piping is present in each of the three 

categories of piping a minimum of 3 

inspections are conducted, one for each 

piping category. One or more inspections are 

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

These figures 

engineering ju

regarding the s

to provide reas

that the intend

underground p

maintained. Th

statistically ba
April 2011 IV-165 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

conducted to inspect at least 2% of the code 

class piping; one or more inspections are 

conducted to inspect at least 2% of the Haz 

Mat piping; and one or more inspections are 

conducted to inspect at least 1% of the “other” 

piping. Alternatively, the entire length of 

stainless steel piping present in all three 

piping categories may be considered to be 

code class piping and inspected accordingly, 

i.e., one or more inspections are conducted to 

inspect at least 2% of the total length of 

stainless steel piping present. All piping which 

is visually inspected to detect external 

corrosion is ultrasonically inspected to detect 

internal corrosion. UT inspection intervals will 

not exceed one foot. Particular attention is 

paid to elbows and the adjacent piping.

PW15: Where do these numbers come from? 

Is there any evidence that 2% is statistically 

the correct number? Provide rationale in 

footnote.

940 XI.M41 

ML101880267 

Comment 

XI.M41-PW16

viii. Opportunistic examinations may be 

credited toward these direct examinations 

PW16: Opportunistic examinations should not 

be credited toward anything, rather they 

should be used to indicate and classify 

targeted examination. 

The staff disagrees 

with this comment 

and the GALL Report 

has not been 

changed.

Opportunistic e

meet the requ

examinations 

toward the dire

the case of un

the staff expec

the external en

therefore, in th

corrosion. An o

therefore, fulfil
NUREG-1950 IV-166 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

objectives for a 

may be credite

941 XI.M41 

ML101880267 

Comment 

XI.M41-PW17

iv. Examinations may be conducted from the 

external surface of the tank using visual 

techniques or from the internal surface of the 

tank using volumetric techniques. If the tank is 

inspected from the external surface a 

minimum 25% coverage is required. This area 

must include at least some of both the top and 

bottom of the tank. If the tank is inspected 

internally by UT, at least 1 measurement is 

required per square foot of tank surface. If the 

tank is inspected internally by another 

volumetric technique, at least 90% of the 

surface of the tank must be inspected

PW17: A UT measurement covers about 0.5 

square inches of surface area. There are 144 

square inches in a square foot. Hence, one 

measurement per square foot covers about 

100/288 percent of surface area. 

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

Sufficient insp

conducted to e

wall thickness 

design require

942 XI.M41 

ML101880267 

Comment 

XI.M41-PW18

(NRC renamed 

second 

Comment 

PW15 due to 

duplication)

b. For coated piping or tanks, there should be 

no evidence of coating degradation. 

PW15: (should be PW18) During the 

teleconference call, it was recommended that 

“no evidence of coating degradation” be 

determined by a “NACE certified inspector” – 

inspector’s judgment calls vary all over the 

map, absent specific criteria by NRC this is 

not an acceptable way to provide reasonable 

assurance.

The staff disagrees 

with this comment 

and the GALL Report 

has not been 

changed.

The inspector 

conduct the in

certified inspec

provide consis

information co

of coating syst

trained person

determinations 

available techn

the extent and 
April 2011 IV-167 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

coating degrad

1051 XI.M41

ML102320585, 

Comment 

XI.M41-1 

Program Description, Element 2 item b (Table 

2b), Element 4 item c (Table 4b), and element 

4 item e. (Table 4d) - Recommend deleting 

“underground” environment and associated 

sections in element 2 and element 4.

“Underground” environment is defined as 

below grade, but contained within a tunnel or 

vault such that they are in contact with air and 

are located where access for inspection is 

restricted. Detection of aging effects for 

underground components exposed to air 

environments is managed by AMP XI.M36 

External Surfaces Monitoring of Mechanical 

Components (see element 4) which requires 

that surfaces that are not readily visible during 

plant operations are inspected when they are 

made accessible and at such intervals that 

would ensure the components intended 

function is maintained. The external surfaces 

program is the appropriate program due to the 

relatively benign environment of air. XI.M41 is 

not appropriate since it is primarily directed at 

components in a soil environment and the 

corresponding inspections are overly 

restrictive and the preventive actions 

regarding coating, cathodic protection and 

backfill are not appropriate. Clarification to be 

added to XI.M36 that requires the 

identification of the underground components, 

their materials, coatings and inspection 

The staff disagrees 

with this comment 

and the GALL Report 

has not been 

changed.

Due to recent 

experience the 

to include “und

AMP. In additi

underground p

discussed toge
NUREG-1950 IV-168 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

amount and frequencies to ensure intended 

functions are maintained. 

NOTE: Due to the changes required to 

incorporate this comment it is not shown in 

AMP markup. Add sentence to describe that 

the aging management of buried fire 

protection components are managed by 

system flow and pressure testing in 

accordance with XI.M27 such that the need 

for notes in Element 2 item a.ii., Element 4 

item b.ix, Element 4 item c.ix, Element 6 item 

g in regards to this testing are not needed.

1053 XI.M41

ML102320585, 

Comment 

XI.M41-2 

Element 2 Table 2a and Element 4 Table 4a 

and associated notes – HDPE should be 

listed in Element 2 item a as a material that 

does not require aging management in a soil 

environment and be deleted from the tables 

and associated footnotes in Element 2 and 

Element 4.

Cracking can be caused by chemical aging. 

PE molecular chains may be broken down by 

temperature plus exposure to ozone, 

ultraviolet radiation, or oxidative chemicals. 

Carbon black is added to HDPE for protection 

from ultraviolet radiation. Ultraviolet radiation 

exposure is not an issue for buried HDPE 

pipe.

Piping system design temperatures are well 

below the oxidation induction temperature 

requirement of 220C. 

The staff disagrees 

with this comment 

and the GALL Report 

has not been 

changed.

There is not en

experience wit

conclude that 

not require an 

program and w

slow crack gro

There is not su

experience to 

determination. 

acknowledges 

research has b

indicating that 

potential, at so

future, of being 

material, when 

which aging m

required. The 

sufficient oper

under the cond
April 2011 IV-169 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

Slow crack growth is the predominant failure 

mode for HDPE. This failure mode is 

addressed by material testing required by 

ASTM D-3350, Standard Specification for 

Polyethylene Plastics Pipe and Fittings 

Materials. PENT Testing performed under 

ASTM D-3350 measures resistance of HDPE 

to slow crack growth and test results can be 

correlated to material service life. HDPE 

materials used in nuclear safety class 

applications are required to as a minimum 

meet ASTM classification 445574C. PENT 

testing for materials assures that slow crack 

growth is not a failure mode during the design 

life of the piping. Crack growth occurs at a 

very slow rate and this condition cannot be 

observed by field inspection. 

HDPE does not absorb water according to 

Plastic Pipe Institute technical report PPI TR19, Chemical Resistance of Thermoplastic 

Piping Materials based on testing performed 

at temperatures up to 140 degrees F. HDPE 

is not subject to water absorption and 

subsequent osmotic blistering that can occur 

with other polymeric materials. There is no 

color change in response to water absorption 

with HDPE.

nuclear power 

not yet availab

determination.

1054 XI.M41

ML102320585, 

Comment 

XI.M41-3 

Element 2 item a.ii., Element 4 item b.ix, 

Element 4 item c.ix, Element 6 item g. – 

Delete this item. This item is redundant to 

periodic NFPA 25 flow testing of fire mains as 

The staff disagrees 

with this comment 

and the GALL Report 

has not been 

In light of rece

experience wit

interval for ins

frequent enoug
NUREG-1950 IV-170 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

described in AMP XI.M27, Fire Water 

Systems. The NFPA 25 flow and pressure 

testing is performed at plant-specific intervals 

determined by engineering evaluation of the 

fire protection piping to ensure that 

degradation will be detected before the loss of 

intended function. NFPA (2008) section 7.3.1 

requires that underground and exposed piping 

shall be flow tested to determine the internal 

condition of the piping at minimum 5 year 

intervals. Change made to Program 

description to eliminate need for these 

additional notes.

changed. performance p

inspection. Th

trended using 

Changes in ins

be considered 

trending.

1055 XI.M41

ML102320585, 

Comment 

XI.M41-4 

Element 2 Table 2a footnote 2 – For 

consistency with Table 2b footnote2, also 

include the following sentence in Table 2a 

footnote 2: “Other coatings may be used if 

justification is provided in the LRA.”

The staff disagrees 

with this comment 

and the GALL Report 

has not been 

changed.

Table 2a addre

and coatings u

protection. Tab

1056 XI.M41

ML102320585,

Comment 

XI.M41-5 

Element 2 Table 2a footnote 4 – Revise this 

footnote to specify that “operation and 

maintenance” of the cathodic protection 

system is in accordance with NACE SP0169-

2007 section 10. Revise the third sentence of 

the footnote to indicate that cathodic 

protection equipment need not be 10 CFR 50 

Appendix B qualified or within the scope of 

license renewal. Parts “a” and “b” of footnote 

4 should be clarified to indicate that either is 

acceptable for not providing cathodic 

protection.

The staff partially 

agrees with this 

comment and the 

document was 

reworded for clarity.

The staff disag

NACE SP0169

because it per

than one year. 

reworded to de

.Clarification a

cathodic prote

need not be qu

50 Appendix B
April 2011 IV-171 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

1057 XI.M41

ML102320585, 

Comment 

XI.M41-6 

Element 2 Table 2a footnote 5 and 6 – Revise 

this footnote to clarify that for purposes of 

initial and subsequent inspections, backfill not 

meeting this standard is acceptable if 

inspections of piping within the scope of 

license renewal do not reveal evidence of 

mechanical damage to pipe coatings due to 

backfill. Add similar note for footnote 6.

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

If no damage t

pipe during the 

subsequent in

observed, then 

meeting the st

acceptable. A 

been added to 

1058 XI.M41

ML102320585, 

Comment 

XI.M41-7 

Element 2 Table 2a footnote 9 – Add a new 

footnote to read: “AWWA C-105 provides a 

standard for determining if the ductile iron 

should be coated and/or CP-protected 

(primarily based upon soil conditions)." DIPRA 

and NBS studies point to > 95% of all soils 

being compatible with and non-corrosive to 

ductile iron.

The staff disagrees 

with this comment 

and the GALL Report 

has not been 

changed.

SP0169-2007 

addresses duc

Other than fire 

there is a limite

iron piping use

plants.

1059 XI.M41

ML102320585, 

Comment 

XI.M41-8 

Element 2 Table 2b footnote 3 – Delete 

footnote 3 and the requirement for providing 

coatings for stainless steel and aluminum 

underground piping.

Stainless steel and aluminum piping are 

highly corrosion resistant materials in an air 

environment and not typically coated. The 

aging evaluation process would evaluate the 

aggressive nature of the environment to 

identify aging and the appropriate aging 

management requirements. Coatings are not 

the only solution for managing aging due to an 

aggressive environment. Periodic inspections 

as noted in element 4.c. or other preventive 

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

It is unlikely th

aluminum pipi

high concentra

very low pH or 

would necessi

coatings for st

aluminum pipi
NUREG-1950 IV-172 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

measures (e.g., stopping the source of the 

leak/aggressive environment) could be used 

to detect and manage aging.

1060 XI.M41

ML102320585, 

Comment 

XI.M41-9 

Element 4 item b.iv. – Revise to read “visual 

inspections may be supplemented”. Surface 

and/or volumetric examinations should be 

optional if significant indications are observed 

and the decision is made to repair or replace 

the piping based on the visual indications. 

Recommend significant indications be defined 

as aging resulting in pitting or surface 

corrosion.

The staff partially 

agrees with this 

comment and the 

document was 

reworded for clarity.

The staff agree

and/or volume

should be opti

replaced but d

piping is repai

1061 XI.M41

ML102320585, 

Comment 

XI.M41-10

Element 4 item b.vi and item c.vi – This 

requirement should be deleted. Not crediting 

shared/common piping systems for multiple 

unit sites will penalize multiple unit sites with 

additional inspections that are not required by 

a single unit site and provides no significant 

additional assurance of the integrity of the 

coating based on the common systems, 

materials and environments including soil 

conditions. For example, 14,000 feet of buried 

FRP common fire protection piping (1% of 

length for other polymer piping) at a 3 unit site 

will require 420 feet of pipe to be inspected 

rather than 140 feet at a single unit site.

The staff disagrees 

with this comment 

and the GALL Report 

has not been 

changed.

The staff does 

inspections are 

The staff also 

fire protection 

example.

1062 XI.M41

ML102320585, 

Comment 

XI.M41-10(2)

Element 4 item b.x and item c.x.. – Revise this 

item to allow either hydrostatic testing (option 

A) or internal inspections (option B) to be 

used in lieu of the inspections noted in Table 

The staff partially 

agrees with this 

comment and the 

document was

Pressure testin

ensure that the 

its intended fu

inspection. Oth
April 2011 IV-173 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

4a. Both methods will provide evidence of a 

loss of pressure boundary function. Delete 

need for staff approval. NRC will have 

opportunity to review the qualified method 

credited during audits. Delete word precisely 

since it is undefined. In addition 49 CFR 195 

is a transportation pipeline standard that 

requires test pressures well above system 

operating pressures that may not be 

achievable for these systems. It also requires 

use of water or gas test mediums which would 

not be possible for fuel oil lines. Recommend 

pressure or inservice leak testing using ASME 

requirements.

reworded for clarity. considered for 

but fuel oil sho

AMP M41 was 

either option.

1063 XI.M41

ML102320585, 

Comment 

XI.M41-11

Element 4 Table 4a footnote 2 and Table 4c 

footnote 2 – Delete the reference to NACE 

SP0169-2007 through footnote 2 and just 

reference element 2 Table 2a. Element 2 

Table 2a and its associated footnotes 

identifies the coating, backfill, and cathodic 

protection preventive measures acceptable to 

the staff.

Identifying applicability of backfill, coating and 

cathodic protection preventive measures to 

both NACE SP0169-2007 and Table 2a is 

confusing and redundant.

Note that several of the element 2 table 2a 

footnotes also allow the use of NACE 

RP0285-2002.

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

The reference 

has been remo

redundant. Re

2002 has been 

table 2a footno

1064 XI.M41 Element 4 Table 4a footnote 2 item C & D and The staff agrees with Five years of o
NUREG-1950 IV-174 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

ML102320585, 

Comment 

XI.M41-12

Table 4c footnote 2 item C & D – Revise 

these items to specify cathodic protection 

system 90% operation is based on the 

previous five years of operation or the time 

since the piping was last inspected. 

Monitoring/trending required by element 5 that 

is associated with five years worth of cathodic 

protection system operation at 90% should 

also provide an indication of the effectiveness 

of the system and/or coatings. Also, plant 

records might not be available to support 90% 

operation for the piping under consideration 

was installed.

this comment and the 

associated changes 

to the GALL Report 

have been made.

cathodic prote

provide the eff

system and/or 

cathodic prote

installed less t

entering the pe

operation, then 

program will b

1065 XI.M41

ML102320585, 

Comment 

XI.M41-13

Element 4 Table 4a footnote 2 item D and 

Table 4c footnote 2 item D – Correct a typo to 

delete “at” in the second sentence so that it 

reads: “...operated in accordance with NACE 

SP0169-2007 for at less than 90%...”.

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

No technical b

incorporate thi

(typographical 

editorial in nat

1066 XI.M41

ML102320585, 

Comment 

XI.M41-14

Element 4 Table 4a footnote 2 item F – This 

preventive action category is confusing with 

criteria C, D and E in direct contradiction to 

each other. Is the intent of item F to specify 

coatings, backfill, and cathodic protection are 

not provided?

The staff disagrees 

with this comment 

and the GALL Report 

has not been 

changed.

The intent is if 

cannot be clas

D, or E, then t

F.

1067 XI.M41

ML102320585, 

Comment 

XI.M41-15

Element 4 Table 4a footnote 3.b and 3.c. and 

Table 4b footnote 2.b and 2.c.– Editorial 

changes

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

No technical b

incorporate thi

editorial in nat
April 2011 IV-175 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

1068 XI.M41

ML102320585, 

Comment 

XI.M41-16

Element 4 Table 4a footnote 5 and Table 4b 

footnote 4 – Revise to read “Hazmat pipe 

normally contains....”

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

No technical b

incorporate thi

editorial in nat

1069 XI.M41

ML102320585, 

Comment 

XI.M41-17

Element 4 Table 4a footnote 6. – Editorial 

changes

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

No technical b

incorporate thi

editorial in nat

1070 XI.M41

ML102320585, 

Comment 

XI.M41-18

Element 4 item c.iv – Delete volumetric 

examinations to detect internal corrosion. 

Internal aging management is performed by 

another AMP and is not part of the Buried and 

Underground Piping and Tanks AMP.

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

This program 

exterior of the 

programs are 

interior of the p

1071 XI.M41

ML102320585, 

Comment 

XI.M41-19

Element 4 item c.vii and item e.vi.– Delete this 

item. How can manual examinations be 

performed if the piping/tank is restricted 

access?

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

Manual exami

performed if th

restricted acce

1072 XI.M41

ML102320585, 

Comment 

XI.M41-20

Element 4 Table 4b footnote 2. – Delete 

excavations this footnote applies to 

underground pipe not buried pipe.

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

No technical b

incorporate thi

editorial in nat

1073 XI.M41

ML102320585, 

Comment 

Element 4 Table 4c footnote 4 & 5 and Table 

4d footnote 3 & 4 – Delete pipe this footnote 

applies to HDPE tanks.

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

No technical b

incorporate thi

editorial in nat
NUREG-1950 IV-176 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

XI.M41-21 have been made.

1074 XI.M41

ML102320585, 

Comment 

XI.M41-22

Element 4 item d.iv. and item e.iv. – If the tank 

is volumetrically inspected internally, the 

required number of inspection locations of the 

tank surface area should be limited to 22 

rather than requiring 90% of the surface of the 

tank.

Inspecting 22 locations will provide a 90/90 

assurance level (reference NUREG 1475 

Table T-8). Inspection of 90% provides no 

significant additional assurance level and has 

no basis.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Ninety percent 

engineering ju

statistically ba

1075 XI.M41

ML102320585, 

Comment 

XI.M41-23

Element 4 item f.iv. – Delete the requirement 

for doubling of the sample size and revise 

item f.iii. to require an evaluation of the 

degradation to determine extent and size of 

the expansion sample. Doubling of the sample 

size with no basis could likely result in 

unnecessary inspections depending on the 

cause of the degradation, may not be possible 

in many cases and in some cases doubling 

may not be enough.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Doubling of the 

considered ac

1076 XI.M41

ML102320585, 

Comment 

XI.M41-24

Element 6 item b – Currently the only 

inspector certification related to visual 

inspection of buried pipe coatings is NACE 

CIP (Coating Inspector Program Level III). 

There are no qualifications for buried piping 

coating inspections at this time. Recommend 

revising this item to include an equivalent 

qualified coatings inspector.

The staff disagrees 

with this comment. 

The GALL Report 

has not been

changed.

The NACE CIP 

coatings.
April 2011 IV-177 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

1077 XI.M41

ML102320585, 

Comment 

XI.M41-25

Element 4 item iii - Added that inspection 

locations should be selected based on risk 

instead of susceptibility to degradation to 

maintain some consistency with the Industry 

Initiative 09-14.

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

The staff agree

appropriate te

1078 XI.M41

ML102320585, 

Comment 

XI.M41-26

Table 4b inspections are excessive when 

compared to the inspections in 4a for hazmat 

piping. For example in 4b for steel 5% is 

required for hazmat underground and only 2% 

is required for buried coated hazmat steel 

piping in table 4a. The potential for corrosion 

of these components in an air environment is 

significantly less than soil if both are coated 

and there is no basis for the percentages 

shown for steel and copper and aluminum 

hazmat. Recommend deleting the Hazmat 

Column and let inspections for code class 

cover all piping without percentages. There is 

no basis for percentages. When the piping is 

contained in a vault or tunnel the risk is much 

lower for it to get in to the environment than 

buried components.

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

The staff agree

2 percent may 

has changed T

and 1 percent.

1155 XI.M41

ML102350027, 

Comment 1

Page 1, Section 1. Scope - Does the scope 

include non-essential systems like culverts, 

storm drains, sewer, potable water? NEI 09-

14 does. We have handled the buried pipe

data for more than a dozen nuclear sites. A 

two unit site can typically have 35-45 miles of 

total buried pipe, These non-essential 

systems can account for up to half the total

buried pipe mileage (15-20 miles). Based on 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

If an applicant 

Report impose

inspection req

exception to th

be proposed. T

GALL report is 

CFR 54 and n

buried piping w
NUREG-1950 IV-178 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

the inspection requirements presented in

Section 4, is it the intent of the NRC to require 

the excavation and inspection of 2-10%

(10,000 ft or more) of these systems?

Rule is addres

1157 XI.M41

ML102350027, 

Comment 2

Page 12, Section 2(e). Direct Inspection 

Underground Tanks - UG Tanks can include 

double wall designs. How can the OD be 

inspected on the inner tank? Could leak 

monitoring in the annular space be an 

approved approach?

The staff agrees with 

this comment and the 

associated changes 

to the GALL Report 

have been made.

The OD of a d

tank cannot be 

ID. Leak mon

approved appr

1158 XI.M41

ML102350027, 

Comment 3

Page 12, Section 4(b)(x)(B)(2)(C, D, E) – 

What is meant by “backfill in accordance with 

SP0169”? This standard does not provide 

criteria for backfill.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

SP0169-2007 

requirements f

Paragraph 5.2

1160 XI.M41

ML102350027, 

Comment 4

Page 13, Section 5. Monitoring and Trending - 

NACE SP0285 does not have the word “trend” 

in the document yet this section says to follow 

the approach in this standard.

This standard covers CP design, operation 

and maintenance activities. Similarly, SP0169 

does not address trending.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

While the stan

specifically use 

changes in cat

current require

which is a form 

1162 XI.M41

ML102350027, 

Comment 5

Page 14, Section 10. Operating Experience - 

It would be helpful if you also included in each 

case whether or not the site had an 

operational CP system.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

At this time, th

protection is n

required to be 

1079 XI.M41

ML102371274, 

Program Description - While corrosion from 

the outer surface of buried pipes may be the 

The staff disagrees 

with this comment. 

This AMP is de

reasonable as
April 2011 IV-179 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

Comment 

XI.M41-PW1

dominant failure mechanism, there have been 

failures from the inside (supply water system 

e.g., which simply are not adequately covered 

by other programs listed in paragraph. It 

makes no sense of excluding internal 

corrosion and verification of the effectiveness 

of alternate programs

The GALL Report 

has not been 

changed.

of the external 

or undergroun

adequately ma

AMPs, as indic

element, have 

adequacy in p

assurance tha

internal surfac

or tanks, whet

underground, 

managed.

1080 XI.M41

ML102371274, 

Comment 

XI.M41-PW2

Program Description

Opportunistic inspections should not be 

credited towards anything, rather they should 

be used to indicate and classify targeted 

examination. Absent from list are that there 

are no required, as there should be, 

inspections to establish the baseline

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

conditions needed to evaluate the 

effectiveness of the program in the future.

Opportunistic e

conducted whe

is exposed for 

Additional info

opportunistic i

found in parag

opportunistic i

replace a direc

when the cond

4.b.v are met. 

conditions, op

inspections pro

same informat

condition of pi

directed inspe

conditions, the 

reason not to p

inspections to 

the overall ins

Aging manage
NUREG-1950 IV-180 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

designed to m

the period of e

This AMP prov

baseline inform

that an inspec

performed dur

preceding the 

of extended op

inspection, con

portion of pipin

be of highest r

discovered, pr

assurance tha

buried or unde

tanks is adequ

entry into the p

operation. In th

degradation is 

inspection also 

information on 

and corrosion 

used in planni

inspections. G

damage to pip

excavation, a 

not justified wi

information reg

of degradation

1081 XI.M41

ML102371274, 

Comment 

Program Description - (1) The water chemistry 

program is a mitigation program and does not 

provide detection for aging effects. More 

The staff disagrees 

with this comment. 

The GALL Report 

(1) This AMP i

address the ex

buried or unde
April 2011 IV-181 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

XI.M41-PW3 frequent complete inspections as part of the 

overall program are the only effective 

assurance that defects created by aging 

components will be uncovered. Tritium leaks 

at reactors across the country belie the 

effectiveness of water chemistry alone to 

prevent leaks.

(2) More broadly, the NRC Groundwater 

Contamination (Tritium) at Nuclear PlantsTask Force – Final Report, Sept 1, 200[6]

studied radioactive leaks from a variety of 

sources. The LLTF stated in the Executive 

Summary ii, that, “The task force did identify 

that under the existing regulatory 

requirements the potential exists for 

unplanned and unmonitored releases of 

radioactive liquids to migrate offsite into the 

public domain undetected.”

has not been 

changed.

tanks. It conta

actions and an 

Effective aging 

obtained throu

of preventive a

supplemented 

inspections. T

program is des

corrosion from 

or tanks, whet

underground o

affect degrada

surfaces of bu

piping or tanks

pertinent to the 

AMP.

(2) The staff is 

groundwater c

and this finding

this AMP, as w

address degra

internal surfac

or structures, t

of these syste

components a

reasonable as

the current reg

their intended 

maintained du

extended oper

1083 XI.M41 Program Description The staff disagrees The term “inac
NUREG-1950 IV-182 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

ML102371274, 

Comment 

XI.M41-PW4

The terms “buried” and “underground” are 

fully defined in Chapter IX of the GALL 

Report. Briefly, buried piping and tanks are in 

direct contact with soil or concrete (e.g., a wall 

penetration). Underground piping and tanks 

are below grade, but are contained within a 

tunnel or vault such that they are in contact 

with air and are located where access for 

inspection is restricted: “Inaccessible Piping & 

Tanks ” would be a better term

with this comment. 

The GALL Report 

has not been 

changed.

not only to bur

piping or tanks 

tanks within a 

access is diffic

for these pipin

sufficiently diff

warrant a diffe

management p

1084 XI.M41

ML102371274, 

Comment 

XI.M41-PW5

Scope of Program - Add piping related to 

AOG system

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed. 

Systems, struc

components w

license renewa

CFR 54.4. Pre

systems, struc

components a

of license rene

plant to plant b

specific scopin

process. Depe

some portions 

may or may no

the potential fo

in scope at so

others, it is no

specifically me

the AMP.

1086 XI.M41

ML102371274, 

Comment 

Preventive Actions - “Periodic flow tests” 

should not provide a “pass.” It cannot detect 

leakage. Periodic is too loose, need specificity 

- what precisely does “periodic” mean in terms 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

Additional info

periodic flow te

paragraph 4.b

provides the te
April 2011 IV-183 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

XI.M41-PW6 of months/years?

Moreover a flow test can indicate that there is 

not a breach in the piping at the time of the 

test but it does not indicate the level of 

corrosion/degradation in the material, wall 

thickness etc or whether there will be a 

breach the day after the flow test.

changed. flow testing to 

in accordance 

24. It should b

standard perm

from brand ne

flow testing wi

leaks, it will en

intended funct

delivering suff

fires, is mainta

that leakage fr

presents no en

The frequency 

tests are perfo

ensure that ad

maintained ev

develop betwe

Additionally, p

maintained in 

through the us

Changes in joc

are monitored 

would initiate a

regarding the c

change.

1088 XI.M41

ML102371274, 

Comment 

XI.M41-PW7

Preventive Actions

“Table 2a, Preventive Actions for Buried 

Piping and Tanks:”

(1) Change to “Preventive Actions for 

Inaccessible Piping & Tanks

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

(1) Please see 

to comment 1

(2) Please see 

to comment 1

(3) The staff fi

of monitoring w
NUREG-1950 IV-184 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

(2) Add Baseline Inspection

(3) Also need detection capability-monitoring 

wells in sufficient number and placed 

according standard design practices, requires 

among other things recent subsurface hydrogeo analysis of site1

1 A well designed monitoring well system 

could pick up a leak relatively quickly - 

approximately within weeks or months after 

the initiation of a leak, depending on the rates 

of groundwater flow and other factors. 

Groundwater monitoring networks are widely 

used to detect leaks at a variety of nuclear 

and non-nuclear sites. Well-established 

protocols exist for proper design of monitoring 

networks including well and screen 

placement, sampling frequency and selection 

of sampled contaminants Sampling the wells 

is usually done about four times a year

the scope of th

54.29(a)(1) req

effects of agin

of extended op

A.1.2.3.4 of th

that, prior to th

intended funct

or structure, ag

responsible fo

detected. Sinc

serve only to id

intended funct

tanks, their inc

inappropriate. 

inclusion of mo

appropriate in 

aware of the u

wells and cont

their use.

1089 XI.M41

ML102371274, 

Comment 

XI.M41-PW8

Preventive Actions

(1) Titanium needs to be included in 

preventive measures. Titanium alloys, like 

other metals, are subject to corrosion in 

certain environments. The primary forms of 

corrosion that have been observed on these

alloys include general corrosion, crevice 

corrosion, anodic pitting, hydrogen damage, 

and SCC.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

(1) The staff a

certain environ

corrosive to tit

environments 

those that will 

buried pipe at 

plants. Preven

required for bu

1090 XI.M41

ML102371274,

Preventive Actions

NUREG/CR 6876 (Brookhaven) titanium 

The staff disagrees 

with this comment. 

The staff ackn

sufficient oper
April 2011 IV-185 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

Comment 

XI.M41-PW8(2)

subject fouling/biofouling. Why coat titanium?

Titanium’s corrosion resistance is 

compromised by exposure to halides such as 

chlorides or fluorides. Residual chlorides lead 

to SCC while fluorides readily attack the 

natural oxide that protects titanium from 

atmospheric corrosion. In addition, due to 

titanium’s extremely passive nature, when 

titanium components are in contact with more 

electrochemically active materials such as 

aluminum, zinc or copper, where the materials 

meet there is such a galvanic charge 

generated due to the dissimilar metal junction, 

galvanic corrosion is wildly accelerated 

beyond what either metal by itself would 

experience. 

http://www.finishing.com/Library/titanium.html 

(2) Polymer: High Density Polyethylene & 

High Density Polypropylene

The GALL Report 

has not been 

changed.

: We have been 

advised that there should be reluctance to use 

polymeric piping in hot service and there is a 

pressure limitation that depends (like in steel 

pipe) on the wall thickness; it should never be 

used either of the materials in organic service 

(buried diesel or fuel oil lines) even though 

organic fluids are routinely transported in 

polyethylene or polypropylene totes; and that 

there is reason for concern about long term 

embrittlement (and eventual cracking) if used 

in buried structures. Another type of problem 

with buried polymeric pipe is the fact that 

not yet availab

aspects of the 

buried or unde

tanks. As a res

includes inspe

materials. 

(2) Additionally

is paid to the c

polymeric pipin

fluids they con

review process

conditions, the 

is possible to p

assurance tha

function of pol

maintained du

extended oper

(3) The staff is 

cathodic prote

protection of s

concrete struc

those exposed 

concentrations 

containing salt

instances, the 

systems are u

retard the corr

the concrete. F

be successful, 

be electrically 

concrete and c
NUREG-1950 IV-186 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

when digging becomes necessary the 

polymeric pipe is cut that much more easily. If 

polymeric pipe(not really plastic pipe) are 

used for repairs, there are problems in the 

mating of steel pipes to polymeric ones. 

Bottom line, we are advised that there is not 

enough experience available to guarantee an 

additional 20 years of service.

(3) Cementitious or Concrete requires 

cathodic protection: The following summarizes 

the international development of cathodic 

protection of steel in concrete. The technology 

was developed in Europe and the USA for 

applications to buried prestressed concrete 

water pipelines (Refs. 1 & 2) and in California 

to deal with deicing salt attack of reinforced 

concrete bridge decks, and has been widely 

applied throughout North America for that 

purpose. It has been used and further 

developed in the UK to deal with a variety of 

problems ranging from buildings with cast in 

chlorides to bridge substructures 

contaminated with deicing salts and to marine 

structures and tunnels. It is also widely used 

on buildings and car parks in UK and Northern 

Europe. In the Middle East, severe corrosion 

problems caused by high levels of salinity in 

soils as well as marine conditions have lead to 

many large projects being carried out. It has 

also been used extensively in the Far East 

including Australia, Japan and Hong Kong. 

http://www.azom.com/details.asp?articleID=1

in nuclear pow

normally expo

chlorides that 

cathodic prote

most instances

steel in these 

not electrically 

the use of cath

technically unf

(4) The staff is 

called monel b

familiar with m

alloy of nickel 

bronze which 

of copper and 

be considered 

and 4. Should 

which the staff 

an applicant m

alternate prote

inspections.
April 2011 IV-187 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

316. There are numerous articles on line. 

(4) What about components within scope NOT 

made of materials listed, such as monel 

bronze?

1091 XI.M41

ML102371274, 

Comment 

XI.M41-PW9

Preventive Actions

4. Cathodic protection is in accordance with 

NACE SP0169-2007 or NACE RP0285- 2002. 

The system monitoring interval discussed in 

section 10.3 of NACE SP0169- 2007 may not 

be extended beyond one year. The equipment 

used to implement cathodic protection need 

not be 10 CFR 50 Appendix B qualified. 

[Emphasis added]”: 

Omit “The equipment used to implement 

cathodic protection need not be 10 CFR 50 

Appendix B qualified.” Rationale: Unless the 

rectifier (or any piece of equipment) was 

explicitly mentioned in the tech specs, its 

failure would be entered into the corrective 

action program but would not enter a limiting 

condition for operation with a deadline for 

fixing or shutting down

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Cathodic prote

serves an agin

function but do

immediate effe

operation of th

safety-related. 

established re

cathodic prote

part of this AM

question has b

AMP.

1093 XI.M41

ML102371274, 

Comment 

XI.M41-PW10

Preventive Actions

Cathodic protection need not be provided if

No exceptions, require as was original plan in 

Gall XI M-28 before NRC caved to bogus 

objections raised by NEI that retrofitting 

cathodic protection could be dangerous and 

then provided M34 as an alternative2

 

: 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The alternative

cathodic prote

soil resistivities

corrosion occu

all, and provis

2007, which de

for which catho

required for bu
NUREG-1950 IV-188 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

Gall XI M-28, focuses on adding cathodic 

protection. Pertinent portions of it say: 

Scope of Program: “The program relies on 

preventive measures, such as coating, 

wrapping, and cathodic protection, and 

surveillance, based on NACE Standard RP0285- 95 and NACE Standard RP-0169-96, to 

manage the effects of corrosion on the 

intended function of buried tanks and piping 

respectively.”

Preventive Actions: “A cathodic protection 

system is used to mitigate corrosion where 

pinholes in the coating allow the piping or 

components to be in contact with the 

aggressive soil environment. The cathodic 

protection imposes a current from an anode 

onto the pipe or tank to stop from corrosion 

from occurring at defects of the coating.” 

Detection of Aging Effects: “Coatings and 

wrappings can be damaged during installation 

or while in service and the cathodic protection 

system is relied upon to avoid any corrosion 

at the damaged locations. Degradation of the 

coatings and wrappings during service will 

result in the requirement for more current from 

the cathodic protection rectifier in order to 

maintain the proper cathodic protection 

protect potentials. Any increase in current 

requirements is an indication of coating and 

wrapping degradation. A close interval pipeto-soil potential survey can be used to locate 

and aluminum 
April 2011 IV-189 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

the locations where degradation has 

occurred.” 

Acceptance Criteria: “In accordance with 

accepted industry practice, per NACE 

Standard RP-0285-95 and NACE RP-0169-

96, the assessment of the condition of the 

coating and cathodic protection system is to 

be conducted on an annual basis and 

compared to predetermined values.”

Corrective Actions: The site corrective action 

program, QA procedures, site review and 

approval process, and the administrative 

controls are implemented in accordance with 

the requirements of 10 CFR Part 50, 

Appendix B. As discussed in the appendix of 

this report, the staff finds the requirements of 

10 CFR Part 50, Appendix B acceptable to 

address the corrective actions, confirmation 

process and administrative controls.”

Operating experience: “Corrosion pits from 

the outside diameter have been discovered in 

buried piping with far less than 60 years of 

operation. Buried pipe that is coated and 

cathodically protected is unaffected after 60 

years of service. Accordingly, operating 

experience from application of the NACE 

standards on non-nuclear systems 

demonstrates the effectiveness of this 

program.”

2 See: TRANSCRIPT ADJUDICATORY 

HEARING PILGRIM NUCLEAR POWER 
NUREG-1950 IV-190 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

STATION’S LICENSE RENEWAL 

APPLCIATION, April 10, 2008, pgs., 769-770; 

available NRC Electronic Reading Room 

(www.nrc.gov); ADAMS accession number 

“ML081070329”

1094 XI.M41

ML102371274, 

Comment 

XI.M41-PW11

Preventive Actions

a. Soil resistivities > 20,000 ohm cm. If this 

condition is met, inspections in Table 4a are 

conducted in accordance with Table 4a 

footnote 2 item C.:

(1) What does NACE SP0169-2007 say? We 

need a copy of the document. 

(2) Not knowing, it seems to need qualification 

regarding if area backfilled, excavated or soil 

conditions are known to have changedEntergy’s BPTIMP, pg.,11 made this notation

The staff agrees with 

this comment. The 

GALL Report has 

been changed.

AMP M41 has 

eliminate the p

Soil resistivitie

(1) NACE SP0

copyrighted pu

property of NA

The standard 

distributed by 

standard is av

by the general 

International. I

the availability 

1801, “Copies 

and standards 

substantive ma

regulatory proc

at the NRC Lib

Flint North, 11

Rockville, MD 

by the public.” 

NACE standar

members of th

appointment.

(2) The staff a

possible for so

change, espec
April 2011 IV-191 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

are conducted 

pipe. Under th

the staff would 

applicant woul

possibility that 

had changed a

necessary.

1096 XI.M41

ML102371274, 

Comment 

XI.M41-PW12

Preventive Actions

b. Corrosion rates, based on at least 5 years 

of data, which indicate that minimum design 

wall thickness for the buried pipe or tank will 

not be reached within the period of extended 

operation. The corrosion rates may be based 

on measurements taken from actual uncoated 

pipe or may be approximated for coated 

piping, which is assumed to contain flaws in 

the coating, from bare metal coupons of 

similar material exposed, on site, to soil of 

similar conditions (e.g., resistivity, ionic 

content, moisture content, etc). Multiple 

corrosion measurements are necessary when 

a length of pipe passes through varying soil 

types. If this condition is met, inspections in 

Table 4a are conducted in accordance with 

Table 4a footnote 2 item D. [Emphasis 

added]:

Omit this exception. The probability of 

corrosion is not constant with time and 

therefore cannot be characterized with a 

number and entered as such into a "Rule", 

like, if we established a rate based on 5 years 

The staff disagrees 

with this comment, 

however some 

changes to the GALL 

Report have been 

made. 

The staff has 

from the AMP

Removal of th

on the comple

it. The staff do

the commente

requesting the 

section. For a 

given soil, mea

rates are quite 

component life

that corrosion 

decrease with 

projection of m

rates almost a

component life

commenter’s r

tub curve” as a 

failures not ap

tub curve is us

of electronic co

have high failu

startup and at 
NUREG-1950 IV-192 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

of data, we can predict the rate going forward. 

First, the corrosion rate is NOT constant with 

time. Therefore, the probability would have to 

be adjusted with age, or the risk becomes a 

function of age

Corrosion of m

have either a h

or a sharp incr

end of their ex

. The so-called “Bath-tub curve 

of degradation” needs to be considered – as 

the component ages the rate sharply 

increases- the corrosion rate is not constant 

over time.

1098 XI.M41

ML102371274, 

Comment 

XI.M41-PW13

Preventive Actions

(i) Re particle size backfill? What does 

SP0169-2007 section 5.2.3 say- is max size 

1⁄2 inch as in previous draft? Crushed concrete 

of 1/2 inch diameter or less can be quite 

jagged and do much damage while river 

bottom pebbles may be harmless. Therefore 

the type of material as to its smoothness is 

relevant. 

Also absent from the discussion on backfill 

material was the degree to which the material 

retained moisture. (ii) Omit exception “Backfill 

not meeting this standard is acceptable if the 

inspections conducted in program element 4 

of this AMP do not reveal evidence of 

mechanical damage to pipe coatings due to 

the backfill:” 

Program element 4 does not provide 

assurance- see comments below on #4.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

SP0169-2007 

concept that th

backfill must b

objects and th

must not be da

installation. AS

discusses agg

distributions. T

cited in the AM

numerous spe

burial of pipe. 

Backfill moistu

affect soil resis

specifically co

The staff does 

comment. The 

value and pote

replacing back

been shown to 

pipe coatings.

1100 XI.M41 Preventive Actions The staff disagrees ASTM D 448-0
April 2011 IV-193 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

ML102371274, 

Comment 

XI.M41-PW14

6. Aggregate size for backfill within 6 inches of 

the pipe must meet ASTM D 448-08 size 

number 10:

Define – data base not available on line

with this comment. 

The GALL Report 

has not been 

changed.

aggregate size 

size distributio

based on num

for the burial o

ASTM D 448-0

publication tha

ASTM Internat

distributed by 

available for p

general public 

International.

1102 XI.M41

ML102371274, 

Comment 

XI.M41-PW15

Preventive Actions

7. Backfill limits apply only if piping is coated:

Omit exception – for example, abrasion 

ignored

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The staff does 

comment. The 

credible evide

concept that b

through a meta

is not subject t

1103 XI.M41

ML102371274, 

Comment 

XI.M41-PW16

Preventive Actions

8. Super austenitic stainless steel, e.g., Al6XN 

or 254 SMO. Superaustenitic stainless steels, 

such as alloy AL-6XN and 254SMO, exhibit 

great resistance to chloride pitting and crevice 

corrosion due to high molybdenum

Omit exception- stray currents ignored, for 

example 

content 

(>6%) and nitrogen additions, and the higher 

nickel content ensures better resistance to 

stress-corrosion cracking versus the 300 

series:

Table 2b footnote 4 - Coating preventive

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Footnote 8 doe

exception; it is 

of super auste

The staff presu

commenter is 

super austenit

will be corrode

from cathodic 

The staff notes 

protection syst

as systems an

all piping and o

current, wheth

protected or no
NUREG-1950 IV-194 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

action - MIC may be issue for super austenitic 

steel AI6XN 

http://www.alleghenyludlum.com/Ludlum/docu

ments/AL_6XN_SourceBook.pdf

corrosion of su

stainless steel 

therefore, of lit

The staff agree

conceivable th

super austenit

finds the risk a

to be sufficient

merit the appli

1105 XI.M41

ML102371274, 

Comment 

XI.M41-PW17

Parameters Monitored/Inspected – 

(1) UT not work if piping is multi-layered such 

as having a CIP liner in the pipe paragraph 

needs to be qualified for conditions effective; 

(2) need to state how much of the component 

needs to be examined and precisely where on 

the component – some areas more 

susceptible to degradation – elbows, welds, 

high flow areas for example

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

This program 

the aging effec

AMP and the i

techniques uti

Specifics conc

techniques are 

in the Detectio

program elem

is referred to t

concerning sp

inspection. Th

external UT in

loss of materia

when an intern

The precise lo

systems that a

a plant-specific 

4.b.3 and 4.c.3 

examine piping 

risk. These pa

example” lists 

considered. Th
April 2011 IV-195 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

the comment a

common issue

the term “flow 

mentioned in t

1106 XI.M41

ML102371274, 

Comment 

XI.M41-PW18

Parameters Monitored/Inspected 

Pipe to soil potential? What about 

conduits/other containment for the piping if 

they are degraded, the pipe inside could be 

sitting in water, for example?

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The staff assu

comment refer

Issues related 

addressed in t

1107 XI.M41

ML102371274, 

Comment 

XI.M41-PW19

Detection of Aging Effects 

Need to include additional variables such as 

age component, flow velocity (FAC), repair 

history

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Flow accelerat

addressed by 

Age of a comp

its degradation

component is 

corrosivity of t

material of con

effectiveness o

actions. Repai

significance bu

component tha

replaced in kin

The staff has n

evidence to su

conclusion.

1108 XI.M41

ML102371274, 

Comment 

XI.M41-PW20

Detection of Aging Effects

Opportunistic Inspections - (1) Opportunistic 

typically means that there has been a leak 

that needs to be repaired. Visual inspection is 

"stone age technology" There has to be a 

decision of how much more pipe to excavate 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

(1) The staff d

comment. The

between oppo

and leaks. Op

inspections are 

number of rea
NUREG-1950 IV-196 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

and at least conduct some quantitative 

examinations. 

(2) What if pipe does not become accessible 

for any reason?

include activiti

maintenance o

is located clos

tank. Informati

extent of inspe

quantitative ex

provided in thi

of the AMP.

(2) If a pipe is 

for an opportu

directed inspe

with Tables 4a

1109 XI.M41

ML102371274, 

Comment 

XI.M41-PW21

Detection of Aging Effects – 

(i) Directed Inspections for buried piping are 

conducted in accordance with Table 4a and 

its accompanying footnotes.

See comments on Table 4a’s footnotes

Not needed. The staff notes 

will address sp

bases for the c

comments on 

1110 XI.M41

ML102371274, 

Comment 

XI.M41-PW22

Detection of Aging Effects

Directed Inspections – Buried Pipe - What 

evidence is there to justify a 10 year interval? 

This is the crux. One simply cannot squeeze 

all these situations into the same shoe box. 10 

years is too infrequent period – especially in 

license renewal when components may well 

be entering the “wear-out” stage (Region C) of 

the Bath Tub Curve of degradation. Inspection 

frequencies need to be based on age.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The 10-year in

consistent with 

contained in A

XI. As discuss

response to C

use of the bath 

is inappropriat

components s

tanks. For con

than optimal, t

to increase the 

rather than the 

inspections. In
April 2011 IV-197 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

extent or frequ

the same goal

The staff finds 

reference to th

as a model for 

not applicable

is used to pred

electronic com

high failure rat

at end of life. 

in soils do not 

initial failure ra

increase in fai

their expected 

1111 XI.M41

ML102371274, 

Comment 

XI.M41-PW23

Detection of Aging Effects

(1) If in fact there are various degrees of 

susceptibility, there should also be varying 

degrees of inspection frequencies.

(2) need a more precise and complete listing 

of locations more susceptible to degradation – 

absent from list, for example, are age 

component, flow rate, elbows, welds

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

(1) See the sta

comment 1110

inspection inte

with most insp

ASME Code S

discussed in th

comment 1110

tub curve conc

for passive co

piping or tanks

are less than o

chosen to incr

inspection rath

frequency of in

Increasing eith

frequency will 

same goal.
NUREG-1950 IV-198 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

(2) Please see 

for Comment 1

location of pip

of highest risk 

issue. Paragra

direct applican

that is of highe

paragraphs pr

lists of issues 

The issues rai

are relatively c

associated wit

characteristics

AMP.

1113 XI.M41

ML102371274, 

Comment 

XI.M41-PW24

Detection of Aging Effects

iv. Visual inspections are supplemented with 

surface and/or volumetric non-destructive 

testing (NDT) if significant indications are 

observed:

“Significant” needs to be defined

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

“Significant” is 

described in p

1134 XI.M41

ML102371274, 

Comment 

XI.M41-PW25

Detection of Aging Effects

v. Opportunistic examinations may be credited 

toward these direct examinations if the 

location selection criteria in item iii, above, are 

met:

Omit - not all factors related to corrosion listed 

in iii and no specification of length component 

requiring inspection- if, for example, they had 

an “opportunity” to inspect a 1 foot section of 

a pipe’s coating it does not mean that the 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Opportunistic 

meet the criter

inspections. T

of an inspectio

inspection is 1

locations are s

the highest ris

words, if an op

inspection is c

inspection, the 
April 2011 IV-199 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

remaining feet of the pipe are in the same 

condition

expected to be 

than that whic

1115 XI.M41

ML102371274, 

Comment 

XI.M41-PW26

Detection of Aging Effects 

vi. At multi-unit sites, individual inspections of 

shared piping may be credited for only one 

unit:

The issue is the quality and frequency of the 

inspection of the pipe not what unit the pipe(s) 

belong

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed. 

At sites which 

nuclear power 

such as fire m

common to all 

indicates that 

conducted on 

may be credite

units.

1116 XI.M41

ML102371274, 

Comment 

XI.M41-PW27

Detection of Aging Effects 

vii. Visual inspections for polymeric materials 

are augmented with manual examinations to 

detect hardening, softening or other changes 

in material properties:

This makes no sense. What does manual 

examination tell you about the embrittlement 

of the pipe.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed. 

Manual exami

valuable for ch

of elastomeric 

polymeric mat

examinations 

softening, swe

embrittlement 

material.

1117 XI.M41

ML102371274, 

Comment 

XI.M41-PW28

Detection of Aging Effects 

Flow test [does] not tell degree degradationwall thickness- it can detect hole at time of 

test not what will happen an hour or 5 months 

later. Flow tests will NOT test any leak unless 

it is >15% above the nominal flow through the 

pipe.

The staff disagrees 

with this comment.

The GALL Report 

has not been 

changed. 

Flow tests are 

The purpose o

verify that the 

of delivering s

sufficient press

The frequency 

assures that m

intended funct

between tests

main pressure 

through the us

Jockey pump a
NUREG-1950 IV-200 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

by the power p

jockey pump a

investigation a

1118 XI.M41

ML102371274, 

Comment 

XI.M41-PW29

Detection of Aging Effects 

x. Inspection as indicated in (A), and (B) 

below may be performed in lieu of the 

inspections contained in Table 4a for either 

code class/safety significant or hazmat piping 

or both:

“at least 25%” – specifics as to 25% need to 

be provided so that they are representative 

age component, configuration etc

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Please see the 

comment 1105

The precise lo

systems that a

a plant-specific 

4.b.3 and 4.c.3 

examine piping 

risk. These pa

example” lists 

considered. Th

the comment a

common issue

the term “flow 

mentioned in t

1120 XI.M41

ML102371274, 

Comment 

XI.M41-PW30

Detection of Aging Effects 

Monel Bronze is used for some buried

comments- is it covered by the program and 

more broadly what other materials may be not 

in list?

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Please see the 

comment 1090

The staff is un

called monel b

familiar with m

alloy of nickel 

bronze which 

of copper and 

be considered 

and 4. Should 

which the staff 

an applicant m

alternate prote
April 2011 IV-201 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

inspections.

1121 XI.M41

ML102371274, 

Comment 

XI.M41-PW31

Detection of Aging Effects 

NACE SP0169-2007 needs to be provided in 

appendix – not available on line to nonmember

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

NACE SP0169

copyrighted pu

property of NA

The standard 

distributed by 

standard is av

by the general 

International. I

the availability 

1801, “Copies 

and standards 

substantive ma

regulatory proc

at the NRC Lib

Flint North, 11

Rockville, MD 

by the public.” 

NACE standar

members of th

appointment.

1122 XI.M41

ML102371274, 

Comment 

XI.M41-PW32

Detection of Aging Effects 

Guidance has no enforcement – we need 

enforceable regulations

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The GALL Rep

regulation. AM

consistent with 

are considered 

acceptable me

aging. Applica

propose altern

contained in th
NUREG-1950 IV-202 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

1124 XI.M41

ML102371274, 

Comment 

XI.M41-PW33

Detection of Aging Effects 

(3a-3c): On what basis can NRC assume that 

10 feet inspected, for example, represents the 

conditions in the remainder of the 

component? It would make more sense to 

require more frequent and more 

comprehensive inspections. Specifically a 100 

percent internal visual inspection of all 

underground pipes must be implemented. The 

inspection cycle should be such that pipes 

within scope are inspected every ten years. 

The Applicant should be required to break the 

testing interval down such that one sixth of all 

pipes are inspected during each refueling 

outage. (This assumes 18 month refueling 

outages, or six every ten years.) The 

Applicant should be required to inspect one 

sixth of the lineal piping, one sixth of the 

elbows and flanges at each outage, even if 

such inspections lengthen the outage time

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

There is some 

excavation of 

inspection of 1

is not justified 

evidence of th

Paragraph 4.b

inspections be 

locations of hig

pipe not inspe

considered to 

than that whic

1190 XI.M41

ML102371274, 

Comment 

XI.M41-PW34

Detection of Aging Effects 

(1) “To be considered hazmat, the 

concentration of radioisotopes within the pipe 

during normal operation must exceed 

established standards such as EPA drinking 

water standard” makes no sense. Some 

radioisotopes have long lives so that if the 

usually concentration during normal 

operations does not exceed established 

standards but the component is leaking 

undetected than the amount leaked could well 

The GALL Report 

has not been 

changed.

The NRC is ac

the issue of lea

the groundwat

two NRC Less

Forces in this 

proposed chan

Environmenta

for License Re

Plants to addre

of the license 

environmental 
April 2011 IV-203 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

exceed established standards – the 

cumulative effect must be covered. 

(2) What about abnormal circumstances?

1127 XI.M41

L102371274, 

Comment 

XI.M41-PW35

Detection of Aging Effects 

6. Only 1 inspection is conducted even if both 

Code Class/safety related and hazmat pipe 

are present:”

Only 1 inspection is insufficient – it appears 

NRC priorities are reversed – public safety 

should be the priority not industry 

convenience.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Based on the 

and/or the pre

place, only min

deemed neces

is to conduct o

either hazmat 

related piping, 

higher risk.

1130 XI.M41

ML102371274, 

Comment 

XI.M41-PW36

Detection of Aging Effects 

Direct Inspections – Underground Pipe - see 

comments Table 4b and accompanying 

footnotes

See subsequent 

comments. 

Please see sta

subsequent co

1131 XI.M41

ML102371274, 

Comment 

XI.M41-PW37

Detection of Aging Effects 

i. Unless otherwise indicated, directed 

inspections as indicated in Table 4b will be 

conducted during each 10 year period 

beginning 10 years prior to the entry into the 

period of extended operation:

10 years too infrequent

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Please see sta

comment PW2

1110).The 10-

interval is cons

inspections co

Code Section 

the staff respo

1096, the use 

concept is inap

passive compo

piping or tanks

are less than o

chosen to incr
NUREG-1950 IV-204 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

inspection rath

frequency of in

Increasing eith

frequency will 

same goal.

1132 XI.M41

ML102371274, 

Comment 

XI.M41-PW38

Detection of Aging Effects 

iii. Inspection locations are selected based on 

susceptibility to degradation. Characteristics 

such as coating type, coating condition, exact 

external environment, and flow characteristics 

within the pipe, are considered:

More characteristics need to be listed – such 

as age, history repair

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Please see sta

comment 1105

The precise lo

systems that a

a plant-specific 

4.b.3 and 4.c.3 

examine piping 

risk. These pa

example” lists 

considered. Th

the comment a

common issue

the term “flow 

mentioned in t

1133 XI.M41

ML102371274, 

Comment 

XI.M41-PW39

Detection of Aging Effects 

iv. Underground pipes are inspected visually 

to detect external corrosion and by a 

volumetric technique such as UT to detect 

internal corrosion:

UT detects both internal and external 

corrosion – separation is tricky but can be 

done.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

It is not the int

utilize UT mea

distinguish bet

external corros

underground p

visually and vo

examined from 

surface. The v

detect externa

volumetric exa

remaining wal

on the assump
April 2011 IV-205 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

preventive act

thickness shou

corrosion.

1114 XI.M41

ML102371274, 

Comment 

XI.M41-PW40

Detection of Aging Effects 

v. Opportunistic examinations may be credited 

toward these direct examinations if the 

location selection criteria in item iii, above, are 

met:

Omit- explained above

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Please see sta

comment 113

Opportunistic 

meet the criter

inspections. T

of an inspectio

inspection is 1

locations are s

the highest ris

words, if an op

inspection is c

inspection, the 

expected to be 

than that whic

1135 XI.M41

ML102371274, 

Comment 

XI.M41-PW41

Detection of Aging Effects 

vi. At multi-unit sites, individual inspections of 

shared piping may be credited for only one 

unit:

This makes no sense. Is it the pipe or site?

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

At sites which 

nuclear power 

such as fire m

common to all 

indicates that 

conducted on 

may be credite

units.

1136 XI.M41

ML102371274, 

Comment 

XI.M41-PW42

Detection of Aging Effects 

vii. Visual inspections for polymeric materials 

are augmented with manual examinations to 

detect hardening, softening or other changes 

in material properties:

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Please see the 

comment 111

Manual exami

valuable for ch

of elastomeric 
NUREG-1950 IV-206 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

This makes no sense. What does manual 

examination tell you about the embrittlement 

of the pipe

polymeric mat

examinations 

softening, swe

embrittlement 

material.

1137 XI.M41

ML102371274, 

Comment 

XI.M41-PW43

Detection of Aging Effects 

Flow test not tell degree degradation- wall 

thickness- it can detect hole at time of test not 

what will happen an hour or 5 months later. 

Piping integrity is the main issue and flow test 

does nothing to identify integrity.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Please see the 

comment 111

Flow tests are 

The purpose o

verify that the 

of delivering s

sufficient press

The frequency 

assures that m

intended funct

between tests

main pressure 

through the us

Jockey pump a

by the power p

jockey pump a

investigation a

1138 XI.M41

ML102371274, 

Comment 

XI.M41-PW44

Detection of Aging Effects 

x. Inspection as indicated in (A), and (B) 

below may be performed in lieu of the 

inspections contained in Table 4a for either 

code class/safety significant or hazmat piping 

or both:

“at least 25%” – specifics as to 25% need to 

be provided so that they are representative 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Please see the 

comment 110

The precise lo

systems that a

a plant-specific 

4.b.3 and 4.c.3 

examine piping 

risk. These pa
April 2011 IV-207 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

age component, configuration etc example” lists 

considered. Th

the comment a

common issue

the term “flow 

mentioned in t

1139 XI.M41

ML102371274, 

Comment 

XI.M41-PW45

Detection of Aging Effects 

Table 4b, Inspections of Underground Pipe - 

Where do these numbers come from? Is there 

any evidence that 2% is statistically the 

correct number? Provide rationale in footnote.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The extent of i

in this table is 

based. The ins

represent the s

judgment as to 

which must be 

provide reason

the intended fu

system is main

period of exten

1140 XI.M41

ML102371274, 

Comment 

XI.M41-PW46

Detection of Aging Effects 

Directed Inspections – Buried Tanks - Tanks 

must include partially buried tanks such as 

SFP, CST and the drywell (it is a partially 

buried tank and the SFP is encased below in 

concrete); and see comments on Table 4C’s 

footnotes

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Buried portion

substantially b

this program. I

of tanks which 

above ground 

Above Ground 

Accessible po

these types of 

by the externa

AMP. Structur

fuel pool and t

tanks. These s

covered by the 

monitoring pro

storage tanks 
NUREG-1950 IV-208 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

considered ab

1141 XI.M41

ML102371274, 

Comment 

XI.M41-PW47

Detection of Aging Effects 

What evidence is there to justify a 10 year 

interval. This is the crux. One simply cannot 

squeeze all these situations into the same 

shoe box. 10 years is too infrequent period – 

especially in license renewal when 

components may well be entering the “wearout” stage (Region C) of the Bath Tub Curve 

of degradation.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Please see sta

comment 111

The 10-year in

consistent with 

contained in A

XI. As discuss

response to co

of the bath tub 

inappropriate f

components s

tanks. For con

than optimal, t

to increase the 

rather than the 

inspections. In

extent or frequ

the same goal

The staff finds 

reference to th

as a model for 

not applicable

is used to pred

electronic com

high failure rat

at end of life. 

in soils do not 

initial failure ra

increase in fai

their expected 
April 2011 IV-209 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

1142 XI.M41

ML102371274, 

Comment 

XI.M41-PW48

Detection of Aging Effects 

(1) UT can inspect both external and internal 

(2) inspecting 25% one time in 10 years 

inadequate; as suggested for buried piping, 

specifically a 100 percent external visual 

inspection of tanks within scope must be 

implemented. The inspection cycle should be 

such that the whole tank is inspected every 

ten years. The Applicant should be required to 

break the testing interval down such that one 

sixth of the tanks surface is inspected during 

each refueling outage. (This assumes 18 

month refueling outages, or six every ten 

years.)

The staff partially 

disagrees with this 

comment. The GALL 

Report has not been 

changed.

(1) This AMP p

aging effects w

external surfac

underground p

tank is excava

from the exter

required to det

aging. Alternat

examined from 

required to det

external surfac

of the interior o

considered by 

(which AMP is 

the contents o

(2) There is so

with excavatio

The inspection 

tank is not just

evidence of th

1144 XI.M41

ML102371274, 

comment 

XI.M41-PW49

Detection of Aging Effects 

v. Visual inspections for polymeric materials 

are augmented with manual examinations to 

detect hardening, softening or other changes 

in material properties:

This makes no sense. What does manual 

examination tell you about the embrittlement.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Please see sta

comment 1116

examination is 

for changes in 

elastomeric m

polymeric mat

examinations 

softening, swe

embrittlement 

material.
NUREG-1950 IV-210 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

1145 XI.M41

ML102371274, 

Comment 

XI.M41-PW50

Detection of Aging Effects 

vi. Opportunistic examinations may be 

credited toward these direct examinations:

Opportunistic examinations should not be 

credited toward anything, rather they should 

be used to indicate and classify targeted 

examination.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Please see sta

comment 108

Opportunistic e

conducted whe

is exposed for 

Additional info

opportunistic i

found in parag

opportunistic i

replace a direc

when the cond

4.b.v are met. 

conditions, op

inspections pro

same informat

condition of pi

directed inspe

conditions, the 

reason not to p

inspections to 

the overall ins

1147 XI.M41

ML102371274, 

Comment 

XI.M41-PW51

Detection of Aging Effects 

NACE RP0285-2002-provide copy

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

NACE RP0285

copyrighted pu

property of NA

The standard 

distributed by 

standard is av

by the general 

International. I

the availability 

1801, “Copies 
April 2011 IV-211 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

and standards 

substantive ma

regulatory proc

at the NRC Lib

Flint North, 11

Rockville, MD 

by the public.” 

NACE standar

members of th

appointment.

1148 XI.M41

ML102371274, 

Comment 

XI.M41-PW52

Acceptance Criteria

that “no evidence of coating degradation” be 

determined by a “NACE certified inspector” – 

inspector’s judgment calls vary all over the 

map, absent specific criteria by NRC this is 

not an acceptable way to provide reasonable 

assurance.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Inspectors trai

and assess the 

indications on 

the best positio

condition of a 

staff also note

inspectors are 

purpose in ass

of coatings on 

transmission p

1149 XI.M41

ML102371274, 

Comment 

XI.M41-PW53

Acceptance Criteria

The goal is to prevent leakage not wait until 

leaking to fix.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Some damage 

of concrete an

piping may occ

installation. Un

reinforcing ma

a result of this 

of damage is n

Therefore, if st

and leakage is 

probability of a 
NUREG-1950 IV-212 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

the damaged l

than a leak oc

location. As a 

need for furthe

this type of da

1150 XI.M41

ML102371274, 

Comment 

XI.M41-PW54

Corrective Actions

Looking at the list of outstanding corrective 

actions at reactors today that NRC has NOT 

looked at – what assurance is provided?

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The scope of t

contained in th

limited to the t

the AMP to wh

pertains. This 

plant-specific c

response to th

require an eva

outstanding co

a plant-by-plan

to whether the

demonstrate a 

that aging is b

managed at ea

1151 XI.M41

ML102371274, 

Comment 

XI.M41-PW55

Operating Experience

Operating experience demonstrates that what 

is needed are NRC regulations that are 

enforced; not voluntary industry initiatives and 

NRC “guidance.”

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The scope of t

contained in th

limited to the t

the AMP to wh

pertains. This 

the need for N

comments on 

This comment 

the content of 

1232 XI.M41

ML102371265,

What is the regulatory authority of a NUREG? No changes to the 

GALL Report have 

The GALL Rep

which, in the o
April 2011 IV-213 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

Comment 

XI.M41-1(b)

been made in 

response to this 

question. 

represent one 

manage aging 

structure, or co

constructed of 

materials and 

environment. I

proposes to m

components in 

consistent with 

the staff will co

approach acce

the GALL Rep

regulation. Ap

propose altern

manage aging

evaluate altern

1203 XI.M41

ML102371265, 

Comment 

XI.M41-1(c)

Will this AMP be applicable for those plants 

that have received an extended license?

No changes to the 

GALL Report have 

been made in 

response to this 

question. 

The scope of t

contained in th

limited to the t

the AMP to wh

pertains. This 

determination 

the GALL Rep

be applied. Su

beyond the sc

1950. 

1204 XI.M41

ML102371265, 

Comment 

XI.M41-1(d)

Brian Holian confirmed during this meeting 

this AMP will this be applicable to plants 

presently under review. Can the NRC take 

any enforcement action if a licensee fails to 

meet the guidance of this NUREG?

The staff agrees with 

this comment. 

However, no changes 

to the GALL Report 

have been made.

The scope of t

contained in th

limited to the t

the AMP to wh

pertains. This 
NUREG-1950 IV-214 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

determination 

the GALL Rep

be applied. Su

beyond the sc

1950. 

1205 XI.M41

ML102371265, 

Comment 

XI.M41-1(e)

Other sites such as Indian Point contain (3) 

700# natural gas lines ranging in size from 26 

to 30 inches in diameter. Are the natural gas 

pipes buried on the Indian Point site pipes 

covered by this proposed program?

No changes to the 

GALL Report have 

been made in 

response to this 

question. 

This AMP cove

underground p

scope for licen

determination 

natural gas pip

commenter ref

license renewa

particular plan

scope of this d

1206 XI.M41

ML102371265, 

Comment 

XI.M41-1(f)

Are there sites other than IP that have pipes 

containing hazardous materials not under the 

direct control of the licensee?

No changes to the 

GALL Report have 

been made in 

response to this 

question.

The scope of t

contained in th

limited to the t

the AMP to wh

pertains. This 

information co

specific piping 

Such a respon

scope of this d

1152 XI.M41

ML102371265, 

Comment 

XI.M41-1(a)

This is a proposed revision to NUREG 1801 

(GALL). 

This is a very positive step in that:

1. It covers pipes and tanks other than steel 

and includes all pipe and tank materials. 

2. It covers tanks and pipes that may contain 

radioactive liquids in excess of EPA drinking 

The staff agrees with 

this comment. 

However, no changes 

to the GALL Report 

have been made.

This comment 

fact and there 

technical basis 

comment.
April 2011 IV-215 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

water limits.

3. It covers buried portions of partially piping 

systems and partially buried tanks such as 

CST, Waste tanks, RWST’s Spent Fuel Pools, 

fuel transfer canals, refueling cavities and 

containments and drywells.

1153 XI.M41

ML102371265, 

Comment 

XI.M41-2(a)

Service Water Piping

(1) Does this program apply to service water 

systems where the majority of the piping is 

buried [?]. 

(2) At lease two plants, in response to GL 89-

13 have excluded the buried portions of the 

SW systems and the NRC has accepted 

these positions. 

No changes to the 

GALL Report have 

been made in 

response to this 

question .

(1) This AMP i

external surfac

underground p

buried portions 

scope for licen

(2) GL 89-13 a

Cooling Water 

(XI.M20) addre

occurs from th

meeting the de

cycle cooling w

AMP primarily 

degradation of 

buried or unde

tanks. Depend

configuration, 

89-13 and the 

Water System 

not be related 

this AMP.

1207 XI.M41

ML102371265, 

Comment 

XI.M41-2(b)

XI.M20 only requires inspection of "lined or 

coated" SW pipes. (See Seabrook LRA) Will 

this AMP supersede M20?

No changes to the 

GALL Report have 

been made in 

response to this 

AMP XI.M20 a

and other issu

inside of piping 

not be buried o
NUREG-1950 IV-216 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

question. AMP addresse

occurring prim

external surfac

underground p

areas of applic

XI.M20 and th

essentially mu

AMP does not 

1208 XI.M41

ML102371265, 

Comment 

XI.M41-2(c)

Review of responses and many LRAs, there 

are no requirements for internal and/or 

external inspections of the SW piping systems 

and branch lines. Which AMP assures the 

integrity of the SW systems in all nuclear 

plants?

, No changes to the 

GALL Report have 

been made in 

response to this 

question.

This AMP prim

degradation oc

external surfac

underground p

Service water 

meet the defin

cooling water. 

GL 89-13 and 

“Open-Cycle C

System.” The 

buried or unde

water piping sy

subject of this 

that service wa

plant are withi

license renewa

for aging mana

external surfac

system are co

1209 XI.M41

ML102371265, 

Comment 

What are the specific requirements for the 

inspections of buried SW systems that have 

experienced numerous internal corrosion 

failures and in some cases, required the 

No changes to the 

GALL Report have 

been made in 

response to this 

The scope of t

contained in th

limited to the t

the AMP to wh
April 2011 IV-217 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

XI.M41-2(d) replacement of the majority of service water 

piping [?]

question. pertains. This 

plant-specific i

concerning ins

requirements.

1231 XI.M41

ML102371265, 

Comment 

XI.M41-3(a)

Why only external surfaces only? Many pipes 

have failed due to internal mechanisms, From 

my years at Millstone, Indian Point and Maine 

Yankee, Connecticut Yankee and recent 

tritium leaks at Vermont Yankee I recall 

numerous internal failures of piping systems 

within the scope of 10 CFR 54.4. or containing 

HAZMAT as defined within. 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The staff is als

piping at seve

the result of lo

the internal su

which may or 

for license ren

the program d

XI.M41 identifi

could be used 

surfaces of bu

1210 XI.M41

ML102371265, 

Comment 

XI.M41-3(b)

The environment and chemistry on the 

external surfaces remains fairly stable 

however the internal surfaces are exposed to 

a wide range of temperature and chemistry. 

(i.e., service water), potentially more 

destructive than the external environments.

The staff agrees with 

the comment, 

however no changes

have been made to 

the GALL Report.

The staff subs

this comment. 

that this AMP 

degradation of 

surfaces of pip

commenter ind

stable and less 

Internal surfac

addressed by 

Open-Cycle C

(XI.M20).

1211 XI.M41

ML102371265, 

Comment 

XI.M41-3(c)

MIC is one form of severe internal corrosion 

that has internally degraded many nuclear 

piping systems yet this is not being addressed 

in this program.

The staff disagrees 

with this comment. 

No changes to the 

GALL Report have 

been made.

This AMP prim

external surfac

subject of MIC

internal surfac

addressed by 
NUREG-1950 IV-218 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

Cooling Water 

Treated Water 

Inspection of I

Miscellaneous 

Components a

programs.

1212 XI.M41

ML102371265, 

Comment 

XI.M41-3(d)

There have been numerous reported failures 

of internal coatings of nuclear plant systems 

and internal erosion and cracking.

The staff agrees with 

this comment. The 

GALL Report has not 

been changed.

This AMP prim

external surfac

subjects of coa

erosion, and c

relate to the in

pipes, are add

Cycle Cooling 

Closed Treate

and Inspection 

in Miscellaneo

Ducting Comp

management p

1213 XI.M41

ML102371265, 

Comment 

XI.M41-3(e)

Why are these failure mechanisms not 

addressed in this proposed program?

The GALL Report 

has not been 

changed in response 

to this question. 

Failure mecha

from the inside 

covered by thi

they are addre

programs whic

degradation m

originate on th

tanks.

1214 XI.M41

ML102371265, 

Comment 

XI.M41-3(f)

This program must be modified to address 

internal corrosion which is the most common 

failure mechanisms

The staff disagrees 

with this comment. 

No changes to the 

GALL Report have 

The staff belie

corrosion issue

addressed by 

does not inten
April 2011 IV-219 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

been made. issues in this A

1156 XI.M41

ML102371265, 

Comment 

XI.M41-4(a)

Is cathodic protection required by any NRC 

regulation?

No changes to the 

GALL Report have 

been made in 

response to this 

question.

Cathodic prote

by NRC regula

1215 XI.M41

ML102371265, 

Comment 

XI.M41-4(b)

Will the NRC require CP for buried pipes? No changes to the 

GALL Report have 

been made in 

response to this 

question.

It is the staff’s 

preventive act

of coatings, ins

protection, and 

backfill, are an 

comprehensiv

managing the 

surfaces of bu

underground p

during the agin

review process

determines tha

piping and tan

the preventive 

the staff would 

applicant woul

take action to 

preventive act

period of exten

take an excep

provide a thoro

justification for 

1216 XI.M41 How does the NRC plan to verify that present No changes to the Backfill quality 
NUREG-1950 IV-220 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

ML102371265, 

Comment 

XI.M41-4(c)

backfill meets the requirements of this 

proposed AMP? See RCA report for Indian 

Point pipe failure of February 2009 where the 

cause was attributed to backfill.

GALL Report have 

been made in 

response to this 

question.

by applicants t

investigations 

NRC. The staf

associated wit

coating attribu

Indian Point.

1159 XI.M41

ML102371265,

Comment 

XI.M41-5(a)

Term not defined. Does this mean the pipes 

will only be inspected after failure?

The staff disagrees 

with this comment. 

No changes to the 

GALL Report have 

been made.

The term “opp

is functionally 

4.a.i, “All burie

piping and tan

their material o

inspected by v

whenever they 

for any reason

definition is no

1217

failures. Oppo

are conducted 

tank is uncove

such as mainte

or any adjacen

component.

XI.M41

ML102371265, 

Comment 

XI.M41-5(b)

Are there other "Opportunistic" opportunities 

other than actual pipe failures or leaks?

The GALL Report 

has not been 

changed in response 

to this question.

In answer to th

“opportunistic 

functionally de

4.a.i; “All burie

piping and tan

their material o

inspected by v

whenever they 

for any reason

definition is no
April 2011 IV-221 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

Opportunistic 

conducted whe

is uncovered f

maintenance o

adjacent burie

component.

1218 XI.M41

ML102371265, 

Comment 

XI.M41-5(c)

This provides the appearance to mislead the 

public.

The staff disagrees 

with this comment. 

No changes to the 

GALL Report have 

been made.

The staff belie

excavations as 

AMP will provi

approach. “Op

inspection” is f

in paragraph 4

underground p

regardless of t

construction a

visual means w

become acces

reason.” This f

is not tied to le

inspections are 

whenever a pi

uncovered for 

maintenance o

adjacent burie

component.

1161 XI.M41

ML102371265, 

Comment 

XI.M41-6(a)

Do any of these programs assure the actual 

integrity of the pipes and tanks?

The GALL Report 

has not been 

changed . in 

response to this 

question

The staff belie

AMP provides 

assurance tha

function of the 

or component 

during the per
NUREG-1950 IV-222 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

operation.

1219 XI.M41

ML102371265, 

Comment 

XI.M41-6(b)

If M41 replaces M20, please clearly state this. The staff disagrees 

with this comment. 

No changes to the 

GALL Report have 

been made.

AMP XI.M41 d

AMP XI.M20 “

Water System

1220 XI.M41

ML102371265, 

Comment 

XI.M41-6(c)

These programs appear to be intended to 

reduce corrosion rather than detect 

degradation.

The staff disagrees 

with this comment. 

No changes to the 

GALL Report have 

been made.

This AMP con

actions and an 

Both are cons

aspects of ma

intended funct

underground p

1221 XI.M41

ML102371265, 

Comment 

XI.M41-7(a)

It is assumed that the definition will include 

pipes and tanks that are not completely 

buried, For example some piping systems are 

above ground however the buried pipes will 

be inspected.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The buried po

run of piping w

some locations 

in other locatio

AMP. The exte

above ground 

covered by the 

Monitoring of M

Components A

1163 XI.M41

ML102371265, 

Comment 

XI.M41-7(b)

It is assumed the same will apply to partially 

buried tanks, including the CST, RWST, 

Waste Tanks, SFP, Drywell and containments 

which are tanks partially buried, within the 

scope of 10 CFR 54.4, and contain levels of 

activity in excess of EPA drinking water limits.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The buried po

run of piping w

some locations 

in other locatio

AMP. The exte

above ground 

covered by the 

Monitoring of M
April 2011 IV-223 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

Components A

1222 XI.M41

ML102371265, 

Comment 

XI.M41-8(a)

Many tanks such as CST and the RWST are 

in contact with sand, concrete, or soil but are 

only partially buried. It is not clear if these 

tanks are within the scope of this proposed 

program.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The definition 

underground i

been clarified 

buried tanks a

1164 XI.M41

ML102371265, 

Comment 

XI.M41-8(b)

Many internal failures of tanks have been 

reported over the past 30 years. How would 

these failures be detected by this proposed 

program? (VY CST and the CY RWST have 

experienced internal failures) 

The staff agrees with 

this comment. 

However, no changes 

to the GALL Report 

have been made.

This program 

degradation of 

from the outsid

Degradation o

surfaces of tan

other AMPs.

1223 XI.M41

ML102371265, 

Comment 

XI.M41-8(c)

The spent fuel pool and the contaminants are 

"tanks" meeting the requirements of the above 

definition in that it is encased in concrete 

and/or soil and at many reactors, is below the 

surface of the ground. The same is true for 

the Spent Fuel Pool.

The staff disagrees 

with this comment. 

No changes to the 

GALL Report have 

been made.

The Spent Fue

liner) is consid

is covered by t

monitoring pro

XI.M41.

1165 XI.M41

ML102371265, 

Comment 

XI.M41-9(a)

How does the NRC expect the licensee to 

inspect "bolting" of valves and flanges of 

buried pipes without any periodic external 

visual inspections? A logical conclusion is that 

it is likely that external bolting of buried pipes 

will never be inspected during the entire 60 

years of plant operation. 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

While bolting i

program, there 

experience to 

inspection is o

staff believes t

inspections of 

occur and that 

sufficient to de

degradation is 

particular plan

1229 XI.M41 How is piping integrity assured in the event of No changes to the This comment 
NUREG-1950 IV-224 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

ML102371265, 

Comment 

XI.M41-9(b)

a common mode event such as a 

earthquake?

GALL Report have 

been made in 

response to this 

question.

mains. The int

not assumed i

earthquake. F

generally not s

piping. Section 

of RG 1.189 a

which fire fight

assured follow

This section of 

provisions that

the plant, two 

connections w

been seismica

provided. Add

states that wat

standpipes an

is provided thr

connect to seis

service water p

is not necessa

contain provis

specifically to 

of fire mains fo

earthquake.

1166 XI.M41

ML102371265, 

Comment 

XI.M41-10 

My concern is the structural integrity of these 

pipes. Please explain how any flow test 

verifies the integrity of these pipes?

The staff agrees with 

this comment. 

However, no changes 

to the GALL Report 

have been made.

Flow tests are 

These mains a

accordance w

24. This stand

leakage from n

systems. Flow 

with sufficient 
April 2011 IV-225 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

sufficient degr

fire main unab

the required vo

will not occur b

consecutive te

pressure is ma

main system t

jockey pumps. 

pumps is mon

for license ren

the activity of t

that may indica

fire main pipin

1167 XI.M41

ML102371265, 

Comment 

XI.M41-11

How will the NRC assure that these backfill 

and cathodic protections measures are 

implemented or verified?

Will the NRC require any type of physical 

verification?

The GALL Report 

has not been 

changed in response 

to this question. 

Information co

cathodic prote

the applicant a

through inspec

NRC regional 

time the plant 

extended oper

1168 XI.M41

ML102371265, 

Comment 

XI.M41-12

Does this infer that all metallic pipes have or 

are required to have cathodic protection 

unless the following conditions are met?

Will the NRC require cathodic protection be 

added to protect these pipes?

. The GALL Report 

has not been 

changed in response 

to this question. 

It is the staff’s 

preventive act

of coatings, ins

protection, and 

backfill, are an 

comprehensiv

managing the 

surfaces of bu

underground p

during the agin

review process
NUREG-1950 IV-226 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

determines tha

piping and tan

the prevent ac

staff would exp

applicant woul

take action to 

preventive act

period of exten

take an excep

provide a thoro

justification for 

1169 XI.M41

ML102371265, 

Comment 

XI.M41-13

Are the presently operating plants in 

compliance with this standard? If not will they 

be required to backfit or verified to meet these 

requirements? See IP-2 RCA for CST line 

failure of February 2009.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The scope of t

contained in th

limited to the t

the AMP to wh

pertains. This 

determination 

the GALL Rep

be applied. Th

this failure.

1170 XI.M41

ML102371265, 

Comment 

XI.M41-14

Are there any preventive measures for 

internal corrosion control such as epoxy or 

concrete. If the pipes are lined are there any 

requirements to inspect the integrity of the 

internal lining or coatings?

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

This AMP prim

degradation th

external surfac

underground p

AMPs that add

surfaces of pip

contain preven

as internal linin

1171 XI.M41 Other materials such as monel, bronze, etc. The staff disagrees Paragraph 1 o
April 2011 IV-227 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

ML102371265, 

Comment 

XI.M41-15

are commonly used in nuclear plants. Are 

these materials covered by this program?

with this comment. 

The GALL Report 

has not been 

changed.

Description sta

“addresses pip

composed of a

is generally a c

is classified as 

nickel copper a

classified as a 

be addressed 

applicant.

1172 XI.M41

ML102371265, 

Comment 

XI.M41-16(a)

What if they never become accessible for any 

reason? Is this OK? [Staff note: This comment 

refers to the opportunistic inspections section 

of the document and specifically to the 

statement “whenever they become accessible 

for any reason”.]

The GALL Report 

has not been 

changed in response 

to this question. 

If opportunistic 

occur, sufficien

then be condu

inspections as 

a-d. 

1224 XI.M41

ML102371265, 

Comment 

XI.M41-16(b)

Wall thickness and integrity must be 

periodically verified.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

If opportunistic 

occur, sufficien

then be condu

inspections as 

a-d. The staff’s 

visual examina

supplemented 

volumetric non

significant con

observed. 

1173 XI.M41

ML102371265, 

Comment 

XI.M41-17

This is very confusing. If a service water 

system contains 10,000 feet of buried pipes, 

how many feet of pipe will be excavated and 

inspected?

Will every branch line be inspected?

The GALL Report 

has not been 

changed in response 

to this question.

The answer to 

plant-specific. 

material of the 

system (gener

steel), whethe
NUREG-1950 IV-228 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

system is clas

code class/saf

presence of ot

class/safety-re

risk associated 

water piping. I

inspections of 

piping would b

also possible t

service water p

inspected.

1174 XI.M41

ML102371265, 

Comment 

XI.M41-18

#5. Hazmat pipe:

Insert "and tanks" [Staff note: The section of 

the document to which this comment refers to 

is Table 4a, which is titled “Inspections of 

Buried Pipe]. 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The section of 

this comment 

only buried pip

1175 XI.M41

ML102371265, 

Comment 

XI.M41-19(a)

As I understand this technology it is an 

unproven method to assure the structural 

integrity of buried pipes.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The staff enco

guided wave u

as a screening 

identifying are

require further 

present time, g

be substituted 

techniques, su

to determine re

thickness. 

1225 XI.M41

ML102371265, 

Comment 

XI.M41-19(b)

The word "encouraged" is meaningless is a 

regulatory environment and obligates a 

licensee to nothing.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

The use of the 

in this instance 

staff wishes to 

of the use of g
April 2011 IV-229 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

changed. screening tool 

impose a requ

applicant to do 

1176 XI.M41

ML102371265, 

Comment 

XI.M41-20(a)

A flow test is not able to detect either internal 

or external degradation of pipes.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Flow tests are 

These mains a

accordance w

24. This stand

leakage from n

systems. Flow 

sufficiently freq

sufficient degr

fire main unab

the required vo

will not occur b

consecutive te

pressure is ma

main system t

jockey pumps. 

pumps is mon

Changes in the 

jockey pumps 

degradation of 

investigated.

1226 XI.M41

ML102371265, 

Comment 

XI.M41-20(b)

A fire main could experience severe 

degradation not detected by a flow test and 

fail as a result of an earthquake when it is 

most likely needed. 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Flow tests are 

These mains a

accordance w

24. This stand

leakage from n

systems. Flow 

conducted suf

that sufficient d
NUREG-1950 IV-230 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

render a fire m

water at the re

pressure will n

two consecutiv

pressure is ma

main system t

jockey pumps. 

pumps is mon

Changes in the 

jockey pumps 

degradation of 

investigated.

The integrity o

assumed in th

earthquake. F

generally not s

piping. Section 

of RG 1.189 a

which fire fight

assured follow

This section of 

provisions that

the plant, two 

connections w

been seismica

provided. Add

states that wat

standpipes an

is provided thr

connect to seis

service water p

is not necessa
April 2011 IV-231 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

contain provis

specifically to 

of fire mains fo

earthquake.

1177 XI.M41

ML102371265, 

Comment 

XI.M41-21(a)

Subpart H of 49 CFR 196 [Staff note; 

Incorrect reference] for corrosion control and 

other applicable parts of 49 CFR 195 must be 

included.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The staff notes 

differences in 

materials trans

and those foun

plants. The sta

CFR 195 subp

purpose of ide

procedures us

hydrostatic tes

chosen to use 

which it deems 

buried and und

tanks found in 

plants to addre

of aging mana

finds it unnece

49 CFR 195 s

of 49 CFR 195 

E.

1227 XI.M41

ML102371265, 

Comment 

XI.M41-21(b)

49 CFR 195 only applies to steel pipes. Will 

this testing apply to all pipes?

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The purpose o

subpart E is fo

hydrostatic tes

the staff would 

this standard f

than steel.

1178 XI.M41 Need a very clear definition for "buried tanks" The staff disagrees GALL Report C
NUREG-1950 IV-232 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

ML102371265, 

Comment 

XI.M41-22

with this comment. 

The GALL Report 

has not been 

changed.

new definition 

piping.

1179 XI.M41

ML102371265, 

Comment 

XI.M41-23

A comprehensive listing of pipe failures due to 

internal corrosion and degradation should also 

be provided.

Provide a listing of only external corrosion 

failures leads to a inference that pipes do not 

degrade [due] to internal mechanisms.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

This AMP prim

external degra

underground p

listing of opera

associated wit

degradation in 

outside the sco

1180 XI.M41

ML102371265, 

Comment 

XI.M41-24

Is it possible to obtain a copy of these 

standards from the NRC?

The GALL Report 

has not been 

changed in response 

to this question.. 

NACE Standa

2007 is a copy

belonging to N

may not be dis

It is available f

general public 

International. T

standards indi

commenter are 

documents be

respective org

may be distrib

are available f

general public 

organization. I

the availability 

1801, “Copies 

and standards 

substantive ma

regulatory proc
April 2011 IV-233 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

at the NRC Lib

Flint North, 11

Rockville, MD 

by the public.” 

NACE standar

members of th

appointment.

1181 XI.M41

ML102420706, 

Comment 1 

During the August 24, 2009 meeting 

discussing the proposed revision to AMP M41 

it was very troubling to hear the NRC state 

that it was not reasonable to require nuclear 

plants to excavate buried pipes (and tanks) 

due to possible damage to the pipes due to 

"backhoe" digging. This statement was made 

at least three times during the meeting.

Please keep in mind that the primary mission 

of the NRC is to provide adequate protection 

to the public. Unless the NRC has 

documented the fact that the risk to the 

general public is greater due to potential pipe 

damage from excavation, it is totally 

inappropriate for the NRC to put forward these 

apparently unsupported statements. If these 

statements are supported, please provide a 

reference.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

While the staff 

possible to da

excavation, it s

certain percen

excavated for 

The staff notes 

Department of 

published data 

ML102500311

significant pipe

cause. The da

single largest c

incidents was 

damage. While 

nuclear situatio

provides repre

information.

1182 XI.M41

ML102420706, 

Comment 2 

In the Program Description of the proposed 

revision to XI.M41 the intent and the 

objectives of the program should be clearly 

stated. Words such as the follow should be 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

The staff notes 

54 already sta

be reasonable 

systems, struc
NUREG-1950 IV-234 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

considered in the program description.

" The purpose of this program is to provide 

reasonable assurance that all piping and 

portions of tanks that are not normally 

accessible (buried, partially buried, or 

otherwise inaccessible) within the scope of 10 

CFR 54.4 or contain radioactive material in 

excess of EPA drinking water limits, maintain 

the ability to perform their designated 

functions and to preclude the release of 

radioactive material to the surrounding soil 

and the environment."

changed. components m

intended funct

1183 XI.M41

ML102420706, 

Comment 3 

Also the Program Description clearly states 

that this program is to manage the aging of 

external

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

surfaces augmented by other AMPs 

such as AMP such as XI.M.20 and XI.M.38. 

These AMPs do not apply to buried pipes and 

XI.M20 applies to lined pipes. (See Seabrook 

LRA). At least two plants in responses to GL 

89-13 specifically exclude buried pipes and 

the NRC has not questioned this total lack of 

internal inspections.

This program a

external surfac

and tanks. The

programs that 

buried piping a

1184 XI.M41

ML102420706, 

Comment 4 

The NRC words "opportunistic" and 

"encouraged" are totally inappropriate for a 

document intended as a regulatory basis for 

the protection of the public. As a professional 

engineer with more than 40 years experience 

maintaining and designing nuclear power 

plants the word "opportunistic" means run the 

system until it fails such as the pipe rupture 

event at Indian Point in February 2009. 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

(1) The term “o

inspection” is f

in paragraph 4

underground p

regardless of t

construction a

visual means w

become acces

reason.” This f
April 2011 IV-235 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

Opportunistic maintenance programs have 

totally failed to prevent failures such as the 

Davis Besse degradation, collapsing piping 

systems, bridges, elevators, levies and I 

would never use such a program to assure 

the safety and/of reliability of my car. (I am 

sure Dave Pelton wouldn't either)

is not tied to le

inspections are 

whenever a pi

uncovered for 

maintenance o

adjacent burie

component.

1185 XI.M41

ML102420706, 

Comment 5 

The proposed AMP has a very strong 

inference that buried pipes and tanks are 

protected by active cathodic protection (NACE 

SP0169-2007 or NACE RP0285- 2002) 

systems and that "backfill" is in accordance 

with SP0169-2007. Will the NRC require 

licensees to verify compliance with these 

standards and verify that cathodic protections 

systems are installed on all systems within the 

scope of this AMP?

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

(1) Cathodic p

required by NR

(2) It is the sta

preventive act

of cathodic pro

essential part 

program for m

the external su

underground p

during the agin

review process

determines tha

piping and tan

the preventive 

the staff would 

applicant woul

take action to 

preventive act

period of exten

take an excep

provide a thoro

justification for 

(3) Backfill qua
NUREG-1950 IV-236 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

determined by 

records or inve

reported to the 

aware of issue

deteriorated co

backfill at India

1186 XI.M41

ML102420706, 

Comment 6

The AMP seems to endorse 49 CFR 195 

Subpart E but it appears portions of Subpart F 

and H could add additional assurance to 

protect the health and safety of the public.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

This AMP doe

CFR 195; rath

reference. The 

deals with ens

structures, and 

able to perform 

functions durin

extended oper

1187 XI.M41

ML102420706, 

Comment 7

The word "may" is not a appropriate for a 

document used for regulatory basis and 

should (must) be changed to either "shall" or 

"will." What is the justification for 25% 

inspection?

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The AMP is an 

managing agin

components a

requirement, s

appropriate. T

engineering ju

statistically ba

1188 XI.M41

ML102420706, 

Comment 8

Finally, a large percentage of buried pipe and 

tank failures are the result of internal failure 

due to corrosion, erosion or other mechanical 

failures and must be addressed by this AMP 

without the use of words such as 

"opportunistic, encouraged, may, etc."

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

This program a

external surfac

and tanks. The

programs that 

buried piping a

1112 XI.M41

ML102420742,

(2) Entergy Vermont Yankee’s Root Cause 

Report makes it clear that the failure of the 

underground AOG piping which recently 

The staff disagrees 

with this comment. 

The GALL Report 

This program a

external surfac

and tanks. The
April 2011 IV-237 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

Comment 

XI.M41-P1

(Ray Shadis 

New England 

Coalition)

released radiological contaminated water to 

the open environment was not the result of 

external corrosion. In fact, the RCR states, the 

leaks were not the result of corrosion at all 

(internal or external) but flow-driven, 

mechanical (not corrosion-assisted) internal 

erosion – pipe thinning. If this is really the 

case, then the unidentified programs which 

“manage aging of internal surfaces” need 

more than augmentation by an improved 

program that is limited to external

Mechanical erosion is caused by accelerated 

surfaces. If 

the high public interest in the leaks at Vermont 

Yankee provided any contributing motive for 

the NRC piping and tanks initiative, then the 

initiative, according to the Entergy VY RCR is 

entirely unresponsive. The VY License 

Renewal ASLB is now reconvened on remand 

from the Commission. NRC Staff has the 

opportunity and the obligation to bring the 

matter of Entergy’s piping AMP failure before 

the ASLB. [Root Cause Evaluation Report 

CR-VTY-2010-00069 says, at page 11-14, A 

and B Recombiner Steam Trap Drain Lines 

Leaks:.... The failed piping segment(s) cannot 

be removed for inspection due to their 

inaccessible location. However, the visual 

inspections performed, and review of the 

operating parameters of the steam trap drain 

lines result in the reasonable conclusion that 

the failure occurred due to mechanical 

erosion.

has not been 

changed.

programs that 

buried piping a
NUREG-1950 IV-238 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

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Comment 

Number

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Reference No.

Comment NRC Disposition Tech

flows, droplet impingement, and two phase 

flow. Mechanical erosion is more likely to 

occur immediately downstream of changes in 

flow direction, such as elbows, where 

increased flow turbulence 

occurs....Mechanical erosion differs from 

FAC, which is a chemical induced 

corrosion/erosion phenomenon.

1119 XI.M41

ML102420742,

Comment 

XI.M41-P2

(John H 

Fitzgerald, III)

(2) Table 2a indicates the writers are 

unfamiliar with the corrosion of buried 

stainless steel (SS) facilities. While Stainless 

Steel (SS) may perform well in loose or fairly 

well aerated soils, it will corrode like carbon 

steel in tight or mucky soils. This is because in 

the absence of oxygen, the protective oxide 

film will not form on SS. I have encountered 

this in various places. The writers compound 

the matter by coating the structures (footnote 

3) and then omitting cathodic protection (CP) - 

more on this late). Left bare, the SS will 

usually undergo general corrosion over the 

entire surface, usually leading to eventual 

failure.

When coated, but without CP, pitting 

corrosion occurs at breaks (holidays) in the 

coating. This leads to fairly rapid corrosion 

and failure. The DOT regulations for gas and 

flammable liquid pipelines, and the EPA 

regulations for buried storage tanks, prohibit 

the use of coating without CP. Nothing less 

should be accepted for nuclear plants.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

In most cases

aluminum will 

corrosion in so

elevated levels 

the pH is very 

The need for c

protection of s

aluminum will 

case by case b
April 2011 IV-239 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

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Document and 

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Reference No.

Comment NRC Disposition Tech

Table 2a also includes aluminum. Aluminum 

is a very poor material for buried use, and we 

see practically no use of it for that purpose 

today. Aluminum is a highly active metal and 

is anodic to just about any other metal to 

which it might be connected. CP can be used 

on aluminum, but great care must be taken. 

CP causes a rise in pH in the soil around the 

protected structure, and with a little too much 

CP, the pH can rise above 8.0, and [in] that 

range aluminum will corrode rapidly even 

under CP.

1123 XI.M41

ML102420742,

Comment 

XI.M41-PW1

(John H 

Fitzgerald, III)

5) Foot note 4a states that CP need not be 

provided in soils of resistivity greater than 

20,000 ohm cm. This thinking dates back to 

the 1950s at which time it was believed that in 

soils of resistivity greater than 10,000 ohm cm 

corrosion failures were infrequent enough that 

it was less expensive to fix leaks than to 

protect the pipelines. That thinking was soon 

put to rest and by 1960, it was standard 

practice to provide coating and CP for steel 

pipelines.

Footnote 4a also applies to carbon steel, and 

now is 60 years out of date.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made. 

Although it is c

coat all steel p

protect the coa

oil and gas pip

same for pipin

power plants. 

has been dele

Report.

1125 XI.M41

ML102420742,

Comment 

XI.M41-PW3

(John H 

Comment 13a – Footnote 5 implies that 

selected backfill is adequate corrosion control 

for buried facilities. It is not. Even if the backfill 

is completely uniform it soon assumes the 

corrosiveness of the surrounding soil. Also, 

one has little control over some future 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Using select b

particles such 

will cause less 

piping and will 

possibility of fu
NUREG-1950 IV-240 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

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Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

Fitzgerald, III) excavation that may disturb the backfill in one 

area and replace it with a different backfill; this 

creates a lack of backfill uniformity, a situation 

that leads to corrosion.

piping.

1128 XI.M41

ML102420742,

Comment 

XI.M41-PW4

(John H 

Fitzgerald, III)

It is curious that in various places, the 

document calls for backfill for non-metallic 

facilities to be consistent with certain sections 

of NACE SP0169. This document deals 

specifically with metallic structures- see the 

second reference on page 15. Similar 

references are made to SP0285; this 

document deals with CP for underground 

tanks and CP is not applicable to non-metallic 

facilities. Some nonmetallic facilities, 

particularly fiberglass tanks require pea gravel 

for backfill, so some consideration must be 

given to backfill.

The staff partially 

agrees with this 

comment and the 

document was 

reworded for clarity.

The document 

to state that so

facilities such 

require pea gr

1126 XI.M41

ML102420742,

Comment 

XI.M41-PW5

(John H 

Fitzgerald, III)

Apply throughout document:

(1) “To be considered hazmat, the 

concentration of radioisotopes within the pipe 

during normal operation must exceed 

established standards such as EPA drinking 

water standard” makes no sense. The 

definition is a snapshot of what is in the 

component at a particular time – it does not 

account for lower concentrations that leak and 

over time can be significant. It wrongly ignores 

the cumulative effect of leakage.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The staff is us

definition for h

recommending 

percentage for 

stands.

1129 XI.M41

ML102420742,

(2) “In the absence of such standards, the 

concentration of radioisotope must exceed the 

The staff disagrees 

with this comment. 

The purpose o

manage the ef
April 2011 IV-241 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

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Comment NRC Disposition Tech

Comment 

XI.M41-PW5(2)

(John H 

Fitzgerald, III)

greater of background or reliable level of 

detection.” Games are typically played with so 

called background – such as using the 

national average - not based on a site specific 

and site pre-operational determined number. 

As for “reliable level of detection” Liquid 

Release Task Force Recommendations 

Implementation Status as of November 19, 

20073 stated at 2 that, “The Staff is revising 

RG 1.21 to incorporate the LLFT 

recommendation that “The NRC should revise 

radioactive effluent release program guidance 

to upgrade the capability and scope of in-plant 

monitoring system, to include additional 

monitoring locations and the capability to 

detect lower radionuclides (i.e., low energy 

gamma, weak beta emitters, and alpha 

particle.” [Emphasis added]

(3) How are “normal” and “abnormal” defined?

(4) It would make sense to sort the 

components within scope that fall under this 

program into those that do/could contain 

radioactive liquids from those that do/could 

not.

The GALL Report 

has not been 

changed.

external surfac

underground p

not intended to 

monitoring pro

addressed by 

outside of the 

1143 XI.M41

ML102420742,

Comment 

XI.M41-PW6

(John H 

Fitzgerald, III)

Comment John Fitzgerald: Selection of 

locations to inspect appear to depend on a 

subjective assessment of likely corrosive 

conditions. I should think the nuclear industry 

would like to up be to date on how to find the 

best places to excavate for external inspection 

on buried pipe. This procedure, known as 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

While the indu

developing ext

direct assessm

techniques are 

sufficiently to b

edition of the G
NUREG-1950 IV-242 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

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Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

External Corrosion Direct Assessment 

(ECDA) and also Internal Corrosion Direct 

Assessment (ICDA) is practiced in the 

pipeline industry under the DOT rules for 

pipeline integrity. These assessments are 

based on detailed assessments of conditions, 

electrical and other measurements to locate 

corroding areas, and the excavations are 

based on these data. Experience has shown 

these procedures to be very accurate. To 

date, these practices have been used only on 

transmission lines, but similar rules are now 

coming out for distribution piping. Distribution 

piping has many resemblances to the piping 

in generating stations.

1146 XI.M41

ML102420742,

Comment 

XI.M41-PW7

(John H 

Fitzgerald, III)

Comment John Fitzgerald: I have not studied 

the XI.M41 document in detail ... My review 

so far indicates to me that this document 

needs a lot of work to make it consistent with 

current corrosion control technology.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

This is a new A

staff believes t

revisions to the 

AMP will be re

1154 XI.M41

ML102420732, 

Comment 

XI.M41-3 (sup)

A frequency of every six months is excessive 

for determining the capability of the system to 

provide proper pressure and flows. This flow 

test along with additional NFPA and XI.M27 

testing and continuous system pressure 

monitoring using jockey fire pump operation 

would detect a significant loss of pressure 

boundary without flow testing at the specified 

frequency. Recommend revising 6 month flow 

testing frequency to a maximum of once every 

The staff partially 

agrees with the 

comment, and some 

changes have been 

made to the GALL 

Report.

In light of rece

experience wit

interval for ins

frequent enoug

performance p

inspection. Th

trended using 

Changes in ins

be considered 

trending. The 
April 2011 IV-243 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

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Commenter 

Reference No.

Comment NRC Disposition Tech

two years which significantly exceeds existing 

NFPA requirements. In addition, a change 

should be made to the Program description to 

eliminate need for these additional notes.

main flow testi

from once eve

per year.

1085 XI.M41

ML102420732, 

Comment 

XI.M41-23 

(sup)

Element 4 item d.iv. and item e.iv. – If the tank 

is volumetrically inspected internally, the 

required number of inspection locations of the 

tank surface area should be in accordance 

with API standard 1631 which specifies an 

exam where the internal tank cylinder wall 

shall be initially divided in 3 foot square (9 ft2) 

sections. Tank ends (heads) shall be divided 

into four equal quadrants and each quadrant 

then divided into 3 foot square (9 ft2) sections. 

Any remaining areas less than 3 ft by 3 ft in 

size shall be considered to be additional 

sections. Any sections with thickness readings 

of 75% or less of the original metal thickness 

shall be subdivided into 9 subsections and 

require additional gauging at the center of 

each subsection.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

These tanks a

the American 

This standard 

for future revis

document. 

1087 XI.M41

ML102420732, 

Comment 

XI.M41-28 

(sup)

Element 1, Scope of Program - For some 

plants, buried pipe is encased in concrete or 

backfilled in controlled low strength material 

(CLSM)/flowable fill (a flowable, self-leveling 

and self-compacting cementitious material 

used in place of traditional compacted fill) with 

trade name such as Fillcrete. CLSM has been 

found to be beneficial in reducing corrosion 

(compared to typical compacted fill) when 

pipes are completely embedded in CLSM. 

The staff partially

agrees with this 

comment. The GALL 

Report has been 

changed.

The staff has 

inspection crite

for prioritizatio

encased in co

material. Thes

found in parag

footnote 10 to 

The staff conc
NUREG-1950 IV-244 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

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Comment NRC Disposition Tech

The reduced permeability of CLSM can 

reduce the ingress of chlorides, and the 

microstructure of CLSM can improve 

corrosion resistance through changes in the 

pH and resistivity of the pore solution. CLSM 

provides more protection against corrosion 

initiation and propagation when metallic 

structures are completely embedded in CLSM 

compared to compacted sand. The above

results included in a study presented in 

Development of a Recommended Practice for 

Use of Controlled Low-Strength Material in 

Highway Construction. Report 597 (2008), 

indicated that corrosion activity for steel pipe 

coupons completely embedded in CLSM was

significantly lower (i.e. negligible) than that 

embedded in sand. This study can be found at 

http://onlinepubs.trb.org/onlinepubs/nchrp/nch

rp_rpt_597.pdf. 

NUREG-1801 line items VII.J.AP-3 and 19 

show no aging effects for carbon or stainless 

steel exposed to concrete. These factors 

present a strong argument for insignificant 

corrosion susceptibility and lack of need for 

excavation. Add that piping encased in 

concrete or CLSM (flowable fill) is not in 

scope of the program.

commenter tha

of steel piping 

controlled low 

substantially le

expected for d

As a result the 

the priority of t

determining w

selected for in

reduced the nu

recommended 

The staff does 

commenter tha

corrosion of th

sufficiently low 

aging manage

and other stee

encased in co

significant corr

the concrete is 

moisture conta

concentrations 

sulfates. It wa

intent that NUR

VII.J.AP-3 (ste

environment o

for moist or bu

was the staff’s 

be used for pip

concrete within 

concrete was d
April 2011 IV-245 NUREG-1950

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Comment NRC Disposition Tech

1092 XI.M41

ML102180192, 

Comment 1

Discussion:

A graded approach to aging management of 

buried piping is proposed that considers the 

following:

− 100% inspection of high risk piping (where 

risk is determined by methods consistent with 

NEI 09-14) within the scope of license 

renewal by direct or indirect inspection 

methods and

− Direct aging management inspections 

based on material-environment

High risk piping inspections will be augmented 

as appropriate with non-high risk piping based 

on direct inspections of each material type 

and maintaining a minimum number of direct 

inspections during each 10 year interval. Prior 

to entry into the period of extended operation, 

at least one direct inspection of each material 

type will be performed. During each 10 year 

inspection interval a minimum of two direct 

inspections will be performed. Adverse 

indications observed during indirect 

inspections will be investigated by the 

corrective action process. The corrective 

action process will evaluate sample 

expansions based on adverse condition such 

as through wall leakage or wall thickness less 

than minimum.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

While the indu

developing NE

techniques are 

sufficiently to b

revision of the 
NUREG-1950 IV-246 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

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Comment NRC Disposition Tech

1095 XI.M41

ML102180192, 

Comment 2

Scope of Inspection

− 100% of the high risk buried piping (where 

risk is determined by methods consistent with 

NEI 09-14) within the scope of license 

renewal will be inspected by direct or indirect 

inspection methods.

− Prior to entry into the period of extended 

operation, direct inspections will be performed 

on at least one of each buried pipe material at 

the site (aluminum, copper, steel, stainless 

steel, polymer, and cementitious).

− During each 10 year inspection interval, a 

minimum of two direct inspections (high risk 

and/or non-high risk piping) per site will be 

performed during each 10 year inspection 

period. Excavation locations for non-high risk 

piping will be based on degradation 

susceptibility considerations (e.g., prior 

inspection results, cathodic protection, 

coatings, and soil conditions).

− Underground piping is managed by the 

external surfaces monitoring of mechanical 

components program (Chapter XI. M36).

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

While the indu

developing ext

direct assessm

techniques are 

sufficiently to b

revision of the 

As has been s

underground p

be included in 

1097 XI.M41

ML102180192, 

Comment 3

Preventive Measures

− Cathodic protection, coatings, and backfill 

are preventive measures and should be 

addressed in program Element 2. An annual 

NACE survey will be performed for systems 

within the scope of license renewal that are 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

This is already 

Element 2.
April 2011 IV-247 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

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Comment NRC Disposition Tech

cathodically protected. 

1099 XI.M41

ML102180192, 

Comment 4

Detection of Aging Effects

− Direct or indirect inspection methods can be 

used for high risk piping 

− All buried piping is opportunistically 

inspected by visual means whenever it 

becomes accessible.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

This is already 

Element 3.

1101 XI.M41

ML102180192, 

Comment 5

Monitoring and Trending

− Directed inspections will be conducted 

during each 10 year period beginning 10 

years prior to the entry into the period of 

extended operation.

− Direct inspections are not required in the 

last 10 year period (year 50 to 60) if no there 

has been no minimum wall failures in the prior 

10 year inspection interval.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The period of e

is 20 years, an

that many app

an additional p

operation. In th

additional insp

required during 

the first period 

operation.

1230 XI.M41

ML102500311

In response to Mr Blanch’s concern over 

data supporting that excavation is more 

significant than external corrosion, I would 

suggest you consider the DOT statistics 

provided at: 

http://primis.phmsa.dot.gov/comm/reports

/safety/SigPSIDet_1990_2009_US.html?n

ocache=1072#_all. Excavation damage 

exceeds corrosion damage (both internal 

& external combined) on average in all 

pipeline markets. Interestingly enough, 1st

party damage (i.e., the owner digging

The staff 

acknowledges receipt 

of this comment. The 

GALL Report has not 

been changed.

This comment 

data but did no

the GALL Rep
NUREG-1950 IV-248 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

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Comment NRC Disposition Tech

their own line) is a greater percentage 

than almost all causes other than 

corrosion or miscellaneous.

150 XI.M6

ML101830328 

Comment 

XI.M6-1 

Remove extra wording in Scope. There is no 

(b) option in the new wording.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

No technical b

incorporate thi

(typographical 

editorial in nat

151 XI.M6 

ML101830328 

Comment 

XI.M6-2 

Typo – Element 4 change blend to bend and 

program description change corrosion to 

corrosion

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

No technical b

incorporate thi

(typographical 

editorial in nat

152 XI.M6 

ML101830328 

Comment 

XI.M6-3 

Add “reviewed and accepted by the NRC in a 

safety evaluation report” after later revisions 

to match earlier changes to allow the use of 

later revisions.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The staff has d

that addresses 

approved for u

basis (via ISG

review incorpo

and use of exc

specific preced

provide a high 

confidence so 

applications ca
April 2011 IV-249 NUREG-1950

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Comment NRC Disposition Tech

that precedent

preamble to G

XI.

377 XI.M6 

ML101830255 

Comment 

XI.M6-1 

This program is not generically applicable to 

the domestic BWR fleet and should be 

removed from the GALL Report.

In regards to thermal fatigue of the CRD 

return line nozzle, BWRVIP-74-A states: “The 

CRD return line nozzles in nearly all domestic 

plants which had them were capped, thus 

eliminating the concern for those 

components.”

If not all, the large majority of domestic 

BWR/3-6s have eliminated flow through their 

CRD return line nozzles by capping the 

nozzle, installation of a blind flange, or other 

method. NRC staff can verify this information 

for many BWRs through review of license 

renewal applications. For the BWR/2 units 

(i.e. Nine Mile Point Unit 1 and Oyster Creek 

Generating Station), the CRD return line 

nozzle has not been capped. NMP Unit 1 

credited the ISI program in lieu of XI.M6 

because the CRD return line nozzle thermal 

sleeve design at NMP Unit 1 makes the 

nozzle less susceptible to thermal fatigue 

cracking than the original designs used in 

other BWRs. Only Oyster Creek Generating 

Station has not capped the CRD return line 

nozzle and also credited XI.M6 in a license 

renewal application. However, the Oyster 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The staff will re

(BWR CRDRL 

available to an

is applicable a

fleet has not im

modifications t

about these co
NUREG-1950 IV-250 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

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Comment NRC Disposition Tech

Creek Generating Station LRA indicates that 

exception is taken to the PT examination 

requirements of NUREG-0619, with UT 

examination used instead.

Based on the above, cracking due to thermal 

fatigue cycling of the CRD return line nozzle is 

no longer a generic issue requiring aging 

management by the BWR fleet. Further, 

XI.M6 is not generally applicable to the 

domestic BWR fleet and should be removed 

from NUREG-1801 so that applicants need 

not address this program in license renewal 

submittals.

SCC of nickel-alloy welds associated with 

CRD return line remains an aging 

management concern. However, SCC can be 

managed through program XI.M7, “BWR 

Stress Corrosion Cracking.” Table TBD 

[editorial comment, as shown in 

ML1018302551 submitted by, EPRI on 

6/29/2010, Table TBD is Table A-3: 

Comments on Section XI.M6 of May 2010 

Draft NUREG-1801: “Control Rod Drive 

Return Line Nozzle” ] below provides EPRI 

BWRVIP comments regarding XI.M7, “BWR 

Stress Corrosion Cracking” program 

description.

153 XI.M7

ML101830328 

Comment 

It seems odd that the ASME Code isn’t 

referred to when discussing the inspections to 

be performed in elements 1, 3, or 4. Then 

suddenly, the results are trended per the 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

The ASME Co

scope of aging 

parameters mo

of aging effect
April 2011 IV-251 NUREG-1950

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XI.M7-1 Code in element 5, have acceptance criteria 

per the code in element 6, and corrective 

action per the code in element 7. Shouldn’t 

the inspections required by the code be 

mentioned earlier on? (Mark-up not provided)

changed as a direct 

result of this 

comment.

NUREG-0313 

However, Elem

revised to bett

ASME code is 

management o

follows the app

154 XI.M7 

ML101830328 

Comment 

XI.M7-2 

Again, the PREVENTIVE ACTIONS section 

should be consistent with other condition 

monitoring AMPs. (See comment on AMP 

XI.M4.)

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Element 2 was 

consistent with 

378 XI.M7 

ML101830255 

Comment 

XI.M7-1 

The preventive actions section discussion for 

water chemistry should simply refer to 

program XI.M2.

Applicable Sections

Specific reference to a version of the EPRI 

BWR Water Chemistry Guidelines and 

discussion regarding control parameter tables 

should be limited to XI.M2 and not be 

repeated in XI.M7. 

: Preventive Actions

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Change to rea

ID Attachment 

condition mon

has no preven

Maintaining hig

reduces susce

IGSCC. React

chemistry is m

maintained in 

Water Chemis

program descr

and technical 

chemistry are 

XI.M2, “Water 

consistent with 

379 XI.M7 

ML101830255 

Comment 

XI.M7-2 

All references to the NRC approved version of 

BWRVIP reports should be “-A.” For example, 

“BWRVIP-75-A,” rather than “BWRVIP-75A.”

This occurs not only throughout the body of 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

Conforms with 

numbering pra
NUREG-1950 IV-252 April 2011

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Reference No.

Comment NRC Disposition Tech

the program text, but also for BWRVIP reports 

cited in the references section.

have been made.

380 XI.M8 

ML101830255 

Comment 

XI.M8-1 

The program scope should be revised to 

include the CRD housing and incoremonitoring housing (ICMH) penetrations. 

These components are addressed by 

BWRVIP-47-A*.

Also;

NUREG-1801 item IV.A1.RP-370 should be 

revised to show the aging management 

program to be XI.M8, “BWR Penetrations” and 

XI.M2, “Water Chemistry.”

The staff should also clarify the components 

addressed by this line item. Reference to the 

component locations should be to incore

monitoring housings (ICMH) and CRD stub 

tubes, which are BWR vessel penetrations. 

Finally, It is unclear what the staff “intends by 

jet pump nozzles.” It is assumed that the staff 

is referring to jet pump instrument line 

penetrations and not the jet pump 

recirculation line nozzles which are full 

penetration welded nozzles.

The inspection approach and conclusions for 

the CRD housing penetrations and ICMH 

penetrations mirror those for instrument 

penetrations addressed in BWRVIP-49-A. 

These are ASME Class 1 pressure-retaining 

components.

XI.M8 addresses pressure vessel 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Incore monitor

CRD stub tube

BWRVIP-47-A 

included in the 

GALL Report, 

(IV.A1-5(R-69)

addressed “jet 

penetrations. T

inadvertently d

GALL Report, 

was created.
April 2011 IV-253 NUREG-1950

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Comment 

Number

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Commenter 

Reference No.

Comment NRC Disposition Tech

penetrations. XI.M8 acknowledges that 

BWRVIP guidance (e.g., BWRV1P-49-A and 

BWRVIP-74-A) conclude that penetration 

locations do not require augmentation of the 

ASME Section XI inspection requirements.

Additionally, these pressure boundary 

components are not, and should not be, 

managed by the XI.M9 BWR Reactor 

Internals” program.

Supporting References:

BWRVIP-74-A 

BWRVIP-47-A* 

BWRVIP-49-A 

EPRI 1018111

* Note: BWRVIP-47-A also addresses nonpressure retaining locations.

381 XI.M8 

ML101830255 

Comment 

XI.M8-2 

The discussion related to ASME Section XI 

examination categories in the detection of 

aging effects section could be misinterpreted 

and should be simplified to eliminate 

reference to the specific categories (e.g., B-D, 

B-F, B-P).

This content is somewhat confusing for a 

program focused on BWR penetrations since 

categories B-D, B-F, and B-J are not 

applicable to the components crediting this 

program. It is suggested that this superfluous 

content be removed.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Categories B-D

not applicable 

crediting this p

reference to th

instead revised 

Examination C

volumetric exa

(ultrasonic tes

testing), surfac

methods (liqui

or magnetic pa

ferritic compon

visual examina
NUREG-1950 IV-254 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

382 XI.M8 

ML101830255 

Comment 

XI.M8-3 

The corrective actions section should not 

reference BWRVIP repair design criteria.

Although BWRVIP repair design criteria 

provide criteria for repairs, aging management 

strategies for repairs are provided by the 

repair designer, not the BWRVIP. For 

pressure retaining components, repairs must 

meet the requirements of the ASME B&PVC. 

Also see general comments contained in the 

main body of the comment letter transmitting 

these comments.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Disagree with 

BWRVIP; how

revised for cla

repairs in acco

Code are acce

383 XI.M8 

ML101830255 

Comment 

XI.M8-4 

All references to the NRC approved version of 

BWRVIP reports should be “-A.” For example, 

“BWRVIP-49-A,” rather than “BWRVIP-49A.”

This occurs not only throughout the body of 

the program text, but also for BWRVIP reports 

cited in the references section.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Conform with 

practices.

155 XI.M9

ML101830328 

Comment 

XI.M9-1 

General Comment on Program - 

The BWR Vessel Internals Program, as 

defined in Rev. 1 of GALL, described the 

BWRVIP including inspection and flaw 

evaluation of vessel internals components in 

conformance with the guidelines of applicable 

and staff-approved boiling water reactor 

vessel and internals project (BWRVIP) 

documents. The staff proposed changes to 

this program for GALL, Rev.2, add component 

aging management guidelines that are outside 

the guidance of the BWRVIP.

Specifically, the changes proposed by the 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The staff agree

to the AMP are 

guidance of th

believes that t

for BWR intern

The BWRVIP-

integrated via 

approval.

When industry 

on manageme

embrittlement 

will review for 
April 2011 IV-255 NUREG-1950

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Draft GALL Report, Rev. 2

Comment 

Number

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Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

staff add aging management guidelines for 

two MEAP combinations; 

(1) the guidance for CASS internals 

components exposed to reactor coolant and 

neutron flux formerly addressed in GALL, 

Rev. 1, XI.M13, Thermal Aging and Neutron 

Irradiation Embrittlement of Cast Austenitic 

Stainless Steel (CASS) ; and 

(2) guidance for X-750 alloy, and precipitationhardened (PH) martensitic stainless steel 

internals components exposed to reactor 

coolant and neutron flux that (according to the 

draft GALL master item RP-182) appear to be 

the subject of a new (but unidentified) ISG.

BWRVIP-234, Thermal Aging and Neutron 

Embrittlement Evaluation of Cast Austenitic 

Stainless Steels for BWR Internals, was 

issued in December 2009, and (presumably) 

is under staff review. This BWRVIP document 

would include the GALL, Rev. 1, XI.M13 

guidance within the BWRVIP program, but 

BWRVIP-234 has not been accepted by the 

staff and is not mentioned in the staff 

proposed changes to XI.M9. Until, the 

BWRVIP-234 is accepted, XI.M13 should 

remain a separate GALL program.

The guidance for X-750 alloy, and 

precipitation-hardened (PH) martensitic 

stainless steel internals components exposed 

to reactor coolant and neutron flux, should be 

established as a separate GALL program if 

incorporation.
NUREG-1950 IV-256 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

appropriate, but should not be added to XI.M9 

unless it is eventually addressed by the 

BWRVIP. Suggest adding “in accordance with 

industry and NRC staff-approved guidance” in 

elements 3, 5 and 6 to allow use of BWRVIP 

guidance when developed that will eliminate 

and exception.

156 XI.M9

ML101830328 

Comment 

XI.M9-2 

Typo for ‘ASME’ in element 4. The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

No technical b

incorporate thi

(typographical 

editorial in nat

157 XI.M9

ML101830328 

Comment 

XI.M9-3 

In the Program Description, for many BWRs, 

the actual Mb [i.e., Mo] content is not given on 

the CMTRs. It was not the practice to sample 

for Mb, especially in the early years of nuclear 

construction, unless Mb was specified as an 

additive. Consequently, there is no way to 

verify the measured Mb. It is safe to assume 

that Mb was not added to material unless 

required. Therefore, CF3, CF3A, CF8, CF8A 

can be assumed to be low-molybdenum 

steels without testing. This is consistent with 

EPRI guidance in TR 100976. See suggested 

revisions below. (pgs. 26-27 of 

ML101830328)

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

NRC does not 

verification. 

384 XI.M9 

ML101830255 

Comment 

XI.M9-1 

The program discussion should be clarified to 

indicate that the BWRVIP program manages 

not only cracking due to SCC or IASCC, but 

also cracking due to fatigue (e.g., steam dryer 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

Cracking due t

make the AMP 

AMR item IV.B

new line for los
April 2011 IV-257 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

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Commenter 

Reference No.

Comment NRC Disposition Tech

assembly) and loss of material (e.g., wear of 

jet pump wedges).

AMR line Item IV.B1.RP-155 lists cracking 

due to flow induced vibration (fatigue) as 

applicable to steam dryers.

Wear occurs in some BWR reactor internals 

components, for example jet pump wedge 

surfaces.

have been made. wear because 

effect for jet pu

which are in sc

385 XI.M9 

ML101830255 

Comment 

XI.M9-2 

Martensitic stainless steel and precipitation 

hardened martensitic stainless steel materials 

have been added to XI.M9, “BWR Reactor 

Internals.” Additionally, these materials have 

been added as aging management review 

items for BWR reactor internals. These 

materials should not be included in NUREG1800 and NUREG- 1801 for BWR reactor 

internals since they are not known by the 

BWRVIP to be in use in the domestic BWR 

fleet in passive and long-lived reactor 

internals applications.

Applicable Sections:

Program Description 

Scope

Parameters Monitored / Inspected

Operating Experience IV.B1.RP-182

The BWRVIP is unaware of the application of 

these martensitic stainless steel materials in 

the domestic BWR fleet. As a result, the 

related discussion in NUREG-1801, Section 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

This is include

potential future 

replacement a

BWR fleet. Th

applicants by h

materials listed 

Report. 
NUREG-1950 IV-258 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

XI.M9 and the associated aging management 

review items is not appropriate for inclusion in 

NUREG-1800 or NUREG-1801.

There are a number of source references 

available to the staff as bases:

- Revision 1 of the BWR Issue Management 

Tables (EPRI 1018111) is a non-proprietary 

report available to the staff. Table A-2 in 

Appendix A of this report contains a listing of 

BWR reactor internals and associated 

materials of construction. Neither martensitic 

stainless steels nor precipitation hardened 

martensitic stainless steels are Included. The 

materials listing in this document is based on 

a review of BWRVIP reports and available 

license renewal documentation.

- The BWRVIP has submitted numerous 

inspection and evaluation guideline 

documents to the staff for review and 

approval. These documents can be reviewed 

by the staff to confirm that martensitic 

materials are not in use within the BWR fleet.

- A majority of domestic BWR units have 

submitted license renewal applications to 

NRC, including all major design types 

(BWR/2s through BWR/6s). To date, 

martensitic stainless steel has not been 

identified as material of construction for a 

BWR reactor internals application.

Supporting References: EPRI 1018111
April 2011 IV-259 NUREG-1950

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Draft GALL Report, Rev. 2

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Number

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Commenter 

Reference No.

Comment NRC Disposition Tech

386 XI.M9 

ML101830255 

Comment 

XI.M9-3 

BWRVIP repair design criteria listed in the, 

program scope section should be removed.

Although BWRVIP repair design criteria 

provide criteria for repairs, aging management 

strategies for repairs are provided by the 

repair designer, not the BWRVIP and repair 

design criteria should not be credited by 

XI.M9. As discussed previously, citation of 

repair design criteria as supporting references 

is acceptable.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Although staff 

the comment, 

revised to clar

“Although BW

criteria provide 

aging manage

repairs are pro

designer, not t

387 XI.M9 

ML101830255 

Comment 

XI.M9-4 

BWRVIP-07 and BWRVIP-63 have been 

superseded by BWRVIP-76-A and should be 

removed from the program scope discussion 

and references section. BWRVIP-76-A is the 

current reference.

BWRVIP-76-A has been published and a non 

proprietary version provided to NRC.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Revised to ref

approved BWR

388 XI.M9 

ML101830255 

Comment 

XI.M9-5A

NRC should reference BWRVIP-183 as the 

applicable guidance for aging management of 

top guide grid structures. Otherwise, the 

BWRVIP has the following comments on the 

top guide grid structure content in XI.M9.

The program scope section discussing top 

guide grid beam inspections:

a) Is not clear regarding the surfaces to be 

inspected. Inspections are limited to more 

susceptible portions of the grid beam and are 

dependent on top guide vintage.

The top guide grid inspection program 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

BWRVIP-183 

approved by th

appropriate to 

this time. XI.M

Internals” will b

some informat

BWRVIP “Bas

when BWRVIP

the staff, the p

BWRVIP-183 

into the AMP a

The staff does 

locations for in
NUREG-1950 IV-260 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

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Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

requirements summarized in XI.M9 appear to 

be associated with a specific plant design 

rather than the entire BWR fleet. Reinspection frequency and scope are warranted 

based on differences in susceptibility of the 

various designs currently in service. The 

BWRVIP recommends that NRC cite 

BWRVIP-183, with acknowledgement of 

outstanding NRC RAIs, as the most direct 

method for communicating the top guide grid 

structure inspection program. Otherwise, the 

BWRVIP recommends clarifications to XI.M9 

as follows: 

a. BWRVIP-183 prescribes the examination 

area to include:

BWR/2-5 — Inspect the bottom 2 inches (50.8 

mm) of the interior side surfaces of the grid 

beam cells and locations at the intersections 

of the grid beams near the slotted notch 

where a sharp corner exists. Inspection of the 

bottom edge of the grid beams is not required.

BWR/6 — Inspect rim areas containing the 

weld and heat affected zone (HAZ) from the 

top surface of the top guide and two cells in 

the same plane/axis as the weld. The regions 

of the grid beam cells to be inspected are the 

bottom 2 inches (50.8 mm) of the interior side 

surfaces. Inspection of the bottom edge of the 

grid cells is not required.

Supporting References:

does describe 

criteria for app

determine loca

inspection
April 2011 IV-261 NUREG-1950

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Number

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Comment NRC Disposition Tech

BWRVIP-183

389 XI.M9 

ML101830255 

Comment 

XI.M9-6 

The program description includes discussion 

of screening criteria for CASS. This content 

was previously addressed in revision 1 of the 

GALL Report as a separate program, XI.M13. 

This discussion should clarify that the 

screening criteria described is NRC-based 

criteria and not a part of the BWRVIP 

program.

This discussion implies that the BWRVIP 

program includes screening criteria for CASS 

consistent with the May 19, 2000 

correspondence from NRC (Grimes) to NEI 

(Walters). The BWRVIP program does not 

include these screening criteria as basis for 

inspection of CASS reactor internals. To 

address this concern for BWR reactor 

internals, the BWRVIP performed a screening 

of CASS reactor internals to identify those 

castings which meet the screening criteria for 

augmented examination based not only on 

casting chemical properties, but also on 

fluence and component loading. Based on this 

review, no castings require augmented 

examination for 60-year service lives. The 

technical report containing this screening, 

BWRVIP-234 has been submitted to the staff 

for information only.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The screening 

in addition to B

needs to be su

aging of CASS 

390 XI.M9 

ML101830255 

The parameters monitored / inspected section 

contains a paragraph addressing 

The staff disagrees 

with this comment. 

The GALL Report 

Will retain disc

fracture tough
NUREG-1950 IV-262 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

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Reference No.

Comment NRC Disposition Tech

Comment 

XI.M9-7A

management of CASS reactor internals.

a. This paragraph includes wording implying 

that BWR CASS reactor internals may be 

subject to void swelling effects. This wording 

should be removed.

a. Operating temperatures and fluence 

exposure for CASS materials are not 

conducive to void nucleation and growth. This 

conclusion is supported by expert panel 

studies of aging mechanisms, EPRI 1016486 

and NUREG/CR-6928.

Supporting References.:

EPRI 1016486, EPRI Materials Degradation 

Matrix — Revision 1.

NUREG/CR-6923, Expert Panel Report on 

Proactive Materials Degradation Assessment

EPRI 1018111, BWR Issue Management 

Tables — Revision 1

[Note: EPRI 1016486 and 1018111 are nonproprietary and available to the NRC staff for 

review.]

has not been 

changed.

swelling, as it 

391 XI.M9 

ML101830255 

Comment 

XI.M9-8 

Wording in the detection of aging effects 

section implies that augmented inspection of 

limiting CASS locations is recommended 

regardless of the results of screening. The 

BWRVIP disagrees. Unless special 

circumstances apply, augmented examination 

of CASS is not required.

Applicable Sections:

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Element 4, 3rd 

sentence to be 

change to “ma

inspection only 

screening crite

BWRVIP 234 

reviewed by th

NRC review, if 
April 2011 IV-263 NUREG-1950

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Number

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Comment NRC Disposition Tech

Detection of Aging Effects 

IV.B1.RP-219

IV.B1.RP-220

BWRVIP-234 documents the results of an 

EPRI BWRVIP study of CASS reactor internal 

components. This evaluation concludes that 

all the BWR CASS reactor internals 

components have ferrite levels below the level 

for which thermal aging embrittlement is a 

concern. Although the end-of-life fluence for 

the orificed fuel support and the jet pump 

assembly castings exceed the threshold, 

toughness data for irradiated austenitic 

stainless steels show that that these 

components will have sufficient fracture 

toughness at the end of license renewal 

period so that augmented inspection is not 

required. The report concludes that 

augmented inspections are not required for 

the BWR CASS reactor internals. BWRVIP234 has been submitted to the staff for 

information only.

inspection is re

process will be 

Although these 

made, they did 

technical inten

by the staff as 

change.

392 XI.M9 

ML101830255 

Comment 

XI.M9-9 

The acceptance criteria section describes flaw 

evaluation criteria for CASS reactor internals 

that come from ASME Code, specifically IWB3640. The staff should consider removing this 

language.

ASME Section XI, Subsection IWB-3640 

addresses flaw tolerance assessment for 

austenitic pressure retaining piping. These 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

ASME Section 

non-mandator

accept non-ma

appendices.
NUREG-1950 IV-264 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

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Reference No.

Comment NRC Disposition Tech

requirements are not appropriate for reactor 

internals components. Further, the 14% ferrite 

restriction is considered to be overly 

restrictive. ASME Section XI, Section C-4000 

allows evaluation of CASS similar to wrought 

materials if ferrite is less than 20%.

Depending on the plant vintage and 

component being evaluated, the casting may 

or may not be considered an ASME Code 

component. Therefore, application of pressure 

retaining piping criteria to all reactor internals 

castings is not appropriate.

Based on the screening assessment 

documented in BWRVIP-234 and on the 

foregoing points, the BWRVIP maintains that 

specific acceptance criteria for CASS BWR 

reactor internals components is not warranted 

in the GALL Report.

393 XI.M9 

ML101830255 

Comment 

XI.M9-10

NUREG-1801 AMR item IV.B1-RP-200 

describes loss of fracture toughness due to 

thermal aging / irradiation embrittlement for X750 BWR reactor internals. This line Item 

should be revised to include only irradiation 

embrittlement.

Some X-750 reactor internals components will 

be exposed to significant EOL neutron fluence 

and some irradiation

embrittlement could occur. To address both 

irradiation effects and other concerns, the 

BWRVIP is initiating a new testing program for 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The staff agree

provided by th

agrees to dele

from this item.
April 2011 IV-265 NUREG-1950

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Draft GALL Report, Rev. 2

Comment 

Number

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Reference No.

Comment NRC Disposition Tech

alloy X-750 materials. If necessary, program 

requirements for X-750 will be revised based 

on the results of this test program. X- 750 jet 

pump beams are managed by BWRVIP-41 

and BWRVIP-138. Management of repair 

hardware is addressed by the repair vendor.

However, regarding thermal aging, the 

BWRVIP is not aware of any data that would 

support the assertion that X-750 is susceptible 

to loss of fracture toughness due to thermal 

aging, Supporting basis documents include 

the NUREG/CR-6923, “Expert Panel Report 

on Proactive Materials Degradation 

Assessment” and EPRI 1016486, “Materials 

Degradation Matrix, Revision 1.” The expert 

assessments documented in these reports do 

not identify thermal aging and loss of fracture 

toughness as specific concerns for BWR 

reactor internals components.

(Note: EPRI 1016486 is non-proprietary and 

available to the NRC staff for review.]

394 XI.M9 

ML101830255 

Comment 

XI.M9-11

The preventive actions section discussion for 

water chemistry should simply refer to 

program XI.M2.

Specific reference to a version of the EPRI 

BWR Water Chemistry Guidelines and 

discussion regarding control parameter tables 

should be limited to XI.M2 and need not be 

repeated in XI.M9.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Change make

wording consis

GALL AMPs. T

view this as a 

change.

395 XI.M9 The monitoring and trending section omits The staff agrees with These are vali
NUREG-1950 IV-266 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

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Comment NRC Disposition Tech

ML101830255 

Comment 

XI.M9-12

BWRVIP-80-A and BWRVIP-99-A.

BWRVIP-80-A provides CGR curves for 

shroud vertical welds. BWRVIP-99-A provides 

CGR curves for irradiated stainless steels.

this comment and 

associated changes 

to the GALL Report 

have been made.

GALL AMP.

396 XI.M9 

ML101830255 

Comment 

XI.M9-13

The last sentence of the first para. in the 

detection of aging effects section may be 

misleading and should be changed to: 

“BWRVIP program requirements provide for 

inspection of BWR reactor internals to 

manage loss of material and cracking using 

appropriate examination techniques, such as 

visual examinations (e.g., EVT-1, VT- 1) and 

volumetric examinations (e.g., UT).”

As written, the sentence implies that only nonASME Code BWR reactor internals are 

inspected per BWRVIP guidance and that 

only cracking is detectable by BWRVIP 

examinations. This is misleading. BWRVIP 

examination requirements apply to many 

BWR reactor internals components, 

regardless of ASME Code classification and 

are also capable of detecting loss of material 

(e.g., wear) as applicable to the component. 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Deleted “non-A

replace with “B

that BWRVIP e

apply to BWR 

of Code categ

397 XI.M9 

ML101830255 

Comment 

XI.M9-14

The operating experience section discussion 

for core plate should be clarified to note that 

inspections of the core plate assembly itself 

are not required. Only core plate bolts or core 

plate retaining wedges require inspection. 

There are not BWRVIP program inspection 

requirements for creviced regions beneath the 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Clarified that in

core plate ass

required, but o

or retaining we

appropriate.
April 2011 IV-267 NUREG-1950

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Draft GALL Report, Rev. 2

Comment 

Number

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Reference No.

Comment NRC Disposition Tech

core plate.

BWRVIP-06R1-A and BWRVIP-25 address 

the safety significance and inspection 

requirements for the core plate assembly. 

Only inspection of core plate bolts (for plants 

without retaining wedges) or inspection of the 

retaining wedges is required.

398 XI.M9 

ML101830255 

Comment 

XI.M9-15

The operating experience section sentence 

addressing dry tubes should delete “CRD” 

immediately preceding “dry tubes.”

Reference to “CRD dry tubes” is misleading. 

Dry tubes are associated with incoremonitoring, not CRD. 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Dry tubes are 

incore-monitor

399 XI.M9 

ML101830255 

Comment 

XI.M9-16

Notable BWR reactor internals operating 

experience missing from the operating 

experience discussion section are listed at 

right.

Core spray pipe cracking. (in addition to core 

spray sparger cracking) 

X-750 jet pump hold down beam cracking. 

Shroud support cracking.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

BWRVIP-18 a

pipe cracking. 

observed in X-

pump hold-dow

400 XI.M9 

ML101830255 

Comment 

XI.M9-17

BWRVIP-29 has been superseded by 

BWRVIP-190 and should be removed from 

the references list.

BWRVIP-190 is the current version of the 

EPRI BWR Water Chemistry Guidelines. This 

version represents the present state of 

industry knowledge regarding management of 

BWR water chemistry. As a minimum, all 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

A specific revis

guideline need

The staff cann

to any later rev

chemistry stan

provided guide

revisions of ind

preamble to G
NUREG-1950 IV-268 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

references to water chemistry guidance in 

NUREG-1801 should be revised to cite 

BWRVIP-190. However, the EPRI BWR 

Water Chemistry Guidelines are periodically 

revised to incorporate recent operating 

experience and to address new and improved 

mitigation techniques (e.g., online 

noblechemTM[)]. Based on NEI 03-08, owners 

are required to update their programs to the 

latest needed and mandatory guidance 

contained in these guidelines. Therefore, 

when possible, reference should cite the 

“EPRI BWR Water Chemistry Guidelines.” 

Otherwise, the reference citations for the 

EPRI BWR Water Chemistry Guidelines will 

become out of date relatively soon.

XI.

401 XI.M9 

ML101830255 

Comment 

XI.M9-18A

IV.B1.R-94 addresses nickel-alloy access 

hole cover components (welded). This line 

item should:

a) Include stainless steel materials of 

construction and,

BWRVIP-180 provides aging management 

requirements for access hole covers. 

BWRVIP-180 has been provided to NRC.

a) Stainless steels are commonly used in 

access hole cover designs. See EPRI 

1018111, BWR Issue Management Tables, 

Revision 1.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Stainless stee

access hole co

402 XI.M9 

ML101830255 

IV.B1.R-95 addresses nickel-alloy mechanical 

access hole cover components. This line Item 

The staff agrees with 

this comment and 

EPRI 1018111

Management T
April 2011 IV-269 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

Comment 

XI.M9-19A 

should:

a) Also include stainless steel materials of 

construction,

a) EPRI 1018111, “BWR Issue Management 

Tables – Revision 1” identifies XM-19 nitrogen 

strengthened stainless steel as an applicable 

material for replacement access hole cover 

materials.

associated changes 

to the GALL Report 

have been made.

identifies XM-1

strengthened s

applicable mat

access hole co

403 XI.M9 

ML101830255 

Comment 

XI.M9-20

All references to the NRC approved version of 

BWRVIP reports should be “-A.” For example, 

“BWRVIP-47-A,” rather than “BWRVIP-47A.”

This occurs not only throughout the body of 

the program text, but also for BWRVIP reports 

cited in the references section.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

This change w

conform to BW

practices, altho

viewed as a no

change and is 

Table II-21.

777 XI.M9

ML101830328 

Comment 

XI.M9-4 

The statement about not actually monitoring 

reduction in fracture toughness that was 

added to Element 3 is good. I suggest it 

should also be included in the program 

description.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

No need for re

Element 3 is a

location to disc

778 XI.M9 

ML101830328 

Comment 

XI.M9-5 

In SCOPE related to top guides. Every BWR 

will exceed the fluence threshold prior to the 

PEO. Most BWRs exceed this threshold in the 

4th or 5th fuel cycle. Eliminate the paragraph 

for those plants that haven’t reached the 

threshold and make the first paragraph the 

only option.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Most BWRs ex

in the 4th or 5t

779 XI.M9 

ML101830328 

Comment 

Make the PREVENTIVE ACTIONS section 

read like all the other condition monitoring 

programs. See comments on XI.M4.

The staff agrees with 

this comment and 

associated changes 

Makes it consi

GALL AMPs. T

clarification an
NUREG-1950 IV-270 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

XI.M9-6 to the GALL Report 

have been made.

the technical in

Therefore, no 

needed.

780 XI.M9 

ML101830328 

Comment 

XI.M9-7 

The footnote in Element 3 about using 

different ASME code versions is different than 

the footnote in other AMPs. Use the same 

footnote in all AMPs unless there is a different 

meaning intended.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Makes it consi

GALL AMPs. T

clarification an

the technical in

Therefore, no 

needed

1019 XI.M9

ML101830255 

Comment 

XI.M9-5B

NRC should reference BWRVIP-183 as the 

applicable guidance for aging management of 

top guide grid structures. Otherwise, the 

BWRVIP has the following comments on the 

top guide grid structure content in XI.M9.

The program scope section discussing top 

guide grid beam inspections:

b) Is not clear regarding inspection scope and 

re-inspection frequency. Re-inspection is 

dependent on top guide vintage. A single 

inspection frequency is not warranted for all 

top guide grid designs.

The top guide grid inspection program 

requirements summarized in XI.M9 appear to 

be associated with a specific plant design 

rather than the entire BWR fleet. Reinspection frequency and scope are warranted 

based on differences in susceptibility of the 

various designs currently in service. The 

BWRVIP recommends that NRC cite 

BWRVIP-183, with acknowledgement of 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Information fro

“Basis” will be 

AMP as the re

and frequency 

the circumstan
April 2011 IV-271 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

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Commenter 

Reference No.

Comment NRC Disposition Tech

outstanding NRC RAIs, as the most direct 

method for communicating the top guide grid 

structure inspection program. Otherwise, the 

BWRVIP recommends clarifications to XI.M9 

as follows: 

b. BWRVIP-183 prescribes re-inspection 

scope and frequency as follows:

BWR/2-5 - Inspect 10% of the grid beam cells 

containing CRDs/blades every twelve years 

with at least 5% to be performed within six 

years.

BWR/6 - Inspect the rim areas containing the 

weld and heat affected zone (HAZ) from the 

top surface of the top guide and two cells in 

the same plane/axis as the weld every six 

years.

Supporting References:

BWRVIP-183

1020 XI.M9 

ML101830255 

Comment 

XI.M9-7B

The parameters monitored / inspected section 

contains a paragraph addressing 

management of CASS reactor internals.

b. Wording related to inspection of CASS 

should be clarified: “...The impact of loss of 

fracture toughness on component integrity 

can be managed by ASME Section XI 

inspections that monitor for cracking in the 

components...”

b. BWRVIP program inspections are not 

focused on detection of loss of fracture 

toughness, but are acknowledged to be 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

No technical b

incorporate thi

split for clarity) 

nature.
NUREG-1950 IV-272 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

capable of detecting significant cracking of 

CASS components. Presently, only visual 

inspection is possible. • Further, BWRVIP 

inspection and evaluation guidelines do not 

explicitly require augmented inspection of 

CASS components. ASME Section XI 

inspection requirements are considered 

adequate.

Supporting References.:

EPRI 1016486, EPRI Materials Degradation 

Matrix — Revision 1.

NUREG/CR-6923, Expert Panel Report on 

Proactive Materials Degradation Assessment

EPRI 1018111, BWR Issue Management 

Tables — Revision 1

[Note: EPRI 1016486 and 1018111 are nonproprietary and available to the NRC staff for 

review.]

1021 XI.M9 

ML101830255 

Comment 

XI.M9-18B

IV.B1.R-94 addresses nickel-alloy access 

hole cover components (welded). This in item 

should:

b) Should specify aging management 

consistent with BWRVIP guidance contained 

in BWRVIP-180, which allows for either UT 

examination or EVT-1 visual examination on 

intervals depending on both inspection 

technique and chemistry regime (NWC vs. 

HWC/ NMCA).

BWRVIP-180 provides aging management 

requirements for access hole covers. 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

BWRVIP-180 

Following staff 

approval of BW

incorporated v

GALL.
April 2011 IV-273 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

BWRVIP-180 has been provided to NRC.

b) BWRVIP-180 specifies examination 

requirements for all access hole cover 

designs. Inspection techniques include both 

Enhanced visual (EVT-1) and volumetric (UT) 

examination of welds. Application of 

inspection techniques is dependent on access 

hole cover design and on operating chemistry 

regime. Longer re-inspection intervals are 

allowed for plants operating under hydrogen 

water chemistry technologies, than for plants 

operating under normal water chemistry. This 

approach is described in BWRVIP-180. This 

guidance has been approved by the BWRVIP 

Executive Committee and is being 

implemented by the BWRVIP membership. 

However, the aging management program

requirement included in the GALL Report is 

not consistent with the BWRVIP program.

It should also be noted that BWRVIP-180 

addresses not only aging management for 

nickel-alloy materials, but also addresses 

SCC susceptible stainless steel locations. The 

GALL Report guidance should also 

acknowledge this BWRVIP program 

inspection requirement.

1022 XI.M9

ML101830255 

Comment 

XI.M9-19B

IV.B1.R-95 addresses nickel-alloy mechanical 

access hole cover components. This line Item 

should:

b) Clarify that the line item includes 

mechanically repaired access hole covers 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The AMR item 

mechanical co

repairs. The ite

welds and wel
NUREG-1950 IV-274 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

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Commenter 

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Comment NRC Disposition Tech

(including the repaired welds) and,

b) BWRVIP-180 specifies VT-1 examination of 

the mechanical repair hardware as adequate 

aging management for the access hole cover 

assembly. Enhanced visual and volumetric 

examination of welds repaired by mechanical 

means no longer require inspection. This 

approach is described in BWRVIP-180 and is 

consistent with the approach used for 

mechanical repairs associated with other 

BWR internals assemblies. Therefore, this line 

item addresses not only the mechanical repair 

components, but also the repaired welds. 

1023 XI.M9

ML101830255 

Comment 

XI.M9-19C

IV.B1.R-95 addresses nickel-alloy mechanical

access hole cover components. This line Item 

should:

c) Include aging management consistent with 

BWRVIP guidance contained in BWRVIP-180.

c) The AMP specified is XI.M2, “Water 

Chemistry” and XI.M1, “ASME Section XI 

Inservice Inspection, Subsections IWB, IWC, 

and IWD” for Class 1 Components.” ASME 

Section XI required inspections would include 

only a VT-3 visual examination of accessible 

surfaces once each 10-year interval. The 

BWRVIP requirement defined in BWRVIP-180 

is a VT-1 of the access hole cover top surface 

on 8-year intervals. The program 

recommended by the BWRVIP Is XI.M2 and 

XI.M9, “BWR Reactor Internals,” with 

modifications to XI.M9 to address access hole 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

BWRVIP-180 

Following staff 

approval of BW

incorporated v

Report.
April 2011 IV-275 NUREG-1950

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

cover management consistent with BWRVIP180.

1228 XI.M41

ML101930270, 

Comment 

XI.M41-1 

[This comment states that ductile iron pipe 

should not be excluded from AMP XI.M41.]

According to studies reviewed by Beyond 

Nuclear, polyethylene coating used in

conjunction with cathodic protection is 

determined to be the most effective age

management and cost-effective control 

method for external corrosion of buried

ductile'iron pipes which are clearly within the 

scope of passive structures that require 

adequate Age Management Programs.

However, the most effective AMP for external 

corrosion of buried pipe systems is to 

abandon all buried and below-grade 

applications for replacement with above 

grade, stainless steel and vaulted systems.

Therefore, the NRC should not provide an 

exemption from AMP for buried pipe systems 

fabricated of ductile iron.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The staff conc

commenter tha

pipe should be 

XI.M41 and th

pipe is subject 

similar to stee

notes that, due 

wall thickness 

present in cas

expectancy of 

may exceed a 

Notwithstandin

difference in w

definition for “s

chapter 9 of th

includes carbo

steel and cast 

ductile iron. A

definition, a giv

subject to the 

aging manage

actions and ins

irrespective of 

constructed fro

iron. This stat

however, imply 

pipe or a ducti

scope drain sy

will receive the 
NUREG-1950 IV-276 April 2011

Table IV-12. Analysis and Disposition of Public Comments on Chapter XI Mechanical AMPs, May 2010 Pu

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

management a

Class 3 pipe o
April 2011 IV-277 NUREG-1950

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Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

208 XI.S1

ML101830328 

Comment 

XI.S1-6 

References: References [EPRI NP-5067, 

EPRI NP-5769 and EPRI TR 104213] do not 

apply to this program.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The reference

useful for the h

if applicable.

899 XI.S1 

ML101830328 

Comment 

XI.S1-1 

Program Description: (1) GL 98-04 and XI.S1 

ASME Section XI, Subsection IWE are 

appropriate for maintaining and monitoring 

coatings inside containment. (2) This increase 

in scope which in Element 4 requires “surface 

examination, in addition to visual examination 

to detect cracking ..” is not supported by two 

OEs cited; one OE on bellows addresses 

stainless steel cracking as result of 

contamination and the other OE addresses 

which is torus cracking apparently due to a 

design issue “lack of an HPCI turbine exhaust 

pipe sparger.” The industry OE does not show 

cracking of penetration sleeves, associated 

steel components and bellows due to cyclic 

loads to be a problem which would warrant an 

augmented requirement for a supplemental 

surface examination. The proposed new 

requirement is above and beyond the 

requirement of ASME Code Section XI, IWE 

and 10CFR50.55a. We believe ASME Section 

XI-IWE and 10CFR 50, Appendix J provide 

adequate requirement for inspection of 

penetration components. 

We recommend that this new requirement be 

eliminated or at the most limited to bellows for 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Limited to Exa

E-F (1992E & 

metal welds an

Allowed the us

vent line bellow
NUREG-1950 IV-278 April 2011

Table IV-13. Analysis and Disposition of Public Comments on Chapter XI Structural AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

cyclic loads and possibly stainless steel and 

dissimilar metal welds for SCC. Carbon steel 

penetration sleeves, closures and fluid heads 

should not be subject to augmented 

supplemental surface examinations.

900 XI.S1 

ML101830328 

Comment 

XI.S1-2 

Element 1: GL 98-04 and XI.S1 ASME 

Section XI, Subsection IWE are appropriate 

for maintaining and monitoring coatings inside 

containment.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The coatings p

related to subs

examination o

corrosion. The 

(Protective Co

Maintenance P

different purpo

coating integri

operability. 

901 XI.S1 

ML101830328 

Comment 

XI.S1-3 

Element 2: The above EPRI and NUREG 

bolting recommendations as listed, appear to 

be design and installation and maintenance 

procedural recommendations more than 

Aging Management Program changes. A 

change of bolting material, torque, tension or 

lubricant selections for a specific application 

would likely require a design change. OE 

does not show degradation and failure of IWE 

bolting, except for the limited specific OE on 

large HS bolts of specific limited application 

bolting material for NSSS IWE supports. 

Other changes do not appear necessary or 

warranted by industry experience and OE. 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

High-strength 

for pressure-re

in containmen

preventive act

structural bolti

using Researc

Structural Con

publication.

902 XI.S1 

ML101830328 

Element 4: This increase in scope which 

requires “surface examination, in addition to 

The staff agrees with 

this comment and 

Limited to bello

and possibly s
April 2011 IV-279 NUREG-1950

Table IV-13. Analysis and Disposition of Public Comments on Chapter XI Structural AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

Comment 

XI.S1-4 

visual examination to detect cracking ..” is not 

supported by two OEs cited; one OE on 

bellows addresses stainless steel cracking as 

result of contamination and the other OE 

addresses which is torus cracking apparently 

due to a design issue “lack of an HPCI turbine 

exhaust pipe sparger.” The industry OE does 

not show cracking of penetration sleeves, 

associated steel components and bellows due 

to cyclic loads to be a problem which would 

warrant an augmented requirement for a 

supplemental surface examination. The 

proposed new requirement is above and 

beyond the requirement of ASME Code 

Section XI, IWE and 10CFR50.55a. We 

believe ASME Section XI-IWE and 10CFR 50, 

Appendix J provide adequate requirement for 

inspection of penetration components. 

We recommend that this new requirement be 

removed or at the most limited to bellows for 

cyclic loads and possibly stainless steel and 

dissimilar metal welds for SCC. Carbon steel 

penetration sleeves, closures and fluid heads 

should not be subject to augmented 

supplemental surface examinations.

associated changes 

to the GALL Report 

have been made.

dissimilar meta

allows the opti

testing. 

903 XI.S1 

ML101830328 

Comment 

XI.S1-5 

Element 10: [In the operating experience

element, degradation of threaded bolting and 

fasteners in closures for the reactor coolant 

pressure boundary from boric acid corrosion, 

SCC, and fatigue loading.] This discussion is 

not relevant to this program.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Since the AMP 

scope of progr

operating expe
NUREG-1950 IV-280 April 2011

Table IV-13. Analysis and Disposition of Public Comments on Chapter XI Structural AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

210 XI.S3

ML101830328 

Comment 

XI.S3-2 

Element 3: Not all high strength bolts are 

susceptible to SCC. 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The provision 

strength bolts 

shown to have 

SCC.

904 XI.S3 

ML101830328 

Comment 

XI.S3-1 

Element 2: This program is a condition 

monitoring program and should not provide 

preventive actions.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

High-strength 

NSSS and pip

components, w

preventive act

A provision of 

for other struct

recommended 

publication.

906 XI.S3 

ML101830328 

Comment 

XI.S3-3 

Element 4: Cracking of high strength bolts is 

not supported by the OE cited for structural 

bolts. Existing OE is for certain material, size, 

torque and lubricant applications only and 

should not be generically applied to all high 

strength bolts of 150 ksi or more. The 

Operating Experience cited in NUREG 1801 

stated “SCC has occurred in high strength 

bolts used for nuclear steam supply system 

component supports (EPRI NP-5769).” The 

above is cited as operating experience in 

XI.M18, XI.S1, XI.S3, XI.S6, and XI.S7. The 

OE cited in NUREG 1801 is NP-5769 (issued 

in 1988) and was found only in certain specific 

materials and specifically for NSSS 

component supports and should not be 

generically applied to all structural high 

strength bolts. In certain cases the failures 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

For structural b

American Insti

Construction (

RCSC discuss

precautionary 

provision of pr

other structura

A325, ASTM A

recommended 

publication.
April 2011 IV-281 NUREG-1950

Table IV-13. Analysis and Disposition of Public Comments on Chapter XI Structural AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

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Reference No.

Comment NRC Disposition Tech

noted were attributed contributing factors 

including use of molybdenum disulfide thread 

lubricant which is considered a corrosive 

environment and is not used in structural steel 

installations. While EPRI NP-5769 Volume 1, 

Table 11-1 does list A490 bolts for ductile 

failures and failure due improper torque, and 

one instance of a special 4140 material with 

200 ksi minimum yield where the A490 

specification was used for heat treatment 

requirements (not an A490 structural bolt) 

where SCC was noted and associated with a 

high preload and borated water environment. 

No SCC failures were noted for commonly 

used materials in Structural Steel bolting 

including A307, A325 or A490 bolts in a 

structural steel application. 

Industry documents including NUREG-1339 

have not identified any determination 

specifically as to the ASTM A-490 material’s 

susceptibility to SCC, but rather a 

determination of the yield stress level at which 

generic materials should be considered for the 

possibility of SCC vulnerability. In order for 

SCC to occur in high strength bolting, three 

parameters must exist; (1) a corrosive 

environment, (2) a susceptible material, and 

(3) high sustained tensile stresses. The 

absence of any one of these three parameters 

eliminates the material’s susceptibility to SCC. 

High Strength Structural Bolts including A490 

bolts are not subject to high-sustained preload 
NUREG-1950 IV-282 April 2011

Table IV-13. Analysis and Disposition of Public Comments on Chapter XI Structural AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

stress and lubricants containing contaminants, 

such as MoS2, are not approved for use. 

Therefore, SCC is not considered an 

applicable aging effect requiring management.

The structural bolting will continue to be 

visually inspected for loss of preload due to 

self loosening and loss of material due to 

corrosion and also visually monitor the 

associated structural steel and connections 

for loss of material or other adverse 

conditions. 

The high strength bolts used for structural 

applications are A325 or A490 Bolts. A325 

bolts have a minimum yield of 92 ksi (unlikely 

to have an actual yield of 150 ksi or more), 

and A490 bolts have a minimum yield of 130 

ksi (potential that some A490 may reach 

actual yield of 150 ksi or more). Most 

structural bolts are 1” or less in diameter, 

however bolts in large girders or supporting 

large equipment may be over 1” diameter. 

Test reports are not generally traceable to 

installation locations. 

The AISC “Guide to Design for Bolted and 

Riveted Joints” Second Edition published in 

2001 addresses this concern in section 4.8 

and concludes that the tests indicate that 

black (not galvanized) A490 bolts can be used 

without problems from “brittle” failures 

(failures due to hydrogen stress cracking or 

SCC) in most environments. It was concluded 
April 2011 IV-283 NUREG-1950

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Draft GALL Report, Rev. 2

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Comment NRC Disposition Tech

that galvanized A490 bolts should not be used 

in structures. This same section also 

concluded that black and galvanized A325 

bolts behave satisfactorily with regard to 

hydrogen stress and SCC in most corrosive 

environments. AISC publications do not 

recommend or require volumetric or surface 

examinations of installed structural bolts for 

SCC. 

This new requirement is above and beyond 

the requirement of ASME Code Section XI, 

IWF. We recommend that this new 

requirement be removed or at the most limited 

to the specific bolting material types identified 

in the OE cited on NSSS supports. Volumetric 

or surface examinations for cracking of high 

strength bolts should not be generically 

imposed for all bolts with actual yield strength 

of 150 ksi or more and greater than 1” 

diameter. Structural high strength bolts, 

including A325 and A490 bolts do not have a 

history of SCC in most environments. 

907 XI.S5 

ML101830328 

Comment 

XI.S5-1 

Comment element 4: Industry guidance found 

in NUREG-1522, NEI 96-03, and ACI 349 

recommend a 5 to 10 year frequency. 

Program inspection frequency should be 

addressed as a part of Maintenance Rule 

implementation. Industry guidance NUREG1522, “Assessment of Inservice Conditions of 

Safety-Related Nuclear Plant Structures, and 

NEI 96-03, “INDUSTRY GUIDELINE FOR 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The staff’s rev

applications in

where the app

very liberal ap

of structure ins

instance, the a

inspecting a st

years. Masonr

weak structure
NUREG-1950 IV-284 April 2011

Table IV-13. Analysis and Disposition of Public Comments on Chapter XI Structural AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

MONITORING THE CONDITION OF 

STRUCTURES AT NUCLEAR POWER 

PLANTS” recommends a 5 to 10 year 

frequency. ACI 349 provides guidance for 

inspecting some structures at greater than a 5 

year frequency. 

Plants have established their maintenance 

rule program including inspection frequency 

based on Maintenance Rule in accordance 

with 10CFR 50.65, “Requirements for 

monitoring the effectiveness of maintenance 

at nuclear power plants.” 10CFR 50.65, “MR,” 

does not require 5 year inspection frequency 

for all the structures. The frequencies of the 

inspections are established based on riskinformed evaluation process relative to their 

significant to public health and safety. As 

such, some structures have inspection 

frequency between 5 to 10 years. And, some 

structures based in their site specific OE are 

inspected even more frequent than every 5 

years. Some structures are already in 5 year 

inspection frequency. For example, Inspection 

of Water Control Structures governed by RG 

1.127 are already conducted on a 5 year or 

more frequently if conditions warrant as 

required by RG 1.127. Concrete Containment 

IWL inspections are also generally performed 

at a 5 year frequency. 

We recommend that this new requirement be 

removed. Imposing 5 year inspection 

and concrete s

of grout and m

to natural and 

environmental 

considers a 5-

reasonable co

scope masonr

Element 4 lang

changed to pro

and now state

masonry walls 

every 5 years, 

more frequent 

where significa

or cracking is o

there is no los

function betwe
April 2011 IV-285 NUREG-1950

Table IV-13. Analysis and Disposition of Public Comments on Chapter XI Structural AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

frequency to all structures and masonry walls 

seems to be extreme measure without any 

bases. The inspection frequency should be 

established based on service and condition 

assessment of each structure in accordance 

with Maintenance Rule 10CFR 50.65. That 

could vary from 5 to 10 years.

214 XI.S6 

ML101830328 

Comment 

XI.S6-2 

Element 2: This program is a condition 

monitoring program and should not provide 

preventive actions.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

For the high-st

associated wit

(XI.S3-IWF) an

supports (coul

Monitoring Pro

the replaceme

precautionary 

relevant.

908 XI.S6 

ML101830328 

Comment 

XI.S6-1 

Program Description and Elements 3 and 4: 

Cracking of high strength bolts is not 

supported by the OE cited for structural bolts. 

Existing OE is for certain material, size, torque 

and lubricant applications only and should not 

be generically applied to all high strength bolts 

of 150 ksi or more. The Operating Experience 

cited in NUREG 1801 stated “SCC has 

occurred in high strength bolts used for 

nuclear steam supply system component 

supports (EPRI NP-5769).” The above is cited 

as operating experience in XI.M18, XI.S1, 

XI.S3, XI.S6, and XI.S7. The OE cited in 

NUREG 1801 is NP-5769 (issued in 1988) 

and was found only in certain specific 

materials and specifically for NSSS 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

As there are a 

and outside th

where the high

been used, the 

preventive me

where structur

ASTM A325, A

ASTM A-490 b

recommends t

discussion rela

measures.
NUREG-1950 IV-286 April 2011

Table IV-13. Analysis and Disposition of Public Comments on Chapter XI Structural AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

component supports and should not be 

generically applied to all structural high 

strength bolts. In certain cases the failures 

noted were attributed contributing factors 

including use of molybdenum disulfide thread 

lubricant which is considered a corrosive 

environment and is not used in structural steel 

installations. While EPRI NP-5769 Volume 1, 

Table 11-1 does list A490 bolts for ductile 

failures and failure due improper torque, and 

one instance of a special 4140 material with 

200 ksi minimum yield where the A490 

specification was used for heat treatment 

requirements (not an A490 structural bolt) 

where SCC was noted and associated with a 

high preload and borated water environment.

No SCC failures were noted for commonly 

used materials in Structural Steel bolting 

including A307, A325 or A490 bolts in a 

structural steel application. 

Industry documents including NUREG-1339 

have not identified any determination 

specifically as to the ASTM A-490 material’s 

susceptibility to SCC, but rather a 

determination of the yield stress level at which 

generic materials should be considered for the 

possibility of SCC vulnerability. In order for 

SCC to occur in high strength bolting, three 

parameters must exist; (1) a corrosive 

environment, (2) a susceptible material, and 

(3) high sustained tensile stresses. The 

absence of any one of these three parameters 
April 2011 IV-287 NUREG-1950

Table IV-13. Analysis and Disposition of Public Comments on Chapter XI Structural AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

eliminates the material’s susceptibility to SCC. 

High Strength Structural Bolts including A490 

bolts are not subject to high-sustained preload 

stress and lubricants containing contaminants, 

such as MoS2, are not approved for use. 

Therefore, SCC is not considered an 

applicable aging effect requiring management. 

The structural bolting will continue to be 

visually inspected for loss of preload due to 

self loosening and loss of material due to 

corrosion and also visually monitor the 

associated structural steel and connections 

for loss of material or other adverse 

conditions. 

The high strength bolts used for structural 

applications are A325 or A490 Bolts. A325 

bolts have a minimum yield of 92 ksi (unlikely 

to have an actual yield of 150 ksi or more), 

and A490 bolts have a minimum yield of 130 

ksi (potential that some A490 may reach 

actual yield of 150 ksi or more). Most 

structural bolts are 1” or less in diameter, 

however bolts in large girders or supporting 

large equipment may be over 1” diameter. 

Test reports are not generally traceable to 

installation locations. 

The AISC “Guide to Design for Bolted and 

Riveted Joints” Second Edition published in 

2001 addresses this concern in section 4.8 

and concludes that the tests indicate that 

black (not galvanized) A490 bolts can be used 
NUREG-1950 IV-288 April 2011

Table IV-13. Analysis and Disposition of Public Comments on Chapter XI Structural AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

without problems from “brittle” failures 

(failures due to hydrogen stress cracking or 

SCC) in most environments. It was concluded 

that galvanized A490 bolts should not be used 

in structures. This same section also 

concluded that black and galvanized A325 

bolts behave satisfactorily with regard to 

hydrogen stress and SCC in most corrosive 

environments. AISC publications do not 

recommend or require volumetric or surface 

examinations of installed structural bolts for 

SCC. 

We recommend that this new requirement be 

removed or at the most limited to the specific 

bolting material types identified in the OE 

cited on NSSS supports. Volumetric or 

surface examinations for cracking of high 

strength bolts should not be generically 

imposed for all bolts with actual yield strength 

of 150 ksi or more and greater than 1” 

diameter. Structural high strength bolts, 

including A325 and A490 bolts do not have a 

history of SCC in most environments. 

909 XI.S6 

ML101830328

Comment 

XI.S6-3 

Element 4: a) Industry guidance found in 

NUREG-1522, NEI 96-03, and ACI 349 

recommend a 5 to 10 year frequency. 

Program inspection frequency should be 

addressed as a part of Maintenance Rule 

implementation. Industry guidance NUREG1522, “Assessment of Inservice Conditions of 

Safety-Related Nuclear Plant Structures, and 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

a) The revised 

latitude for ins

certain in-scop

b) The AMP g

requirement. H

has noticed a 

which the Stru

Program base
April 2011 IV-289 NUREG-1950

Table IV-13. Analysis and Disposition of Public Comments on Chapter XI Structural AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

NEI 96-03, “INDUSTRY GUIDELINE FOR 

MONITORING THE CONDITION OF 

STRUCTURES AT NUCLEAR POWER 

PLANTS” recommends a 5 to 10 year 

frequency. ACI 349 provides guidance for 

inspecting some structures at greater than a 5 

year frequency. 

Plants have established their maintenance 

rule program including inspection frequency 

based on Maintenance Rule in accordance 

with 10 CFR 50.65, “Requirements for 

monitoring the effectiveness of maintenance 

at nuclear power plants.” 10 CFR 50.65, “MR,” 

does not require 5 year inspection frequency 

for all the structures. The frequencies of the 

inspections are established based on riskinformed evaluation process relative to their 

significant to public health and safety. As 

such, some structures have inspection 

frequency between 5 to 10 years. And, some 

structures based in their site specific OE are 

inspected even more frequent than every 5 

years. Some structures are already in 5 year 

inspection frequency. For example, Inspection 

of Water Control Structures governed by RG 

1.127 are already conducted on a 5 year or 

more frequently if conditions warrant as 

required by RG 1.127. Concrete Containment 

IWL inspections are also generally performed 

at a 5 year frequency. 

We recommend that this new requirement be 

Maintenance R

implemented. 

the staff is bas

a reasonable i
NUREG-1950 IV-290 April 2011

Table IV-13. Analysis and Disposition of Public Comments on Chapter XI Structural AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

removed. Imposing 5 year inspection 

frequency to all structures and masonry walls 

seems to be extreme measure without any 

bases. The inspection frequency should be 

established based on service and condition 

assessment of each structure in accordance 

with Maintenance Rule 10 CFR 50.65. That

could vary from 5 to 10 years.

b) The ACI 349.3R provides more restrictive 

qualifications requirements of personnel than 

the current commitments of most plants under 

their current licenses. Qualifications that are 

similar to the guidelines of ACI 349.3 R should 

also be acceptable as they have been under 

the current license basis. We recommend that 

this new requirement be removed. 

910 XI.S7 

ML101830328 

Comment 

XI.S7-1 

The bolting [EPRI NP-5067, EPRI NP-5769 

and EPRI TR 104213] references do not apply 

to this program.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The use of the 

reports will be 

cannot be rule

911 XI.S7 

ML101830328 

Comment 

XI.S7-2 

This program is a condition monitoring 

program and should not provide preventive 

actions.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

If applicable, p

are appropriat

912 XI.S7 

ML101830328 

Comment 

XI.S7-3 

Cracking of high strength bolts is not 

supported by the OE cited for structural bolts. 

Existing OE is for certain material, size, torque 

and lubricant applications only and should not 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

As per the rec

strength bolt re

elements 2 an

only if applicab
April 2011 IV-291 NUREG-1950

Table IV-13. Analysis and Disposition of Public Comments on Chapter XI Structural AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

be generically applied to all high strength bolts 

of 150 ksi or more. The Operating Experience 

cited in NUREG 1801 stated “SCC has 

occurred in high strength bolts used for 

nuclear steam supply system component 

supports (EPRI NP-5769).” The above is cited 

as operating experience in XI.M18, XI.S1, 

XI.S3, XI.S6, and XI.S7. The OE cited in 

NUREG 1801 is NP-5769 (issued in 1988) 

and was found only in certain specific 

materials and specifically for NSSS 

component supports and should not be 

generically applied to all structural high 

strength bolts. In certain cases the failures 

noted were attributed contributing factors 

including use of molybdenum disulfide thread 

lubricant which is considered a corrosive 

environment and is not used in structural steel 

installations. While EPRI NP-5769 Volume 1, 

Table 11-1 does list A490 bolts for ductile 

failures and failure due improper torque, and 

one instance of a special 4140 material with 

200 ksi minimum yield where the A490 

specification was used for heat treatment 

requirements (not an A490 structural bolt) 

where SCC was noted and associated with a 

high preload and borated water environment.

No SCC failures were noted for commonly 

used materials in Structural Steel bolting 

including A307, A325 or A490 bolts in a 

structural steel application. 

Industry documents including NUREG-1339 

changed. For other struc

includes ASTM 

guidance for p

are in RCSC p

referenced in t
NUREG-1950 IV-292 April 2011

Table IV-13. Analysis and Disposition of Public Comments on Chapter XI Structural AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

have not identified any determination 

specifically as to the ASTM A-490 material’s 

susceptibility to SCC, but rather a 

determination of the yield stress level at which 

generic materials should be considered for the 

possibility of SCC vulnerability. In order for 

SCC to occur in high strength bolting, three 

parameters must exist; (1) a corrosive 

environment, (2) a susceptible material, and 

(3) high sustained tensile stresses. The 

absence of any one of these three parameters 

eliminates the material’s susceptibility to SCC. 

High Strength Structural Bolts including A490 

bolts are not subject to high-sustained preload 

stress and lubricants containing contaminants, 

such as MoS2, are not approved for use. 

Therefore, SCC is not considered an 

applicable aging effect requiring management. 

The structural bolting will continue to be 

visually inspected for loss of preload due to 

self loosening and loss of material due to 

corrosion and also visually monitor the 

associated structural steel and connections 

for loss of material or other adverse 

conditions. 

The high strength bolts used for structural 

applications are A325 or A490 Bolts. A325 

bolts have a minimum yield of 92 ksi (unlikely 

to have an actual yield of 150 ksi or more), 

and A490 bolts have a minimum yield of 130 

ksi (potential that some A490 may reach 

actual yield of 150 ksi or more). Most 
April 2011 IV-293 NUREG-1950

Table IV-13. Analysis and Disposition of Public Comments on Chapter XI Structural AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

structural bolts are 1” or less in diameter, 

however bolts in large girders or supporting 

large equipment may be over 1” diameter. 

Test reports are not generally traceable to 

installation locations. 

The AISC “Guide to Design for Bolted and 

Riveted Joints” Second Edition published in 

2001 addresses this concern in section 4.8 

and concludes that the tests indicate that 

black (not galvanized) A490 bolts can be used 

without problems from “brittle” failures 

(failures due to hydrogen stress cracking or 

SCC) in most environments. It was concluded 

that galvanized A490 bolts should not be used 

in structures. This same section also 

concluded that black and galvanized A325 

bolts behave satisfactorily with regard to 

hydrogen stress and SCC in most corrosive 

environments. AISC publications do not 

recommend or require volumetric or surface 

examinations of installed structural bolts for 

SCC. 

We recommend that this new requirement be 

removed or at the most limited to the specific 

bolting material types identified in the OE 

cited on NSSS supports. Volumetric or 

surface examinations for cracking of high 

strength bolts should not be generically 

imposed for all bolts with actual yield strength 

of 150 ksi or more and greater than 1” 

diameter. Structural high strength bolts, 
NUREG-1950 IV-294 April 2011

Table IV-13. Analysis and Disposition of Public Comments on Chapter XI Structural AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

including A325 and A490 bolts do not have a 

history of SCC in most environments. 

913 XI.S8 

ML101830328 

Comment 

XI.S8-1 

Program Description and Elements 1, 3, and 

10: A coatings program developed to 

previously approved, and adopted by current 

licensing basis to in accordance with RG 1.54 

Rev. 0 should also meet the aging 

management program requirements and 

should be acceptable here as well. 

Reg. Guide 1.54, Rev 0 is the current 

licensing basis at a number of plants. The 

new requirement, compliance with Reg. Guide 

1.54 Rev 1 (and later), requires an expanded 

coating program, and the Rev 2 document 

(soon to be issued) will require expanded 

resources including an ASTM qualified 

“Coating Specialist” at each site. Rev 2 also 

requires full compliance to ASTM standards 

that were recently written to support new 

power plants. We believe the ASTM 

Committee D33 had no intention that these 

would be a back fit applied to existing licensed 

power plants. New ASTM standards have not 

been reviewed for gaps against ANSI 

requirements. The current licensing basis 

commitments are considered appropriate to 

detect and address coatings condition. 

We recommend revising this new requirement 

to state a coating program developed to the 

previously approved RG 1.54 Rev. 0 and 

improved in response to GL 98-04 and 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

The later stand

appropriate to 

The later stand

practices for m

maintaining co

coatings. Degr

protective coa

impair safety s

systems.
April 2011 IV-295 NUREG-1950

Table IV-13. Analysis and Disposition of Public Comments on Chapter XI Structural AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

implemented per the Maintenance Rule meets 

the current licensing basis and should be 

acceptable in GALL Rev. 2. Otherwise, for 

license renewal this new requirement will 

force the licensee to take exception to GALL. 
NUREG-1950 IV-296 April 2011

Table IV-14. Analysis and Disposition of Public Comments on Chapter XI Electrical AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

259 XI.E1

ML101830328

Comment 

XI.E1-1 

Page XI E1-1, Program Description, 

Paragraph 3: Move the 3rd paragraph to the 

1st paragraph. Also, spell out the acronym 

“AMP.” Consistency with the format of XI.E2 -

XI.E4.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Changes incor

format consist

and with the o

260 XI.E1 

ML101830328

Comment 

XI.E1-2 

Page XI E1-1, Program Description, 

Paragraph 2: 7th line: revise “or moisture 

specification over the specified life (if 

applicable) of the cables or connection...” to 

read “or moisture conditions for the cables or 

connection...” Also make connection plural 

(i.e. should read connections). Sentence is 

now consistent with the last sentence in 

Element 3. 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The text in the 

Description wa

to “...most limi

temperature, r

for the insulati

or connections

consistency w

of Element 3.

261 XI.E1 

ML101830328

Comment 

XI.E1-3 

Page XI E1-1, Program Description, 

Paragraph 2: Last line: revise “plant specific 

industry operating experience.” to read “plant 

specific and industry operating experience.” 

This was also as submitted in our NEI letter to 

the NRC concerning this topic. 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

No technical b

incorporate thi

(typographical 

editorial in nat

262 XI.E1 

ML101830328

Comment 

XI.E1-4 

Page XI E1-2, Parameters 

Monitored/Inspected (Element 3), Paragraph 

1: line three, change “signs of...” to “indicating 

we may have...”

The staff partially 

agrees with this 

comment and the 

GALL Report was 

reworded for clarity.

Staff partially a

comment and 

wording was re

changed “sign

signs of...”

263 XI.E1 

ML101830328, 

Comment 

XI.E1-5 

Page XI E1-2, Parameters 

Monitored/Inspected (Element 3), Paragraph 

1: Delete the word “all.” This word would 

change this effort from reasonable assurance 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

Deleted the wo

of this word wo

from reasonab

absolute assu
April 2011 IV-297 NUREG-1950

Table IV-14. Analysis and Disposition of Public Comments on Chapter XI Electrical AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

to an absolute assurance that would require 

more than just a visual inspection.

have been made. require more t

inspection.

264 XI.E1 

ML101830328

Comment 

XI.E1-6 

Page XI E1-3, Operating Experience (Element 

10), Paragraph 1: line two, the list of 

environments should read “temperature, 

radiation, or moisture” [missing commas]

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

No technical b

incorporate thi

the missing co

editorial (typog

nature. The lis

now reads “...

radiation, or m

265 XI.E2 

ML101830328

Comment 

XI.E2-1 

Page XI E2-1, Program Description, 

Paragraph 2: Make the first 2 sentences a 

stand-alone paragraph. Consistent with XI.E1. 

Or, conversely, make XI.E1 one long 

paragraph like XI.E2. The change shown is 

with the paragraph split.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Paragraph wa

consistent with 

paragraphs of 

maintain cons

electrical AMP

266 XI.E3 

ML101830328

Comment 

XI.E3-1 

Page XI E3-1, Program Description, 

Paragraph 2: second line, “be” at the end of 

the line should be “and are”

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

No technical b

incorporate thi

change provid

editorial (typog

nature.

267 XI.E3 

ML101830328

Comment 

XI.E3-4 

Page XI E3-2, Preventive Actions (Element 2), 

Paragraph 1: change fourth line “conduit ends 

and...” to “conduit ends in...”

[Comments XI.E3-2 and XI.E3-3 were not 

provided.] 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

Staff needs to 

cables in cond

are free of wat

operating expe

cable failures 

because of mo

and potential r

in conduit syst
NUREG-1950 IV-298 April 2011

Table IV-14. Analysis and Disposition of Public Comments on Chapter XI Electrical AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

268 XI.E3 

ML101830328, 

Comment 

XI.E3-5 

Page XI E3-2, Parameters 

Monitored/Inspected (Element 3), Paragraph 

1: Current change discusses inspection first, 

then testing. Suggest reversing the order. 

Cable testing is the primary method for 

assessing aging of cable insulation.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

This element i

and inspection 

recommended 

269 XI.E3 

ML101830328

Comment 

XI.E3-6 

Page XI E3-2, Detection of Aging Effects 

(Element 4), Paragraph 1: First sentence 

relative to verifying dewatering system 

operation prior to known or predicted flood 

events should be deleted. The verification is 

neither an aging preventive nor an aging 

detection mechanism. Infrequent 

submergence (rain and drain) is not a stressor 

for cable insulation degradation. 

The staff disagrees 

with this comment. 

However, the 

comment did result in 

a change to the 

GALL Report. 

Current NRC i

identified that 

of dewatering 

known or pred

is key to preve

submergence. 

existing first pa

4 was moved t

270 XI.E3 

ML101830328

Comment 

XI.E3-7 

Page XI E3-2, Detection of Aging Effects 

(Element 4), Paragraph 1: Second sentence 

sets maximum frequency at annually, or more 

frequent based on operating experience. 

Suggest maximum frequency remain at 2 

years.

The staff disagrees 

with this comment. 

However, the 

comment did result in 

a change to the 

GALL Report. 

Current NRC R

Process inspe

identified that 

frequency is n

prevent cable 

more frequent 

required based 

experience bu

performed at le

paragraph 1 o

moved and no

Element 2 (see 

277 XI.E3 

ML101830328

Comment 

Page XI E3-2, Detection of Aging Effects 

(Element 4), Paragraph 1: Third sentence, 

suggest manhole inspections not be required 

The staff disagrees 

with this comment. 

The GALL Report 

This is consist

Reactor Overs

baseline inspe
April 2011 IV-299 NUREG-1950

Table IV-14. Analysis and Disposition of Public Comments on Chapter XI Electrical AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

XI.E3-8 if dewatering equipment is functioning. Sump 

trouble alarms will provide indications of water 

accumulation. Sump levels ensure cable is 

not immersed or submerged. Note that 

Structures Monitoring Program would not be 

changed regardless of mechanism for 

dewatering.

has not been 

changed.

stated in the p

element 4, the 

the licensee’s 

should include 

that cables are 

submerged, th

and cable sup

intact, and tha

dewatering/dra

sump pumps) 

alarms operate 

found during in

exposed to sig

corrective actio

keep the cable 

performed to a

degradation.

278 XI.E3 

ML101830328

Comment 

XI.E3-9 

Page XI E3-2, Detection of Aging Effects 

(Element 4), Paragraph 2: First sentence sets 

test frequency at once every 3 refueling 

cycles. Suggest test frequency remain at 

every 10 years, adjusted for test results as 

determined through the corrective action 

process. Or at least use every 6 years instead 

of every 3R.

The staff partially 

agrees with this 

comment. However, 

the comment did 

result in a change to 

the GALL Report. 

Staff will revise 

frequency to e

of every 3 refu

Inspection freq

Operating Exp

exceed 6 year

testing is requ

cable performa

279 XI.E3 

ML101830328

Comment 

XI.E3-10

Page XI E3-2, Detection of Aging Effects 

(Element 4), Paragraph 1: Move to Element 2 

and make frequency commensurate with plant 

operating experience or corrective action 

program. 

The staff partially 

agrees with this 

comment in its 

entirety. However, 

the comment did 

result in a revision to 

Staff agreed to 

of Element 4 to 

suggested to m

within this AM

electrical AMP

Description an
NUREG-1950 IV-300 April 2011

Table IV-14. Analysis and Disposition of Public Comments on Chapter XI Electrical AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

the GALL Report for 

clarification.

281 XI.E3 

ML101830328

Comment 

XI.E3-13

Page XI E3-3, Operating Experience (Element 

10), Paragraph 1: First sentence, remove the 

word “most” 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made. 

Have removed 

listing of insula

HMWPE, and 

282 XI.E3 

ML101830328

Comment 

XI.E3-14

Page XI E3-4, Operating Experience (Element 

10), Paragraph 2 & 3: The paragraphs 

beginning “The NRC...” and “Therefore...” 

should be deleted. The information is 

background/historical information about the 

process rather than operating experience

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

These two par

be deleted as 

with NRC revie

operating expe

performance a

283 XI.E4 

ML101830328

Comment 

XI.E4-1 

Page XI E4-1, Program Description, 

Paragraph 2: should clarify the details for the 

MEB types. Some of this information is 

specific to a manufacturer, and does not apply 

to all. The bus being insulated is not 

applicable to all manufacturers and 

applications because this is just one way the 

BIL rating of the bus can be achieved during 

the design of the bus. For example, corona is 

not applicable to 480 VAC MEB applications.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Paragraph wa

comment and 

of the different 

enclosed bus; 

to only some M

284 XI.E4 

ML101830328

Comment 

XI.E4-2 

Page XI E4-1, Program Description, 

Paragraph 3: Delete second sentence. First 

two sentences are redundant

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Redundant se

No technical b

incorporate thi

editorial in nat

285 XI.E4 Page XI E4-1, Program Description, The staff does not Revised “is...” 
April 2011 IV-301 NUREG-1950

Table IV-14. Analysis and Disposition of Public Comments on Chapter XI Electrical AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

ML101830328

Comment 

XI.E4-3 

Paragraph 5: Second sentence change “is...” 

to “will be....” 

It is presumed part of program implementation 

as opposed to part of the LRA Appendices A 

and/or B.

agree with this 

comment. However, 

the comment did 

result in a change to 

the GALL Report. 

technical basis 

change is prim

nature. Additio

Description for 

revised to be c

wording.

286 XI.E4 

ML101830328

Comment 

XI.E4-4 

Page XI E4-2, Detection of Aging Effects 

(Element 4), Paragraph 2: third sentence, 

change “part of AMPs documentation” to “part 

of the AMPs site documentation”

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

It is acceptable 

technical basis 

documentation 

287 XI.E4 

ML101830328

Comment 

XI.E4-5 

Page XI E4-2, Detection of Aging Effects 

(Element 4), Paragraph 1: Last sentence: 

revise to read “Accessible elastomers (e.g., 

gaskets, boots, and sealants) are inspected 

for degradation including cracking, crazing, 

shrinkage, discoloration, weathering, 

hardening and loss of strength.” Note: 

Corresponding line item in Table VI.A also 

warrants change. Consistent with elastomer 

degradation criteria shown in Table IX.F and 

the term “Hardening and loss of strength” 

shown in Table IX.E. Proposed wording is 

also more appropriate for this electrical 

application. 

The staff disagrees 

with this comment. 

The GALL Report

has not been 

changed. 

The staff want

possible degra

elastomers, su

cracking, craz

dimensional ch

ballooning and 

shrinkage, disc

and loss of str

during inspect

elastomers. 

288 XI.E4 

ML101830328 

Comment 

XI.E4-6 

Page XI E4-3, Acceptance Criteria (Element 

6), Paragraph 1: Acceptance criteria for 

gaskets is inconsistent with that shown in 

Element 4. Revise Element 6 consistent with 

proposal to Element 4. Inconsistency between 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Elements 4 an

consistency w

Additionally, th

AMR item in T

change and w
NUREG-1950 IV-302 April 2011

Table IV-14. Analysis and Disposition of Public Comments on Chapter XI Electrical AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

elements. Or, simply make Element 4 read 

identical to Element 6. Note: Corresponding 

line item in Table VI.A may also warrant 

change.

accordingly fo

Elements 4 an

were incorpora

within GALL V

29.

289 XI.E4 

ML101830328 

Comment 

XI.E4-7 

Page XI E4-3, Corrective Actions (Element 7), 

Paragraph 1: 1st sentence: revise the word 

“required” to read “taken.” Typo-consistent 

with Element 7 in XI.E3.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Change (revis

“required” to “t

to ensure cons

with Element 7 

290 XI.E5 

ML101830328 

Comment 

XI.E5-1 

Page XI E5-1, Program Description, 

Paragraph 1: Consider adding new purpose 

statement similar to the following as the 1st 

paragraph, “The purpose of the aging 

management program (AMP) described 

herein is to provide reasonable assurance that 

the intended functions of the metallic clamps 

of fuse holders located outside of active 

devices and susceptible to aging effects are 

maintained consistent with the current 

licensing basis through the period of extended 

operation.” Or, use a reasonable facsimile. 

Consistency with the format of XI.E1 -XI.E4. 

The staff partially 

agrees with this 

comment and the 

GALL Report was 

reworded for clarity.

A new Purpos

added as the 1

Program Desc

consistency w

established in 

XI.E4.

291 XI.E5 

ML101830328

Comment 

XI.E5-2 

Page XI E5-1, Scope of Program (Element 1), 

Paragraph 1: 1st sentence: add “electrical 

transients” between thermal cycling and 

frequent manipulation. Consistent with 

corresponding line item in Table VI.A and 

Element 3.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Change (adde

transients” bet

cycling and fre

was incorpora

consistency w

AMR line item 
April 2011 IV-303 NUREG-1950

Table IV-14. Analysis and Disposition of Public Comments on Chapter XI Electrical AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

292 XI.E5 

ML101830328

Comment 

XI.E5-3 

Page XI E5-2, Parameters 

Monitored/Inspected (Element 3), Paragraph 

1: Paragraph should begin “The metallic...”

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

No technical b

incorporate thi

(typographical 

editorial in nat

293 XI.E5 

ML101830328

Comment 

XI.E5-4 

Page XI E5-2, Corrective Actions (Element 7), 

Paragraph 1: 1st sentence: revise the word 

“required” to read “taken.” Typo-consistent 

with Element 7 in XI.E3.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

Revised to be 

Element 7 in A

XI.E4.

294 XI.E6 

ML101830328

Comment 

XI.E6-1 

Page XI E6-1, Program Description, 

Paragraph 1: Consider adding new purpose 

statement similar to the following as the 1st 

paragraph “The purpose of the aging 

management program (AMP) described 

herein is to provide reasonable assurance that 

the intended functions of the metallic parts of 

cable connections located outside of active 

devices and susceptible to age-related 

degradation resulting in increased resistance 

of connection due to thermal cycling, ohmic 

heating, electrical transients, vibration, 

chemical contamination, corrosion, or 

oxidation are maintained consistent with the 

current licensing basis through the period of 

extended operation.” Or, use a reasonable 

facsimile. Consistency with the format of 

XI.E1 -XI.E4. 

The staff partially 

agrees with this 

comment and the 

GALL Report was 

reworded for clarity.

A new Purpos

added to main

the format esta

XI.E1 through 

includes a 10 C

reference.

295 XI.E6 

ML101830328

Page XI E6-2, Parameters 

Monitored/Inspected (Element 3), Paragraph 

The staff disagrees 

with this comment. 

The connectio

bolted connec
NUREG-1950 IV-304 April 2011

Table IV-14. Analysis and Disposition of Public Comments on Chapter XI Electrical AMPs, May 2010 Pub

Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

Comment 

XI.E6-2 

1: 2nd to last sentence: delete “connection 

type” from parameters monitored. Inconsistent 

with Element 3 of Final LR-ISG-2007-02 dated 

Dec 15, 2009. Also, the circuit application 

dictates the type of connection installed. 

Implementation of this AMP should be 

dictated by environmental stressors (which is 

the basis for all electrical AMPs) not the type 

of connection. If this is intended to indicate 

bolted connections, the addition in the first 

sentence is recommended.

The GALL Report 

has not been 

changed.

be other types 

consider when 

documenting t

for the represe

selection.

296 XI.E6 

ML101830328

Comment 

XI.E6-3 

Page XI E6-2, Parameters 

Monitored/Inspected (Element 3), Paragraph 

1: Connection type should be deleted. This is 

not a contributor to stressors.

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

They may not 

connections, a

other types of 

consider. See 

297 XI.E6 

ML101830328

Comment 

XI.E6-4 

Page XI E6-3, Detection of Aging Effects 

(Element 4), Paragraph 1: last line, change 

“part of AMPs documentation” to “part of the 

AMPs site documentation”

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

It is acceptable 

technical basis 

documentation 
April 2011 IV-305 NUREG-1950

Table IV-15. Analysis and Disposition of Public Comments on General BWR Vessel Internals Aging Mana

Programs, May 2010 Public Comment Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Public ID No.

Comment NRC Disposition Tech

916 ML101830255 

Comment 1

NRC license renewal guidance documents 

should identify the BWRVIP as an issue 

program addressed by the NEI 03-08 

materials initiative and should employ a 

flexible approach that recognizes periodic 

revisions and updates to the BWRVIP 

program, Further, it is not necessary for all of 

the documents supporting the NEI 03-08 

materials management programs be 

submitted to the NRC for review and approval. 

Providing credit for the NEI 03-08 initiative 

within the SRP-LR and GALL Report is an 

efficient use of NRC and industry resources. 

Under the NEI 03-08 materials initiative, utility 

compliance is required, implemented via site 

procedures, covered under 10 CFR 50

Appendix B, and thus is subject [to] NRC 

oversight. All deviations from “mandatory” or 

“needed” NEI 03-08 guidance are required to 

be reported to the NRC.

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The staff agree

a basic docum

NRC Staff has 

process for BW

and will also u

license renewa

necessary for 

LR.

917 ML101830255 

Comment 2

The BWRVIP is an active program. Program 

guidance and implementation requirements 

are based on relevant current operating 

experience, substantial field inspection data, 

and up to date research data. New program 

documents are routinely published and 

existing guidance documents are periodically 

revised as appropriate. When appropriate to 

address emergent issues, interim guidance is 

issued to member utilities. Therefore, it should 

be recognized that it is not feasible for the 

SRP-LR and GALL Reports to be kept up to 

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

The staff will c

Interim Staff g

process for int

license renewa

documents. U

guidance can 

an ISG. No ch

for the GALL o

An alternative 

adopted (prea

that will allow 

of industry gui
NUREG-1950 IV-306 April 2011

Table IV-15. Analysis and Disposition of Public Comments on General BWR Vessel Internals Aging Mana

Programs, May 2010 Public Comment Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Public ID No.

Comment NRC Disposition Tech

date with the EPRI BWRVIP program. 

Further, member utilities are required to 

implement new guidance as a part of the NEI 

03-08 initiative, Discrepancies between 

member utility BWRVIP program 

implementation and the program documents 

and requirements cited in the SRP-LR and 

GALL Report will necessarily result. When 

discrepancies occur, industry and NRC 

resources are unnecessarily expended on 

reconciliation of the differences. Instead, the 

BWRVIP maintains that license renewal 

guidance related to program implementation 

should focus on describing program elements 

and the related means of NRC oversight. 

Toward this objective, the BWRVIP 

recommends the following for implementation 

in the SRP-LR and GALL Report:

- It is appropriate to cite BWRVIP Inspection 

and Evaluation Guidelines that are submitted 

to the NRC for review and approval as 

effective aging management programs. 

However, where cited, the SRP-LR and GALL 

Report should stipulate “or latest NRC 

approved version.”

- Inspection and Evaluation Guidelines 

submitted to the staff for review and approval, 

but which are not yet approved, can and 

should be cited in the SRP-LR and GALL 

Report.

This is consistent with other documents which 

are not directly approved by the staff, but 

been approved 

generic use (v

guide, topical 

incorporation i

plant specific p

use, then appl

to use the late

an exception t

and reference 

provides high 

the exception 

The BWRVIP 

design criteria

the NRC they 

the GALL. The 

revised to refle

procedures to 

BWRVIP repa

are plant spec
April 2011 IV-307 NUREG-1950

Table IV-15. Analysis and Disposition of Public Comments on General BWR Vessel Internals Aging Mana

Programs, May 2010 Public Comment Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Public ID No.

Comment NRC Disposition Tech

have been cited as bases for aging 

management.

- Water chemistry guidelines, although not 

submitted to the staff for review and approval, 

are addressed by the NEI 03-08 materials 

initiative, Compliance with water chemistry 

action levels is considered “needed” under the 

initiative and implemented by site procedures. 

Compliance is verified by Institute of Nuclear 

Power Operations during review visits.

- Other BWRVIP reports can be cited as 

supporting references, but should not be 

specifically credited for aging management in 

the SRP-LR or GALL Report. These include 

repair design criteria, crack growth rate 

evaluations, and other technical basis 

documents.

918 ML101830255 

Comment 3

Aging management review line items and 

summary items included in the SRP-LR and 

GALL Report should address components 

and materials known to be typically used in 

the U.S. BWR fleet in passive and long-lived 

applications. In many cases, aging 

management review items in sections IV.AI 

and IV.B1 of the GALL Report include 

component and material combinations not 

typical of the domestic BWR fleet. EPRI 

Report 1018111, “BWRVIP-167NP, Revision 

1: BWR Vessel and Internals Project: Boiling 

Water Reactor Issue Management Tables” is 

a non-proprietary, publically available 

document developed by the BWRVIP that can 

The staff disagrees 

with this comment. 

The GALL Report 

has not been 

changed.

While some of 

may not reflec

fleet compone

the information 

the GALL for p

by domestic a

are not affecte

information ret
NUREG-1950 IV-308 April 2011

Table IV-15. Analysis and Disposition of Public Comments on General BWR Vessel Internals Aging Mana

Programs, May 2010 Public Comment Draft GALL Report, Rev. 2

Comment 

Number

Location in 

Document and 

Public ID No.

Comment NRC Disposition Tech

be used by NRC staff to identify typical 

component and material combinations for 

BWR reactor vessel and reactor internals 

components.
April 2011 IV-309 NUREG-1950

Table IV-16. Analysis and Disposition of Chapter 1 Public Comments on May 2010 Public Comment Draft 

Comment 

Number

Location in 

Document and 

Public ID No.

Comment NRC Disposition Tech

N/A N/A There were no public comments on Chapter 1

of the SRP-LR

N/A N/A
NUREG-1950 IV-310 April 2011

Table IV-17. Analysis and Disposition of Chapter 2 Public Comments on May 2010 Public Comment Draft 

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

241 2.1

ML101830328 

Comment 

2.1.3-1 

Page 2.1-9, Paragraph 5, grammatical: 

Remove proposed change in last sentence, 

and change existing word “included” to 

“considered.”

The staff disagrees 

with this comment. 

The SRP-LR has not 

been changed.

Wording is con

1.155 and SBO 

242 2.1 

ML101830328 

Comment 

2.1.3-2 

Page 2.1-9, Paragraph 5: Add new final 

sentence “However, the staff review is based 

on the plant-specific current licensing basis, 

regulatory requirements, and offsite power 

design configurations.” This is similar to 

Section 2.5.2.1.1.

The staff agrees with 

this comment and 

associated changes 

to the SRP-LR have 

been made.

Consistent wit

Also, consiste

made in SRP 2

Report, Chapt

243 2.5

ML101830328 

Comment 2.5-1 

Page 2.5-3, Section 2.5.2.1.1: third bullet; 

Components Within the Scope of SBO (10 

CFR 50.63) Add new final sentence 

“However, the staff review is based on the 

plant-specific current licensing basis, 

regulatory requirements, and offsite power 

design configurations.”

The staff agrees with 

this comment and 

associated changes 

to the SRP-LR have 

been made.

Consistent wit

Also, consiste

made in SRP 2

Report, Chapt

244 2.5 

ML101830328 

Comment 2.5-2 

Page 2.5-3, Section 2.5.2.1.1, “Components 

Within the Scope of SBO (10 CFR 50.63), 

third bullet, third sentence, change wording 

from “circuit breakers” to “inter-tie devices” to 

keep the same terminology as the previous 

added sentence.

The staff disagrees 

with this comment. 

Wording shou

within SRP 2.5

sentence was 

Replaced “inte

“circuit breake

sentence. Cha

with wording in 

Chapter VI.

245 2.5 

ML101830328 

Comment 2.5-3 

Page 2.5-3 and 2.5-4, Section 2.5.3, Review 

Procedures, 3rd paragraph, The last 

paragraph on page 2.5-3 that is cont. to the 

top of page 2.5-4 needs to be revised to 

clarify TLAAs associated with EQ 

The staff disagrees 

with this comment. 

The SRP-LR has not 

been changed.

Kept wording c

CFR 50.49.
April 2011 IV-311 NUREG-1950

Table IV-17. Analysis and Disposition of Chapter 2 Public Comments on May 2010 Public Comment Draft 

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

qualifications. Roger to provide proposed 

markup, [which follows:] 

Page 2.5-3 and 2.5-4, Section 2.5.3

The scope of 10 CFR 50.49 electric 

equipment to be included within 10 CFR 

54.4(a)(3) is that “long-lived” (qualified life of 

40 years or greater) equipment already 

identified by licensees under 10 CFR 

50.49(b), which specifies certain electric 

equipment important to safety. Licensees may 

rely upon their listing of environmental 

qualification equipment, as required by 10 

CFR 50.49(d), for purposes of satisfying 10 

CFR 54.4(a)(3) with respect to equipment 

within the scope of 10 CFR 50.49 (60 FR 

22466). However, the License Renewal Rule 

has a requirement (10 CFR 54.21(c)) on the 

evaluation of TLAAs, including environmental 

qualification (10 CFR 50.49) analyses or 

calculations. Environmental qualification 

equipment is analyses are not limited to 

analyses for “passive” equipment. The 

applicant may identify environmental 

qualification equipment analyses separately 

for TLAA evaluation and not include such the

equipment covered by such analyses as 

subject to an AMR under 10 CFR 54.21(a)(1). 

The environmental qualification equipment

analyses identified for TLAA evaluation would 

include the “passive” environmental 

qualification equipment that is not subject to 

an AMR because it is subject to replacement 

based on a qualified life. The TLAA evaluation 
NUREG-1950 IV-312 April 2011

Table IV-17. Analysis and Disposition of Chapter 2 Public Comments on May 2010 Public Comment Draft 

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

would ensure that the environmental 

qualification equipment analyses would be

show the qualified equipment

246

to be functional 

for the period of extended operation. The staff 

reviews the applicant’s environmental 

qualification TLAA evaluation separately 

following the guidance in Section 4.4. 

2.5 

ML101830328

Comment 2.5-4 

Page 2.5-4, Section 2.5.3.1, “Components 

within the Scope of License Renewal,” 

paragraph 1; First and Second lines use 

“component types/commodity groups” instead 

of “components”

Page 2.5-4, Section 2.5.3.1

In this step, the staff determines whether the 

applicant has properly identified the 

components component types/commodity 

groups that are WSLR. The Rule requires that 

the LRA identify and list components

component types/commodity groups

The staff disagrees 

with this comment. 

The SRP-LR has not 

been changed.

that are 

WSLR and are subject to an AMR. Whereas, 

in the past, LRAs have included a table of 

components that are WSLR, generally that 

information need not be submitted with future 

LRAs. Although that information will be 

available at plant sites for inspection, the 

reviewer must determine through sampling of 

one line diagrams, and review of UFSAR and 

other plant documents, what portion of the 

components are WSLR. The reviewer must

check to see if any components exist that the 

staff believes are within the scope but are not 

identified by the applicant as being subject to 

The terminolog

with 10 CFR 5
April 2011 IV-313 NUREG-1950

Table IV-17. Analysis and Disposition of Chapter 2 Public Comments on May 2010 Public Comment Draft 

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

AMR (any request that the applicant provide 

justification for omitting those components 

that are “passive” and “long lived”).
NUREG-1950 IV-314 April 2011

Table IV-18. Analysis and Disposition of Chapter 3 Public Comments on May 2010 Public Comment Draft 

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

247 3.0

ML101830328 

Comment 3.0-1 

Page 3.0-1, Section 3.0.1, “Background on 

the Types of Reviews,” Paragraph 1, second 

line “with” should be replaced by “within”

The staff agrees with 

this comment and 

associated changes 

to the SRP-LR have 

been made.

No technical b

incorporate thi

editorial in nat

248 3.0 

ML101830328

Comment 3.0-2 

Page 3.0-11, Table 3.0-1, “FSAR Supplement 

for Aging Management of Applicable 

Systems,” Paragraph 3 (XI.E6), fifth line: add 

a space between “that” and “period”

The staff agrees with 

this comment and 

associated changes 

to the SRP-LR have 

been made.

No technical b

incorporate thi

(typographical 

editorial in nat

249 3.0 

ML101830328 

Comment 3.0-3 

Page 3.0-14, Table 3.0-1, Paragraph 4 

(XI.E3), first line: “call” should be “calls”

The staff agrees with 

this comment and 

associated changes 

to the SRP-LR have 

been made.

No technical b

incorporate thi

(typographical 

editorial in nat

250 3.0 

ML101830328 

Comment 3.0-4 

Page 3.0-14, Table 3.0-1, Paragraph 4 

(XI.E3): The frequency for this program is at 

least once every 5 years. The value used in 

GALL is 3R instead of 5 years. Neither is 

acceptable, but they should be consistent. 

The frequency of at least once every 10 years 

should be used with the statement that the 

licensee must justify this frequency. As a 

minimum the value of 6 years should be used. 

The frequency of the manhole inspections 

should be changed to every 2 years or reflect 

that annually this is a sample similar to the 

regional inspections for Part 50.

The staff partially 

agrees with this 

comment and the 

SRP-LR was 

reworded for clarity.

Ten years was 

data. However

provides data 

justify the incre

This is based o

operating expe

years is consis

AMP XI.E3 (In

Cables Not Su

50.49 Environ

Requirements

Frequency of m

should be eve

a sampling ba

inspection eve

flooding proce
April 2011 IV-315 NUREG-1950

Table IV-18. Analysis and Disposition of Chapter 3 Public Comments on May 2010 Public Comment Draft 

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

is on a samplin

consistent with 

251 3.0 

ML101830328 

Comment 3.0-5 

Page 3.0-16, Table 3.0-1, Paragraph 1 

(XI.E2): Revise the 1st paragraph to read: 

“The program calls for the review of 

calibration results or findings of surveillance 

tests on electrical cables and connections 

used in circuits with sensitive, high-voltage, 

low-level current signals, such as radiation 

monitoring and nuclear instrumentation, to 

provide an indication of the existence of aging 

effects based on acceptance criteria related to 

instrumentation circuit performance. By 

reviewing the results obtained during normal 

calibration or surveillance, severe aging 

degradation may be detected prior to the loss 

of the cable and connection intended function. 

The review of calibration results or findings of 

surveillance tests is performed once every 10 

years.” This paragraph is confusing and 

technically incorrect. Normal instrument loop 

calibration results or surveillance tests do not 

provide sufficient indication to determine 

severe aging degradation on electrical cables 

and connections used in circuits with 

sensitive, high-voltage, low-level current 

signals, such as radiation monitoring and 

nuclear instrumentation prior to a loss of 

function. New paragraph as written is 

consistent with Element 4 of NUREG-1801, 

XI.E2.

The staff agrees with 

this comment and 

associated changes 

to the SRP-LR have 

been made.

No technical b

incorporate thi

change as it is 

252 3.0 Page 3.0-14, Table 3.0-1,The program call for The staff partially All changes in
NUREG-1950 IV-316 April 2011

Table IV-18. Analysis and Disposition of Chapter 3 Public Comments on May 2010 Public Comment Draft 

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

ML101830328 

Comment 3.0-

14

inaccessible or underground power (greater 

than or equal to 480 volts) cables exposed to 

significant moisture to be tested at least once 

every (remove 5 and replace with 6) six (6)

agrees with this 

comment and has 

revised the SRP-LR 

for clarification.

years to provide an indication of the condition 

of the conductor insulation. The specific type 

of test performed is determined prior to the 

initial test, and is to be a proven test for 

detecting deterioration of the insulation 

system due to wetting. The applicant can 

assess the condition of the cable insulation 

with reasonable confidence using one or more 

of the following techniques: Dielectric Loss 

(Dissipation Factor/Power Factor), AC Voltage 

Withstand, Partial Discharge, Step Voltage, 

Time Domain Reflectometry, Insulation 

Resistance and Polarization Index, Line 

Resonance Analysis or other testing that is 

state-of-the-art at the time the tests are 

performed. Periodic exposure to moisture for 

more than a few days at a time is not 

significant for power cables that are designed 

for these conditions (e.g., continuous wetting 

or submergence are not significant for 

submarine cables). In addition, inspection for 

water collection is established and performed 

based on plant-specific operating experience 

with water accumulation in the manholes (i.e., 

operation of dewatering devices should be 

inspected and operation verified prior to any 

known or predicted flooding events). 

However, the inspection frequency is at least 

(remove annual) annual (and replace with 

consistent with 

require 100% 

basis) inspecti

consistent with 

Procedure freq
April 2011 IV-317 NUREG-1950

Table IV-18. Analysis and Disposition of Chapter 3 Public Comments on May 2010 Public Comment Draft 

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

once every two (2) years) once every two (2) 

years

253

. 

3.0

ML101830328 

Comment 3.0-

16

Page 3.0-16, Table 3.0-1, The program calls 

for the review of calibration results or findings 

of surveillance tests on

In cases where cables are not part of

calibration or surveillance program, a proven 

cable test (such as insulation resistance tests, 

time domain reflectometry tests, or other tests 

judged to be effective) for detecting 

electrical cables and 

connections used in circuits with sensitive, 

high-voltage, low-level current signals, such 

as radiation monitoring and nuclear 

instrumentation, (remove) to be calibrated as 

part of the instrumentation loop calibration at 

the normal calibration frequency (end of 

removal) (add) to provide an indication of the 

existence of aging effects based on 

acceptance criteria related to instrumentation 

circuit performance.(end of addition)( remove) 

This calibration provides sufficient indication 

of the need for corrective actions based on 

acceptance criteria related to instrumentation 

loop performance.(end of removal) (add) By 

reviewing the results obtained during normal 

calibration or surveillance, severe aging 

degradation may be detected prior to the loss 

of the cable and connection intended 

function.(end of addition) The review of 

calibration results (add) or findings of 

surveillance tests (end of addition) is 

performed once every 10 years. 

The staff agrees with 

this comment and 

associated changes 

to the SRP-LR have 

been made.

No technical b

incorporate thi

change as it is 

(See Commen
NUREG-1950 IV-318 April 2011

Table IV-18. Analysis and Disposition of Chapter 3 Public Comments on May 2010 Public Comment Draft 

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

deterioration of the insulation system are 

performed. The test frequency is based on

engineering evaluation and is at least once 

every 10 years.

358 3.0

ML101830328, 

Comment 18

SRP, Table 3.0-1, The ASME Section XI, 

Subsection IWE program consists of periodic 

visual, surface, and volumetric inspection of 

pressure-retaining components of steel and 

concrete containments for signs of 

degradation, assessment of damage, and 

corrective actions. The program also includes 

aging management for the potential loss of 

material due to corrosion in the inaccessible 

areas of the boiling water reactor (BWR) Mark 

I steel containment, (DELETE) and surface 

examination for the detection of cracking of 

structural bolting (end of deletion). This 

program is in accordance with ASME Section 

XI, Subsection IWE, (DELETE) 20014 (end of 

deletion) (ADD) 2004 (end of addition) edition, 

including the 2002 and 2003 Addenda.

IWE addresses pressure retaining bolting. 

The staff partially 

disagrees with this 

comment. Some 

changes to the SRPLR have been made. 

AMP XI.S1, a

pressure retain

bolting. ASME 

corrections ha

360 3.0

ML101830328, 

Comment 19

[Revise SRP, Table 3.0-1, XI.M26, Fire 

Protection as shown below to delete reference 

to the diesel-driven fire pump:]

The program includes fire barrier and dieseldriven fire pump inspections. The fire barrier 

inspection program requires periodic visual 

inspection of fire barrier penetration seals, fire 

barrier walls, ceilings, and floors, and periodic 

visual inspection and functional tests of fire 

The staff agrees with 

this comment and 

associated changes 

to the SRP-LR have 

been made.

The scope of X

to delete inspe

performance te

driven fire pum

consistent with 

XI.M26, Fire P

in GALL Repo
April 2011 IV-319 NUREG-1950

Table IV-18. Analysis and Disposition of Chapter 3 Public Comments on May 2010 Public Comment Draft 

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

rated doors to ensure that their operability is 

maintained. The diesel-driven fire pump 

inspection program requires that the pump be 

periodically tested to ensure that the fuel 

supply line can perform the intended function.

The program also includes periodic inspection 

and test of halon/carbon dioxide fire 

suppression systems.

361 Table 3.0-1 

ML101830328,

Comment 20

The program evaluates the effectiveness of 

the maintenance monitoring program and the 

effects of past and future usage on the 

structural reliability of cranes and hoists. 

(DELETE) The number and magnitude of lifts 

made by the hoist or crane are also reviewed. 

(KEEP) Rails and girders are visually 

inspected on a routine basis for degradation; 

functional tests are performed to assure their 

integrity. These cranes must also comply with 

the maintenance rule requirements provided 

in 10 CFR 50.65. To match the scope of 

XI.M23 Inspection of Overhead Heavy Load 

and Light Load Handling Related to Refueling) 

Handling Systems.

The staff disagrees 

with this comment. 

The SRP-LR has not 

been changed.

It is necessary 

number and m

because this in

for TLAA purp

the number of 

the design num

837 3.1

ML101880269 

Comment 39

SRP Section 3.1.2.2.3: Based on Comments 

3, 4, and 5 this section should be eliminated. 

[Comments 3, 4, and 5 refer to comment 

numbers 863, 864 and 945, respectively of 

NUREG-1950.]

The use of an AMP consistent with GALL 

should not require further evaluation.

The staff disagrees 

with this comment. 

The SRP-LR has not 

been changed.

The staff disag

3, 4, and 5, to 

refers; therefo

not applicable

1950 commen

and 945 for tec

 

958 3.1 SRP Section 3.1.2.2.9: Based on The staff disagrees The staff disag
NUREG-1950 IV-320 April 2011

Table IV-18. Analysis and Disposition of Chapter 3 Public Comments on May 2010 Public Comment Draft 

Comment 

Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

ML101880269 

Comment 40 

Comments 6, 8, and 10, this section 

should be eliminated. [Comments 6, 8, 

and 10 refer to comment numbers 866, 

868, and 870, respectively.] The NRC staff 

review of MRP-227 should address this issue 

and provide guidance in the SE that is to be 

issued.

with this comment. 

The SRP-LR has not 

been changed.

6, 8, and 10, to 

comment refer

comment is no

to NUREG-195

numbers 866, 

technical basis

959 3.1 

ML101880269 

Comment 41 

SRP Section 3.1.2.2.10: Based on 

Comments 7, 9, and 11, this section should 

be eliminated. [Comments 7, 9, and 11 refer 

to comments 867, 869, and 871, respectively.]

The NRC staff review of MRP-227 should 

address this issue and provide guidance in 

the SE that is to be issued.

The staff disagrees 

with this comment. 

The SRP-LR has not 

been changed.

The staff disag

7, 9, and 11, to 

comment refer

comment is no

to NUREG-195

numbers 867, 

technical basis

. 

960 3.1 

ML101880269 

Comment 42 

SRP Section 3.1.3.2.9: Delete this section. 

There are no further evaluation required

(FER) items that refer to this section. It is a 

duplicate of Section 3.1.2.2.9.

The staff disagrees 

with this comment. 

The SRP-LR has not 

been changed.

SRP Section 3

companion se

Section 3.1.2.2

3.1.2.2.9 provi

evaluation rec

Section 3.1.3.2

guidance for th

Consequently, 

should not be 

items refer to t

recommendati

guidance. The

needed.

961 3.1 

ML101880269 

SRP Section 3.1.3.2.10: Delete this section.

There are no FER items that refer to this 

The staff disagrees 

with this comment. 

The SRP-LR has not 

SRP subsectio

companion se

subsection 3.1
April 2011 IV-321 NUREG-1950

Table IV-18. Analysis and Disposition of Chapter 3 Public Comments on May 2010 Public Comment Draft 

Comment 

Number

Location in 

Document and 

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Reference No.

Comment NRC Disposition Tech

Comment 43 section. It is a duplicate of Section 3.1.2.2.10. been changed 3.1.2.2.10 prov

evaluation req

subsection 3.1

guidance for th

Consequently, 

3.1.3.2.10 sho

The FER items 

evaluation req

reviewer guida

change is nee

962 Table 3.1-21 

ML101880269 

Comment 44 

SRP Table 3.1-21: See Comments 3, 4, 5, 

and 21. (strikethrough)Yes, plant-specific 

(See subsection 3.1.2.2.3.2),(strikethrough) 

(underline)No [Comments 3, 4, 5, and 21 

refer to comment numbers 863, 864, 945,and 

881, respectively.] The use of an AMP 

consistent with GALL should not require 

further evaluation.

The staff disagrees 

with this comment. 

The SRP has not 

been changed.

The staff disag

3, 4, 5, and 21 

comment refer

comment is no

to NUREG-195

numbers 863, 

for technical b

963 Table 3.1-25 

ML101880269 

Comment 45 

SRP Table 3.1-25: See Comment 13. To 

accommodate the “Pressurizer relief tank: 

tank shell and heads; flanges; nozzles” 

managed by “Chapter XI.M2, “Water 

Chemistry,” and Chapter XI.M32, “One-Time 

Inspection,” add “IV.C2.RP-XXX” to the Rev2 

Item Column. The pressurizer spray head is 

also a non-ASME Section XI component that 

is managed by the same AMPs (see page 

IV.C2-8, AMR line IV.C2.RP-41) for the same 

aging effect.

The staff agrees with 

this comment and 

associated changes 

to the SRP-LR have 

been made.

A new AMR ite

has been adde

pressurizer co

combination o

Chemistry and 

Inspection pro

previously bee

manage this m

and aging effe

non-ASME co

964 3.2

ML101880269, 

SRP Section 3.2.3.2.6: Delete this section.

There are no FER items that refer to this 

The staff disagrees 

with this comment. 

SRP subsectio

companion se
NUREG-1950 IV-322 April 2011

Table IV-18. Analysis and Disposition of Chapter 3 Public Comments on May 2010 Public Comment Draft 

Comment 

Number

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Comment NRC Disposition Tech

Comment 46 section. It is a duplicate of Section 3.2.2.2.6. The SRP-LR has not 

been changed

subsection 3.2

3.2.2.2.6 provi

evaluation req

3.2.3.2.6 provi

staff reviewer. 

subsection 3.2

deleted. The fu

recommendati

to the further e

recommendati

guidance. The

needed.

965 3.2

ML101880269, 

Comment 47 

SRP Table 3.2-12: See Comments 18, 19, 

and 20. [Comments 18, 19, and 20 refer to 

comment numbers 879, 880, and 947, 

respectively in NUREG-1950.]

Revise the roll up line as follows: 

[see original document for the table within the 

table that goes with this comment] [Referring 

to AMR Items V.B.EP-103, V.C.EP-103, 

V.D1.EP-103, V.D2.EP-103:

(ADD) Reference to V.B.EP-XXX

(DELETE) Chapter XI.M1, “ASME Section XI 

Inservice Inspection, Subsections IWB, IWC,

and IWD” for ASME Code components or

(KEEP) Chapter XI.M36, “External Surfaces 

Monitoring of Mechanical Components” for 

non-ASME Code components (ADD) or None] 

There is a lack of operating experience to 

support aging effects associated with the 

described material-environment and ISI is not 

The staff agrees with 

this comment and 

associated changes 

to the SRP-LR have 

been made.

The staff agree

18, 19, and 20 

Report, as doc

NUREG-1950 

879, 880, and 

Conforming ch

the SRP. Refe

number 879, 8

technical basis 

GALL Report.
April 2011 IV-323 NUREG-1950

Table IV-18. Analysis and Disposition of Chapter 3 Public Comments on May 2010 Public Comment Draft 

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Comment NRC Disposition Tech

adequate to manage component external 

surfaces. This is a generic comment 

applicable to Chapters VII and VIII.

If the evaluation performed to address FER 

3.2.2.2.6 determines that the conditions 

described are not applicable then a 

corresponding AMR line is required.

362 Table 3.5-1 

Item 22

ML101830328

Comment 21

DELETE) Structural (KEEP) Pressure - 

retaining bolting, Steel elements: downcomer 

pipes

Chapter XI.S1, "ASME Section XI, Subsection 

IWE" applies to containment pressure - 

retaining bolting only.

The staff disagrees 

with this comment. 

The SRP-LR has not 

been changed

Structural bolt

downcomers a

BWR Mk I con

be pressure bo

However, they 

examined.

363 Table 3.5-1 

Item 58

ML101830328

Comment 22

III.B1.1.TP-41

(DELETE) III.B2.TP-41

(DELETE) III.B3.TP-41

The staff agrees with 

this comment and 

associated changes 

to the GALL Report 

have been made.

This is a duplic

and III.B3.TP-4

364 Table 3.5-1 

Item 65

ML101830328

Comment 23

Delete this line item. 

The aging effect for the block walls are 

adequately covered under line item III.A5.T12.

The staff disagrees

with this comment. 

The SRP-LR has not 

been changed

The aging effe

different than t

365 Table 3.5-1 

Item 77

ML101830328

Comment 24

1. (DELETE) High-strength structural bolting, 

(KEEP) Support members; welds; bolted 

connections; support anchorage to building 

structure

2. (DELETE) III.A1.TP-287, III.A2.TP-287, 

The staff partially 

agrees with this 

comment; however, 

the SRP-LR has not 

been changed.

High-strength 

only called out 

effect of crack

aging effects, 

identify high-st
NUREG-1950 IV-324 April 2011

Table IV-18. Analysis and Disposition of Chapter 3 Public Comments on May 2010 Public Comment Draft 

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III.A3.TP-287, III.A4.TP-287, III.A5.TP-287, 

III.A7.TP-287, III.A8.TP-287, III.A9.TP-287, 

III.B2.TP-287, III.B3.TP-287, III.B4.TP-287, 

and III.B5.TP-287 

1 & 2) These line items are covered under 

III.A1.TP-248 and III.A1.TP-274. 

bolting from an

bolting. TP-28

because it did 

cracking. TP-2

address other 

366 Table 3.5-1 

Item 76

ML101830328

Comment 25

Delete these line items. 

These line items are not supported by OE and 

should be removed or limited to the specific 

type of bolting material and sizes where 

cracking has been found on NSSS supports. 

It is not warranted to generically extend the 

limited material specific OE (which may be 

partially caused by the type of lubricant) to all 

bolts of 150 ksi and over regardless of 

material and lubricant.

The staff partially 

agrees with this 

comment and some 

changes have been 

made to the SRP-LR.

Item 76 in the 

comment beca

LR Final. A no

ASTM A325, F

bolts are not p

254 3.6

ML101830328 

Comment 3.6-1 

Page 3.6-4, Section 3.6.3.2 (All): All of the 

subsections of 3.6.3.2 seem to be a repeat of 

Section 3.6.2.2. There are slight differences, 

but this is unnecessary repetition of 

information.

The staff disagrees 

with this comment. 

The SRP-LR has not 

been changed.

These are diffe

SRP. The text 

one section is 

recommendati

the associated 

paragraph.

255 3.6

ML101830328 

Comment 3.6-2 

Page 3.6-8, Table 3.6-1, “Summary of Aging 

Management Programs for the Electrical 

Components Evaluated in Chapter VI of the 

GALL Report” (All): Order of table entries 

appears random. Suggest alphabetical by 

Component but rather the intent is to keep 

commodity groups together.

The staff disagrees 

with this comment. 

The SRP-LR has not 

been changed.

The proposed 

enhance techn

order is consis

Report Table.
April 2011 IV-325 NUREG-1950

Table IV-19. Analysis and Disposition of Chapter 4 Public Comments on May 2010 Public Comment Draft 

Comment 

Number

Location in 

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Reference No.

Comment NRC Disposition Tech

511 4.2.2.1.1.2

ML101830328 

In several places, ft-lb were changed to 

joules, such as replacing “50 ft-lb” with “68 

joules (50 ft-lb).” As ft-lb is more common 

usage than joules, shouldn’t this say “50 ft-lb 

(68 joules)”? This would then be consistent 

with the format in 10 CFR 50, Appendix G.

The staff agrees with 

this comment and 

associated changes 

to the SRP-LR have 

been made.

No technical b

incorporate thi

change as it is 

Not a technica

512 4.2.2.1.4.1

ML101830328 

Minor wording changes only.

10 CFR 54.21(c)(1)(iii) An applicant for 

renewal of a license should address this issue 

by noting that it will be handled through a reapplication under 10 CFR 50.55a(a)(3). An 

applicant for a license to operate such

renewal of

The staff partially 

agrees with this 

comment and some

changes to the SRPLR have been made.

a BWR may provide justification to 

extend this relief into the period of extended 

operation in accordance with BWRVIP-74-A 

(Ref 8), which is the revised and NRC 

approved version of BWRVIP-74 (Ref. 9). The 

staff’s review of BWRVIP-74 (Ref. 9) is 

contained in an October 18, 2001 letter to C. 

Terry, BWRVIP Chairman (Ref. 10). Section 

A.4.5 of Report BWRVIP-74-A indicates that

Appendix E of the staff’s final safety 

evaluation report (FSER) (Ref. 10) 

conservatively evaluated BWR RPV’s to have

64 effective full power years (EFPY), which is 

10 EFPY greater than the maximum of what is 

realistically expected for the end of the license 

renewal period. Since this is a generic 

analysis, a licensee relying on BWRVIP-74-A 

should provide plant-specific information to 

demonstrate that at the end of the renewal 

period, the circumferential beltline weld 

No technical b

incorporate thi

change as it is 

Not a technica
NUREG-1950 IV-326 April 2011

Table IV-19. Analysis and Disposition of Chapter 4 Public Comments on May 2010 Public Comment Draft 

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materials meet the limiting conditional failure 

probability for circumferential welds specified 

in Appendix E of the FSER (Ref. 10) and that 

operator training and procedures are utilized 

during the license renewal term to limit the 

frequency for cold over-pressure events to the 

amount specified in the NRC FSER (Ref. 10).

513 4.2.3.1.1

ML101830328 

Put the discussion of neutron fluence after 

4.2.3.1.1 and before 

4.2.1.1.1/4.2.3.1.1.2/4.2.3.1.1.3 as it applies 

to all three subsections.

The staff disagrees 

with this comment. 

The SRP-LR has not 

been changed.

Subsections 4

4.2.3.1.1.2 con

neutron fluenc

understandabl

discussion in s

4.2.3.1.1.3 doe

discussion of n

because the s

recommends t

demonstrate th

adequately ma

of extended op

by-case basis. 

514 4.2.3.1.1.2

ML101830328 

The second half of this section is confusing. 

Many plants have surveillance data that 

shows a larger drop in USE than that 

predicted by RG 1.99 Revision 2, Position 1. 

RG 1.99 Position 2 allows the adjustment of 

the predicted USE based on the plant’s 

surveillance data. Only plants without 

adequate surveillance data to make the 

adjustment could have larger reductions in 

USE than that predicted by RG 1.99. In the 

BWRVIP Integrated Surveillance Program, 

there is no BWR in this condition. Suggest 

The staff disagrees 

with this comment. 

The SRP-LR has not 

been changed.

Applicants mu

the projected p

Charpy USE fo

materials is les

for the limiting 

BWRVIP-74-A 

reduction in C

surveillance m

than or equal t

using NRC RG 

These are two 

and both are r
April 2011 IV-327 NUREG-1950

Table IV-19. Analysis and Disposition of Chapter 4 Public Comments on May 2010 Public Comment Draft 

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rewording the last part of the paragraph as 

shown below.

For Boiling Water Reactors, the staff confirms 

that the beltline materials are evaluated in 

accordance with Renewal Applicant Action 

Item 10 in the staff’s SER, for BWRVIP-74 

(Letter to C. Terry dated October 18, 2001) 

(Ref. 10). Action Item 10: To demonstrate that 

the beltline materials meet the Charpy USE 

criteria specified in Appendix B of BWRVIP74-A or the NRC FSER (Ref. 10), the 

applicant demonstrates that the projected

percent reduction in Charpy USE for their 

beltline materials is less than that specified for 

the limiting BWR/3-6 plates and the limiting

non

If there should be a BWR with more 

embrittlement than RG 1.99 Position 1 and 

not enough credible surveillance data to 

correct it (say someone drops out of the ISP 

for some reason); the real question is what 

action would the staff require in this case?

-Linde 80 submerged arc welds. and that 

the percent reduction in Charpy USE for their 

surveillance weld and plate are less than or 

equal to the values projected using the 

methodology in NRC RG 1.99, Revision 2.

demonstrate th

Charpy USE m

BWRVIP-74.

Staff will review 

case basis.

515 4.2.3.1.3

ML101830328 

Put the discussion of neutron fluence after 

4.2.3.1.3 and before 

4.2.1.3.1/4.3.2.1.4.2/4.2.1.3.3 as it applies to 

all three subsections.

Does every plant use 3⁄4 T to determine P-T 

The staff disagrees 

with this comment. 

The SRP-LR has not 

been changed.

Subsections 4

4.2.3.1.3.2 con

neutron fluenc

understandabl

discussion in s

4.2.3.1.3.3 doe
NUREG-1950 IV-328 April 2011

Table IV-19. Analysis and Disposition of Chapter 4 Public Comments on May 2010 Public Comment Draft 

Comment 

Number

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limits? If not, this should just say 1⁄4 T. discussion of n

because the s

recommends t

demonstrate th

adequately ma

of extended op

plants use bot

determine P-T 

eliminated.

516 4.2.3.1.3.1

ML101830328 

The documented results of the projected 

neutron fluence for the 1⁄4T and 3⁄4 T locations 

at the end of the period of extended operation 

they are bounded by the neutron fluences 

used to develop the existing P-T limit analysis.

The staff agrees with 

this comment. 

Associated changes 

to the SRP-LR have 

been made.

No technical b

incorporate thi

change as it is 

Not a technica

517 4.3.2

ML101830328 

Subpart 2 describes the stress reduction 

factors as “maximum allowable.” However, 

there are not min/max values for the factors 

listed in Table 4.3-1. Consider clarifying as 

shown below.

2. Implicit fatigue-based maximum allowable 

stress calculations for piping components 

designed to USAS ANSI B31.1 (Ref. 2) 

requirements, and ASME Code Class 2 and 3 

components designed to ASME Section III 

design requirements that are similar to the 

guidance in ANSI B31.1. 

ANSI B31.1 applies only to piping and does 

not call for an explicit fatigue analysis. It 

specifies allowable stress levels based on the 

number of anticipated full thermal range 

transient cycles. The specific maximum 

The staff disagrees 

with this comment. 

The SRP-LR has not 

been changed.

Table 4.3-1 is 

that it provides 

reduction facto

number of equ

temperature cy
April 2011 IV-329 NUREG-1950

Table IV-19. Analysis and Disposition of Chapter 4 Public Comments on May 2010 Public Comment Draft 

Comment 

Number

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Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

allowable stress range reductions factors

518

due 

to full thermal cycles are listed in Table 4.3-1.

4.3.1

ML101830328 

Most metallurgists and fatigue experts would 

disagree that a CUF of 1.0 assumes there is a 

crack. Suggested rewording below.

A CUF below above a value of one provides 

assurance that no assumes that a small, but 

analyzable crack has been formed. A CUF 

above a value of one allows for the possibility 

that a crack may form, and that if If 

undetected or left untreated, the crack could

The staff agrees with 

this comment. 

Associated changes 

to the SRP-LR have 

been made.

will propagate exponentially under fatigue 

loading and eventually lead to coolant leakage 

in reactor pressure boundary components, or 

even general structural failure.

Most metallurg

experts agree 

the number wh

and therefore, 

should be mai

519 4.3.2.1.1.3 

ML101830328 

Don’t limit GALL X.M1 to the RCS pressure 

boundary. There are lots of non-RCS 

pressure boundary items (containment 

buildings, supports, PWR secondary side 

items, etc.) that are identified in GALL 

Sections II through VIII that have cycles that 

need monitoring with this program. SRP-LR 

Section 4.3.1 acknowledges this.

The staff agrees with 

this comment. 

Associated changes 

to the SRP-LR have 

been made.

GALL X.M1 tit

to “Fatigue Mo

reference to R

boundary com

been removed

that more com

pressure boun

that need mon

520 4.3.2.1.3

ML101830328 

The last paragraph is not clear. It seems to 

imply that the nickel-alloy Fens from RG 1.207 

can be used with the existing ASME fatigue 

curves. This is not what RG 1.207 (or 

NUREG\CR-6909 says). This paragraph 

should be clarified. Note that 4.3.3.1.3 does 

not allow this.

The staff agrees with 

this comment. 

Associated changes 

to the SRP-LR have 

been made.

This paragrap

to provide guid

for Fen calcula

low-alloy steel

and nickel-allo
NUREG-1950 IV-330 April 2011

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Number

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Document and 

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Reference No.

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521 4.3.2.1.4

ML101830328 

There is no 4.3.2.1.4, the report goes from 

4.3.2.1.3 to 4.3.2.1.5.

The staff agrees with 

this comment. 

Associated changes 

to the SRP-LR have 

been made.

Subsection 4.3

added. Provide

ensures consis

information in 

to provide con

AMP for that e

information is 

element to ano

the element is 

revised section 

522 4.3.2.1.5.3

ML101830328 

Why isn’t GALL X.M1 an acceptable basis for 

accepting flaw growth and fracture mechanics 

analyses? Seems like an explanation is in 

order. Note that section 4.3.3.1.5.3 re-iterates 

this statement while section 4.3.3.1.1.3 seems 

to contradict it.

The staff disagrees 

with this comment. 

The SRP-LR has not 

been changed.

GALL X.M1 m

the number of 

pressure trans

selected comp

the fatigue usa

the allowable l

fatigue crackin

components c

cyclic strains i

program is not 

accept flaw gro

mechanics ana

corrective actio

CUF<1.0, an a

choose the op

fracture mecha

repair or repla

523 4.3.3.1.1.2

ML101830328 

“Adequate” needs definition. Suggest 

rewording to eliminate it.

The operating transient experience is 

reviewed to ensure that

The staff agrees with 

this comment. 

Associated changes 

to the SRP-LR have and a list of the 

Clarification w

nature. Senten

reworded to en

used for any re

exceeds the n
April 2011 IV-331 NUREG-1950

Table IV-19. Analysis and Disposition of Chapter 4 Public Comments on May 2010 Public Comment Draft 

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Number

Location in 

Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

increased number of assumed transients used 

for any re-analysis meets or exceeds the 

number of transients

been made.

projected to the end of 

the period of extended operation are reviewed 

to ensure that the transient projection is 

adequate. The revised CUF calculations 

based on the projected number of assumed 

transients are reviewed to ensure that the 

CUF remains less than or equal to one at the 

end of the period of extended operation. For 

consistency purposes, the review also 

includes an assessment of the TLAA 

information against relevant design basis 

information and CLB information (including 

applicable cycle-counting requirements in 

technical specifications).

projected to th

of extended op

130 4.3

ML101660084, 

Comment 1

In Table 4.1-3 of NUREG-1800, Rev. 2, 

ductility reduction of fracture toughness for the

reactor vessel internals has been identified as 

a plant-specific time-limited aging analysis

(TLAA). However, all operating reactors in the 

U.S. have been designed with no explicit

embrittlement analysis based on the plant life 

for reactor core internals. Loss of fracture

toughness due to radiation embrittlement was 

not considered in the design of light water

reactor (LWR) core internal components 

constructed of austenitic stainless steels 

(SSs). These steels have [been] used 

extensively in LWRs as structural alloys in the 

internal components of reactor pressure 

vessels because of their relatively high 

strength, ductility, and fracture toughness. 

The staff disagrees 

with this comment. 

The SRP-LR has not 

been changed.

Ductility, reduc

toughness is a 

stainless steel 

with Babcock 

designed PWR 

internals, and 

internals with c

hardware and 

Dresden and Q

Renewal Appl

4.2.4), becaus

analyses that 

criteria of 10 C

PWR or BWR 

types of reacto

have not ident

fracture tough
NUREG-1950 IV-332 April 2011

Table IV-19. Analysis and Disposition of Chapter 4 Public Comments on May 2010 Public Comment Draft 

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Document and 

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Comment NRC Disposition Tech

Fracture of these steels occurs by stable 

tearing at stresses well above the yield stress, 

and tearing instabilities require extensive 

plastic deformation.

However, exposure to neutron irradiation for 

extended periods degrades their fracture

properties. For example, at a neutron dose of 

5-8 dpa the fracture toughness of SSs can 

decrease from a JIc value well above 200 

kJ/m2 to as low as 7.5 kJ/m2 (or stress

intensity factor KJc of 38 MPa m1/2 or 34.5 ksi 

in. 1/2). Furthermore, while the initial aging 

effect is loss of ductility and toughness, 

unstable crack extension is the eventual aging 

effect if a crack is present and the local 

applied stress intensity exceeds the reduced

fracture toughness. The decrease in fracture 

toughness of austenitic SSs with neutron 

exposure has been documented in several 

industry and NRC reports.

The current evaluation of the structural and 

functional integrity of the reactor vessel

internals assumes that the irradiated materials 

will retain sufficient ductility to rule out the

likelihood of unstable crack extension when 

the local applied stress intensity exceeds a

KJc value of 38 MPa m1/2 (34.5 ksi in.1/2). The 

total neutron fluence for some vessel

internal components that are highly stressed 

or have a high fatigue usage is likely to

exceed 4 dpa within the 60-year life. As 

stainless steel

because they 

analyses that 

criteria of 10 C

Although redu

toughness in a

steels resulting 

irradiation is n

reactor vessel 

evaluated in M

PWRs, and in 

reports for BW

is being review

the basis for G

and GALL AM

reactor vessel 

BWRVIP repo

GALL AMP XI

line items for B

internals. Acco

for PWR intern

for BWR core 

loss of fracture 

by neutron irra

embrittlement 

monitored; ins

loss of fracture 

component int

managed by u

volumetric exa

to monitor for c

components a
April 2011 IV-333 NUREG-1950

Table IV-19. Analysis and Disposition of Chapter 4 Public Comments on May 2010 Public Comment Draft 

Comment 

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Commenter 

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Comment NRC Disposition Tech

discussed in comment 2 [Comment 131 of 

NUREG 1950], the cumulative fatigue usage 

in air (i.e., without considering the effects of 

neutron irradiation and coolant environment 

on fatigue life) is typically above 0.5 for upper 

and lower core plate in PWRs, and for the 

core shroud in BWRs it is above 0.35. To 

prevent unstable crack extension if a crack is 

present in these components, a TLAA to 

evaluate the ductility reduction of fracture 

toughness of highly stressed vessel internals 

should be performed. In reactor vessel 

design, since the material fracture toughness 

is based on an explicitly assumed 40-year 

plant life, pursuant to 10 CFR 54.21 (c)(1), the 

applicant should evaluate the ductility 

reduction of fracture toughness for the reactor 

vessel internals.

applicable red

toughness pro

evaluations if c

in the compon

extensive eno

supplemental 

tolerance eval

MRP-227 or B

or ASME Code

requirements. 

BWRVIP-76 in

criteria are req

with GALL AM

PWRs and GA

BWRs.

These AMPs a

will be sufficie

aging effect of 

toughness of a

steels resulting 

irradiation duri

extended oper

with 10 CFR 5

131 4.3

ML101660084, 

Comment 2

In NUREG-1800, Rev. 2, Section 4.3.1, item 

#3, environmental fatigue calculations are 

recommended only for ASME Code Class 1 

reactor coolant pressure boundary

components. Similarly, in NUREG-1801, Rev. 

2, Tables IV B1 through IV B4, fatigue of

the reactor vessel internal components is 

considered a time-limited aging analysis

(TLAA) to be evaluated for the period of 

The staff disagrees 

with this comment. 

The SRP-LR has not 

been changed.

The third party

to expanding t

environmental

calculations fo

components a

structures (in a

Code Class 1 

piping location

The third party 
NUREG-1950 IV-334 April 2011

Table IV-19. Analysis and Disposition of Chapter 4 Public Comments on May 2010 Public Comment Draft 

Comment 

Number

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Document and 

Commenter 

Reference No.

Comment NRC Disposition Tech

extended operation. However, the effects of

coolant environment are not included in the 

evaluation. It is well known that unlike

carbon and low-alloy steels, which show little 

or no environmental effects on fatigue

crack initiation in low corrosion potential 

environments such as hydrogen water

chemistry BWR or PWR environment, the 

fatigue life of austenitic stainless steels (SSs)

can be decreased by a factor of up to 10 in 

these environments. Regulatory Guide

(RG)-1.207 provides guidance for determining 

the acceptable fatigue life of ASME

Class 1 components with consideration of the 

LWR environment. Fatigue evaluations

for reactor vessel internal components 

performed by license renewal applicants, yield

cumulative fatigue usage in air above 0.5 for 

upper and lower core plate in PWRs, and 

above 0.35 for BWR core shroud.

The design and construction of the core 

support structures of new reactors comply 

with the requirements of ASME Section III, 

Subsection NG, "Core Support Structures," 

and NUREG-0800, "Standard Review Plan" 

(SRP) Section 3.9.3. In addition, the design 

criteria, loading conditions, and analyses that 

provide the bases for the design of reactor

internals other than the core support 

structures also meet the guidelines of 

Subsection NG-3000 and are constructed not 

to affect the integrity of the core support 

Section III Par

support his po

NG-2160 state

responsibility o

material suitab

in the design s

3250), with sp

given to the ef

conditions upo

the material.”

The staff’s gui

4.3.3.1.3 of NU

Revision 2, St

for Review of L

Applications fo

Plants (SRP-L

Sections 4.3.2

SRP-LR, Revi

relative to reco

performance o

adjustments o

ASME Section 

components, w

the SRP-LR to 

resolution of te

fatigue assess

in Generic Saf

Fatigue Evalua

Components f

(GSI-190). 

The staff has d
April 2011 IV-335 NUREG-1950

Table IV-19. Analysis and Disposition of Chapter 4 Public Comments on May 2010 Public Comment Draft 

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Number

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Comment NRC Disposition Tech

structures adversely (Subsection NG 1122). 

Subsection NG-3200 describes the 

requirements for the acceptability of a design 

by analysis, including an analysis for cyclic 

operation. The effect of service conditions 

such as neutron irradiation or the hightemperature coolant environment on fatigue 

life has to be included in the analysis. 

Subsection NG-2160 "Deterioration of 

Material in Service" states that it is the 

responsibility of the Owner to select material 

suitable for the conditions stated in the Design 

Specification (NCA-3250), with specific 

attention being given to the effects of service 

conditions upon the properties of the material.

The fatigue evaluations that are being 

performed for reactor core internal

components of operating reactors do not 

include the possible effects of irradiation on 

fatigue life. Information regarding the effects 

of irradiation on fatigue crack initiation is, at 

best, very limited. The only data on the effect 

of neutron irradiation on fatigue crack initiation 

and fatigue crack growth rate were obtained 

under the fast breeder reactor program. Most 

of the data are on fatigue crack growth rates, 

and were obtained on SSs irradiated in fast 

reactors (primarily EBR-lI) at 370-450°C and 

tested at 427-593°C. For Type 304 and

316 SS irradiated at 405-410 °C to 1.2x1022

n/cm2 (E>0.1 MeV), the crack growth rates at 

427°C are up to a factor of 2 higher than 

scope of the s

concerns in GS

scope of the s

environmental

analysis studie

6260, Applicat

5999 Interim F

Selected Nucl

Components, 

coolant pressu

components, w

scope of ASM

Subsection NB 

requirements. 

The staff does 

pursuant to 10 

ASME Section 

requirements, 

perform CUF c

RVI componen

as core suppo

reactor vessel

applicable pro

Section III Sub

exemption of a 

structure comp

analyzed unde

However, the s

ASME Section 

requirements d

mandated prov

CUF calculatio
NUREG-1950 IV-336 April 2011

Table IV-19. Analysis and Disposition of Chapter 4 Public Comments on May 2010 Public Comment Draft 

Comment 

Number

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Commenter 

Reference No.

Comment NRC Disposition Tech

those for nonirradiated material at low ΔK 

values (less than 40 ksi in.1/2 ). A similar 

behavior is observed for Type 316 weld.

Limited fatigue strain-vs.-life (S-N) data on 

irradiated SSs shows moderate decrease in

life in the low-cycle regime and superior 

fatigue life in the high-cycle regime. There is 

no fatigue S-N data on materials irradiated 

under LWR conditions and tested at LWR 

operating temperatures. Several studies have 

shown significant differences in the

microstructure and microchemistry of 

materials irradiated in LWRs and fast 

reactors. Specifically, the effect of cavities and 

He bubbles in austenitic SSs irradiated at 

temperatures above 320°C to high neutron 

dose levels in PWRs.

Since the possible effect of neutron irradiation 

on fatigue life is not considered in the current 

fatigue evaluations, if the known effect of 

LWR coolant environments on fatigue life is 

also ignored, the fatigue evaluations would be 

severely compromised. I would like to point 

out that SRP-LR (NUREG-1800, Rev.1) 

Section 4.3.1.1.1 states, "ASME Class 1

components, which include core support 

structures, are analyzed for metal fatigue.

ASME Section III requires a fatigue analysis 

for Class 1 components that considers all 

transient loads based on the anticipated 

number of transients." Therefore,

environmental effects should have been 

structures by a

adjustment fac

has not determ

incorporation o

effects is nece

components, b

item for future 

The staff does 

number of indu

are currently w

establishing pr

evaluating the 

environmental 

reactor coolan

for RVI compo

support structu

organizations 

applicable ASM

subcommittee

requirements, 

applicable com

BWRVIP and 

staff’s position 

appropriate to 

comment as p

update of the G

However, the s

technical upda

SRP-LR conte

issue by using 

warranted.
April 2011 IV-337 NUREG-1950

Table IV-19. Analysis and Disposition of Chapter 4 Public Comments on May 2010 Public Comment Draft 

Comment 

Number

Location in 

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Commenter 

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Comment NRC Disposition Tech

included in the fatigue evaluation for reactor

core internal components, in support of 

license renewal. I request the staff to 

reconsider the regulatory position to consider 

environmental effects only for Class 1

pressure boundary components and not for 

the reactor core support structures.
NUREG-1950 IV-338 April 2011

Table IV-20. Analysis and Disposition of Appendices Public Comments on May 2010 Public Comment Dr

Rev. 2 

Comment 

Number

Location in 

Document and 

Public ID No.

Comment/Proposed Change and Rationale NRC Disposition Tech

N/A N/A There were no public comments on the 

Appendices to the SRP-LR

N/A N/A
April 2011 IV-339 NUREG-1950

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Houston, TX, 2007.

NACE Standard RP0285-2002, “Corrosion Control of Underground Storage Tank Systems by 

Cathodic Protection,” National Association of Corrosion Engineers International, 2002.

NACE Standard RP0285-95, “Corrosion Control of Underground Storage Tank Systems by 

Cathodic Protection,” National Association of Corrosion Engineers International, 1995.

NACE Standard RP0169-96, “Control of External Corrosion on Underground or Submerged 

Metallic Piping Systems,” National Association of Corrosion Engineers International, 1996.

NFPA 24, “Standard for the Installation of Private Fire Service Mains and Their Appurtenances,” 

National Fire Protection Association, Quincy, MA.

NFPA 25, “Inspection, Testing and Maintenance of Water-Based Fire Protection Systems,” 

National Fire Protection Association, 1998 and later editions. 

NextEra Energy Seabrook, LLC, et al., Juno Beach, FL, “License Renewal Application, 

Seabrook Station, Unit No. 1, June 2010. 

NEI 09-14, “Guideline for the Management of Buried Piping Integrity,” Nuclear Energy Institute, 

Washington, D.C., January 2010.
NUREG-1950 IV-344 April 2011

NEI 07-07, “Industry Groundwater Protection Initiative – Final Guidance Document,” Nuclear 

Energy Institute, August 2007.

NEI 03-08, “Guideline for the Management of Materials Issues,” Nuclear Energy Institute, May 

2003.

NEI 96-03, “Guideline for Monitoring the Condition of Structures at Nuclear Power Plants,” 

Nuclear Energy Institute, 1996.

NEI 97-06, Revision 1 and Rev. 2, “Steam Generator Program Guidelines,” Revision 2, Nuclear 

Energy Institute, September 2005. 

Nippon Steel, “Super-austenitic Steel for Piping and Tubing Applications,” Technical Report No. 

90, July 2004

NRC Branch Technical Position IQMB-1, “Quality Assurance for Aging Management Programs,” 

U.S. Nuclear Regulatory Commission, Washington, DC.

NRC Branch Technical Position RLSB-2, “Generic safety Issues Related to Aging,” U.S. Nuclear 

Regulatory Commission, Washington, DC.

NRC Bulletin 96-03, “Potential Plugging of Emergency Core Cooling Suction Strainers by Debris 

in Boiling-Water Reactors,” U.S. Nuclear Regulatory Commission, Washington, DC, May 6, 

1996.

NRC Final License Renewal Interim Staff Guidance LR-ISG-27007-02, “Groundwater 

Contamination (Tritium) at Nuclear Plants-Task Force – Final Report,” Sept 1, U.S. Nuclear 

Regulatory Commission, Washington, DC.

NRC Staff Guidance LR-ISG-2009-01, “Aging Management of Spent Fuel Pool NeutronAbsorbing Materials Other Than Boraflex,” U.S. Nuclear Regulatory Commission, Washington, 

DC, 2010. 

NRC GL 04-02, “Potential Impact of Debris Blockage on Emergency Recirculation during 

Design Basis Accidents at Pressurized-Water Reactors,” U.S. Nuclear Regulatory Commission,

Washington, DC, September 13, 2004.

NRC GL 88-01, “NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping,” January 

25, 1988; Supplement 1, U.S. Nuclear Regulatory Commission, Washington, DC, February 4, 

1992.

NRC GL 88-05, “Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary

Components in PWR Plants,” U.S. Nuclear Regulatory Commission, Washington, DC, March 

17, 1988.

NRC GL 88-14, “Instrument Air Supply Problems Affecting Safety-Related Components,” U.S. 

Nuclear Regulatory Commission, Washington, DC, August 8, 1988.

NRC GL 89-10, “Safety-Related Motor-Operated Valve Testing and Surveillance,” June 28, 

1989.

NRC GL 89-13, “Service Water System Problems Affecting Safety-Related Components,” U.S. 

Nuclear Regulatory Commission, Washington, DC, July 18, 1989.

NRC GL 98-04, “Potential for Degradation of the Emergency Core Cooling System and the 

Containment Spray System after a Loss-of-Coolant Accident Because of Construction and 

Protective Coating Deficiencies and Foreign Material in Containment,” U.S. Nuclear Regulatory 

Commission, Washington, DC, July 14, 1998.
April 2011 IV-345 NUREG-1950

NRC GL 2007-01, Summary Report, “Inaccessible or Underground Power Cable Failures that 

Disable Accident Mitigation Systems or Cause Plant Transients,” U.S. Nuclear Regulatory 

Commission, Washington, DC, November 12, 2008.

NRC IN 88-82, “Torus Shells with Corrosion and Degraded Coatings in BWR Containments,” 

U.S. Nuclear Regulatory Commission, October 14, 1988 and Supplement 1, May 2, 1989. 

NRC IN 90-04, “Cracking of the Upper Shell-to-Transition Cone Girth Welds in Steam 

Generators,” U.S. Nuclear Regulatory Commission, January 26, 1990.

NRC IN 92-20, “Inadequate Local Leak Rate Testing,” U.S. Nuclear Regulatory Commission, 

March 3, 1992.

NRC IN 99-19, “Rupture of the Shell Side of a Feedwater Heater at the Point Beach Nuclear

Plant,” U.S. Nuclear Regulatory Commission, Washington, DC, June 23, 1999.

NRC, Letter from Christopher I. Grimes, U.S. Nuclear Regulatory Commission, License 

Renewal and Standardization Branch, to Douglas J. Walters, Nuclear Energy Institute, License 

Renewal Issue No. 98-0030, “Thermal Aging Embrittlement of Cast Stainless Steel 

Components,” May 19, 2000 (ADAMS Accession No. ML003717179). 

NRC, Letter to Carl Terry of Niagara Mohawk Power Company, BWRVIP Chairman, from 

Christopher Grimes, of NRC, “Acceptance for Referencing of EPRI Proprietary Report TR113596, BWR Vessel and Internals Project, BWR Reactor Pressure Vessel Inspection and Flaw 

Evaluation Guidelines BWRVIP-74), and Appendix A, Demonstration of Compliance with the 

Technical Information Requirements of the License Renewal Rule (10CFR54.21),” dated 

October 18, 2001. 

NRC, Letter to Alexander Marion of NEI, from P.T. Kuo of NRC, on the staff’s resolution of 

License Renewal Interim Staff Guidance LR-ISG-23, dated December 20, 2006 

(ML062990314).

NRC, Letter withdrawing LR-ISG-23, “Replacement Parts Necessary to Meet 10 CFR 50.48 

(Fire Protection),” December 20, 2006 (ML062990314).

NUREG-0313, Rev. 2, “Technical Report on Material Selection and Processing Guidelines for 

BWR Coolant Pressure Boundary Piping,” U.S. Nuclear Regulatory Commission, Washington, 

DC, January 1988.

NUREG-0619, “BWR Feedwater Nozzle and Control Rod Drive Return Line Nozzle Cracking,” 

U.S. Nuclear Regulatory Commission, Washington, DC, November 1980

NUREG-1339, “Resolution of Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear 

Power, U.S. Nuclear Regulatory Commission, Washington, DC.

NUREG-1522, “Assessment of Inservice Conditions of Safety-Related Nuclear Plant Structures, 

U.S. Nuclear Regulatory Commission, Washington, DC.

NUREG-1557, Summary of Technical Information and Agreements from Nuclear Management 

and Resources Council Industry Reports Addressing License Renewal, U.S. Nuclear Regulatory 

Commission, Washington, DC, October 1996.

NUREG-1800, “Standard Review Plan for Review of License Renewal Applications for Nuclear 

Power Plants,” Rev. 2, U.S. Nuclear Regulatory Commission, Washington, DC.

NUREG-1801, “Generic Aging Lessons Learned (GALL) Report,” and Revision 2 to NUREG1800, “Standard Review Plan for Review of License Renewal Applications for Nuclear Power 

Plants,.” Rev 0, 1, and 2, U.S. Nuclear Regulatory Commission, Washington, DC.
NUREG-1950 IV-346 April 2011

NUREG-1832, “Analysis of Public Comments on the Revised License Renewal Guidance 

Documents,” U.S. Nuclear Regulatory Commission, Washington, DC, 2005. 

NUREG-1833, “Technical Bases for Revision to the License Renewal Guidance Documents,” 

U.S. Nuclear Regulatory Commission, Washington, DC, October 2005.

NUREG/CR-4513, Rev. 1, “Estimation of Fracture Toughness of Cast Stainless Steels during 

Thermal Aging in LWR Systems,” U.S. Nuclear Regulatory Commission, August 1994. 

NUREG-1339, “Resolution of Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear 

Power Plants,” U.S. Nuclear Regulatory Commission, Washington, DC.

NUREG/CR-5704, “Effects of LWR Coolant Environments on Fatigue Design Curves of 

Austenitic Stainless Steels,” U.S. Nuclear Regulatory Commission, Washington, DC, April 1999. 

NUREG/CR-6260, Application of NUREG/CR-5999 Interim Fatigue Curves to Selected Nuclear

Power Plant Components," U.S. Nuclear Regulatory Commission, Washington, DC.

NUREG/CR-6583, “Effects of LWR Coolant Environments on Fatigue Design Curves of Carbon 

and Low–Alloy Steels,” U.S. Nuclear Regulatory Commission, Washington, DC, March 1998.

NUREG/CR-6909, “Effect of LWR Coolant Environments on Fatigue Life of Reactor Materials” 

(Final Report), U.S. Nuclear Regulatory Commission, Washington, DC, February 2007.

NUREG/CR-6923, Expert Panel Report on Proactive Materials Degradation Assessment, U.S. 

Nuclear Regulatory Commission, Washington, DC, February 2007.

NRC RG 1.21, “Measuring, Evaluating, and Reporting Radioactive Material in Liquid and 

Gaseous Effluents and Solid Waste,” U.S. Nuclear Regulatory Commission, Washington, DC,

June 2009.

NRC RG 1.35.1, “Determining Prestressing Forces for Inspection of Prestressed Concrete 

Containments,” U.S. Nuclear Regulatory Commission, Washington, DC, July 1990.

NRC RG 1.54 “Service Level I, II, and III Protective Coating Applied to Nuclear Power Plants,” 

Rev 0, Revision 1, and later, U.S. Nuclear Regulatory Commission, Washington, DC,. 

NRC RG 1.65, “Material and Inspection for Reactor Vessel Closure Studs,” Revision 1, U.S. 

Nuclear Regulatory Commission, Washington, DC, April 2010.

NRC RG 1.99 “Radiation Embrittlement of Reactor Vessel Materials,” Revision 2, U.S. Nuclear 

Regulatory Commission, Washington, DC, May 1988 (ADAMS Accession No. ML003740284). 

NRC RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants,” 

Revision 1, U.S. Nuclear Regulatory Commission, Washington, DC, March 1978.

NRC RG 1.137, “Fuel Oil Systems for Standby Diesel Generators,” Revision 1, U.S. Nuclear 

Regulatory Commission, Washington, DC, October 1979.

NRC RG 1.160, “Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,” 

Revision 2, U.S. Nuclear Regulatory Commission, Washington, DC, March 1997. 

NRC RG 1.189, “Fire Protection for Nuclear Power Plants,” Rev. 2, U.S. Nuclear Regulatory 

Commission, Washington, DC, November 2009.

NRC RG 1.190, “Calculational and Dosimetry Methods for Determining Pressure Vessel 

Neutron Fluence,” U.S. Nuclear Regulatory Commission, Washington, DC, March 31, 2001 

(ADAMS Accession Number ML010890301). 
April 2011 IV-347 NUREG-1950

NRC RG 1.207, “Guidelines for Evaluating Fatigue Analyses Incorporating the Life Reduction of 

Metal Components due to the Effects of the Light-Water Reactor Environment for New 

Reactors,” U.S. Nuclear Regulatory Commission, Washington, DC, March 2007.

NRC Regulatory Information Summary (RIS) 2008-25, “Regulatory Approach for Primary Water 

Stress Corrosion Cracking (PWSCC) of Dissimilar Metal Butt Welds in Pressurized Water 

Reactor Primary Coolant System Piping,” U.S. Nuclear Regulatory Commission, Washington, 

DC, October 2008. 

NRC "Safety Evaluation Report Related to the License Renewal of the Beaver Valley Power 

Station, Units 1 and 2," U.S. Nuclear Regulatory Commission, Washington, DC, June 2009. In 

October 2009, the report was published as NUREG-1929. 

NRC “Safety Evaluation Report with Open Items Related to the License Renewal of the 

Shearon Harris Nuclear Power Plant, Unit 1," U.S. Nuclear Regulatory Commission, 

Washington, DC, March 18, 2008. The report is available in ADAMS under accession number 

ML080780632. In December 2008, the report was issued as NUREG-1916, Vol. 1 and Vol. 2. 

The report is available in ADAMS under accession numbers ML082340985. NRC “Safety 

Evaluation Report Related to the License Renewal of Oyster Creek Generating Station,” U.S. 

Nuclear Regulatory Commission, Washington, DC, March 2007. The report is available in 

ADAMS under accession number ML070890637. In September 2008, a supplement was 

issued, available in ADAMS under accession number ML080230078. 

NRC "Safety Evaluation Report Related to the License Renewal of Pilgrim Nuclear Power 

Station," U.S. Nuclear Regulatory Commission, Washington, DC, June 2007. In September

2007, a supplement to the report was issued. In November 2007, the report was issued as 

NUREG-1891.

NRC "Safety Evaluation Report Related to the License Renewal of Three Mile Island Nuclear 

Station, Unit 1," U.S. Nuclear Regulatory Commission, Washington, DC, June 30, 2009. In 

October 2009, the report was issued as NUREG-1928.

NRC “Safety Evaluation Report Related to the License Renewal of Vogtle Electric Generating 

Plant, Units 1 and 2," U.S. Nuclear Regulatory Commission, Washington, DC, November 20, 

2008. In April 2009, the report was issued as NUREG-1920, Volume 1-part 1, Volume 1-part 2

and Volume 2. 

NRC “Safety Evaluation Report Related to the License Renewal of Vermont Yankee Nuclear 

Power Station" (NUREG-1907), May 2008. In September 2009, Supplement 1 to NUREG 1907 

was issued.

NRC "Safety Evaluation Report Related to the License Renewal of Wolf Creek Generating 

Station," U.S. Nuclear Regulatory Commission, Washington, DC, July 2008. The report is 

available in ADAMS under accession number ML082180210. In October 2008, the report was 

issued as NUREG-1915. The report is available in ADAMS under accession number 

ML083090483.

NRC Staff Position and Rationale for the Final License Renewal Interim Staff Guidance LR-ISG2006-01, “Plant-Specific Aging Management Program for Inaccessible Areas of Boiling Water 

Reactor (BWR) Mark I Steel Containments Drywell Shell,” U.S. Nuclear Regulatory 

Commission, Washington, DC, November 16, 2006. Notice of availability was published in the 

Federal Register, November 24, 2006 (71 FR 67923).

NRC Transcript Adjudicatory Hearing Pilgrim Nuclear Power Station’s License Renewal 

Application, U.S. Nuclear Regulatory Commission, Washington, DC, April 10, 2008, pgs., 769-
NUREG-1950 IV-348 April 2011

770; available NRC Electronic Reading Room (www.nrc.gov); ADAMS accession number 

ML081070329.

Draft “Standard Review Plan for Review of License Renewal Applications for Nuclear Power 

Plants” (NUREG-1800), Revision 2 and Draft “Generic Aging Lessons Learned (GALL) Report” 

(NUREG-1801), Revision 2, issued April 1, 2010, and published in the Federal Register Vol. 75, 

May 18, 2010 pages 27838 - 27840 (75 FR 27838) Office of the Federal Register, National 

Archives and Records Administration.

ULNRC-4233, “Manual Reactor Trip Due To Heater Drain System Pipe Rupture Caused By 

Flow Accelerated Corrosion, LER 1999-003-01,” Callaway Unit 1, Union Electric Co., May 1, 

2000. 

PPI Technical Report 19, “Chemical Resistance of Thermoplastic Piping Materials,” Plastic Pipe 

Institute, 2007.
April 2011 A-1 NUREG-1950

APPENDIX A: Crosswalk and Staff Technical Positions

A.1 GALL Report 2000-2005-2010 Crosswalk

GALL Rev. 2 contains item numbers (e.g., “IV.A1.R-04”) that have been assigned to each AMR 

line item. To assist in relating these line items to the AMR line items in GALL Rev. 1 and Rev. 0, 

the tables in this appendix have been provided.

For each system chapter in GALL Rev. 2 (Chapters II through VIII), these tables relate the item 

numbers in GALL Rev. 2 to those in GALL Revisions 1 and 0. For example, as shown in Table 

A-3, “Relationship of Reactor Vessel, Internals and Reactor Coolant (RCS) System IDs in GALL 

Report,” item IV.A1.R-04 in Rev. 2 (which is located in the reactor vessel subsystem in Chapter 

IV) relates to items A1.1-b, A1.2-a, and others in GALL Rev. 0 and to item R-04 in GALL Rev 1. 

All GALL Rev. 0 line items are related to one or more line items in GALL Rev. 1 and 2, except 

for those that are retired. However, not all GALL Rev. 1 and 2 items relate back to a GALL Rev. 

0 line item (i.e., when a new item was added to GALL Rev. 1 and 2). In such cases, although 

there is no GALL Rev. 0 item number to relate to, the relationship table still contains a row for 

the new item. Items that are new in Rev. 2 have “none” in the Rev. 0 and Rev. 1 columns. For 

items that were new in Rev. 1, the GALL Rev. 0 column contains only a subsystem identifier, 

not a GALL Rev. 0 item number. For example, RP-25 is a new item in GALL Rev. 1. Table A-3 

shows “RP-25” is related to “A1.” in GALL Rev. 0, indicating that RP-25 has been added in Rev. 

1 of GALL and it can be found in subsystem A1, the reactor vessel subsystem in Chapter IV.

The sequence of the entries for new items to GALL Rev. 2, i.e., those that are listed at the 

beginning of each table with “none” in the first two columns, and for items in a given cell in the 

Rev.2 column is alphabetical order of structure; followed by alphabetical order of material, 

followed by alphabetical order of environment. 
NUREG-1950 A-2 April 2011

Table A-1. Relationship of 

Containment Structures IDs in GALL 

Report, Chapter II

Rev.0 Rev. 1 Rev. 2

None None

II.B1.2.CP-114

II.B2.1.CP-114

II.B2.2.CP-114

None None II.A3.CP-148

II.B4.CP-148

None None II.A3.CP-150

II.B4.CP-150

None None II.A3.CP-152

II.B4.CP-152

None None II.B1.1.CP-44

A1.1-a C-01

II.A1.CP-147

II.A1.CP-31

A1.1-b C-02

II.A1.CP-102

II.A1.CP-32

A1.1-c C-03

II.A1.CP-100

II.A1.CP-87

A1.1-d C-04

II.A1.CP-33

II.A1.CP-67

A1.1-e C-05

II.A1.CP-68

II.A1.CP-97

A1.1-f C-37 II.A1.CP-101

A1.1-g C-07

II.B3.2.C-07

II.B3.1.C-07

II.B2.2.C-07

II.B1.2.C-07

II.A2.C-07

II.A1.C-07

A1.1-h C-08 II.A1.CP-34

A1.2-a C-09

II.B3.2.CP-35

II.A2.CP-35

II.A1.CP-35

II.A1.CP-98

II.A2.CP-98

II.B3.2.CP-98

A1.3-a C-10

II.B2.2.C-10

II.A1.C-10

Table A-1. Relationship of 

Containment Structures IDs in GALL 

Report, Chapter II

Rev.0 Rev. 1 Rev. 2

A1.3-b C-11

II.B2.2.C-11

II.A1.C-11

A2.1-a C-09

II.B3.2.CP-35

II.A2.CP-35

II.A1.CP-35

II.A1.CP-98

II.A2.CP-98

II.B3.2.CP-98

A2.2-a C-28

II.A2.CP-51

II.A2.CP-70

A2.2-b C-30

II.A2.CP-155

II.B3.1.CP-156

II.B3.1.CP-53

II.A2.CP-53

A2.2-c C-25

II.B3.1.CP-71

II.A2.CP-71

II.B3.1.CP-72

II.A2.CP-72

A2.2-d C-38

II.A2.CP-104

II.A2.CP-58

A2.2-e C-43

II.A2.CP-74

II.B3.1.CP-74

II.B3.1.CP-75

II.A2.CP-75

A2.2-f C-36

II.B3.1.CP-69

II.A2.CP-69

A2.2-g C-07

II.B3.2.C-07

II.B3.1.C-07

II.B2.2.C-07

II.B1.2.C-07

II.A2.C-07

II.A1.C-07

A2.2-h C-34 Retired

A3.1-a C-12

II.B4.CP-36

II.A3.CP-36

A3.1-b C-13 II.B4.C-13
April 2011 A-3 NUREG-1950

Table A-1. Relationship of 

Containment Structures IDs in GALL 

Report, Chapter II

Rev.0 Rev. 1 Rev. 2

II.A3.C-13

A3.1-c C-14

II.B4.CP-37

II.A3.CP-37

A3.1-d C-15

II.B4.CP-38

II.A3.CP-38

A3.2-a C-16

II.B4.C-16

II.A3.C-16

A3.2-b C-17

II.B4.CP-39

II.A3.CP-39

A3.3-a C-18

II.B4.CP-40

II.A3.CP-40

II.B4.CP-41

II.A3.CP-41

B1.1.1-a C-19

II.B1.1.CP-109

II.B3.1.CP-113

II.B3.1.CP-158

II.B3.1.CP-43

II.B1.1.CP-43

II.B1.1.CP-48

B1.1.1-b C-20 II.B1.1.CP-49

B1.1.1-c C-21 II.B1.1.C-21

B1.1.1-d C-22 II.B1.1.CP-50

B1.1.1-e C-23

II.B2.2.C-23

II.B2.1.C-23

II.B1.2.C-23

II.B1.1.C-23

B1.2. C-41

II.B2.2.CP-79

II.B1.2.CP-79

II.B1.2.CP-80

II.B2.2.CP-80

B1.2. C-35

II.B2.2.CP-57

II.B1.2.CP-57

B1.2. C-06

II.B3.2.CP-105

II.B2.2.CP-105

II.B1.2.CP-105

B1.2. C-07 II.B3.2.C-07

Table A-1. Relationship of 

Containment Structures IDs in GALL 

Report, Chapter II

Rev.0 Rev. 1 Rev. 2

II.B3.1.C-07

II.B2.2.C-07

II.B1.2.C-07

II.A2.C-07

II.A1.C-07

B1.2. C-39

II.B2.2.CP-59

II.B1.2.CP-59

II.B2.2.CP-99

II.B1.2.CP-99

B1.2. C-23

II.B2.2.C-23

II.B2.1.C-23

II.B1.2.C-23

II.B1.1.C-23

B1.2. C-26

II.B2.2.CP-106

II.B1.2.CP-106

B1.2. C-46

II.B1.2.CP-117

II.B2.2.CP-117

II.B2.1.CP-117

II.B2.1.CP-46

II.B2.2.CP-46

II.B1.2.CP-46

II.B2.2.CP-63

II.B2.1.CP-63

II.B1.2.CP-63

B1.2. C-31

II.B2.2.CP-110

II.B1.2.CP-110

II.B2.2.CP-54

II.B1.2.CP-54

B1.2. C-49

II.B2.2.C-49

II.B1.2.C-49

B2.1.1-a C-46

II.B1.2.CP-117

II.B2.2.CP-117

II.B2.1.CP-117

II.B2.1.CP-46

II.B2.2.CP-46

II.B1.2.CP-46

II.B2.2.CP-63
NUREG-1950 A-4 April 2011

Table A-1. Relationship of 

Containment Structures IDs in GALL 

Report, Chapter II

Rev.0 Rev. 1 Rev. 2

II.B2.1.CP-63

II.B1.2.CP-63

B2.1.1-b C-44

II.B2.1.CP-107

II.B2.1.CP-142

B2.1.1-c C-45 II.B2.1.C-45

B2.1.1-d C-23

II.B2.2.C-23

II.B2.1.C-23

II.B1.2.C-23

II.B1.1.C-23

B2.2.1-a C-31

II.B2.2.CP-110

II.B1.2.CP-110

II.B2.2.CP-54

II.B1.2.CP-54

B2.2.1-b C-26

II.B2.2.CP-106

II.B1.2.CP-106

B2.2.1-c C-39

II.B2.2.CP-59

II.B1.2.CP-59

II.B2.2.CP-99

II.B1.2.CP-99

B2.2.1-d C-41

II.B2.2.CP-79

II.B1.2.CP-79

II.B1.2.CP-80

II.B2.2.CP-80

B2.2.1-e C-06

II.B3.2.CP-105

II.B2.2.CP-105

II.B1.2.CP-105

B2.2.1-f C-07

II.B3.2.C-07

II.B3.1.C-07

II.B2.2.C-07

II.B1.2.C-07

II.A2.C-07

II.A1.C-07

B2.2.1-g C-35

II.B2.2.CP-57

II.B1.2.CP-57

B2.2.2-a C-46

II.B1.2.CP-117

II.B2.2.CP-117

Table A-1. Relationship of 

Containment Structures IDs in GALL 

Report, Chapter II

Rev.0 Rev. 1 Rev. 2

II.B2.1.CP-117

II.B2.1.CP-46

II.B2.2.CP-46

II.B1.2.CP-46

II.B2.2.CP-63

II.B2.1.CP-63

II.B1.2.CP-63

B2.2.2-b C-49

II.B2.2.C-49

II.B1.2.C-49

B2.2.2-c C-47 II.B2.2.CP-64

B2.2.2-d C-48 II.B2.2.C-48

B2.2.2-e C-23

II.B2.2.C-23

II.B2.1.C-23

II.B1.2.C-23

II.B1.1.C-23

B2.2.3-a C-10

II.B2.2.C-10

II.A1.C-10

B2.2.3-b C-11

II.B2.2.C-11

II.A1.C-11

B3.1.1-a C-19

II.B1.1.CP-109

II.B3.1.CP-113

II.B3.1.CP-158

II.B3.1.CP-43

II.B1.1.CP-43

II.B1.1.CP-48

B3.1.1-b C-24

II.B3.2.C-24

II.B3.1.C-24

B3.1.2-a C-30

II.A2.CP-155

II.B3.1.CP-156

II.B3.1.CP-53

II.A2.CP-53

B3.1.2-b C-25

II.B3.1.CP-71

II.A2.CP-71

II.B3.1.CP-72

II.A2.CP-72

B3.1.2-c C-51 II.B3.1.CP-66
April 2011 A-5 NUREG-1950

Table A-1. Relationship of 

Containment Structures IDs in GALL 

Report, Chapter II

Rev.0 Rev. 1 Rev. 2

II.B3.1.CP-83

B3.1.2-d C-43

II.A2.CP-74

II.B3.1.CP-74

II.B3.1.CP-75

II.A2.CP-75

B3.1.2-e C-36

II.B3.1.CP-69

II.A2.CP-69

B3.1.2-f C-07

II.B3.2.C-07

II.B3.1.C-07

II.B2.2.C-07

II.B1.2.C-07

II.A2.C-07

II.A1.C-07

B3.1.2-g C-50 II.B3.1.CP-65

B3.1.2-g C-50 II.B3.1.CP-65

B3.2.1-a C-29

II.B3.2.CP-135

II.B3.2.CP-52

B3.2.1-b C-32

II.B3.2.CP-122

II.B3.2.CP-55

B3.2.1-c C-27

II.B3.2.CP-73

II.B3.2.CP-84

B3.2.1-d C-40

II.B3.2.CP-121

II.B3.2.CP-60

B3.2.1-e C-42

II.B3.2.CP-88

II.B3.2.CP-89

B3.2.1-f C-06

II.B3.2.CP-105

II.B2.2.CP-105

II.B1.2.CP-105

B3.2.1-g C-07

II.B3.2.C-07

II.B3.1.C-07

II.B2.2.C-07

II.B1.2.C-07

II.A2.C-07

II.A1.C-07

B3.2.1-h C-33 II.B3.2.CP-108

B3.2.2-a C-09 II.B3.2.CP-35

Table A-1. Relationship of 

Containment Structures IDs in GALL 

Report, Chapter II

Rev.0 Rev. 1 Rev. 2

II.A2.CP-35

II.A1.CP-35

II.A1.CP-98

II.A2.CP-98

II.B3.2.CP-98

B3.2.2-b C-24

II.B3.2.C-24

II.B3.1.C-24

B4.1-a C-12

II.B4.CP-36

II.A3.CP-36

B4.1-b C-13

II.B4.C-13

II.A3.C-13

B4.1-c C-14

II.B4.CP-37

II.A3.CP-37

B4.1-d C-15

II.B4.CP-38

II.A3.CP-38

B4.2-a C-16

II.B4.C-16

II.A3.C-16

B4.2-b C-17

II.B4.CP-39

II.A3.CP-39

B4.3-a C-18

II.B4.CP-40

II.A3.CP-40

II.B4.CP-41

II.A3.CP-41
NUREG-1950 A-6 April 2011

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

None None III.A3.TP-219

None None III.A6.TP-221

None None III.A6.TP-223

None None

III.B1.1.TP-226

III.B1.2.TP-226

III.B1.3.TP-226

None None

III.B1.1.TP-229

III.B1.2.TP-229

III.B1.3.TP-229

None None

III.B1.1.TP-232

III.B1.2.TP-232

III.B1.3.TP-232

None None

III.B1.1.TP-235

III.B1.2.TP-235

III.B1.3.TP-235

None None

III.A1.TP-248

III.A2.TP-248

III.A3.TP-248

III.A4.TP-248

III.A5.TP-248

III.A6.TP-248

III.A7.TP-248

III.A8.TP-248

III.A9.TP-248

III.B2.TP-248

III.B3.TP-248

III.B4.TP-248

III.B5.TP-248

None None

III.A1.TP-261

III.A2.TP-261

III.A3.TP-261

III.A4.TP-261

III.A5.TP-261

III.A6.TP-261

III.A7.TP-261

III.A8.TP-261

III.A9.TP-261

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.B2.TP-261

III.B3.TP-261

III.B4.TP-261

III.B5.TP-261

None None

III.A1.TP-274

III.A2.TP-274

III.A3.TP-274

III.A4.TP-274

III.A5.TP-274

III.A7.TP-274

III.A8.TP-274

III.A9.TP-274

III.B2.TP-274

III.B3.TP-274

III.B4.TP-274

III.B5.TP-274

None None

III.A1.TP-300

III.A2.TP-300

III.A3.TP-300

III.A4.TP-300

III.A5.TP-300

III.A7.TP-300

III.A8.TP-300

III.A9.TP-300

III.B2.TP-300

III.B3.TP-300

III.B4.TP-300

III.B5.TP-300

None None III.A4.TP-301

None None III.A5.TP-34

A1.1-a T-01

III.A9.TP-108

III.A8.TP-108

III.A5.TP-108

III.A7.TP-108

III.A3.TP-108

III.A2.TP-108

III.A1.TP-108

III.A9.TP-23
April 2011 A-7 NUREG-1950

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.A8.TP-23

III.A7.TP-23

III.A5.TP-23

III.A3.TP-23

III.A2.TP-23

III.A1.TP-23

A1.1-b T-02

III.A9.TP-24

III.A8.TP-24

III.A7.TP-24

III.A5.TP-24

III.A3.TP-24

III.A2.TP-24

III.A1.TP-24

III.A9.TP-67

III.A8.TP-67

III.A7.TP-67

III.A5.TP-67

III.A3.TP-67

III.A1.TP-67

III.A2.TP-67

A1.1-c T-03

III.A1.TP-204

III.A8.TP-204

III.A7.TP-204

III.A5.TP-204

III.A4.TP-204

III.A3.TP-204

III.A2.TP-204

III.A9.TP-204

III.A2.TP-25

III.A3.TP-25

III.A4.TP-25

III.A5.TP-25

III.A7.TP-25

III.A1.TP-25

III.A9.TP-25

III.A8.TP-25

A1.1-d T-04

III.A9.TP-26

III.A7.TP-26

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.A5.TP-26

III.A4.TP-26

III.A3.TP-26

III.A2.TP-26

III.A1.TP-26

A1.1-e T-05

III.A9.TP-212

III.A8.TP-212

III.A7.TP-212

III.A5.TP-212

III.A3.TP-212

III.A2.TP-212

III.A1.TP-212

III.A9.TP-27

III.A8.TP-27

III.A7.TP-27

III.A5.TP-27

III.A3.TP-27

III.A2.TP-27

III.A1.TP-27

A1.1-f T-06

III.A9.TP-28

III.A7.TP-28

III.A5.TP-28

III.A4.TP-28

III.A3.TP-28

III.A2.TP-28

III.A1.TP-28

A1.1-g T-07

III.A9.TP-29

III.A8.TP-29

III.A7.TP-29

III.A5.TP-29

III.A3.TP-29

III.A2.TP-29

III.A1.TP-29

A1.1-h T-08

III.A9.TP-30

III.A8.TP-30

III.A7.TP-30

III.A6.TP-30

III.A5.TP-30
NUREG-1950 A-8 April 2011

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.A3.TP-30

III.A2.TP-30

III.A1.TP-30

A1.1-i T-09

III.A9.TP-31

III.A8.TP-31

III.A7.TP-31

III.A6.TP-31

III.A5.TP-31

III.A3.TP-31

III.A2.TP-31

III.A1.TP-31

A1.1-j T-10

III.A5.TP-114

III.A4.TP-114

III.A3.TP-114

III.A2.TP-114

III.A1.TP-114

A1.2-a T-11

III.A8.TP-302

III.A7.TP-302

III.A5.TP-302

III.A4.TP-302

III.A3.TP-302

III.A2.TP-302

III.A1.TP-302

A1.3-a T-12

III.A6.T-12

III.A5.T-12

III.A3.T-12

III.A2.T-12

III.A1.T-12

A2.1-a T-01

III.A9.TP-108

III.A8.TP-108

III.A5.TP-108

III.A7.TP-108

III.A3.TP-108

III.A2.TP-108

III.A1.TP-108

III.A9.TP-23

III.A8.TP-23

III.A7.TP-23

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.A5.TP-23

III.A3.TP-23

III.A2.TP-23

III.A1.TP-23

A2.1-b T-02

III.A9.TP-24

III.A8.TP-24

III.A7.TP-24

III.A5.TP-24

III.A3.TP-24

III.A2.TP-24

III.A1.TP-24

III.A9.TP-67

III.A8.TP-67

III.A7.TP-67

III.A5.TP-67

III.A3.TP-67

III.A1.TP-67

III.A2.TP-67

A2.1-c T-03

III.A1.TP-204

III.A8.TP-204

III.A7.TP-204

III.A5.TP-204

III.A4.TP-204

III.A3.TP-204

III.A2.TP-204

III.A9.TP-204

III.A2.TP-25

III.A3.TP-25

III.A4.TP-25

III.A5.TP-25

III.A7.TP-25

III.A1.TP-25

III.A9.TP-25

III.A8.TP-25

A2.1-d T-04

III.A9.TP-26

III.A7.TP-26

III.A5.TP-26

III.A4.TP-26
April 2011 A-9 NUREG-1950

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.A3.TP-26

III.A2.TP-26

III.A1.TP-26

A2.1-e T-05

III.A9.TP-212

III.A8.TP-212

III.A7.TP-212

III.A5.TP-212

III.A3.TP-212

III.A2.TP-212

III.A1.TP-212

III.A9.TP-27

III.A8.TP-27

III.A7.TP-27

III.A5.TP-27

III.A3.TP-27

III.A2.TP-27

III.A1.TP-27

A2.1-f T-06

III.A9.TP-28

III.A7.TP-28

III.A5.TP-28

III.A4.TP-28

III.A3.TP-28

III.A2.TP-28

III.A1.TP-28

A2.1-g T-07

III.A9.TP-29

III.A8.TP-29

III.A7.TP-29

III.A5.TP-29

III.A3.TP-29

III.A2.TP-29

III.A1.TP-29

A2.1-h T-08

III.A9.TP-30 

III.A8.TP-30

III.A7.TP-30

III.A6.TP-30

III.A5.TP-30

III.A3.TP-30

III.A2.TP-30

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.A1.TP-30

A2.1-i T-09

III.A9.TP-31

III.A8.TP-31

III.A7.TP-31

III.A6.TP-31

III.A5.TP-31

III.A3.TP-31

III.A2.TP-31

III.A1.TP-31

A2.1-j T-10

III.A5.TP-114

III.A4.TP-114

III.A3.TP-114

III.A2.TP-114

III.A1.TP-114

A2.2-a T-11

III.A8.TP-302

III.A7.TP-302

III.A5.TP-302

III.A4.TP-302

III.A3.TP-302

III.A2.TP-302

III.A1.TP-302

A2.3-a T-12

III.A6.T-12

III.A5.T-12

III.A3.T-12

III.A2.T-12

III.A1.T-12

A3.1-a T-01

III.A9.TP-108

III.A8.TP-108

III.A5.TP-108

III.A7.TP-108

III.A3.TP-108

III.A2.TP-108

III.A1.TP-108

III.A9.TP-23

III.A8.TP-23

III.A7.TP-23

III.A5.TP-23

III.A3.TP-23
NUREG-1950 A-10 April 2011

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.A2.TP-23

III.A1.TP-23

A3.1-b T-02

III.A9.TP-24

III.A8.TP-24

III.A7.TP-24

III.A5.TP-24

III.A3.TP-24

III.A2.TP-24 

III.A1.TP-24

III.A9.TP-67

III.A8.TP-67

III.A7.TP-67

III.A5.TP-67

III.A3.TP-67

III.A1.TP-67

III.A2.TP-67

A3.1-c T-03

III.A1.TP-204

III.A8.TP-204

III.A7.TP-204

III.A5.TP-204

III.A4.TP-204

III.A3.TP-204

III.A2.TP-204

III.A9.TP-204

III.A2.TP-25

III.A3.TP-25

III.A4.TP-25

III.A5.TP-25

III.A7.TP-25

III.A1.TP-25

III.A9.TP-25

III.A8.TP-25

A3.1-d T-04

III.A9.TP-26

III.A7.TP-26

III.A5.TP-26

III.A4.TP-26

III.A3.TP-26

III.A2.TP-26

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.A1.TP-26

A3.1-e T-05

III.A9.TP-212

III.A8.TP-212

III.A7.TP-212

III.A5.TP-212

III.A3.TP-212

III.A2.TP-212

III.A1.TP-212

III.A9.TP-27

III.A8.TP-27

III.A7.TP-27

III.A5.TP-27

III.A3.TP-27

III.A2.TP-27

III.A1.TP-27

A3.1-f T-06

III.A9.TP-28

III.A7.TP-28

III.A5.TP-28

III.A4.TP-28

III.A3.TP-28

III.A2.TP-28

III.A1.TP-28

A3.1-g T-07

III.A9.TP-29

III.A8.TP-29

III.A7.TP-29

III.A5.TP-29

III.A3.TP-29

III.A2.TP-29

III.A1.TP-29

A3.1-h T-08

III.A9.TP-30

III.A8.TP-30

III.A7.TP-30

III.A6.TP-30

III.A5.TP-30

III.A3.TP-30

III.A2.TP-30

III.A1.TP-30

A3.1-i T-09 III.A9.TP-31
April 2011 A-11 NUREG-1950

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.A8.TP-31

III.A7.TP-31

III.A6.TP-31

III.A5.TP-31

III.A3.TP-31

III.A2.TP-31

III.A1.TP-31

A3.1-j T-10

III.A5.TP-114

III.A4.TP-114

III.A3.TP-114

III.A2.TP-114

III.A1.TP-114

A3.2-a T-11

III.A8.TP-302

III.A7.TP-302

III.A5.TP-302

III.A4.TP-302

III.A3.TP-302

III.A2.TP-302

III.A1.TP-302

A3.3-a T-12

III.A6.T-12

III.A5.T-12

III.A3.T-12

III.A2.T-12

III.A1.T-12

A4.1-a T-06

III.A9.TP-28

III.A7.TP-28

III.A5.TP-28

III.A4.TP-28

III.A3.TP-28

III.A2.TP-28

III.A1.TP-28

A4.1-b T-03

III.A1.TP-204

III.A8.TP-204

III.A7.TP-204

III.A5.TP-204

III.A4.TP-204

III.A3.TP-204

III.A2.TP-204

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.A9.TP-204

III.A2.TP-25

III.A3.TP-25

III.A4.TP-25

III.A5.TP-25

III.A7.TP-25

III.A1.TP-25

III.A9.TP-25

III.A8.TP-25

A4.1-c T-10

III.A5.TP-114

III.A4.TP-114

III.A3.TP-114

III.A2.TP-114

III.A1.TP-114

A4.1-d T-04

III.A9.TP-26

III.A7.TP-26

III.A5.TP-26

III.A4.TP-26

III.A3.TP-26

III.A2.TP-26

III.A1.TP-26

A4.2-a T-11

III.A8.TP-302

III.A7.TP-302

III.A5.TP-302

III.A4.TP-302

III.A3.TP-302

III.A2.TP-302

III.A1.TP-302

A4.2-b T-13 III.A4.TP-35

A5.1-a T-01

III.A9.TP-108

III.A8.TP-108

III.A5.TP-108

III.A7.TP-108

III.A3.TP-108

III.A2.TP-108

III.A1.TP-108

III.A9.TP-23

III.A8.TP-23
NUREG-1950 A-12 April 2011

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.A7.TP-23

III.A5.TP-23

III.A3.TP-23

III.A2.TP-23

III.A1.TP-23

A5.1-b T-02

III.A9.TP-24

III.A8.TP-24

III.A7.TP-24

III.A5.TP-24

III.A3.TP-24

III.A2.TP-24

III.A1.TP-24

III.A9.TP-67

III.A8.TP-67

III.A7.TP-67

III.A5.TP-67

III.A3.TP-67

III.A1.TP-67

III.A2.TP-67

A5.1-c T-03

III.A1.TP-204

III.A8.TP-204

III.A7.TP-204

III.A5.TP-204

III.A4.TP-204

III.A3.TP-204

III.A2.TP-204

III.A9.TP-204

III.A2.TP-25

III.A3.TP-25

III.A4.TP-25

III.A5.TP-25

III.A7.TP-25

III.A1.TP-25

III.A9.TP-25

III.A8.TP-25

A5.1-d T-04

III.A9.TP-26

III.A7.TP-26

III.A5.TP-26

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.A4.TP-26

III.A3.TP-26

III.A2.TP-26

III.A1.TP-26

A5.1-e T-05

III.A9.TP-212

III.A8.TP-212

III.A7.TP-212

III.A5.TP-212

III.A3.TP-212

III.A2.TP-212

III.A1.TP-212

III.A9.TP-27

III.A8.TP-27

III.A7.TP-27

III.A5.TP-27

III.A3.TP-27

III.A2.TP-27

III.A1.TP-27

A5.1-f T-06

III.A9.TP-28

III.A7.TP-28

III.A5.TP-28

III.A4.TP-28

III.A3.TP-28

III.A2.TP-28

III.A1.TP-28

A5.1-g T-07

III.A9.TP-29

III.A8.TP-29

III.A7.TP-29

III.A5.TP-29

III.A3.TP-29

III.A2.TP-29

III.A1.TP-29

A5.1-h T-08

III.A9.TP-30

III.A8.TP-30

III.A7.TP-30

III.A6.TP-30

III.A5.TP-30

III.A3.TP-30
April 2011 A-13 NUREG-1950

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.A2.TP-30

III.A1.TP-30

A5.1-i T-09

III.A9.TP-31

III.A8.TP-31

III.A7.TP-31

III.A6.TP-31

III.A5.TP-31

III.A3.TP-31

III.A2.TP-31

III.A1.TP-31

A5.1-j T-10

III.A5.TP-114

III.A4.TP-114

III.A3.TP-114

III.A2.TP-114

III.A1.TP-114

A5.2-a T-11

III.A8.TP-302

III.A7.TP-302

III.A5.TP-302

III.A4.TP-302

III.A3.TP-302

III.A2.TP-302

III.A1.TP-302

A5.2-b T-14 III.A5.T-14

A5.3-a T-12

III.A6.T-12

III.A5.T-12

III.A3.T-12

III.A2.T-12

III.A1.T-12

A6.1-a T-15

III.A6.TP-110

III.A6.TP-36

A6.1-b T-16

III.A6.TP-109

III.A6.TP-37

A6.1-c T-17 III.A6.TP-220

A6.1-d T-18

III.A6.TP-104

III.A6.TP-38

A6.1-e T-19 III.A6.TP-107

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

A6.1-f T-08

III.A9.TP-30

III.A8.TP-30

III.A7.TP-30

III.A6.TP-30

III.A5.TP-30

III.A3.TP-30

III.A2.TP-30

III.A1.TP-30

A6.1-g T-09

III.A9.TP-31

III.A8.TP-31

III.A7.TP-31

III.A6.TP-31

III.A5.TP-31

III.A3.TP-31

III.A2.TP-31

III.A1.TP-31

A6.1-h T-20 III.A6.T-20

A6.2-a T-21 Retired

A6.3-a T-12

III.A6.T-12

III.A5.T-12

III.A3.T-12

III.A2.T-12

III.A1.T-12

A6.4-a T-22 III.A6.T-22

A6. TP-7 III.A6.TP-7 

A7.1-a T-01

III.A9.TP-108

III.A8.TP-108

III.A5.TP-108

III.A7.TP-108

III.A3.TP-108

III.A2.TP-108

III.A1.TP-108

III.A9.TP-23

III.A8.TP-23

III.A7.TP-23

III.A5.TP-23

III.A3.TP-23
NUREG-1950 A-14 April 2011

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.A2.TP-23

III.A1.TP-23

A7.1-b T-02

III.A9.TP-24

III.A8.TP-24

III.A7.TP-24

III.A5.TP-24

III.A3.TP-24

III.A2.TP-24

III.A1.TP-24

III.A9.TP-67

III.A8.TP-67

III.A7.TP-67

III.A5.TP-67

III.A3.TP-67

III.A1.TP-67

III.A2.TP-67

A7.1-c T-03

III.A1.TP-204

III.A8.TP-204

III.A7.TP-204

III.A5.TP-204

III.A4.TP-204

III.A3.TP-204

III.A2.TP-204

III.A9.TP-204

III.A2.TP-25

III.A3.TP-25

III.A4.TP-25

III.A5.TP-25

III.A7.TP-25

III.A1.TP-25

III.A9.TP-25

III.A8.TP-25

A7.1-d T-04

III.A9.TP-26

III.A7.TP-26

III.A5.TP-26

III.A4.TP-26

III.A3.TP-26

III.A2.TP-26

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.A1.TP-26

A7.1-e T-05

III.A9.TP-212

III.A8.TP-212

III.A7.TP-212

III.A5.TP-212

III.A3.TP-212

III.A2.TP-212

III.A1.TP-212

III.A9.TP-27

III.A8.TP-27

III.A7.TP-27

III.A5.TP-27

III.A3.TP-27

III.A2.TP-27

III.A1.TP-27

A7.1-f T-06

III.A9.TP-28

III.A7.TP-28

III.A5.TP-28

III.A4.TP-28

III.A3.TP-28

III.A2.TP-28

III.A1.TP-28

A7.1-g T-07

III.A9.TP-29

III.A8.TP-29

III.A7.TP-29

III.A5.TP-29

III.A3.TP-29

III.A2.TP-29

III.A1.TP-29

A7.1-h T-08

III.A9.TP-30

III.A8.TP-30

III.A7.TP-30

III.A6.TP-30

III.A5.TP-30

III.A3.TP-30

III.A2.TP-30

III.A1.TP-30

A7.1-i T-09 III.A9.TP-31
April 2011 A-15 NUREG-1950

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.A8.TP-31

III.A7.TP-31

III.A6.TP-31

III.A5.TP-31

III.A3.TP-31

III.A2.TP-31

III.A1.TP-31

A7.2-a T-11 

III.A8.TP-302

III.A7.TP-302

III.A5.TP-302

III.A4.TP-302

III.A3.TP-302

III.A2.TP-302

III.A1.TP-302

A7.2-b T-23

III.A8.T-23

III.A7.T-23

A8.1-a T-01

III.A9.TP-108

III.A8.TP-108

III.A5.TP-108

III.A7.TP-108

III.A3.TP-108

III.A2.TP-108

III.A1.TP-108

III.A9.TP-23

III.A8.TP-23

III.A7.TP-23

III.A5.TP-23

III.A3.TP-23

III.A2.TP-23

III.A1.TP-23

A8.1-b T-02

III.A9.TP-24

III.A8.TP-24

III.A7.TP-24

III.A5.TP-24

III.A3.TP-24

III.A2.TP-24

III.A1.TP-24

III.A9.TP-67

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.A8.TP-67

III.A7.TP-67

III.A5.TP-67

III.A3.TP-67

III.A1.TP-67

III.A2.TP-67

A8.1-c T-03

III.A1.TP-204

III.A8.TP-204

III.A7.TP-204

III.A5.TP-204

III.A4.TP-204

III.A3.TP-204

III.A2.TP-204

III.A9.TP-204

III.A2.TP-25

III.A3.TP-25

III.A4.TP-25

III.A5.TP-25

III.A7.TP-25

III.A1.TP-25

III.A9.TP-25

III.A8.TP-25

A8.1-d T-05

III.A9.TP-212

III.A8.TP-212

III.A7.TP-212

III.A5.TP-212

III.A3.TP-212

III.A2.TP-212

III.A1.TP-212

III.A9.TP-27

III.A8.TP-27

III.A7.TP-27

III.A5.TP-27

III.A3.TP-27

III.A2.TP-27

III.A1.TP-27

A8.1-e T-07

III.A9.TP-29

III.A8.TP-29
NUREG-1950 A-16 April 2011

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.A7.TP-29

III.A5.TP-29

III.A3.TP-29

III.A2.TP-29

III.A1.TP-29

A8.1-f T-08

III.A9.TP-30

III.A8.TP-30

III.A7.TP-30

III.A6.TP-30

III.A5.TP-30

III.A3.TP-30

III.A2.TP-30

III.A1.TP-30

A8.1-g T-09

III.A9.TP-31

III.A8.TP-31

III.A7.TP-31

III.A6.TP-31

III.A5.TP-31

III.A3.TP-31

III.A2.TP-31

III.A1.TP-31

A8.2-a T-11

III.A8.TP-302

III.A7.TP-302

III.A5.TP-302

III.A4.TP-302

III.A3.TP-302

III.A2.TP-302

III.A1.TP-302

A8.2-b T-23

III.A8.T-23

III.A7.T-23

A9.1-a T-01

III.A9.TP-108

III.A8.TP-108

III.A5.TP-108

III.A7.TP-108

III.A3.TP-108

III.A2.TP-108

III.A1.TP-108

III.A9.TP-23

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.A8.TP-23

III.A7.TP-23

III.A5.TP-23

III.A3.TP-23

III.A2.TP-23

III.A1.TP-23

A9.1-b T-02

III.A9.TP-24

III.A8.TP-24

III.A7.TP-24

III.A5.TP-24

III.A3.TP-24

III.A2.TP-24

III.A1.TP-24

III.A9.TP-67

III.A8.TP-67

III.A7.TP-67

III.A5.TP-67

III.A3.TP-67

III.A1.TP-67

III.A2.TP-67

A9.1-c T-03

III.A1.TP-204

III.A8.TP-204

III.A7.TP-204

III.A5.TP-204

III.A4.TP-204

III.A3.TP-204

III.A2.TP-204

III.A9.TP-204

III.A2.TP-25

III.A3.TP-25

III.A4.TP-25

III.A5.TP-25

III.A7.TP-25

III.A1.TP-25

III.A9.TP-25

III.A8.TP-25

A9.1-d T-04

III.A9.TP-26

III.A7.TP-26
April 2011 A-17 NUREG-1950

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.A5.TP-26

III.A4.TP-26

III.A3.TP-26

III.A2.TP-26

III.A1.TP-26

A9.1-e T-05

III.A9.TP-212

III.A8.TP-212

III.A7.TP-212

III.A5.TP-212

III.A3.TP-212

III.A2.TP-212

III.A1.TP-212

III.A9.TP-27

III.A8.TP-27

III.A7.TP-27

III.A5.TP-27

III.A3.TP-27

III.A2.TP-27

III.A1.TP-27

A9.1-f T-06

III.A9.TP-28

III.A7.TP-28

III.A5.TP-28

III.A4.TP-28

III.A3.TP-28

III.A2.TP-28

III.A1.TP-28

A9.1-g T-07

III.A9.TP-29

III.A8.TP-29

III.A7.TP-29

III.A5.TP-29

III.A3.TP-29

III.A2.TP-29

III.A1.TP-29

A9.1-h T-08

III.A9.TP-30

III.A8.TP-30

III.A7.TP-30

III.A6.TP-30

III.A5.TP-30

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.A3.TP-30

III.A2.TP-30

III.A1.TP-30

A9.1-i T-09

III.A9.TP-31

III.A8.TP-31

III.A7.TP-31

III.A6.TP-31

III.A5.TP-31

III.A3.TP-31

III.A2.TP-31

III.A1.TP-31

B1.1 TP-9 Retired

B1.1 TP-10 III.B1.1.TP-10

B1.1. TP-11 III.B1.1.TP-8 

B1.1. TP-3 

III.B3.TP-3 

III.B2.TP-3 

III.B1.3.TP-3 

III.B1-2.TP-3 

III.B1.1.TP-3 

III.B5.TP-3 

III.B4.TP-3

B1.1. TP-8 III.B1.1.TP-8 

B1.1. TP-5 III.B1.1.TP-8 

B1.1. TP-4 

III.B5.TP-4 

III.B4.TP-4 

III.B3.TP-4 

III.B2.TP-4 

III.B1.3.TP-4 

III.B1.2.TP-4 

III.B1.1.TP-4

B1.1.1-a T-24

III.B1.3.T-24

III.B1.2.T-24

III.B1.1.T-24

B1.1.1-b T-25

III.B5.T-25

III.B4.T-25

III.B3.T-25

III.B2.T-25
NUREG-1950 A-18 April 2011

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.B1.2.T-25

III.B1.1.T-25

B1.1.1-c T-26

III.B1.3.T-26

III.B1.2.T-26

III.B1.1.T-26

B1.1.2-a T-27 III.B1.1.TP-41

B1.1.3-a T-28

III.B1.3.T-28

III.B1.2.T-28

III.B1.1.T-28

B1.1.4-a T-29

III.B5.TP-42

III.B4.TP-42

III.B3.TP-42

III.B2.TP-42

III.B1.3.TP-42

III.B1.2.TP-42

III.B1.1.TP-42

B1.2. TP-3 

III.B3.TP-3 

III.B2.TP-3 

III.B1.3.TP-3 

III.B1-2.TP-3 

III.B1.1.TP-3 

III.B5.TP-3 

III.B4.TP-3

B1.2. TP-5 III.B1.2.TP-8 

B1.2. TP-8 III.B1.2.TP-8 

B1.2. TP-4 

III.B5.TP-4 

III.B4.TP-4 

III.B3.TP-4 

III.B2.TP-4 

III.B1.3.TP-4 

III.B1.2.TP-4 

III.B1.1.TP-4

B1.2. TP-11 III.B1.2.TP-8 

B1.2.1-a T-24

III.B1.3.T-24

III.B1.2.T-24

III.B1.1.T-24

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

B1.2.1-b T-25

III.B5.T-25

III.B4.T-25

III.B3.T-25

III.B2.T-25

III.B1.2.T-25

III.B1.1.T-25

B1.2.1-c T-26

III.B1.3.T-26

III.B1.2.T-26

III.B1.1.T-26

B1.2.2-a T-28

III.B1.3.T-28

III.B1.2.T-28

III.B1.1.T-28

B1.2.3-a T-29

III.B5.TP-42

III.B4.TP-42

III.B3.TP-42

III.B2.TP-42

III.B1.3.TP-42

III.B1.2.TP-42

III.B1.1.TP-42

B1.3. TP-3 

III.B3.TP-3 

III.B2.TP-3 

III.B1.3.TP-3 

III.B1-2.TP-3 

III.B1.1.TP-3 

III.B5.TP-3 

III.B4.TP-3

B1.3. TP-4 

III.B5.TP-4 

III.B4.TP-4 

III.B3.TP-4 

III.B2.TP-4 

III.B1.3.TP-4 

III.B1.2.TP-4 

III.B1.1.TP-4

B1.3. TP-5 III.B1.3.TP-8 

B1.3. TP-11 III.B1.3.TP-8 

B1.3. TP-8 III.B1.3.TP-8 

B1.3.1-a T-24 III.B1.3.T-24
April 2011 A-19 NUREG-1950

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.B1.2.T-24

III.B1.1.T-24

B1.3.1-b T-26

III.B1.3.T-26

III.B1.2.T-26

III.B1.1.T-26

B1.3.2-a T-28

III.B1.3.T-28

III.B1.2.T-28

III.B1.1.T-28

B1.3.3-a T-29

III.B5.TP-42

III.B4.TP-42

III.B3.TP-42

III.B2.TP-42

III.B1.3.TP-42

III.B1.2.TP-42

III.B1.1.TP-42

B2. TP-4 

III.B5.TP-4 

III.B4.TP-4 

III.B3.TP-4 

III.B2.TP-4 

III.B1.3.TP-4 

III.B1.2.TP-4 

III.B1.1.TP-4

B2. TP-11 III.B2.TP-8 

B2. TP-2 

III.B4.TP-47

III.B2.TP-47

B2. TP-8 III.B2.TP-8 

B2. TP-6 

III.B4.TP-6 

III.B2.TP-6

B2. TP-1 

III.B2.TP-46

III.B4.TP-46

B2. TP-5 III.B2.TP-8 

B2. TP-3 

III.B3.TP-3 

III.B2.TP-3 

III.B1.3.TP-3 

III.B1-2.TP-3 

III.B1.1.TP-3 

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.B5.TP-3

III.B4.TP-3

B2.1-a T-30

III.B5.TP-43

III.B4.TP-43

III.B3.TP-43

III.B2.TP-43

B2.1-b T-25

III.B5.T-25

III.B4.T-25

III.B3.T-25

III.B2.T-25

III.B1.2.T-25

III.B1.1.T-25

B2.2-a T-29

III.B5.TP-42

III.B4.TP-42

III.B3.TP-42

III.B2.TP-42

III.B1.3.TP-42

III.B1.2.TP-42

III.B1.1.TP-42

B3. TP-8 III.B3.TP-8 

B3. TP-3 

III.B3.TP-3 

III.B2.TP-3 

III.B1.3.TP-3 

III.B1-2.TP-3 

III.B1.1.TP-3 

III.B5.TP-3 

III.B4.TP-3

B3. TP-4 

III.B5.TP-4 

III.B4.TP-4 

III.B3.TP-4 

III.B2.TP-4 

III.B1.3.TP-4 

III.B1.2.TP-4 

III.B1.1.TP-4

B3. TP-5 III.B3.TP-8 

B3. TP-11 III.B3.TP-8 

B3.1-a T-30 III.B5.TP-43
NUREG-1950 A-20 April 2011

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

III.B4.TP-43

III.B3.TP-43

III.B2.TP-43

B3.1-b T-25

III.B5.T-25

III.B4.T-25

III.B3.T-25

III.B2.T-25

III.B1.2.T-25

III.B1.1.T-25

B3.2-a T-29

III.B5.TP-42

III.B4.TP-42

III.B3.TP-42

III.B2.TP-42

III.B1.3.TP-42

III.B1.2.TP-42

III.B1.1.TP-42

B4. TP-1 

III.B2.TP-46

III.B4.TP-46

B4. TP-6 

III.B4.TP-6 

III.B2.TP-6

B4. TP-2 

III.B4.TP-47

III.B2.TP-47

B4. TP-5 III.B4.TP-8 

B4. TP-3 

III.B3.TP-3 

III.B2.TP-3 

III.B1.3.TP-3 

III.B1-2.TP-3 

III.B1.1.TP-3 

III.B5.TP-3 

III.B4.TP-3

B4. TP-4 

III.B5.TP-4 

III.B4.TP-4 

III.B3.TP-4 

III.B2.TP-4 

III.B1.3.TP-4 

III.B1.2.TP-4 

III.B1.1.TP-4

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

B4. TP-11 III.B4.TP-8 

B4. TP-8 III.B4.TP-8 

B4.1-a T-30

III.B5.TP-43

III.B4.TP-43

III.B3.TP-43

III.B2.TP-43

B4.1-b T-25

III.B5.T-25

III.B4.T-25

III.B3.T-25

III.B2.T-25

III.B1.2.T-25

III.B1.1.T-25

B4.2-a T-31 III.B4.TP-44

B4.3-a T-29

III.B5.TP-42

III.B4.TP-42

III.B3.TP-42

III.B2.TP-42

III.B1.3.TP-42

III.B1.2.TP-42

III.B1.1.TP-42

B5. TP-3 

III.B3.TP-3 

III.B2.TP-3 

III.B1.3.TP-3 

III.B1-2.TP-3 

III.B1.1.TP-3 

III.B5.TP-3 

III.B4.TP-3 

B5. TP-4 

III.B5.TP-4 

III.B4.TP-4 

III.B3.TP-4 

III.B2.TP-4 

III.B1.3.TP-4 

III.B1.2.TP-4 

III.B1.1.TP-4 

B5. TP-8 III.B5.TP-8 

B5. TP-5 III.B5.TP-8 

B5. TP-11 III.B5.TP-8 
April 2011 A-21 NUREG-1950

Table A-2. Relationship of Structures 

and Component Supports IDs in GALL 

Report, Chapter III

Rev. 0 Rev. 1 Rev. 2

B5.1-a T-30

III.B5.TP-43

III.B4.TP-43

III.B3.TP-43

III.B2.TP-43

B5.1-b T-25

III.B5.T-25

III.B4.T-25

III.B3.T-25

III.B2.T-25

III.B1.2.T-25

III.B1.1.T-25

B5.2-a T-29

III.B5.TP-42

III.B4.TP-42

III.B3.TP-42

III.B2.TP-42

III.B1.3.TP-42

III.B1.2.TP-42

III.B1.1.TP-42
NUREG-1950 A-22 April 2011

Table A-3. Relationship of Reactor 

Vessel, Internals, and Reactor 

Coolant (RCS) System IDs in GALL 

Report, Chapter IV

Rev. 0 Rev. 1 Rev. 2

None None IV.D2.RP-162

None None IV.A1.RP-165

None None IV.C2.RP-166

None None IV.C2.RP-167

None None IV.B1.RP-182

None None IV.B1.RP-200

None None IV.A1.RP-201

None None IV.B4.RP-236

None None IV.B4.RP-237

None None IV.B4.RP-238

None None IV.B4.RP-239

None None IV.B2.RP-265

None None IV.B2.RP-267

None None IV.B2.RP-268

None None IV.B2.RP-269

None None IV.B2.RP-296

None None IV.B2.RP-297

None None IV.B2.RP-302

None None IV.B3.RP-306

None None IV.B3.RP-307

None None IV.B3.RP-309

None None IV.B3.RP-311

None None IV.B3.RP-313

None None IV.B3.RP-322

None None IV.B3.RP-323

None None IV.B3.RP-324

None None IV.B3.RP-325

None None IV.B3.RP-326

None None IV.B3.RP-331

None None IV.B3.RP-333

None None IV.B3.RP-338

Table A-3. Relationship of Reactor 

Vessel, Internals, and Reactor 

Coolant (RCS) System IDs in GALL 

Report, Chapter IV

Rev. 0 Rev. 1 Rev. 2

IV.B3.RP-342

IV.B3.RP-343

IV.B2.RP-345

IV.B2.RP-346

None None IV.B4.RP-352

None None IV.B2.RP-354

None None IV.B2.RP-355

None None IV.B2.RP-356

None None IV.B3.RP-357

None None IV.B3.RP-358

None None IV.B3.RP-359

None None IV.B3.RP-360

None None IV.B3.RP-361

None None IV.B3.RP-362

None None IV.B3.RP-363

None None IV.B3.RP-364

None None IV.B3.RP-365

None None IV.B3.RP-366

None None IV.D1.RP-372

None None IV.B4.RP-375

None None IV.B4.RP-376

None None IV.B1.RP-377

None None IV.E.RP-378

None None IV.B1.RP-381

None None IV.C2.RP-383

None None IV.D1.RP-385

None None IV.B2.RP-386

None None IV.B2.RP-387

None None IV.B2.RP-388

None None IV.B3.RP-389

None None IV.B3.RP-390
April 2011 A-23 NUREG-1950

Table A-3. Relationship of Reactor 

Vessel, Internals, and Reactor 

Coolant (RCS) System IDs in GALL 

Report, Chapter IV

Rev. 0 Rev. 1 Rev. 2

None None IV.B3.RP-391

A1. RP-25 IV.A1.RP-157

A1.1-a R-59 IV.A1.RP-50

A1.1-b R-04 IV.A1.R-04

A1.1-c R-60 IV.A1.RP-51

A1.1-d R-61 IV.A1.R-61

A1.2-a R-04 IV.A1.R-04

A1.2-b R-04 IV.A1.R-04

A1.2-c R-62 IV.A1.R-62

A1.2-d R-63 IV.A1.RP-227

A1.2-e R-64 IV.A1.R-64

A1.3-a R-04 IV.A1.R-04

A1.3-b R-65 IV.A1.R-65

A1.3-c R-66 IV.A1.R-66

A1.3-d R-04 IV.A1.R-04

A1.3-e R-67 IV.A1.R-67

A1.4-a R-68 IV.A1.R-68

A1.4-b R-04 IV.A1.R-04

A1.5-a R-69

IV.A1.RP-369

IV.A1.RP-371

A1.5-b R-04 IV.A1.R-04

A1.6-a R-04 IV.A1.R-04

A1.7-a R-70

IV.A2.R-70

IV.A1.R-70

A2. RP-28 IV.A2.RP-28

A2. RP-13 IV.A2.RP-154

A2.1-a R-17

IV.A2.R-17

IV.D2.R-17

IV.D1.R-17

IV.C2.R-17

IV.A2.RP-379

IV.C2.RP-380

Table A-3. Relationship of Reactor 

Vessel, Internals, and Reactor 

Coolant (RCS) System IDs in GALL 

Report, Chapter IV

Rev. 0 Rev. 1 Rev. 2

A2.1-b R-219 IV.A2.R-219

A2.1-c R-71 IV.A2.RP-52

A2.1-d R-72 IV.A2.RP-53

A2.1-e R-73 IV.A2.RP-54

A2.1-f R-74 IV.A2.R-74

A2.2-a R-75 IV.A2.RP-186

A2.2-b R-76 IV.A2.RP-55

A2.2-c R-219 IV.A2.R-219

A2.2-d R-77 IV.A2.R-77

A2.2-e R-78 IV.A2.R-78

A2.2-f R-79 IV.A2.R-79

A2.2-g R-80 IV.A2.R-80

A2.3-a R-81 IV.A2.R-81

A2.3-b R-82 IV.A2.RP-228

A2.3-c R-219 IV.A2.R-219

A2.4-a R-219 IV.A2.R-219

A2.4-b R-83 IV.A2.RP-234

A2.5-a R-84 IV.A2.R-84

A2.5-b R-85 IV.A2.R-85

A2.5-c R-86 IV.A2.RP-229

A2.5-d R-219 IV.A2.R-219

A2.5-e R-17

IV.A2.R-17

IV.D2.R-17

IV.D1.R-17

IV.C2.R-17

IV.A2.RP-379

IV.C2.RP-380

A2.5-f R-87 IV.A2.R-87

A2.6-a R-88 IV.A2.RP-57

A2.7-a R-89 IV.A2.RP-59

A2.7-b R-90 IV.A2.R-90

A2.8-a R-70 IV.A2.R-70
NUREG-1950 A-24 April 2011

Table A-3. Relationship of Reactor 

Vessel, Internals, and Reactor 

Coolant (RCS) System IDs in GALL 

Report, Chapter IV

Rev. 0 Rev. 1 Rev. 2

IV.A1.R-70

A2.8-b R-17

IV.A2.R-17

IV.D2.R-17

IV.D1.R-17

IV.C2.R-17

IV.A2.RP-379 

IV.C2.RP-380

B1. RP-26 IV.B1.RP-26

B1. RP-18 IV.B1.RP-155

B1.1-a R-92 IV.B1.R-92

B1.1-b R-93 IV.B1.R-93

B1.1-c R-53

IV.B4.R-53

IV.B1.R-53

IV.B2.RP-303

IV.B3.RP-339

B1.1-d R-94 IV.B1.R-94

B1.1-e R-95 IV.B1.R-95

B1.1-f R-96 IV.B1.R-96

B1.1-g R-97 IV.B1.R-97

B1.2-a R-98 IV.B1.R-98

B1.2-b R-53

IV.B4.R-53

IV.B1.R-53

IV.B2.RP-303

IV.B3.RP-339

B1.3-a R-99 IV.B1.R-99

B1.3-b R-53

IV.B4.R-53

IV.B1.R-53

IV.B2.RP-303

IV.B3.RP-339

B1.4-a R-100 IV.B1.R-100

B1.4-b R-53

IV.B4.R-53

IV.B1.R-53

IV.B2.RP-303

IV.B3.RP-339

Table A-3. Relationship of Reactor 

Vessel, Internals, and Reactor 

Coolant (RCS) System IDs in GALL 

Report, Chapter IV

Rev. 0 Rev. 1 Rev. 2

B1.4-c R-101 IV.B1.RP-219

B1.4-d R-102 Retired

B1.5-a R-103 IV.B1.RP-220

B1.5-b R-53

IV.B4.R-53

IV.B1.R-53

IV.B2.RP-303

IV.B3.RP-339

B1.5-c R-104 IV.B1.R-104

B1.6-a R-105 IV.B1.R-105

B1.6-b R-53

IV.B4.R-53

IV.B1.R-53

IV.B2.RP-303

IV.B3.RP-339

B2. RP-24

IV.B3.RP-24

IV.B2.RP-24

IV.B4.RP-24

B2.1-a R-106 Retired

B2.1-b R-107 Retired

B2.1-c R-53

IV.B4.R-53

IV.B1.R-53

IV.B2.RP-303

IV.B3.RP-339

B2.1-d R-108 IV.B2.RP-300

B2.1-e R-109 Retired

B2.1-f R-110 Retired

B2.1-g R-111 Retired

B2.1-h R-53

IV.B4.R-53

IV.B1.R-53

IV.B2.RP-303

IV.B3.RP-339

B2.1-i R-112 IV.B2.RP-301

B2.1-j R-113 Retired

B2.1-k R-114 Retired
April 2011 A-25 NUREG-1950

Table A-3. Relationship of Reactor 

Vessel, Internals, and Reactor 

Coolant (RCS) System IDs in GALL 

Report, Chapter IV

Rev. 0 Rev. 1 Rev. 2

B2.1-l R-115 IV.B2.RP-299

B2.1-m R-53

IV.B4.R-53

IV.B1.R-53

IV.B2.RP-303

IV.B3.RP-339

B2.2-a R-116 Retired

B2.2-b R-117 Retired

B2.2-c R-53

IV.B4.R-53

IV.B1.R-53

IV.B2.RP-303

IV.B3.RP-339

B2.2-d R-118 IV.B2.RP-298

B2.2-e R-119 Retired

B2.2-f R-53

IV.B4.R-53

IV.B1.R-53

IV.B2.RP-303

IV.B3.RP-339

B2.3-a R-120

IV.B2.RP-276

IV.B2.RP-278

IV.B2.RP-280

IV.B2.RP-282

B2.3-b R-121 Retired

B2.3-c R-122 IV.B2.RP-281

B2.3-d R-53

IV.B4.R-53

IV.B1.R-53

IV.B2.RP-303

IV.B3.RP-339

B2.4-a R-123 Retired

B2.4-b R-124 IV.B2.RP-270

B2.4-c R-125

IV.B4.RP-241

IV.B4.RP-244

IV.B2.RP-271

IV.B2.RP-273

B2.4-d R-126 Retired

Table A-3. Relationship of Reactor 

Vessel, Internals, and Reactor 

Coolant (RCS) System IDs in GALL 

Report, Chapter IV

Rev. 0 Rev. 1 Rev. 2

B2.4-e R-127 Retired

B2.4-f R-128

IV.B4.RP-240

IV.B4.RP-243

IV.B2.RP-272

IV.B2.RP-274

IV.B2.RP-275

B2.4-g R-53

IV.B4.R-53

IV.B1.R-53

IV.B2.RP-303

IV.B3.RP-339

B2.4-h R-129 Retired

B2.5-a R-130 IV.B2.RP-289

B2.5-b R-131 Retired

B2.5-c R-132 IV.B2.RP-288

B2.5-d R-53

IV.B4.R-53

IV.B1.R-53

IV.B2.RP-303

IV.B3.RP-339

B2.5-e R-133 IV.B2.RP-286

B2.5-f R-134 Retired

B2.5-g R-135 IV.B2.RP-287

B2.5-h R-136 Retired

B2.5-i R-137 IV.B2.RP-285

B2.5-j R-53

IV.B4.R-53

IV.B1.R-53

IV.B2.RP-303

IV.B3.RP-339

B2.5-k R-138

IV.B2.RP-291

IV.B2.RP-293

IV.B2.RP-294

B2.5-l R-139 Retired

B2.5-m R-140

IV.B2.RP-290

IV.B2.RP-292

B2.5-n R-141 IV.B2.RP-295
NUREG-1950 A-26 April 2011

Table A-3. Relationship of Reactor 

Vessel, Internals, and Reactor 

Coolant (RCS) System IDs in GALL 

Report, Chapter IV

Rev. 0 Rev. 1 Rev. 2

B2.5-o R-142 IV.B2.RP-382

B2.5-p R-53

IV.B4.R-53

IV.B1.R-53

IV.B2.RP-303

IV.B3.RP-339

B2.6-a R-143 IV.B2.RP-284

B2.6-b R-144 Retired

B2.6-c R-145 Retired

B3. RP-24

IV.B3.RP-24

IV.B2.RP-24

IV.B4.RP-24

B3.1-a R-146 Retired

B3.1-b R-147 Retired

B3.1-c R-148 Retired

B3.2-a R-149 IV.B3.RP-312

B3.2-b R-150 Retired

B3.2-c R-151 Retired

B3.2-d R-152 Retired

B3.2-e R-153 Retired

B3.2-f R-53

IV.B4.R-53

IV.B1.R-53

IV.B2.RP-303

IV.B3.RP-339

B3.2-g R-154 Retired

B3.3-a R-157 Retired

B3.3-a R-155

IV.B3.RP-327

IV.B3.RP-328

IV.B3.RP-329

B3.3-b R-158 Retired

B3.3-b R-156 IV.B3.RP-332

B3.4-a R-159 Retired

B3.4-b R-160 Retired

B3.4-c R-161 Retired

Table A-3. Relationship of Reactor 

Vessel, Internals, and Reactor 

Coolant (RCS) System IDs in GALL 

Report, Chapter IV

Rev. 0 Rev. 1 Rev. 2

B3.4-d R-53

IV.B4.R-53

IV.B1.R-53

IV.B2.RP-303

IV.B3.RP-339

B3.4-e R-162

IV.B3.RP-314

IV.B3.RP-316

IV.B3.RP-319

IV.B3.RP-320

B3.4-f R-163 IV.B3.RP-318

B3.4-g R-164 Retired

B3.4-h R-165

IV.B3.RP-315

IV.B3.RP-317

B3.5-a R-166 Retired

B3.5-b R-167

IV.B3.RP-330

IV.B3.RP-334

IV.B3.RP-335

B3.5-c R-168 Retired

B3.5-d R-169 Retired

B3.5-e R-170

IV.B3.RP-336

IV.B3.RP-382

B3.5-f R-171 Retired

B3.5-g R-53

IV.B4.R-53

IV.B1.R-53

IV.B2.RP-303

IV.B3.RP-339

B4. RP-24

IV.B3.RP-24

IV.B2.RP-24

IV.B4.RP-24

B4.1-a R-172 Retired

B4.1-b R-173 Retired

B4.1-c R-174 Retired

B4.1-d R-53

IV.B4.R-53

IV.B1.R-53

IV.B2.RP-303
April 2011 A-27 NUREG-1950

Table A-3. Relationship of Reactor 

Vessel, Internals, and Reactor 

Coolant (RCS) System IDs in GALL 

Report, Chapter IV

Rev. 0 Rev. 1 Rev. 2

IV.B3.RP-339

B4.2-a R-175 Retired

B4.2-b R-176 Retired

B4.2-c R-177 Retired

B4.2-d R-53

IV.B4.R-53

IV.B1.R-53

IV.B2.RP-303

IV.B3.RP-339

B4.2-e R-178 Retired

B4.2-f R-179 IV.B4.RP-382

B4.3-a R-180 Retired

B4.3-b R-181 Retired

B4.3-c R-182 Retired

B4.3-d R-183

IV.B4.RP-242

IV.B4.RP-258

B4.3-e R-184 Retired

B4.3-f R-53

IV.B4.R-53

IV.B1.R-53

IV.B2.RP-303

IV.B3.RP-339

B4.4-a R-185 Retired

B4.4-b R-186 Retired

B4.4-c R-187 Retired

B4.4-d R-188 IV.B4.RP-252

B4.4-e R-53

IV.B4.R-53

IV.B1.R-53

IV.B2.RP-303

IV.B3.RP-339

B4.4-f R-190 IV.B4.RP-251

B4.4-g R-191 IV.B4.RP-253

B4.4-h R-192 Retired

B4.5-a R-193 Retired

B4.5-b R-194 IV.B4.RP-245

Table A-3. Relationship of Reactor 

Vessel, Internals, and Reactor 

Coolant (RCS) System IDs in GALL 

Report, Chapter IV

Rev. 0 Rev. 1 Rev. 2

IV.B4.RP-247

B4.5-c R-195 Retired

B4.5-d R-196

IV.B4.RP-246

IV.B4.RP-248

IV.B4.RP-249

IV.B4.RP-250

B4.5-e R-197 Retired

B4.5-f R-53

IV.B4.R-53

IV.B1.R-53

IV.B2.RP-303

IV.B3.RP-339

B4.5-g R-125

IV.B4.RP-241

IV.B4.RP-244

IV.B2.RP-271

IV.B2.RP-273

B4.5-h R-199 Retired

B4.5-i R-128

IV.B4.RP-240

IV.B4.RP-243

IV.B2.RP-272

IV.B2.RP-274

IV.B2.RP-275

B4.5-j R-201 Retired

B4.6-a R-202 Retired

B4.6-b R-203

IV.B4.RP-261

IV.B4.RP-262

B4.6-c R-204 Retired

B4.6-d R-205

IV.B4.RP-259

IV.B4.RP-260

B4.6-e R-206 Retired

B4.6-f R-53

IV.B4.R-53

IV.B1.R-53

IV.B2.RP-303

IV.B3.RP-339

B4.6-g R-207 Retired
NUREG-1950 A-28 April 2011

Table A-3. Relationship of Reactor 

Vessel, Internals, and Reactor 

Coolant (RCS) System IDs in GALL 

Report, Chapter IV

Rev. 0 Rev. 1 Rev. 2

B4.6-h R-208 Retired

B4.7-a R-209 Retired

B4.7-b R-210

IV.B4.RP-254

IV.B4.RP-256

B4.7-c R-211 Retired

B4.7-d R-212 Retired

B4.7-e R-213 Retired

B4.8-a R-214 Retired

B4.8-b R-215 Retired

B4.8-c R-216 Retired

C1. RP-27 IV.C1.RP-158

C1.1-a R-23 IV.C1.R-23

C1.1-b R-220 IV.C1.R-220

C1.1-c R-23 IV.C1.R-23

C1.1-d R-220 IV.C1.R-220

C1.1-e R-220 IV.C1.R-220

C1.1-e R-220 IV.C1.R-220

C1.1-f R-20 IV.C1.R-20

C1.1-f R-21 IV.C1.R-21

C1.1-g R-52

IV.C2.R-52

IV.C1.R-52

C1.1-h R-220 IV.C1.R-220

C1.1-i R-03 IV.C1.RP-230

C1.2-a R-220 IV.C1.R-220

C1.2-b R-20 IV.C1.R-20

C1.2-c R-08

IV.C2.R-08

IV.C1.R-08

C1.2-d R-29 Retired

C1.2-d R-26 IV.C1.RP-42

C1.2-e R-27 IV.C1.RP-43

C1.2-f R-28 IV.C1.RP-44

Table A-3. Relationship of Reactor 

Vessel, Internals, and Reactor 

Coolant (RCS) System IDs in GALL 

Report, Chapter IV

Rev. 0 Rev. 1 Rev. 2

C1.3-a R-23 IV.C1.R-23

C1.3-b R-08

IV.C2.R-08

IV.C1.R-08

C1.3-c R-20 IV.C1.R-20

C1.3-d R-220 IV.C1.R-220

C1.3-e R-26 IV.C1.RP-42

C1.3-e R-29 Retired

C1.3-f R-27 IV.C1.RP-43

C1.3-g R-28 IV.C1.RP-44

C1.4-a R-15 IV.C1.R-15

C1.4-a R-225 IV.C1.R-225

C1.4-b R-16 IV.C1.RP-39

C2. RP-12 IV.C2.RP-12

C2. RP-31 IV.C2.RP-159

C2. RP-23 IV.C2.RP-23

C2. RP-11 IV.C2.RP-222

C2. RP-10 IV.C2.RP-221

C2. RP-22 IV.C2.RP-156

C2.1-a R-223 IV.C2.R-223

C2.1-b R-223 IV.C2.R-223

C2.1-c R-56 IV.C2.R-56

C2.1-c R-30 IV.C2.R-30

C2.1-d R-17

IV.A2.R-17

IV.D2.R-17

IV.D1.R-17

IV.C2.R-17

IV.A2.RP-379

IV.C2.RP-380

C2.1-e R-05 IV.C2.R-05

C2.1-f R-52

IV.C2.R-52

IV.C1.R-52
April 2011 A-29 NUREG-1950

Table A-3. Relationship of Reactor 

Vessel, Internals, and Reactor 

Coolant (RCS) System IDs in GALL 

Report, Chapter IV

Rev. 0 Rev. 1 Rev. 2

C2.1-g R-02 IV.C2.RP-235

C2.2-a R-223 IV.C2.R-223

C2.2-b R-223 IV.C2.R-223

C2.2-c R-223 IV.C2.R-223

C2.2-d R-17

IV.A2.R-17

IV.D2.R-17

IV.D1.R-17

IV.C2.R-17

IV.A2.RP-379

IV.C2.RP-380

C2.2-e R-52

IV.C2.R-52

IV.C1.R-52

C2.2-f R-07

IV.D1.RP-232

IV.C2.RP-344

C2.2-g R-05 IV.C2.R-05

C2.2-h R-02 IV.C2.RP-235

C2.3-a R-223 IV.C2.R-223

C2.3-a R-223 IV.C2.R-223

C2.3-b R-09 IV.C2.R-09

C2.3-c R-08

IV.C2.R-08

IV.C1.R-08

C2.3-d R-18 IV.C2.R-18

C2.3-e R-11 IV.C2.R-11

C2.3-f R-17

IV.A2.R-17

IV.D2.R-17

IV.D1.R-17

IV.C2.R-17

IV.A2.RP-379

IV.C2.RP-380

C2.3-g R-12 IV.C2.R-12

C2.4-a R-223 IV.C2.R-223

C2.4-b R-09 IV.C2.R-09

C2.4-c R-08 IV.C2.R-08

Table A-3. Relationship of Reactor 

Vessel, Internals, and Reactor 

Coolant (RCS) System IDs in GALL 

Report, Chapter IV

Rev. 0 Rev. 1 Rev. 2

IV.C1.R-08

C2.4-d R-18 IV.C2.R-18

C2.4-e R-11 IV.C2.R-11

C2.4-f R-17

IV.A2.R-17

IV.D2.R-17

IV.D1.R-17

IV.C2.R-17

IV.A2.RP-379

IV.C2.RP-380

C2.4-g R-12 IV.C2.R-12

C2.5-a R-223 IV.C2.R-223 

C2.5-b R-17

IV.A2.R-17

IV.D2.R-17

IV.D1.R-17

IV.C2.R-17

IV.A2.RP-379

IV.C2.RP-380

C2.5-c R-25 IV.C2.R-25

C2.5-c R-58 IV.C2.R-58

C2.5-d R-223 IV.C2.R-223

C2.5-e R-223 IV.C2.R-223

C2.5-f R-223 IV.C2.R-223

C2.5-g R-25 IV.C2.R-25

C2.5-g R-58 IV.C2.R-58

C2.5-h R-07

IV.D1.RP-232

IV.C2.RP-344

C2.5-i R-05 IV.C2.R-05

C2.5-j R-24

IV.C2.RP-40

IV.C2.RP-41

C2.5-k R-06 IV.C2.RP-37

C2.5-l R-52

IV.C2.R-52

IV.C1.R-52

C2.5-m R-07

IV.D1.RP-232

IV.C2.RP-344
NUREG-1950 A-30 April 2011

Table A-3. Relationship of Reactor 

Vessel, Internals, and Reactor 

Coolant (RCS) System IDs in GALL 

Report, Chapter IV

Rev. 0 Rev. 1 Rev. 2

C2.5-m R-06 IV.C2.RP-37

C2.5-n R-11 IV.C2.R-11

C2.5-o R-17

IV.A2.R-17

IV.D2.R-17

IV.D1.R-17

IV.C2.R-17

IV.A2.RP-379

IV.C2.RP-380

C2.5-p R-12 IV.C2.R-12

C2.5-q R-223 IV.C2.R-223

C2.5-r R-217 IV.C2.R-217

C2.5-s R-06 IV.C2.RP-37

C2.5-t R-18 IV.C2.R-18

C2.5-u R-17

IV.A2.R-17

IV.D2.R-17

IV.D1.R-17

IV.C2.R-17

IV.A2.RP-379

IV.C2.RP-380

C2.5-v R-19 IV.C2.R-19

C2.5-w R-18 IV.C2.R-18

C2.6-a R-13 IV.C2.R-13

C2.6-b R-17

IV.A2.R-17

IV.D2.R-17

IV.D1.R-17

IV.C2.R-17

IV.A2.RP-379

IV.C2.RP-380

C2.6-c R-14 IV.C2.RP-231

D1. RP-21 IV.D1.RP-367

D1. RP-17 IV.D1.RP-17 

D1. RP-14 IV.D1.RP-384

D1. RP-15

IV.D1.RP-225

IV.D1.RP-226

Table A-3. Relationship of Reactor 

Vessel, Internals, and Reactor 

Coolant (RCS) System IDs in GALL 

Report, Chapter IV

Rev. 0 Rev. 1 Rev. 2

D1. RP-16 IV.D1.RP-161

D1.1-a R-33

IV.D2.R-33

IV.D1.R-33

D1.1-b R-33

IV.D2.R-33

IV.D1.R-33

D1.1-c R-34 IV.D1.RP-368

D1.1-d R-37 IV.D1.R-37

D1.1-e R-39 IV.D1.R-39

D1.1-f R-32

IV.D2.RP-46

IV.D1.RP-46

D1.1-g R-17

IV.A2.R-17

IV.D2.R-17

IV.D1.R-17

IV.C2.R-17

IV.A2.RP-379

IV.C2.RP-380

D1.1-h R-221 IV.D1.R-221

D1.1-i R-01

IV.D2.RP-36

IV.D1.RP-36

D1.1-i R-07

IV.D1.RP-232

IV.C2.RP-344

D1.1-j R-01

IV.D2.RP-36

IV.D1.RP-36

D1.1-k R-17

IV.A2.R-17 

IV.D2.R-17

IV.D1.R-17

IV.C2.R-17

IV.A2.RP-379

IV.C2.RP-380

D1.1-l R-10 IV.D1.R-10

D1.2-a R-44

IV.D2.R-44

IV.D1.R-44

D1.2-b R-47

IV.D2.R-47

IV.D1.R-47
April 2011 A-31 NUREG-1950

Table A-3. Relationship of Reactor 

Vessel, Internals, and Reactor 

Coolant (RCS) System IDs in GALL 

Report, Chapter IV

Rev. 0 Rev. 1 Rev. 2

D1.2-c R-48

IV.D2.R-48

IV.D1.R-48

D1.2-d R-46

IV.D2.R-46

IV.D1.R-46

D1.2-e R-49

IV.D2.RP-233

IV.D1.RP-233

D1.2-f R-50 IV.D1.R-50

D1.2-g R-43 IV.D1.R-43

D1.2-h R-41 IV.D1.RP-48

D1.2-i R-40

IV.D2.R-40

IV.D1.R-40

D1.2-j R-40

IV.D2.R-40

IV.D1.R-40

D1.2-k R-42

IV.D2.R-42

IV.D1.R-42

D1.3-a R-51 IV.D1.RP-49

D2. R-226 IV.D2.R-226

D2. R-42

IV.D2.R-42

IV.D1.R-42

D2.1-a R-35 IV.D2.RP-47

D2.1-b R-17

IV.A2.R-17

IV.D2.R-17

IV.D1.R-17

IV.C2.R-17

IV.A2.RP-379

IV.C2.RP-380

D2.1-c R-222 IV.D2.R-222

D2.1-d R-33

IV.D2.R-33

IV.D1.R-33

D2.1-e R-224 IV.D2.RP-153

D2.1-f R-38 IV.D2.R-38

D2.1-g R-33

IV.D2.R-33

IV.D1.R-33

Table A-3. Relationship of Reactor 

Vessel, Internals, and Reactor 

Coolant (RCS) System IDs in GALL 

Report, Chapter IV

Rev. 0 Rev. 1 Rev. 2

D2.1-h R-01

IV.D2.RP-36

IV.D1.RP-36

D2.1-i R-36 IV.D2.R-36

D2.1-j R-17

IV.A2.R-17

IV.D2.R-17

IV.D1.R-17

IV.C2.R-17

IV.A2.RP-379

IV.C2.RP-380

D2.1-k R-32

IV.D2.RP-46

IV.D1.RP-46

D2.1-l R-31 IV.D2.R-31

D2.2-a R-44

IV.D2.R-44

IV.D1.R-44

D2.2-b R-47

IV.D2.R-47

IV.D1.R-47

D2.2-c R-48

IV.D2.R-48

IV.D1.R-48

D2.2-d R-49

IV.D2.RP-233

IV.D1.RP-233

D2.2-e R-46

IV.D2.R-46

IV.D1.R-46

D2.2-f R-40

IV.D2.R-40

IV.D1.R-40

D2.2-g R-40

IV.D2.R-40

IV.D1.R-40

E. RP-04 IV.E.RP-04

E. RP-06 IV.E.RP-06

E. RP-07 IV.E.RP-07

E. RP-05 IV.E.RP-05

E. RP-01 IV.E.RP-353

E. RP-03 IV.E.RP-03
NUREG-1950 A-32 April 2011

Table A-4. Relationship of 

Engineered Safety Features (ESF) 

System IDs in GALL Report, Chpt. V

Rev. 0 Rev. 1 Rev. 2

None None

V.B.EP-103

V.C.EP-103

V.D1.EP-103

V.D2.EP-103

None None

V.B.EP-107

V.C.EP-107

V.D1.EP-107

V.D2.EP-107

None None V.E.EP-114

None None V.F.EP-115

None None V.E.EP-116

None None V.E.EP-117

None None V.E.EP-118

None None V.E.EP-119

None None V.E.EP-120

None None V.E.EP-121

None None V.E.EP-122

None None V.E.EP-123

None None V.F.EP-65

None None V.F.EP-66

None None V.F.EP-67

None None V.F.EP-68

None None V.F.EP-82

None None V.F.EP-87

A. EP-39 V.A.EP-100

A. EP-47

V.D2.EP-78

V.D1.EP-78

V.A.EP-78

A. EP-43 V.A.EP-43

A. EP-34

V.D2.EP-74

V.A.EP-74

A. E-43

V.D1.E-43

V.A.E-43

Table A-4. Relationship of 

Engineered Safety Features (ESF) 

System IDs in GALL Report, Chpt. V

Rev. 0 Rev. 1 Rev. 2

A. EP-44

V.D2.EP-98

V.D1.EP-98

V.C.EP-98

V.A.EP-98

A. EP-53

V.D1.EP-81

V.A.EP-81

A. EP-33

V.D2.EP-95

V.D1.EP-95

V.C.EP-95

V.A.EP-95

A. EP-13

V.D2.EP-94

V.D1.EP-94

V.A.EP-94

A. EP-42 V.A.EP-42

A. EP-50

V.D2.EP-79

V.D1.EP-79

V.A.EP-79

A. EP-35

V.D2.EP-96

V.D1.EP-96

V.A.EP-96

A. EP-45

V.D2.EP-76

V.D1.EP-76

V.A.EP-76

A. EP-27

V.D2.EP-27

V.D1.EP-27

V.B.EP-27

V.A.EP-27

A. EP-46

V.D2.EP-77

V.D1.EP-77

V.A.EP-77

A. EP-41

V.D1.EP-41

V.A.EP-41

A. EP-36

V.D2.EP-97

V.D1.EP-97

V.B.EP-97

V.A.EP-97
April 2011 A-33 NUREG-1950

Table A-4. Relationship of 

Engineered Safety Features (ESF) 

System IDs in GALL Report, Chpt. V

Rev. 0 Rev. 1 Rev. 2

A. EP-37

V.D2.EP-37

V.D1.EP-37

V.B.EP-37

V.A.EP-37

A. EP-40

V.D2.EP-75

V.D1.EP-75

V.A.EP-75

A.1-a E-12

V.D1.E-12

V.A.E-12

A.1-b E-28

V.E.E-28

V.D1.E-28

V.A.E-28

A.1-c E-12

V.D1.E-12

V.A.E-12

A.2-a E-29

V.D2.E-29

V.A.E-29

A.2-a E-26 

V.D2.E-26

V.B.E-26

V.A.E-26

A.3-a E-12

V.D1.E-12

V.A.E-12

A.3-b E-28

V.E.E-28

V.D1.E-28

V.A.E-28

A.4-a E-12

V.D1.E-12

V.A.E-12

A.4-b E-28

V.E.E-28

V.D1.E-28

V.A.E-28

A.5-a E-26

V.D2.E-26

V.B.E-26

V.A.E-26

A.5-a E-29

V.D2.E-29

V.A.E-29

A.5-b E-28

V.E.E-28

V.D1.E-28

Table A-4. Relationship of 

Engineered Safety Features (ESF) 

System IDs in GALL Report, Chpt. V

Rev. 0 Rev. 1 Rev. 2

V.A.E-28

A.6-a E-18

V.D2.EP-90

V.D1.EP-90

V.A.EP-90

A.6-a E-20

V.D2.EP-91

V.D1.EP-91

V.A.EP-91

A.6-b E-21

V.D2.E-21

V.D1.E-21

V.A.E-21

A.6-c E-19

V.D2.EP-93

V.D1.EP-93

V.A.EP-93

A.6-c E-17

V.D2.EP-92

V.D1.EP-92

V.A.EP-92

A.6-d E-28

V.E.E-28

V.D1.E-28

V.A.E-28

B. EP-36

V.D2.EP-97

V.D1.EP-97

V.B.EP-97

V.A.EP-97

B. EP-37

V.D2.EP-37

V.D1.EP-37

V.B.EP-37

V.A.EP-37

B. EP-27

V.D2.EP-27

V.D1.EP-27

V.B.EP-27

V.A.EP-27

B. E-42 V.B.EP-111

B. EP-54

V.D2.EP-54

V.D1.EP-54

V.B.EP-54

B.1-a E-26 V.D2.E-26
NUREG-1950 A-34 April 2011

Table A-4. Relationship of 

Engineered Safety Features (ESF) 

System IDs in GALL Report, Chpt. V

Rev. 0 Rev. 1 Rev. 2

V.B.E-26

V.A.E-26

B.1-a E-40 V.B.E-40

B.1-b E-06

V.B.EP-58

V.B.EP-59

B.2-a E-25 V.B.E-25

B.2-a E-26

V.D2.E-26

V.B.E-26

V.A.E-26

B.2-b E-06

V.B.EP-58

V.B.EP-59

C. EP-33

V.D2.EP-95

V.D1.EP-95

V.C.EP-95

V.A.EP-95

C. EP-48 V.C.EP-99

C. EP-44 

V.D2.EP-98

V.D1.EP-98

V.C.EP-98

V.A.EP-98

C.1-a E-35 V.C.E-35

C.1-a E-22 V.C.E-22

C.1-a E-30 V.C.E-30

C.1-a E-31 V.C.EP-62

C.1-b E-34 V.C.E-34

C.1-b E-33 V.C.EP-63

D1. E-43

V.D1.E-43

V.A.E-43

D1. EP-44

V.D2.EP-98

V.D1.EP-98

V.C.EP-98

V.A.EP-98

D1. EP-31

V.D2.EP-72

V.D1.EP-72

D1. EP-54 V.D2.EP-54

Table A-4. Relationship of 

Engineered Safety Features (ESF) 

System IDs in GALL Report, Chpt. V

Rev. 0 Rev. 1 Rev. 2

V.D1.EP-54

V.B.EP-54

D1. EP-50

V.D2.EP-79

V.D1.EP-79

V.A.EP-79

D1. EP-45

V.D2.EP-76

V.D1.EP-76

V.A.EP-76

D1. EP-52 V.D1.EP-52

D1. EP-36

V.D2.EP-97

V.D1.EP-97

V.B.EP-97

V.A.EP-97

D1. EP-40

V.D2.EP-75

V.D1.EP-75

V.A.EP-75

D1. EP-27

V.D2.EP-27

V.D1.EP-27

V.B.EP-27

V.A.EP-27

D1. EP-33

V.D2.EP-95

V.D1.EP-95

V.C.EP-95

V.A.EP-95

D1. EP-46

V.D2.EP-77

V.D1.EP-77

V.A.EP-77

D1. EP-37

V.D2.EP-37

V.D1.EP-37

V.B.EP-37

V.A.EP-37

D1. EP-13

V.D2.EP-94

V.D1.EP-94

V.A.EP-94

D1. EP-35

V.D2.EP-96

V.D1.EP-96
April 2011 A-35 NUREG-1950

Table A-4. Relationship of 

Engineered Safety Features (ESF) 

System IDs in GALL Report, Chpt. V

Rev. 0 Rev. 1 Rev. 2

V.A.EP-96

D1. EP-41

V.D1.EP-41

V.A.EP-41

D1. EP-53

V.D1.EP-81

V.A.EP-81

D1. EP-49 V.D1.EP-49

D1. EP-55 V.D1.EP-55

D1. EP-51 V.D1.EP-80

D1. EP-47

V.D2.EP-78

V.D1.EP-78

V.A.EP-78

D1.1-a E-12

V.D1.E-12

V.A.E-12

D1.1-b E-47 V.D1.E-47

D1.1-c E-13 V.D1.E-13

D1.1-d E-28

V.E.E-28

V.D1.E-28

V.A.E-28

D1.2-a E-12

V.D1.E-12

V.A.E-12

D1.2-b E-28

V.E.E-28

V.D1.E-28

V.A.E-28

D1.2-c E-24 V.D1.E-24

D1.3-a E-28

V.E.E-28

V.D1.E-28

V.A.E-28

D1.4-a E-13 V.D1.E-13

D1.4-b E-12

V.D1.E-12

V.A.E-12

D1.4-c E-28

V.E.E-28

V.D1.E-28

V.A.E-28

D1.5-a E-17 V.D2.EP-92

Table A-4. Relationship of 

Engineered Safety Features (ESF) 

System IDs in GALL Report, Chpt. V

Rev. 0 Rev. 1 Rev. 2

V.D1.EP-92

V.A.EP-92

D1.5-a E-19

V.D2.EP-93

V.D1.EP-93

V.A.EP-93

D1.5-b E-28

V.E.E-28

V.D1.E-28

V.A.E-28

D1.6-a E-19

V.D2.EP-93

V.D1.EP-93

V.A.EP-93

D1.6-a E-17

V.D2.EP-92

V.D1.EP-92

V.A.EP-92

D1.6-b E-18

V.D2.EP-90

V.D1.EP-90

V.A.EP-90

D1.6-b E-20

V.D2.EP-91

V.D1.EP-91

V.A.EP-91

D1.6-c E-21

V.D2.E-21

V.D1.E-21

V.A.E-21

D1.6-d E-28

V.E.E-28

V.D1.E-28

V.A.E-28

D1.7-a E-28

V.E.E-28

V.D1.E-28

V.A.E-28

D1.7-b E-38 V.D1.E-38

D1.7-b E-12

V.D1.E-12

V.A.E-12

D1.8-a E-12

V.D1.E-12

V.A.E-12

D1.8-b E-28

V.E.E-28

V.D1.E-28
NUREG-1950 A-36 April 2011

Table A-4. Relationship of 

Engineered Safety Features (ESF) 

System IDs in GALL Report, Chpt. V

Rev. 0 Rev. 1 Rev. 2

V.A.E-28

D1.8-c E-01 V.D1.E-01

D2. EP-13

V.D2.EP-94

V.D1.EP-94

V.A.EP-94

D2. EP-2 V.D1.EP-101

D2. EP-45

V.D2.EP-76

V.D1.EP-76

V.A.EP-76

D2. EP-36

V.D2.EP-97

V.D1.EP-97

V.B.EP-97

V.A.EP-97

D2. EP-34

V.D2.EP-74

V.A.EP-74

D2. EP-47

V.D2.EP-78

V.D1.EP-78

V.A.EP-78

D2. EP-26 V.D2.EP-71

D2. EP-37

V.D2.EP-37

V.D1.EP-37

V.B.EP-37

V.A.EP-37

D2. EP-50

V.D2.EP-79

V.D1.EP-79

V.A.EP-79

D2. EP-27

V.D2.EP-27

V.D1.EP-27

V.B.EP-27

V.A.EP-27

D2. EP-44

V.D2.EP-98

V.D1.EP-98

V.C.EP-98

V.A.EP-98

D2. EP-32 V.D2.EP-73

D2. EP-35 V.D2.EP-96

Table A-4. Relationship of 

Engineered Safety Features (ESF) 

System IDs in GALL Report, Chpt. V

Rev. 0 Rev. 1 Rev. 2

V.D1.EP-96

V.A.EP-96

D2. EP-54

V.D2.EP-54

V.D1.EP-54

V.B.EP-54

D2. EP-40

V.D2.EP-75

V.D1.EP-75

V.A.EP-75

D2. EP-31

V.D2.EP-72

V.D1.EP-72

D2. EP-46

V.D2.EP-77

V.D1.EP-77

V.A.EP-77

D2. EP-33

V.D2.EP-95

V.D1.EP-95

V.C.EP-95

V.A.EP-95

D2.1-a E-08 V.D2.EP-60

D2.1-b E-10 V.D2.E-10

D2.1-c E-37 V.D2.E-37

D2.1-d E-11 V.D2.E-11

D2.1-e E-26

V.D2.E-26

V.B.E-26

V.A.E-26

D2.1-e E-14 V.D2.EP-61

D2.1-e E-27 V.D2.E-27

D2.1-f E-07 V.D2.E-07

D2.2-a E-08 V.D2.EP-60

D2.3-a E-09 V.D2.E-09

D2.3-b E-08 V.D2.EP-60

D2.3-c E-37 V.D2.E-37

D2.4-a E-20

V.D2.EP-91

V.D1.EP-91

V.A.EP-91

D2.4-a E-18 V.D2.EP-90
April 2011 A-37 NUREG-1950

Table A-4. Relationship of 

Engineered Safety Features (ESF) 

System IDs in GALL Report, Chpt. V

Rev. 0 Rev. 1 Rev. 2

V.D1.EP-90

V.A.EP-90

D2.4-b E-21

V.D2.E-21

V.D1.E-21

V.A.E-21

D2.4-b E-23 V.D2.E-23

D2.4-c E-19

V.D2.EP-93

V.D1.EP-93

V.A.EP-93

D2.4-c E-17

V.D2.EP-92

V.D1.EP-92

V.A.EP-92

D2.5-a E-26

V.D2.E-26

V.B.E-26

V.A.E-26

D2.5-a E-29

V.D2.E-29

V.A.E-29

D2.5-b E-04 V.D2.EP-113

E. E-41 V.E.E-41

E. EP-38 V.E.EP-38

E. EP-24 V.E.EP-69

E. EP-1 V.E.EP-64

E. EP-25 V.E.EP-70

E. E-44 V.E.E-44

E. E-45 V.E.E-45

E.1-a E-28

V.E.E-28

V.D1.E-28

V.A.E-28

E.1-b E-46 V.E.E-46

E.2-a E-02 V.E.E-02

E.2-b E-03 V.E.E-03

F. EP-4 V.F.EP-4 

F. EP-3 V.F.EP-3 

F. EP-14 V.F.EP-14

Table A-4. Relationship of 

Engineered Safety Features (ESF) 

System IDs in GALL Report, Chpt. V

Rev. 0 Rev. 1 Rev. 2

F. EP-12 V.F.EP-12

F. EP-5 V.F.EP-112

F. EP-29 V.F.EP-29

F. EP-30 V.F.EP-30

F. EP-20 V.F.EP-20

F. EP-9 V.F.EP-9 

F. EP-18 V.F.EP-18

F. EP-7 V.F.EP-7 

F. EP-10 V.F.EP-10

F. EP-16 V.F.EP-16

F. EP-15 V.F.EP-15

F. EP-28 V.F.EP-28

F. EP-17 V.F.EP-17

F. EP-19 V.F.EP-19

F. EP-22 V.F.EP-22

None None

V.B.EP-103

V.C.EP-103

V.D1.EP-103

V.D2.EP-103

None None

V.B.EP-107

V.C.EP-107

V.D1.EP-107

V.D2.EP-107

None None V.E.EP-114

None None V.F.EP-115

None None V.E.EP-116

None None V.E.EP-117

None None V.E.EP-118

None None V.E.EP-119

None None V.E.EP-120

None None V.E.EP-121

None None V.E.EP-122

None None V.E.EP-123
NUREG-1950 A-38 April 2011

Table A-4. Relationship of 

Engineered Safety Features (ESF) 

System IDs in GALL Report, Chpt. V

Rev. 0 Rev. 1 Rev. 2

None None V.F.EP-65

None None V.F.EP-66

None None V.F.EP-67

None None V.F.EP-68

None None V.F.EP-82

None None V.F.EP-87

A. EP-39 V.A.EP-100

A. EP-47

V.D2.EP-78

V.D1.EP-78

V.A.EP-78

A. EP-43 V.A.EP-43

A. EP-34

V.D2.EP-74

V.A.EP-74

A. E-43

V.D1.E-43

V.A.E-43

A. EP-44

V.D2.EP-98

V.D1.EP-98

V.C.EP-98

V.A.EP-98

A. EP-53

V.D1.EP-81

V.A.EP-81

A. EP-33

V.D2.EP-95

V.D1.EP-95

V.C.EP-95

V.A.EP-95

A. EP-13

V.D2.EP-94

V.D1.EP-94

V.A.EP-94

A. EP-42 V.A.EP-42

A. EP-50

V.D2.EP-79

V.D1.EP-79

V.A.EP-79

A. EP-35

V.D2.EP-96

V.D1.EP-96

V.A.EP-96

Table A-4. Relationship of 

Engineered Safety Features (ESF) 

System IDs in GALL Report, Chpt. V

Rev. 0 Rev. 1 Rev. 2

A. EP-45

V.D2.EP-76

V.D1.EP-76

V.A.EP-76

A. EP-27

V.D2.EP-27

V.D1.EP-27

V.B.EP-27

V.A.EP-27

A. EP-46

V.D2.EP-77

V.D1.EP-77

V.A.EP-77

A. EP-41

V.D1.EP-41

V.A.EP-41

A. EP-36

V.D2.EP-97

V.D1.EP-97

V.B.EP-97

V.A.EP-97

A. EP-37

V.D2.EP-37

V.D1.EP-37

V.B.EP-37

V.A.EP-37

A. EP-40

V.D2.EP-75

V.D1.EP-75

V.A.EP-75

A.1-a E-12

V.D1.E-12

V.A.E-12

A.1-b E-28

V.E.E-28

V.D1.E-28

V.A.E-28

A.1-c E-12

V.D1.E-12

V.A.E-12

A.2-a E-29

V.D2.E-29

V.A.E-29

A.2-a E-26

V.D2.E-26

V.B.E-26

V.A.E-26

A.3-a E-12 V.D1.E-12
April 2011 A-39 NUREG-1950

Table A-4. Relationship of 

Engineered Safety Features (ESF) 

System IDs in GALL Report, Chpt. V

Rev. 0 Rev. 1 Rev. 2

V.A.E-12

A.3-b E-28

V.E.E-28

V.D1.E-28

V.A.E-28

A.4-a E-12

V.D1.E-12

V.A.E-12

A.4-b E-28

V.E.E-28

V.D1.E-28

V.A.E-28

A.5-a E-26

V.D2.E-26

V.B.E-26

V.A.E-26

A.5-a E-29

V.D2.E-29

V.A.E-29

A.5-b E-28

V.E.E-28

V.D1.E-28

V.A.E-28

A.6-a E-18

V.D2.EP-90

V.D1.EP-90

V.A.EP-90

A.6-a E-20

V.D2.EP-91

V.D1.EP-91

V.A.EP-91

A.6-b E-21

V.D2.E-21

V.D1.E-21

V.A.E-21

A.6-c E-19

V.D2.EP-93

V.D1.EP-93

V.A.EP-93

A.6-c E-17

V.D2.EP-92

V.D1.EP-92

V.A.EP-92

A.6-d E-28

V.E.E-28

V.D1.E-28

V.A.E-28

B. EP-36 V.D2.EP-97

Table A-4. Relationship of 

Engineered Safety Features (ESF) 

System IDs in GALL Report, Chpt. V

Rev. 0 Rev. 1 Rev. 2

V.D1.EP-97

V.B.EP-97

V.A.EP-97

B. EP-37

V.D2.EP-37

V.D1.EP-37

V.B.EP-37

V.A.EP-37

B. EP-27

V.D2.EP-27

V.D1.EP-27

V.B.EP-27

V.A.EP-27

B. E-42 V.B.EP-111

B. EP-54

V.D2.EP-54

V.D1.EP-54

V.B.EP-54

B.1-a E-26

V.D2.E-26

V.B.E-26

V.A.E-26

B.1-a E-40 V.B.E-40

B.1-b E-06

V.B.EP-58

V.B.EP-59

B.2-a E-25 V.B.E-25

B.2-a E-26

V.D2.E-26

V.B.E-26

V.A.E-26

B.2-b E-06

V.B.EP-58

V.B.EP-59

C. EP-33

V.D2.EP-95

V.D1.EP-95

V.C.EP-95

V.A.EP-95

C. EP-48 V.C.EP-99

C. EP-44

V.D2.EP-98

V.D1.EP-98

V.C.EP-98

V.A.EP-98
NUREG-1950 A-40 April 2011

Table A-4. Relationship of 

Engineered Safety Features (ESF) 

System IDs in GALL Report, Chpt. V

Rev. 0 Rev. 1 Rev. 2

C.1-a E-35 V.C.E-35

C.1-a E-22 V.C.E-22

C.1-a E-30 V.C.E-30

C.1-a E-31 V.C.EP-62

C.1-b E-34 V.C.E-34

C.1-b E-33 V.C.EP-63

D1. E-43

V.D1.E-43

V.A.E-43

D1. EP-44

V.D2.EP-98

V.D1.EP-98

V.C.EP-98

V.A.EP-98

D1. EP-31

V.D2.EP-72

V.D1.EP-72

D1. EP-54

V.D2.EP-54

V.D1.EP-54

V.B.EP-54

D1. EP-50

V.D2.EP-79

V.D1.EP-79

V.A.EP-79

D1. EP-45

V.D2.EP-76

V.D1.EP-76

V.A.EP-76

D1. EP-52 V.D1.EP-52

D1. EP-36

V.D2.EP-97

V.D1.EP-97

V.B.EP-97

V.A.EP-97

D1. EP-40

V.D2.EP-75

V.D1.EP-75

V.A.EP-75

D1. EP-27

V.D2.EP-27

V.D1.EP-27

V.B.EP-27

V.A.EP-27

Table A-4. Relationship of 

Engineered Safety Features (ESF) 

System IDs in GALL Report, Chpt. V

Rev. 0 Rev. 1 Rev. 2

D1. EP-33

V.D2.EP-95

V.D1.EP-95

V.C.EP-95

V.A.EP-95

D1. EP-46

V.D2.EP-77

V.D1.EP-77

V.A.EP-77

D1. EP-37

V.D2.EP-37

V.D1.EP-37

V.B.EP-37

V.A.EP-37

D1. EP-13

V.D2.EP-94

V.D1.EP-94

V.A.EP-94

D1. EP-35

V.D2.EP-96

V.D1.EP-96

V.A.EP-96

D1. EP-41

V.D1.EP-41

V.A.EP-41

D1. EP-53

V.D1.EP-81

V.A.EP-81

D1. EP-49 V.D1.EP-49

D1. EP-55 V.D1.EP-55

D1. EP-51 V.D1.EP-80

D1. EP-47

V.D2.EP-78

V.D1.EP-78

V.A.EP-78

D1.1-a E-12

V.D1.E-12

V.A.E-12

D1.1-b E-47 V.D1.E-47

D1.1-c E-13 V.D1.E-13

D1.1-d E-28

V.E.E-28

V.D1.E-28

V.A.E-28

D1.2-a E-12 V.D1.E-12
April 2011 A-41 NUREG-1950

Table A-4. Relationship of 

Engineered Safety Features (ESF) 

System IDs in GALL Report, Chpt. V

Rev. 0 Rev. 1 Rev. 2

V.A.E-12

D1.2-b E-28

V.E.E-28

V.D1.E-28

V.A.E-28

D1.2-c E-24 V.D1.E-24

D1.3-a E-28

V.E.E-28

V.D1.E-28

V.A.E-28

D1.4-a E-13 V.D1.E-13

D1.4-b E-12

V.D1.E-12

V.A.E-12

D1.4-c E-28

V.E.E-28

V.D1.E-28

V.A.E-28

D1.5-a E-17

V.D2.EP-92

V.D1.EP-92

V.A.EP-92

D1.5-a E-19

V.D2.EP-93

V.D1.EP-93

V.A.EP-93

D1.5-b E-28

V.E.E-28

V.D1.E-28

V.A.E-28

D1.6-a E-19

V.D2.EP-93

V.D1.EP-93

V.A.EP-93

D1.6-a E-17

V.D2.EP-92

V.D1.EP-92

V.A.EP-92

D1.6-b E-18

V.D2.EP-90

V.D1.EP-90

V.A.EP-90

D1.6-b E-20

V.D2.EP-91

V.D1.EP-91

V.A.EP-91

Table A-4. Relationship of 

Engineered Safety Features (ESF) 

System IDs in GALL Report, Chpt. V

Rev. 0 Rev. 1 Rev. 2

D1.6-c E-21 

V.D2.E-21

V.D1.E-21

V.A.E-21

D1.6-d E-28

V.E.E-28

V.D1.E-28

V.A.E-28

D1.7-a E-28

V.E.E-28

V.D1.E-28

V.A.E-28

D1.7-b E-38 V.D1.E-38

D1.7-b E-12

V.D1.E-12

V.A.E-12

D1.8-a E-12

V.D1.E-12

V.A.E-12

D1.8-b E-28

V.E.E-28

V.D1.E-28

V.A.E-28

D1.8-c E-01 V.D1.E-01

D2. EP-13

V.D2.EP-94

V.D1.EP-94

V.A.EP-94

D2. EP-2 V.D1.EP-101

D2. EP-45

V.D2.EP-76

V.D1.EP-76

V.A.EP-76

D2. EP-36

V.D2.EP-97

V.D1.EP-97

V.B.EP-97

V.A.EP-97

D2. EP-34

V.D2.EP-74

V.A.EP-74

D2. EP-47

V.D2.EP-78

V.D1.EP-78

V.A.EP-78

D2. EP-26 V.D2.EP-71
NUREG-1950 A-42 April 2011

Table A-4. Relationship of 

Engineered Safety Features (ESF) 

System IDs in GALL Report, Chpt. V

Rev. 0 Rev. 1 Rev. 2

D2. EP-37

V.D2.EP-37

V.D1.EP-37

V.B.EP-37

V.A.EP-37

D2. EP-50

V.D2.EP-79

V.D1.EP-79

V.A.EP-79

D2. EP-27

V.D2.EP-27

V.D1.EP-27

V.B.EP-27

V.A.EP-27

D2. EP-44

V.D2.EP-98

V.D1.EP-98

V.C.EP-98

V.A.EP-98

D2. EP-32 V.D2.EP-73

D2. EP-35

V.D2.EP-96

V.D1.EP-96

V.A.EP-96

D2. EP-54

V.D2.EP-54

V.D1.EP-54

V.B.EP-54

D2. EP-40

V.D2.EP-75

V.D1.EP-75

V.A.EP-75

D2. EP-31

V.D2.EP-72

V.D1.EP-72

D2. EP-46

V.D2.EP-77

V.D1.EP-77

V.A.EP-77

D2. EP-33

V.D2.EP-95

V.D1.EP-95

V.C.EP-95

V.A.EP-95

D2.1-a E-08 V.D2.EP-60

D2.1-b E-10 V.D2.E-10

Table A-4. Relationship of 

Engineered Safety Features (ESF) 

System IDs in GALL Report, Chpt. V

Rev. 0 Rev. 1 Rev. 2

D2.1-c E-37 V.D2.E-37

D2.1-d E-11 V.D2.E-11

D2.1-e E-26

V.D2.E-26

V.B.E-26

V.A.E-26

D2.1-e E-14 V.D2.EP-61

D2.1-e E-27 V.D2.E-27

D2.1-f E-07 V.D2.E-07

D2.2-a E-08 V.D2.EP-60

D2.3-a E-09 V.D2.E-09

D2.3-b E-08 V.D2.EP-60

D2.3-c E-37 V.D2.E-37

D2.4-a E-20

V.D2.EP-91

V.D1.EP-91

V.A.EP-91

D2.4-a E-18

V.D2.EP-90

V.D1.EP-90

V.A.EP-90

D2.4-b E-21

V.D2.E-21

V.D1.E-21

V.A.E-21

D2.4-b E-23 V.D2.E-23

D2.4-c E-19

V.D2.EP-93

V.D1.EP-93

V.A.EP-93

D2.4-c E-17

V.D2.EP-92

V.D1.EP-92

V.A.EP-92

D2.5-a E-26

V.D2.E-26

V.B.E-26

V.A.E-26

D2.5-a E-29

V.D2.E-29

V.A.E-29

D2.5-b E-04 V.D2.EP-113
April 2011 A-43 NUREG-1950

Table A-4. Relationship of 

Engineered Safety Features (ESF) 

System IDs in GALL Report, Chpt. V

Rev. 0 Rev. 1 Rev. 2

E. E-41 V.E.E-41

E. EP-38 V.E.EP-38

E. EP-24 V.E.EP-69

E. EP-1 V.E.EP-64

E. EP-25 V.E.EP-70

E. E-44 V.E.E-44

E. E-45 V.E.E-45

E.1-a E-28

V.E.E-28

V.D1.E-28

V.A.E-28

E.1-b E-46 V.E.E-46

E.2-a E-02 V.E.E-02

E.2-b E-03 V.E.E-03

F. EP-4 V.F.EP-4 

F. EP-3 V.F.EP-3 

F. EP-14 V.F.EP-14

F. EP-12 V.F.EP-12

F. EP-5 V.F.EP-112

F. EP-29 V.F.EP-29

F. EP-30 V.F.EP-30

F. EP-20 V.F.EP-20

F. EP-9 V.F.EP-9 

F. EP-18 V.F.EP-18

F. EP-7 V.F.EP-7 

F. EP-10 V.F.EP-10

F. EP-16 V.F.EP-16

F. EP-15 V.F.EP-15

F. EP-28 V.F.EP-28

F. EP-17 V.F.EP-17

F. EP-19 V.F.EP-19

F. EP-22 V.F.EP-22
NUREG-1950 A-44 April 2011

Table A-5. Relationship of Electrical 

Components System IDs in GALL 

Report, Chapter VI

Rev. 0 Rev. 1 Rev. 2

A. LP-01

VI.A.LP-23

VI.A.LP-31

A. LP-02 VI.A.LP-24

A. LP-03 Retired

A. LP-04 VI.A.LP-25

A. LP-05 VI.A.LP-26

A. LP-06

VI.A.LP-41

VI.A.LP-42

VI.A.LP-43

VI.A.LP-44

A. LP-07 VI.A.LP-28

A. LP-08

VI.A.LP-38

VI.A.LP-46

VI.A.LP-47

VI.A.LP-48

A. LP-09 VI.A.LP-39

A. LP-10 VI.A.LP-29

A. LP-11 VI.A.LP-32

A. LP-12 VI.A.LP-30

A.1-a L-01 VI.A.LP-33

A.1-b L-02 VI.A.LP-34

A.1-c L-03 VI.A.LP-35

A.2-a L-04 VI.A.LP-36

B.1-a L-05 VI.B.L-05
April 2011 A-45 NUREG-1950

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

None None VII.E1.AP-119

None None VII.J.AP-123

None None VII.J.AP-134

None None VII.J.AP-135

None None VII.J.AP-144

None None VII.G.AP-149

None None VII.G.AP-150

None None VII.J.AP-151

None None VII.C1.AP-152

None None VII.C1.AP-153

None None VII.H2.AP-154

None None VII.C1.AP-155

None None VII.C1.AP-156

None None VII.C1.AP-157

None None VII.I.AP-159

None None VII.J.AP-160

None None VII.C1.AP-161

None None VII.H2.AP-162

None None VII.J.AP-166

None None VII.J.AP-167

None None VII.C1.AP-171

None None VII.C1.AP-172

None None VII.C1.AP-173

None None VII.C1.AP-174

None None VII.C1.AP-175

None None VII.C1.AP-176

None None VII.C1.AP-177

None None VII.C1.AP-178

None None

VII.C1.AP-209

VII.C2.AP-209

VII.C3.AP-209

VII.D.AP-209

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.E1.AP-209

VII.E4.AP-209

VII.F1.AP-209

VII.F2.AP-209

VII.F4.AP-209

VII.G.AP-209

VII.H1.AP-209

VII.H2.AP-209

None None

VII.C1.AP-221

VII.C2.AP-221

VII.C3.AP-221

VII.D.AP-221

VII.E1.AP-221

VII.E4.AP-221

VII.F1.AP-221

VII.F2.AP-221

VII.F4.AP-221

VII.G.AP-221

VII.H1.AP-221

VII.H2.AP-221

None None VII.C1.AP-237

None None VII.C1.AP-238

None None VII.C1.AP-239

None None VII.D.AP-240

None None VII.I.AP-241

None None VII.I.AP-242

None None VII.I.AP-243

None None VII.I.AP-244

None None VII.C1.AP-248

None None VII.C1.AP-249

None None VII.C1.AP-250

None None VII.C1.AP-251

None None VII.C1.AP-252

None None VII.C1.AP-253

None None VII.C2.AP-254
NUREG-1950 A-46 April 2011

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

None None VII.H2.AP-255

None None VII.I.AP-256

None None VII.C2.AP-257

None None VII.H2.AP-258

None None VII.C2.AP-259

None None VII.J.AP-260

None None VII.I.AP-261

None None VII.I.AP-262

None None VII.I.AP-263

None None VII.I.AP-264

None None VII.I.AP-265

None None VII.I.AP-266

None None VII.I.AP-267

None None VII.J.AP-268

None None VII.J.AP-269

None None VII.E5.AP-270

None None VII.E5.AP-271

None None VII.E5.AP-272

None None VII.E5.AP-273

None None VII.E5.AP-274

None None VII.E5.AP-275

None None VII.E5.AP-276

None None VII.J.AP-277

None None VII.E5.AP-278

None None VII.E5.AP-279

None None VII.E5.AP-280

None None VII.E5.AP-281

None None VII.J.AP-96

None None VII.J.AP-97

None None VII.J.AP-98

None None VII.I.AP-284

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

A1.1-a A-94 VII.A1.A-94

A2. AP-79

VII.E1.AP-79

VII.A3.AP-79

VII.A2.AP-79

A2.1-a A-86 VII.A2.A-86

A2.1-a A-87 VII.A2.A-87

A2.1-b A-89 VII.A2.AP-236

A2.1-b A-88 VII.A2.AP-235

A2.1-c A-97 VII.A2.A-97

A2.1-c A-96 VII.A2.A-96

A3. AP-43

VII.E3.AP-43

VII.E1.AP-43

VII.C2.AP-43

VII.A4.AP-43

VII.A3.AP-43

VII.H2.AP-43

VII.H1.AP-43

VII.F4.AP-43

VII.F3.AP-43

VII.F2.AP-43

VII.F1.AP-43

VII.E4.AP-43

A3. AP-79

VII.E1.AP-79

VII.A3.AP-79

VII.A2.AP-79

A3. AP-31

VII.G.AP-31

VII.F4.AP-31

VII.F2.AP-31

VII.F1.AP-31

VII.E4.AP-31

VII.E3.AP-31

VII.E1.AP-31

VII.C2.AP-31

VII.A4.AP-31

VII.A3.AP-31

A3. AP-1 VII.E1.AP-1 
April 2011 A-47 NUREG-1950

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.A3.AP-1

A3. AP-12

VII.H2.AP-199

VII.H1.AP-199

VII.F4.AP-199

VII.F3.AP-199

VII.F2.AP-199

VII.F1.AP-199

VII.E4.AP-199

VII.E3.AP-199

VII.E1.AP-199

VII.C2.AP-199

VII.A4.AP-199

VII.A3.AP-199

A3.1-a A-79

VII.I.A-79

VII.E1.A-79

VII.A3.A-79

A3.2-a A-39 VII.A3.AP-107

A3.2-a A-15 VII.A3.AP-100

A3.2-b A-79

VII.I.A-79

VII.E1.A-79

VII.A3.A-79

A3.2-c A-79

VII.I.A-79

VII.E1.A-79

VII.A3.A-79

A3.2-d A-15 VII.A3.AP-100

A3.3-a A-15 VII.A3.AP-100

A3.3-a A-39 VII.A3.AP-107

A3.3-b A-56 VII.A3.A-56

A3.3-c A-79

VII.I.A-79

VII.E1.A-79

VII.A3.A-79

A3.3-d A-15 VII.A3.AP-100

A3.4-a A-63

VII.F4.AP-189

VII.F3.AP-189

VII.F2.AP-189

VII.F1.AP-189

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.E4.AP-189

VII.E3.AP-189

VII.E1.AP-189

VII.C2.AP-189

VII.A4.AP-189

VII.A3.AP-189

A3.4-b A-79

VII.I.A-79

VII.E1.A-79

VII.A3.A-79

A3.5-a A-15 VII.A3.AP-100

A3.5-a A-39 VII.A3.AP-107

A3.5-b A-79

VII.I.A-79

VII.E1.A-79

VII.A3.A-79

A3.5-c A-15 VII.A3.AP-100

A3.6-a A-79

VII.I.A-79

VII.E1.A-79

VII.A3.A-79

A4. AP-31

VII.G.AP-31

VII.F4.AP-31

VII.F2.AP-31

VII.F1.AP-31

VII.E4.AP-31

VII.E3.AP-31

VII.E1.AP-31

VII.C2.AP-31

VII.A4.AP-31

VII.A3.AP-31

A4. AP-12

VII.H2.AP-199

VII.H1.AP-199

VII.F4.AP-199

VII.F3.AP-199

VII.F2.AP-199

VII.F1.AP-199

VII.E4.AP-199

VII.E3.AP-199

VII.E1.AP-199
NUREG-1950 A-48 April 2011

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.C2.AP-199

VII.A4.AP-199

VII.A3.AP-199

A4. AP-38

VII.E4.AP-130

VII.E3.AP-130

VII.A4.AP-130

A4. AP-62

VII.E3.AP-139

VII.A4.AP-139

A4. AP-32

VII.E4.AP-32

VII.E3.AP-32

VII.C2.AP-32

VII.A4.AP-32

A4. AP-64

VII.E4.AP-140

VII.E3.AP-140

VII.A4.AP-140

A4. AP-43

VII.E3.AP-43

VII.E1.AP-43

VII.C2.AP-43

VII.A4.AP-43

VII.A3.AP-43

VII.H2.AP-43

VII.H1.AP-43

VII.F4.AP-43

VII.F3.AP-43

VII.F2.AP-43

VII.F1.AP-43

VII.E4.AP-43

A4.1-a A-58

VII.E4.AP-110

VII.E3.AP-110

VII.A4.AP-110

A4.2-a A-16 VII.A4.AP-101

A4.2-a A-40 VII.A4.AP-108

A4.2-b A-16 VII.A4.AP-101

A4.3-a A-16 VII.A4.AP-101

A4.3-a A-40 VII.A4.AP-108

A4.3-b A-16 VII.A4.AP-101

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

A4.4-a A-63

VII.F4.AP-189

VII.F3.AP-189

VII.F2.AP-189

VII.F1.AP-189

VII.E4.AP-189

VII.E3.AP-189

VII.E1.AP-189

VII.C2.AP-189

VII.A4.AP-189

VII.A3.AP-189

A4.4-b A-70 VII.A4.AP-111

A4.5-a A-40 VII.A4.AP-108

A4.5-a A-16 VII.A4.AP-101

A4.5-b A-16 VII.A4.AP-101

A4.6-a A-58

VII.E4.AP-110

VII.E3.AP-110

VII.A4.AP-110

B.1-a A-06 VII.B.A-06

B.1-b A-07 VII.B.A-07

B.2-a A-05 VII.B.A-05

C1. AP-59

VII.H2.AP-138

VII.G.AP-138

VII.E4.AP-138

VII.E1.AP-138

VII.C2.AP-138

VII.C1.AP-138

C1. AP-61

VII.H2.AP-187

VII.G.AP-187

VII.C3.AP-187

VII.C1.AP-187

C1. AP-47

VII.H2.AP-133

VII.G.AP-133

VII.E4.AP-133

VII.E1.AP-133

VII.C2.AP-133

VII.C1.AP-133
April 2011 A-49 NUREG-1950

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

C1. AP-56

VII.H2.AP-137

VII.H1.AP-137

VII.G.AP-137

VII.C3.AP-137

VII.C1.AP-137

C1. AP-75 VII.C1.AP-75

C1. AP-76 VII.C1.AP-76

C1. AP-30

VII.H2.AP-127

VII.G.AP-127

VII.F4.AP-127

VII.F3.AP-127

VII.F2.AP-127

VII.F1.AP-127

VII.E4.AP-127

VII.E1.AP-127

VII.C2.AP-127

VII.C1.AP-127

C1. AP-53

VII.C3.AP-206

VII.C1.AP-206

C1.1-a A-38

VII.H2.AP-194

VII.C3.AP-194

VII.C1.AP-194

C1.1-a A-44 VII.C1.AP-196

C1.1-a A-54 VII.C1.A-54

C1.1-a A-47

VII.H2.A-47

VII.G.A-47

VII.C3.A-47

VII.C1.A-47

C1.1-b A-01

VII.H1.AP-198

VII.G.AP-198

VII.C3.AP-198

VII.C1.AP-198

C1.1-c A-02

VII.H1.A-02

VII.G.A-02

VII.C3.A-02

VII.C1.A-02

VII.H2.A-02

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

C1.2-a A-44 VII.C1.AP-196

C1.2-a A-38

VII.H2.AP-194

VII.C3.AP-194

VII.C1.AP-194

C1.2-a A-47

VII.H2.A-47

VII.G.A-47

VII.C3.A-47

VII.C1.A-47

C1.2-a A-54 VII.C1.A-54

C1.3-a A-66 VII.C1.A-66

C1.3-a A-65 VII.C1.AP-179

C1.3-a A-64 VII.C1.AP-183

C1.3-b A-72 VII.C1.A-72

C1.4-a A-54 VII.C1.A-54

C1.5-a A-51

VII.H2.A-51

VII.G.A-51

VII.C3.A-51

VII.C1.A-51

C1.5-a A-38

VII.H2.AP-194

VII.C3.AP-194

VII.C1.AP-194

C1.6-a A-38

VII.H2.AP-194

VII.C3.AP-194

VII.C1.AP-194

C1.6-a A-54 VII.C1.A-54

C2. AP-59

VII.H2.AP-138

VII.G.AP-138

VII.E4.AP-138

VII.E1.AP-138

VII.C2.AP-138

VII.C1.AP-138

C2. AP-31

VII.G.AP-31

VII.F4.AP-31

VII.F2.AP-31

VII.F1.AP-31

VII.E4.AP-31
NUREG-1950 A-50 April 2011

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.E3.AP-31

VII.E1.AP-31

VII.C2.AP-31

VII.A4.AP-31

VII.A3.AP-31

C2. AP-30

VII.H2.AP-127

VII.G.AP-127

VII.F4.AP-127

VII.F3.AP-127

VII.F2.AP-127

VII.F1.AP-127

VII.E4.AP-127

VII.E1.AP-127

VII.C2.AP-127

VII.C1.AP-127

C2. AP-80

VII.F3.AP-205

VII.F2.AP-205

VII.F1.AP-205

VII.C2.AP-205

C2. AP-12

VII.H2.AP-199

VII.H1.AP-199

VII.F4.AP-199

VII.F3.AP-199

VII.F2.AP-199

VII.F1.AP-199

VII.E4.AP-199

VII.E3.AP-199

VII.E1.AP-199

VII.C2.AP-199

VII.A4.AP-199

VII.A3.AP-199

C2. AP-63

VII.E4.AP-188

VII.E3.AP-188

VII.C2.AP-188

C2. AP-60

VII.E4.AP-186

VII.E3.AP-186

VII.C2.AP-186

C2. AP-47 VII.H2.AP-133

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.G.AP-133

VII.E4.AP-133

VII.E1.AP-133

VII.C2.AP-133

VII.C1.AP-133

C2. A-63

VII.F4.AP-189

VII.F3.AP-189

VII.F2.AP-189

VII.F1.AP-189

VII.E4.AP-189

VII.E3.AP-189

VII.E1.AP-189

VII.C2.AP-189

VII.A4.AP-189

VII.A3.AP-189

C2. AP-32

VII.E4.AP-32

VII.E3.AP-32

VII.C2.AP-32

VII.A4.AP-32

C2. AP-43

VII.E3.AP-43

VII.E1.AP-43

VII.C2.AP-43

VII.A4.AP-43

VII.A3.AP-43

VII.H2.AP-43

VII.H1.AP-43

VII.F4.AP-43

VII.F3.AP-43

VII.F2.AP-43

VII.F1.AP-43

VII.E4.AP-43

C2.1-a A-25

VII.H2.AP-202

VII.F4.AP-202

VII.F3.AP-202

VII.F2.AP-202

VII.F1.AP-202

VII.C2.AP-202

C2.2-a A-25 VII.H2.AP-202
April 2011 A-51 NUREG-1950

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.F4.AP-202

VII.F3.AP-202

VII.F2.AP-202

VII.F1.AP-202

VII.C2.AP-202

C2.2-a A-52 VII.C2.A-52

C2.3-a A-25

VII.H2.AP-202

VII.F4.AP-202

VII.F3.AP-202

VII.F2.AP-202

VII.F1.AP-202

VII.C2.AP-202

C2.3-a A-50

VII.F3.A-50

VII.C2.A-50

C2.4-a A-25

VII.H2.AP-202

VII.F4.AP-202

VII.F3.AP-202

VII.F2.AP-202

VII.F1.AP-202

VII.C2.AP-202

C2.5-a A-25

VII.H2.AP-202

VII.F4.AP-202

VII.F3.AP-202

VII.F2.AP-202

VII.F1.AP-202

VII.C2.AP-202

C3. A-01

VII.H1.AP-198

VII.G.AP-198

VII.C3.AP-198

VII.C1.AP-198

C3. AP-53

VII.C3.AP-206

VII.C1.AP-206

C3. AP-56

VII.H2.AP-137

VII.H1.AP-137

VII.G.AP-137

VII.C3.AP-137

VII.C1.AP-137

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

C3. A-02

VII.H1.A-02

VII.G.A-02

VII.C3.A-02

VII.C1.A-02

VII.H2.A-02

C3. A-51

VII.H2.A-51

VII.G.A-51

VII.C3.A-51

VII.C1.A-51

C3. AP-61

VII.H2.AP-187

VII.G.AP-187

VII.C3.AP-187

VII.C1.AP-187

C3.1-a A-47

VII.H2.A-47

VII.G.A-47

VII.C3.A-47

VII.C1.A-47

C3.1-a A-43 VII.C3.AP-195

C3.1-a A-38

VII.H2.AP-194

VII.C3.AP-194

VII.C1.AP-194

C3.2-a A-43 VII.C3.AP-195

C3.2-a A-47

VII.H2.A-47

VII.G.A-47

VII.C3.A-47

VII.C1.A-47

C3.2-a A-38

VII.H2.AP-194

VII.C3.AP-194

VII.C1.AP-194

C3.2-a A-53 VII.C3.A-53

C3.3-a A-38

VII.H2.AP-194

VII.C3.AP-194

VII.C1.AP-194

D. AP-81 VII.D.AP-81

D.1-a A-80 VII.D.A-80

D.1-a A-26 VII.D.A-26
NUREG-1950 A-52 April 2011

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

D.2-a A-80 VII.D.A-80

D.2-a A-26 VII.D.A-26

D.2-a A-103 VII.D.AP-121

D.3-a A-80 VII.D.A-80

D.3-a A-26 VII.D.A-26

D.4-a A-26 VII.D.A-26

D.4-a A-80 VII.D.A-80

D.5-a A-26 VII.D.A-26

D.5-a A-80 VII.D.A-80

D.6-a A-26 VII.D.A-26

D.6-a A-80 VII.D.A-80

E1. AP-43

VII.E3.AP-43

VII.E1.AP-43

VII.C2.AP-43

VII.A4.AP-43

VII.A3.AP-43

VII.H2.AP-43

VII.H1.AP-43

VII.F4.AP-43

VII.F3.AP-43

VII.F2.AP-43

VII.F1.AP-43

VII.E4.AP-43

E1. AP-59

VII.H2.AP-138

VII.G.AP-138

VII.E4.AP-138

VII.E1.AP-138

VII.C2.AP-138

VII.C1.AP-138

E1. AP-65

VII.F3.AP-65

VII.F1.AP-65

VII.E1.AP-65

E1. AP-12

VII.H2.AP-199

VII.H1.AP-199

VII.F4.AP-199

VII.F3.AP-199

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.F2.AP-199

VII.F1.AP-199

VII.E4.AP-199

VII.E3.AP-199

VII.E1.AP-199

VII.C2.AP-199

VII.A4.AP-199

VII.A3.AP-199

E1. AP-82 VII.E1.AP-82

E1. AP-47

VII.H2.AP-133

VII.G.AP-133

VII.E4.AP-133

VII.E1.AP-133

VII.C2.AP-133

VII.C1.AP-133

E1. AP-31

VII.G.AP-31

VII.F4.AP-31

VII.F2.AP-31

VII.F1.AP-31

VII.E4.AP-31

VII.E3.AP-31

VII.E1.AP-31

VII.C2.AP-31

VII.A4.AP-31

VII.A3.AP-31

E1. AP-34

VII.F3.AP-203

VII.F1.AP-203

VII.E1.AP-203

E1. AP-30

VII.H2.AP-127

VII.G.AP-127

VII.F4.AP-127

VII.F3.AP-127

VII.F2.AP-127

VII.F1.AP-127

VII.E4.AP-127

VII.E1.AP-127

VII.C2.AP-127

VII.C1.AP-127
April 2011 A-53 NUREG-1950

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

E1. AP-1 

VII.E1.AP-1 

VII.A3.AP-1

E1. AP-85 VII.E1.AP-85

E1. AP-79

VII.E1.AP-79

VII.A3.AP-79

VII.A2.AP-79

E1.10-a A-79

VII.I.A-79

VII.E1.A-79

VII.A3.A-79

E1.1-a A-34

VII.E3.A-34

VII.E1.A-34

E1.1-a A-57 VII.E1.A-57

E1.1-b A-79

VII.I.A-79

VII.E1.A-79

VII.A3.A-79

E1.2-a A-79

VII.I.A-79

VII.E1.A-79

VII.A3.A-79

E1.3-a A-34

VII.E3.A-34

VII.E1.A-34

E1.3-a A-57 VII.E1.A-57

E1.3-b A-79

VII.I.A-79

VII.E1.A-79

VII.A3.A-79

E1.4-a A-79

VII.I.A-79

VII.E1.A-79

VII.A3.A-79

E1.5-a A-104 VII.E1.AP-122

E1.5-a A-76

VII.E1.AP-114

VII.E1.AP-115

E1.5-b A-79

VII.I.A-79

VII.E1.A-79

VII.A3.A-79

E1.6-a A-79

VII.I.A-79

VII.E1.A-79

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.A3.A-79

E1.7-a A-57 VII.E1.A-57

E1.7-a A-34

VII.E3.A-34

VII.E1.A-34

E1.7-b A-79

VII.I.A-79

VII.E1.A-79

VII.A3.A-79

E1.7-c A-84 VII.E1.AP-118

E1.8-a A-57 VII.E1.A-57

E1.8-a A-34

VII.E3.A-34

VII.E1.A-34

E1.8-a A-100 VII.E1.A-100

E1.8-b A-69 VII.E1.A-69

E1.8-c A-63

VII.F4.AP-189

VII.F3.AP-189

VII.F2.AP-189

VII.F1.AP-189

VII.E4.AP-189

VII.E3.AP-189

VII.E1.AP-189

VII.C2.AP-189

VII.A4.AP-189

VII.A3.AP-189

E1.8-d A-79

VII.I.A-79

VII.E1.A-79

VII.A3.A-79

E1.9-a A-79

VII.I.A-79

VII.E1.A-79

VII.A3.A-79

E1.10-a A-79

VII.I.A-79

VII.E1.A-79

VII.A3.A-79

E2. AP-73 VII.E2.AP-141

E2.1-a A-59 VII.E2.AP-181

E2.2-a A-59 VII.E2.AP-181
NUREG-1950 A-54 April 2011

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

E2.3-a A-59 VII.E2.AP-181 

E2.4-a A-59 VII.E2.AP-181

E3. A-63

VII.F4.AP-189

VII.F3.AP-189

VII.F2.AP-189

VII.F1.AP-189

VII.E4.AP-189

VII.E3.AP-189

VII.E1.AP-189

VII.C2.AP-189

VII.A4.AP-189

VII.A3.AP-189

E3. A-58

VII.E4.AP-110

VII.E3.AP-110

VII.A4.AP-110

E3. AP-43

VII.E3.AP-43

VII.E1.AP-43

VII.C2.AP-43

VII.A4.AP-43

VII.A3.AP-43

VII.H2.AP-43

VII.H1.AP-43

VII.F4.AP-43

VII.F3.AP-43

VII.F2.AP-43

VII.F1.AP-43

VII.E4.AP-43

E3. AP-12

VII.H2.AP-199

VII.H1.AP-199

VII.F4.AP-199

VII.F3.AP-199

VII.F2.AP-199

VII.F1.AP-199

VII.E4.AP-199

VII.E3.AP-199

VII.E1.AP-199

VII.C2.AP-199

VII.A4.AP-199

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.A3.AP-199

E3. AP-32

VII.E4.AP-32

VII.E3.AP-32

VII.C2.AP-32

VII.A4.AP-32

E3. AP-31

VII.G.AP-31

VII.F4.AP-31

VII.F2.AP-31

VII.F1.AP-31

VII.E4.AP-31

VII.E3.AP-31

VII.E1.AP-31

VII.C2.AP-31

VII.A4.AP-31

VII.A3.AP-31

E3. AP-38

VII.E4.AP-130

VII.E3.AP-130

VII.A4.AP-130

E3. AP-60

VII.E4.AP-186

VII.E3.AP-186

VII.C2.AP-186

E3. A-35

VII.E4.AP-106

VII.E3.AP-106

E3. AP-63

VII.E4.AP-188

VII.E3.AP-188

VII.C2.AP-188

E3. AP-64

VII.E4.AP-140

VII.E3.AP-140

VII.A4.AP-140

E3. AP-62

VII.E3.AP-139

VII.A4.AP-139

E3.1-a A-60 VII.E3.AP-283

E3.1-b A-62

VII.E4.A-62

VII.E3.A-62

E3.2-a A-60 VII.E3.AP-283

E3.2-b A-62 VII.E4.A-62
April 2011 A-55 NUREG-1950

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.E3.A-62

E3.2-c A-34

VII.E3.A-34

VII.E1.A-34

E3.3-d A-85 VII.E3.AP-120

E3.4-a A-68 VII.E3.AP-192

E3.4-a A-71 VII.E3.AP-112

E3.4-b A-67

VII.E4.AP-191

VII.E3.AP-191

E4. AP-59

VII.H2.AP-138

VII.G.AP-138

VII.E4.AP-138

VII.E1.AP-138

VII.C2.AP-138

VII.C1.AP-138

E4. AP-43

VII.E3.AP-43

VII.E1.AP-43

VII.C2.AP-43

VII.A4.AP-43

VII.A3.AP-43

VII.H2.AP-43

VII.H1.AP-43

VII.F4.AP-43

VII.F3.AP-43

VII.F2.AP-43

VII.F1.AP-43

VII.E4.AP-43

E4. AP-38

VII.E4.AP-130

VII.E3.AP-130

VII.A4.AP-130

E4. AP-31

VII.G.AP-31

VII.F4.AP-31

VII.F2.AP-31

VII.F1.AP-31

VII.E4.AP-31

VII.E3.AP-31

VII.E1.AP-31

VII.C2.AP-31

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.A4.AP-31

VII.A3.AP-31

E4. AP-64

VII.E4.AP-140

VII.E3.AP-140

VII.A4.AP-140

E4. AP-63

VII.E4.AP-188

VII.E3.AP-188

VII.C2.AP-188

E4. AP-47

VII.H2.AP-133

VII.G.AP-133

VII.E4.AP-133

VII.E1.AP-133

VII.C2.AP-133

VII.C1.AP-133

E4. AP-32

VII.E4.AP-32

VII.E3.AP-32

VII.C2.AP-32

VII.A4.AP-32

E4. AP-30

VII.H2.AP-127

VII.G.AP-127

VII.F4.AP-127

VII.F3.AP-127

VII.F2.AP-127

VII.F1.AP-127

VII.E4.AP-127

VII.E1.AP-127

VII.C2.AP-127

VII.C1.AP-127

E4. AP-12

VII.H2.AP-199

VII.H1.AP-199

VII.F4.AP-199

VII.F3.AP-199

VII.F2.AP-199

VII.F1.AP-199

VII.E4.AP-199

VII.E3.AP-199

VII.E1.AP-199

VII.C2.AP-199
NUREG-1950 A-56 April 2011

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.A4.AP-199

VII.A3.AP-199

E4. AP-60

VII.E4.AP-186

VII.E3.AP-186

VII.C2.AP-186

E4.1-a A-35

VII.E4.AP-106

VII.E3.AP-106

E4.1-a A-58

VII.E4.AP-110

VII.E3.AP-110

VII.A4.AP-110

E4.1-b A-62

VII.E4.A-62

VII.E3.A-62

E4.1-c A-61 VII.E4.A-61

E4.2-a A-35

VII.E4.AP-106

VII.E3.AP-106

E4.3-a A-61 VII.E4.A-61

E4.4-a A-67

VII.E4.AP-191

VII.E3.AP-191

E4.4-a A-63

VII.F4.AP-189

VII.F3.AP-189

VII.F2.AP-189

VII.F1.AP-189

VII.E4.AP-189

VII.E3.AP-189

VII.E1.AP-189

VII.C2.AP-189

VII.A4.AP-189

VII.A3.AP-189

F1. AP-43

VII.E3.AP-43

VII.E1.AP-43

VII.C2.AP-43

VII.A4.AP-43

VII.A3.AP-43

VII.H2.AP-43

VII.H1.AP-43

VII.F4.AP-43

VII.F3.AP-43

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.F2.AP-43

VII.F1.AP-43

VII.E4.AP-43

F1. AP-12

VII.H2.AP-199

VII.H1.AP-199

VII.F4.AP-199

VII.F3.AP-199

VII.F2.AP-199

VII.F1.AP-199

VII.E4.AP-199

VII.E3.AP-199

VII.E1.AP-199

VII.C2.AP-199

VII.A4.AP-199

VII.A3.AP-199

F1. AP-65

VII.F3.AP-65

VII.F1.AP-65

VII.E1.AP-65

F1. AP-34

VII.F3.AP-203

VII.F1.AP-203

VII.E1.AP-203

F1. AP-80

VII.F3.AP-205

VII.F2.AP-205

VII.F1.AP-205

VII.C2.AP-205

F1. AP-77

VII.F4.AP-204

VII.F3.AP-204

VII.F2.AP-204

VII.F1.AP-204

F1. AP-30

VII.H2.AP-127

VII.G.AP-127

VII.F4.AP-127

VII.F3.AP-127

VII.F2.AP-127

VII.F1.AP-127

VII.E4.AP-127

VII.E1.AP-127

VII.C2.AP-127
April 2011 A-57 NUREG-1950

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.C1.AP-127

F1. AP-74

VII.F4.AP-142

VII.F3.AP-142

VII.F2.AP-142

VII.F1.AP-142

F1. A-63

VII.F4.AP-189

VII.F3.AP-189

VII.F2.AP-189

VII.F1.AP-189

VII.E4.AP-189

VII.E3.AP-189

VII.E1.AP-189

VII.C2.AP-189

VII.A4.AP-189

VII.A3.AP-189

F1. AP-31

VII.G.AP-31

VII.F4.AP-31

VII.F2.AP-31

VII.F1.AP-31

VII.E4.AP-31

VII.E3.AP-31

VII.E1.AP-31

VII.C2.AP-31

VII.A4.AP-31

VII.A3.AP-31

F1. AP-41

VII.F2.AP-41

VII.H2.AP-41

VII.G.AP-41

VII.F4.AP-41

VII.F3.AP-41

VII.F1.AP-41

F1.1-a A-105

VII.I.A-105

VII.F4.A-105

VII.F3.A-105

VII.F2.A-105

VII.F1.A-105

F1.1-a A-08

VII.F4.A-08

VII.F3.A-08

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.F2.A-08

VII.F1.A-08

F1.1-a A-10

VII.F4.A-10

VII.F3.A-10

VII.F2.A-10

VII.F1.A-10

F1.1-b A-17

VII.F4.AP-102

VII.F3.AP-102

VII.F2.AP-102

VII.F1.AP-102

F1.1-c A-18

VII.F4.AP-103

VII.F3.AP-103

VII.F2.AP-103

VII.F1.AP-103

F1.1-c A-73

VII.F4.AP-113

VII.F3.AP-113

VII.F2.AP-113

VII.F1.AP-113

F1.2-a A-46

VII.F4.AP-109

VII.F3.AP-109

VII.F2.AP-109

VII.F1.AP-109

F1.3-a A-25

VII.H2.AP-202

VII.F4.AP-202

VII.F3.AP-202

VII.F2.AP-202

VII.F1.AP-202 

VII.C2.AP-202

F1.4-a A-09

VII.F3.AP-99

VII.F2.AP-99

VII.F1.AP-99

F1.4-a A-08

VII.F4.A-08

VII.F3.A-08

VII.F2.A-08

VII.F1.A-08

F1.4-a A-10

VII.F4.A-10

VII.F3.A-10
NUREG-1950 A-58 April 2011

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.F2.A-10

VII.F1.A-10

F1.4-b A-17

VII.F4.AP-102

VII.F3.AP-102

VII.F2.AP-102

VII.F1.AP-102

F2. AP-12

VII.H2.AP-199

VII.H1.AP-199

VII.F4.AP-199

VII.F3.AP-199

VII.F2.AP-199

VII.F1.AP-199

VII.E4.AP-199

VII.E3.AP-199

VII.E1.AP-199

VII.C2.AP-199

VII.A4.AP-199

VII.A3.AP-199

F2. AP-77

VII.F4.AP-204

VII.F3.AP-204

VII.F2.AP-204

VII.F1.AP-204

F2. AP-30

VII.H2.AP-127

VII.G.AP-127

VII.F4.AP-127

VII.F3.AP-127

VII.F2.AP-127

VII.F1.AP-127

VII.E4.AP-127

VII.E1.AP-127

VII.C2.AP-127

VII.C1.AP-127

F2. AP-43

VII.E3.AP-43

VII.E1.AP-43

VII.C2.AP-43

VII.A4.AP-43

VII.A3.AP-43

VII.H2.AP-43

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.H1.AP-43

VII.F4.AP-43 

VII.F3.AP-43

VII.F2.AP-43

VII.F1.AP-43

VII.E4.AP-43

F2. AP-80

VII.F3.AP-205

VII.F2.AP-205

VII.F1.AP-205

VII.C2.AP-205

F2. A-63

VII.F4.AP-189

VII.F3.AP-189

VII.F2.AP-189

VII.F1.AP-189

VII.E4.AP-189

VII.E3.AP-189

VII.E1.AP-189

VII.C2.AP-189

VII.A4.AP-189

VII.A3.AP-189

F2. AP-74

VII.F4.AP-142

VII.F3.AP-142

VII.F2.AP-142

VII.F1.AP-142

F2. AP-41

VII.F2.AP-41

VII.H2.AP-41

VII.G.AP-41

VII.F4.AP-41

VII.F3.AP-41

VII.F1.AP-41

F2. AP-31

VII.G.AP-31

VII.F4.AP-31

VII.F2.AP-31

VII.F1.AP-31

VII.E4.AP-31

VII.E3.AP-31 

VII.E1.AP-31

VII.C2.AP-31
April 2011 A-59 NUREG-1950

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.A4.AP-31

VII.A3.AP-31

F2.1-a A-10

VII.F4.A-10

VII.F3.A-10

VII.F2.A-10

VII.F1.A-10

F2.1-a A-08

VII.F4.A-08

VII.F3.A-08

VII.F2.A-08

VII.F1.A-08

F2.1-a A-105

VII.I.A-105

VII.F4.A-105

VII.F3.A-105

VII.F2.A-105

VII.F1.A-105

F2.1-b A-17

VII.F4.AP-102

VII.F3.AP-102

VII.F2.AP-102

VII.F1.AP-102

F2.1-c A-18

VII.F4.AP-103

VII.F3.AP-103

VII.F2.AP-103

VII.F1.AP-103

F2.1-c A-73

VII.F4.AP-113

VII.F3.AP-113

VII.F2.AP-113

VII.F1.AP-113

F2.2-a A-46

VII.F4.AP-109

VII.F3.AP-109

VII.F2.AP-109

VII.F1.AP-109

F2.3-a A-25

VII.H2.AP-202

VII.F4.AP-202

VII.F3.AP-202

VII.F2.AP-202

VII.F1.AP-202

VII.C2.AP-202

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

F2.4-a A-08

VII.F4.A-08

VII.F3.A-08

VII.F2.A-08

VII.F1.A-08

F2.4-a A-09

VII.F3.AP-99

VII.F2.AP-99

VII.F1.AP-99

F2.4-a A-10

VII.F4.A-10

VII.F3.A-10

VII.F2.A-10

VII.F1.A-10

F2.4-b A-17

VII.F4.AP-102

VII.F3.AP-102

VII.F2.AP-102

VII.F1.AP-102

F3. AP-30

VII.H2.AP-127

VII.G.AP-127

VII.F4.AP-127

VII.F3.AP-127

VII.F2.AP-127

VII.F1.AP-127

VII.E4.AP-127

VII.E1.AP-127

VII.C2.AP-127

VII.C1.AP-127

F3. AP-41

VII.F2.AP-41

VII.H2.AP-41

VII.G.AP-41

VII.F4.AP-41

VII.F3.AP-41

VII.F1.AP-41

F3. AP-34

VII.F3.AP-203

VII.F1.AP-203

VII.E1.AP-203

F3. A-50

VII.F3.A-50

VII.C2.A-50

F3. AP-80 VII.F3.AP-205
NUREG-1950 A-60 April 2011

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.F2.AP-205

VII.F1.AP-205

VII.C2.AP-205

F3. AP-74

VII.F4.AP-142

VII.F3.AP-142

VII.F2.AP-142

VII.F1.AP-142

F3. A-63

VII.F4.AP-189

VII.F3.AP-189

VII.F2.AP-189

VII.F1.AP-189

VII.E4.AP-189

VII.E3.AP-189

VII.E1.AP-189

VII.C2.AP-189

VII.A4.AP-189

VII.A3.AP-189

F3. AP-12

VII.H2.AP-199

VII.H1.AP-199

VII.F4.AP-199

VII.F3.AP-199

VII.F2.AP-199

VII.F1.AP-199

VII.E4.AP-199

VII.E3.AP-199

VII.E1.AP-199

VII.C2.AP-199

VII.A4.AP-199

VII.A3.AP-199

F3. AP-65

VII.F3.AP-65

VII.F1.AP-65

VII.E1.AP-65

F3. AP-77

VII.F4.AP-204

VII.F3.AP-204

VII.F2.AP-204

VII.F1.AP-204

F3. AP-43

VII.E3.AP-43

VII.E1.AP-43

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.C2.AP-43

VII.A4.AP-43

VII.A3.AP-43

VII.H2.AP-43

VII.H1.AP-43

VII.F4.AP-43

VII.F3.AP-43

VII.F2.AP-43

VII.F1.AP-43

VII.E4.AP-43

F3.1-a A-08

VII.F4.A-08

VII.F3.A-08

VII.F2.A-08

VII.F1.A-08

F3.1-a A-10

VII.F4.A-10

VII.F3.A-10

VII.F2.A-10

VII.F1.A-10

F3.1-a A-105

VII.I.A-105

VII.F4.A-105

VII.F3.A-105

VII.F2.A-105

VII.F1.A-105

F3.1-b A-17

VII.F4.AP-102

VII.F3.AP-102

VII.F2.AP-102

VII.F1.AP-102

F3.1-c A-18

VII.F4.AP-103

VII.F3.AP-103

VII.F2.AP-103

VII.F1.AP-103

F3.1-c A-73

VII.F4.AP-113

VII.F3.AP-113

VII.F2.AP-113

VII.F1.AP-113

F3.2-a A-46

VII.F4.AP-109

VII.F3.AP-109
April 2011 A-61 NUREG-1950

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.F2.AP-109

VII.F1.AP-109

F3.3-a A-25

VII.H2.AP-202

VII.F4.AP-202

VII.F3.AP-202

VII.F2.AP-202

VII.F1.AP-202

VII.C2.AP-202

F3.4-a A-08

VII.F4.A-08

VII.F3.A-08

VII.F2.A-08

VII.F1.A-08

F3.4-a A-09

VII.F3.AP-99

VII.F2.AP-99

VII.F1.AP-99

F3.4-a A-10

VII.F4.A-10

VII.F3.A-10

VII.F2.A-10

VII.F1.A-10

F3.4-b A-17

VII.F4.AP-102

VII.F3.AP-102

VII.F2.AP-102

VII.F1.AP-102

F4. AP-41

VII.F2.AP-41

VII.H2.AP-41

VII.G.AP-41

VII.F4.AP-41

VII.F3.AP-41

VII.F1.AP-41

F4. A-63

VII.F4.AP-189

VII.F3.AP-189

VII.F2.AP-189

VII.F1.AP-189

VII.E4.AP-189

VII.E3.AP-189

VII.E1.AP-189

VII.C2.AP-189

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.A4.AP-189

VII.A3.AP-189

F4. AP-12

VII.H2.AP-199

VII.H1.AP-199

VII.F4.AP-199

VII.F3.AP-199

VII.F2.AP-199

VII.F1.AP-199

VII.E4.AP-199

VII.E3.AP-199

VII.E1.AP-199

VII.C2.AP-199

VII.A4.AP-199

VII.A3.AP-199

F4. AP-31

VII.G.AP-31

VII.F4.AP-31

VII.F2.AP-31

VII.F1.AP-31

VII.E4.AP-31

VII.E3.AP-31

VII.E1.AP-31

VII.C2.AP-31

VII.A4.AP-31

VII.A3.AP-31

F4. AP-74

VII.F4.AP-142

VII.F3.AP-142

VII.F2.AP-142

VII.F1.AP-142

F4. AP-77

VII.F4.AP-204

VII.F3.AP-204

VII.F2.AP-204

VII.F1.AP-204

F4. AP-43

VII.E3.AP-43

VII.E1.AP-43

VII.C2.AP-43

VII.A4.AP-43

VII.A3.AP-43

VII.H2.AP-43
NUREG-1950 A-62 April 2011

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.H1.AP-43

VII.F4.AP-43

VII.F3.AP-43

VII.F2.AP-43

VII.F1.AP-43

VII.E4.AP-43

F4. AP-30

VII.H2.AP-127

VII.G.AP-127

VII.F4.AP-127

VII.F3.AP-127

VII.F2.AP-127

VII.F1.AP-127

VII.E4.AP-127

VII.E1.AP-127

VII.C2.AP-127

VII.C1.AP-127

F4.1-a A-08

VII.F4.A-08

VII.F3.A-08

VII.F2.A-08

VII.F1.A-08

F4.1-a A-10

VII.F4.A-10

VII.F3.A-10

VII.F2.A-10

VII.F1.A-10

F4.1-a A-105

VII.I.A-105

VII.F4.A-105

VII.F3.A-105

VII.F2.A-105

VII.F1.A-105

F4.1-b A-17

VII.F4.AP-102

VII.F3.AP-102

VII.F2.AP-102

VII.F1.AP-102

F4.1-c A-18

VII.F4.AP-103

VII.F3.AP-103

VII.F2.AP-103

VII.F1.AP-103

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

F4.1-c A-73

VII.F4.AP-113

VII.F3.AP-113

VII.F2.AP-113

VII.F1.AP-113

F4.2-a A-46

VII.F4.AP-109

VII.F3.AP-109

VII.F2.AP-109

VII.F1.AP-109

F4.3-a A-25

VII.H2.AP-202

VII.F4.AP-202

VII.F3.AP-202

VII.F2.AP-202

VII.F1.AP-202

VII.C2.AP-202

G. AP-83 VII.G.AP-180

G. AP-44

VII.H2.AP-132

VII.H1.AP-132

VII.G.AP-132

G. AP-56

VII.H2.AP-137

VII.H1.AP-137

VII.G.AP-137

VII.C3.AP-137

VII.C1.AP-137

G. AP-78 VII.G.AP-143

G. AP-40

VII.H2.AP-40

VII.G.AP-40

G. AP-54

VII.H2.AP-136

VII.H1.AP-136

VII.G.AP-136

G. AP-41

VII.F2.AP-41

VII.H2.AP-41

VII.G.AP-41

VII.F4.AP-41

VII.F3.AP-41

VII.F1.AP-41

G. A-51

VII.H2.A-51

VII.G.A-51
April 2011 A-63 NUREG-1950

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.C3.A-51

VII.C1.A-51

G. A-23

VII.H2.A-23

VII.G.A-23

G. AP-31

VII.G.AP-31

VII.F4.AP-31

VII.F2.AP-31

VII.F1.AP-31

VII.E4.AP-31

VII.E3.AP-31

VII.E1.AP-31

VII.C2.AP-31

VII.A4.AP-31

VII.A3.AP-31

G. AP-30

VII.H2.AP-127

VII.G.AP-127

VII.F4.AP-127

VII.F3.AP-127

VII.F2.AP-127

VII.F1.AP-127

VII.E4.AP-127

VII.E1.AP-127

VII.C2.AP-127

VII.C1.AP-127

G. AP-61

VII.H2.AP-187

VII.G.AP-187

VII.C3.AP-187

VII.C1.AP-187

G. AP-59

VII.H2.AP-138

VII.G.AP-138

VII.E4.AP-138

VII.E1.AP-138

VII.C2.AP-138

VII.C1.AP-138

G. A-02

VII.H1.A-02

VII.G.A-02

VII.C3.A-02

VII.C1.A-02

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.H2.A-02

G. A-01

VII.H1.AP-198

VII.G.AP-198

VII.C3.AP-198

VII.C1.AP-198

G. AP-47

VII.H2.AP-133 

VII.G.AP-133

VII.E4.AP-133

VII.E1.AP-133

VII.C2.AP-133

VII.C1.AP-133

G.1-a A-19 VII.G.A-19

G.1-a A-20 VII.G.A-20

G.1-b A-92 VII.G.A-92

G.1-b A-90 VII.G.A-90

G.1-c A-93 VII.G.A-93

G.1-c A-91 VII.G.A-91

G.1-d A-22 VII.G.A-22

G.1-d A-21 VII.G.A-21

G.2-a A-19 VII.G.A-19

G.2-a A-20 VII.G.A-20

G.2-b A-90 VII.G.A-90

G.2-b A-92 VII.G.A-92

G.2-c A-93 VII.G.A-93

G.2-c A-91 VII.G.A-91

G.2-d A-21 VII.G.A-21

G.2-d A-22 VII.G.A-22

G.3-a A-20 VII.G.A-20

G.3-a A-19 VII.G.A-19

G.3-b A-92 VII.G.A-92

G.3-b A-90 VII.G.A-90

G.3-c A-91 VII.G.A-91

G.3-c A-93 VII.G.A-93
NUREG-1950 A-64 April 2011

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

G.3-d A-22 VII.G.A-22

G.3-d A-21 VII.G.A-21

G.4-a A-20 VII.G.A-20

G.4-a A-19 VII.G.A-19

G.4-b A-90 VII.G.A-90

G.4-b A-92 VII.G.A-92

G.4-c A-91 VII.G.A-91

G.4-c A-93 VII.G.A-93

G.4-d A-22 VII.G.A-22

G.4-d A-21 VII.G.A-21

G.5-a A-90 VII.G.A-90

G.5-b A-91 VII.G.A-91

G.5-c A-21 VII.G.A-21

G.6-a A-55 VII.G.A-55

G.6-a A-33 VII.G.A-33

G.6-b A-45 VII.G.AP-197

G.6-b A-33 VII.G.A-33

G.6-b A-55 VII.G.A-55

G.6-b A-47

VII.H2.A-47

VII.G.A-47

VII.C3.A-47

VII.C1.A-47

G.7-a A-82 VII.G.AP-116

G.7-b A-83 VII.G.AP-117

G.8-a A-28 VII.G.AP-234

H1. AP-56

VII.H2.AP-137

VII.H1.AP-137

VII.G.AP-137

VII.C3.AP-137

VII.C1.AP-137

H1. AP-54

VII.H2.AP-136

VII.H1.AP-136

VII.G.AP-136

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

H1. AP-35

VII.H2.AP-129

VII.H1.AP-129

H1. AP-44

VII.H2.AP-132

VII.H1.AP-132

VII.G.AP-132

H1. AP-43

VII.E3.AP-43

VII.E1.AP-43

VII.C2.AP-43

VII.A4.AP-43

VII.A3.AP-43

VII.H2.AP-43

VII.H1.AP-43

VII.F4.AP-43

VII.F3.AP-43

VII.F2.AP-43

VII.F1.AP-43

VII.E4.AP-43

H1. A-02

VII.H1.A-02

VII.G.A-02

VII.C3.A-02

VII.C1.A-02

VII.H2.A-02

H1. AP-12

VII.H2.AP-199

VII.H1.AP-199

VII.F4.AP-199

VII.F3.AP-199

VII.F2.AP-199

VII.F1.AP-199

VII.E4.AP-199

VII.E3.AP-199

VII.E1.AP-199

VII.C2.AP-199

VII.A4.AP-199

VII.A3.AP-199

H1.1-a A-24 VII.H1.A-24

H1.1-b A-01

VII.H1.AP-198

VII.G.AP-198
April 2011 A-65 NUREG-1950

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.C3.AP-198

VII.C1.AP-198

H1.2-a A-24 VII.H1.A-24

H1.3-a A-24 VII.H1.A-24

H1.4-a A-30

VII.H2.AP-105

VII.H1.AP-105

H1.4-b A-95 VII.H1.A-95

H2. AP-55 VII.H2.AP-55

H2. AP-59

VII.H2.AP-138

VII.G.AP-138

VII.E4.AP-138 

VII.E1.AP-138

VII.C2.AP-138

VII.C1.AP-138

H2. AP-61

VII.H2.AP-187

VII.G.AP-187

VII.C3.AP-187

VII.C1.AP-187

H2. AP-39 VII.H2.AP-131

H2. AP-40

VII.H2.AP-40

VII.G.AP-40

H2. A-47

VII.H2.A-47

VII.G.A-47

VII.C3.A-47

VII.C1.A-47

H2. A-02

VII.H1.A-02

VII.G.A-02

VII.C3.A-02

VII.C1.A-02

VII.H2.A-02

H2. AP-47

VII.H2.AP-133

VII.G.AP-133

VII.E4.AP-133

VII.E1.AP-133

VII.C2.AP-133

VII.C1.AP-133

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

H2. AP-56

VII.H2.AP-137

VII.H1.AP-137

VII.G.AP-137

VII.C3.AP-137

VII.C1.AP-137

H2. AP-12

VII.H2.AP-199

VII.H1.AP-199

VII.F4.AP-199

VII.F3.AP-199

VII.F2.AP-199

VII.F1.AP-199

VII.E4.AP-199

VII.E3.AP-199

VII.E1.AP-199

VII.C2.AP-199

VII.A4.AP-199

VII.A3.AP-199

H2. AP-33 VII.H2.AP-128

H2. AP-54

VII.H2.AP-136

VII.H1.AP-136

VII.G.AP-136

H2. AP-30

VII.H2.AP-127

VII.G.AP-127

VII.F4.AP-127

VII.F3.AP-127

VII.F2.AP-127

VII.F1.AP-127

VII.E4.AP-127

VII.E1.AP-127

VII.C2.AP-127

VII.C1.AP-127

H2. A-51

VII.H2.A-51

VII.G.A-51

VII.C3.A-51

VII.C1.A-51

H2. AP-35

VII.H2.AP-129

VII.H1.AP-129
NUREG-1950 A-66 April 2011

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

H2. AP-43

VII.E3.AP-43

VII.E1.AP-43

VII.C2.AP-43

VII.A4.AP-43

VII.A3.AP-43

VII.H2.AP-43

VII.H1.AP-43

VII.F4.AP-43

VII.F3.AP-43

VII.F2.AP-43

VII.F1.AP-43

VII.E4.AP-43

H2. AP-44

VII.H2.AP-132

VII.H1.AP-132

VII.G.AP-132

H2. AP-41

VII.F2.AP-41

VII.H2.AP-41

VII.G.AP-41

VII.F4.AP-41

VII.F3.AP-41

VII.F1.AP-41

H2. AP-45 VII.H2.AP-193

H2.1-a A-25

VII.H2.AP-202

VII.F4.AP-202

VII.F3.AP-202

VII.F2.AP-202

VII.F1.AP-202

VII.C2.AP-202

H2.1-b A-38

VII.H2.AP-194

VII.C3.AP-194

VII.C1.AP-194

H2.2-a A-23

VII.H2.A-23

VII.G.A-23

H2.3-a A-23

VII.H2.A-23

VII.G.A-23

H2.4-a A-27 VII.H2.AP-104

H2.5-a A-30 VII.H2.AP-105

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

VII.H1.AP-105

I. AP-66 VII.I.AP-66

I. AP-26 VII.I.AP-124

I. AP-27 VII.I.AP-125

I. A-105

VII.I.A-105

VII.F4.A-105

VII.F3.A-105

VII.F2.A-105

VII.F1.A-105

I. AP-28 VII.I.AP-126

I. A-102 VII.I.A-102

I.1-a A-79

VII.I.A-79

VII.E1.A-79

VII.A3.A-79

I.1-b A-77 VII.I.A-77

I.1-b A-78 VII.I.A-78

I.1-b A-81 VII.I.A-81

I.2-a A-03 VII.I.A-03

I.2-b A-04 VII.I.A-04

J. AP-51 VII.J.AP-51

J. AP-22 VII.J.AP-22

J. AP-15 VII.J.AP-15

J. AP-13 VII.J.AP-13

J. AP-50 VII.J.AP-50

J. AP-9 VII.J.AP-9 

J. AP-2 VII.J.AP-2 

J. AP-18 VII.J.AP-18

J. AP-17 VII.J.AP-17

J. AP-20 VII.J.AP-20

J. AP-48 VII.J.AP-48

J. AP-19 VII.J.AP-19

J. AP-3 VII.J.AP-282

J. AP-37 VII.J.AP-37
April 2011 A-67 NUREG-1950

Table A-6. Relationship of Auxiliary 

System IDs in GALL Report, Chpt. 

VII

Rev. 0 Rev. 1 Rev. 2

J. AP-36 VII.J.AP-36

J. AP-52 VII.J.AP-52

J. AP-6 VII.J.AP-6 

J. AP-8 VII.J.AP-8 

J. AP-11 VII.J.AP-11

J. AP-49 VII.J.AP-49

J. AP-16 VII.J.AP-16

J. AP-4 VII.J.AP-4 

J. AP-14 VII.J.AP-14
NUREG-1950 A-68 April 2011

Table A-7. Relationship of Steam 

and Power Conversion (SPC) 

System IDs in GALL Report, Chpt 

VIII

Rev. 0 Rev. 1 Rev. 2

None None VIII.I.SP-104

None None VIII.I.SP-108

None None VIII.BI.SP-110

VIII.B2.SP-110

None None VIII.I.SP-111

None None VIII.G.SP-113

None None VIII.G.SP-114

None None VIII.E.SP-115

None None VIII.G.SP-116

None None

VIII.A.SP-118

VIII.B1.SP-118

VIII.B2.SP-118

VIII.C.SP-118

VIII.D1.SP-118

VIII.D2.SP-118

VIII.E.SP-118

VIII.F.SP-118

VIII.G.SP-118

None None

VIII.A.SP-127

VIII.B1.SP-127

VIII.B2.SP-127

VIII.C.SP-127

VIII.D1.SP-127

VIII.D2.SP-127

VIII.E.SP-127

VIII.F.SP-127

VIII.G.SP-127

None None VIII.E.SP-137

None None VIII.E.SP-138

None None VIII.E.SP-139

None None VIII.E.SP-140

None None VIII.H.SP-141

None None VIII.H.SP-142

None None VIII.H.SP-143

Table A-7. Relationship of Steam 

and Power Conversion (SPC) 

System IDs in GALL Report, Chpt 

VIII

Rev. 0 Rev. 1 Rev. 2

None None VIII.H.SP-144

None None VIII.H.SP-147

VIII.I.SP-148

None None VIII.H.SP-149

None None VIII.H.SP-150

None None VIII.H.SP-151

None None VIII.I.SP-152

None None VIII.I.SP-153

None None VIII.I.SP-67

None None VIII.I.SP-68

None None VIII.I.SP-69

None None VIII.I.SP-70

None None VIII.I.SP-86

None None VIII.I.SP-93

None None VIII.H.SP-161

A. SP-25

VIII.G.SP-91

VIII.E.SP-91

VIII.D2.SP-91

VIII.D1.SP-91

VIII.A.SP-91

A. SP-30

VIII.A.SP-30

VIII.G.SP-30

VIII.F.SP-30

VIII.E.SP-30

A. SP-46 Retired

A. S-23

VIII.G.S-23

VIII.F.S-23

VIII.E.S-23

VIII.A.S-23

A. SP-45

VIII.B2.SP-98

VIII.A.SP-98

A. SP-44 VIII.B1.SP-98

A. SP-32 VIII.G.SP-92
April 2011 A-69 NUREG-1950

Table A-7. Relationship of Steam 

and Power Conversion (SPC) 

System IDs in GALL Report, Chpt 

VIII

Rev. 0 Rev. 1 Rev. 2

VIII.E.SP-92

VIII.D2.SP-92

VIII.D1.SP-92

VIII.A.SP-92

A. SP-38

VIII.G.SP-95

VIII.E.SP-95

VIII.D2.SP-95

VIII.D1.SP-95

VIII.A.SP-95

A. SP-64

VIII.G.SP-64

VIII.F.SP-64

VIII.E.SP-64

VIII.A.SP-64

A. SP-27

VIII.G.SP-27

VIII.F.SP-27

VIII.E.SP-27

VIII.A.SP-27

A. SP-31

VIII.G.SP-31

VIII.F.SP-31

VIII.E.SP-31

VIII.A.SP-31

A. SP-28

VIII.G.SP-28

VIII.A.SP-28

A. SP-43

VIII.B1.SP-155

VIII.A.SP-155

A. SP-61

VIII.F.SP-101

VIII.A.SP-101

A.1-a S-15

VIII.C.S-15

VIII.B2.S-15

VIII.B1.S-15

VIII.A.S-15

A.1-b S-04

VIII.C.SP-71

VIII.A.SP-71

A.1-b S-06 Retired

A.2-a S-15

VIII.C.S-15

VIII.B2.S-15

Table A-7. Relationship of Steam 

and Power Conversion (SPC) 

System IDs in GALL Report, Chpt 

VIII

Rev. 0 Rev. 1 Rev. 2

VIII.B1.S-15

VIII.A.S-15

A.2-b S-04

VIII.C.SP-71

VIII.A.SP-71

A.2-b S-06 Retired

B1. SP-43

VIII.B1.SP-155

VIII.A.SP-155

B1. SP-59 VIII.B1.SP-59

B1. SP-17

VIII.G.SP-88

VIII.F.SP-88

VIII.E.SP-88

VIII.D1.SP-88

VIII.C.SP-88

VIII.B1.SP-88

B1. SP-44 VIII.B1.SP-98

B1. SP-16

VIII.G.SP-87

VIII.F.SP-87

VIII.E.SP-87

VIII.D2.SP-87

VIII.D1.SP-87

VIII.C.SP-87

VIII.B1.SP-87

B1. S-10

VIII.G.SP-74

VIII.F.SP-74

VIII.D1.SP-74

VIII.B1.SP-74

B1. SP-18 VIII.B1.SP-157

B1. SP-60

VIII.G.SP-60

VIII.B1.SP-60

B1.1-a S-07 VIII.B1.SP-71

B1.1-b S-08

VIII.B2.S-08

VIII.B1.S-08

B1.1-c S-15

VIII.C.S-15

VIII.B2.S-15

VIII.B1.S-15
NUREG-1950 A-70 April 2011

Table A-7. Relationship of Steam 

and Power Conversion (SPC) 

System IDs in GALL Report, Chpt 

VIII

Rev. 0 Rev. 1 Rev. 2

VIII.A.S-15

B1.2-a S-07 VIII.B1.SP-71

B1.2-b S-15

VIII.C.S-15

VIII.B2.S-15

VIII.B1.S-15

VIII.A.S-15

B2. SP-45

VIII.B2.SP-98

VIII.A.SP-98

B2. SP-46 Retired

B2. S-09

VIII.E.SP-73

VIII.D2.SP-73

VIII.C.SP-73

VIII.B2.SP-73

B2.1-a S-05 VIII.B2.SP-160

B2.1-b S-15

VIII.C.S-15

VIII.B2.S-15

VIII.B1.S-15

VIII.A.S-15

B2.1-c S-08

VIII.B2.S-08

VIII.B1.S-08

B2.2-a S-15

VIII.C.S-15

VIII.B2.S-15

VIII.B1.S-15

VIII.A.S-15

B2.2-b S-05 VIII.B2.SP-160

C. S-10

VIII.G.SP-74

VIII.F.SP-74

VIII.D1.SP-74

VIII.B1.SP-74

C. S-09

VIII.E.SP-73

VIII.D2.SP-73

VIII.C.SP-73

VIII.B2.SP-73

C. SP-16

VIII.G.SP-87

VIII.F.SP-87

Table A-7. Relationship of Steam 

and Power Conversion (SPC) 

System IDs in GALL Report, Chpt 

VIII

Rev. 0 Rev. 1 Rev. 2

VIII.E.SP-87

VIII.D2.SP-87

VIII.D1.SP-87

VIII.C.SP-87

VIII.B1.SP-87

C. SP-17

VIII.G.SP-88

VIII.F.SP-88

VIII.E.SP-88

VIII.D1.SP-88

VIII.C.SP-88

VIII.B1.SP-88

C.1-a S-15

VIII.C.S-15

VIII.B2.S-15

VIII.B1.S-15

VIII.A.S-15

C.1-b S-04

VIII.C.SP-71

VIII.A.SP-71

C.1-b S-06 Retired

C.2-a S-15

VIII.C.S-15

VIII.B2.S-15

VIII.B1.S-15

VIII.A.S-15

C.2-b S-04

VIII.C.SP-71

VIII.A.SP-71

C.2-b S-06 Retired

D1. SP-16

VIII.G.SP-87

VIII.F.SP-87

VIII.E.SP-87

VIII.D2.SP-87

VIII.D1.SP-87

VIII.C.SP-87

VIII.B1.SP-87

D1. SP-25

VIII.G.SP-91

VIII.E.SP-91

VIII.D2.SP-91

VIII.D1.SP-91
April 2011 A-71 NUREG-1950

Table A-7. Relationship of Steam 

and Power Conversion (SPC) 

System IDs in GALL Report, Chpt 

VIII

Rev. 0 Rev. 1 Rev. 2

VIII.A.SP-91

D1. SP-24

VIII.G.SP-90

VIII.F.SP-90

VIII.E.SP-90

VIII.D2.SP-90

VIII.D1.SP-90

D1. SP-38

VIII.G.SP-95

VIII.E.SP-95 

VIII.D2.SP-95

VIII.D1.SP-95

VIII.A.SP-95

D1. SP-17

VIII.G.SP-88

VIII.F.SP-88

VIII.E.SP-88

VIII.D1.SP-88

VIII.C.SP-88

VIII.B1.SP-88

D1. SP-32

VIII.G.SP-92

VIII.E.SP-92

VIII.D2.SP-92

VIII.D1.SP-92

VIII.A.SP-92

D1.1-a S-16

VIII.G.S-16

VIII.F.S-16

VIII.E.S-16

VIII.D2.S-16

VIII.D1.S-16

D1.1-b S-11

VIII.G.S-11

VIII.D2.S-11

VIII.D1.S-11

D1.1-c S-10

VIII.G.SP-74

VIII.F.SP-74

VIII.D1.SP-74

VIII.B1.SP-74

D1.2-a S-16

VIII.G.S-16

VIII.F.S-16

Table A-7. Relationship of Steam 

and Power Conversion (SPC) 

System IDs in GALL Report, Chpt 

VIII

Rev. 0 Rev. 1 Rev. 2

VIII.E.S-16

VIII.D2.S-16

VIII.D1.S-16

D1.2-b S-10

VIII.G.SP-74

VIII.F.SP-74

VIII.D1.SP-74

VIII.B1.SP-74

D1.3-a S-10

VIII.G.SP-74

VIII.F.SP-74

VIII.D1.SP-74

VIII.B1.SP-74

D1.3-b S-16

VIII.G.S-16

VIII.F.S-16

VIII.E.S-16

VIII.D2.S-16

VIII.D1.S-16

D2. SP-16

VIII.G.SP-87

VIII.F.SP-87

VIII.E.SP-87

VIII.D2.SP-87

VIII.D1.SP-87

VIII.C.SP-87

VIII.B1.SP-87

D2. SP-38

VIII.G.SP-95

VIII.E.SP-95

VIII.D2.SP-95

VIII.D1.SP-95

VIII.A.SP-95

D2. SP-25

VIII.G.SP-91

VIII.E.SP-91

VIII.D2.SP-91

VIII.D1.SP-91

VIII.A.SP-91

D2. SP-32

VIII.G.SP-92

VIII.E.SP-92

VIII.D2.SP-92

VIII.D1.SP-92
NUREG-1950 A-72 April 2011

Table A-7. Relationship of Steam 

and Power Conversion (SPC) 

System IDs in GALL Report, Chpt 

VIII

Rev. 0 Rev. 1 Rev. 2

VIII.A.SP-92

D2. SP-24

VIII.G.SP-90

VIII.F.SP-90

VIII.E.SP-90

VIII.D2.SP-90

VIII.D1.SP-90

D2.1-a S-16

VIII.G.S-16

VIII.F.S-16

VIII.E.S-16

VIII.D2.S-16

VIII.D1.S-16

D2.1-b S-09

VIII.E.SP-73

VIII.D2.SP-73

VIII.C.SP-73

VIII.B2.SP-73

D2.1-c S-11

VIII.G.S-11

VIII.D2.S-11

VIII.D1.S-11

D2.2-a S-16

VIII.G.S-16

VIII.F.S-16

VIII.E.S-16

VIII.D2.S-16

VIII.D1.S-16

D2.2-b S-09

VIII.E.SP-73

VIII.D2.SP-73

VIII.C.SP-73

VIII.B2.SP-73

D2.3-a S-16

VIII.G.S-16

VIII.F.S-16

VIII.E.S-16

VIII.D2.S-16

VIII.D1.S-16

D2.3-b S-09

VIII.E.SP-73

VIII.D2.SP-73

VIII.C.SP-73

VIII.B2.SP-73

Table A-7. Relationship of Steam 

and Power Conversion (SPC) 

System IDs in GALL Report, Chpt 

VIII

Rev. 0 Rev. 1 Rev. 2

E. SP-29

VIII.G.SP-29

VIII.F.SP-29

VIII.E.SP-29

E. SP-38

VIII.G.SP-95

VIII.E.SP-95

VIII.D2.SP-95

VIII.D1.SP-95

VIII.A.SP-95

E. SP-56

VIII.G.SP-56

VIII.F.SP-56

VIII.E.SP-56

E. SP-39

VIII.G.SP-39

VIII.F.SP-39 

VIII.E.SP-39

E. SP-17

VIII.G.SP-88

VIII.F.SP-88

VIII.E.SP-88

VIII.D1.SP-88

VIII.C.SP-88

VIII.B1.SP-88

E. SP-40

VIII.F.SP-96

VIII.E.SP-96

E. SP-55

VIII.G.SP-55

VIII.F.SP-55

VIII.E.SP-55

E. SP-19 Retired

E. SP-36

VIII.G.SP-36

VIII.F.SP-36

VIII.E.SP-36

E. SP-30

VIII.A.SP-30

VIII.G.SP-30

VIII.F.SP-30

VIII.E.SP-30

E. SP-25

VIII.G.SP-91

VIII.E.SP-91

VIII.D2.SP-91
April 2011 A-73 NUREG-1950

Table A-7. Relationship of Steam 

and Power Conversion (SPC) 

System IDs in GALL Report, Chpt 

VIII

Rev. 0 Rev. 1 Rev. 2

VIII.D1.SP-91

VIII.A.SP-91

E. SP-27

VIII.G.SP-27

VIII.F.SP-27

VIII.E.SP-27

VIII.A.SP-27

E. SP-24

VIII.G.SP-90

VIII.F.SP-90

VIII.E.SP-90

VIII.D2.SP-90

VIII.D1.SP-90

E. SP-54

VIII.G.SP-54

VIII.F.SP-54

VIII.E.SP-54

E. SP-26

VIII.G.SP-26

VIII.E.SP-26

E. SP-32

VIII.G.SP-92

VIII.E.SP-92

VIII.D2.SP-92

VIII.D1.SP-92

VIII.A.SP-92

E. SP-31

VIII.G.SP-31

VIII.F.SP-31

VIII.E.SP-31

VIII.A.SP-31

E. SP-41

VIII.G.SP-41

VIII.F.SP-41

VIII.E.SP-41

E. SP-37

VIII.G.SP-94

VIII.E.SP-94

E. SP-57 VIII.E.SP-57

E. SP-8 

VIII.G.SP-8 

VIII.F.SP-8 

VIII.E.SP-8 

E. SP-16

VIII.G.SP-87

VIII.F.SP-87

Table A-7. Relationship of Steam 

and Power Conversion (SPC) 

System IDs in GALL Report, Chpt 

VIII

Rev. 0 Rev. 1 Rev. 2

VIII.E.SP-87

VIII.D2.SP-87

VIII.D1.SP-87

VIII.C.SP-87

VIII.B1.SP-87

E. SP-58 

VIII.G.SP-100

VIII.F.SP-100

VIII.E.SP-100

E. SP-42 VIII.E.SP-97

E.1-a S-16

VIII.G.S-16

VIII.F.S-16

VIII.E.S-16

VIII.D2.S-16

VIII.D1.S-16

E.1-b S-10

VIII.G.SP-74

VIII.F.SP-74

VIII.D1.SP-74

VIII.B1.SP-74

E.1-b S-09

VIII.E.SP-73

VIII.D2.SP-73

VIII.C.SP-73

VIII.B2.SP-73

E.2-a S-16

VIII.G.S-16

VIII.F.S-16

VIII.E.S-16

VIII.D2.S-16

VIII.D1.S-16

E.2-b S-09

VIII.E.SP-73

VIII.D2.SP-73

VIII.C.SP-73

VIII.B2.SP-73

E.2-b S-10

VIII.G.SP-74

VIII.F.SP-74

VIII.D1.SP-74

VIII.B1.SP-74

E.3-a S-10 VIII.G.SP-74
NUREG-1950 A-74 April 2011

Table A-7. Relationship of Steam 

and Power Conversion (SPC) 

System IDs in GALL Report, Chpt 

VIII

Rev. 0 Rev. 1 Rev. 2

VIII.F.SP-74

VIII.D1.SP-74

VIII.B1.SP-74

E.3-a S-09

VIII.E.SP-73

VIII.D2.SP-73

VIII.C.SP-73

VIII.B2.SP-73

E.4-a S-22

VIII.F.SP-81

VIII.E.SP-81

E.4-a S-21 VIII.E.SP-80

E.4-a S-19

VIII.F.SP-78

VIII.E.SP-78

E.4-a S-18 VIII.E.SP-77

E.4-b S-24

VIII.G.SP-146

VIII.F.SP-146

VIII.E.SP-146

E.4-b S-26

VIII.G.SP-117

VIII.F.SP-117

VIII.E.SP-117

E.4-c S-28

VIII.G.S-28

VIII.F.S-28

VIII.E.S-28

E.4-d S-21 VIII.E.SP-80

E.4-d S-22

VIII.F.SP-81

VIII.E.SP-81

E.4-d S-19

VIII.F.SP-78

VIII.E.SP-78

E.4-d S-18 VIII.E.SP-77

E.4-e SP-64

VIII.G.SP-64

VIII.F.SP-64

VIII.E.SP-64

VIII.A.SP-64

E.4-e S-25

VIII.G.S-25

VIII.F.S-25

VIII.E.S-25

Table A-7. Relationship of Steam 

and Power Conversion (SPC) 

System IDs in GALL Report, Chpt 

VIII

Rev. 0 Rev. 1 Rev. 2

E.4-e S-23

VIII.G.S-23

VIII.F.S-23

VIII.E.S-23

VIII.A.S-23

E.5-a S-09

VIII.E.SP-73

VIII.D2.SP-73

VIII.C.SP-73

VIII.B2.SP-73

E.5-a S-13

VIII.E.SP-75

VIII.G.SP-75

E.5-a S-10

VIII.G.SP-74

VIII.F.SP-74

VIII.D1.SP-74

VIII.B1.SP-74

E.5-b S-13

VIII.E.SP-75

VIII.G.SP-75

E.5-c S-31

VIII.E.S-31

VIII.G.S-31

E.5-d S-01

VIII.G.SP-145

VIII.E.SP-145

E.6-a S-10

VIII.G.SP-74

VIII.F.SP-74

VIII.D1.SP-74

VIII.B1.SP-74

E.6-a S-09

VIII.E.SP-73

VIII.D2.SP-73

VIII.C.SP-73

VIII.B2.SP-73

F. SP-61

VIII.F.SP-101

VIII.A.SP-101

F. SP-17

VIII.G.SP-88

VIII.F.SP-88

VIII.E.SP-88

VIII.D1.SP-88

VIII.C.SP-88

VIII.B1.SP-88
April 2011 A-75 NUREG-1950

Table A-7. Relationship of Steam 

and Power Conversion (SPC) 

System IDs in GALL Report, Chpt 

VIII

Rev. 0 Rev. 1 Rev. 2

F. SP-27

VIII.G.SP-27

VIII.F.SP-27

VIII.E.SP-27

VIII.A.SP-27

F. SP-30

VIII.A.SP-30

VIII.G.SP-30

VIII.F.SP-30

VIII.E.SP-30

F. SP-31

VIII.G.SP-31

VIII.F.SP-31

VIII.E.SP-31

VIII.A.SP-31

F. SP-55

VIII.G.SP-55

VIII.F.SP-55

VIII.E.SP-55

F. SP-29

VIII.G.SP-29

VIII.F.SP-29

VIII.E.SP-29

F. SP-40

VIII.F.SP-96

VIII.E.SP-96

F. SP-56

VIII.G.SP-56

VIII.F.SP-56

VIII.E.SP-56

F. SP-41

VIII.G.SP-41

VIII.F.SP-41

VIII.E.SP-41

F. SP-36

VIII.G.SP-36

VIII.F.SP-36

VIII.E.SP-36

F. SP-54

VIII.G.SP-54

VIII.F.SP-54

VIII.E.SP-54

F. SP-39

VIII.G.SP-39

VIII.F.SP-39

VIII.E.SP-39

Table A-7. Relationship of Steam 

and Power Conversion (SPC) 

System IDs in GALL Report, Chpt 

VIII

Rev. 0 Rev. 1 Rev. 2

F. SP-24

VIII.G.SP-90

VIII.F.SP-90

VIII.E.SP-90

VIII.D2.SP-90

VIII.D1.SP-90

F. SP-8 

VIII.G.SP-8 

VIII.F.SP-8 

VIII.E.SP-8 

F. SP-58

VIII.G.SP-100

VIII.F.SP-100

VIII.E.SP-100

F. SP-16

VIII.G.SP-87

VIII.F.SP-87

VIII.E.SP-87

VIII.D2.SP-87

VIII.D1.SP-87

VIII.C.SP-87

VIII.B1.SP-87

F.1-a S-16

VIII.G.S-16

VIII.F.S-16

VIII.E.S-16

VIII.D2.S-16

VIII.D1.S-16

F.1-b S-10

VIII.G.SP-74

VIII.F.SP-74

VIII.D1.SP-74

VIII.B1.SP-74

F.2-a S-16

VIII.G.S-16

VIII.F.S-16

VIII.E.S-16

VIII.D2.S-16

VIII.D1.S-16

F.2-b S-10

VIII.G.SP-74 

VIII.F.SP-74

VIII.D1.SP-74

VIII.B1.SP-74
NUREG-1950 A-76 April 2011

Table A-7. Relationship of Steam 

and Power Conversion (SPC) 

System IDs in GALL Report, Chpt 

VIII

Rev. 0 Rev. 1 Rev. 2

F.3-a S-10

VIII.G.SP-74

VIII.F.SP-74

VIII.D1.SP-74

VIII.B1.SP-74

F.4-a S-39 VIII.F.SP-85

F.4-a S-22

VIII.F.SP-81

VIII.E.SP-81

F.4-a S-19

VIII.F.SP-78

VIII.E.SP-78

F.4-b S-24

VIII.G.SP-146

VIII.F.SP-146

VIII.E.SP-146

F.4-b S-26

VIII.G.SP-117

VIII.F.SP-117

VIII.E.SP-117

F.4-c S-28

VIII.G.S-28

VIII.F.S-28

VIII.E.S-28

F.4-d S-19

VIII.F.SP-78

VIII.E.SP-78

F.4-d S-22

VIII.F.SP-81

VIII.E.SP-81

F.4-e S-23

VIII.G.S-23

VIII.F.S-23

VIII.E.S-23

VIII.A.S-23

F.4-e S-25 

VIII.G.S-25

VIII.F.S-25

VIII.E.S-25

F.4-e SP-64

VIII.G.SP-64

VIII.F.SP-64

VIII.E.SP-64

VIII.A.SP-64

G. SP-32 VIII.G.SP-92

Table A-7. Relationship of Steam 

and Power Conversion (SPC) 

System IDs in GALL Report, Chpt 

VIII

Rev. 0 Rev. 1 Rev. 2

VIII.E.SP-92

VIII.D2.SP-92

VIII.D1.SP-92

VIII.A.SP-92

G. SP-29

VIII.G.SP-29

VIII.F.SP-29

VIII.E.SP-29

G. SP-31

VIII.G.SP-31

VIII.F.SP-31

VIII.E.SP-31

VIII.A.SP-31

G. SP-36

VIII.G.SP-36

VIII.F.SP-36

VIII.E.SP-36

G. SP-38

VIII.G.SP-95

VIII.E.SP-95

VIII.D2.SP-95

VIII.D1.SP-95

VIII.A.SP-95

G. SP-60

VIII.G.SP-60

VIII.B1.SP-60

G. SP-55

VIII.G.SP-55

VIII.F.SP-55

VIII.E.SP-55

G. SP-56 

VIII.G.SP-56

VIII.F.SP-56

VIII.E.SP-56

G. SP-30

VIII.A.SP-30

VIII.G.SP-30

VIII.F.SP-30

VIII.E.SP-30

G. SP-58

VIII.G.SP-100

VIII.F.SP-100

VIII.E.SP-100

G. SP-37

VIII.G.SP-94

VIII.E.SP-94
April 2011 A-77 NUREG-1950

Table A-7. Relationship of Steam 

and Power Conversion (SPC) 

System IDs in GALL Report, Chpt 

VIII

Rev. 0 Rev. 1 Rev. 2

G. SP-25

VIII.G.SP-91

VIII.E.SP-91

VIII.D2.SP-91

VIII.D1.SP-91

VIII.A.SP-91

G. SP-53 VIII.G.SP-99

G. SP-54

VIII.G.SP-54

VIII.F.SP-54

VIII.E.SP-54

G. SP-39

VIII.G.SP-39

VIII.F.SP-39

VIII.E.SP-39

G. SP-27

VIII.G.SP-27

VIII.F.SP-27

VIII.E.SP-27

VIII.A.SP-27

G. SP-16

VIII.G.SP-87

VIII.F.SP-87

VIII.E.SP-87

VIII.D2.SP-87 

VIII.D1.SP-87

VIII.C.SP-87

VIII.B1.SP-87

G. SP-63 VIII.G.SP-103

G. SP-17

VIII.G.SP-88

VIII.F.SP-88

VIII.E.SP-88

VIII.D1.SP-88

VIII.C.SP-88

VIII.B1.SP-88

G. SP-41

VIII.G.SP-41

VIII.F.SP-41

VIII.E.SP-41

G. SP-8 

VIII.G.SP-8 

VIII.F.SP-8 

VIII.E.SP-8 

Table A-7. Relationship of Steam 

and Power Conversion (SPC) 

System IDs in GALL Report, Chpt 

VIII

Rev. 0 Rev. 1 Rev. 2

G. SP-62 VIII.G.SP-102

G. SP-28

VIII.G.SP-28

VIII.A.SP-28

G. SP-26

VIII.G.SP-26

VIII.E.SP-26

G. SP-24

VIII.G.SP-90

VIII.F.SP-90

VIII.E.SP-90

VIII.D2.SP-90

VIII.D1.SP-90

G.1-a S-16

VIII.G.S-16

VIII.F.S-16

VIII.E.S-16

VIII.D2.S-16

VIII.D1.S-16

G.1-b S-11

VIII.G.S-11

VIII.D2.S-11

VIII.D1.S-11

G.1-c S-10

VIII.G.SP-74

VIII.F.SP-74

VIII.D1.SP-74

VIII.B1.SP-74

G.1-d S-12 VIII.G.SP-136

G.1-e S-01

VIII.G.SP-145

VIII.E.SP-145

G.2-a S-10

VIII.G.SP-74

VIII.F.SP-74

VIII.D1.SP-74

VIII.B1.SP-74

G.3-a S-10

VIII.G.SP-74

VIII.F.SP-74

VIII.D1.SP-74

VIII.B1.SP-74

G.4-a S-10

VIII.G.SP-74

VIII.F.SP-74
NUREG-1950 A-78 April 2011

Table A-7. Relationship of Steam 

and Power Conversion (SPC) 

System IDs in GALL Report, Chpt 

VIII

Rev. 0 Rev. 1 Rev. 2

VIII.D1.SP-74

VIII.B1.SP-74

G.4-a S-13

VIII.E.SP-75

VIII.G.SP-75

G.4-b S-13

VIII.E.SP-75

VIII.G.SP-75

G.4-c S-31

VIII.E.S-31

VIII.G.S-31

G.4-d S-01

VIII.G.SP-145

VIII.E.SP-145

G.5-a S-26

VIII.G.SP-117

VIII.F.SP-117

VIII.E.SP-117

G.5-a S-24

VIII.G.SP-146

VIII.F.SP-146

VIII.E.SP-146

G.5-b S-27 VIII.G.S-27

G.5-b S-28

VIII.G.S-28

VIII.F.S-28

VIII.E.S-28

G.5-c S-23

VIII.G.S-23

VIII.F.S-23

VIII.E.S-23

VIII.A.S-23

G.5-c S-25

VIII.G.S-25

VIII.F.S-25

VIII.E.S-25

G.5-c SP-64

VIII.G.SP-64

VIII.F.SP-64

VIII.E.SP-64

VIII.A.SP-64

G.5-d S-17 VIII.G.SP-76

G.5-d S-20 VIII.G.SP-79

Table A-7. Relationship of Steam 

and Power Conversion (SPC) 

System IDs in GALL Report, Chpt 

VIII

Rev. 0 Rev. 1 Rev. 2

H. S-40 VIII.H.S-40

H. S-32 VIII.H.SP-82

H. S-33 VIII.H.SP-83

H. S-34 VIII.H.SP-84

H.1-a S-30 VIII.H.S-30

H.1-b S-42 VIII.H.S-42

H.1-b S-41 VIII.H.S-41

H.1-b S-29 VIII.H.S-29

H.2-a S-02 VIII.H.S-02

H.2-b S-03 VIII.H.S-03

I. SP-35 VIII.I.SP-35

I. SP-10 VIII.I.SP-10

I. SP-13 VIII.I.SP-13

I. SP-6 VIII.I.SP-6 

I. SP-5 VIII.I.SP-5 

I. SP-23 VIII.I.SP-23

I. SP-34 VIII.I.SP-34

I. SP-15 VIII.I.SP-15

I. SP-12 VIII.I.SP-12

I. SP-11 VIII.I.SP-11

I. SP-4 VIII.I.SP-4 

I. SP-33 VIII.I.SP-33

I. SP-9 VIII.I.SP-9 

I. SP-2 VIII.I.SP-154

I. SP-1 VIII.I.SP-1 
April 2011 A-79 NUREG-1950

A.2 Staff Technical Positions

Table A-8. Summary of Changes to the Updated License Renewal Documents as a 

Result of License Renewal Interim Staff Guidance (LR-ISG)

LR-ISG 

Number Title Summary

Affected Areas of the 

License Renewal 

Guidance Documents

LR-ISG-19B Cracking of NickelAlloy Components 

in the Reactor 

Coolant Pressure 

Boundary

NRC staff deferred this issue to 

address it in the updated license 

renewal guidance documents. As 

such, an LR-ISG was not issued.

GALL Report Section 

XI.M11B

LR-ISG-23 Replacement Parts 

Necessary to Meet 

10 CFR 50.48 (Fire 

Protection)

NRC staff withdrew this LR-ISG as 

documented by letter dated 

December 20, 2006 

(ML062990314).

None

LR-ISG-2006-01 Plant-Specific 

Aging Management 

Program for 

Inaccessible Areas 

of Boiling Water 

Reactor Mark I 

Steel Containment 

Drywell Shell

The final LR-ISG was issued on 

November 16, 2006 

(ML063210029), and a notice of 

availability was published in the 

Federal Register on November 24, 

2006 (71 FR 67923).

GALL Report 

Section XI.S1 and 

Table II.B.1.2

SRP-LR Table 3.5-1 

LR-ISG-2006-02 Staff Guidance on 

Acceptance 

Review for 

Environmental 

Reports for License 

Renewal 

Applications

This LR-ISG concerns 

environmental areas of the license 

renewal process; therefore, it does 

not pertain to the GALL Report and 

SRP-LR. Furthermore, it was 

withdrawn as noticed in the Federal 

Register on July 16, 2009 

(74 FR 34597).

None

LR-ISG-2006-03 Staff Guidance For 

Preparing Severe 

Accident Mitigation 

Alternatives 

Analyses

This LR-ISG concerns 

environmental areas of the license 

renewal process; therefore, it does 

not pertain to the GALL Report and 

SRP-LR.

The final LR-ISG was issued on 

August 2, 2007 (ML071640133), 

and a notice of availability was 

published in the Federal Register on 

August 14, 2007 (72 FR 45466).

None
NUREG-1950 A-80 April 2011

Table A-8. Summary of Changes to the Updated License Renewal Documents as a 

Result of License Renewal Interim Staff Guidance (LR-ISG)

LR-ISG 

Number Title Summary

Affected Areas of the 

License Renewal 

Guidance Documents

LR-ISG-2007-01 License Renewal 

Interim Staff 

Guidance Process, 

Revision 1 

This LR-ISG concerns the process 

for developing and implementing 

LR-ISGs; therefore, it does not 

pertain to the GALL Report and 

SRP-LR.

The final LR-ISG was issued on 

August 7, 2009 (ML091950069), 

and a notice of availability was 

published in the Federal Register on 

August 17, 2009 (74 FR 41461).

None

LR-ISG-2007-02 Changes to 

Generic Aging 

Lessons Learned 

(GALL) Report 

Aging Management 

Program (AMP) 

XI.E6, “Electrical 

Cable Connections 

Not Subject to 10 

CFR 50.49 

Environmental 

Qualification 

Requirements” 

The final LR-ISG was issued on 

December 15, 2009 

(ML091940093), and a notice of 

availability was published in the 

Federal Register on December 23, 

2009 (74 FR 68287).

GALL Report 

Section XI.E6.

LR-ISG-2008-01 Staff Guidance 

Regarding the 

Station Blackout 

Rule (10 CFR 

50.63) Associated 

with License 

Renewal 

Applications

The LR-ISG was withdrawn as 

noticed in the Federal Register on 

July 13, 2009 (74 FR 33478).

None 

LR-ISG-2009-01 Aging Management 

of Spent Fuel Pool 

Neutron-Absorbing 

Materials other 

than Boraflex

The final LR-ISG was issued on 

April 27, 2010 (ML100621321), and 

a notice of availability was 

published in the Federal Register on 

May 4, 2010 (75 FR 23821).

GALL Report Section 

XI.M40 and Table VII.A2

SRP-LR Section 3.3