ML11273A008

Requests for Additional Information for the Review of the South Texas Project, Units 1 and 2, License Renewal Application - Aging Management Review, Set 4

ML11273A008
Person / Time
Site:	South Texas
Issue date:	10/11/2011
From:	Daily J License Renewal Projects Branch 1
To:	Gerry Powell South Texas
Daily J
References
TAC ME4936, TAC ME4937
Download: ML11273A008 (6)

Text

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October 11, 2011

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• • • • -1' Mr. G. T. Powell, Vice President Technical Support and Oversight STP Nuclear Operating Company P.O. Box 289 Wadsworth, TX 77483

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE SOUTH TEXAS PROJECT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION - AGING MANAGEMENT REVIEW, SET 4 (TAC NOS. ME4936 AND ME4937)

Dear Mr. Powell:

By letter dated October 25,2010, STP Nuclear Operating Company submitted an application pursuant to Title 10 of the Code of Federal Regulations, Part 54, to renew operating licenses NPF-76 and NPF-80 for South Texas Project, Units 1 and 2, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review.

These requests for additional information were discussed with Arden Aldridge, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-3873 or bye-mail at john.daily@nrc.gov.

Sincerely,

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John W. Daily, Senior Project Manager 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

SOUTH TEXAS PROJECT, UNITS 1 AND 2, REQUEST FOR ADDITIONAL INFORMATION AGING MANAGEMENT REVIEW, SET 4 (T AC NOS. ME4936 AND ME4937)

Flow*Accelerated Corrosion (018)

RAI 3.3.2.19*1

Background:

The standard review plan for review of license renewal (SRP-LR) states that the "Evaluation Findings" subsections present conclusions which include a determination as to whether the applicant has adequately identified the aging effects and the aging management program (AMP) credited with managing the aging effects. The Generic Aging Lessons Learned (GALL) Report states the conditions and operating experience at the plant must be bound by the conditions and operating experience for which the GALL Report program was evaluated. Otherwise, it is incumbent on the applicant to augment the GALL program as appropriate to address the additional aging effects.

The Flow-Accelerated Corrosion (FAG) Program is credited for managing aging due to wall thinning of various carbon steel components in license renewal application (LRA)

Tables 3.3.2-19, "Chemical and Volume Control," Table 3.3.2-22, "Liquid Waste Processing,"

and Table 3.4.2-2, "Auxiliary Steam System and Boilers," as well as several other tables.

Issue:

The implementing procedure for the FAC Program and the FAC Program Manual provides a list of systems that are susceptible to F AC; however, the list in these documents does not include the three systems cited above. It is not clear whether the current FAC program, as implemented at the site, includes the components cited in the LRA.

In addition, the implementing procedure for the FAC Program, states that an erosion/corrosion program has been developed, which includes wall thinning of piping systems that are not included in the FAC Program, and addresses damage caused by cavitation, flashing, and impingement. It is not clear whether there are components within the scope of license renewal, that are being managed for wall thinning by an erosion/corrosion program, which are not included in the FAC Program.

Request:

1)

Provide information demonstrating that the current flow-accelerated corrosion program includes the associated components specified in LRA Tables 3.3.2-19, 3.3.2-22, and 3.4.2-2, or clarify which aging management program addresses wall thinning for these components.

ENCLOSURE

- 2

2)

If there are components within the scope of license renewal that are being managed for wall thinning by a separate erosion/corrosion program, provide details about this plant-specific program and clarify which components listed in the LRA are managed by this program.

Buried Piping and Tanks (035)

Background:

In its response to request for additional information (RAI) B2.1.1S-1, dated September 15, 2011, the applicant stated that there are no piping or valves, within systems included only for the criterion in Title 10 of the Code of Federal Regulations (10 CFR) 54.4(a)(2), that are managed by the Buried Piping and Tanks Inspection program, therefore the piping in LRA Table 3.3.2-27 that credited the Buried Piping and Tanks Inspection program for aging management was removed from the scope of license renewal.

Issue:

The staff reviewed the license renewal drawings associated with the low pressure nitrogen system and determined that, with the exception of one drawing, all buried piping in the low pressure nitrogen system, which is shown to be within the scope of license renewal per the criterion in 10 CFR 54.4(a)(2), is not directly connected to any other components that are within the scope of license renewal per the criteria in 10 CFR 54.4(a)(1). Therefore, the staff would not expect the buried nitrogen system piping to be within the scope of license renewal. The one exception is shown on license renewal drawing LR-STP-NL-6T1S0F0007S, Revision OA at locations C7 and GS. These lines continue onto license renewal drawings LR-STP-CT-5S199F00020#1 and LR-STP-CT-5S199F00020#2, and connect to the auxiliary feedwater storage tank via the condensate transfer system. There are no (a)(2) termination notes shown on these two drawings for the condensate transfer system to indicate that a seismic anchor or equivalent exists.

NEI 95-10, Revision 6, in Appendix F, states that an alternative to specifically identifying a seismic anchor or series of equivalent anchors that support the safety-related/nonsafety-related piping interface is to include enough-of the nonsafety-related piping run to ensure these anchors are included and thereby ensure the piping and anchor intended functions are maintained. This may include a point where buried piping exits the ground. The buried portion of the piping should be included in the scope of license renewal. LR-STP-NL-6T1S0F0007S, Revision OA includes a note FAe, which is listed under the heading U(a)(2) Termination Symbols," and is defined as "Point where buried piping exits the ground - buried portion of pipe in-scope."

Because a specific reason for the removal of the buried nitrogen system piping from the scope of license renewal was not provided and there are no indications on the drawings (LR-STP-CT -5S 199F00020#1 and LR-STP-CT -5S 199F00020#2) that seismic anchors exist, the staff cannot determine if the buried nitrogen system piping identified on license renewal drawing LR-STP-NL-6T1S0F0007S, Revision OA at locations C7 and GS should be within the scope of license renewal.

- 3 Request:

For the buried nitrogen system piping identified on license renewal drawing LR-STP-NL-6T180F00078, Revision OA at locations C7 and G8, provide a reason why the piping is not within the scope of license renewal.

ML11273A008

• concurrence via e-mail

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10/11/2011

Letter to G. T Powell from John W. Daily dated October 11, 2011

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE SOUTH TEXAS PROJECT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION AGING MANAGEMENT REVIEW, SET 4 (TAC NOS. ME4936 AND ME4937)

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