ML11154A013

Summary of Telephone Conference Call Held on May 23, 2011, Between the NRC and STPNOC, Concerning Requests for Additional Information Pertaining to the South Texas Project, LRA-Future Consideration of Operating Experience

ML11154A013
Person / Time
Site:	South Texas
Issue date:	07/06/2011
From:	Daily J License Renewal Projects Branch 1
To:	South Texas
Daily J
References
TAC ME4937, TAC ME4939
Download: ML11154A013 (7)

Text

~",!I REGu~ UNITED STATES

",vv "1;

",-iiI'... o~.t. NUCLEAR REGULATORY COMMISSION

~" WASHINGTON, D.C. 20555*0001

<t 0 Ii.  :

~ r:; July 6, 2011

~ ~

'S-., ~o If-***~

LICENSEE: STP Nuclear Operating Company FACILITY: South Texas Project, Units 1 and 2

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON MAY 23, 2011, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND STP NUCLEAR OPERATING COMPANY, CONCERNING REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO THE SOUTH TEXAS PRO~IECT, LICENSE RENEWAL APPLICATION - FUTURE CONSIDERATION OF OPERATING EXPERIENCE (TAC NOS. ME4936 AND M34937)

The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of South Texas Project Nuclear Operating Company (STPNOC or the applicant) held a telephone conference call on May 23, 2011, to discuss and clarify the staff's request for additional information (RAI) concerning the South Texas Project, Units 1 and 2 license renewal application. The telephone conference call was useful in clarifying the intent of the staff's RAI.

Enclosure 1 provides a listing of the participants; Enclosure 2 contains a summary of the RAI and the related discussion.

The applicant had an opportunity to comment on this summary.

John W. Daily Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499

Enclosures:

As stated cc w/encls: Listserv

TELEPHONE CONFERENCE CALL SOUTH TEXAS PROJECT LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS MAY 23,2011 PARTICIPANTS AFFILIATIONS John Daily NRC Matt Homiack NRC David Wrona NRC Arden Aldriqge STPNOC Ken Taplett STPNOC Tony Harris STARS COB Chalmer Myers STARS COB Gary Warner STARS COB Eric Blocker STARS COB ENCLOSURE 1

REQUESTS FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION MAY 23,2011 The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of South Texas Projects Nuclear Operating Company (STPNOC) held a telephone conference call on May 23, 2011, to discuss and clarify the following request for additional information (RAI) concerning the applicant's license renewal application (LRA).

RAI #81.4-1

Background:

Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 54.21 (a)(3), a license renewal applicant is required to demonstrate that the effects of aging on structures and components subject to an aging management review are adequately managed so that their intended functions will be maintained consistent with the current licensing basis for the period of extended operation. Section 3.0.1 of NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants," Revision 2 (SRP-LR), defines an aging management review as the identification of the materials, environments, aging effects, and aging management programs (AMPs) credited for managing the aging effects. In turn, SRP-LR Section A.1.2.3 defines an acceptable AMP as consisting of ten elements. Element 10, "Operating Experience," in part, is described in SRP-LR Section A.1.2.3.1 0, paragraph 1, as follows:

Consideration of future plant-specific and industry operating experience relating to aging management programs should be discussed. Reviews of operating experience by the applicant in the future may identify areas where aging management programs should be enhanced or new programs developed. An applicant should commit to a future review of plant-specific and industry operating experience to confirm the effectiveness of its aging management programs or indicate a need to develop new aging management programs (emphasis added). This information should provide objective evidence to support the conclusion that the effects of aging will be managed adequately so that the structure and component intended function(s) will be maintained during the period of extended operation.

In addition, 10 CFR 54.21 (d) requires the application to contain a final safety analysis report (FSAR) supplement. This supplement must contain a summary description of the programs and activities for managing the effects of aging and the evaluation of time-limited aging analyses for the period of extended operation.

Based on its review of the South Texas Project, Units 1 and 2, LRA, the staff determined that Section B1.4 provides a general description of how the applicant gathered and considered operating experience in preparing its LRA, and Sections B2.1.1 through B2.1.37 and B3.1 through 83.3 summarize the specific operating experience considered for each AMP.

ENCLOSURE 2

- 2 Issue:

Although LRA Sections 81.4, 82.1.1 through 82.1.37, and 83.1 through 83.3 describe how the applicant incorporated operating experience into its AMPs, they do not fully describe how the applicant will use future operating experience to ensure that the AMPs will remain effective for managing the aging effects during the period of extended operation. The main focus of these LRA sections is on how the applicant evaluated operating experience available at the time the application was prepared to justify the adequacy of its proposed AMPs. Some of the program descriptions, particularly those for new programs, contain statements indicating that future plant-specific and industry operating experience will be used to adjust the programs as appropriate. However, for the majority of the AMPs, it is not clear whether the applicant currently has or intends to implement actions to monitor operating experience on an ongoing basis and use it to ensure the continued effectiveness of the AMPs. The LRA also does not state whether new AMPs will be developed, as necessary. Further, the majority of the AMP descriptions do not provide the staff reasonable assurance that ongoing operating experience reviews will continue to inform AMP updates for license renewal.

Request:

Describe the programmatic activities that will be used to continually identify aging issues, evaluate them, and, as necessary, enhance the AMPs or develop new AMPs for license renewal. In this description, address the following:

• Describe the sources of plant-specific and industry operating experience that are monitored on an ongoing basis to identify potential aging issues. Indicate whether these plant-specific sources require monitoring: corrective action program, system health reports, licensee event reports (LERs), and the results of inspections performed under the AMPs. Similarly, indicate whether these industry sources require monitoring: vendor recommendations, revisions to industry standards on which the AMPs are based, LERs from other plants, NRC 8ulletins, Generic Letters, Regulatory Issue Summaries, Information Notices, Regulatory Guides, License Renewal Interim Staff Guidance, and revisions to NUREG-1801, "Generic Aging Lessons Learned (GALL) Report." Describe the criteria used to classify a particular piece of information as aging related and outline the training provided to plant personnel so that they can adequately make such classifications.

• Describe how the identified aging issues are further evaluated to determine their potential impact on the plant aging management activities. Indicate whether the affected structures and components and their materials, environments, aging effects, aging mechanisms, and AMPs are identified and documented consistent with the methods used to prepare the LRA. Describe how the results of AMP inspections are considered to adjust the frequency of future inspections, establish new inspections, and ensure an adequate depth and breadth of component, material, environment, and aging effect combinations. Describe the records of these evaluations and indicate whether they are maintained in an auditable and retrievable form.

• Describe the process and criteria used to ensure that the identified enhancements are implemented in a timely manner.

- 3

• Describe the administrative controls over these programmatic activities.

Provide a summary description of these activities for the FSAR supplement required by 10 CFR S4.21(d). If enhancements for license renewal are necessary, also provide the updates for the FSAR supplement.

If such an operating experience program is determined to be unnecessary, provide a detailed explanation of the bases for this determination.

Discussion:

The staff and applicant reviewed the Background, Issue, and Request. The applicant indicated that the RAI is understood and that STPNOPC's response will be provided to the staff. A mutually agreeable timeframe for the response is by June 27,2011.

ML11154A013 PM: DLRlRPB1 BC: DLR/RPB1 OFFICE LA:DLR SFigueroa JDaily BPham NAME

• DATE 06/7/2011 06/8/2011 07/6/2011 Letter to STP Nuclear Operating Company from John W. Daily Dated July 06, 2011

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON MAY 23, 2011, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND STP NUCLEAR OPERATING COMPANY, CONCERNING REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO THE SOUTH TEXAS PROJECT, LICENSE RENEWAL APPLICATION - FUTURE CONSIDERATION OF OPERATING EXPERIENCE (TAC NOS. ME4936 AND M34937)

DISTRIBUTION:

HARDCOPY:

DLR RtF E-MAIL:

PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRerb Resource RidsNrrDlrRpob Resource RidsOgcMailCenter JDaily TTran ICouret,OPA BSingal, DORL WWalker, RIV JDixon, RIV BTharakan, RIV WMaier, RIV VDricks, RIV NOKeefe, RIV