NOC-AE-11002730, Response to Request for Additional Information for License Renewal Application (TAC Nos. ME4936 and ME4937)

Response to Request for Additional Information for License Renewal Application (TAC Nos. ME4936 and ME4937)

ML11266A019
Person / Time
Site:	South Texas
Issue date:	09/15/2011
From:	Gerry Powell South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-11002730, STI: 32913936, TAC ME4936, TAC ME4937
Download: ML11266A019 (25)

Text

Nuclear Operating Company South Texas ProjectElectric GeneratinS Station Po.Bao 289 Wadsworth. Texas 77483 AA --

September 15, 2011 NOC-AE-1 1002730 10CFR54 STI: 32913936 File: G25 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2746 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Response to Request for Additional Information for the South Texas Proiect License Renewal Application (TAC Nos. ME4936 and ME4937)

References:

1. STPNOC Letter dated October 25, 2010, from G. T. Powell to NRC Document Control Desk, "License Renewal Application," (NOC-AE-10002607) (ML103010257)

2. NRC letter dated August 15, 2011, "Requests for Additional Information for the Review of the South Texas Project, Units 1 and 2 License Renewal Application -

Aging Management Programs Audit, Plant Systems" (ML11214A008)

3. Electronic Mail dated August 18, 2011, from John Daily, NRC, to Arden Aldridge, STPNOC, "Errata in AMP RAI Package - ML11214A008" (ML112300016)

By Reference 1, STP Nuclear Operating Company (STPNOC) submitted a License Renewal Application (LRA) for South Texas Project (STP) Units 1 and 2. By Reference 2 as modified by Reference 3, the NRC staff requests additional information for review of the STP LRA. STPNOC's response to the request for additional information is provided in the Enclosure to this letter.

There are no regulatory commitments in this letter.

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

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

Executed on f-15-_4011 Date G. T. Powell Vice President, Technical Support & Oversight KJT

Enclosure:

STPNOC Response to Requests for Additional Information

NOC-AE-1 1002730 Page 2 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission Kathryn M. Sutton, Esquire 612 East Lamar Blvd, Suite 400 Morgan, Lewis & Bockius, LLP Arlington, Texas 76011-4125 Balwant K. Singal John Ragan Senior Project Manager Catherine Callaway U.S. Nuclear Regulatory Commission Jim von Suskil One White Flint North (MS 8B1) NRG South Texas LP 11555 Rockville Pike Rockville, MD 20852 Ed Alarcon Senior Resident Inspector Kevin Polio U. S. Nuclear Regulatory Commission Richard Pena P. 0. Box 289, Mail Code: MNl 16 City Public Service Wadsworth, TX 77483 C. M. Canady Peter Nemeth City of Austin Crain Caton & James, P.C.

Electric Utility Department 721 Barton Springs Road C. Mele Austin, TX 78704 City of Austin John W. Daily Richard A. Ratliff License Renewal Project Manager (Safety) Alice Rogers U.S. Nuclear Regulatory Commission Texas Department of State Health Services One White Flint North (MS 011-Fl)

Washington, DC 20555-0001 Balwant K. Singal Tam Tran John W. Daily License Renewal Project Manager Tam Tran (Environmental) U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission One White Flint North (MS O11F01)

Washington, DC 20555-0001

Enclosure NOC-AE-1 1002730 Page 1 of 23 STPNOC Response to Requests for Additional Information SOUTH TEXAS PROJECT LICENSE RENEWAL APPLICATION REQUESTS FOR ADDITIONAL INFORMATION - AGING MANAGEMENT PROGRAMS AUDIT, PLANT SYSTEMS Note: In all cases unless otherwise noted, references to the generic aging lessons learned (GALL) Report, a GALL aging management program (AMP), or the SRP-LR refer to the current approved revision, Revision 2.

RAI B2.11.7-1 Back-ground:

GALL AMP XI.M18, "Bolting Integrity," "scope of program" program element states that the program relies on recommendations for a comprehensive bolting integrity program as delineated in electric power and research institute (EPRI) TR-1 04213, EPRI NP-5769 and NUREG-1339.

License renewal application (LRA), Section B2.1.7, "Bolting Integrity," "scope of program" program element states an exception to GALL AMP XI.M18 where the applicant does not explicitly address the guidelines outlined in EPRI TR-104213. Instead, the applicant's Bolting Integrity Program relies on the recommendations contained in EPRI NP-5067, EPRI NP-5769 and NUREG-1339.

Issue:

The use of EPRI NP-5067 as guidance in place of the GALL Report recommended guidance delineated in EPRI TR-1 04213 requires further clarification to determine how EPRI NP-5067 meets the intent of EPRI TR-104213 as identified in GALL AMP XI.M18, and whether or not its usage will contradict the GALL guidance.

Request:

Provide clarification on the use of EPRI NP-5067 as guidance for this program. Specifically, provide an explanation of any contradictions between EPRI NP-5067 and the GALL recommended guidance delineated in EPRI TR-104213 that it is replacing and its impact on this program.

STPNOC Response:

LRA Appendix B2.1.7 and LRA Basis Document AMP XI.M18 (B2.1.7) will be revised to delete the exception to Scope of Program (Element 1) and state that the Bolting Integrity program conforms to the guidance contained in EPRI TR-104213.

Enclosure NOC-AE-1 1002730 Page 2 of 23 RAI B2.1.7-2 Backgqround:

GALL AMP XI.M18, "Bolting Integrity," "detection of aging effects" program element recommends that for high strength structural bolting (actual measured yield strength greater than or equal to 150 ksi or 1,034 MPa) in sizes greater than 1 inch nominal diameter, volumetric examination comparable to that of American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section Xl, Table IWB-2500-1, Examination Category BG-1 should be performed to detect cracking in addition to the VT-3 examination.

The Bolting Integrity plant basis document states that, "Based on STP operating experience, volumetric examinations of high strength structural bolts greater than 1-inch nominal diameter is not required." Justification is provided in the basis document which states 3 criteria for initiation of SCC: high stress, corrosive environment, and susceptible material. Though STP has high stresses and susceptible material, they state that the corrosive environment has been eliminated by following proper lubrication and sealant guidelines.

Issue:

It is unclear how a non-corrosive environment is achieved, and how that non-corrosive environment can be guaranteed to be continuously maintained throughout the period of extended operation.

Request:

Provide additional information to demonstrate that all high-strength structural bolts have been completely removed from a corrosive environment, and are not at risk of being exposed to a corrosive environment, or update the basis documents to show that volumetric examinations comparable to that of ASME Code, Section Xl, Table IWB-2500-1, Examination Category B-G-1 are being performed on high strength structural bolting in sizes greater than 1 inch nominal diameter.

STPNOC Response:

GALL AMP XI.M18, Bolting Integrity, Detection of Aging Effects program element requires that for high strength structural bolting for nuclear steam supply system (NSSS) component supports in sizes greater than 1 inch nominal diameter, volumetric examination comparable to that of ASME Code Section Xl, Table IWB-2500-1, Examination Category B-G-1, should be performed to detect cracking in addition to the VT-3 examination. GALL allows this requirement to be waived with adequate plant-specific justification.

Stress corrosion cracking occurs through the combination of high stress (both applied and residual tensile stress), a corrosive environment, and a susceptible material. At STP, the high strength structural bolting for NSSS component supports is not exposed to a corrosive environment. The NSSS component supports are located in the reactor containment building.

The atmosphere in containment is plant indoor air that is not a corrosive environment. In addition, lubricants containing molybdenum disulfide are not used in the reactor containment building. Visual inspections of this bolting are performed as required by the ASME Section Xl, Subsection IWF aging management program (B2.1.29), and include an examination for corrosion. Corrosion is indicative of a corrosive environment. If corrosion is detected, then appropriate corrective action is taken under the Corrective Action Program. If an event occurs that exposes the bolting to a corrosive environment (e.g., such as a leak), this condition will be

Enclosure NOC-AE-1 1002730 Page 3 of 23 addressed in the Corrective Action Program. There have been no instances of failed high strength structural bolting in NSSS supports due to stress corrosion cracking at STP.

Therefore, it is justified to waive the requirement for volumetric examination of this bolting.

RAI B2.1.9-1

Background:

LRA Section B2.1.9, "Open-Cycle Cooling Water System Program," states that the program manages the aging effects of cracking, loss of material, and reduction of heat transfer. This is also stated in the Final Safety Analysis Report (FSAR) Supplement, LRA Section A1.9. However, the LRA does not include any AMR Table 2 line items for which the Open-Cycle Cooling Water System Program manages the aging effect of cracking.

GALL AMP XI.M20, "Open-Cycle Cooling Water System," does not include cracking as an aging effect requiring management (AERM) by the Open-Cycle Cooling Water System Program.

Discussions with applicant staff during the AMP Audit indicated that the inclusion of cracking as an aging effect managed by the Open-Cycle Cooling Water System Program was an error.

Issue:

The applicant appears to have included cracking as an aging effect managed by the Open-Cycle Cooling Water System Program in error. Had the applicant chosen to include cracking as an aging effect to be managed by this program, the staff would have considered this to be an exception to GALL AMP XI.M20 and would have expected an appropriate technical justification for the exception to be included in the LRA.

Request:

Revise LRA Sections B.2.1.9, A 1.9, and any other applicable LRA section as appropriate, to accurately reflect the aging effects to be managed by the Open-Cycle Cooling Water System Program.

STPNOC Response:

The Open Cycle Cooling Water program manages loss of material and reduction of heat transfer. Cracking is not managed by this program. LRA Appendices A1.9 and B2.1.9 will be revised to delete cracking as an aging effect in the Open Cycle Cooling Water program. No other sections of the LRA were identified that require revision for this error.

RAI B2.1.10-1 Back-ground:

The "detection of aging effects" program element of GALL AMP XI.M21A, "Closed Treated Water Systems," recommends that inspections be conducted whenever the system boundary is opened (i.e., opportunistically) and a representative sample of piping and components be selected based upon likelihood of corrosion or cracking and inspected at an interval not to exceed once in 10 years.

Enclosure NOC-AE-1 1002730 Page 4 of 23 In the LRA, the Closed-Cycle Cooling Water (CCCW) System Program is used to manage carbon steel, carbon steel (galvanized), cast iron, copper alloy, copper alloy> 15% Zn, titanium, and stainless steel components exposed to closed-cycle cooling water for loss of material, cracking, and reduction of heat transfer. An enhancement to this program states that the interior of piping that is attached to the excess letdown heat exchanger component cooling water (CCW) return check valves will be periodically inspected to detect loss of material and fouling. The staffs review of the program documentation during the AMP audit indicated that this is the only inspection location for this program.

Issue:

1. The CCCW System Program does not include opportunistic inspections when systems are opened during maintenance. It is the staffs position that, because the control of water chemistry may not be fully effective in mitigating aging, such inspections can ensure that material degradation does not result in loss of component intended functions.

2. LRA Section B2.1.10 does not state how often inspections of the piping associated with the CCW return check valve will be conducted. GALL AMP XI.M21A recommends a maximum 10-year inspection interval on a representative sample of components to ensure all material-aging effect combinations are adequately addressed by the opportunistic inspections during system maintenance.

3. It is not clear to the staff whether the proposed inspection location is a representative sample of components most likely to corrode or crack for all the various material-aging effect combinations. For example, the staff noted that cracking was not included in the description of the inspection activities for the piping associated with the CCW check valves, although several LRA items manage cracking of stainless steel components exposed to closed-cycle cooling water with the CCCW System Program.

Request:

1. Include opportunistic inspections in the CCCW System Program or provide technical justification for how the inspections of the piping associated with the CCW return check valve is adequate to ensure material degradation is not occurring in the closed-cycle cooling water systems.

2. State how often a representative sample of components will be inspected during the period of extended operation and, if the inspection interval exceeds 10 years, provide technical justification for why the frequency is adequate to manage aging.

3. Confirm whether the proposed inspection location is representative of the components most likely to corrode or crack for all the material-aging effect combinations managed by the CCCW System Program (e.g., cracking of stainless steel in closed-cycle cooling water> 60 0 C, reduction of heat transfer of copper and stainless steel heat exchanger tubes in closed-cycle cooling water). If the inspection of the piping associated with the CCW check valves is not representative of the components managed by the CCCW System Program, propose an alternative sampling methodology.

STPNOC Response:

LRA Appendix B2.1.10 and LRA Basis Document AMP XI.M21(B2.1.10), Closed-Cycle Cooling Water System program, will be revised to require that representative samples of each

Enclosure NOC-AE-1 1002730 Page 5 of 23 combination of material and water treatment program be visually inspected at least every ten years or opportunistically when consistent with sample requirements. The sample population will be based on the likelihood of corrosion and cracking for components in each material and water treatment program. The sample population will include more than the piping associated with the CCW return check valve.

RAI B2.1.13-1

Background:

SRP-LR, Table 3.0-1, states that the recommended FSAR supplement description of the program for GALL Report AMP XI.M27, "Fire Water System," includes" ... testing or replacement of sprinklers that have been in place for 50 years."

Issue:

Although the applicant has committed to enhance the Fire Water System Program to include testing or replacement of sprinklers (LRA Table A4-1, Item #8 and LRA Section B2.1.13), testing or replacement of sprinklers that have been in place for 50 years is not included in the FSAR Supplement, LRA Section Al.13.

Request:

Revise the FSAR Supplement to indicate that the Fire Water System Program includes testing or replacement of sprinklers that have been in place for 50 years.

STPNOC Response:

LRA Table A4-1, Item #8 and LRA Appendix B2.1.13 commit to testing or replacement of sprinklers that have been in place for 50 years. However, the commitment was inadvertently not included in the FSAR Supplement, LRA Appendix A1.13.

LRA Appendix Al.13 will be revised to add the following:

The pro-gram will replace sprinklers prior to 50 years in service or will field service test a representative sample of the sprinklers and test them every 10 years thereafter during the period of extended operation to ensure signs of degradation, such as corrosion, are detected in a timely manner.

RAI B2.1.16-1

Background:

SRP-LR A. 1.2.3.10, "Operating Experience," section 3 states "Additionally, an applicant should commit to a review of future plant-specific and industry operating experience for new programs to confirm their effectiveness."

In LRA Table A4-1, "License Renewal Commitment List," the new One-Time Inspection Program does not include a commitment to perform a review of future operating experience to confirm the effectiveness of this program.

Enclosure NOC-AE-1 1002730 Page 6 of 23 Issue:

This program's LRA commitment list is not consistent with the current staff position as stated in the SRP-LR concerning reviews of future operating experience for new Aging Management Programs.

Request:

Revise LRA Table A4-1, "License Renewal Commitments," item No. 11 for the One-Time Inspection Program to include a commitment to perform a future review of operation experience to confirm the effectiveness of this program or justify why such a review is not necessary.

STPNOC Response:

In a letter to the NRC dated June 23, 2011 (ML11181A037), STPNOC revised LRA Licensing Commitment #29 as follows:

As additional industry and plant-specific applicable operating experience becomes available, it will be evaluated and incorporated into each aging management program or in the development of a new aging management program(s), as necessary, to provide assurance that the effects of aging will be managed during the period of extended operation.

In a letter to the NRC dated August 18, 2011 (ML11238A071), STPNOC submitted Amendment 3 to the LRA. Amendment 3 captured revised Commitment #29 in Section Al, "Summary Descriptions of Aging Management Programs," of the Final Safety Analysis Report Supplement of the LRA.

Revised Commitment #29 and Amendment 3 to the LRA assures that future operating experience will be reviewed to confirm the effectiveness of the One-Time Inspection Program.

Commitment #29 specifically lists the One-Time Inspection Program (B2.1.16) as an applicable program for this commitment. Revision of Commitment #11 of LRA Table A4-1 is not required.

RAI B2.1.16-2 Backqround:

SRP-LR Table 3.0-1 states a detailed description for XI.M32 that is to be provided within the FSAR supplement detailing selection based on materials, examination techniques, evaluation of follow-up examinations, and the restrictions to when this program may be applied for structures and components.

LRA Section Al. 16 states that the program's scope, sample methodologies, and the sample locations are to be based on service period, operating conditions, and design margins, including additional actions that are included within this program.

Issue:

The SRP-LR presents a comprehensive program description for the One-Time Inspection program, whereas LRA Section A1.16 omits sample selection based on materials, examination techniques, evaluation of follow-up examinations, and restrictions to when this program may be applied for structures and components.

Enclosure NOC-AE-1 1002730 Page 7 of 23 Request:

Resubmit the UFSAR supplement to fully describe this program consistent with the SRP-LR FSAR supplement guidance for this program.

STPNOC Response:

LRA Appendix Al.16 will be revised as follows to include one-time inspection component sample size, examination techniques, follow-up examinations, and program restrictions.

The One-Time Inspection program conducts one-time inspections of plant system piping and components to verify the effectiveness of the Water Chemistry program (Al.2), Fuel Oil Chemistry program (Al.14), and Lubricating Oil Analysis program (Al.23). The aging effects to be evaluated by the One-Time Inspection program are loss of material, cracking, and reduction of heat transfer. The One-Time Inspection program determines non-destructive examination (NDE) sample sizes for each material enVir*onental gou.pUsing established statistfic~al mnethodologioc and colects pipingicompencnt inspection locatfions with the sample that are based on se.....e pc.iod, operating conditions, and design m.argin,* based on the population of components in a group sharing the same material, environment, and agingq effects. For each population, a representative sample size of 20 percent of the population is selected up to a maximum of 25 components. The components making up the sample are those determined to be most susceptible to degradation based on a review of environment conditions and operatinq experience. The program will focus on bounding or lead components most susceptible to aging due to time in service, and severity of operating conditions. Inspections will be performed using a variety of NDE methods, including visual, volumetric, and surface techniques by qualified inspectors. The program will not be used for component inspections with known age-related degradation mechanisms or when the environment in the period of extended operation is not equivalent to that in the prior 40 years. The One-Time Inspection program specifies corrective actions and incFeas sampling of components if aging effects are found. The corrective action program may specify follow-up inspections for confirmation of aging effects at the same or different locations. If aging effects are detected, a plant-specific program will be developed for the material, environment, and aging effect combination that has produced the aging effects.

This new program will be implemented and completed within the 10 year period prior to the period of extended operation. Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.

RAI B2.1.17-1 Back-ground:

GALL AMP XI.M33 "Selective Leaching of Materials," states "Where practical, the inspection includes a representative sample of the system population and focuses on the bounding or lead components most susceptible to aging due to time in service, severity of operating conditions, and lowest design margin."

Enclosure NOC-AE-1 1002730 Page 8 of 23 Issue:

Based on a review of the applicant's program basis document during the AMP Audit, it is not clear to the staff that the copper alloy (> 15% Zn) solenoid valves in LRA Table 3.3.2-7, Compressed Air System, will be included in the "representative sample" of components to be inspected.

Request:

State the basis for why the copper alloy (> 15% Zn) solenoid valves in LRA Table 3.3.2-7, Compressed Air System were not included the "representative sample" of components to be inspected. Otherwise, include the copper alloy (> 15% Zn) solenoid valves in LRA Table 3.3.2-7 in the potential inspection scope of the Selective Leaching of Materials AMP.

STPNOC Response:

GALL AMP XI.M33, Selective Leaching of Materials program, scope states "Component types within the scope of the Selective Leaching of Materials program include pump casings, piping, and valve bodies. These gray cast iron and copper alloys with greater than 15 percent zinc components with treated water, raw water, or groundwater (buried) environments are potentially susceptible to the loss of material due to selective leaching."

The addenda to the draft procedure OPGP04-ZE-0009 for implementing the Selective Leaching of Materials AMP contain listings of the components applicable to this program. Addendum 3 shows that the two instrument air copper alloy (> 15% Zn) solenoid valves that are exposed to internal plant indoor air (condensation) are managed by the Selective Leaching of Materials program as indicated in LRA Table 3.3.2-7 and are part of the representative sample. One of the two valves will be inspected.

RAI B2.1.17-2

Background:

GALL AMP XI.M33 "Selective Leaching of Materials," states "Where practical, the inspection includes a representative sample of the system population and focuses on the bounding or lead components most susceptible to aging due to time in service, severity of operating conditions, and lowest design margin." The "scope of program" program element description of LRA AMP B2.1.17, "Selective Leaching of Materials," states that the program procedure provides for visual and mechanical inspections for each system/material/environment combination.

Issue:

It is not clear to the staff that the LRA AMP and GALL AMP XI.M33 are consistent because the applicant could select components that are not the most susceptible to selective leaching.

Request:

Explain how the sample of components to be inspected for selective leaching are determined such that the bounding or lead components most susceptible to aging due to time in service, severity of operating conditions, and lowest design margin are included.

Enclosure NOC-AE-1 1002730 Page 9 of 23 STPNOC Response:

LRA Basis Document AMP XI.M33 (B2.1.17), Selective Leaching of Materials program, and the draft implementing procedure OPGP04-ZE-0009 will be revised to include guidance for sample selection that focuses on bounding or lead components most susceptible to aging due to time in service, severity of operating conditions, and lowest design margin.

LRA Appendix B2.1.17 will be revised to state that sample selection criteria will focus on bounding or lead components most susceptible to aging due to time in service, severity of operating conditions, and lowest design margin.

RAI B2.1.17-3 Back-ground:

LRA Amendment 2, Section B.2.1.17, "parameters monitored/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, "Buried and Underground Piping and Tanks." GALL AMP XI.M41 recommends that GALL AMP XI.M33, "Selective Leaching of Materials," be used to manage selective leaching in addition to the program requirements of GALL AMP XI.M41. LRA Table 3.3.2-17, "Fire Protection System," includes buried hydrants and valves that are constructed of gray cast iron that will be managed for loss of material by selective leaching.

Issue:

It is not clear to the staff that utilizing flow testing of fire mains to manage selective leaching of buried gray cast iron components in the fire protection system is consistent with GALL AMP XI.M41.

Request:

Explain how flow testing of fire mains will be effective in managing selective leaching of buried in-scope gray cast iron components of the fire protection system.

STPNOC Response:

While flow testing is capable of detecting indications of loss of material of buried piping due to through wall corrosion, it is not a reliable method for identifying selective leaching. LRA Basis Document AMP XI.M33 (B2.1.17), Selective Leaching of Materials program, will be revised so that selective leaching of buried gray cast iron valves is no longer managed with flow testing.

These valves will be managed by inspection of a sample set in accordance with the criteria of the Selective Leaching program.

LRA Appendices Al.17 and B2.1.17 will be revised to remove use of flow testing for management of selective leaching in fire protection gray cast iron valves and to add that inspection of a sample set will be used for management of selective leaching in fire protection gray cast iron valves.

Enclosure NOC-AE-1 1002730 Page 10 of 23 RAI B2.1.17-4

Background:

GALL AMP XI.M33, "Selective Leaching of Materials," "detection of aging" program element recommends that the selective leaching inspections be conducted in the 5-year period prior to the period of extended operation. The "parameters monitored/inspected" program element of LRA Section B2.1.17, "Selective Leaching of Materials," states that the program will be implemented prior to the period of extended operation.

Issue:

The LRA is not consistent with GALL AMP XI.M33, in that it does not specify that the inspections will be conducted in the five-year period prior to the period of extended operation.

Request:

State the basis for why inspections conducted before the five-year period prior to the period of extended operation will be sufficient to determine whether loss of materials due to selective leaching is occurring.

STPNOC Response:

LRA Appendices A1.17 and B2.1.17 and LRA Basis Document AMP XI.M33 (B2.1.17), Selective Leaching of Materials program, will be revised to state that the selective leaching program will be implemented in the five-year period prior to the period of extended operation.

RAI B2.1.17-5

Background:

The GALL Report, items A-51 and SP-28, recommend that components made of gray cast iron exposed to raw water be managed for selective leaching by GALL AMP XI.M33 "Selective Leaching of Materials." During the audit, the 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 initiated an extent of condition review to identify any other affected AMR items. LRA Table 3.3.2-17 states that these pumps are constructed of cast iron and are being managed for loss of material by the Fire Water System. This item references GALL Report item A-33, which does not include selective leaching as an aging effect requiring management. LRA Section B2.1.13, "Fire Water System," does not include inspections for selective leaching.

Issue:

Given that the fire water system program does not include inspections for selective leaching that include hardness testing for detecting this aging effect, the staff believes that managing the raw water internal environment by the fire water system program may not be sufficient.

In addition, pending the completion of the applicant's extent of condition reviews, the staff lacks sufficient information to conclude that no other AMR items are affected.

Enclosure NOC-AE-1 1002730 Page 11 of 23 Request:

1. State the basis for why managing the diesel fire pumps pumps solely with the Fire Water System program will provide reasonable assurance that the components' current licensing basis function will be met, or revise LRA Table 3.3.2-17 to include managing the gray cast iron fire water pumps by the Selective Leaching AMP in addition to the fire water system.

2. State the final results of the extent of condition review as described in the background of this RAI and revise the LRA as necessary to address any other components that did not have the correct material identified.

STPNOC Response:

LRA Table 3.3.2-17 will be revised to show that the diesel fire pumps are fabricated of gray cast iron and that the aging management program will be B2.1.17, Selective Leaching of Materials program.

The extent of condition for plant components listed as cast iron found that, in most cases, insufficient information existed to distinguish between component material being cast iron or gray cast iron. Conservatively, these components will be considered gray cast iron. For components that are changed to gray cast iron, aging management of these components will be assigned to B2.1.17, Selective Leaching of Materials program.

These component material changes will affect LRA Sections 3.3.2.1.7, 3.3.2.1.9, 3.3.2.1.17, 3.3.2.1.19, 3.3.2.1.20, 3.3.2.1.22, 3.3.2.1.24, 3.3.2.1.25, 3.3.2.1.27 and LRA Tables 3.3.2-7, 3.3.2-9, 3.3.2-17, 3.3.2-19, 3.3.2-20, 3.3.2-22, 3.3.2-24, 3.3.2-25, and 3.3.2-27. These LRA Sections and Tables will be revised accordingly.

RAI B2.1.18-1

Background:

The basis document for LRA AMP B2.1.18, "Buried Piping and Tanks Inspection," "scope of program" program element states that 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)," also includes buried in-scope piping and valves.

Issue:

It is not clear to the staff that the applicant has included all systems (including those described in Table 3.3.2-27) with buried in-scope piping in its Buried Piping and Tanks Inspection program.

Request:

Clarify if the buried piping and valves as listed in LRA Table 3.3.2-27 are subject to the management of the Buried Piping and Tanks Inspection AMP. If so, state whether the implementing procedures for the program require inspection of these buried piping and valves that are part of the miscellaneous systems in scope only for criterion 10 CFR 54.4(a)(2).

Enclosure NOC-AE-1 1002730 Page 12 of 23 STPNOC Response:

No piping or valves from systems only included under Criterion 10 CFR 54.4(a)(2) are managed by the Buried Piping and Tanks program. The piping in LRA Table 3.3.2-27 that credited the Buried Piping and Tanks program for aging management was removed from the scope of license renewal. LRA Table 3.3.2-27 was inadvertently not updated when the LRA was submitted. LRA Table 3.3.2-27 will be revised to remove these buried components.

RAI B2.1.18-2

Background:

GALL AMP XI.M41 , "preventive actions" program element, Table 2a, footnote 5 states that, 'The staff considers backfill that is located within 6 inches of the pipe that meets American Society for Testing and Materials (ASTM) D448-08 size number 67 to meet the objectives of SP0169-2007." The "preventive actions" program element of the LRA AMP states that backfill for buried piping is consistent with ASTM D448-08 size number 67; however, the implementing procedure allows non-category 1 backfill material above plant elevation 26. The staff notes that some buried in-scope piping rises through elevation 26 and up to ground elevation, which is approximately 28 feet.

Issue:

Based on discussions with the applicant's staff during the AMP Audit, non-category 1 backfill may not meet the requirements of ASTM D448-08 size number 67. Given that there is buried in-scope piping that rises through elevation 26 and up to ground elevation which is approximately 28 feet, the applicant's implementing procedures may not be consistent with the "preventive actions" program element for GALL AMP XI.M41, for backfill quality.

Reg uest:

If the plant-specific backfill requirements for backfill installed above plant elevation 26 do not meet the requirements of ASTM D448-08 size number 67, provide an exception and include the basis for why these backfill requirements will not result in damage to buried in-scope piping or its coatings.

STPNOC Response:

The procedure for backfilling requires the use of backfill that meets the ASTM D448 Size 67 criteria for piping above the 26 foot elevation. The original installation specifications indicate that fire protection hydrant riser piping above the 26 foot elevation is backfilled with non-safety related backfill. Non-safety related backfill may be structural fill, clay, or coarse material that may or may not be in accordance with the ASTM D448-08 size number 67 criteria. While the GALL AMP XI.M41 does specify that backfill satisfying the ASTM D448-08 size 67 standard is acceptable, the GALL AMP also allows the applicant to examine the backfill to determine its acceptability. If upon examining the coating of the buried pipe and it is determined there is no damage to the coating due to backfill, then the backfill may be considered acceptable.

Inspections performed to date of the fire protection hydrant risers following removal of backfill have shown no evidence of damage to the pipe coatings. Based on the results of these inspections, the non-safety related backfill of riser piping above the 26 foot elevation is considered acceptable. Therefore, the fire hydrant riser piping will be managed using flow testing along with the rest of the fire protection system.

Enclosure NOC-AE-1 1002730 Page 13 of 23 RAI B2.1.18-3 Back-ground:

GALL AMP XI. M41, "detection of aging effects" program element states "If adverse indications are detected, inspection sample sizes within the affected piping categories are doubled. If adverse indications are found in the expanded sample, the inspection sample size is again doubled. This doubling of the inspection sample size continues as necessary." LRA Section B.2.1.18, "detection of aging effects" program element 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.

Issue:

It is not clear to the staff that the LRA AMP statement is consistent with the GALL AMP because the LRA does not state whether the doubling of inspection sample sizes will continue in locations with similar materials and environments.

Request:

Describe what actions will be taken for areas of similar material and environment where adverse conditions are not extensive. If the planned actions are not consistent with GALL AMP XI.M41 "detection of aging effects" program element 4.f.iv. (i.e., inspections will continue in locations with similar materials and environment other than the portion(s) of the system that will be replaced), provide a justified exception to the program element.

STPNOC Response:

GALL AMP XI.M41, Buried Underground Piping and Tanks program, states in element 4:

If adverse indications are detected, inspection sample sizes within the affected piping categories will be doubled. If adverse indications are found in the expanded sample, the inspection sample size will again be doubled. This doubling of the inspection sample size continues until no more adverse conditions are found.

The GALL wording of "affected piping categories" is considered equivalent to "locations with similar materials and environment". LRA Basis Document AMP XI.M41 (B2.1.18), Buried Underground Piping and Tanks program, will be revised to clarify that when adverse indications are detected, the sample size will expand in locations with similar materials and environment.

This change is consistent with the GALL.

RAI B2.1.18-4

Background:

GALL AMP XI.M41 "detection of aging effects" program element recommends that two percent of underground piping containing materials hazardous to the environment be inspected. The basis document for LRA Section B.2.1.18 "detection of aging effects" program element does not state an inspection size for the underground in-scope oily waste system piping.

Enclosure NOC-AE-1 1002730 Page 14 of 23 Issue:

It is not clear to the staff that these statements are consistent because the applicant did not state an inspection scope for the underground in-scope oily waste system piping.

Request:

State why there are no inspections for the underground in-scope oily waste system piping; otherwise, revise LRA Section B.2.1.18 to be consistent with the inspection recommendations of GALL AMP XI.M41, Table 4b.

STPNOC Response:

GALL AMP XI.M41 lists inspection requirements for safety-related and hazmat piping. The in-scope oily waste buried piping is non-safety related and is in-scope per Criterion (a)(3) of 10 CFR 54.4 to remove firewater from the diesel generator rooms in the case of a fire or to remove fuel oil in case of a fuel oil spill. The piping is considered empty and does not contain oily waste and is therefore not hazmat. This portion of the oily waste system piping is not considered hazmat. No buried pipe inspections are required for the portions of the oily waste system managed by this program.

LRA Basis Document AMP XI.M41 (B2.1.18), Buried Underground Piping and Tanks program, was revised to clarify that the oily waste piping is neither safety related, nor hazmat, and does not require inspection.

RAI B2.1.20-1

Background:

The "parameters monitored/inspected" program element of GALL Report AMPs XI.M36, "External Surfaces Monitoring of Mechanical Components," and XI.M38 "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components," Revision 2, 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. The program basis document for LRA Section B2.1.20, "External Surfaces Monitoring Program," "scope of program" program element states that physical manipulation of elastomers may be used to augment visual inspections. In addition, the Program Description for LRA Section B2.1.22 "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components" states that physical manipulation of elastomers may be used to augment visual inspections.

Issue:

It is not clear to the staff that these statements are consistent because the term "may" allows discretion in determining whether or not to physically manipulate elastomers during visual examinations.

Request:

Revise LRA Sections B2.1.20 and B2.1.22 to state that physical manipulation of elastomers "will" be used to augment visual inspections where the component and material are appropriate for

Enclosure NOC-AE-1 1002730 Page 15 of 23 manipulation or state the basis for how the hardening and loss of strength aging effects can be consistently detected in elastomers without physically manipulating the material.

STPNOC Response:

The term "may" was inadvertently used in LRA Appendix A1.20 and in LRA Basis Document AMP XI.M36 (B2.1.20), External Surfaces Monitoring program, Scope of Program (Element 1) and Detection of Aging Effects (Element 4) as well as in LRA Appendix A1.22, Appendix B2.1.22 and LRA Basis Document AMP XI.M38 (B2.1.22), Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program, Detection of Aging Effects (Element 4).

when referring to manipulation of elastomers.

The wording in LRA Appendix B2.1.20 is satisfactory by stating, "physical manipulation of elastomers is used to augment visual inspections to confirm the absence of hardening or loss of strength."

LRA Appendix A1.20 and LRA Basis Document AMP XI.M36 (B2.1.20), External Surfaces Monitoring program, Scope of Program and Detection of Aging Effects will be revised to state:

When appropriate for the component configuration and material, physical manipulation may will be used to augment visual inspection to confirm the absence of elastomer hardening and loss of strength.

LRA Appendix A1.22, Appendix B2.1.22 will be revised to state:

Visual inspections may will be augmented by physical manipulation, when appropriate for the component configuration and material, to detect hardening and loss of strength of both internal and external surfaces of elastomers.

LRA Basis Document AMP XI.M38 (B2.1.22), Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program, Detection of Aging Effects will be revised to state:

Visual inspections may wil.l be augmented by (1) physical manipulation, when appropriate for the component configuration and material, to detect hardening and loss of strength of elastomers, (2) volumetric examinations of inaccessible tank external locations, taken from tank internal surfaces, to confirm the absence of loss of material due to corrosion, and (3) volumetric evaluation to detect stress corrosion cracking of the internal surfaces of stainless steel components exposed to diesel exhaust.

RAI B2.1.20-2 Back~ground:

LRA Section B2.1.20, "External Surfaces Monitoring Program," "scope of program" program element states that the program 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 items associated with dampers containing internal surfaces within ducting (or a plenum) exposed to atmospheric weather internal environment which are managed by the External Surfaces Monitoring Program. GALL AMP XI.M36, "External Surfaces Monitoring of Mechanical Components," "scope of program" program element states that the program may be used to age manage internal surfaces if the program describes how the component's internal and external environments are similar.

Enclosure NOC-AE-1 1002730 Page 16 of 23 Issue:

It is not clear to the staff how these components will either be periodically monitored (i.e., subject to direct visual inspection) using the External Surfaces Monitoring Program or, conversely, how the internal and external environments could be considered sufficiently similar to allow the use of the External Surfaces Monitoring Program alone.

Request:

State how the dampers exposed to an atmospheric weather internal environment in LRA Tables 3.3.2-11 and 3.3.2-12 will be periodically inspected by the External Surfaces Monitoring Program or state how the internal and external environments can be considered sufficiently similar to allow the use of the External Surfaces Monitoring Program alone.

STPNOC Response:

The dampers in LRA Tables 3.3.2-11 and 3.3.2-12 are the supply HVAC tornado dampers for the Fuel Handling and Mechanical Auxiliary Buildings, respectively, and are subject to an atmosphere/weather environment. The External Surfaces Monitoring Program was inadvertently specified for monitoring the internal pressure boundary surfaces of the tornado dampers.

LRA Tables 3.3.2-11 and 3.3.2-12 will be revised to specify AMP B2.1.22, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program, for management of the internal surfaces of the supply HVAC tornado dampers for the Fuel Handling and Mechanical Auxiliary Buildings.

RAI B2.1.20-3

Background:

GALL AMP XI.M36, "External Surfaces Monitoring of Mechanical Components," "detection of aging effects" program element recommends that at least 10 percent of the available surface area of elastomeric or polymeric materials be manipulated during inspections. LRA Section B2.1.20, External Surfaces Monitoring Program, "scope of program" program element states that physical manipulation of elastomers may be used to augment visual inspections.

Issue:

It is not clear to the staff that the applicant's program will require that at least 10 percent of the available surface area of elastomeric or polymeric materials be manipulated during inspections.

Request:

Revise LRA Section B2.1.20 to require that at least 10 percent of the available surface area of elastomeric or polymeric materials be manipulated during inspections, or state the basis for why manipulating less than 10 percent of the available surface will be adequate to detect hardening and loss of strength in elastomeric and polymeric materials.

Enclosure NOC-AE-1 1002730 Page 17 of 23 STPNOC Response:

LRA Appendices A1.20 and B2.1.20 and LRA Basis Document AMP XI.M36 (B2.1.20), External Surfaces Monitoring program, will be revised to require manipulation of at least 10 percent of the available surface area of elastomeric or polymeric materials to confirm the absence of hardening or loss of strength.

RAI B2.1.20-4

Background:

GALL AMP XI.M36, "External Surfaces Monitoring of Mechanical Components," 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, as determined during the AMP audit, 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.

Issue:

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.

Request:

1. State how component(s} that are not readily accessible during plant operations and refueling outages will be evaluated to ensure that the components' intended functions are maintained between inspections and how the inspection interval will be determined.

2. State how the inspections for component(s) that are not readily accessible during plant operations and refueling outages will be tracked to ensure that the inspections are conducted as planned.

STPNOC Response:

The normal external monitoring inspection frequency for components in-scope of AMP XI.M36, External Surfaces Monitoring program, is every refueling outage cycle. However, in some cases it may not be advisable to inspect some components every refueling cycle due to inaccessibility caused by high radiation exposure or the physical difficulty to accomplish the inspections. In such cases, longer inspection frequencies may be considered with appropriate justification that assures the component intended functions are maintained during the period of extended operation.

LRA Basis Document AMP XI.M36 (B2.1.20), External Surfaces Monitoring program, and the implementing procedure for AMP XI.M36 will be revised to:

• Include guidance for identifying, logging, and tracking components that are not available for inspection during plant operations and refueling outages.

Enclosure NOC-AE-1 1002730 Page 18 of 23

" Address inspection frequencies for affected components that assure component intended functions are maintained in the period of extended operation.

" Specify that longer component inspection frequencies may be considered with appropriate justification such as using results from external inspections of components at different locations with the same materials, environmental conditions, and potential spatial interactions.

• Ensure that all extended inspection frequencies are justified and documented.

• Ensure that all inaccessible components are inspected at least once prior to entering the period of extended operation.

RAI B2.1.20-5

Background:

GALL AMP XI.M29, "Aboveground Metallic Tanks," recommends that any tank exposed to weather and 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 that 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.

LRA Table 3.3.2-17 credits the External Surfaces Monitoring program to manage loss of material for the steel fire water storage tank, which is exposed to atmosphere/weather and constructed on a concrete foundation. 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.

Furthermore, LRA Table 3.4.2-6 states that there is no aging effect and no AMP for the concrete stainless steel lined auxiliary feedwater storage tank exposed to atmosphere/weather.

Revision 2 of the SRP-LR, Table 3.0-1, states that for the program that manages aboveground metallic tanks constructed on concrete or soil which are exposed to atmosphere/weather, the UFSAR Supplement should state that preventive measures to mitigate corrosion by installing sealant or caulking at the concrete-component interface are utilized, and tank program effectiveness is determined by measuring the thickness of the tank bottoms to ensure that significant degradation is not occurring and that the component's intended function is maintained during the period of extended operation.

Issue:

During the AMP audit, the staff and applicant walked down the fire water storage and auxiliary feedwater storage tanks. The fire water storage tank has caulking applied at its interface with the concrete foundation. Due to walk down limitations, it is not clear to the staff if all penetrations in the concrete of the auxiliary feedwater concrete stainless steel lined storage tank are caulked.

Although structural caulking and sealants exposed to atmosphere/weather are managed by the Structures Monitoring Program in LRA Table 3.5.2-3, the periodicity of inspections for the Structures Monitoring Program is not as frequent as those recommended by GALL AMP XI.M29.

The External Surfaces Monitoring Program does not conduct tank bottom thickness measurements. Additionally, the FSAR Supplement is not consistent with SRP-LR Revision 2, Table 3.0-1.

Request:

1. State whether all penetrations through the concrete of the auxiliary feedwater concrete stainless steel lined storage tank which could allow water to enter between the tank lining

Enclosure NOC-AE-1 1002730 Page 19 of 23 material and the concrete are caulked or sealed. If they are not caulked or sealed, state the basis for a reasonable assurance that the tank will perform its current license basis function throughout the period of extended operation.

2. State the technical basis for not inspecting caulking and sealants utilized at the tank to concrete interface joints on a 2-year interval, or revise the LRA to increase the frequency of these inspections.

3. State the basis for not conducting tank bottom thickness measurements for the fire water storage tank and auxiliary feedwater storage tank at least once within 5 years of entering the period of extended operation and whenever the tank is drained, or revise the LRA to include these inspections.

4. Based upon the responses to requests 1 through 3, revise the UFSAR supplement for the program that manages the above aging for the fire water storage tank and auxiliary feedwater storage tank to be consistent with SRP-LR Revision 2, Table 3.0-1.

STPNOC Response:

The GALL Rev 2 requirements for AMP XI.M29 for outside tanks founded on concrete are included in LRA Basis Document AMP XI.M36 (B13.20), External Surfaces Monitoring program, and LRA Basis Document AMP XI.M38 (B2.1.22), Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program, as discussed below.

1. The auxiliary feedwater storage tank (AFST) penetrations are not caulked. The stainless steel tank liner is completely encased in concrete that was poured around the liner and all tank penetrations (approximately two feet thick). Any gaps or spaces on the tank exterior and around penetrations are grouted to prevent water entry. Volumetric inspection of the AFST tank bottom by LRA Basis Document AMP XI.M38 (B2.1.22),

Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program, will assure no loss of material is occurring on the tank bottom surfaces in contact with concrete.

2. As stated above, no caulking or sealants are used on the concrete portions of the AFST.

The firewater storage tank (FWST) bottom-to-concrete foundation interface is caulked to prevent water entry under the tank bottom. The FWST external surface is included in LRA Basis Document AMP XI.M36 (B2.1.20), External Surfaces Monitoring program, and elastomer inspections are part of the program. Inspection walkdowns of the FWST are performed at least once every refueling cycle.

3. The AFST and FWST bottoms will be volumetrically inspected from the inside of the tanks by LRA Basis Document AMP XI.M38 (B2.1.22), Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components. Volumetric examination of the tank bottoms from the inside will assure no loss of material is occurring on the tank bottom surfaces in contact with concrete. These inspections will be conducted within 5 years prior to entering the period of extended operation and whenever the tanks are drained.

4. LRA Appendices A1.22 and B2.1.22 and LRA Basis Document AMP XI.M38 (B2.1.22),

Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program, will be revised to volumetrically inspect the AFST and FWST tank bottoms from the inside of the tank within 5 years prior to entering the period of extended operation and whenever the tanks are drained. LRA Tables 3.3.2-17 and 3.4.2-6 will be revised to credit LRA Basis Document XI.M38 (B2.1.22) to manage loss of material from

Enclosure NOC-AE-1 1002730 Page 20 of 23 tank bottoms founded on concrete. LRA Tables 3.3.2-17 will be revised to credit LRA Basis Document XI.M36 (B2.1.20) to manage hardening and loss of strength of the caulking around the FWST tank bottom, LRA Appendix A1.20, B2.1.22 and LRA Basis Document AMP XI.M36 (B2.1.20), External Surfaces Monitoring program will be revised to include visual inspection during periodic plant walkdowns to monitor for degradation of protective paints, coatings, caulking, or sealants.

RAI B2.1.22-1

Background:

GALL AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components," program description states that the program applies to water systems other than open-cycle cooling water (XI.M20), closed treated water system (XI.M21A), and fire water system (XI.M27).

The applicant's basis documents for LRA AMP B2.1.22, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components," indicates that the program applies to water systems including closed-cycle cooling water system and fire protection system components.

Additionally, LRA AMP B.2.1.22 also states, in the program description, that hardening and loss of strength for both internal and external surfaces of elastomers is in the scope of this AMP.

Issue:

The program's scope concerning closed cycle cooling water, fire protection and the application of external elastomers is not consistent with the scope of GALL AMP XI.M38.

Request:

The applicant should evaluate the scope currently listed within this program concerning closed cycle cooling water, fire protection and external elastomers. If these elements are retained within the current program please state a justification for this exception to GALL AMP XI.M38.

STPNOC Response:

1. LRA Basis Document AMP XI.M38 (B2.1.22), Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program, inappropriately listed closed cycle cooling water (CCCW) as an applicable environment in the Scope of Program for copper alloy components. The scope of program description in this basis document will be revised to remove reference to copper alloy and CCCW.

2. The Fire Protection (FP) system is listed in LRA Basis Document AMP XI.M38 (B2.1.22) as an applicable plant system for this AMP. The in-scope FP system components are not associated with an internal environment of fire water. Instead, these components have internal environments of plant indoor air and diesel generator exhaust, or an external environment of concrete. These environments are correct for internal inspection or ultrasonic inspection of tank bottoms.

Enclosure NOC-AE-1 1002730 Page 21 of 23

3. LRA Appendix A1.22 and Appendix B2.1.22 inappropriately refer to the external surfaces of elastomers. LRA Appendix A1.22 and Appendix B2.1.22 will be revised to remove reference to external surfaces of elastomers.

RAI B2.1.22-2

Background:

GALL AMP Xl.M38 program element, "parameters monitored/inspected" provides examples of inspection parameters for polymers such as crazing, scuffing, dimensional change, and exposure of internal reinforcement.

The applicant's basis documents for LRA AMP B2.1.22, Section 4.5.3, do not include the above inspection parameters.

Issue:

The program's basis documents do not comprehensively consider all the inspection parameters associated with polymers.

Request:

The applicant is requested to present a cumulative list of inspection parameters that the program will apply to polymers. If there are parameters consistent with the GALL Report that will not be included, the applicant is requested to present a justification for their absence.

STPNOC Response:

The correct section for LRA Basis Document AMP XI.M38 (B2.1.22) is Section 3.3.2 not Section 4.5.3 as noted in the RAI. LRA Basis Document AMP XI.M38 (B2.1.22), Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program, Section 3.3.2 will be revised to include inspection parameters for elastomers including crazing, scuffing, dimensional change, and exposure of internal reinforcement for reinforced elastomers.

RAI B2.1.22-3

Background:

GALL AMP XI.M38 program element, "detection of aging effects" identifies the sample size for manipulation of flexible polymeric components as "at least 10 percent of available surface area.

The applicant's LRA and basis document do not provide guidance on sample size for flexible polymeric components.

Issue:

There is no sample size associated with physical manipulation of flexible polymeric components in the applicant's documentation.

Enclosure NOC-AE-1 1002730 Page 22 of 23 Request:

Please submit and document the program's intended sample size associated with physical manipulation of flexible polymeric components. If the intended sample size differs from recommendations of the GALL Report, the applicant is asked to provide technical justification for an alternate method.

STPNOC Response:

LRA Appendix A1.22, Appendix B2.1.22 and LRA Basis Document AMP XI.M38 (B2.1.22),

Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program, Detection of Aging Effects will be revised to include the requirement to manipulate at least 10 percent of available surface area for in-scope elastomers.

RAI B2.1.22-4 Backgqround:

GALL AMP XI.M38 program description states that if visual inspections of internal surfaces are not possible, then the applicant needs to provide a plant-specific program.

The applicant's basis document states that in cases where the internal surface is not available for internal examination, [volumetric examination] may be substituted for visual examinations.

Issue:

While utilizing volumetric examinations at non-accessible internal inspection locations is acceptable, neither the applicant's program description in LRA Section B.2.1.22, FSAR Supplement, nor associated commitment section mentions this plant-specific approach to inspecting inaccessible surfaces.

As such, the applicant's program does not identify a program enhancement consistent with the GALL Report concerning the plant specific inspection procedure for inaccessible surfaces.

Request:

The applicant is requested to document an enhancement to STP's new program identifying the intent to utilize volumetric examinations in lieu of visual inspections where internal surfaces are inaccessible. Additionally, the UFSAR Supplement should be revised to reflect this plant-specific approach to inspecting inaccessible surfaces.

STPNOC Response:

LRA Appendix A1.22 and Appendix B.2.1.22 and the draft plant implementing procedure will be revised to state that volumetric examination may be substituted for internal visual inspections in cases where internal surfaces are not available for visual inspection.

Enclosure NOC-AE-1 1002730 Page 23 of 23 RAI B2.1.22-5

Background:

SRP-LR, A.1.2.3.10, "Operating Experience," Section 3, states" ... an applicant should commit to a review of future plant-specific and industry operating experience for new programs to confirm their effectiveness."

In LRA Table A4-1, "License Renewal Commitment List," the new Internal Surfaces in Miscellaneous Piping and Ducting Components Program does not include a commitment to perform a review of future operating experience to confirm the effectiveness of this program.

Issue:

This program's LRA commitment list is not consistent with the current staff position as stated within the SRP-LR concerning reviews of future operating experience for new Aging Management Programs.

Request:

Revise LRA Table A4-1, "License Renewal Commitments," Item No. 17 for the Internal Surfaces in Miscellaneous Piping and Ducting Components Program to include a commitment to perform a future review of operating experience to confirm the effectiveness of this program, or justify why such a review is not necessary.

STPNOC Response:

In a letter to the NRC dated June 23, 2011 (ML11181A037), STPNOC revised LRA Licensing Commitment #29 as follows:

As additional industry and plant-specific applicable operating experience becomes available, it will be evaluated and incorporated into each aging management program or in the development of a new aging management program(s), as necessary, to provide assurance that the effects of aging will be managed during the period of extended operation.

In a letter to the NRC dated August 18, 2011 (ML11238A071), STPNOC submitted Amendment 3 to the LRA. Amendment 3 captured revised Commitment #29 in Section Al, "Summary Descriptions of Aging Management Programs," of the Final Safety Analysis Report Supplement of the LRA.

Revised Commitment #29 and Amendment 3 to the LRA assures that operating experience will be reviewed to confirm the effectiveness of the Internal Surfaces in Miscellaneous Piping and Ducting Components Program. Commitment #29 specifically lists the Internal Surfaces in Miscellaneous Piping and Ducting Components Program (B2.1.22) as an applicable program for this commitment. Revision of Commitment #17 of LRA Table A4-1 is not required.