ML11299A105

Requests for Additional Information for the Review of the South Texas Project, Units 1 and 2, License Renewal Application - Aging Management Program, Set 7

ML11299A105
Person / Time
Site:	South Texas
Issue date:	11/03/2011
From:	Daily J License Renewal Projects Branch 1
To:	Rencurrel D South Texas
Daily J
References
TAC ME4936, TAC ME4937
Download: ML11299A105 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 3,2011 Mr. D. W. Rencurrel, Sr. 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 PROGRAM, SET 7 (T AC NOS. ME4936 AND ME4937)

Dear Mr. Rencurrel:

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, JvC John W. Daily, Sr. Project Man ger 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 REVIEWS, SET 7 (TAC NOS. ME4936 AND ME4937)

Fuel Oil Chemistry (031)

RAI 82.1.14-1

Background

The updated final safety analysis report (UFSAR) Supplement description contained in the Standard Review Plan for License Renewal (SRP-LR), Table 3.0-1, "FSAR Supplement for Aging Management of Applicable Systems," provides an acceptable program description which includes the specific American Society for Testing and Materials International (ASTM) standards to be used for the monitoring and controlling of fuel oil contamination to maintain fuel oil quality.

License renewal application (LRA) Section A1.14, "Fuel Oil Chemistry," states "The program includes (a) surveillance and monitoring procedures for maintaining fuel oil quality by controlling contaminants in accordance with the Technical Specifications and applicable ASTM Standards ... "

Issue The specific ASTM standards used in the program are not specified. Specifying the ASTM standards to be used ensures that there is an adequate description of the critical elements of the Fuel Oil Chemistry Aging Management Program to provide assurance that the program will be properly executed during a period of extended operations.

Request Discuss why the specific ASTM standards utilized in the program are not listed in the FSAR Supplement provided in the LRA Appendix A. Describe the procedures and testing that will be used in lieu of the ASTM standards. Alternatively, provide a revision to your FSAR supplement to add the specific ASTM standards.

RAI82.1.14-2

Background

After the issuance of Revision 1 of the NUREG-1801, "Generic Aging Lessons Learned (GALL)

Report," the U.S. Nuclear Regulatory Commission (NRC) issued Information Notice (IN) 2009 02, "Biodiesel in Fuel Oil Could Adversely Impact Diesel Engine Performance," This IN discusses potential issues that may occur with the use of B5 blend fuel oil, such as suspended water particles, biodegradation of B5, material incompatibility, and so on.

Issue The LRA does not provide information discussing the concerns of IN 2009-02 and the acceptable or unacceptable use of biodiesel at South Texas Project (STP).

ENCLOSURE

2 Request

1. Provide a summary of the actions taken to determine the impact of IN 2009-02 and the use of biodiesel fuel oil at STP; particularly, whether issues of suspended water particles and biodegradation introduce a new aging environment to be considered.

2. If biodiesel is currently being used at STP, please describe any problems that STP has encountered with the use of biodiesel and the associated corrective actions to prevent reoccurrence in the future.

3. If biodiesel has been determined to be not acceptable for use at STP, please describe the actions taken and/or will be taken to prevent its addition into fuel oil supply. Please also describe actions that will be taken if it is determined that biodiesel has been added into the fuel oil supply.

RAI 82.1.14-3

Background

The LRA states that condition reports have documented that fuel oil chemistry was out of specification in regards to water and fine sediment intrusion into the auxiliary fuel oil storage tank, diesel generator fuel oil storage tank, fire pump fuel oil storage tank, and the vendor fuel oil trailer tanks during the period of 1999-2009. The applicant also stated that corrective actions were taken and that fuel oil chemistry was brought back into specification limits.

Issue The LRA does not provide information on when and why water and fine sediment intrusion into storage tanks were found and identified.

Request Please discuss whether the trending of water and sediment measurements have remained the same, increased, or decreased as a result of corrective actions.

RAI82.1.14-4

Background

Periodic draining and cleaning of diesel fuel tanks is performed so that internal surfaces can be visually and volumetrically inspected allowing for detection of corrosion and other degradation inside the tanks. Regulatory Guide (RG) 1.137, "Fuel Oil Systems for Standby Diesel Generators," Revision 1, Regulatory Position C.2.f, as documented in the GALL Report Revision 2, recommends draining and cleaning of diesel fuel tank internal surfaces at least once every 10 years during the period of extended operation.

LRA aging management program (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 standby diesel generator (SDG) fuel oil drain tanks and diesel fire pump fuel oil storage tanks.

3 Issue The LRA does not indicate whether the program enhancement will include the balance of plant (BOP) day tanks.

Request Provide the frequency for draining, cleaning, and inspection of the BOP day tanks. If the frequency is greater than 10 years, please discuss how it is consistent with the GALL Report recommendation of draining and cleaning of diesel fuel tank internal surfaces at least once every 10 years during the period of extended operation.

Xf.S8-1 Protective Coating Monitoring and Maintenance (048)

Background

The GALL Report states that proper maintenance of protective coatings inside containment (defined as Service Level I in NRC RG 1.54, Revision 1) is essential to ensure operability of post-accident safety systems that rely on water recycled through the containment sump/drain system. Degradation of coatings can lead to clogging of strainers, which reduces flow through the sump/drain system. The STP LRA does not credit the protective coating monitoring and maintenance program for aging management.

Issue Although the applicant does not credit the program for aging management, the applicant needs to provide adequate assurance that proper management and maintenance of the protective coatings in containment is occurring, such that coatings will not degrade and become a debris source that may challenge the Emergency Core Cooling Systems performance.

Request

1. Discuss why XI.S8, "Protective Coating Monitoring and Maintenance Program," is not credited for aging management.

2. Discuss in detail whether the applicant has a coatings monitoring and maintenance program. Describe the program if one is used.

3. Describe how the applicant will ensure that there will be proper maintenance of the protective coatings inside containment such that they will not become a debris source that could impact the operability of post-accident safety systems that rely on water recycled through the containment sump or drain system during the period of extended operation.

a. Provide the 10 elements of the AMP for coating, (i.e., scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, corrective actions, confirmation process, administrative controls, and operating experience).

4 Steam Generator Tube Integrity (020)

RAI 82.1.8-1

Background

SRP-LR Section 3.1.2.2.11 and the GALL Report identify that cracking due to primary water stress-corrosion cracking (PWSCC) could occur in steam generator (SG) nickel alloy tube-to tubesheet welds exposed to reactor coolant. The GALL Report recommends the Water Chemistry AMP to manage this aging effect. This aging effect is addressed in GALL Report, item IV.D1.RP-385, and is applicable to recirculating SGs. In addition, the GALL Report and SRP-LR indicate that unless the NRC has approved a redefinition of the pressure boundary in which the tube-to-tubesheet weld is no longer included, the effectiveness of the primary water chemistry program should be verified to ensure cracking is not occurring. The need for a program depends, in part, on the materials used in joining the tube to the tubesheet.

In LRA Table 3.1.1, the applicant stated that LRA item 3.1.1.35 is not applicable because STP does not have once-through SGs, and therefore do not have the components associated with this model of SGs. In LRA Section B2.1.8, the applicant stated that the STP replacement SGss have thermally treated Alloy 690 tubes.

Issue The LRA was developed prior to the finalization of Revision 2 of the SRP-LR and the GALL Report. The LRA does not provide information on the tubesheet clad material or the tube-to tubesheet weld region.

RequestFor STP Model Delta 94 SGs, confirm that the tube-to-tubesheet weld is part of the reactor coolant pressure boundary and clarify the materials used in forming the tube-to tubesheet joins (welds). If the tube-to-tubesheet weld is part of the reactor coolant pressure boundary and the cladding material has a chemical composition similar to Alloy 600 (e.g., Alloy 82 or Alloy 182), provide a plant-specific AMP, along with the Primary Water Chemistry Program, to manage this potential aging effect and ensure that cracking due to PWSCC is not occurring in tube-to-tubesheet welds. Alternatively, justify why no AMP is needed.

' .. ML11299A105 *concurrence via e-mail OFFICE LA:DLR* PM:DLR:RPB1 BC:DLR:RPB1 PM:DLR:RPB1 DMorey NAME IKing JDaily JDaily (JDailv for)

DATE 10/26/2011 11/312011 11/3/2011 11/3/2011

Letter to D. W. Rencurrel, from John W. Daily dated November 3, 2011

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE SOUTH TEXAS PROJECT, UNITS 1 AND 2, LICENSE RENEWAL

. APPLICATION -AGING MANAGEMENT PROGRAM, SET 7 (TAC NOS. ME4936 AND ME4937)

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