ML11224A265

Aging Management Programs Audit Report Regarding the South Texas Project, Units 1 and 2, Station License Renewal Application

ML11224A265
Person / Time
Site:	South Texas
Issue date:	09/22/2011
From:	Daily J License Renewal Projects Branch 1
To:	Gerry Powell South Texas
Daily J
References
TAC ME4936, TAC ME4937
Download: ML11224A265 (96)

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UNITED STATES NUCLEAR REGULATORY COMMISSION Go-<!>';;;~'

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September 22, 2011

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",,0 Mr. G. T. Powell, Vice President Technical Support and Oversight STP Nuclear Operating Company P.O. Box 289 Wadsworth, TX 77483

SUBJECT:

AGING MANAGEMENT PROGRAMS AUDIT REPORT REGARDING THE SOUTH TEXAS PROJECT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. ME4936 AND ME4937)

Dear Mr. Powell:

By letter dated October 25, 2010, STP Nuclear Operating Company (STPNOC or the Applicant) submitted an application for renewal of operating licenses NPF-76 and NPF-80 for South Texas Project (STP), Units 1 and 2. The staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing this application in accordance with the guidance in NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants." On June 24, 2011, the staff of the staff completed the onsite audit of aging management programs.

The audit report is enclosed.

If you have any questions, please contact me by telephone at 301-415-3873 or bye-mail at John.Daily@nrc.gov.

Sincerely,

)DL~~

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

Enclosure:

As stated cc w/encl: Listserv

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION, DIVISION OF LICENSE RENEWAL Docket Nos:

License Nos:

Licensee:

Facility:

Location:

Dates:

Reviewers:

Approved By:

050-00498,050-00499 NPF-76, NPF-80 South Texas Nuclear Operating Company South Texas Project, Units 1 and 2 P.O. Box 289 Wadsworth, TX 77483 June 13 - 24,2011 J. Daily, Sr. Project Manager, Audit Team Leader, Division of License Renewal (DLR)

R. Auluck, Branch Chief, DLR D. Pelton, Branch Chief, DLR A. Buford, Structural Engineer, DLR A. Prinaris, Structural Engineer, DLR B. Lehman, Structural Engineer, DLR A. Istar, Structural Engineer, DLR D. Brittner, Mechanical Engineer, DLR C. Doutt, Sr. Electrical Engineer, DLR D. Nguyen, Electrical Engineer, DLR R. Li, Electrical Engineer, DLR D. Naus, Consultant (Oak Ridge National Lab)

W. Holston, Mechanical Engineer, DLR J. Klos, Mechanical Engineer, DLR C. Ng, Mechanical Engineer, DLR B. Fu, Mechanical Engineer, DLR S. Min, Mechanical Engineer, DLR A. Obodoako, Mechanical Engineer, DCI K. Axler, ConSUltant (Southwest Research Institute (SWRI))

L. Howard, Consultant (SWRI)

L. Miller, Consultant (SWRI)

Rajender Auluck, Chief Aging Management of Structural and Electrical Systems Branch Division of License Renewal Dave Pelton, Chief Aging Management of Plants Systems Branch Division of License Renewal Bo Pham, Chief Aging Management of Reactor Systems and Guidance Update Branch Division of License Renewal ENCLOSURE

Introduction A 10-day audit was conducted by the U.S. Nuclear Regulatory Commission staff (NRC or the staff) at the South Texas Project, Units 1 and 2 (STP, or the plant), near Wadsworth, TX, from June 13 - 24, 2011. The purposes of this audit were to examine the South Texas Project Nuclear Operating Company (STPNOC or the applicant) aging management programs (AMPs) and related documentation for STP and to verify the applicant's claims of consistency with corresponding Generic Aging Lessons Learned (GALL) Report (NUREG-1801, Revision 2)

AMPs. As described in the GALL Report, the staff based its evaluation of the adequacy of each AMP on its review of the following 10 AMP program elements: 1) scope of program, 2) preventive actions, 3) parameters monitored or inspected, 4) detection of aging effects, 5) monitoring and trending, 6) acceptance criteria, 7) corrective actions, 8) confirmation process, 9) administrative controls, and 10) operating experience.

Exceptions to the GALL AMP elements will be evaluated separately as part of the staff's review of the STPNOC license renewal application (LRA) and documented in the staff's Safety Evaluation Report.

The Standard Review Plan for Review of LRAs for Nuclear Power Plants (SRP-LR) (NUREG 1800, Revision 2) provides the staff guidance for reviewing an LRA. The SRP-LR allows an applicant to reference in its LRA, the AMPs described in the GALL Report. By referencing the GALL AMPs, the applicant concludes that its AMPs correspond to those AMPs which are reviewed and approved in the GALL Report and that no further staff review is required. If an applicant credits an AMP for being consistent with the GALL Report program, it is incumbent on the applicant to ensure that the plant program contains all of the elements of the referenced the GALL Report program. The applicant's determination should be documented in an auditable form and maintained onsite.

During this audit, the staff audited AMP elements 1-6, and 10 (scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and operating experience). These elements of the applicant's AMPs were claimed to be consistent with the GALL Report and were audited against the related elements of the associated AMP described in the GALL Report, unless otherwise indicated in this audit report. Elements 7-9 (corrective actions, confirmation process, and administrative controls),

were audited during the Scoping and Screening Methodology audit conducted on May 16 - 20, 2011, and are evaluated separately. The staff audited all AMPs that the applicant stated were consistent with the GALL Report AMPs.

During this audit, if an applicant took credit for a program in the GALL Report, the staff verified that the plant program contains all the elements of the referenced the GALL Report program. In addition, the staff verified that the conditions at the plant were bounded by the conditions for which the GALL Report program was evaluated.

In performing this audit, the staff examined the applicant's LRA, program bases documents, and related references; interviewed various applicant representatives; and conducted walkdowns of several plant areas. In total, 35 AMPs were reviewed and 25 breakout (discussion) sessions with applicant representatives were conducted. This report documents the staff's activities during this audit.

- 2 Existing Program Consistent with the GALL Report, LRA AMP B2.1.1, "ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD" Summary of Information in the Application: The LRA states that AMP B2.1.1, "ASME Section XI Inservice Inspection, Subsections IWB, IWe, and IWD," is an existing program that is consistent with the program elements in GALL AMP XI.M1, "ASME Section Xllnservice Inspection, Subsections IWB, IWe, and IWD." To verify this claim of consistency, the staff audited LRA AMP B2.1.1.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the following search terms: "cracking,"

"failure," "degradation" and "weld."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Datl

! 1. STP-AMP-B2.1.1 ASME Section XI Inservice Inspection, Subsections IWB, Revision 2, IWC, and IWD 4/27/2011

2. OPEP10-ZA-004 General Ultrasonic Examination Revision 3, 3/8/2007

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3. CR02-8654 Condition Record:

6/17/2002 i

i 4.

Inservice Inspection Program Plan Revision 4, 9/30/2008

5. OPGP04-ZA-0002 Condition Record Engineering Evaluation Revision 10, 10/18/2008

6. RR-ENG-3-4 Proposed Alternative in Accordance with 10CFR50.55a(a)(3)(i) 12/30/1999

7. LER 4992005001 Unit 2 Shutdown Due to Reactor Coolant System 4/5/2005 Pressure Boundary Leak

8. CR 05-1819-8 Root Cause Investigation, Unit Shutdown Due RCS Pressure Boundary Leak at RC-0127 3/11/2005

9. NRC IN 2003-11 Leakage Found on Bottom-Mounted Instrumentation Nozzles 8/13/2003 i

During the audit of program elements one through six, the staff found that program elements "scope of program," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by

- 3 the applicant, is adequate to detect and manage aging effects during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the Updated Final Safety Analysis Report (UFSAR) Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that LRA program elements "scope of program," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," "acceptance criteria," and "operating experience" are consistent with the corresponding program elements in the GALL Report AMP.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that LRA AMP B2.1.1, as implemented by the applicant, is adequate to detect and manage aging. In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

Existing Program Consistent with the GALL Report with Enhancement(s), LRA AMP 82.1.2, "Water Chemistry" Summary of Information in the Application: The LRA states that AMP B2.1.2, "Water Chemistry," is an existing program with an enhancement that is consistent with the program elements in GALL AMP XI.M2, "Water Chemistry." To verify this claim of consistency, the staff audited the LRA AMP.

The enhancement affects the LRA AMP "monitoring and trending," "corrective action," and "confirmation process." The LRA states that the procedures will be enhanced to include a statement that the sampling frequency for the primary and secondary water systems is temporarily increased whenever corrective actions are taken to address an abnormal chemistry condition for action level parameters, and that this increased sampling is utilized to verify that the desired condition has been achieved, and when it is achieved the sampling frequencies are returned to the Electric Power Research Institute (EPRI) - recommended frequencies.

In Table A4-1 of the LRA, the applicant committed (Commitment No.1) to implement this enhancement prior to the period of extended operation.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the following search terms: "corrosion,"

"pitting," and "stress corrosion cracking."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

- 4 Relevant Documents Reviewed Document Title Revision [Date

1. STP-AMP-B2.1.2 STP Program Evaluation Report, B2.1.2 Water Chemistry, Revision 2, NUREG-1801, XI.M2 09/13/2010 i

i

2. OPGP03-Z0-0012:

South Texas Project Electric Generating Station; Plant I Revision 17, STI 32445283 Systems Chemistry Control

. 04/07/2009 i

3.0PCP01-ZA-0038; ST132455496

4. STI 32865681 South Texas Project Electric Generating Station; Plant Chemistry Specifications Revision 37, 04/07/2009 i

i Secondary Chemistry Optimization Plan Revision 7, 6/22/2011 I

The staff conducted its audit of LRA AMP program elements one through six based on the contents of the existing program as modified by the proposed enhancements.

During the audit, the staff found that program elements "scope of program," "preventive actions,"

"parameters monitored or inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that LRA program elements "scope of program," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.

In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

- 5 Existing Program Consistent with the GALL Report with Exception(s), LRA AMP 82.1.3, "Reactor Head Closure Studs" Summary of Information in the Application: The LRA states that AMP 82.1.3, "Reactor Head Closure Studs," is an existing program with exceptions that is consistent with the program elements in GALL AMP XI.M3, "Reactor Head Closure Studs." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER. This audit report does not consider the sufficiency of exceptions; these will be evaluated in the SER.

The first exception affects the LRA "scope of program" program element. The LRA states that Regulatory Guide 1.65 (Revision 1) states that the ultimate tensile strength of stud bolting material should not exceed 170 ksi, and that one closure head insert has a tensile strength of 174.5 ksL The LRA also states that STP credits inservice inspections that are within the scope of this AMP, which are implemented in accordance with the STP Inservice Inspection Program, Examination Category 8-G-1 requirements, as the basis for managing cracking in these components. The applicant identified the use of the closure stud with the ultimate tensile strength exceeding 170 ksi as an exception.

The second exception affects the LRA "corrective actions" program element. The LRA states that NUREG-1801,Section XI.M3, specifies the use of Regulatory Guide 1.65 requirements for closure stud, and nut material, and that STP uses SA-540, Grade 8-24 (as modified by Code Case 1605) stud material. The LRA also states that the use of this material has been found acceptable to the NRC for this application within the limitations discussed in Regulatory Guide 1.85, "Materials Code Case Acceptability." The applicant identified that the use of SA-540, Grade 8-24 (as modified by Code Case 1605) stud material was an exception.

As stated above, the staff did not evaluate the sufficiency of these exceptions during the audit.

The staff's evaluation of the adequacy of these exceptions will be documented in the SER.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the following search terms: "closure studs,"

"head studs," "wear," "corrosion," and "pitting."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

- 6 Relevant Documents Reviewed Document Title Revision I Date

1. STP-AMP-B2.1.3 South Texas Project Aging Management Program Revision 3, Evaluation Report Reactor Head Closure Studs 4/27/2011

2. STP-SCR-RCVI South Texas Project license Renewal Component Revision 3, Summary Screening Report license Renewal Id No. RCVI 8/10/2010 Reactor Vessel and Internals

3. OPMP04-RX-0022 Reactor Head Stud Cleaning and Inspection Revision 2, 2/12/2009

4. 32375150 Inservice Inspection Program Plan for Examination of Revision 4, Component Supports, Concrete Containment, Containment. 9/29/2008 Metal liner, Repair/Replacement Activities, Steam Generator Tubing, System Pressure Testing and Weld Inspections of the South Texas Project Electric Generating Station Units 1 and 2 Revision 2,

5. CR 03-5590 Condition Record 4/5/2003 Revision 1,

6. WO 454559 Work Order 4/12/2007 Revision 1, Corresponding Insert

7. DCP # 07-5020-13

• Disposition to Denting of Stud (ROTO-LOK) #30 and 4/9/2007 Expendable Material Specification: 2001 Space Age Oil Revision 2, 1/10/2002

8. STI31400313

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The staff conducted its audit of LRA AMP program elements one through six based on the contents of the existing program. Aspects of program element "scope of program" of the LRA AMP associated with the exception were not evaluated during this audit. Aspects of this program element that are not associated with the exception were evaluated and are described below.

During the audit, the staff found that program elements, "parameters monitored or inspected,"

"detection of aging effects," "monitoring and trending," and "acceptance criteria" of the LRA AMP are consistent with the corresponding elernents of the GALL Report AMP. The staff also found that aspects of program element "scope of program" not associated with the exception are consistent with the corresponding program elements in the GALL Report AMP. The staffs evaluation of aspects of these program elements associated with the exceptions will be addressed in the SER In addition, the staff found that for the program element "preventive actions," sufficient information was not available to determine whether it was consistent with the corresponding program element of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing an RAI for the subject discussed below.

The "preventive actions" program element of LRA AMP 82.1.3, as addressed in the applicant's aging management program evaluation report for this program, states that the applicant follows the preventive measures in RG 1.65 to prevent aging effects due to corrosion or hydrogen

- 7 embrittlement; however, the program element does not address a provision to preclude the use of reactor head closure stud bolting material with yield strength greater than 150 ksi as a preventive measure against stress corrosion cracking. In comparison, GALL AMP XI.M3, Revision 2, recommends using bolting material for closure studs that has an actual measured yield strength less than 150 ksi. It is not clear to the staff that the applicant's program element "preventive actions" is consistent with the corresponding program element of GALL AMP XI.M3, Revision 2, because the LRA and related onsite documentation do not clearly indicate whether or not the applicant's program has a provision to preclude reactor head closure stud bolting material with yield strength greater than 150 ksi.

During the audit of the "operating experience" prograrn element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation. In order to obtain the information necessary to verify whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing an RAI for the subject discussed below.

In its review of applicant's operating experience related to the program during the audit, the staff noted that a work order dated April 12, 2007, indicates that an ASME Code,Section XI replacement of the #30 ROTO-LOK stud was conducted in Unit 2 during Refueling Outage 12 per the disposition of a design change package dated April 9, 2007. The design change package indicates that Stud #30 of Unit 2 had rotated inadvertently during the detensioning process, causing it to partially engaged inside the stud insert, which is also called the bushing, and this condition caused damage to all the lugs of the stud that were partially engaged. The design change package also indicates that the applicant decided to replace Stud #30 of Unit 2 with a spare stud of the same kind from the warehouse. Based on the evaluation performed on the stud insert, the applicant dispositioned the non-conforming condition of the stud insert as "Use-As-Is." The applicant's design change package further indicates that the damaged areas of the insert lug bearing surfaces were conservatively estimated to be 17 percent of the original contact areas.

In addition, in its review during the audit, the staff noted that the applicant's Inservice Inspection Plan, Revision 4, dated September 29, 2008, specifies the inspection plan for the second interval that started September 2000 and October 2000 for Units 1 and 2, respectively. The staff also noted that Examination Category B-G-1, Item No. B6.50 in the applicant's inspection plan indicates that alternative volumetric examination is specified as the inspection method for the closure bushings, which are also called stud inserts, instead of a visual VT-1 examination as specified in Table IWB-2500-1 of the 2004 edition of the ASME Code,Section XI, Subsection IWB. The staff further noted that LRA Section B2.1.3 does not identify this alternative volumetric examination as an exception of the program. Therefore, the staff found a need to clarify why the alternative volumetric examination of the stud inserts is not an exception in the applicant's program. The staff will consider issuing RAls for this.

- 8 In its review, the staff finds that the reduced load bearing surfaces of the partially damaged (rolled) stud insert increase the stress levels applied to the lugs of the stud insert such that loss of material due to wear and cracking due to stress corrosion cracking may be facilitated. In addition, the partially damaged stud insert may cause partial engagement and galling of the stud bolting, and adversely affect the prevention of reactor vessel flange leakage. Therefore, the staff also found a need to confirm why the continuous use of the partially damaged stud insert is acceptable to manage loss of material.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that LRA AMP program elements "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" are consistent with the corresponding program elements in the GALL Report AMP. The staff also verified that aspects of LRA AMP program element "scope of program" not associated with the exception are consistent with the corresponding program element in the GALL Report. The staff's evaluation of aspects of the element associated with the exception will be addressed in the SER. The staff also determined certain aspects of LRA AMP program element "preventive actions" will require additional information or additional evaluation before consistency can be determined.

Based on this audit, the staff also identified that additional information regarding operating experience is required before a determination can be made regarding the sufficiency of the LRA AMP, as implemented by the applicant, to detect and manage aging. In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

Existing Program Consistent with the GALL Report with Enhancement(s), LRA AMP B2.1.4, "Boric Acid Corrosion" Summary of Information in the Application: The LRA states that AMP B2.1.4, "Boric Acid Corrosion," is an existing program with one enhancement that is consistent with the program elements in GALL AMP XI,M1 0, "Boric Acid Corrosion." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER.

The enhancement affects the LRA AMP "scope of program" program element. The LRA states that procedures will be enhanced to state that susceptible components adjacent to potential leakage sources will include electrical components and connectors and other materials, such as aluminum and copper alloys, that are susceptible to boric acid corrosion.

In Table A4-1 of the LRA, the applicant committed (Commitment No.2) to implement the enhancement prior to the period of extended operation.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of

- 9 the applicant's operating experience database using the following search terms: "corrosion,"

"degradation," "piping," "copper," and "perforation."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. STP-AMP-B2.1.4 South Texas Project Aging Management Program Evaluation Report Boric Acid Corrosion - B2.1.4 Revision 2, 4/27/2011 2.0PGP03-ZE-0133 Boric Acid Corrosion Control Program Revision 3.

9/30/2010

3. CR 10-2072 Condition Record 2/4/2010

4. OPGP03-ZE-0033 RCS Pressure Boundary Inspection for Boric Acid Leaks Revision 10, 7/14/2008

5. OPGP03-ZA-0133 Fluid Leak Management Program Revision 2, 11/05/2007

6. CR 07-18971 Condition Record 10/22/2008

7. CR 08-2840 Condition Record 6/24/2009

8. OPGP03-ZE-0033 RCS Pressure Boundary Inspection for Boric Acid Leaks Revision 12, 3/23/2011 The staff conducted its audit of LRA AMP program elements one through six based on the contents of the existing program as modified by the proposed enhancement.

During the audit, the staff found that program elements "scope of program," "preventive actions,"

"parameters monitored or inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that LRA program elements "scope of program," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," "acceptance criteria," and "operating experience," are consistent with the corresponding program elements in the GALL Report AMP.

- 10 Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.

In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

Existing Program Consistent with the GALL Report, LRA AMP 82.1.5, "Nickel-Alloy Penetration Nozzles welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors" Summary of Information in the Application: The LRA states that AMP B2.1.5, "Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors," is an existing program that is consistent with the program elements in GALL AMP XI.M11A, "Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER.

Audit Activities: Due to the nature of this AMP, the staff was able to verify that the applicant is capable of managing the aging of nickel-alloy penetration nozzles welded to the upper reactor vessel closure heads without conducting a full audit of AMP program elements 1 - 6. The basis for this verification follows.

The applicant filed its license renewal application in accordance with the GALL Report, Revision 1 (AMP XI.M11A). GALL AMP XI.M11A manages the aging of applicable components based on Commission Order EA-03-009 as revised/amended. This order has been superseded. The staff, however, notes that the applicant in its LRA stated that its existing program has been enhanced to meet ASME Code Case N-729-1, subject to the conditions specified in 10 CFR 50.55a(g)(6)(ii)(0).

Subsequent to the submission of the LRA, the staff issued the GALL Report, Revision 2. In the GALL Report, Revision 2, the AMPs XI.M11 and XI.M11A are combined in AMP XI.M11 B, "Cracking of Nickel-Alloy Components and Loss of Material due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components (PWRs Only)." This AMP ensures the adequacy of aging management for upper head penetrations by recommending the use of ASME Code Case N-729-1, "Alternative Examination Requirements for PWR Reactor Vessel Upper Heads with Nozzles Having Pressure-Retaining Partial-Penetration Welds,Section XI, Division 1." Based on the GALL Report, Revision 2, consistency with Code Case N-729-1 is deemed to be consistent with program elements 1 - 6 of the AMP, as the AMP recommends no actions beyond those contained in the code case.

Prior to the issuance of the GALL Report, Revision 2, the staff revised 10 CFR 50.55.a. 10 CFR 50.55a, paragraph (g)(6)(iO(0), mandates the use of Code Case N-729-1 subject to the conditions specified in paragraphs (g)(6)(ii)(0)(2) through (6).

- 11 Based on the above, the staff notes: that the applicant has committed in its LRA to the use of code case N-729-1; that, according to the GALL Report, Revision 2, AMP XI.M11 B, the use of code case N-729-1 provides an acceptable method of aging management; and that 10 CFR 50.55a(g)(6)(ii)(0) mandates the use of code case N-729-1 and precludes any variation between the LRA AMP and the GALL AMP. As a result of the inability of the applicant to deviate from an acceptable approach to the management of aging of upper head penetrations, a detailed audit of each of program elements 1 - 6 of the LRA AMP is unnecessary.

In addition to AMP program elements 1 - 6, the staff considered program element 10, "Operational Experience" during this audit. The staff notes that the head for Unit 1 was replaced during refueling outage 1 RE15 (October 2009) and the head for Unit 2 was replaced during refueling outage 2RE14 (April 2010). The staff also notes that the components penetrating the new heads were fabricated and welded using PWSCC resistant materials. Oue to the recent nature of these head replacements, no operating experience is expected. Additionally, the staff is not aware of any industry operating experience which is not bounded by code case N-729-1.

The staff further notes that the LRA indicates that operating experience will be incorporated into the program as it becomes available. The staff finally notes that 10 CFR 50.55a(g)(6)(ii)(0)(6) mandates the incorporation of operating experience in the use of code case N-729-1 in that, if flaws are discovered, the inspection interval permitted by the code case is reduced. Based on the available operating experience the staff finds no reason to believe that the aging management approach, i.e., code case N-729-1, proposed by the applicant, recommended by the GALL AMP and required by 10 CFR 50.55a(g)(6)(ii)(0) will not be effective in managing the aging of the applicable components.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description varied considerably from that included in the SRP-LR Revision 1.

However, given the changes to the program which are recommended in the GALL Report, Revision 2, and required by 10 CFR 50.55a, the program description provided in the UFSAR supplement constitutes an adequate description of the program.

Audit Results: Based on this audit, the staff determined that the recommendations for aging management of upper head penetrations contained in the GALL Report, Revision 1, have been superseded. The staff also determined that the program recommended for aging management of upper head penetrations recommended by the GALL Report, Revision 2, is the implementation of ASME Code Case N-729-1. The GALL Report, Revision 2, does not recommend any actions in addition to this code case for the aging management of upper head penetrations. The staff further determined that the use of Code Case N-729-1 is mandated by 10 CFR 50.55a(g)(6)(ii)(0) subject to the conditions specified in paragraphs (g)(6)(ii)(0)(2) through (6). The staff finally determined that the LRA states that the applicant's program consists of complying with 10 CFR 50.55a(g)(6)(ii)(0), i.e., Code Case N-729-1. Based on the above, the staff finds that the applicant's AMP is consistent with the program recommended by the GALL Report, Revision 2, and subject to inspection verification, meets the requirements of 10 CFR 50.55a(g)(6)(ii)(0).

Also based on this audit, the staff found no industry or plant specific operating experience which would indicate that the LRA AMP or the regulatory requirements of 10 CFR 50.55a(g)(6)(ii)(0) would be ineffective in detecting or managing aging of upper head penetrations.

- 12 Finally, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

Existing Program Consistent with the GALL Report with Exception(s), LRA AMP 82.1.6, "Flow-Accelerated Corrosion" Summary of Information in the Application: The LRA states that AMP B2.1.6, "Flow-Accelerated Corrosion," is an existing program with an exception that is consistent with the program elements in GALL AMP XI.M17, "Flow-Accelerated Corrosion." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER. This audit report does not consider the sufficiency of the exception; this will be evaluated in the SER.

The exception affects the LRA "scope of program," and "detection of aging effects," program elements. The LRA states that STP uses the recommendations provided in EPRI Guideline NSAC-202L-R3, which is an update that became available since the GALL recommendation was made for the AMP to use EPRI Guideline NSAC-202L-R2.

As stated above, the staff did not evaluate the sufficiency of this exception during the audit. The staff's evaluation of the adequacy of this exception will be documented in the SER.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the following search terms: "wall thinning,"

"flow accelerated," "perforation," "through wall/' and "piping."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date 1.0PGP04-ZA-0012 Flow-Accelerated Corrosion Program Revision 4, 5/17/2011

2. OPGP04-ZA-0002 Condition Record Engineering Evaluation Revision 15, 2/16/2011

3. STI32233163 Flow-Accelerated Corrosion Program Manual Revision 5, 1/3/2008

4. CR 05-6558 Condition Record 5/4/2005

5. CR 01-15470 Condition Record 10/3/2001 The staff conducted its audit of LRA AMP program elements one through six based on the contents of the existing program. Aspects of program elements "scope of program" and "detection of aging effects" of the LRA AMP associated with the exception were not evaluated during this audit. Aspects of these program elements that are not associated with the exception were evaluated and are described below.

- 13 During the audit, the staff found that program elements "preventive actions," "parameters monitored or inspected," "monitoring and trending," and "acceptance criteria" of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff also found that aspects of program elements "scope of program" and "detection of aging effects" not associated with the exceptions are consistent with the corresponding program elements in the GALL Report AMP. The staff's evaluation of aspects of these program elements associated with the exception will be addressed in the SER.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that LRA program elements "preventive actions," "parameters monitored or inspected," "monitoring and trending," "acceptance criteria,"

and "operating experience" are consistent with the corresponding program elements in the GALL Report AMP. The staff also verified that aspects of LRA program elements "scope of program" and "detection of aging effects" not associated with the exceptions are consistent with the corresponding program elements in the GALL Report. The staff's evaluation of aspects of elements associated with exceptions will be addressed in the SER.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.

In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

Existing Program Consistent with the GALL Report with Exception(s) and Enhancement(s), LRA AMP 82.1.7, "Bolting Integrity" Summary of Information in the Application: The LRA states that AMP B2.1.7, "Bolting Integrity,"

is an existing program with exceptions that is consistent with the program elements in GALL AMP XI.M18, "Bolting Integrity." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER. This audit report does not consider the sufficiency of exceptions, which will be evaluated in the SER.

The first exception affects the LRA AMP "scope of program" program element. The LRA states that the LRA AMP does not reference EPRI TR-104213 as an applicable source document, but instead refers to EPRI NP-5067, EPRI NP-5769,and NUREG-1339 and states that the use of these documents is consistent with the use of EPRI TR-104213.

- 14 The second exception affects the LRA AMP "parameters monitored or inspected" program element. The LRA states that loss of preload is not a parameter of inspection for this program.

It states that the use of good bolting techniques provided by vendors and plant procedures is sufficient to minimize the possibility of loss of preload. It also states that these practices, along with visual inspections for leakage, will detect a loss of preload/prestress prior to a loss of intended function.

The third exception affects the LRA AMP "monitoring and trending" program element. The LRA states that, when a leak is detected, the inspection frequency will be adjusted as necessary based on the trending of inspection results.

As stated above, the staff did not evaluate the sufficiency of these exceptions during the audit.

The staff's evaluation of the adequacy of the exceptions will be documented in the SER.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the following search terms: "bolt,"

"corrosion," "mission," "SCC," "rus!," "fatigue," "wear," "degradation," and "pitting."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. STP-AMP-B2.1.11 South Texas Project Aging Management Program Evaluation Report Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems -B2.1.11 Revision 4, 04/27/2011

2. OPMP02-ZG-0004 Bolted Joint Procedure Revision 14.

03/26/2005

3. OPGP03-ZE-0027 ASME Section XI Repair, Replacement and Post-Maintenance Pressure Testing Revision 28, 06/18/2009 4.0PEP10-ZA-0023 System Pressure Testing Program Revision 19, 12/10/2008

• 5. OPGP04-ZE-0304 Inservice Inspection Program For Welds and Component Supports Revision 7, 10/22/2008 6.0PEP10-ZA-0024 ASME XI Examination for VT-1 and VT-3 Revision 1, 08/28/2002

7. OPSP11-RC-0015 ASME Section XI Inservice Inspection Revision 13, 10/21/2008

8. OPGP03-ZE-0049 Structural Steel Revision 6, 08/25/1999

9. CR 01-1673 Condition Record 01/30/2001

10. CR 01-17209 Condition Record 10/20/2001

11. CR 02-12652 Condition Record 09/10/2002

12. CR 03-5854 Condition Record 04/08/2003

13. CR 05-5162 Condition Record 04/06/2005

14. CR 05-15760 Condition Record 12/01/2005

- 15 Document

15. CR 06-2088

16. CR 06-16081 Title Revision I Date Condition Record Condition Record 02/08/2006 11/20/2006 The staff conducted its audit of LRA AMP program elements one through six based on the contents of the existing program. Aspects of program elements "scope of program,"

"parameters monitored or inspected" and "monitoring and trending" of the LRA AMP associated with the exceptions were not evaluated during this audit. Aspects of these program elements that are not associated with the exceptions were evaluated and are described below.

During the audit, the staff found that program elements "preventive actions" and "acceptance criteria" of the LRA AMP are consistent with the corresponding elements of the GALL AMP.

The staff also found that aspects of program elements "parameters monitored or inspected" and "monitoring and trending" not associated with the exceptions are consistent with the corresponding program elements in the GALL AMP. The staff's evaluation of aspects of these program elements associated with the exceptions will be addressed in the SER. In addition, the staff found that for program elements "scope of program" and "detection of aging effects" sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAls for the subjects discussed below:

The "scope of program" program element of the LRA AMP states that EPRI TR-104213 is not referenced or incorporated in the procedures for this AMP. In the place of EPRI TR-104213 the LRA AMP uses EPRI NP-5067. The GALL Report AMP recommends following the industry recommendations provided in EPRI TR-104213. It is not clear to the staff that these statements are consistent because the recommendations given in EPRI NP-5067 may not equal the recommendations provided in EPRI TR-104213.

The "detection of aging effects" program element of the LRA AMP states that based on plant operating experience, high strength structural bolting greater than 1 inch nominal diameter does not need to be inspected using volumetric examination. The GALL Report AMP recommends using volumetric examination to inspect high strength structural bolting larger than 1 inch nominal diameter for signs of cracking. It is not clear to the staff that these statements are consistent because volumetric examination to detect cracking in high strength structural bolting greater than 1 inch nominal diameter is recommended by the GALL Report, but would not be performed by this LRA AMP.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (I.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.

- 16 The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that the "preventive actions," "acceptance criteria," and "operating experience" LRA program elements are consistent with the corresponding program elements in the GALL Report AMP. The staff also verified that aspects of LRA program elements "parameters monitored or inspected" and "monitoring and trending" not associated with the exceptions are consistent with the corresponding program elements in the GALL Report. The staff's evaluation of aspects of elements associated with exceptions will be addressed in the SER. The staff also determined that certain aspects of LRA AMP program elements "scope of program" and "detection of aging effects" will require additional information or additional evaluation before consistency can be before consistency can be determined.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.

In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

Existing Program Consistent with the GALL Report, LRA AMP 82.1.8, "Steam Generator Tube Integrity" Summary of Information in the Application: The LRA states that AMP B2.1.8, "Steam Generator Tube Integrity Program," is an existing program that is consistent with the program elements in GALL AMP XI.M19, "Steam Generator Tube Integrity." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicant's operating experience database using the keyword, "steam generator."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. STP-AMP Steam Generator Tubing Integrity Revision 3, 4/27/2011 i

2. OPGP04-ZE-0305 Inservice Inspection Program for Steam Generator Tubing Revision 4, 9/28/2006

3. OPGP03-Z0-0044 Steam Generator Management Program Revision 3, 7/30/2006

4. OPGP03-Z0-0041 Action for Monitoring Primary to Secondary Leakage Revision 14,

...J!..11/20Q5_

- 17 During the audit of program elements one through six, the staff found that program elements "scope of program," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation. In order to obtain the information necessary to verify whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAls for the subjects discussed below.

In LRA Table 3.1.1, the applicant stated that cracking due to primary water stress corrosion cracking (PWSCC) on the primary coolant side of PWR steam generator (SG) tube to tubesheet welds made or clad with nickel alloy is not applicable because they do not have once-through steam generators. The LRA does not provide information on the tubesheet clad material or the tube-to-tubesheet weld region.

From foreign operating experience in SGs with a similar design to that of STP SGs, cracking due to PWSCC has been identified in SG divider plate assemblies made with Alloy 600, even with proper primary water chemistry. Specifically, cracks have been detected in the stub runner, very close to the tubesheet/stub runner weld and with depths of almost a third of the divider plate thickness. Therefore, the staff notes that the water chemistry program alone does not appear to be effective in managing the aging effect of cracking due to PWSCC in SG divider plate assemblies. The LRA does not provide information on the SG divider plate assemblies.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that LRA AMP program elements "scope of program," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," "acceptance criteria," and "operating experience" are consistent with the corresponding program elements in the GALL Report AMP.

Based on this audit, the staff also identified that additional information regarding operating experience is required before a determination can be made regarding the sufficiency of the LRA AMP, as implemented by the applicant, to detect and manage aging. In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

- 18 Existing Program Consistent with the GALL Report with Exception(s) and Enhancement(s), LRA AMP B2.1.9, "Open-Cycle Cooling Water System" Summary of Information in the Application: The LRA states that AMP B2.1.9, "Open-Cycle Cooling Water System," is an existing program with enhancement and exception that is consistent with the program elements in GALL AMP XI,M20, "Open-Cycle Cooling Water System." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER. This audit report does not consider the sufficiency of exceptions, which will be evaluated in the SER.

The exception affects the LRA AMP "preventive actions," "parameters monitored or inspected,"

and "detection of aging effects" program elements. The LRA states that an exception is taken to flushing the Essential Cooling Water (ECW) train cross-tie dead legs and inspecting the interior of these lines. Instead, the LRA states that the external surfaces of the cross-tie lines are included in the six month dealloying visual external inspection walkdowns; and that the cross-tie valves and piping are included in the ECW system inservice pressure test, which includes a VT 2 inspection of these components.

As stated above, the staff did not evaluate the sufficiency of this exception during the audit. The staff's evaluation of the adequacy of this exception will be documented in the SER.

The enhancement affects the LRA AMP "parameters monitored or inspected" and "detection of aging effects" program elements. The LRA states procedures will be enhanced to include visual inspections of the strainer inlet area and the interior surfaces of the adjacent upstream and downstream piping. The LRA states that these inspections will provide visual evidence of loss of material and fouling in the ECW system and serve as an indicator of the condition of the interior of ECW system piping components otherwise inaccessible for visual inspection. The LRA also states that procedures will be enhanced to include the acceptance criteria for this visual inspection.

In Appendix A, Table A4-1 of the LRA, the applicant committed (Commitment No.4) to implement this enhancement prior to the period of extended operation.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the balance of plant (BOP) diesel generator room, including diesel generators and cooling water radiators; the ECW intake structure pump, strainer, and traveling water screen areas; the standby diesel generator building ECW cooling components; and the mechanical auxiliary building ECW components including component cooling water (CCW) -- ECW heat exchangers and piping, CCW pump, ECW chillers, and the ECW sump area, which includes the ECW cross tie valves and piping dead legs. The staff also conducted an independent search of the applicant's operating experience database using the following search terms: "biofoul,"

"microbiological," "inspection," "corrosion." "erosion," "coating," and "cavitation."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

- 19 Relevant Documents Reviewed Document Title Revision { Date

1. STP-AMP-B2.1. 9 South Texas Project Aging Management Program Revision 3 Evaluation Report Open-Cycle Cooling Water System 4/27/2011 B2.1.9 I 2. ST-HL-AE-3341 South Texas Project Dockets Nos. STN 50-498, STN 50 1/29/1990 499 Response to NRC Generic Letter 89-13, "Service Water System Problems Affecting Safety-Related Equipment"

3. ST-HL-AE-3720 South Texas Project Dockets Nos. STN 50-498, STN 50 3/27/1991 499 Response to NRC Generic Letter 89-13, "Service Water System Problems Affecting Safety-Related Equipment"

4. ST-HL-AE-3701 South Texas Project Dockets Nos. STN 50-498, STN 50 4/03/1991 499 Revised Schedule for NRC Generic Letter 89-13, "Service Water System Problems Affecting Safety-Related Equipment"

5. ST-HL-AE-3761 South Texas Project Dockets Nos. STN 50-498, STN 50 5/15/1991 499 Supplemental Response to NRC Generic Letter 89-13, "Service Water System Problems Affecting Safety-Related Equipment"

6. ST-HL-AE-4126 South Texas Project Dockets Nos. STN 50-498, STN 50 6/23/1992 499 Revised Response to NRC Generic Letter 89-13, "Service Water System Problems Affecting Safety-Related Equipment" 7.0PCP01-ZQ-0004 Cooling Water System Inspection Guidelines Revision 2,

• 12/18/2001 8.0PCP01-ZA-0038 Plant Chemistry Specifications Revision 37, 4/07/2009

9. OPOP02-EW-0001 Essential Cooling Water Operations Revision 47, 6/12/2009

10. OPGP03-ZM-0002 Preventive Maintenance Program Revision 34, 7/02/2008

• 11. STI 323497708 Conduct of Chemistry, Chapter 14, Service (Open Loop)

Cooling Water Chemistry StrategiC Plan Revision 0, 8/18/2008

12. LER 4992010001 Licensee Event Report Unit 2 Essential Cooling Water (ECW) 12/14/2009

, 13. LER 4992005004 Licensee Event Report Essential Cooling Water (ECW) 7/11/2005 J

I The staff conducted its audit of LRA AMP program elements one through six based on the contents of the existing program as modified by the proposed enhancements. Aspects of program elements "preventive actions," "parameters monitored or inspected," and "detection of aging effects," of the LRA AMP associated with the exception were not evaluated during this audit. Aspects of these program elements that are not associated with the exception were evaluated and are described below.

During the audit, the staff found that program elements "scope of program," "monitoring and trending," and "acceptance criteria" of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff also found that aspects of program elements "preventive actions," "parameters monitored or inspected," and "detection of aging effects," not associated with the exceptions are consistent with the corresponding program elements in the

- 20 GALL Report AMP. The staff's evaluation of aspects of these program elements associated with the exception will be addressed in the SER.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR Supplement was an adequate description of the LRA AMP. In order to obtain the information necessary to verify the sufficiency of the UFSAR Supplement program description, the staff will consider issuing RAls for the following subject:

UFSAR Supplement LRA Section A 1.9 states the Open-Cycle Cooling Water System program manages aging effects of cracking, loss of material, and reduction of heat transfer. This is also stated in the Program Description of LRA Section B2.1.9, but cracking is not addressed in the AMP program elements. GALL AMP XI,M20 does not include cracking as an aging effect requiring management by the Open-Cycle Cooling Water System program. In addition, the LRA does not include AMR Table 2 line items in which the Open-Cycle Cooling Water System program manages the aging effect of cracking.

Audit Results: Based on this audit, the staff verified that LRA AMP program elements "scope of program," "monitoring and trending," "acceptance criteria," and "operating experience," are consistent with the corresponding program elements in the GALL Report AMP. The staff also verified that, for the "preventive actions," "parameters monitored or inspected," and "detection of aging effects" elements, the aspects of the LRA AMP program elements that are not associated with the exception are consistent with the corresponding program elements in the GALL Report.

The staff's evaluation of aspects of elements associated with exceptions will be addressed in the SER.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.

In addition, the staff identified a need for additional information regarding the adequacy of the program description in the UFSAR Supplement.

Existing Program Consistent with the GALL Report with Exception(s) and Enhancement(s), LRA AMP 82.1.10, "Closed-Cycle Cooling Water System" Summary of Information in the Application: The LRA states that AMP B2.1.10, "Closed-Cycle Cooling Water System," is an existing program with enhancements and exceptions that is consistent with the program elements in GALL AMP XI.M21A, "Closed Treated Water Systems."

- 21 To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER. This audit report does not consider the sufficiency of exceptions, which will be evaluated in the SER.

The first exception affects the LRA AMP "preventive actions," "parameters monitored or inspected," and "acceptance criteria" program elements. The LRA states that, since chloride and fluoride are monitored as diagnostic parameters in the HVAC chilled water systems with an alert value of 5 ppm, the applicant's practice is more restrictive than the EPRI guideline (EPRI TR-107396, Revision 1) control parameter normal operating range of less than or equal to 10 ppm. The LRA also states that the chemistry control is consistent with, but not identical to, the EPRI recommended approach. The staff noted that EPRI TR-107396, Revision 1, is the EPRI guideline document 1007820 that is referenced in GALL AMP XLM21A.

The second exception affects the LRA AMP "parameters monitored or inspected," "detection of aging effects," and "monitoring and trending" program elements. The LRA states that performance/functional testing is not performed on the heat exchangers served by closed-cycle cooling water systems, since this is not required in EPRI TR-107396, Revision 1, guidance. The LRA also states that reduction of heat transfer is managed through a combination of chemistry controls and inspection activities.

The third exception affects the LRA AMP "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" program elements. The LRA states that the Closed-Cycle Cooling Water System Program is based on the 2004 version of the EPRI Closed Cooling Water Chemistry Guideline (TR-107396, Revision 1) rather than the 1997 version (TR-107396, Revision 0).

As stated above, the staff did not evaluate the sufficiency of these exceptions during the audit.

The staff's evaluation of the adequacy of these exceptions will be documented in the SER.

The first enhancement affects the LRA AMP "detection of aging effects," "monitoring and trending," "acceptance criteria," and "corrective actions" program elements. The LRA states that procedures will be enhanced to include visual inspection of the interior of the piping that is attached to the excess letdown heat exchanger component cooling water (CCW) return second check valves. The LRA states that this periodic internal inspection will detect loss of material and fouling and serve as a leading indicator of the condition of the interior of piping components otherwise inaccessible for visual inspection.

The second enhancement affects the LRA AMP "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," "acceptance criteria," and "corrective actions" program elements. The LRA states that procedures will be enhanced to monitor chemistry parameters consistent with EPRI guidelines for the glycol-based formulations used for the BOP and fire pump diesel jack water cooling systems. The LRA also states that the EPRI TR-107396, Revision 1 guidelines recommend periodic monitoring of control and diagnostic parameters.

In Table A4-1 of the LRA, the applicant committed (Commitment No.5) to implement these enhancements prior to the period of extended operation.

- 22 Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the BOP diesel generator room including diesel generator cooling water and radiators; the standby diesel generator building including CCW jacket water coolers and lube oil coolers; and the mechanical auxiliary building including CCW heat exchangers and piping, pump, and chemical addition and sampling stations. The staff also conducted an independent search of the applicant's operating experience database using the following search terms: "cavitation,"

"coating," "cracking," "erosion," "inspection," "loss of material," and "corrosion."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Revision I Date Title Document South Texas Project Aging Management Program Revision 5, Evaluation Report Closed-Cycle Cooling Water System

. 6/01/2011 B2.1.10

1. STP-AMP-B2.1.1 0

2. OPOP02-CC-0001 Component Cooling Water Revision 34, 10/03/2008

3. EPRI TR-107396 Closed Cooling Water Chemistry Guideline (issued as TR-Revision 1, 1007820) 4/2004

4. OPGP03-Z0-0012 Plant Systems Chemistry Control Revision 17, 4/07/2009 5.0PCP01-ZA-0038 Plant Chemistry Specifications Revision 37, 4/07/2009 i

6. TR-8ST Aging Effects Position Paper Revision 1, I

10/27/2010

7. OPOP02-CC-0001 Component Cooling Water Revision 34, 10103/2008

8. ST-HL-AE-3341 South Texas Project Dockets Nos. STN 50-498, STN 50 Revision 0, 499 Response to NRC Generic Letter 89-13, "Service 1/29/1990 Water System Problems Affecting Safety-Related Equipment" The staff conducted its audit of LRA AMP program elements one through six based on the contents of the existing program as modified by the proposed enhancements. Aspects of program elements "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" of the LRA AMP associated with the exceptions were not evaluated during this audit. Aspects of these program elements that are not associated with the exceptions were evaluated and are described below.

During the audit, the staff found that aspects of program elements "preventive actions,"

"acceptance criteria," and "corrective actions" not associated with the exceptions are consistent with the corresponding program elements in the GALL Report AMP. The staff's evaluation of aspects of these program elements associated with the exceptions will be addressed in the SER In addition, the staff found that for program elements "scope of program," "parameters monitored or inspected," "detection of aging effects," and "monitoring and trending," sufficient information was not available to determine whether they were consistent with the corresponding

- 23 program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAls for the subjects discussed below:

The "detection of aging effects" program element of the LRA AMP states it will be enhanced to include visual inspection of the interior of the piping that is attached to the excess letdown heat exchanger CCW return second check valves. The GALL Report AMP recommends that inspections are conducted whenever the system boundary is opened and that a representative sample of piping and components is selected and inspected at an interval not to exceed once in 10 years. It is not clear to the staff that these statements are consistent, because the LRA AMP does not specify opportunistic inspections or an inspection interval. Also, the identified inspection location may not represent all the material-environment combinations managed by the LRA AMP.

The "scope of program," "parameters monitored or inspected," and "monitoring and trending" program elements of the LRA AMP do not specify cracking as an aging effect requiring management, which is not consistent with the GALL Report AMP. The staff noted that the LRA AMP Program Description does include cracking; in addition, there are LRA line items that manage cracking using the Closed-Cycle Cooling Water System AMP (e.g., RHR heat exchangers).

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (I.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that aspects of LRA program elements "preventive actions," "acceptance criteria," and "corrective actions" not associated with the exceptions are consistent with the corresponding program elements in the GALL Report. The staff's evaluation of aspects of elements associated with exceptions will be addressed in the SER The staff also determined that certain aspects of LRA AMP program elements "scope of program," "parameters monitored or inspected," "detection of aging effects," and "monitoring and trending" will require additional information or additional evaluation before consistency can be determined.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.

In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

- 24 Existing Program Consistent with the GALL Report with Enhancement{s), LRA AMP 82.1.11, "Inspection of Overhead Heavy Load and Light Load (Related to Refueling)

Handling Systems" Summary of Information in the Application: The LRA states that AMP B2.1.11, "Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems," is an existing program with enhancements that is consistent with the program elements in GALL AMP XI.M23, "Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems."

To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER The first enhancement affects the LRA AMP "parameters monitored or inspected" program element. The applicant's onsite documentation states that procedures OPMP02-ZG-0003A and OPMP02-ZG-0003B, and PMs 96000655 and 96000656 will be enhanced to inspect crane structural members for loss of material due to corrosion. It also states that procedures OPMP02-ZG-0003C and OPMP02-ZG-0003D, and PMs 01000275 and 01000276 will be enhanced to inspect crane structural members for loss of material due to corrosion and rail wear.

The second enhancement affects the LRA AMP "detection of aging effects" program element.

The applicant's onsite documentation states that procedures OPMP02-ZG-0003A and OPMP02-ZG-0003B, and PMs 96000655 and 96000656 will be enhanced to inspect crane structural members for loss of material due to corrosion. It also states that procedures OPMP02-ZG-0003C and OPMP02-ZG-0003D, and PMs 01000275 and 01000276 will be enhanced to inspect crane structural members for loss of material due to corrosion and rail wear.

In Table A4-1 of the LRA, the applicant committed (Commitment No.6) to implement these enhancements prior to the period of extended operation.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the spent fuel shipping cask crane, the spent fuel handling crane, Unit 1 & 2 component cooling pump monorails and hoists, and the emergency diesel generator crane. The staff also conducted an independent search of the applicant's operating experiel1ce database using the following search terms: "crane," "hoist," "SCC," "rust," "corrosion," "pitting," "loss of material,"

"degradation," "fatigue," "coating," and "wear."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

- 25 Relevant Documents Reviewed Revision I Date Document South Texas Project Aging Management Program

. Revision 3, Evaluation Report

1. STP-AMP-82.1.11 i 04/27/2011 i Inspection of Overhead Heavy Load and Light Load (Related to RefuelinQ) HandlinQ Systems -82.1.11 Title Revision 3, Inspection for Multi-Hoist Cranes

2. OPMP02-ZG-0003D 03/17/2010 Revision 22 Control of Heavy Loads

3. OPGP03-ZA-0069 07/30/2009 Revision 5, Inspection for Jib Cranes

4. OPMP02-ZG-00038 09/27/2010 Revision 3, Inspection for Single Hoist Cranes

5. OPMP02-ZG-0003C 03/17/2010 Revision 1, Inspection for Hoists

6. OPMP02-ZG-0003A 02/09/2009 10/31/2001 Condition Record

7. CR 01~18049 11/12/2001 Condition Record

8. CR 01-18558 02/12/2003

9. CR 03-2279 Condition Record 04/15/2004 Condition Record

10. CR 04-5522 06/19/2004

11. CR 04-8788 Condition Record 07/22/2004

12. CR 04-10213 Condition Record 08/03/2006

13. CR 06-9805 Condition Record 08/03/2006

14. CR 06-9807 Condition Record 11/0412009

15. CR 09-18221 Condition Record The staff conducted its audit of LRA AMP program elements one through six based on the contents of the existing program as modified by the proposed enhancements.

During the audit, the staff found that program elements "scope of program," "preventive actions,"

"parameters monitored or inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that the "scope of program," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and

- 26 trending," "acceptance criteria," and "operating experience" LRA program elements are consistent with the corresponding program elements in the GALL Report AMP.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.

In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

Existing Program Consistent with the GALL Report with Exception(s) and Enhancement(s), LRA AMP 82.1.12, "Fire Protection" Summary of Information in the Application: The LRA states that AMP B2.1.12, "Fire Protection" is an existing program, with enhancements and an exception, that is consistent with the program elements in GALL AMP XI.M26, "Fire Protection." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER. This audit report does not consider the sufficiency of exceptions, which will be evaluated in the SER.

The exception affects the LRA "parameters monitored or inspected" and "detection of aging effects" program elements. The LRA states that the functional testing of the Halon fire suppression system is performed every 18 months. The LRA further states that the18-month functional testing interval, together with visual inspection performed on a six-month interval, provides assurance that intended function will be maintained through the period of extended operation.

As stated above, the staff did not evaluate the sufficiency of this exception during the audit. The staff's evaluation of the adequacy of this exception will be documented in the SER.

The first enhancement affects the LRA AMP "parameters monitored or inspected," "detection of aging effects," and "acceptance criteria" program elements. The LRA states that procedures will be enhanced to provide visual inspection for degradation, corrosion and mechanical damage of the Halon system at least once every six rnonths.

The second enhancement affects the LRA AMP "parameters monitored or inspected" and "detection of aging effects" program elements. The LRA states that procedures will be enhanced to provide inspections to detect penetration seal deficiencies, including signs of degradation such as cracking, seal separation, separation of layers of material, and rupture and puncture of seals.

The third enhancement affects the LRA "detection of aging effects" program element. The LRA states that procedures will be enhanced to include qualification criteria for individuals performing inspections of fire doors, fire barrier penetration seals, and fire barrier walls, ceilings, and floors.

The fourth enhancement affects the LRA AMP "acceptance criteria" program element. The LRA states that procedures will be enhanced to include additional acceptance criteria, including no cracks, spalling, or loss of material that would prevent the barrier from performing its design function.

- 27 In LRA Appendix A Table A4-1, the applicant committed (Commitment No.7) to implement these enhancements prior to the period of extended operation.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the fire protection yard area including the fire pump house, fire water storage tanks, and various hose stations, fire protection water lines, and sprinkler systems throughout the balance of plant (BOP), standby diesel generator rooms, and the mechanical auxiliary building. The staff also conducted an independent search of the applicant's operating experience database using the following search terms: "buried," "corrosion," "tank," "underground," "piping," and "degradation."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Protection

2. OPGP03-ZT-0131 Fire Protection Training and Qualification Program Revision I Date Revision 2, 8/10/2010 Revision 7, i 1/11/2007

.3. OPTP03-FP-0125 I Fire Rated Assembly Vi~

Revision 5, 2/21/2006 P03-FP-0108

' Halon System Automatic Actuation Verification Revision 7, 1/31/2006

14. OPT

~ 05-10487 Condition Record 2/7/2009

~~R 05-8031 Condition Record 10/15/2010 The staff conducted its audit of LRA AMP program elements one through six based on the contents of the existing program as modified by the proposed enhancements. Aspects of the "parameters monitored or inspected" and "detection of aging effects" program elements of the LRA AMP associated with the exception were not evaluated during this audit. Aspects of these program elements that are not associated with the exception were evaluated and are described below.

During the audit, the staff found that the "scope of program," "preventive actions," "monitoring and trending," and "acceptance criteria" program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff also found that aspects of the "parameters monitored or inspected" and "detection of aging effects" program elements that are not associated with the exceptions are consistent with the corresponding program elements in the GALL Report AMP. The staff's evaluation of the aspects of these program elements associated with the exception will be addressed in the SER.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent

- 28 database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit. the staff verified that the LRA AMP "scope of program,"

"preventive actions," "monitoring and trending," "acceptance criteria," and "operating experience" program elements are consistent with the corresponding program elements in the GALL Report AMP. The staff also verified that the aspects of the LRA "parameters monitored or inspected" and "detection of aging effects" program elements not associated with the exception are consistent with the corresponding program elements in the GALL Report. The staff's evaluation of the aspects of those elements associated with exceptions will be addressed in the SER.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.

In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

Existing Program Consistent with the GALL Report with Exception(s) and Enhancement(s), LRA AMP 82.1.13, "Fire Water System" Summary of Information in the Application: The LRA states that AMP B2.1.13, "Fire Water System" is an existing program with enhancements and exceptions that is consistent with the program elements in GALL AMP XI.M27, "Fire Water System." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER. This audit report does not consider the sufficiency of exceptions, which will be evaluated in the SER.

The first exception affects the LRA AMP "scope of program" program element. The LRA states that although the GALL Report AMP manages steel components in the fire protection system, the Fire Water System program manages aging effects of copper alloy and stainless steel fire water system components.

The second exception affects the LRA AMP "detection of aging effects" program element. The LRA states that STP performs power block hose station gasket inspections at least once every 18 months, rather than annually as specified by NFPA-25 referenced in the GALL Report.

As stated above, the staff did not evaluate the sufficiency of these exceptions during the audit.

The staffs evaluation of the adequacy of these exceptions will be documented in the SER.

- 29 The first enhancement affects the LRA AMP "preventive actions," "parameters monitored or inspected," and "detection of aging effects" program elements. The LRA states that procedures will be enhanced to include volumetric examinations or direct measurement on representative locations of the fire water system to determine pipe wall thickness.

The second enhancement affects the LRA AMP "detection of aging effects" program element.

The LRA states that procedures will be enhanced to replace sprinklers prior to 50 years in service or field service test a representative sample and test every 10 years thereafter to ensure signs of degradation are detected in a timely manner.

The third enhancement affects the LRA AMP "monitoring and trending" program element. The LRA states that procedures will be enhanced for trending of fire water piping flow parameters recorded during fire water flow tests.

In LRA Appendix A, Table A4-1, the applicant committed (Commitment No.8) to implement these enhancements prior to the period of extended operation.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the fire protection yard area including the fire pump house, fire water storage tanks, and various hose stations, fire protection water lines, and sprinkler systems throughout the balance of plant (BOP), standby diesel generator rooms, and mechanical auxiliary building. The staff also conducted an independent search of the applicant's operating experience database using the following search terms: "loss of material," "inspection," "buried," "corrosion," "tank,"

"underground," and "piping."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. STP-AMP-B2.1.13 South Texas Project Aging Management Program Evaluation Report Fire Water System B2.1.13 NUREG 1801 ProQram Xl.M27 (included appropriate CRs)

Revision 4, 4/27/2011

2. OPGP03-ZF-0001 Fire Protection Program Revision 21, 2/16/2009 3.0PGP03-ZF-0018 Fire Protection System Functionality Requirements Revision 14, 11/25/2008

4. OPTP03-FP-0106 Fire Protection Water System Functional Test Revision 10, 510512009

5. OPTP03-FP-0103 Fire Protection System Flush Revision 5, 7/13/2004 6.0PTP03-FP-0120 Fire Hose Hydrostatic Test Revision 8, 5/19/2009 The staff conducted its audit of LRA AMP program elements one through six based on the contents of the existing program as modified by the proposed enhancements. Aspects of the "scope of program" and "detection of aging effects" program elements of the LRA AMP

- 30 associated with the exceptions were not evaluated during this audit. Aspects of these program elements that are not associated with the exceptions were evaluated and are described below.

During the audit, the staff found that the "preventive actions," "parameters monitored or inspected," "monitoring and trending," and "acceptance criteria" program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff also verified that for the "scope of program" and "detection of aging effects" elements, the aspects of the LRA program element that are not associated with the exceptions are consistent with the corresponding program elements in the GALL Report. The staff's evaluation of the aspects of the program elements associated with the exceptions will be addressed in the SER.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (i,e., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation, The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR Supplement was an adequate description of the LRA AMP. In order to obtain the information necessary to verify the sufficiency of the UFSAR Supplement program description, the staff will consider issuing RAls for the following subject discussed below:

SRP-LR Table 3.0-1 for GALL Chapter XI.M27, "Fire Water System," provides the recommended UFSAR Supplement Description of Program and includes".., and testing or replacement of sprinklers that have been in place for 50 years." Although the applicant has committed to enhance the Fire Water System program to include sprinkler replacement (LRA Table A4-1, Item #8 and LRA Section B2,1, 13), it is not addressed in the UFSAR Supplement Section A 1.13.

Audit Results: Based on this audit, the staff verified that the "preventive actions," "parameters monitored or inspected," "monitoring and trending," and "acceptance criteria" program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff also verified that for the "scope of program" and "detection of aging effects" program elements, the aspects of the LRA program elements that are not associated with the exceptions are consistent with the corresponding program elements in the GALL Report. The staffs evaluation of aspects of elements associated with exceptions will be addressed in the SER.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.

In addition, the staff identified a need for additional information regarding the adequacy of the program description in the UFSAR Supplement.

- 31 Existing Program Consistent with the GALL Report with Exception(s) and Enhancement(s), LRA AMP 82.1.14, "Fuel Oil Chemistry" Summary of Information in the Application: The LRA states that AMP B2.1.14, "Fuel Oil Chemistry Program," is an existing program with exceptions that is consistent with the program elements in GALL AMP XI.M30, "Fuel Oil Chemistry." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER. This audit report does not consider the sufficiency of exceptions, which will be evaluated in the SER.

The first exception affects the LRA AMP "scope of program" and "acceptance criteria" program elements. The LRA states that the GALL Report [Revision 1] recommends maintaining fuel oil quality in accordance with ASTM standards 01796, 02276, 02709, 06217, and 04057. The LRA also states that ASTM D6217 and Modified D2276, Method A are used as guidance for determination of particulates. The STP program specifies that fuel oil particulate concentrations be measured using a 0.8 micrometer (J./m) nominal pore size filter, in accordance with ASTM 02276. The Modified 02276, Method A, consists of using a filter with a pore size of 3.0 J./m, instead of 0.8 J./m. STP technical specifications, Section 6.8.3.i.3, specifies using a test method based on ASTM 02276 to assure total particulate concentration is greater than 10 milligrams per liter (mgll). In addition, the applicant uses ASTM 02276 as opposed to ASTM 06217 because the former provides guidance on determining particulate contamination using a field monitor, whereas the latter provides guidance on determining particulate contamination by sample filtration at an offsite laboratory.

The second exception affects the LRA AMP "scope of program," "parameters monitored or inspected" and "acceptance criteria" program elements. The LRA states that the GALL Report

[Revision 1] recommends the use of ASTM 02709 in determining water and sediment contamination in diesel fuel. The applicant's AMP uses only ASTM 01796, not ASTM 02709, for determining water and sediment contamination in diesel fuel. The applicant further stated that ASTM 01796 gives quantitative results, whereas ASTM 02709 testing gives only pass-fail results.

In addition, the LRA states that the GALL Report [Revision 1] recommends the use of ASTM 04057 for guidance on oil sampling. It was indicated that this standard requires that multilevel sampling be performed for tanks the size of the Standby Oiesel Generator (SOG) fuel oil storage tanks (i.e., approximately 65,000 gallons). The STP program does not perform multilevel sampling of the fuel oil storage tanks. Rather, composite samples are taken from the bottom of the fuel oil storage tanks, where contaminants may collect. The applicant further stated that the fuel oil in the other levels of the tank contain less contaminants per volume than the bottom, making sampling away from the bottom less effective in managing fuel oil contaminants.

The third exception affects the LRA AMP "parameters monitored or inspected" and "acceptance criteria" program elements. The LRA states that the GALL Report [Revision 1] recommends a filter with a pore size of 3.0 J./m be used in the determination of particulates. The STP program does not use a filter with a pore size of 3.0 J./m. Rather, the program follows the STP technical specifications, which call for the use of ASTM 02276 in that a filter with pore size of 0.8 J./m is

- 32 used for the analysis of fuel oil. The applicant stated that using a filter with a smaller pore size is more conservative, since more contaminants will be captured.

As stated above, the staff did not evaluate the sufficiency of these exceptions during the audit.

The staff's evaluation of the adequacy of these exceptions will be documented in the SER.

The first enhancement affects the LRA AMP "scope of program" program element. The LRA states that the procedures to the Fuel Oil Chemistry Program will be enhanced to extend the scope of the program to include the SDG fuel oil drain tanks.

The second enhancement affects the LRA AMP "scope of program" and "preventive actions" program elements. The LRA states that the program procedures will be enhanced to check and remove the accumulated water from the fuel oil drain tanks, day tanks, and storage tanks associated with the SDG, BOP, and fire water pump diesel generators. The applicant further stated that a minimum frequency of water removal from the fuel oil tanks will be included in the procedure.

The third enhancement affects the LRA AMP "preventive actions," "parameters monitored or inspected" and "detection of aging effects" program elements. The LRA states that procedures will be enhanced to include 10-year periodic draining, cleaning, and inspection for corrosion of the SDG fuel oil drain tanks and diesel fire pump fuel oil storage tanks. In addition, procedures will be enhanced to inspect the BOP diesel generator fuel oil day tanks for internal corrosion.

The applicant also stated that the procedures will be enhanced to require periodic testing of the SDG and diesel fuel oil storage tanks for microbiological organisms.

The fourth enhancement affects the LRA AMP "parameters monitored or inspected," "monitoring and trending" and "acceptance criteria" program elements. The LRA states that the program procedures will be enhanced to require analysis for water, biological activity, sediment, and particulate contamination of the diesel fire pump fuel oil storage tanks and the BOP diesel generator fuel oil day tanks on a quarterly basis.

The fifth enhancement affects the LRA AMP "detection of aging effects" program element. The LRA states that the program procedures will be enhanced to conduct ultrasonic testing or pulsed eddy current thickness examination to detect corrosion-related wall thinning once on the tank bottoms for the SDG and diesel fire pump fuel oil storage tanks, and the BOP diesel generator fuel oil day tanks.

The sixth enhancement affects the LRA AMP "monitoring and trending" program element. The LRA states that the program procedures will be enhanced to incorporate the sampling and testing of the diesel fire pump fuel oil storage tanks for particulate contamination and water and to incorporate the trending of water, particulate contamination, and microbiological activity in the SDG and diesel fire pump fuel oil storage tanks, and the BOP diesel generator fuel oil day tanks.

In Section A4 of the LRA, the applicant committed (Commitment No.9) to implement these enhancements prior to the period of extended operation.

- 33 Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the SDG diesel fuel storage tanks, BOP day tanks, SDG drain tanks, and Fire pumps storage tanks.

The staff also conducted an independent search of the applicant's operating experience database using the following search terms: "fuel oil" and "diesel fuel oiL" The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicant's experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. STP-AMP-S2.1.14 Fuel Oil Chemistry Revision 5, 4/27/2011

2. OPSP07-ZC-002 Diesel Fuel Oil Receipt Testing Revision 19, 12/10/2009 i

The staff conducted its audit of LRA AMP program elements one through six based on the contents of the existing program as modified by the proposed enhancements. Aspects of program elements "scope of program," "parameters monitored or inspected," and "acceptance criteria" of the LRA AMP associated with the exceptions were not evaluated during this audit.

Aspects of these program elements that are not associated with the exceptions were evaluated and are described below.

During the audit, the staff found that program elements "preventive actions," "detection of aging effects," and "monitoring and trending" of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff also found that aspects of program elements "scope of program," "parameters monitored or inspected," and acceptance criteria" not associated with the exceptions are consistent with the corresponding program elements in the GALL Report AMP. The staff's evaluation of aspects of these program elements associated with the exceptions will be addressed in the SER.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation. In order to obtain the information necessary to verify whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAls for the subjects discussed below.

After the issuance of Revision 1 of the GALL Report, the NRC has issued Information Notice (IN) 2009-02, "8iodiesel in Fuel Oil Could Adversely Impact Diesel Engine Performance." This Information Notice discusses potential issues that may occur with the use of 85 blend fuel oil, such as: suspended water particles, biodegradation of 85, material incompatibility, etc. The

- 34 LRA does not provide information discussing the concerns of IN 2009-02 and the acceptable or unacceptable use of biodiesel at STP.

The LRA states that condition records have documented that fuel oil chemistry was out of specification in regards to water and fine sediment intrusion into the auxiliary fuel oil storage tanks, diesel generator fuel oil storage tanks, fire pump fuel oil storage tanks, and the vendor fuel oil trailer tanks during the period of 1999-2009. Corrective actions were taken and the applicant stated that fuel oil chemistry was brought back into specification limits. The LRA does not provide information on when and why water and fine sediment intrusion into storage tanks were found and identified.

LRA AMP B2.1.14, "Fuel Oil Chemistry Program," states that the program procedures will be enhanced to include 10-year periodic draining, cleaning, and inspection for corrosion of the SDG fuel oil drain tanks and diesel fire pump fuel oil storage tanks. The LRA does not indicate whether the program enhancement will include the BOP day tanks or the SOG drain tanks.

Audit Results: Based on this audit, the staff verified that LRA program elements "preventive actions," "detection of aging effects," and "monitoring and trending" are consistent with the corresponding program elements in the GALL Report AMP. The staff also verified that aspects of LRA program elements "preventive actions," "detection of aging effects," and "monitoring and trending" not associated with the exceptions are consistent with the corresponding program elements in the GALL Report. The staff's evaluation of aspects of elements associated with exceptions will be addressed in the SER. The staff also determined that certain aspects of LRA AMP program element "operating experience" will require additional information or additional evaluation before consistency can be determined.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.

In addition, the staff identified a need for additional information regarding the adequacy of the program description in the UFSAR Supplement.

Existing Program Consistent with the GALL Report with Enhancement(s), LRA AMP 82.1.15, "Reactor Vessel Surveillance" Summary of Information in the Application: The LRA states that AMP B2.1.15, "Reactor Vessel Surveillance," is an existing program with an enhancement that is consistent with the program elements in GALL AMP XI.M31, "Reactor Vessel Surveillance."

The staff's evaluation of this LRA AMP will be addressed in the SER.

New Program Consistent with the GALL Report, LRA AMP 82.1.16, "One~Time Inspection" Summary of Information in the Application: The LRA states that AMP B2.1.16 "One-Time Inspection," is a new program that is consistent with the program elements in GALL AMP XI.M32 "One-time Inspection." The applicant committed to implement this program during the 10 years prior to the period of extended operation in LRA Appendix A, Table A4-1. To verify

- 35 this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicant's operating experience database using the the following search terms:

"rust," "pitting," and "loss of materiaL" The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date I

1. STP-AMP-B2.1.16

2. TR-1075514 STP Program Evaluation Report, B2.1.16, One-Time Inspection, NUREG-1801, XI.M32 Age-Related Degradation Inspection Method and

- Demonstration Revision 2, 04/27/2011 0411998 I

i

~

During the audit of program elements one through six, the staff found that program elements "scope of program," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit, the staff noted several editorial issues with STP-AMP-B2.1.16. Although these issues do not affect the staff's evaluation of consistency, the applicant acknowledged these comments stating that they would do the following:

Use current plant inspection procedures for penetrant test, visual, radiographic and eddy current inspection processes Revise Section 6.5 to clarify the wording regarding aging effects Delete Section 6.6.10, "Caulking/Sealants," and Section 6.6.12, "Expansion Joints/Flex Hoses/Sight gauges"

• Relocate caulking and sealants to appropriate AMPs and ensure the OTI program applies to non-elastomeric expansion joints Remove the two condition records from the site's AMP procedure booklet because they do not apply On June 16, 2011, the applicant submitted Amendment 2 to the license renewal application, which, for LRA Section A 1.16, "One-time Inspection Program," clarifies how component sampling will be determined. The review of this amendment will be addressed in the SER.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent

- 36 database search is sufficient to allow the staff to verify that the lRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.

The staff also audited the description of the lRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-lR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that lRA program elements "scope of program," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," "acceptance criteria," and "operating experience," are consistent with the corresponding program elements in the GAll Report AMP.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the lRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.

In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

New Program Consistent with Exception(s), LRA AMP 82.1.17, "Selective Leaching of Materials" Summary of Information in the Application: The lRA states that AMP B2.1.17, "Selective leaching of Materials," is a new program with exceptions that is consistent with the program elements in GAll AMP XI,M33, "Selective leaching of Materials." The applicant committed to implement this program during the ten-year period prior to the period of extended operation in Commitment No. 12. To verify this claim of consistency, the staff audited the lRA AMP. Issues identified but not resolved in this report are addressed in the SER. This audit report does not consider the sufficiency of exceptions, which will be evaluated in the SER.

The first exception affects the lRA AMP "scope of program" program element. The lRA states that aluminum bronze components susceptible to selective leaching will not be age managed by the Selective leaching of Materials Program, but rather will be managed by the Selective leaching of Aluminum Bronze plant-specific program.

The second exception affects the lRA AMP "scope of program," "parameters monitored or inspected," and "detection of aging effects" program elements. The lRA states that qualitative detection of selective leaching (e.g., scraping, chipping) will be used instead of hardness testing.

As stated above, the staff did not evaluate the sufficiency of these exceptions during the audit.

The staff's evaluation of the adequacy of these exceptions will be documented in the SER.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the following search terms: "leach" and "through-wall."

- 37 The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. STP-AMP-B2.1.17 STP AMP Evaluation Report Selective Leaching of Materials - B2.1.17 NUREG 1801 Program XI.M33 Revision 2, 8/10/2010

2.

STP LR Aging Management CR Operating experience 12/2/2010

• Report for AMP XI.M33 "Selective Leaching of Materials" B.2.1.17 I

.3.

STP LR Component List for XI.M33 "Selective Leaching of Materials" B.2.1.17 I

Aging Management Program for Selective Leaching of None - draft

4. OPGP04-ZE-0009 I

Material The staff conducted its audit of LRA AMP program elements one through six based on the contents of the new program. Aspects of program elements "scope of program," "parameters monitored or inspected," and "detection of aging effects," program elements of the LRA AMP associated with the exceptions were not evaluated during this audit Aspects of these program elements that are not associated with the exceptions were evaluated and are described below.

During the audit, the staff found that program elements "preventive actions," "monitoring and trending," and "acceptance criteria" of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for program elements "scope of program," "parameters monitored or inspected," and "detection of aging effects,"

sufficient information was not available to determine whether they are consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAls for the subjects discussed below:

The "scope of program" program element of the LRA AMP states that the program manages the loss of material due to selective leaching for copper alloys with greater than 15 percent zinc and gray cast iron components exposed to treated and raw water within the scope of license renewal. The GALL Report AMP recommends that components made of gray cast iron and copper alloys (except for inhibited brass) that contain greater than 15 percent zinc (> 15% Zn) or greater than 8 percent aluminum

(>8% AI in the case of aluminum-bronze) exposed to a raw water be managed for selective leaching. During the audit, the applicant and staff conducted a random sample of field components to determine if the correct materials and environments were identified in the LRA. During this audit, the applicant determined that the diesel fire pumps are constructed of gray cast iron instead of cast iron. The applicant conducted an extent of condition review of cast iron components and found no other discrepancies.

The "scope of program" program element of the LRA AMP states the program includes a one-time inspection of a sample of components made from gray cast iron and copper alloys with greater than 15 percent zinc. The GALL Report AMP recommends that the inspection consist of a representative sample of the system population. It is not clear to

- 38 the staff if the applicant will sample components from the compressed air system which contains components that are susceptible to selective leaching.

• The "parameters monitored or inspected" program element of the LRA AMP states that the program will be implemented prior to the period of extended operation. The GALL Report AMP recommends that the inspections be conducted in the five-year period prior to the period of extended operation. This recommendation originated with Revision 2 of the GALL Report while the applicant's LRA followed the recommendations of Revision 1 of the GALL Report.

• The "scope of program" program element description of the LRA AMP states that the program procedure provides for visual and mechanical inspections for each system/material/environment combination. In the basis document for the AMP under the "detection of aging effects" program element, the applicant states that "the one-time visual inspection and hardness measurement includes close examination of a select set of components to determine whether selective leaching has occurred." The GALL Report AMP recommends that components most susceptible to aging due to time in service, severity of operating conditions, and lowest design margin be inspected. It is not clear to the staff that these statements are consistent since the applicant has not defined the sample of components that will be inspected.

I n Amendment 2 of the LRA, dated June 16, 2011, the "parameters monitored or inspected" and "detection of aging effects" program element descriptions state that flow testing of fire mains is credited for management of selective leaching of buried cast iron valves in the fire protection system in accordance with GALL AMP XI.M41. GALL AMP XI.M41, "Buried and Underground Piping and Tanks," recommends that GALL AMP XI.M33, "Selective Leaching of Materials" be used to manage selective leaching in addition to the program requirements of AMP XI. M41. It is not clear to the staff that these statements are consistent because although AMP XI.M41 allows fire protection flow testing to manage the aging of buried fire protection piping, it states that AMP XI.M33 is additionally used to manage selective leaching of buried piping.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP~LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that LRA program elements "preventive actions," "monitoring and trending," "acceptance criteria," and "operating experience," are consistent with the corresponding program elements in the GALL Report AMP. The staff also verified that aspects of LRA program elements "scope of program," "parameters monitored or inspected," and "detection of aging effects" not associated with the exceptions are consistent

- 39 with the corresponding program elements in the GALL Report. The staff's evaluation of aspects of elements associated with exceptions will be addressed in the SER. The staff also determined that certain aspects of LRA program elements "scope of program," "parameters monitored or inspected," and "detection of aging effects" will require additional information or additional evaluation before consistency can be determined.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.

In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

Existing Program Consistent with the GALL Report with Exception(s) and Enhancement(s), LRA AMP B2.1.18, "Buried Piping and Tanks Inspection" Summary of Information in the Application: LRA Amendment 2, dated June 16, 2011, states that AMP B2.1.18, "Buried and Underground Piping and Tanks," is an existing program with enhancements and exceptions that is consistent with the program elements in GALL AMP XI,M41, "Buried and Underground Piping and Tanks," Revision 2. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER. This audit report does not consider the sufficiency of exceptions, which will be evaluated in the SER.

The first exception affects the LRA "preventive actions" program element. The LRA states that the plant-specific implementing procedures for backfill did not include requirements to ensure that the piping was lowered carefully into the ditch nor ensure that rocks and debris do not strike and damage pipe coatings, and are therefore not completely consistent with NACE SP0169-2007.

The second exception affects the LRA "preventive actions" program element. The LRA states that plant-specific implementing procedures for coatings did not reference American Water Works Standards C-203, C-209, and C-214, and are therefore not completely consistent with NACE SP0169-2007.

As stated above, the staff did not evaluate the sufficiency of these exceptions during the audit.

The staffs evaluation of the adequacy of these exceptions will be documented in the SER.

The first enhancement affects the LRA AMP "preventive actions" program element. The LRA states that plant specifications will be enhanced to include:

• handling and lowering of the pipe proper storage and handling techniques for the piping excavation of trenches and use of qualified backfill qualification of coating in accordance with NACE SP0169-2007 coating of essential cooling water system copper alloy piping that is embedded in backfill or directly encased in concrete

- 40 The second enhancement affects the LRA AMP "preventive actions" program element. The LRA states that plant procedures will be enhanced to include:

acceptability of backfill that is located within 6 inches of the pipe that is consistent with ASTM D 448-08 size number 67 annual surveys of the cathodic protection system, and bimonthly checks of the rectifier current bimonthly monitoring of the cathodic protection system rectifier output and subsequent actions if output deviates significantly from target value annual evaluation of the effectiveness of isolating fittings, continuity bonds and casing isolation

• qualifications for the performance technicians who perform the plant yard cathodic protection system annual surveys The third enhancement affects the LRA AMP "parameters monitored or inspected" and "detection of aging effects" program elements. The LRA states that plant procedures will be enhanced to include visual inspections of piping, and supplemental surface and/or volumetric non-destructive testing if significant degradation is observed.

The fourth enhancement affects the "detection of aging effects" program element. The LRA states that plant procedures will be enhanced to include:

• the periodicity of inspections

• the selection of inspection locations considerations of risk ranking of buried, underground, and back-filled piping use of external corrosion direct assessment credit for opportunistic exams of non-leaking pipes use of guided wave UT or other advanced inspection techniques credit for inspection of shared piping between units

• examination of piping, valves, and bolting when exposed

• two alternatives for inspections of buried or underground piping that is safety-related, hazmat or both

• flow testing of fire mains

• the definition for "hazmat" piping examples of adverse conditions

• corrective actions for adverse conditions

• the scope of inspection and inspection requirements for buried piping, and buried and underground stainless steel piping The fifth enhancement affects the LRA AMP "monitoring and trending" program element. The LRA states that plant procedures will be enhanced to include trending of results of the plant yard cathodic protection system annual surveys.

The sixth enhancement affects the LRA AMP "acceptance criteria" program element. The LRA states that plant procedures will be enhanced to include:

- 41 actions if coating degradation is present acceptability of backfill that is located within 6 inches of the pipe that is consistent with ASTM D 448-08 size number 67 actions for the condition "without leakage," as required by 49 CFR 195.302 The seventh enhancement affects the LRA AMP "detection of aging effects" and "acceptance criteria" program elements. The LRA states that a list of the systems with buried or underground piping within the scope of this program will be developed. The list will contain whether the pipe is safety-related or hazmat for each piping material and system within the scope of this program, and indicate whether or not the coating, backfill and cathodic protection of the piping are in compliance with NACE SP0169-2007 and the other requirements of Section XI.M41, Table 2a of the GALL Report, Revision 2.

In the LRA, the applicant committed (Commitment No. 13) to implement these enhancements prior to the period of extended operation.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the following search terms: "underground,"

"through wall," "tank," "holiday," "excavat," "dug," "dug up," "coating," and "buried."

The table below lists the documents which were reviewed by the staff and were found to be relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date 1 STP-AMP-B2.1.18 STP AMP Evaluation Report, Buried and Underground 4/27/11 Piping and Tanks - B2.1.18 i 2.

STP LR Aging Management CR Operating Experience 12/2/10 Report for XI.M34 "Buried Piping and Tanks Inspection" B2.1.18

3.

STP LR Aging Management Industry Operating Experience 12/2/10 Report for XI.M34 "Buried Piping and Tanks Inspection" B2.1.18 i 4. 7A810AS1000 SpeCification for Field Coating of Surfaces Outside of the Revision 18, Reactor Containment Building 6/10/1992

! 5.0PGP04-ZA-0606 Buried Piping and Tanks Program Revision 2, 9/27/2010

• 6. OPGP03*ZE-0046 Excavation and Installation of Backfill Revision 3, 8/25/1999 7.0PEP07*NM-003 Plant Yard Cathodic Protection Potential Survey Revision 7, 11/19/2009

8. OPEP10-ZA*0039 Visual Examination of Buried Piping Components 2/25/2009

9. CR 09-7935 Review actions taken for funding of cathodic protection 5/19/2009 repairs

10. CR 07*5258 Cracking on mortar coating on Unit 1 OC supply line 4/3/2007

11. CR 05-765 Evaluation of Palo Verde event - underground fire 1/18/2005 pr()tection ~g failure

I

- 42 Revision f Date Title Document 4/24/2000 Fire water storage tank inlet piping has an underground

12. CR 07-7497 leak 1/6/2001 Underground leak north of Unit 2 TGB

13. CR 01-311 1/13/2001 Underground service water leak southwest of Unit 1 AFW

14. CR 01-695 storaQe tank 9/4/2003 Fire protection line leak from underground in west yard area

15. CR 03-13780 8/18/2010 Cathodic Protection Rectifier PMWO

16. PT-0-94002738 The staff conducted its audit of LRA AMP program elements one through six based on the contents of the existing program as modified by the proposed enhancements. Aspects of program element "preventive actions" of the LRA AMP associated with the exceptions were not evaluated during this audit. Aspects of this program element that are not associated with the exceptions were evaluated and are described below.

During the audit, the staff found that program elements "parameters monitored or inspected,"

"monitoring and trending," and "acceptance criteria" of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff's evaluation of aspects of this program element associated with the exceptions will be addressed in the SER. In addition, the staff found that for program elements "scope of program," "preventive actions," and "detection of aging effects" sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL ReportAMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAls for the subjects discussed below:

• The "detection of aging effects" program element of the LRA AMP states that if extensive adverse conditions are found during inspections, inspections may be halted in an area of concern that is planned for replacement, provided continued operation does not pose a significant hazard. The GALL Report AMP recommends that if adverse conditions are detected, the sample size is doubled, and if adverse conditions are found in the expanded sample, the inspection size is doubled again. It further recommends that the doubling of inspections continue as necessary. It is not clear to the staff that these statements are consistent because the LRA does not state if the doubling of inspection sample sizes will continue in locations with similar materials and environment where the adverse conditions are not extensive.

• The "preventive actions" program element of the LRA AMP states that backfill for buried piping is consistent with ASTM D 448-08 size number 67. However, the implementing procedure allows non-category 1 backfill material above plant elevation 26. There is buried in-scope piping that rises through elevation 26 and up to ground elevation which is approximately 28 feet. Non-category 1 backfill may not meet the requirements of ASTM D 448-08 size nurnber 67.

• The "scope of program" program element of the LRA AMP states the auxiliary feedwater, essential cooling water and essential cooling water screen wash, fire protection, and oily waste systems contain buried in-scope piping. However, LRA Table 3.3.2-27, Miscellaneous Systems in scope ONLY for Criterion 10 CFR 54.4(a)(2), includes buried in-scope piping and valves.

- 43

• The "detection of aging effects" program element of the LRA AMP basis document does not state an inspection size for the underground in-scope oily waste system piping. The GALL Report AMP recommends that two percent of underground piping containing materials hazardous to the environment be inspected. It is not clear to the staff that these statements are consistent because the applicant did not state an inspection scope for the piping.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that LRA program elements "parameters monitored or inspected," "monitoring and trending," "acceptance criteria," and "operating experience," are consistent with the corresponding program elements in the GALL Report AMP.

The staffs evaluation of aspects of elements associated with exceptions will be addressed in the SER. The staff also determined that certain aspects of LRA AMP program elements "scope of program," "preventive actions," and "detection of aging effects" will require additional information or additional evaluation before consistency can be determined.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.

In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

New Program Consistent with the GALL Report with Exception(s), LRA AMP B2.1.32, "One*Time Inspection of ASME Code Class 1 Small-Bore Piping" Summary of Information in the Application: The LRA states that AMP B2.1.19, "One-Time Inspection of ASME Code Class 1 Small-Bore Piping," is a new program, with an exception, that is consistent with the program elements in GALL AMP XI.M35, "One-Time Inspection of ASME Code Class 1 Small-Bore Piping." The applicant committed to implementing this program within six years prior to the start of the period of extended operation. To verify this claim of consistency, the staff audited LRA AMP B2.1.19. Issues identified but not resolved in this report are addressed in the SER. This audit report does not consider the sufficiency of the exception, which will be evaluated in the SER The exception affects the LRA "scope of program" program element. The LRA states, 'The STP risk-informed process examination requirements are performed consistent with EPRI

- 44 TR-112657, Revised Risk-Informed Inservice Inspection Evaluation Procedure, Revision 8-A, instead of EPRI Report 1000701, Interim Thermal Fatigue Management Guidance (MRP-24)."

As stated above, the staff did not evaluate the sufficiency of the exception during the audit. The staff's evaluation of the adequacy of the exception will be documented in the SER.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the following search terms: "cracking,"

"failure," "socket," "butt," "full penetration," and "weld."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. STP-AMP-B2.1.19 One-Time Inspection of ASME Code Class 1 Small-Bore Piping Revision 3, 4/27/2011

2. LER 4992005001 Unit 2 Shutdown Due to Reactor Coolant System Pressure Boundary Leak 4/5/2005

3. CR 02-8654 Condition Record: Steam Out of Insulation Downstream 6/17/2002

4. CR 07-18256 Condition Record: Through-Wall Leak Repair 12/13/2007 The staff conducted its audit of LRA AMP program elements one through six based on the contents of the new program. Aspects of program element, "scope of program," of the LRA AMP associated with the exception were not evaluated during this audit. Aspects of this program element that are not associated with the exception were evaluated and are described below.

During the audit, the staff found that program elements "preventive actions," "parameters monitored or inspected," "monitoring and trending," and "acceptance criteria" of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff also found that aspects of program element "scope of program" not associated with the exception are consistent with the corresponding program element in the GALL Report AMP. The staff's evaluation of aspects of this program element associated with the exception will be addressed in the SER. In addition, the staff found that for program element "detection of aging effect,"

sufficient information was not available to determine whether it was consistent with the corresponding program element of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAls for the subject discussed below.

According to the "detection of aging effects" program element of GALL AMP XI.M35, the applicant's program should include ten percent of the weld population or a maximum of 25 welds of each weld type (e.g., full penetration or socket weld) using a methodology to select the

- 45 most susceptible and risk-significant welds. During its audit, the staff found that the applicant does not have specific information regarding the subject small-bore piping weld population, nor its inspection sampling size for butt welds. This information is necessary for the staff to evaluate if the applicant's inspection sampling is adequate, and is consistent with the GALL Report AMP.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is adequate to detect and manage aging effects during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that LRA program elements "preventive actions," "parameters monitored or inspected," "monitoring and trending," "acceptance criteria,"

and "operating experience" are consistent with the corresponding program elements in the GALL Report AMP. The staff also verified that aspects of LRA program element "scope of program" not associated with the exception are consistent with the corresponding program element in the GALL Report. The staffs evaluation of aspects associated with the exception will be addressed in the SER. The staff also determined that certain aspects of LRA AMP program element "detection of aging effects" will require additional information or additional evaluation before consistency can be determined.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is adequate to detect and manage aging.

In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

New Program Consistent with the GALL Report with Exception(s), LRA AMP 82.1.20, "External Surfaces Monitoring Program" Summary of Information in the Application: The LRA states that AMP B2.1.20, "External Surfaces Monitoring Program" is a new program with an exception that is consistent with the program elements in GALL AMP XI.M36 "External Surfaces Monitoring." The applicant committed to implement this program prior to the period of extended operation in Commitment No. 15. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER. This audit report does not consider the sufficiency of exceptions, which will be evaluated in the SER.

The exception affects the LRA "scope of program" and "detection of aging effects" program elements. The LRA states that the scope of the program has been expanded to include

- 46 additional materials (stainless steel, aluminum, copper, and elastomers), additional aging effects (elastomer hardening and loss of strength), and additional inspection techniques (manipulation of elastomers).

As stated above, the staff did not evaluate the sufficiency of this exception during the audit. The staff's evaluation of the adequacy of this exception will be documented in the SER.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the Fire Water Storage Tank, Auxiliary Feedwater Storage Tank, Unit 2 Mechanical Auxiliary Building 23 ft. elevation, Unit 2 Fuel Handling Building -21 ft. elevation, Unit 2 Electrical Auxiliary Building 86' elevation, #12 Emergency Diesel Generator Bay, Isolation Valve Cubicle D bay - Steam Generator Auxiliary Feedwater, Isolation Valve Cubicle B bay - Motor Driven Auxiliary Feedwater. The staff also conducted an independent search of the applicant's operating experience database using the following search terms: "degradation," "corrosi," "cracking,"

"crevice," "damage," "loss of material," "perforation," and "pitting."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. STP-AMP-B2.1.20 STP AMP Evaluation Report External Sutiaces Monitoring Revision 1, Program - 82.1.20 06/22/2010

2. None STP LR Aging Management CR operating Experience 12/02/2010 Report for AMP XI.M36 "External Sutiaces Monitoring Program" 82.1.20

3. SEG-001 System Engineering Administrative Guideline Revision 7, 09/25/2008

4.

External Sutiaces Monitoring Program Draft Procedure, Draft April 2010 April 2010

5. CR 00-8889 Corrosion observed on CCW valves inside the RCB 05/06/2000

6. CR 01-6598 Control Room HVAC duct has pooled condensation on top 04/11/2001 creating areas that are almost rusted through

7. CR 02-14439 Heavy corrosion on flange and fasteners of return line from 10109/2002 CCW non-essential header

8. CR 02-5515 Fire damper grill is severely corroded and needs replacing 04/10/2002

. 9. CR 05-4225 CCW pipe upstream of 1-CC-0198 and just downstream of containment penetration M-24 has significant exterior 03/23/2005 I

rusting j

10. CR 98-19537 Sixty DPM leak from under lagging of "D" feed reg valve 12/05/1998

11. CR 04-9837 Cathodic protection declining petiormance 03/12/2003

12. CR 08-6119 INPO AFI essential cooling water and fire protection 04/08/2008 cathodic protection monitoring is not sufficient I

The staff conducted its audit of LRA AMP program elements one through six based on the contents of the new program. Aspects of program elements "scope of program" and "detection of aging effects" of the LRA AMP associated with the exception were not evaluated during this

- 47 audit. Aspects of these program elements that are not associated with the exception were evaluated and are described below.

During the audit, the staff found that program elements "preventive actions," "monitoring and trending," and "acceptance criteria" of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff's evaluation of aspects of elements associated with the exception will be addressed in the SER. In addition, the staff found that for program elements "scope of program," "parameters monitored or inspected," and "detection of aging effects" sufficient information was not available to determine whether it was consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAls for the subjects discussed below:

The "scope of program" program element of the LRA AMP states that physical manipulation of elastomers may be used to augment visual inspections. The GALL Report AMP program element "parameters monitored or inspected" recommends that the purpose of manual manipulation of elastomers is to reveal changes in material properties to make the visual examination process more effective in identifying aging effects. It is not clear to the staff that these statements are consistent because the term "may" allows discretion in determining whether to use manipulation of elastomers.

The "scope of program" program element of the LRA AMP states that the External Surfaces Monitoring AMP will not be used for managing loss of material for internal surfaces. However, LRA Tables 3.3.2-11 and 3.3.2-12 contain components exposed to atmospheric weather internal and they are only managed by the External Surfaces Monitoring Program. It is not clear to the staff how these components will be periodically monitored by this program.

The "scope of program" program element of the LRA AMP states that physical manipulation of elastomers may be used to augment visual inspections. The GALL Report AMP recommends that at least 10 percent of the available surface area be manipulated. This GALL Report program element "detection of aging effects" recommendation originated with Revision 2 of the GALL Report while the applicant's LRA was submitted to Revision 1 of the GALL Report.

LRA Table 3.3.2-17 credits the External Surfaces Monitoring to manage loss of material for the steel fire water storage tank exposed to atmosphere/weather. LRA Table 3.4.2-6 states that there is no aging effect and no AMP for the stainless steel auxiliary feedwater storage tanks exposed to atmosphere/weather. GALL AMP XI.M29, "Aboveground Metallic Tanks," Revision 2, recommends that tanks exposed to weather and are constructed on concrete or soil be managed for aging by having sealant or caulking applied at its base, that the sealant or caulking be visually inspected, and the tank bottom thickness be measured at least once within five years of entering the period of extended operation and whenever the tank is drained. It is not clear to the staff that these statements are consistent because the External Surfaces Monitoring Program does not require sealant or caulking as a preventive action nor does it conduct bottom thickness measurements of the tank. Although structural caulking and sealants exposed to atmospheric/weather are managed by the Structures Monitoring Program in LRA

- 48 Table 3.5.2-3, the periodicity of inspections for the Structures Monitoring Program is not as frequent as those recommended by AMP XI.M29.

GALL AMP program element "detection of aging effects" recommends that surfaces that are not readily visible during plant operations and refueling outages are inspected when they are made accessible and at such intervals that would ensure the components' intended functions are maintained. The LRA AMP states that it is consistent with GALL AMP XI.M36; however, the implementing procedure lacks sufficient detail to preclude a component which is inaccessible during normal operation from having its inspection deferred such that it is not inspected at all during the period of extended operation. It is not clear to the staff how the applicant will evaluate or track exceptions to inspections due to the component(s) not being readily accessible during plant operations and refueling outages.

The staff noted several instances where the applicant's External Surfaces Monitoring Program was consistent with GALL AMP XI.M36 "External Surfaces Monitoring of Mechanical Components." However, during the audit, the staff noted that the draft implementing procedure(s) lacked sufficient detail related to the following. The staff noted that these three items are editorial corrections to the implementing procedures and do not affect the staff's evaluation of consistency. The applicant acknowledged these comments:

• The implementing procedure does not list stainless steel as a material type of concern for aging management walkdowns; however, the LRA contains stainless steel items being managed by the External Surfaces Monitoring Program.

The implementing procedure states that ventilation systems contain elastomeric materials; however, LRA Tables 3.3.2-18 and 3.3.2-26 also list elastomeric components.

The "acceptance criteria" program element lists sixteen acceptance criteria used to determine if no aging effects are occurring. The corresponding list in the implementing procedure only contains ten criteria.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that the "preventive actions," "monitoring and trending," "acceptance criteria," and "operating experience" LRA program elements are consistent with the corresponding program elements in the GALL Report AMP. The staff's evaluation of aspects of elements associated with the exception will be addressed in the SER.

- 49 The staff also determined that certain aspects of LRA AMP program elements "scope of program," "parameters monitored or inspected," and "detection of aging effects" will require additional information or additional evaluation before consistency can be determined.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.

In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

Existing Program Consistent with the GALL Report with Enhancement(s), LRA AMP 82.1.21, "Flux Thimble Tube Inspection" Summary of Information in the Application: The LRA states that AMP B2.1.21, "Flux Thimble Tube Inspection," is an existing program with enhancements that is consistent with the program elements in GALL AMP XI.M37, "Flux Thimble Tube Inspection." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER.

The first enhancement affects the LRA AMP "scope of program," "preventive actions,"

"parameters monitored or inspected," and "detection of aging effects" program elements. The LRA states that a new program procedure will be created, which contains provisions to perform a wall thickness eddy current inspection of all flux thimble tubes that form part of the reactor coolant system pressure boundary. The LRA also states that the inspections are scheduled for each outage, and may be deferred by using an evaluation that considers the actual wear rate.

The second enhancement affects the LRA AMP "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," "corrective actions,"

"confirmation process," and "administrative controls" program elements. The LRA states that a new program procedure will be created that contains provisions to evaluate flux thimble tube wear by design engineering personnel and perform corrective actions based on evaluation results after each inspection.

The third enhancement affects the LRA AMP "monitoring and trending," "acceptance criteria,"

"corrective actions," "confirmation process," and "administrative controls" program elements.

The LRA states that a new program procedure will be created that contains provisions to trend wall thickness measurements and calculate wear rates by design engineering personnel.

The fourth enhancement affects the LRA AMP "monitoring and trending," "corrective actions,"

"confirmation process," and "administrative controls" program elements. The LRA states that a new program procedure will be created that contains provisions to take corrective actions to reposition, cap or replace the tube, if the predicted wear (as a measure of percent through wall) for a given flux thimble tube is projected to exceed the established acceptance criterion prior to the next outage.

The fifth enhancement affects the LRA AMP "scope of program," "parameters monitored or inspected," and "acceptance criteria" program elements. The LRA states that a new program procedure will be created that contains prOVisions to include a description of the testing and

50 analysis methodology. This enhancement also includes a new program procedure to establish the through wall acceptance criteria (i.e., a maximum 80-percent through wall loss).

The sixth enhancement affects the LRA AMP "corrective actions," "confirmation process," and "administrative controls" program elements. The LRA states that a new program procedure will be created that contains provisions to remove flux thimbles from service to ensure the integrity of the reactor coolant system pressure boundary for flux thimble tubes that cannot be inspected over the tube length, that are subject to wear due to restriction or other defects, and that cannot be shown by analysis to be satisfactory for continued service.

In Appendix A, Section A4, "License Renewal Commitment" of the LRA, the applicant committed (Commitment No. 16) to implement these enhancements prior to the period of extended operation.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the following search terms: "flux thimble,"

and "wear."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. STP-AMP-B2.1.21 South Texas Project Aging Management Program Evaluation Report Flux Thimble Tube Inspection Revision 3, 4/27/2011

2. CR 07-5066 Condition Record 4/1/2007

, 3. CR 09-16025 Condition Record 10/8/2009

4. ST-HL-AE-2832 Response to NRC Bulletin 88-009: "Thimble Tube Thinning in Westinghouse Reactors" 11/1/1988

5. ST-HL-AE-3780 Thimble Tube Thinning in Westinghouse Reactors 7/25/1991 The staff conducted its audit of LRA AMP program elements one through six based on the contents of the existing program. In addition, due to the large number of flux thimble tube repositioning and replacements for Unit 2, the staff also reviewed certain aspects of the applicant's "corrective action" (element 7) based on the plant-specific OE related to this element and the specific "corrective action" recommendations in the corresponding element of GALL AMP XI.M37.

During the audit, the staff found that for program elements "scope of program," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and

- 51 trending," and "acceptance criteria," sufficient information was not available for the staff to determine whether each element was consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify this, the staff will consider issuing RAls for the subject discussed below.

For the "monitoring and trending" program element, GALL AMP XI.M37 recommends trending and monitoring of the flux thimble tube wall loss with sufficient conservatism. In comparison, LRA Section 82.1.21 and the onsite documentation related to the program do not clearly address how the program manages discrepancies between projected wall loss and measured wall loss. Therefore, the staff needs the applicant to clarify how it will manage discrepancies between prOjected wall loss and measured wall loss.

LRA Section 82.1.21 states that the applicant's Flux Thimble Tube Inspection Program is an existing program and the program implements the recommendations of NRC 8ulletin 88-09, "Thimble Tube Thinning in Westinghouse Reactors." The LRA also describes six program enhancements regarding the creation of new program procedures as described above for the "scope of program," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" program elements. The staff found a need for the applicant to clarify, for each enhancement, whether portions were revisions or additions to the existing program. In addition, the staff found that, if new program procedures include a change to certain technical aspects of the existing program (e.g., a change to wear projection methodology or acceptance criteria for wall loss), the technical basis of the change to the existing program will need to be addressed. The staff will therefore need clarification on the above in order to determine the program's consistency with the GALL Report's recommendation.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation. In order to obtain the information necessary to verify whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing an RAI for the subject discussed below.

In its review, the staff noted that the LRA does not clearly indicate the root cause(s) that resulted in the repositioning and replacement of a relatively large number (> 25) of the flux thimble tubes that are addressed in LRA Section 82.1.21. In addition, the staff noted that the LRA does not sufficiently provide the inspection and evaluation results associated with the corrective actions in order to demonstrate the adequacy of the program-defined wear projection methodology, inspection frequency and acceptance criteria for the tube wall loss.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

• 52*

Audit Results: Based on this audit, the staff determined that certain aspects of LRA program elements "scope of program," "preventive actions," "parameters monitored or inspected,"

"detection of aging effects," "monitoring and trending," and "acceptance criteria" will require additional information or additional evaluation is required before consistency can be determined.

Based on this audit, the staff also identified that additional information regarding operating experience is required before a determination can be made regarding the sufficiency of the LRA AMP, as implemented by the applicant, to detect al1d manage aging. In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

New Program Consistent with the GALL Report with Exception(s), LRA AMP 82.1.22, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components" Summarv of Information in the Application: The LRA states that AMP B2.1.22, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components," is a new program with exceptions that is consistent with the program elements in GALL AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components." The applicant committed to implement this program prior to the period of extended operation in Table A4-1, item 17, of the LRA's License Renewal Commitments list. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER. This audit report does not consider the sufficiency of exceptions, which will be evaluated in the SER.

The exception affects the LRA "scope of program," "parameters monitored or inspected,"

"detection of aging effects," and "monitoring and trending" program elements. The LRA states that the exception to GALL AMP XI.M38 is (1) an increase to the scope of the materials inspected by including stainless steel, aluminum, copper alloy, stainless steel-cast austenitic, nickel alloys, glass and elastomers, in addition to steel, and (2) an increase to the scope of aging effects by including hardening and loss of strength for elastomers. Additionally, the LRA states that visual inspections may be augmented (1) by physical manipulation to detect hardening and loss of strength of elastomers when appropriate for the component configuration and material, and (2) by volumetric evaluation to detect stress corrosion cracking of the internal surfaces of stainless steel components exposed to diesel exhaust.

As stated above, the staff did not evaluate the sufficiency of this exception during the audit. The staff's evaluation of the adequacy of this exception will be documented in the SER.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the following search terms: "loss of material," "piping," and "cracking."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

- 53 Relevant Documents Reviewed Document Title Revision I Date

1. STP-AMP-82.1.22 South Texas Project Program Evaluation Report, 82.1.22 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, NUREG-1801, XI.M38 Revision 1, 6/22/2010

2. OPGP04-ZE-XXXX, STI XXXXXX (DRAFT, not yet numbered)

DRAFT South Texas Project Electric Generating Station, Internal Surfaces Inspection Program Revision DRAFT 3.0PTP03-FP-0109, STI31374957 South Texas Project Electric Generating Station, SprinklerlSpray$ystem Visual Inspection Revision 2, 11/1412001 i

The staff conducted its audit of LRA AMP program elements one through six based on the contents of the new program. Aspects of program elements "scope of program," "parameters monitored or inspected," "detection of aging effects," and "monitoring and trending" of the LRA AMP associated with the exception were not evaluated during this audit. Aspects of these prograrn elements that are not associated with the exception were evaluated and are described below.

A detailed breakout session for this AMP was completed at the site. The following items were discussed in those meetings between the staff and the applicant that would amend, edit and improve the AMP program's implementation program (document No.2 listed above) by:

modifying the text of Section 4.5.3 to include manual manipulation of polymers modifying Section 1.2 to note that the program will be implemented prior to the period of extended operation During the audit, the staff found that program elements "preventive actions" and "acceptance criteria" of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff also found that aspects of program element "monitoring and trending" associated with the exceptions are consistent with the corresponding program elements in the GALL Report AMP. The staff's evaluation of aspects of these program elements associated with the exception will be addressed in the SER. In addition, the staff found that for program elements "scope of program," "parameters monitored or inspected," and "detection of aging effects," sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAls for the subjects discussed below:

• The "scope of program" program element of the LRA AMP design basis documents states the material and environment combinations that are applicable and includes closed-cycle cooling water system components even though no AMR line items with this environment are listed in the LRA managed by this AMP. The applicant's design basis document states that the fire protection system is included within this program. The LRA AMP also states, in the program description, that hardening and loss of strength for "both internal and external surfaces of elastomers" is within the scope of this AMP.

- 54 GALL AMP XI.M38 recommends, in the program description, that "the program consists of"... any water system other than open-cycle cooling water (XI.M20), closed treated water system (XI.M21A), and fire water system (XI.M27)." It is not clear to the staff that these statements are consistent, because the program's scope concerning open cycle cooling water, fire protection and the application of external elastomers is not consistent with the GALL Report.

• The "parameters monitored or inspected" program element of the LRA AMP states, in the applicant's program basis documents, Section 4.5.3 that hardening, cracking, discoloration, and delamination (bubbles) are the inspection parameters for polymers.

The GALL AMP XLM38 recommends examples of inspection parameters for polymers of crazing, scuffing, dimensional change (ballooning and necking), and exposure of internal reinforcement. It is not clear to the staff that these statements are consistent because this program's design documents do not comprehensively consider all the inspection parameters associated with polymers.

The "detection of aging effects" program element of the LRA AMP does not state in the design basis document any guidance concerning sample size of flexible polymeric components. The GALL AMP M38 recommends that the sample size for manipulation of flexible polymeric components has at least 10 percent of available surface area. It is not clear to the staff that these statements are consistent because the sample size associated with physical manipulation of flexible polymeric components in the applicant's document is silent on this aspect versus the GALL Report.

• The "scope of program" program element of the LRA AMP's design basis documents, Section 1.5 states that "in cases where the internal surface is not available for internal examination [volumetric examination] may be substituted for visual examinations." The program description in GALL AMP XI.M38 states "if visual inspection of internal surfaces is not possible, then the applicant needs to provide a plant-specific program." It is not clear to the staff that these statements are consistent because the applicant's program does not identify a program enhancement consistent with the GALL Report.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is not bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation. In order to obtain the information necessary to verify whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing an RAJ for the subject discussed below:

This program's LRA commitment is not consistent with the current staff position, as stated within the SRP-LR Revision 2, concerning future reviews of operating experience for new Aging Management Programs such as the One-Time Inspection Program. The applicant was requested to revise LRA Table A4-1, License Renewal Commitments, Item No. 11 for the One-Time Inspection Program to include a commitment to perform a

- 55 future review of operation experience to confirm the effectiveness of this program or justify why such a review is not necessary.

The staff also audited the description of the LRA AMP provided in the U FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that LRA program elements "preventive actions," and "acceptance criteria" are consistent with the corresponding program elements in the GALL Report AMP. The staff also verified that aspects of LRA program element "monitoring and trending," associated with the exception is consistent with the corresponding program element in the GALL Report. The staff's evaluation of aspects of elements associated with exceptions will be addressed in the SER. The staff also determined that certain aspects of LRA program elements "scope of program," "parameters monitored or inspected," "detection of aging effects," and "operating experience" will require additional information or additional evaluation before consistency can be determined.

Based on this audit, the staff also identified that additional information regarding operating experience is required before a determination can be made regarding the sufficiency of the LRA AMP, as implemented by the applicant, to detect and manage aging. In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

Existing Program Consistent with the GAll Report with Exception(s) and Enhancement(s), lRA AMP B2.1.23, "lubricating Oil Analysis" Summary of Information in the Application: The LRA states that AMP B2.1.23, "Lubricating Oil Analysis Program," is an existing program with enhancements and an exception that is consistent with the program elements in GALL AMP XI.M39, "Lubricating Oil Analysis." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER. This audit report does not consider the sufficiency of exceptions, which will be evaluated in the SER.

The exception affects the LRA "parameters monitored or inspected" program element. The LRA states, the GALL Report recommends using particle-counting test methods to detect evidence of abnormal wear rates or excessive corrosion for lubricating oil in components subject to periodic oil changes. The applicant stated that analysis of the standby diesel generator oil for total particle count does not yield an accurate count due to the dark color of the oil. Instead of particle count testing, the applicant performs an analysis for metal particles by ferrography on a quarterly basis with results that provide indication as to the amount and type of wear particles contained within the oil.

In addition, the LRA states, the GALL Report recommends determining flash points for oils in components that do not have regular oil changes. The applicant stated that flash pOint is not determined for sampled oil from the auxiliary feedwater turbine, BOP diesel generator, or feedwater isolation valve hydraulic oil. It was further reported that flash point is not performed because analysis for particle count, viscosity, total acid/base, water content, and metals content

- 56 provide sufficient information to verify the oil does not contain water or contaminants that would permit the onset of aging effects. The applicant stated that STP monitors the percent fuel dilution in the BOP diesel generator lubricating oil.

As stated above, the staff did not evaluate the sufficiency of this exception during the audit. The staff's evaluation of the adequacy of this exception will be documented in the SER.

The first enhancement affects the LRA AMP "parameters monitored or inspected" program element. The LRA states, the Lubricating Oil Analysis Program procedures will be enhanced to require analysis for particle count of the lubricating oil for the centrifugal charging pump.

The second enhancement affects the LRA AMP "acceptance criteria" program element. The LRA states that the program procedures will be enhanced to require that sample analysis data results, for which no acceptance criteria is specified, be evaluated and trended against baseline data and data from previous samples to determine the acceptability of oil for continued use.

In Section A4 of the LRA, the applicant committed (Commitment No. 18) to implement these enhancements prior to the period of extended operation.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the keyword, "lube oiL" The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

• 1. LMON-FW-MOBL YAP Lubrication Analysis Specification Sheet 1/2212001

2. LMON-CH-YORK DOC Lubrication Analysis Specification Sheet 1/17/2001

3. LMON-FW-MOBL GOV Lubrication Analysis Specification Sheet 1/2212001 The staff conducted its audit of LRA AMP program elements one through six based on the contents of the existing program as modified by the proposed enhancements. Aspects of program element "parameters monitored or inspected" of the LRA AMP associated with the exception were not evaluated during this audit. Aspects of this program element that are not associated with the exception were evaluated and are described below.

During the audit, the staff found that program elements "scope of program," "preventive actions,"

"detection of aging effects," "monitoring and trending," and "acceptance criteria" of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff also found that aspects of program element "parameters monitored or inspected" not associated with the exception are consistent with the corresponding program element in the GALL Report AMP.

- 57 The staff's evaluation of aspects of this program element associated with the exception will be addressed in the SER.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (I.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that LRA program elements "scope of program," "preventive actions," "detection of aging effects," "monitoring and trending,"

"acceptance criteria," and "operating experience" are consistent with the corresponding program elements in the GALL Report AMP. The staff also verified that aspects of LRA program elements "parameters monitored or inspected" not associated with the exception are consistent with the corresponding program element in the GALL Report. The staffs evaluation of aspects of elements associated with exceptions will be addressed in the SER.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.

In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

New Program Consistent with the GALL Report, LRA AMP 82.1.24, "Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements" Summary of Information in Application: The LRA states that AMP B2.1.24, "Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements," is a new program that is consistent with the program elements in GALL AMP XI.E1, "Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements." The applicant committed to implement this program prior to the period of extended operation in LRA Section A 1.24. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the switchyard, manholes, transformers, and metal enclosed buses. The staff also conducted an independent database search of the applicant's operating experience database using the the following search terms: "bus'," "cable," "cracking," "stress," "thermal," and "underground."

- 58 The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. STP-AMP-B2.1.24 Electrical Cables and Connections Not Subject to 10 CFR Revision 1, 50.49 Environmental Qualification Requirements 6/22/2010

2. CR 05-1384 Request Operability Review For a Degrading Condition On MCC E2B3 10/2/2006

• 3. CR 05-522 Cable Jackets for Pump Indications are dry rotted and cracked on several cables 10/28/2005

4. CR 05-7067 Engineering Evaluation is Needed For Low Megger I

Readin~

16/62005

5. CR 06-13332 The Cable Tray Fire Detection Thermal Wire Located Outside of Room 305 In The RCB Has An Approximate 4

. 12/13/2006 Inch Section That The Jacketing Has Been Removed/Damaged.

• 6. CR 98-15248 Protecto-wire On The Face ofThe Tray Was Observed To Have Insulation Damage 10/24/1998

7. CR 02-6517 RX Head Stud Tensioner Position Indication Cable Has A Damaged Outer Jacket And Requires Repair.

5/9/2002

8. CR 02-16248 The Rubber Insulation Over The Wires Has Degraded Due To Heat.

11/5/2002

9. CR 01-6147 Top Cables In Festoon Show Indication Of Dry Rot And Cracking At The Carriers.

04/03/2001

10. CR 03-6927 Cables For The Portable Diesel Generator Load Bank Need To Be Replaced 04/21/2003

11. OPG03-ZX-0013 Operating Experience Program Revision 9, 2/1/2011 During the audit of program elements one through six, the staff found that program elements "scope of program," "preventive actions," "detection of aging effects," "monitoring and trending,"

and "acceptance criteria" of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For program element "parameters monitored or inspected," sufficient information was not available to determine whether it was consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAls for the subjects discussed below.

GALL AMP XI.E1 Revision 2, states that adverse localized environment exists based on the most limiting condition for temperature, radiation, or moisture for the insulation material of cables or connections. It further states that adverse localized environment can be identified through the use of an integrated approach such as review of EO zone maps that show radiation levels and temperature for various plant areas, consultations with plant staff who are cognizant of plant conditions, utilization of infrared thermography to identify hot spots on a real-time basis, and the review of relevant plant-specific and industry operating experience. In the LRA Section 82.1.24, the applicant states that Non-EO cables, connections and terminal blocks within the scope of license renewal in accessible areas within adverse localized environments are

- 59 inspected. It is not clear to the staff what methodology the applicant will use to identify adverse localized environment.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that LRA program elements "scope of program," "preventive actions," "detection of aging effects," "monitoring and trending,"

"acceptance criteria," and "operating experience" are consistent with the corresponding program elements in the GALL Report AMP. The staff also determined that certain aspects of LRA AMP program elements "scope of program" and "parameters monitored or inspected" will require additional information or additional evaluation before consistency can be determined.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.

In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

Existing Program Consistent with the GALL Report with Enhancement(s), LRA AMP 82.1.25, "Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements" Summary of Information in the Application: The LRA states that AMP B2.1.25, "Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements," is an existing program with enhancements that are consistent with the program elements in GALL AMP XI.E3, "Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER.

The first enhancement affects the LRA AMP "scope of program" program element. The LRA states that procedures will be enhanced to identify the cables and manholes that are within the scope of the Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements program.

The second enhancement affects the LRA AMP "preventive actions" and "detection of aging effects" program elements. The LRA states that procedures will be enhanced to require that the

- 60 cable manholes be inspected for water collection based on plant experience. The enhancement requires that the inspection frequencies for all in-scope manholes be at least once every two years. The enhancement requires any manholes containing water to be pumped dry, the source of the water is investigated, and the inspection frequency increased based on past experience.

The third enhancement affects the LRA AMP "parameters monitored or inspected" program element. The LRA states that procedures will be enhanced to require all in-scope non-EQ inaccessible medium voltage cables exposed to significant moisture simultaneously with significant voltage be tested to provide an indication of the conductor insulation condition.

The fourth enhancement affects the LRA AMP "acceptance criteria" program element. The LRA states that procedures will be enhanced to require that the acceptance criteria be defined prior to each test for the specific type of test performed and the specific cable tested.

The fifth enhancement affects the LRA AMP "corrective actions" program element. The LRA states that procedures will be enhanced to require an engineering evaluation that considers the age and operating environment of the cable be performed when the test acceptance criteria are not met.

In Appendix A, Table A4-1, of the LRA, the applicant committed (Commitment No. 20) to implement these enhancement(s) prior to the period of extended operation.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of in scope cable manholes. The staff also conducted an independent search of the applicant's operating experience database using the following search terms: "manhole," "duct," "water,"

"submergence," "cable," "underground," and "vault."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed i

Document Title Revision I Date

1. STP OPGP04ZEOO07 License Renewal Electrical Aging Management Revision: Draft

2. TR-11ST Electrical Component Aging Evaluation License Renewal Topical Report

3. Integrated Inspection Report 05000498/2009005 0500049912009005 South Texas Project Electrical Generating Station NRC Integrated Inspection Report 1/28/2010

4. Integrated Inspection Report 05000498/2010003 05000499/2010003 South Texas Project Electric Generating Station - NRC Integrated Inspection Report 8/4/2010

i

- 61 Revision I Date Title Document 1/24/2010 Inspection Report South Texas Project Electrical Generating Station - NRC

5. Integrated Integrated Inspection Report 05000498/2010005 0500049912010005 I

5/14/2002

6. CR 02-7166 Condition Record

..~i 9/6/2005 Condition Record

7. CR 05-11188

8. CR 05-13907 Condition Record 7/27/2006 Condition Record

9. CR 06-9530 10/20/98 Condition Record

• 10. CR 98-16869 12/2/2010

• 11. IN 2010-26 Information Notice 2010-26 Revision 3, CFR 50.49 EO Requirements

12. STP-AMP-B2.1.25 Inaccessible Medium Voltage Cables Not Subject to 10 10/4/2010 Response to NRC Generic Letter 2007-01 6/21/2007

13. N/A 4/16/2008

14. N/A Response to Request for Additional Information on Generic Letter 2007-01

15. STP-AMP-B2.1.25 Inaccessible Medium Voltage Cables Not Subject to 10 Revision 4, CFR 50.49 EO Requirements 6/2/2011 5/18/2010

16. CR-10-11611 Condition Record 9/15/2005

17. CR-05-11548 Condition Record Operating Experience Program Revision 9,

• 18. OPG03-ZX-0013

. 2/1/2011 Revision 26, Underground Duct Banks Electrical Class IE General Arrangement Station i 19. 5E100E02100 10/10/2006

20. 6-E-10-0-E-21 01 Electrical BOP Manholes Schedule and Details

' Revision 15, I 3/26/1986 I

21. 6-E-10-0-E-21 02 Electrical BOP Manhole Schedule and Details Revision 17, 3/26/1986 i

The staff conducted its audit of LRA AMP program elements one through six based on the contents of the existing program as modified by the proposed enhancements.

In addition, the staff found that for program elements "scope of program," "preventive actions,"

"parameters monitored or inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAls for the subjects discussed below.

GALL AMP XI.E3 states that the scope applies to all inaccessible or underground (e.g., in conduit, duct bank, or direct buried) power cables (greater than or equal to 400 volts) within the scope of license renewal exposed to adverse environments, primarily Significant moisture (exposure for more than a few days). It is not clear to the staff that the "scope of program" program element of the LRA AMP is consistent because it is not clear that the "scope of program" program element includes greater than 400 volt power cables and that medium voltage cable may be screened out based on the significant voltage criterion. The application of GALL AMP XI.E3 to medium voltage cables was based on the operating experience available at the time Revision 1 of the GALL Report was developed. However, industry operating

- 62 experience subsequent to the GALL Report, Revision 1, indicates that the presence of water or moisture can be a contributing factor in inaccessible power cables failures at lower service voltages (400 V to 2 kV). Applicable operating experience was identified in licensee responses to Generic Letter (GL) 2007-01, "Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients," which included failures of power cables operating at service voltages of less than 2 kV where water was considered a contributing factor. The staff also noted that the significant voltage screening criterion (subject to system voltage for more than energized 25% of the time) was not applicable for all of the inaccessible power cable failures noted.

GALL AMP XI. E3 provides specific recommendations for "preventive actions" "detection of aging effects," "monitoring and trending," and "acceptance criteria" such as periodic annual inspections and a six-year testing frequency. In particular, the staff has determined, based on the review of the cable failure data, that an annual inspection of manholes and a cable test frequency of at least every 6 years (with evaluation of inspection results to determine the need for an increased inspection frequency) is a conservative approach to ensuring the operability of power cables and, therefore, should be considered. The use of test and inspection results in the determination of the need for adjustment of test and inspection frequencies should be considered.

Furthermore, with respect to "preventive actions," industry operating experience subsequent to the GALL Report, Revision 1, has also shown that some NRC licensees may experience cable manhole water intrusion events, such as flooding or heavy rain, that subjects cables within the scope of program for GALL AMP XI. E3 to significant moisture. The staff has determined that event driven inspections of cable manholes, in addition to a 1 year periodic inspection frequency, is a conservative approach and, therefore, should also be considered.

Based on the above, it is not clear to the staff that the applicant's aging management program elements, "scope of program," "preventive actions," "parameters monitored or inspected,"

"detection of aging effects," "monitoring and trending," and "acceptance criteria" are consistent with GALL AMP XI.E3 or SRP-LR Section A.1.2.3.10 concerning inspection and test frequencies, event driven occurrences, or in-scope inaccessible power cable and screening criteria. Therefore. additional information is required by the staff to verify the applicant's conclusion that the effects of aging will be managed adequately so that the in-scope inaccessible power cable intended functions will be maintained during the period of extended operation.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation. In order to obtain the information necessary to verify whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAls for the subjects discussed below.

- 63 It is not clear to the staff that the applicant's aging management program elements, "scope of program," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" are representative of recent industry operating experience consistent with GALL AMP XI.E3 or SRP-LR, Section A.1.2.3.1 0 concerning inspection and test frequencies, event driven occurrences, in-scope inaccessible power cable and screening criteria. Therefore, additional information is required by the staff to verify the applicant's conclusion that the effects of aging will be managed adequately so that the in-scope inaccessible power cable intended functions will be maintained during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR Supplement was an adequate description of the LRA AMP. In order to obtain the information necessary to verify the sufficiency of the UFSAR Supplement program description, the staff will consider issuing RAls for the subjects discussed below.

The applicant's UFSAR supplement did not reflect the information in SRP-LR Table 3.0-1 Revision 2, in the following areas:

• The deletion of the "exposure to significant voltage" criterion (defined as subject to system voltage for more than 25 percent of the time)

Increased scope to include 400V to 2kV inaccessible power cables Frequency of inspections for water collection in manholes at least annually

• Frequency of testing of in-scope inaccessible power cables for degradation of cable insulation at least once every 6 years Incorporate event-driven inspections (e.g., as a result of heavy rain or flood)

In addition, it is not clear that cable test results are evaluated to determine the need for more frequent testing consistent with staff recommendations.

Audit Results: The staff identified certain aspects of the "scope of program," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," "acceptance criteria," and "operating experience" LRA program elements which will require additional information or additional evaluation before consistency can be determined.

Based on this audit, the staff also identified that additional information regarding operating experience is required before a determination can be made regarding the sufficiency of the LRA AMP, as implemented by the applicant; to detect and manage aging. In addition, the staff identified a need for additional information regarding the adequacy of the program description in the UFSAR Supplement.

- 64 Existing Program Consistent with the GALL Report with Enhancement(s), LRA AMP B2.1.26, "Metal Enclosed Bus" Summary of Information in the Application: The LRA states that AMP B2.1.26, "Metal Enclosed Bus" is an existing program with enhancements that is consistent with the program elements in GALL AMP XI.E4, "Metal Enclosed Bus." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER.

The enhancement affects the LRA AMP "scope of program," "preventive actions," "detection of aging effects," "acceptance criteria," and "corrective actions" program elements. The LRA states that the Metal Enclosed Bus program procedures will be enhanced to proceduralize the existing bus inspection activities for inspection and testing of the MEBs to identify license renewal scope, specific bus inspection requirements, aging effects to be detected, frequency of inspections, acceptance criteria, and actions to be taken when acceptance criteria are not met.

In Appendix A, Table A4-1, of the LRA, the applicant committed (Commitment No. 21) to implement these enhancement(s) prior to the period of extended operation.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of metal enclosed bus and iso-phase bus outside the turbine buildings. The staff also conducted an independent database search of the applicant's operating experience database using the the following search terms: "bus insulation," "loose connection," "corrosion," and "cracking."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. STP-AMP-B2.1.26 Metal Enclosed Bus Revision 2

! 2. TR-11ST Electrical Component Aging Evaluation License Renewal Revision 1 Topical Report

• 3. CR 04-12979 Condition Record on Cracked Noryl on the Horizontal 09/24/2004 Section of Bus

4. PMI-EM-GM-004 Main Generator Grounding Transformer Neutral Bus and 315/2008 I

Generator Isol{oase Bus Inspection The staff conducted its audit of LRA AMP program elements one through six based on the contents of the existing program as modified by the proposed enhancements.

During the audit, the staff found that program elements "scope of program," "preventive actions,"

"parameters monitored or inspected," "monitoring and trending," and "acceptance criteria" of the LRA AMP are consistent with the corresponding element(s) of the GALL Report AMP. In addition, the staff found that for program element "detection of aging effects," sufficient information was not available to determine whether it was consistent with the corresponding program element of the GALL Report AMP. In order to obtain the information necessary to

- 65 verify whether this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAls for the subject discussed below.

GALL AMP XI.E4, Revision 2, under the "detection of aging effects" program element, states that a sample of accessible bolted connections is inspected for increased resistance of connection by using thermography or by measuring connection resistance using a micro-ohmmeter. Twenty percent of the population with a maximum sample of 25 constitutes a representative sample size. Otherwise, a technical justification of the methodology and sample size used for selecting components should be included as part of the AMP's site documentation.

It further states that if an unacceptable condition or situation is identified in the selected sample, a determination is made as to whether the same condition or situation is applicable to other connections not tested. In the South Texas Project (STP) Aging Program Evaluation Report for Metal Enclosed Bus (MEB) B2.1.26, STP-AMP-B2.1.26, under same element, it states that a sample of non-segregated phase bus accessible bolted connections in each bus section shall be inspected for evidence of overheating using thermography. The applicant has not identified the sample size of bolted connections nor developed the technical basis for selecting samples of bolted connections in each MEB section.

The "detection of aging effects" program element is not specifically provided in the LRA AMP.

However, the STP basis document, STP-AMP-B2.1.26-Revision 2, states that a sample of the MEB accessible bolted connections in each bus section shall be inspected using thermography for evidence of overheating. The applicant also states that acceptable criteria will be based on a temperature rise above the reference temperature and the reference temperature will be the ambient temperature or the baseline temperature date from the same type of connections being tested. The inspections are performed on all accessible bus sections while the bus is energized. In general, windows are installed on the MEB for thermography inspections. The metal enclosed cover may mask the heat created by loosening of bus connections and the temperature differences between bus connections which may not be detected if windows are not installed on MEBs.

The GALL Report also states, under the "detection of aging effects" program element, that a sample of accessible bolted connections will be checked for loose connections. In the basis document STP-AMP-B2.1.26-Revision 2, the applicant only requires a sample of the non segregated phase bus bolted connections to be inspected but it was silent on the inspection of iso-phase bus connections. Iso-phase bus connections could be loose due to ohmic heating and could cause iso-phase bus failure.

In addition, relative to the corrective actions program element, the staff reviewed Condition Record (CR) 04-12979 relating to Noryl cracking on a horizontal section of non-segregated bus section. The Noryl sleeve covering part of the B-phase bus was split (approx. 3" long) close to a bus support. The copper bus could be observed through the split. The applicant evaluated this CR in 2004 and concluded that repair of the bus was not required if the separation distance was greater than 7 inches at the 15 kV voltage level and the crack was acceptable. The staff questioned the applicant evaluation in light of industry operating experience with bus failures due to cracked Noryl insulation and requested the applicant to follow up on the CR. In response to the staff request, the applicant provided the preventive maintenance work order (PMWO) EM 1-02000085. This work order indicated that the cracked Noryl was replaced/repaired. The

- 66 applicant also provided PM 0286/0287, which requires replacing cracked or defective Nory!.

This resolved the staff concern about the corrective action taken by the applicant.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that the "scope of program," "preventive actions," "parameters monitored or inspected," "monitoring and trending," "acceptance criteria,"

and "operating experience" LRA program elements are consistent with the corresponding program elements in the GALL Report AMP. The staff also determined that certain aspects of the "detection of aging effects" LRA AMP program element will require additional information or additional evaluation before consistency can be determined.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.

In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

Existing Program Consistent with the GALL Report with Exception(s), LRA AMP 82.1.27, "ASME Section XI, Subsection IWE" Summary of Information in the Application: The LRA states that AMP B2.1.27, "ASME Section XI, Subsection IWE," is an existing program with exceptions that is consistent with the program elements in GALL AMP XI.S1, "ASME Section XI, Subsection IWE." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER. This audit report does not consider the sufficiency of exceptions, which will be evaluated in the SER.

The exception affects the LRA "scope of program," "parameters monitored or inspected,"

monitoring and trending," "acceptance criteria," "corrective actions," and "confirmation process,"

program elements. The LRA states that the 2004 edition of the ASME Code is implemented; however, the GALL Report discusses requirements in the 1998 code edition and endorses the 2001 edition. The LRA takes exception to the differences between the 1998 and the 2004 code editions.

As stated above, the staff did not evaluate the sufficiency of this exception during the audit. The staff's evaluation of the adequacy of this exception will be documented in the SER.

- 67 Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the following search terms: "coating,"

"liner," "corrosion," "rust," and "containment."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document

1. STP-AMP-B2.1.27 Title Revision I Date South Texas Project Aging Management Program Revision 3, Evaluation Report "ASME Section XI, Subsection IWE 10/5/2010

• 2. OPEP10-ZA-0025 B2.1,27" ASME Section XI Visual Examination for Containment Revision 3,

3. OPGP03-ZE-0075 Metal Liner Inspections 12/1/2010 Inservice Inspection Program for Containment Metal Liner Revision 7,

4. OPSP11-RC-0015

• 5.

ASME Section XI Inservice Inspection Summary Report for the 1RE151nservice Inspection of Unit

. 3/23/2011 Revision 16, 3/14/2011 February 2010 i

• 6. CR 98-7801

7. CR 00-6787 1

Condition Record: "Develop and Implement the IWE Program for Unit 1 and Unit 2" Condition Record: "Areas of Minor Surface Corrosion Exist 5/18/1998 4/13/2000

8. CR 07*3125

9. CR 03*11820

, 10.0PSP11*IL-0008 Condition Record: "During 2RE12 Pre-Outage Visual... "

Condition Record: "Unit 1 Equipment Hatch Sealing Surface is Pitted in Bottom Portion... "

Reactor Containment Building Inspection 2/27/2007 7/31/2003 Revision 3 The staff conducted its audit of LRA AMP program elements one through six based on the contents of the existing program. Aspects of program elements "scope of program,"

"parameters monitored or inspected," "monitoring and trending," and "acceptance criteria" of the LRA AMP associated with the exceptions were not evaluated during this audit. Aspects of these program elements that are not associated with the exceptions were evaluated and are described below, During the audit, the staff found that the aspects of program elements "scope of program/'

"parameters monitored or inspected," "monitoring and trending," and "acceptance criteria" not associated with the exceptions are consistent with the corresponding program elements in the GALL Report AMP. The staff's evaluation of aspects of these program elements associated with the exceptions will be addressed in the SER. In addition, the staff found that for program elements "preventive actions" and "detection of aging effects," sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAls for the subjects discussed below.

- 68 The "preventive actions" program element of the LRA AMP does not discuss preventive actions related to proper storage, lubricants, and installation of high strength bolts. The GALL Report AMP recommends following recommendations discussed in NUREG-1339 and other industry documents regarding proper storage and lubricants for high strength bolts. It is not clear to the staff that the applicant's AMP adequately addresses the recommendations in the GALL Report.

The "detection of aging effects" program element of the LRA AMP does not explain if there are any stainless steel penetration sleeves, dissimilar metal welds, bellows, or steel components that are subject to cyclic loading but have no current licenSing basis fatigue analysis. The GALL Report AMP recommends surface examinations for any of the above components which are subject to cyclic loading but have no current licensing basis fatigue analysis. It is not clear to the staff that these statements are consistent because the applicant does not explain if they have components which meet these criteria and if they do, whether or not the recommended inspections are being conducted.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (I.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation. In order to obtain the information necessary to verify whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAls for the subject discussed below.

During the audit, the staff reviewed a Condition Record (CR 00-6787) which identified minor corrosion around the containment moisture barrier. The applicant stated that the condition had been repaired and found acceptable; however, it was not clear to the staff that the appropriate follow-up inspections had been conducted per IWE-2420. It was also unclear to the staff if an analysis of the moisture barrier area had been conducted to demonstrate that the augmented inspections of IWE-1241 were not necessary.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that aspects of LRA program elements "scope of program," "parameters monitored or inspected," "monitoring and trending," and "acceptance criteria" not associated with the exceptions are consistent with the corresponding program elements in the GALL Report. The staffs evaluation of aspects of elements associated with exceptions will be addressed in the SER The staff also determined that certain aspects of LRA AMP program elements "preventive actions" and "detection of aging effects" will require additional information or additional evaluation before consistency can be determined.

- 69 Based on this audit, the staff also identified that additional information regarding operating experience is required before a determination can be made regarding the sufficiency of the LRA AMP, as implemented by the applicant, to detect and manage aging. In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

Existing Program Consistent with the GALL Report with Enhancement(s), LRA AMP 82.1.28, "ASME Section XI, Subsection IWL," and Existing Program Consistent with the GALL Report, LRA AMP 83.3, "Concrete Containment Tendon Prestress" Summary of Information in the Application: The LRA states that AMP B2.1.28, "ASME Section XI, Subsection IWL," is an existing program with an enhancement that is consistent with the program elements in GALL AMP XI.S2, "ASME Section XI, Subsection IWL." The LRA also states that evaluations of tendon prestressing forces are addressed under B3.3, "Concrete Containment Tendon Prestress" program, within the applicant's "ASME Section XI, Subsection IWL" program, is also an existing program without exceptions and enhancements that is consistent with the program elements in X.S1 "Concrete Containment Tendon Prestress,"

program. The staff reviewed B2.1.28 and B3.3 LRA programs simultaneously during the site audit. To verify this claim of consistency, the staff audited the LRA AMPs. Issues identified but not resolved in this report are addressed in the SER.

The enhancement for the "ASME Section XI, Subsection IWL" program, affects the LRA scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, corrective actions, confirmation process, and administrative controls program elements. The LRA states that it will incorporate in its procedures the 2004 Edition of ASME Code,Section XI Subsection IWL (no addenda), supplemented with the applicable requirements of 10 CFR Part 50.55a(b)(2).

In Appendix A of the LRA, the applicant committed (Commitment No. 22) to implement these enhancements prior to the period of extended operation.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. In addition, on June 14, 2011, the staff conducted walkdowns of: (1) Unit 1 and Unit 2 containment buttresses and exteriors of containment structures from ground, turbine deck, and fuel handling building roof elevations; (2) Unit 2 tendon gallery floor at -36 ft. elevation and the area between south containment wall and the fuel handling building at -13 ft. elevation.

Based on the concerns identified during the walkdowns, the following 2 Condition Records (CR) were issued:

(1) CR-110033 "Grease Stains on Unit 2 Containment Wall" (2) CR-110085 "Leaking Grease Cans in Unit 2 Tendon Gallery" The staff also conducted an independent search of the applicant's operating experience database using the following search terms: "IWL," "containment," "tendon," and "concrete."

- 70 The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document

1. 4C23HCSOO01 i

' 2. OPGP03-ZE-0027 3.OPSP09-TD-0001

4. NUERG-1346

5. STP UFSAR

6. STP#-31757332

7. STP#-32463769

8. OPGP03-ZX-0002

9. PSC Procedure 8.4 10.0PG04-ZA-0002

11. CC-5207

12. ST-N1024-501

! 13. 2C01-9-C-1060 14.2C23-9-C-1016 1 15.2C23-9-C-1020 1 16.2C23-9-C-1021

17. 2C02-9-C-1031 18.2C02-9-C-1032 19.2C22-9-C-1033 20.2C22-9-C-1036 21.2C23-9-C-1018

22. ASTM A421 I A421M-10

23. CR No 04-7430 Title Revision f Date Specifications of Inservice Surveillance of Containment Revision 8 Post-Tensioning System ASME Section XI Repair, Replacement and Post Revision 27 Maintenance Pressure Testing Containment Tendon TestiEnd Anchorage and Adjacent Revision 4 Concrete Inspection Technical Specifications South Texas Project, Unit Nos. 1 March 1989 and 2 South Texas Project Electric Generating Station (STPEGS)

Revision 15 Updated Final Safety Analysis report (UFSAR)

Final report for the 15th Post-Tensioning Surveillance 6f10f2004 Final report for the 20th Post-Tensioning Surveillance 4f23f2009 Condition Record Procedure Revision 40 i

Precision Surveillance Corporation (PSC) Procedure 8.4 1

"PSC Quality Surveillance Procedure, General Visual

, 11f19f2010 Examination of Concrete Containment" Problem Statement: Missing wire during the 20 m year I Revision 11 I

containment post tensioning surveillance in the horizontal tendon 2H021 in Unit 2 was identified, which violated subsection IWL-3221.3(c) of the ASTM Section XI Code...

Reactor Containment Building Tendon Surveillance Revision 8 i

Regression Analysis to Predict the Tendon Forces 04/15/2009 Concrete Strain Gauges & Def. Meas. Points, Reactor Revision 5 Containment Building Elevation-Plan" J

2C23-9-C-1 016 "Concrete Post tensioning Reactor Revision 2 Containment Building Interior Elevation, U 1 & 2 Reactor Containment Building Post-tensioning System, U

! Revision 6 1& 2 Reactor Containment Building Post-tensioning System, U Revision 1 1& 2 Reactor Containment Building Containment Buttress Plan &

Revision 2 Section, U 1& 2 Reactor Containment Building Containment Buttress Revision 2 Reinforced Sections & Details, U 1 & 2 Reactor Containment Building Containment Dome Revision 7 Reinforcement Plan, U 1 & 2 Reactor Containment Building Containment Dome tendon Revision 1 Anchorage Locations, U 1 & 2 Concrete Post-Tensioning Reactor Containment Building Revision 2 Penetration Schedule Standard Specification for Uncoated Stress-Relieved Steel 2010 Wire for Prestressed Concrete

==

Description:==

Grease voids in excess of 10% of the duct I

volume were identified in Unit 2 during 15th year post

, 7f20f2010 tensioning surveillance - closed CR.

i

- 71 Title I Revision I Date Document i

==

Description:==

NRC IN 2010-14, Discussed the requirement I

8/10/2010 to perform containment exterior concrete surface

. 24. CR No 10-17171 Open CR i

examinations on a 5 year frequency +1-1 year - open CR.

Problem Statement: Horizontal tendon, 2H021 was missing 125. CR No 09-1055-1 wire during 20th year containment post-tensioning i 2009 i per OPGP04-ZA-0002 surveillance in U2.

6/15/2011

==

Description:==

grease stains on Unit 2 containment wall

26. CR No 11-10003 6/16/2011

==

Description:==

leaking grease cans in Unit 2 tendon gallery

27. CR No 11-10085

==

Description:==

NRC IN 99-10, Degradation of Prestressing

. 28. Industry Event Tendon System in Prestressed Concrete Containments -

Analysis - Plant Issues included:

i

• Revision 4 Impact Evaluation 99 (1) prestressing tendon wire breakage, 6843, OPGP03-ZX (2) effects of high temperature on tendon relaxation, 0013 (3) trend analysis of prestressinQ force.

29.0PGP03-ZX-0013 Revision 9 Operating Experience Program

30. Program Basis South Texas Project Aging Management Program i Revision 1 Document Evaluation Report: Concrete Containment Tendon

! 10/5/2010 Prestress - B3.3 NUREG 1801 Program X.S1 I

31. Program Basis South Texas Project Aging Management Program Document Evaluation Report: ASME Section XI, Subsection IWL i =/~~~s~~~ 3 32.0PGP03-ZX-0002 Condition Reporting Process I Revision 38 I

The staff conducted its audit of LRA AMP program elements one through six based on the contents of the 82.1.28 and 83.3 LRA existing programs.

During the audit, the staff found that program elements "scope of program," "preventive actions,"

and "monitoring and trending" of the LRA 82.1.28 and 83.3 AMPs are consistent with the corresponding elements of the GALL Report AMPs.

For the combined programs, the staff found that for the program element "parameters monitored or inspected," insufficient information was available to determine whether it is consistent with the corresponding program element of the GALL Report. The staff also determined that additional information is required for certain aspects of LRA program elements "detection of aging effects" and "acceptance criteria" before consistency with the corresponding program elements of the GALL Report AMP can be determined. Specifically the staff noted that, although the applicant is committed to perform visual inspections of containment concrete and post-tensioning systems, the staff noted grease stains on the containment wall during walkdowns that led to the above-listed CRs. Similarly, for the "parameters monitored or inspected" and "acceptance criteria" program elements of the LRA AMP, the staff noted that there was no discussion of quantitative acceptance criteria based on the ACI 349.3R Code. During the audit, it was unclear to the staff if the quantitative evaluation and acceptance criteria in Chapter 5, "Evaluation Criteria" of ACI 349.3R provide the basis to establish general structural condition of containment structure. Furthermore, the staff found that for the program element "acceptance criteria" (see LRA Section 83.3), insufficient information was provided in the LRA to determine the corrective actions taken on failed lift-off tests of two tendons and grease voids found in excess of surveillance requirements under the Containment Tendon Prestress Program. In order to obtain the information necessary to verify whether these program elements are consistent with the

- 72 corresponding program elements of the GALL Report AMP, the staff will consider issuing RAls for the subjects discussed above.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation. In order to obtain the information necessary to verify whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing an RAI for the subject discussed below.

During the audit, the staff reviewed calculations CC-5207, Revision 8, "Reactor Containment Building Tendon Surveillance," ST -N1 024-501, 04/15/09, "Regression Analysis to Predict the Tendon Forces," and interviewed the applicant's staff regarding resolution of the issue described in NRC Information Notice (IN) 99-10, "Degradation of Pre-Stressed Tendon Systems in Pre Stressed Concrete Containments," which includes the effects of high temperature on the pre stressing force in tendons. The staff concluded that the effects of high temperature on the pre stressing forces in tendons may have not been considered appropriately; therefore, the staff will consider issuing an RAI.

The staff also audited the descriptions of the LRA AMPs provided in the UFSAR Supplement.

The staff found these descriptions to be consistent with the descriptions provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that for B2.1.28 and B3.3 LRA programs, "scope of program," "preventive actions," and "monitoring and trending" program elements are consistent with the corresponding program elements of the GALL Report AMPs. The staff also identified that "parameters monitored or inspected," "detection of aging effects," and "acceptance criteria" LRA program elements will require additional information or additional evaluations before consistency can be determined.

Based on this audit, the staff also identified that additional information regarding operating experience is required before a determination can be made regarding the sufficiency of the LRA AMP, as implemented by the applicant. to detect and manage aging. In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the programs.

Existing Program Consistent with the GALL Report with Enhancement(s), LRA AMP B2.1.29, "ASME Section XI, Subsection IWF" Summary of Information in the Application: The LRA states that AMP B2.1.29, "ASME Section XI, Subsection IWF," is an existing program with enhancement that is consistent with the program elements in GALL AMP XI.S3, "ASME Section XI, Subsection IWF." To verify this claim of consistency, the staff audited the LRA aging management program (AMP). Issues identified but not resolved in this report are addressed in the safety evaluation report (SER).

i

- 73 The enhancement affects the LRA AMP "scope of program," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," "acceptance criteria," and "corrective actions" program elements. The LRA states that the procedures will be enhanced to incorporate the 2004 Edition of ASME Code,Section XI, Subsection IWF (with no addenda).

In Appendix A of the LRA, the applicant committed (Commitment No. 23) to implement this enhancement prior to the period of extended operation.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed on-site documentation provided by the applicant. In addition, the staff conducted walkdowns of the essential cooling water intake structure, Unit 1 turbine building, Unit 2 mechanical auxiliary building, Unit 2 fuel handling building, and the Unit 2 spent fuel pool area. The staff also conducted an independent search of the applicant's operating experience database using the following search terms: "bolt," "support," "inspect," "corro," "degrad," and "hanger."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision { Date

1.

South Texas Project Aging Management Program i Revision 1, Evaluation Report: ASME Section XI, Subsection lWF-

• 6/28/2010 82.1.29 and STP Aging Management Industry Operating Experience Report for AMP XI.S3, "ASME Section XI, i

Subsection IWF"

... -------4 2.0PEP10-ZA-0023 Visual Examination of Component Supports For ASME Revision 5,Section XI Inservice Inspection 12/01/10

3. OPGP04-ZE-0304 Inservice Inspection Program for Welds and Component Revision 10, Supports 9/30/2010 I

! 4.

Inservice Inspection Summary Report for Component 11/29/2005 Supports, Containment Metal Liner, Repair and Replacement, System Pressure Testing and Weld I

Inspection Programs

5.

Inservice Inspection Summary Report for Welds and 11/5/0303 Component SUPr:>.orts - 1 RE11

6.

Inservice Inspection Summary Report 2RE12 7/25/2007

.7.

Inservice Inspection Summary Report 1 RE13

~

1/8/2007 I

8.

Inservice Inspection Summary Report 2RE13 1/20/2009

9. VTC-2011-007, 008, Visual Component Support Examination Examples

! and 009

10.

Inservice Inspection Program Plan for Examination of

! 9/30/2008 Component Supports, Concrete Containment, Containment Metal Liner, Repair/Replacement Activities, Steam Generator Tubing, System Pressure Testing and Weld Inspections of South Texas Project Electric Generating Station Units 1 and

- 74 The staff conducted its audit of LRA AMP program elements one through six based on the contents of the eXisting program (use for existing programs with enhancements) as modified by the proposed enhancements.

During the audit, the staff found that program elements "scope of program," "preventive actions,"

"parameters monitored or inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the "operating experience" program element, the staff found that the operating experience provided. by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation. In order to obtain the information necessary to verify whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing an RAI for the subject discussed below.

Upon review of plant-specific operating experience, the staff noted that during inservice inspection examination activities for a component support on the essential cooling water intake structure, excessive corrosion was found on the support baseplate and baseplate bolts. The licensee performed an engineering evaluation of the corroded support to determine whether the component was unacceptable for continued service. The engineering evaluation determined that the component support still met the criteria for functionality in accordance with subsection IWF-3000. The licensee used the provisions of ASME Code Case N-491-2, Section IWF-2430 to justify that no successive or additional examinations would need to be conducted.

Notwithstanding, the licensee chose to rework the component to arrest further corrosion. On a field walk-down of the area, the staff noticed that adjacent supports in the same area showed signs of excessive corrosion. The licensee issued a Condition Record to repair the supports the staff identified as showing signs of degradation. The staff was concerned that, on a programmatic level, when component supports that are in the scope of lSI examinations are reworked to as-new condition, they are no longer representative of adjacent component supports that show similar signs of aging but are not in the specific lSI inspection sample.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that LRA program elements "scope of program," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" are consistent with the corresponding program elements in the GALL Report AMP.

Based on this audit, the staff also identified that additional information regarding operating experience is required before a determination can be made regarding the sufficiency of the LRA

- 75 AMP, as implemented by the applicant, to detect and manage aging. In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

Existing Program Consistent with the GALL Report with Enhancement(s), LRA AMP 82.1.30, "10 CFR Part 50 Appendix J" Summary of Information in the Application: The LRA states that AMP B2.1.30, "10 CFR Part 50, Appendix J," is an existing program with an enhancement that is consistent with the program elements in GALL AMP XI.S4, "10 CFR Part 50, Appendix J." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

The enhancement affects the LRA AMP "Corrective Actions" program element. The LRA states that prior to the period of extended operation procedures will be enhanced to specify a surveillance frequency of 10 years following a successful Type A test.

In Appendix A of the LRA, the applicant committed (Commitment No. 24) to implement the enhancement prior to the period of extended operation.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the keyword: "Appendix J."

The table below lists the documents, which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision' Date J

1. BTP-AMP-B2.1.30 South Texas Project (STP) Program Evaluation Report Revision 2.

I NUREG 1801 Program XI.S4 08/10/2010 2.0PSP11-ZA-0005 Local Leakage Rate Test Cales, Guidelines. and Program

.Revision 19, i

07/28/2010

. 3. OPSP11-IL-0009 Reactor Containment Visual Inspection 03/31/09

• 4. OPSP11-IL-0007 Reactor Containment Building Integrated Leakage Rate Revision 6, I

Test 03/12/2007 5.0PSP11-IL-0007 Reactor Containment Building Integrated Leakage Rate Revision 7, Test 08/06/2009 J

6. TR-9ST Plant Systems and Aging Management Programs Position Revision 1, Paper 08/16/2010 J

7. OPGP03-ZX-0002 Condition Reporting Process Revision 40, 06/06/2011

8. OPGP03-Z0-EC01 Equipment Clearance Order Form Revision 19, I

12/20/2010 9.0POP01-ZA-0001 Plant Operations Dept. Administrative Guidelines Revision 34, 10/21/2010 I

I

- 76 Document Title Revision f Date

10. CR 05-3718-1thru LLRT Testing Exemption (Appendix J, Option B, Section 03/16/2005 6

III.B to 10 CFR Part 50) with attachments (includes

• 09/25/200811

. OPGP04-ZA-0002 CR Engineering Eva!)

I

11. CR 02-1485-1thru Quality Assurance Risk Ranking - Check Valve Appendix J 01/28/2002 14 Potential Exemption Evaluation - Action Differed 10105/2008

12. CR 01-13456 1 Validity of ANSIIANS 56.8 1994 LLRT Test Methodology 08/21/2001 Inside Containment Isolation Valve Operability (includes 08/23/2001 OPGP04-ZA-0002 CR EnQineering Evan

13. CR 05-5277-1thru

• Valve Rework to Correct Leakage Found During LLRT Test 04/08/2005, 2

M-42 (includes PMWO WAN 295999 and 296000) 04/08/2005 I 14. CR 00-6787-1 Unit 2 - Minor Surface Corrosion Reactor Containment 04/13/2000 Liner Plate 06/20/2000

15. CR 03-11820-1 Unit 1 - Equipment Hatch Pitting Corrosion 07/31/2003 08/01/2003

! 16. OPSP11-XC-001 Local Leakage Penetration: M-92 Equipment Hatch Revision 6, wlAddendum 04/17/2003

~

17.0PSP11-XC-001 Local Leakage Penetration: M-92 Equipment Hatch Revision 7, wlAddendum 07/31/2003

18. CR01-11302-thru-NRC Relief-Pressure Test Differed. Repairl Replace 07111/2001 3

Containment Pressure Boundary. VT-1 to be used 11112/2001

19. CR 07-3377-1 UFSAR Section 6.2.4 Revision to Meet As-Built Config, 03/05/2007 GDC 56, and Appendix J Leakage ReQuirements 11/15/2007

20. DWG 2C26-9-S-Unit 1 and 2 - Steel Reactor Containment Building. Liner Revision 3 1007 Plate Developed Elevation

21. DWG 2C26-9-S-Unit 1 and 2 - Steel Reactor Containment Building.

Revision 2 1008

22. DWG 2C26-9-S-Unit 1 and 2 - Steel Reactor Containment Building. Liner Revision 10 1010 Penetration Details

23. DWG 2C22-9-S-Unit 1 and 2 - Steel Reactor Containment Building. Dome Revision 2 1012 Liner. Plans, Sections, and Details

24. DWG 2C22-9-S-Unit 1 and 2 - Steel Reactor Containment Building. Dome Revision 0 1013 Liner Details The staff conducted its audit of LRA AMP program elements one through six based on the contents of the existing program as modified by the proposed enhancement.

During the audit, the staff found that program elements "scope of program," "preventive actions,"

"parameters monitored or inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" of the LRA AMP are consistent with the corresponding element(s) of the GALL Report AMP.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation. In order to obtain the information necessary to verify whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAls for the subject{s) discussed below.

- 77 The potential RAls are related to licensing and may be issued if there is no continuance of:

1. An exemption to 10 CFR Parts 21,50, and 100 (ML011990368);

2. An IWE inspection relief (ML011800402 and ML011280241).

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that LRA program elements "scope of program," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" are consistent with the corresponding program element in the GALL Report AMP.

Based on this audit, the staff also identified that additional information regarding operating experience is required before a determination can be made regarding the sufficiency of the LRA AMP, as implemented by the applicant, to detect and manage aging. Two condition records, CR 05-3718 and CR 01-11302011 may yield potential RAls. CR 05-3718 deals with the exemption to 10 CFR Parts 21,50, and 100 while CR 01-11302011 deals with the IWE inspection relief. In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

Existing Program Consistent with the GALL Report, LRA AMP 82.1.31, "Masonry Wall Program" Summary of Information in the Application: The LRA states that AMP B2.1.31, "Masonry Wall Program," is an existing program that is consistent with the program elements in GALL AMP XI.S5, "Masonry Wall Program." The LRA also states that the Masonry Wall Program is integrated and administered as part of the "Structures Monitoring Program," B2.1.32, that implements structures monitoring requirements as specified by 10 CFR 50.65 (Maintenance Rule). To verify the claim of consistency, the staff audited the LRA AMP and the relevant parts of the "Structures Monitoring Program," B2.1.32. Issues identified but not resolved in this report are addressed in the SER.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of in-scope masonry walls in the turbine building. The staff also conducted an independent database search of the applicant's operating experience database using the the following search terms: "spalling," "masonry," and "cracking."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

I

- 78 Relevant Documents Reviewed Revision I Date Title Document Revision 2, Evaluation Report "Masonry Wall Program - B2.1.31" South Texas Project Aging Management Program

1. STP-AMP-B2.1.31 9/14/2010 Revision 2 Checklist Structures Monitoring - Form 4: Masonry Wall Inspection

2. OPEP04-ZE-0001 12/17/2003 Revision 4, Maintenance Rule Program 3.0PGP04-ZE-0313 811512002 3/25/2007 Condition Record: "Fire Wall for U1 29' TGB Room 103 has

4. CR 07-4452 a Crack... "

The staff conducted its audit of LRA AMP program elements one through six based on the contents of the existing program, augmented by the relevant parts of the applicant's "Structures Monitoring Program" in LRA Section B2.1.32.

During the audit of program elements one through six, the staff found that program elements "scope of program," "preventive actions," "parameters monitored or inspected," "monitoring and trending," and "acceptance criteria" of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For the program element "detection of aging effects,"

sufficient information was not available to determine whether it was consistent with the corresponding element of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding element of the GALL Report AMP, the staff will consider issuing an RAI for the subject discussed below.

The "detection of aging effects" program element of the LRA AMP basis document states that a total inspection of an equivalent unit is performed at a frequency of no more than five years.

The GALL Report AMP recommends masonry walls be inspected every five years, with provisions for more frequent inspections in areas where significant loss of material or cracking is observed. It is not clear to the staff that these statements are consistent because the applicant is inspecting an 'equivalent unit' every five years, as opposed to all masonry walls within the scope of license renewal, as recommended in the GALL Report.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (I.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that LRA program elements "scope of program," "preventive actions," "parameters monitored or inspected," "monitoring and trending,"

and "acceptance criteria" are consistent with the corresponding program elements in the GALL

- 79 Report AMP. The staff also determined that certain aspects of LRA AMP program element "detection of aging effects" will require additional information or additional evaluation before consistency can be determined.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.

In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

Existing Program Consistent with the GALL Report with Enhancement(s), LRA AMP B2.1.32, "Structures Monitoring Program" Summary of Information in the Application: The LRA states that AMP B2.1.32, "Structures Monitoring Program," is an existing program with enhancements that is consistent with the program elements in GALL AMP XI.S6, "Structures Monitoring Program." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER.

The first enhancement affects the LRA AMP "parameters monitored or inspected" program element. The LRA states that the Structures Monitoring Program procedures will be enhanced to specify inspections of seismic gaps, caulking and sealants, duct banks and manholes, valve pits and access vaults, doors, electrical conduits, raceways, cable trays, electrical cabinets/enclosures, and associated anchorage.

The second enhancement affects the LRA AMP "parameters monitored or inspected" program element. The LRA states that plant procedures will be enhanced to monitor at least two groundwater samples every 5 years for pH, sulfates, and chloride concentrations.

The third enhancement affects the LRA AMP "detection of aging effects" program element. The LRA states that the Structures Monitoring Program procedure will be enhanced to specify inspection intervals so that all accessible areas of both units are inspected every ten years.

The fourth enhancement affects the LRA AMP "detection of aging effects" program element.

The LRA states that the Structures Monitoring Program procedure will be enhanced to specify inspector qualifications in accordance with ACI 349.3R-96.

In Appendix A of the LRA, the applicant committed (Commitment No. 25) to implement these enhancements prior to the period of extended operation.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of Unit 2 Emergency Cooling Water Structure, Mechanical Auxiliary Building, Fuel Handling Building, Reactor Containment Building Tendon Gallery, and outside containment structure. The staff also conducted an independent search of the applicant's operating experience database using the following search terms: "bolt," "concrete," "corrosion or corrosive," "degradation," and "spalling."

- 80 The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date I

1. B2.1.32 South Texas Project Aging Management Program

. Revision 1, I

Evaluation Report - Structures Monitoring Program 7/14/2010 B2.1.32 J

2. OPEP04-ZE-0001 Structures Monitoring Procedure Revision 2, I

10/17/2003 3.0PGP04-ZE-0313 Maintenance Rule Procedure Revision 4, I

8115/2002

4. 7Y310YS1000 Specs for Geotechnical Monitoring Revision 9, I

9/05/2001

5. OPGP05-ZA-0002 Condition Record Engineering Evaluation Form, CR 95 i 04/03/1997 I

13422, Action 95-13422-1, Groundwater Inleakage into the Unit 1 FHB and the Unit 1 ReB Tendon Gallery and Unit 2 I

I FHB i

The staff conducted its audit of LRA AMP program elements one through six based on the contents of the existing program as modified by the proposed enhancements.

During the audit, the staff found that program elements "scope of program" and "monitoring and trending" of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for program elements "preventive actions," "parameters monitored or inspected," "detection of aging effects," and "acceptance criteria," insufficient information was available to determine whether they were consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAls for the subjects discussed below.

The "preventive actions" program element of the LRA AMP states that inspection attributes of concrete elements, structural steel, masonry walls, roofing, and siding components are monitored by the Structures Monitoring Program. The GALL Report AMP recommends that if ASTM A325, ASTM F1852, and/or ASTM A490 bolts are used, the preventive actions in Section 2 of "Specification for Structural Joints Using ASTM A325 or A490 Bolts" should be addressed. It is not clear to the staff that the applicant's statements are consistent with the GALL Report, because the LRA does not discuss the use of ASTM A325, ASTM F1852, and/or ASTM A490 bolts and the preventive actions in Section 2 of the "Specification for Structural Joints Using ASTM A325 or A490 Bolts" when these bolts are present.

The "parameters monitored or inspected" program element of the LRA AMP states that the plant procedures will be enhanced to monitor at least two groundwater samples every 5 years for pH, sulfates, and chloride concentrations. The GALL Report AMP recommends for detection of aging effects in inaccessible, below-grade concrete structural elements for plants with non-aggressive groundwater that: (1) the acceptability of inaccessible areas be evaluated when conditions exist in accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas; and (2) examining representative samples of exposed portions of below-grade concrete when excavated for any reason. The GALL Report also notes for plants

- 81 with aggressive groundwater or where concrete elements have experienced degradation, a plant-specific AMP that accounts for the extent of degradation experienced should be implemented to manage concrete aging during the period of extended operation. It is not clear to the staff that these statements are consistent because the LRA does not provide historical results (including seasonal variations) to demonstrate that the ground water is either aggressive or non-aggressive, or that when below-grade concrete is excavated for any reason, opportunistic inspections of the exposed portions of the below-grade concrete will be performed.

The "detection of aging effects" program element of the LRA AMP states that inspection intervals are selected to ensure that aging degradation will be detected and quantified before there is a loss of intended functions and that the inspections are scheduled so that all accessible areas of both units are inspected every ten years. The GALL Report, Revision 2, recommends that all structures within the scope of license renewal should be monitored on a frequency not to exceed five years. It is not clear to the staff that these LRA statements are consistent with the GALL Report, because it is not certain that the applicant's inspection interval meets the five-year inspection interval recommendations, or that a technical justification exists for a longer inspection interval.

The "acceptance criteria" program element of the LRA AMP states that if inspections identify any areas having significant aging effects, notifications are made to determine the appropriate corrective action using categories of "acceptable," "acceptable with degraded condition," and "unacceptable." The GALL Report AMP recommends that ACI 349.3R-96 provides an acceptable basis for developing acceptance criteria for concrete structures, and that applicants who are not committed to ACI 349.3R-96 and elect to use plant-specific criteria for concrete structures should describe the criteria and provide a technical basis for deviations from those listed in ACI 349.3R-96. It is not clear to the staff how the applicant's quantitative acceptance criteria are consistent with those recommended in the GALL Report.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is not bounded by industry operating experience (I.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation. In order to obtain the information necessary to verify whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAls for the subjects discussed below.

During the field walk-down, the staff noted that there was essentially no leakage from the spent fuel pool leak chase channels and visual examinations of the exterior wall of the spent fuel pool as well as the underside of the spent fuel pool indicated no signs of leakage from the spent fuel pool. It is unclear to the staff whether the absence of leakage from the leak chase channels is representative of no leakage occurring, or if the leak chase channels are clogged.

During the field walk-down, the staff noted and requested background information on the groundwater that had accumulated to a depth of a few feet in Room 011 between the Unit 2

- 82 Fuel Handling Building and the Unit 2 Reactor Containment Building. The applicant stated that no criteria exist as to when the water was/is removed and that the visible concrete surfaces in this area are not routinely inspected. Since it was noted in the lRA that the aggregate materials are potentially reactive, it is unclear to the staff that the standing water has not resulted in concrete degradation or would not lead to degradation during the period of extended operation.

The staff also audited the description of the lRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-lR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that lRA program elements "scope of program" and "monitoring and trending" of the lRA AMP are consistent with the corresponding program elements in the GAll Report AMP. The staff also determined that certain aspects of LRA AMP program elements "preventive actions," "parameters monitored or inspected,"

"detection of aging effects," and "acceptance criteria" will require additional information or additional evaluation before consistency can be determined.

Based on this audit, the staff also identified that additional information on operating experience is required before a determination can be made regarding the sufficiency of the lRA AMP, as implemented by the applicant, to detect and manage aging. In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

Existing Program Consistent with the GALL Report with Enhancement{s), LRA AMP 82.1.33, "RG 1.127 Inspection of Water Control Structures Associated with Nuclear Power Plants" Summary of Information in the Application: The lRA states that AMP B2.1.33, "RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants," is an existing program with an enhancement that is consistent with the program elements in GAll AMP XI.S7, "RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants." The lRA further states that this program is implemented as part of the applicant's "Structures Monitoring Program," B2.1.32, which also manages cracking, loss of bond, loss of material (spalling, scaling), cracking due to expansion, increase in porosity and permeability, loss of strength by performing inspection and surveillance activities for water control structures.

To verify the claim of consistency, the staff audited the lRA AMP and the relevant parts of the applicant's "Structures Monitoring Program," B2.1.32. Issues identified but not resolved in this report will be addressed in the SER.

The enhancement affects the lRA AMP "detection of aging effects" program element. The lRA states that procedures will be enhanced to specify inspection intervals not to exceed 5 years or immediately following significant natural phenomena.

In Appendix A of the lRA, the applicant committed (Commitment No. 26) to implement this enhancement prior to the period of extended operation.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the Unit 2 Emergency Cooling Water Structure. The staff also conducted an independent search of

- 83 the applicant's operating experience database using the following search terms: "bolt,"

"concrete," "corrosion or corrosive," "degradation," and "spalling."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date 1.82.1.33 i South Texas Project Aging Management Program Revision 2, Evaluation Report Regulatory Guide 1.127, Inspection of 8/10/2010 Water-Control Stuctures Associated with Nuclear Power Plants

2. OPEP04-ZE-0001 Structures Monitoring Procedure Revision 2, 12/17/2003 3.7Y310YS1000

. Specs for Geotechnical Monitoring Revision 9, 9/5/2001 The staff conducted its audit of LRA AMP program elements one through six based on the contents of the existing program, augmented by the relevant parts of the applicant's "Structures Monitoring Program," 82.1.32, and as modified by the proposed enhancement.

During the audit, the staff found that program elements "scope of program," "detection of aging effects," and "monitoring and trending," of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for program elements "preventive actions," "parameters monitored or inspected," and "acceptance criteria" sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAls for the subjects discussed below.

The "preventive actions" program element of the LRA AMP (see also "Structures Monitoring Program," 82.1.32) states that inspection attributes of concrete elements, structural steel, masonry walls, roofing, and siding components are monitored by the Structures Monitoring Program. The GALL Report AMP recommends that if ASTM A325, ASTM F1852, and/or ASTM A490 bolts are used, the preventive actions in Section 2 of "Specification for Structural Joints Using ASTM A325 or A490 801ts" should be addressed. It is not clear to the staff that the applicant's statements are consistent with the GALL Report, because the LRA does not discuss the use of ASTM A325, ASTM F1852, and/or ASTM A490 bolts and the preventive actions in Section 2 of the "Specification for Structural Joints Using ASTM A325 or A490 801ts" when these bolts are present.

The "parameters monitored or inspected" program element of the LRA AMP (see also "Structures Monitoring Program," 82.1.32) states that the plant procedures will be enhanced to monitor at least two groundwater samples every 5 years for pH, sulfates, and chloride concentrations. The GALL Report AMP recommends for detection of aging effects in inaccessible, below-grade concrete structural elements for plants with non-aggressive groundwater that: (1) the acceptability of inaccessible areas be evaluated when conditions exist

- 84 in accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas; and (2) examining representative samples of exposed portions of below-grade concrete when excavated for any reason. The GALL Report also notes for plants with aggressive groundwater or where concrete elements have experienced degradation, a plant-specific AMP that accounts for the extent of degradation experienced should be implemented to manage concrete aging during the period of extended operation. It is not clear to the staff that these statements are consistent because the LRA does not provide historical results (including seasonal variations) to demonstrate that the ground water is either aggressive or non-aggressive, or that when below-grade concrete is excavated for any reason, opportunistic inspections of the exposed portions of the below-grade concrete will be performed.

The "acceptance criteria" program element of the LRA AMP (see also "Structures Monitoring Program," B2.1.32) states that if inspections identify any areas having significant aging effects, notifications are made to determine the appropriate corrective action using categories of "acceptable," "acceptable with degraded condition," and "unacceptable." The GALL Report AMP recommends that ACt 349.3R-96 provides an acceptable basis for developing acceptance criteria for concrete structures and that applicants who are not committed to ACI 349.3R-96 and elect to use plant-specific criteria for concrete structures should describe the criteria and provide a technical basis for deviations from those listed in ACt 349.3R-96. It is not clear to the staff that these statements are consistent because it is uncertain how the quantitative acceptance criteria used by the applicant correspond to those recommended in the GALL Report.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is not bounded by industry operating experience (I.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation. In order to obtain the information necessary to verify whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAls for the subjects discussed below.

The "operating experience" program element of the LRA states that the ECW intake and discharge structures have been subjected to relatively few aging effects and inspections of these structures are conducted under the Structures Monitoring Program. It is unclear to the staff what procedures are used to conduct the visual inspections of accessible intake and discharge structures, and at what frequency these inspections are performed.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that LRA program elements "scope of program," "detection of aging effects," and "monitoring and trending" are consistent with the corresponding program elements in the GALL Report AMP. The staff also determined that certain aspects of LRA AMP program elements, augmented by the relevant parts of the

- 85 applicant's "Structures Monitoring Program," 82.1.32, "preventive actions," "parameters monitored or inspected," and "acceptance criteria" will require additional information or additional evaluation before consistency can be determined.

Based on this audit, the staff identified that additional information regarding operating experience is required before a determination can be made regarding the sufficiency of the LRA AMP, as implemented by the applicant, to detect and manage aging. In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

New Program Consistent with the GALL Report, LRA AMP 82.1.36, "Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements" Summary of Information in the Application: The LRA states that AMP B2.1.36, "Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements," is a new program that is consistent with the program elements in License Renewal Interim Staff Guidance LR-ISG-2007-02 and GALL AMP XI.E6, "Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER.

In Appendix A, Table A4-1, of the LRA, the applicant committed (Commitment No. 28) to implement this program prior to the period of extended operation.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicant's operating experience database using the the following search terms:

"cable connections," "loosening," and "corrosion."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. STP-AMP-B2.1.36 Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Revision 2

2. TR-11ST Electrical Component Aging Evaluation License Renewal Topical Report Revision 1

3. OPMP02-ZG-004 Bolted Joint Procedure

• 3/26/2005 During the audit of program elements one through six, the staff found that program elements "scope of program," "preventive actions," "detection of aging effects," "monitoring and trending,"

and "acceptance criteria" of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For program element "parameters monitored or inspected," sufficient information was not available to determine whether it was consistent with the corresponding

- 86 program element of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAls for the subjects discussed below.

In the basis document STP-AMP-B2.1.36-Revision 2, the applicant states that program elements "scope of program," "parameters monitored or inspected," "detection of aging effects,"

and "monitoring and trending" are consistent with those in the GALL Report, Revision 1. The staff reviewed these program elements and found that they are not consistent with those in the GALL Report, Revision 1. However, while these program elements are not consistent with those in the GALL Report, Revision 1, they are consistent with approved LR-ISG-2007 -02 which was incorporated in the GALL Report, Revision 2.

In the program basis document STP-AMP-B2.1.36-Revision 2, under the "parameters monitored or inspected" program element, the applicant states that the infrared thermography testing is being performed to identify loosening of bolted connections due to thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation. The connections associated with cables within the scope of license renewal are splices (butt or bolted), crimp-type ring lugs, connectors, and terminal blocks as described in the program description in GALL AMP XI.E6, Revision 2. The NRC staff believes that loosening of cable connections may also occur in different types of connections and may not only be limited to bolted connections.

The "parameters monitored or inspected" program element of basis document STP-AMP-B2.1.36, Revision 2, states that the technical basis for selected samples will be documented. GALL AMP XI.E6, Revision 2, recommends that 20 percent of the population, with a maximum sample of 25, constitutes a representative sample. Otherwise, a technical justification of the methodology and sample size used for selecting components for one-time testing should be included as part of the AMP's site documentation. It is not clear to the staff that the "parameters monitored or inspected" program element is consistent with those in the GALL Report because the applicant has not developed the technical basis or criteria for sample selection technique.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that the "scope of program," "preventive actions," "detection of aging effects," "monitoring and trending," "acceptance criteria" and

- 87 "operating experience" LRA program elements are consistent with the corresponding program elements in the GALL Report AMP. The staff also determined that certain aspects of the "parameters monitored or inspected" program element, will require additional information or additional evaluation before consistency can be determined.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.

In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

Existing Program Consistent with the GALL Report with Enhancement(s). LRA AMP B3.1, "Metal Fatigue of Reactor Coolant Pressure Boundary" Summary of Information in the Application: The LRA states that AMP B3.1, "Metal Fatigue of Reactor Coolant Pressure Boundary," is an existing program with enhancements that is consistent with the program elements in GALL AMP X.M1, "Fatigue Monitoring." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER.

The first enhancement affects the LRA AMP "scope of program" program element. The LRA states that procedures will be enhanced to include locations identified by the evaluation of ASME Code,Section I" fatigue analyses, locations necessary to ensure accurate calculations of fatigue, and the NUREG/CR-6260 locations for a newer-vintage Westinghouse Plant.

The second enhancement affects the LRA AMP "scope of program" program element. The LRA states that procedures will be enhanced to include additional transients that contribute significantly to fatigue usage identified by the evaluation of ASME Code,Section III fatigue analyses.

The third enhancement affects the LRA AMP "detection of aging effects" program element. The LRA states that procedures will be enhanced to (1) include additional transients necessary to ensure accurate calculations of fatigue; (2) monitor fatigue usage at specified locations; and (3) specify the frequency and process of periodic reviews of the results of the monitored cycle count and CUF data at least once per fuel cycle.

The fourth enhancement affects the LRA AMP "preventive actions" and "acceptance criteria" program elements. The LRA states that procedures will be enhanced to include additional cycle count and fatigue usage action limits, which will invoke appropriate corrective actions if a component approaches a cycle count action limit or a fatigue usage action limit.

The fifth enhancement affects the LRA AMP "corrective actions" program element. The LRA states that procedures will be enhanced to include appropriate corrective actions to be invoked if a component approaches a cycle count or CUF action limit.

In LRA Table A4-1, the applicant committed (Commitment No. 30) to implement these enhancements prior to the period of extended operation.

- 88 Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the following search terms: "fatigue," "leak,"

"CUF," "EAF," "transients" and "crack."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Revision I Date Title Document Revision 2,

1. STP-AMP-B3.1 I Metal Fatigue of Reactor Coolant Pressure Boundary 10/2010 Revision 6, Transient Cycle Counting Limits

2. OPEP02-ZE-0001 02/2003 Revision 8, 3.0PGP03-ZX-0013 Industry Events Analysis 08/2009 i

4. STP CR 05-5586 Transient Cycle Counting Limits for Loss of Charging 04/12/2005

5. STP CR 07-7042 Temperature differential between the pressurizer liquid 04/25/2007 and the reactor coolant

6. STP CR 03-4718 Transient Cycle Counting Limits for COMS Actuation 03/26/2003

7. SIR-08-073 System Review and Recommendations for a Transient 04/2008 I

and Fatigue Monitoring System at the South Texas Project Units 1 and 2 i

8. ST-WN-HS-0961 Cycle Counting Procedure Exemptions 06/27/1989

9. WCAP-12276 Houston Light and Power Company South Texas Project 0511989 Units 1 and 2 Electric Generating Stations Transient Cycle Counting Technical Basis

! 10. WCAP-10865(P)

South Texas Plant (TGX) Reactor Internals Flow-Induced 06/1985 Vibration Assessment

11. DCP 07-5020-13 Disposition to Denting of Stud (ROTO-LOK) #30 and 04/09/2007 Corresponding Insert

12. WCAP-15385 Addendum to Analytical Report for the South Texas 02/2000 Project Unit No.2 Reactor Vessel (Replacement Steam Generator Evaluation)

I

13. FP-STP-305.

Cycle and Fatigue Basline, Startup Through YE 2008 07/29/2009 The staff conducted its audit of LRA AMP program elements one through six based on the contents of the existing program as modified by the proposed enhancements. The staff also conducted a limited audit of the plant-specific time-limited aging analyses (TLAAs) in the LRA that credit the Fatigue Monitoring Program. Observations from this TLAA portion of the audit supplement the staff's review of the TLAA As part of the audit, the staff discussed the applicant's use of LRA AMP B3.1 to manage crack growth for the following TLAA: LRA Section 4.3.2.11 "Fatigue Crack Growth Assessments and Fracture Mechanics Stability Analyses for Leak-Before-Break (LBB) Elimination of Dynamic Effects of Primary Loop Piping Failures." The staff noted that the applicant's program is applicable to CUF calculations/analyses whereas this TLAA is a non-CUF type analysis. The applicant's current licenSing basis may need to be updated and the applicant's program may need additional enhancements justifying its use for non-CUF type analyses.

- 89 During the audit, the staff found that LRA AMP program elements "preventive actions,"

"parameters monitored or inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" are consistent with the corresponding elements of the GALL Report AMP.

In addition, the staff found that for program elements "scope of program" and "corrective actions," insufficient information was available for the staff to determine whether each element was consistent with the corresponding program element of the GALL Report AMP. In order to obtain the necessary information, the staff will consider issuing RAls for the subject discussed below.

For the "scope of program" program element, the LRA AMP states the program will be enhanced to include additional transients and locations identified by the evaluation of ASME Code,Section III fatigue analysis locations necessary to ensure accurate calculations of fatigue, and the NUREG/CR-6260 locations for a newer-vintage Westinghouse Plant. GALL AMP X.M1 recommends that additional plant-specific component locations in the reactor coolant pressure boundary, other than those considered in NUREG/CR-6260, should also be evaluated if they could be more limiting. It is not clear to the staff whether the applicant's plant-specific configuration contains locations that should be analyzed for the effects of the reactor coolant environment beyond those identified in NUREG/CR-6260.

For the "corrective actions" program element, the LRA AMP states the program will be enhanced to include seven options as acceptable corrective actions when a CUF action limit is reached or has approached 1.0. The GALL Report AMP recommends three acceptable corrective actions: repair of the component, replacement of the component, or a more rigorous analysis of the component. It is not clear to the staff how and when the four proposed additional options for corrective action options to prevent the usage factor from exceeding the design code limit will be implemented by the applicant's program.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that LRA program elements "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," "acceptance criteria," and "operating experience" are consistent with the corresponding program elements in the GALL Report AMP. The staff also determined that certain aspects of LRA AMP program elements "scope of program" and "corrective actions" will require additional information or additional evaluation before conSistency can be determined.

- 90 8ased on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.

In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

Existing Program Consistent with the GALL Report, LRA AMP 83.2, "Environmental Qualification (EQ) of Electric Components" Summary of Information in Application: The LRA states that AMP 83.2, "Environmental Qualification (EQ) of Electrical Components," is an existing program that is consistent with the program elements in GALL AMPX. E 1, "Environmental Qualification (EQ) of Electrical Components." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER.

Audit Activities: During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the switchyard, manholes, transformers, and metal enclosed buses. The staff also conducted an independent database search of the applicant's operating experience database using the the following search terms: "bus," "cable," "cracking," "stress," "thermal," and "underground."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed I

Document Title Revision I Date

1. STP-AMP-B3.2-Rev 2

Environmental Qualification (EQ) of Electrical Components Revision 2, 10/4/2010

2. OPDP01-ZE-0002 Environmental Equipment Qualification Program Revision 4, 9/3/2009

3.

EQ Health Report 1211712008

4.

EQ Health Report I

7130/2009

. 5.

EQ Health Report 12/30/2009

6.

EQ Health Report 712612010

7.

EQ Health Report 4/28/2011

8. OPGP04-ZE-0309 Design Change Package Revision 25

9. OPGP04-ZA-0307 Preparation of Calculations Revision 4

10. DCP #06-12245-9 Design Change Package (DCP) 9/15/2009

11. CR 00-25 Perimeter Intrusion Detection Zone Exceeded F AR/NAR Criteria 1119/2000

- 91 Document Title Revision I Date..

• 12. CR 90-12 Steam Generator 1A Feed-Water Flow Transmitter Was Found Out-Of-Tolerance 5/18/1990 13, CR 93-33 Release Of Patients Treated With Temporary Implants 5/6/1993 14,OPG03-ZX-0013 Operating Experience Program Revision 9, 2/1/2011 During the audit of program elements one through six, the staff found that program elements "preventive actions," "parameters monitored or inspected," "detection of aging effects,"

"monitoring and trending," and "acceptance criteria" of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP, For program element "scope of program" sufficient information was not available to determine whether it was consistent with the corresponding program elements of the GALL Report AMP, In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAls for the subjects discussed below.

GALL AMP XI.E2 applies to electrical cables and connections (cable system) used in circuits with sensitive, high voltage, lOW-level current signals (such as radiation monitoring and nuclear instrumentation) that are subject to aging management review and installed in adverse localized environments caused by temperature, radiation, or moisture. The applicant stated that electrical cables and connections which would normally be included in GALL AMP XI.E2 are in scope of LRA AMP B3.2, which the applicant claims is consistent with GALL AMP X,E1, The staff requested the applicant to submit a list of the cables and connections used in circuits with sensitive, high voltage, low-level current signals that are in scope of LRA AMP B3.2, along with any additional justification.

During the audit of the "operating experience" program element, the staff found that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also found that the operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Audit Results: Based on this audit, the staff verified that LRA program elements "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," "acceptance criteria," and "operating experience" are consistent with the corresponding program elements in the GALL Report AMP, The staff also determined that certain aspects of LRA AMP program element "scope of program" will require additional information or additional evaluation before consistency can be determined.

- 92 Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.

In addition, the staff verified that the description provided in the UFSAR Supplement is an adequate description of the program.

September 22, 2011 Mr. G. T. Powell, Vice President Technical Support and Oversight STP Nuclear Operating Company P.O. Box 289 Wadsworth, TX 77483

SUBJECT:

AGING MANAGEMENT PROGRAMS AUDIT REPORT REGARDING THE SOUTH TEXAS PROJECT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. ME4936 AND ME4937)

Dear Mr. Powell:

By letter dated October 25, 2010, STP Nuclear Operating Company (STPNOC or the Applicant) submitted an application for renewal of operating licenses NPF-76 and NPF-80 for South Texas Project (STP), Units 1 and 2. The staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing this application in accordance with the guidance in NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants." On June 24, 2011, the staff of the staff completed the onsite audit of aging management programs.

The audit report is enclosed.

If you have any questions, please contact me by telephone at 301-415-3873 or bye-mail at John. Daily@nrc.gov.

Sincerely, IRA!

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

Enclosure:

As stated cc w/encl: Listserv DISTRIBUTION:

See next page ADAMS Accession No.: ML11224A265

• concurrence via email OFFICE I LADLR*

I PM:RPB1:DLR BC:RPB1:DLR LADLR*

PM:RPB1 :DLR NAME

• SFigueroa

• JDaily JDaily DMorel'

_ SFigueroa 09/21/2011 r09/15/20 11 DATE I 09/15/2011 I 09/15/2011 0912212011 OFFICIAL RECORD COpy I

Letter to G.T. Powell from John W. Daily dated September 22,2011

SUBJECT:

AGING MANAGEMENT PROGRAMS AUDIT REPORT REGARDING THE SOUTH TEXAS PROJECT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. ME4936 AND ME4937)

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