ML11130A061

Response to Request for Additional Information for License Renewal Application

ML11130A061
Person / Time
Site:	South Texas
Issue date:	05/05/2011
From:	Gerry Powell South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-11002671
Download: ML11130A061 (9)

Text

Nuclear Operating Company South Teass Pro/ed Electric Generating Station P. Box 289 Wadsworth, Texas 77483 A

May 05, 2011 NOC-AE-1 1002671 10CFR54 STI: 32862187 File: G25 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2746 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Response to Request for Additional Information for the South Texas Proiect License Renewal Application

Reference:

1. STPNOC Letter dated October 25, 2010, from G. T. Powell to NRC Document Control Desk, "License Renewal Application", (NOC-AE-1 0002607) (ML103010257)

2. NRC Letter dated April 14, 2011, "Request for Additional Information for the Review of the South Texas Project, License Renewal Application - Section 2.4 Structural",

(ML110820579)

By Reference 1, STP Nuclear Operating Company (STPNOC) submitted the License Renewal Application (LRA) for South Texas Project (STP) Units 1 and 2. By Reference 2, the NRC staff requested additional information for the review of the STP LRA. STPNOC's response to the request for additional information is included in the Enclosure to this letter.

There are no regulatory commitments in this letter.

Should you have any questions regarding this letter, please contact either Arden Aldridge, STP License Renewal Project Lead, at (361) 972-8243 or Ken Taplett, STP License Renewal Project Regulatory point-of-contact, at (361) 972-8416.

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

Executed on Mg 5, gll G. T. Powell Vice President, Technical Support & Oversight KJT

Enclosure:

STPNOC Response to Request for Additional Information

NOC-AE-1 1002671 Page 2 cc:

(paper copy without enclosures)

Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 612 East Lamar Blvd, Suite 400 Arlington, Texas 76011-4125 Balwant K. Singal Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North (MS 8B1) 11555 Rockville Pike Rockville, MD 20852 Senior Resident Inspector U. S. Nuclear Regulatory Commission P. 0. Box 289, Mail Code: MN1 16 Wadsworth, TX 77483 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704 John W. Daily License Renewal Project Manager (Safety)

U.S. Nuclear Regulatory Commission One White Flint North (MS 011-Fl) 11555 Rockville Pike Rockville, MD 20852 Tam Tran License Renewal Project Manager (Environmental)

U. S. Nuclear Regulatory Commission One White Flint North (MS 011 F01) 11555 Rockville Pike Rockville, MD 20852 (electronic copy without enclosures)

A. H. Gutterman, Esquire Kathryn M. Sutton, Esquire Morgan, Lewis & Bockius, LLP John Ragan Catherine Callaway Jim von Suskil NRG South Texas LP Ed Alarcon Kevin Polio Richard Pena City Public Service Peter Nemeth Crain Caton & James, P.C.

C. Mele City of Austin Richard A. Ratliff Alice Rogers Texas Department of State Health Services Balwant K. Singal John W. Daily Tam Tran U. S. Nuclear Regulatory Commission

Enclosure NOC-AE-1 1002671 Page 1 STPNOC Response to Request for Additional Information RAI 2.4.1-1

Background:

South Texas Project (STP) Updated Final Safety Analysis Report (UFSAR) Section 9.5.1 states, in relation to fire protection, that "The protection provided is composed of fire suppression systems, the use of fire-retardant coatings, thermal barriers or fire stops, or a combination of these, as indicated in the Fire Hazard Analysis Report (FHAR). Fire stops are installed in cable trays at rated fire barrier penetrations or specific deviations are identified and justified in the FHAR."

Issue:

Insufficient information has been provided regarding fire stops for cable trays.

Request:

Please provide additional information regarding the fire stops installed in cable trays at rated fire barrier penetrations and confirm the location in the license renewal application (LRA) where they have been included per 54.4(a)(3). In addition, clearly state the corresponding aging management program (AMP) for this component. Otherwise, please justify their exclusion from scope.

STPNOC Response As noted in STP UFSAR section 9.5.1, fire stops are installed in cable trays at fire barrier penetrations. Fire stops are included in and evaluated with the component type "fire barrier seals" in LRA Tables 2.4-2, 2.4-3, 2.4-4, 2.4-5, 2.4-6, 2.4-8, and 2.4-9 as components within the scope of license renewal and subject to an Aging Management Review (AMR). LRA Tables 3.5.2-2, 3.5.2-3, 3.5.2-4, 3.5.2-5, 3.5.2-6, 3.5.2-8, and 3.5.2-9 identify the Fire Protection program (B2.1.12) as the AMP that manages the aging of "fire barrier seals."

RAI 2.4.1-2

Background:

STP UFSAR Section 9.5.1 also states that "Safety-related structures are primarily of reinforced concrete construction on a structural steel framing and provide ample inherent fire resistance for walls, floors, and ceilings which separate redundant systems. Exposed structural steel is protected with spray-applied fireproofing material having a fire rating of at least 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> except where it was deemed unnecessary due to the low fire loading."

Issue:

Further explanation on the spray-applied fireproofing material is needed.

Request:

Please explain the differences and/or similarities between the fire-retardant coatings detailed in request RAI 2.4.1-1 and the spray-applied fireproofing material mentioned above. In addition, please state the location in the LRA where the spray-applied fireproofing material is covered. In addition, clearly state the corresponding AMP for this component. Otherwise, please justify its exclusion from scope.

Enclosure NOC-AE-1 1002671 Page 2 STPNOC Response The terms "fire-retardant coatings" and "spray-applied fireproofing material" both refer to cementitious fireproofing that is applied to the structural steel components. This fireproofing material is included in and evaluated with the component type "fire barrier coatings and wraps" in LRA Tables 2.4-1, 2.4-2, 2.4-5, and 2.4-8 as components within the scope of license renewal and subject to an AMR. LRA Tables 3.5.2-1, 3.5.2-2, 3.5.2-5, and 3.5.2-8 identify the Fire Protection program (B2.1.12) as the AMP that manages the aging of "fire barrier coatings and wraps."

RAI 2.4.2-1

Background:

As stated in the STP UFSAR Section 9.5.1, some safety-related structures, such as the control room, contain suspended ceilings, which in turn may house lighting and communication circuits in steel conduits or fire detection circuits in aluminum sheathing in the space above.

Issue:

Additional information regarding the scoping of aluminum sheathing is needed to complete the staff's review.

Request:

Please provide additional information on the structures within the scope of License Renewal that contain the aforementioned aluminum sheathing and the location in the LRA where the sheathing is covered for each structure. In addition, clearly state the corresponding AMP for this component. Otherwise, please justify their exclusion from scope.

STPNOC Response The aluminum sheathing is included in and evaluated with the component type "conduit and supports" in LRA Table 2.4-11 and Table 2.4-12 as components within the scope of license renewal and subject to an AMR. LRA Table 3.5.2-11 identifies component type "conduit and supports" constructed of the material "aluminum" exposed to the environment "plant indoor air (structural)" as being evaluated per NUREG 1801 line III.B2-4, which specifies that this component/material/environment combination has no applicable aging effect and does not require aging management.

RAI 2.4.2-2

Background:

STP UFSAR Section 3.4.1 "Flood Protection" states that "All seismic joints between Category I structures contain dual 9-in. water stops capable of withstanding potential seismic and hydrostatic effects."

Issue:

Additional information regarding the scoping of structures with water stops (as described above) is needed for staff to complete its review.

Request:

Please provide additional information on the structures within the scope of License Renewal that contain the aforementioned waterstops credited for flood protection and the location in the LRA where they are covered for each structure. In addition, clearly state the corresponding AMP for this component. Otherwise, please justify their exclusion from scope.

Enclosure NOC-AE-1 1002671 Page 3 STPNOC Response The water stops between Category I structures with the intended function of flood barrier are included in and evaluated with the component type "caulking and sealant" in LRA Tables 2.4-3, 2.4-5, 2.4-7, 2.4-8, 2.4-9, and 2.4-10 as components within the scope of license renewal and subject to an AMR. LRA Tables 3.5.2-3, 3.5.2-5, 3.5.2-7, 3.5.2-8, 3.5.2-9, and 3.5.2-10 identify the Structures Monitoring Program (B2.1.32) as the AMP that manages the aging of "caulking and sealant."

RAI 2.4.3-1

Background:

LRA drawing LR-STP-STRUC-9Y100M00001, Rev. 15, lists Building #73 as being the Diesel Fuel Oil Filtration Skid, physically located northeast of the Diesel Generator Building.

Issue:

Additional information is required for staff review regarding the structural configuration and components of Building 73.

Request:

Please provide additional information on the structural configuration of the building and its components. In addition, please explain briefly how its failure would not prevent satisfactory accomplishment of any of the functions performed by the diesel generators, which would justify the exclusion of Building #73 from the scope of LR.

STPNOC Response The Diesel Fuel Oil Filtration Skid is identified as the Auxiliary Fuel Oil Filtration Skid in STP UFSAR Section 9.5.4.2. The skid is a low-level steel and concrete structure that provides anchorage for filters and other equipment used to process fuel oil being transferred from the Auxiliary Fuel Storage and Transfer System, or from fuel trucks, to the diesel fuel oil storage tanks inside the diesel generator building. The fuel oil storage tanks inside the diesel generator building are designed to provide the required fuel oil supply for the standby diesel generators without replenishment from the Auxiliary Fuel Storage and Transfer System, or from fuel trucks.

There are no SSCs associated with the Diesel Fuel Oil Filtration Skid whose failure could prevent satisfactory accomplishment of any of the functions performed by the standby diesel generators. The Diesel Fuel Oil Filtration Skid and its supporting structure do not have a license renewal intended function and are not within the scope of license renewal.

RAI 2.4.3-2

Background:

STP UFSAR Section 3.4.1 "Flood Protection" states that "The three maintenance knockout panels in the exterior walls of the Diesel-Generator Building, which are located below the maximum water surface elevation of 45.0 ft MSL, are watertight and designed for the hydrostatic forces."

Issue:

Table 2.4-3 only lists caulking and sealant, concrete elements, and doors as being credited with the Flood Barrier intended function in the Diesel Generator Building.

Enclosure NOC-AE-1 1002671 Page 4 Request:

Please provide additional information regarding the knockout panels and the location in the LRA where they are covered and credited for their intended function. In addition, clearly state the corresponding AMP for this component. Otherwise, please justify their exclusion from scope.

STPNOC Response The knockout panels are included in and evaluated with the component type "hatches and plugs" in LRA Table 2.4-3 as components within the scope of license renewal and subject to an AMR. LRA Table 3.5.2-3 identifies the Structures Monitoring Program (B2.1.32) as the AMP that manages the aging of "hatches and plugs."

The intended function of "flood barrier" will be added to the component type "hatches and plugs" in LRA Table 2.4-3 and Table 3.5.2-3.

Table 2.4-3 Diesel Generator Building Component Type Intended Function

,Hatches and Plugs Fire Barrier Flood Barrier Missile Barrier Shelter, Protection

Enclosure NOC-AE-1 1002671 Page 5 Table 3.5.2-3 Containments, Structures, and Component Supports - Summary of Aging Management Evaluation - Diesel Generator Building Component Intended Material Environment Aging Effect Aging Management NUREG-ITable I Item Notes Type 1Function Requiring Program 1801 Vol.

_Management 2 Item Hatches and FFB, FLB, !Concrete Atmosphere/

Cracking due to Structures Monitoring III.A3-2 3.5.1.27

'A Plugs

MB, SH

'Weather expansion Program (B2.1.32)

Hatches and Plugs Hatches and Plugs FB, FLB,

Concrete MB, SH FB, FLB,

ýConcrete MMB, SH Hatches and FB, FLB, Concrete Plugs MMB, SH Hatches and FB, FLB, Concrete Plugs MB, SH

.(Structural) (Ext)

Atmosphere/

Weather (Structural)(Ext)

Atmosphere/

Weather

'(Structural) (Ext)

Atmosphere/

ýWeather (Structural) (Ext)

Atmosphere/

Weather (Structural) (Ext)

Atmosphere/

.Weather

.(Structural) (Ext)

-Plant Indoor Air

_'(Structural) (Ext)

Plant Indoor Air (Structural) (Ext)

Loss of material (spalling, scaling) and cracking Cracking, loss of bond, and loss of material (spalling,

,scaling)

Increase in porosity and permeability, cracking, loss of material (spalling, scaling)

Concrete cracking and spalling Loss of material

-Cracking due to

_'expansion Cracking, loss of bond, and loss of material (spalling, scaling)

Structures Monitoring Program (B2.1.32)

Structures Monitoring Program (B2.1.32)

Structures Monitoring Program (B2.1.32)

II1.A3-6 3.5.1.26 A

II1.A3-9 3.5.1.23 A

/lI.A3-10 3.5.1.24 A

Hatches and Plugs FFB, FLB, 'Concrete MMB, SH Fire Protection (B2.1.12) VII.G-30 and Structures Monitoring Program (B2.1.32)

Fire Protection (B2.1.12) VII.G-31 and Structures Monitoring Program (B2.1.32)

Structures Monitoring I IL.A3-2 Program (B2.1.32)

Structures Monitoring III.A3-9 Program (B2.1.32) 3.3.1.66 3.3.1.67 3.5.1.27 Hatches and FB, FLB, Concrete P Plugs

9MB, SH i Hatches and FB, FLB, Concrete Plugs

MB, SH A

3.5.1.23 -

,A

Enclosure NOC-AE-1 1002671 Page 6 Hatches and

'Plugs Hatches and Plugs Hatches and Plugs

• FB, FLB, Concrete

.MB, SH FB, FLB, I MB, SH

Concrete Plant Indoor Air (Structural) (Ext)

Plant Indoor Air (Structural) (Ext)

Plant Indoor Air (Structural) (Ext)

Increase in porosity and permeability, cracking, loss of material (spalling, scaling)

Structures Monitoring Program (B2.1.32)

III.A3-10 3.5.1.24 Concrete cracking Fire Protection (B2.1.12) VII.G-28 and spalling and Structures Monitoring Program (B2.1.32)

Loss of material Fire Protection (B2.1.12) VII.G-29 and Structures Monitoring Program (B2.1.32)

A B

B 3.3.1.65 3.3.1.67 FB, FLB, Concrete MB, SH

Enclosure NOC-AE-1 1002671 Page 7 RAI 2.4.9-1

Background:

STP UFSAR Section 3.8.4.1.4 lists strainers, trash racks, and traveling screens as debris prevention/removing mechanisms that are part of the Essential Cooling Water Intake Structure.

Issue:

These components are not listed in Table 2.4-9, "Essential Cooling Water Structures."

Request:

Please justify the exclusion of these components from scope of LR per LRA Table 2.4-9.

Otherwise, please identify the applicable aging effects and the AMP related to these components.

STPNOC Response The trash racks are included in and evaluated with the component type "structural steel" in LRA Table 2.4-9 as components within the scope of license renewal and subject to an AMR. LRA Table 3.5.2-9 identifies the Structures Monitoring Program (B2.1.32) as the AMP that manages the aging of "structural steel." The strainers and traveling screens are included in and evaluated with the component types "strainer element" and "traveling screen", respectively, in LRA Table 2.3.3-4 for the Essential Cooling Water (ECW) and the ECW screen wash system as components within the scope of license renewal and subject to an AMR. LRA Table 3.3.2-4 identifies the Open-Cycle Cooling Water System (B2.1.9) as the AMP that manages the aging of "strainer elements" and "traveling screens."