ML11319A026
| ML11319A026 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 11/04/2011 |
| From: | Rencurrel D South Texas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NOC-AE-1 1002750, TAC ME4936, TAC ME4937, G25, STI: 33013593 | |
| Download: ML11319A026 (91) | |
Text
Nuclear Operating Company South re=s Project Electric GeneratinS Station P0. Box 289 Wadsworth, T-as 77483 November 4, 2011 NOC-AE-1 1002750 10 CFR 54 STI: 33013593 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 Supplement to the South Texas Project License Renewal Application (TAC NOS. ME4936 and ME4937)
A A A A I I I
I
References:
- 1.
Letter from G. T. Powell, STP Nuclear Opepating Company, to NRC Document Control Desk, "License Renewal Application," dated October 25, 2010 (NOC-AE-1 0002607)
- 2.
Letter from G. T. Powell, STP Nuclear Operating Company, to NRC Document Control Desk, "Response to Request for Additional Information for the South Texas Project License Renewal Application (TAC Nos. ME4936 and ME4937)," dated September 15, 2011 (NOC-AE-11002730) (ML11266A019)
- 3.
Letter from G. T. Powell, STP Nuclear Operating Company, to NRC Document Control Desk, "Response to Requests for Additional Information for the South Texas Project License Renewal Application (TAC Nos. ME4936 and ME4937)," dated September 15, 2011 (NOC-AE-11002731) (ML11266A020)
By Reference 1, STP Nuclear Operating Company (STPNOC) submitted a License Renewal Application (LRA) for South Texas Project (STP) Units 1 and 2. This letter supplements responses to requests for additional information regarding the LRA provided in References 2 and 3. The supplemental responses are in the form of revisions to the LRA and are provided in Enclosures 1 and 2.
Revised regulatory commitments to Table A4-1 of the LRA are provided in Enclosure 2. There are no other 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
/.
Date Rencurrel Senior Vice President, Technical Support & Oversight KJT
Enclosures:
- 1. Changes to the STPNOC LRA 2: Revised Regulatory Commitments
NOC-AE-1 1002750 Page 2 of 2 cc:
(paper copy)
(electronic copy)
Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 612 East Lamar Blvd, Suite 400 Arlington, Texas 76011-4125 Balwant K. Singal Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North (MS 881) 11555 Rockville Pike Rockville, MD 20852 Senior Resident Inspector U. S. Nuclear Regulatory Commission P. 0. Box 289, Mail Code: MN116 Wadsworth, TX 77483 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704 John W. Daily License Renewal Project Manager (Safety)
U.S. Nuclear Regulatory Commission One White Flint North (MS 01 1-Fl) 11555 Rockville Pike Rockville, MD 20852 Tam Tran License Renewal Project Manager (Environmental)
U. S. Nuclear Regulatory Commission One White Flint North (MS O11F01) 11555 Rockville Pike Rockville, MD 20852 A. H. Gutterman, Esquire Kathryn M. Sutton, Esquire Morgan, Lewis & Bockius, LLP John Ragan Chris O'Hara Jim von Suskil NRG South Texas LP Kevin Polio Richard Pena City Public Service Peter Nemeth Crain Caton & James, P.C.
C. Mele City of Austin Richard A. Ratliff Alice Rogers Texas Department of State Health Services Balwant K. Singal John W. Daily Tam Tran U. S. Nuclear Regulatory Commission NOC-AE-1 1002750 Enclosure I Changes to the STPNOC LRA NOC-AE-1 1002750 Page 1 of 84 Changes to the STPNOC LRA
References:
1.
Letter from G. T. Powell, STP Nuclear Operating Company, to NRC Document Control Desk, "Response to Request for Additional Information for the South Texas Project License Renewal Application (TAC Nos. ME4936 and ME4937),"
dated September 15, 2011 (NOC-AE-11002730) (ML11266A019)
- 2. Letter from G. T. Powell, STP Nuclear Operating Company, to NRC Document Control Desk, "Response to Requests for Additional Information for the South Texas Project License Renewal Application (TAC Nos. ME4936 and ME4937),"
dated September 15, 2011 (NOC-AE-1 1002731) (ML11266A020)
The following table lists the affected STPNOC LRA Sections and Tables and the reason for each change. The LRA changes following the table are formatted in a "line-out" (i.e. text being deleted from the LRA) and "line-in" (i.e., text being added to the LRA) structure.
Referenced RAI Affected Reason for Change Letter Number Section of LRA 1
B2.1.17-5 3.3.2.1.7 Components will be considered gray cast iron. For components changed to gray cast iron, aging management of these components is assigned to B2.1.17, Selective Leaching of Materials program.
Affected 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, 3.3.2-27.
1 B2.1.17-5 3.3.2.1.9 Same as above 1
B2.1.17-5 3.3.2.1.17 Same as above 1
B2.1.20-5 3.3.2.1.17 Revised to manage hardening and loss of strength of the caulking around the FWST tank bottom.
Added concrete environment.
1 B2.1.17-5 3.3.2.1.19 Components will be considered gray cast iron. For components changed to gray cast iron, aging management of these components is assigned to B2.1.17, Selective Leaching of Materials program.
Affected 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, 3.3.2-27.
1 B2.1.17-5 3.3.2.1.20 Same as above 1
B2.1.17-5 3.3.2.1.22 Same as above NOC-AE-1 1002750 Page 2 of 84 Referenced RAI Affected Reason for Change Letter Number Section of LRA 1
B2.1.17-5 3.3.2.1.24 Same as above 1
B2.1.17-5 3.3.2.1.25 Same as above 1
B2.1.17-5 3.3.2.1.27 Same as above 1
B2.1.18-1 3.3.2.1.27 LRA Table 3.3.2-27 will be revised to remove these buried components. Revision also requires Section 3.3.2.1.27 to be revised to remove "buried" as an environment.
1 B2.1.20-5 3.4.2.1.6 Added concrete as an environment to manage loss of material from tank bottoms founded on concrete.
2 B2.1.3-3 Table LRA Table 2.3.1-1 revises component type of "RV 2.3.1-1 Closure Head Bolts" to "RV Closure Head Bolting Assemblies.
1 B2.1.20-5 Table 2.3.3-Added caulking and sealant as component types 17 that perform an intended function for management of loss of material from tank bottoms founded on concrete.
1 B2.1.20-5 Table Added concrete as a mechanical environment to be 3.0-1 evaluated for aging effects 2
B2.1.3-3 Table LRA Table 3.1.2-1 revises "RV Closure Head Bolts" 3.1.2-1 to "RV Closure Head Bolting Assemblies.
1 B2.1.17-5 Table Components will be considered gray cast iron. For 3.3.2-7 components that are changed to gray cast iron, aging management of these components was assigned to B2.1.17, Selective Leaching of Materials program. Affected 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, 3.3.2-27.
1 B2.1.17-5 Table Same as above.
3.3.2-9 1
B2.1.20-2 Table LRA Tables 3.3.2-11 and 3.3.2-12 will be revised to 3.3.2-11 specify AMP B2.1.22 for management of the internal surfaces of the supply HVAC tornado dampers for the Fuel Handling and Mechanical Auxiliary Buildings.
1 B2.1.20-2 Table Same as above 3.3.2-12 1
B2.1.17-5 Table Components will be considered gray cast iron. For 3.3.2-17 components that are changed to gray cast iron, aging management of these components was assigned to B2.1.17, Selective Leaching of Materials program. Affected 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, 3.3.2-27.
1 B2.1.20-5 Table LRA Table 3.3.2-17 will be revised to credit LRA NOC-AE-1 1002750 Page 3 of 84 Referenced RAI Affected Reason for Change Letter Number Section of LRA 3.3.2-17 Basis Document XI.M36 (B2.1.20) to manage hardening and loss of strength of the caulking around the FWST tank bottom 1
B2.1.17-5 Table Components will be considered gray cast iron. For 3.3.2-19 components that are changed to gray cast iron, aging management of these components was assigned to B2.1.17, Selective Leaching of Materials program. Affected 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, 3.3.2-27.
1 B2.1.17-5 Table Same as above 3.3.2-20 1
B2.1.17-5 Table Same as above 3.3.2-22 1
B2.1.17-5 Table Same as above 3.3.2-24 1
B2.1.17-5 Table Same as above 3.3.2-25 1
B2.1.17-5 Table Same as above 3.3.2-27 1
B2.1.18-1 Table LRA Table 3.3.2-27 revised to remove these buried 3.3.2-27 components due to previous submitted scope change.
1 B2.1.20-5 Table LRA Tables 3.3.2-17 and 3.4.2-6 revised to credit LRA 3.4.2-6 Basis Document XI.M38 (B2.1.20) to manage loss of material from tank bottoms founded on concrete. (See Note 1) 2 B3.1-3 Table The scope, corrective actions, and enhancements to 4.3-2 address Leak-Before-Break and ASME Section Xl fatigue crack growth analyses are revised to AMP B3.1. The Program Limiting Value for the High Head Safety Injection transient is revised.
1 B2.1.7-1 A.11.7 LRA Appendix B2.1.7 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. LRA Appendix A is revised to be consistent with the AMP.
1 B2.1.9-1 A1.9 LRA Appendices A1.9 and B2.1.9 revised to delete cracking as an aging effect in the Open Cycle Cooling Water program.
1 B2.1.13-1 A1.13 LRA Appendix Al.13 revised to 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.
NOC-AE-1 1002750 Page 4 of 84 Referenced RAI Affected Reason for Change Letter Number Section of LRA 1
B2.1.16-2 A1.16 LRA Appendix Al.16 revised as indicated in the response to the RAI to include one-time inspection component sample size, examination techniques, follow-up examinations, and program restrictions.
1 B2.1.17-3 A1.17 LRA Appendices A1.17 and B2.1.17 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.
1 B2.1.17-4 A1.17 LRA Appendices A1.17 and B2.1.17 revised to state that the selective leaching program will be implemented in the five-year period prior to the period of extended operation.
2 B2.1.19-1 A1.19 LRA Appendices A1.19 and B2.1.19 revised to include numbers of different joints in sample determination.
1 B2.1.20-1 A1.20 LRA Appendices A1.20, A1.22, B2.1.20, B2.1.22 revised to include physical manipulation of elastomers.
1 B2.1.20-3 A1.20 LRA Appendices A1.20 and B2.1.20 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.
1 B2.1.20-1 A1.22 LRA Appendices A1.20, A1.22, B2.1.20, B2.1.22 revised to include physical manipulation of elastomers.
1 B2.1.20-5 A1.22 LRA Appendices A1.22 and B2.1.22 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.
1 B2.1.22-1 A1.22 LRA Appendices A1.22 and B2.1.22 revised to remove reference to external surfaces of elastomers.
1 B2.1.22-3 A1.22 LRA Appendices A1.22 and B2.1.22 revised to include the requirement to manipulate at least 10 percent of available surface area for in-scope elastomers.
1 B2.1.22-4 A1.22 LRA Appendices A1.22 and B.2.1.22 revised to state that volumetric examination may be substituted for internal visual inspections in cases where internal surfaces are not available for visual inspection.
2 B3.1-3 A2.1 Changes are required to AMP B3.1 scope, corrective actions, and enhancements to address LBB and ASME Section XI fatigue crack growth analyses. Section A2.1 revised to be consistent with AMP change.
2 B2.1.3-1 A4-1 LRA Table A4-1 revised to include Commitment 38 NOC-AE-1 1002750 Page 5 of 84 Referenced RAI Affected Reason for Change Letter Number Section of LRA for procedure enhancement to preclude the use of replacement closure stud assemblies fabricated from material with a measured yield strength greater than or equal to 150 ksi 2
B2.1.3-1 B2.1.3 LRA Appendix B2.1.3 revised to preclude the use of replacement closure stud assemblies fabricated from material with a measured yield strength greater than or equal to 150 ksi.
1 B2.1.7-1 B2.11.7 LRA Appendix B2.11.7 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. Procedures will be enhanced to conform to the guidance contained in EPRI TR-104213. One minor editorial change made to the exception to Element 3.
1 B2.1.9-1 B2.1.9 LRA Appendices Al.9 and B2.11.9 revised to delete cracking as an aging effect in the Open Cycle Cooling Water program.
1 B2. 1.10-1 B2. 1.10 LRA Appendix B2.1.1 0 revised to require that representative samples of each combination of material and water treatment program be visually inspected at least every ten years or opportunistically when consistent with sample requirements.
1 B2.1.16-2 B2.1.16 LRA Appendix A1.16 revised as follows to include one-time inspection component sample size, examination techniques, follow-up examinations, and program restrictions.
1 B2.1.17-2 B2.1.17 LRA Appendix B2.1.17 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.
1 B2.1.17-3 B2.1.17 LRA Appendices Al.17 and B2.1.17 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.
1 B2.1.17-4 B2.1.17 LRA Appendices A1.17 and B2.1.17 revised to state that the selective leaching program will be implemented in the five-year period prior to the period of extended operation.
2 B2.1.19-1 B2.1.19 LRA Appendices A1.19 and B2.1.19 revised to include numbers of different joints in sample determination.
1 B2.1.20-3 B2.1.20 LRA Appendices Al.20 and B2.1.20 revised to require manipulation of at least 10 percent of the available surface area of elastomeric or polymeric materials to NOC-AE-1 1002750 Page 6 of 84 Referenced RAI Affected Reason for Change Letter Number Section of LRA confirm the absence of hardening or loss of strength.
1 B2.1.20-1 B2.1.20 LRA Appendices A1.20, A1.22, B2.1.20, B2.1.22 revised to include physical manipulation of elastomers.
1 B2.1.20-1 B2.1.22 LRA Appendices A1.20, A1.22, B2.1.20, B2.1.22 revised to include physical manipulation of elastomers.
1 B2.1.22-1 B2.1.22 LRA Appendix A1.22 and B2.1.22 revised to remove reference to external surfaces of elastomers.
1 B2.1.22-3 B2.1.22 LRA Appendices A1.22 and B2.1.22 revised to include the requirement to manipulate at least 10 percent of available surface area for in-scope elastomers.
1 B2.1.22-4 B2.1.22 LRA Appendices A1.22 and B.2.1.22 revised to state that volumetric examination may be substituted for internal visual inspections in cases where internal surfaces are not available for visual inspection.
1 B2.1.20-5 B2.1.22 LRA Appendices A1.22 and B2.1.22 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.
2 B3.1-1 B3.1 LRA Appendix B3.1 revised to clarify the corrective actions to be invoked if a component cycle counting action limit is reached and the corrective actions to be invoked if a CUF or CUFen action limit is reached.
2 B3.1-3 B3.1 LRA Appendix B3.1 revised to identify the increase in the scope of the program to ensure the fatigue crack growth analyses, which support the leak-before-break (LBB) analyses, remain valid by counting the transients used in the analyses.
2 B3.1-4 B3.1 LRA Appendix B3.1, the Section on Enhancements for Corrective Actions (Element 7) regarding when the CUE action limit is reached revised to clarify corrective actions if CUF limit is reached NOC-AE-1 1002750 Page 7 of 84 Note 1: An editorial error was noted in the response to RAI B2.1.20-5 in Reference 1. The last sentence in the STPNOC response under item 4 is revised to read:
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 20 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.
NOC-AE-1 1002750 Page 8 of 84 3.3.2.1.7 Compressed Air System Materials The materials of construction for the compressed air system component types are:
Carbon Steel Carbon Steel (Galvanized)
Copper Alloy Copper Alloy (> 15 percent Zinc)
Stainless Steel Stainless Steel Cast Austenitic 3.3.2.1.9 Chilled Water HVAC System Materials The materials of construction for the chilled water HVAC system component types are:
Carbon Steel Carbon Steel (Galvanized)
Copper Alloy Copper Alloy (> 15 percent Zinc)
Glass Stainless Steel Titanium South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 9 of 84 3.3.2.1.17 Fire Protection System Materials The materials of construction for the fire protection system component types are:
Aluminum Carbon Steel Carbon Steel (Galvanized)
Cast Iron Cast Iron (Gray Cast Iron)
Copper Alloy Ductile Iron Elastomer Stainless Steel Environment The fire protection system component types are exposed to the following environments:
Atmosphere/ Weather Buried Closed-Cycle Cooling Water Concrete Diesel Exhaust Dry Gas Encased in Concrete Fuel Oil Plant Indoor Air Raw Water Ventilation Atmosphere Aging Effects Requiring Management The following fire protection system aging effects require management:
Cracking Hardening and loss of material Loss of material South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 10 of 84 Loss of preload Reduction of heat transfer South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 11 of 84 3.3.2.1.19 Chemical and Volume Control System Materials The materials of construction for the chemical and volume control system component types are:
Aluminum Carbon Steel Cast Iron (Gray Cast Iron)
Copper Alloy Insulation Calcium Silicate Insulation Fiberglass Nickel Alloys Stainless Steel Stainless Steel Cast Austenitic Thermoplastics Environment The chemical and volume control system component types are exposed to the following environments:
Borated Water Leakage Closed-Cycle Cooling Water Demineralized Water Dry Gas Lubricating Oil Plant Indoor Air Reactor Coolant Secondary Water Steam Treated Borated Water Zinc Acetate South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 12 of 84 Aging Effects Requiring Management The following chemical and volume control system aging effects require management:
Cracking Loss of material Loss of preload Reduction of heat transfer Wall thinning Aging Management Programs The following aging management programs manage the aging effects for the chemical and volume control system component types:
ASME Section Xl Inservice Inspection, Subsections IWB, IWC, and IWD (B2.1.1)
Bolting Integrity (B2.1.7)
Closed-Cycle Cooling Water System (B2.1.10)
External Surfaces Monitoring Program (82.1.20)
Flow-Accelerated Corrosion (B2.1.6)
Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B2.1.22)
Lubricating Oil Analysis (B2.1.23)
One-Time Inspection (82.1.16)
One-Time Inspection of ASME Code Class 1 Small-Bore Piping (B2.1.19)
Selective Leachinq of Materials (B2.1.17)
Water Chemistry (B2.1.2)
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 13 of 84 3.3.2.1.20 Standby Diesel Generator and Auxiliaries System Materials The materials of construction for the standby diesel generator and auxiliaries system component types are:
Aluminum Carbon Steel Cast Iron (Gray Cast Iron)
Copper Alloy Glass Stainless Steel Titanium Environment The standby diesel generator and auxiliaries system component types are exposed to the following environments:
Closed-Cycle Cooling Water Diesel Exhaust Dry Gas Fuel Oil Lubricating Oil Plant Indoor Air Raw Water Aging Effects Requiring Management The following standby diesel generator and auxiliaries system aging effects require management:
Cracking Loss of material Loss of preload Reduction of heat transfer South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 14 of 84 Aging Management Programs The following aging management programs manage the aging effects for the standby diesel generator and auxiliaries system component types:
Bolting Integrity (B2.1.7)
Closed-Cycle Cooling Water System (B2.1.10)
External Surfaces Monitoring Program (B2.1.20)
Fuel Oil Chemistry (B2.1.14)
Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B2.1.22)
Lubricating Oil Analysis (B2.1.23)
One-Time Inspection (B2.1.16)
Open-Cycle Cooling Water System (B2.1.9)
Selective Leaching of Materials (B2.1.17)
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 15 of 84 3.3.2.1.22 Liquid Waste Processing System Materials The materials of construction for the liquid waste processing system component types are:
Carbon Steel Cast Iron (Gray Cast Iron)
Copper Alloy Glass Stainless Steel Stainless Steel Cast Austenitic Environment The liquid waste processing system component types are exposed to the following environments:
Borated Water Leakage Closed-Cycle Cooling Water Demineralized Water Dry Gas Plant Indoor Air Raw Water Secondary Water Sodium Hydroxide Steam Treated Borated Water Aging Effects Requiring Management The following liquid waste processing system aging effects require management:
Cracking Loss of material Loss of preload Wall thinning South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 16 of 84 Aging Management Programs The following aging management programs manage the aging effects for the liquid waste processing system component types:
Bolting Integrity (B2.1.7)
Boric Acid Corrosion (B2.1.4)
Closed-Cycle Cooling Water System (B2.1.10)
External Surfaces Monitoring Program (B2.1.20)
Flow-Accelerated Corrosion (B2.1.6)
Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B2.1.22)
One-Time Inspection (B2.1.16)
Selective Leaching of Materials (B2.1.17)
Water Chemistry (B2.1.2)
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 17 of 84 3.3.2.1.24 Nonradioactive Waste Plumbing Drains and Sump System Materials The materials of construction for the nonradioactive waste plumbing drains and sump system component types are:
Carbon Steel Carbon Steel (Galvanized)
Cast kron Cast Iron (Gray Cast Iron)
Copper Alloy Ductile Iron Polyvinyl Chloride (PVC)
Stainless Steel South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 18 of 84 3.3.2.1.25 Oily Waste System Materials The materials of construction for the oily waste system component types are:
Carbon Steel Carbon Steel (Galvanized)
Copper Alloy Ductile Iron Stainless Steel Environment The oily waste system component types are exposed to the following environments:
Buried Encased in Concrete Plant Indoor Air Raw Water Aging Effects Requiring Management The following oily waste system aging effect requires management:
Loss of material Loss of preload Aging Management Programs The following aging management programs manage the aging effects for the oily waste system component types:
Bolting Integrity (B2.1.7)
Buried Piping and Tanks Inspection (B2.1.18)
External Surfaces Monitoring Program (B2.1.20)
Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B2.1.22)
Selective Leachinq of Materials (B2.1.17)
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 19 of 84 3.3.2.1.27 Miscellaneous Systems In-Scope ONLY based on Criterion 10 CFR 54.4(a)(2)
Materials The materials of construction for the miscellaneous systems in scope ONLY based on Criterion 10 CFR 54.4(a)(2) component types are:
Aluminum Carbon Steel Cast Iron (Gray Cast Iron)
Copper Alloy Copper Alloy (Aluminum > 8 percent)
Copper Alloy (Zinc > 15 percent)
Ductile Iron Glass Nickel-Alloys Polyvinyl Chloride (PVC)
Stainless Steel Stainless Steel Cast Austenitic Environment The miscellaneous systems in scope ONLY based on Criterion 10 CFR 54.4(a)(2) component types are exposed to the following environments:
Atmosphere/ Weather Borated Water Leakage Closed-Cycle Cooling Water Demineralized Water Dry Gas Plant Indoor Air Potable Water Raw Water Secondary Water Sodium Hydroxide Treated Borated Water South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 20 of 84 Aging Effects Requiring Management The following miscellaneous systems in-scope ONLY based on Criterion 10 CFR 54.4(a)(2) aging effects require management:
0 Cracking 0
Loss of material Loss of preload 0
Wall thinning Aging Management Programs The following aging management programs manage the aging effects for the miscellaneous systems in scope ONLY based on Criterion 10 CFR 54.4(a)(2) component types:
Bolting Integrity (B2.1.7)
Buried Piping and Tanks Inpectin (B2,1.18)
Closed-Cycle Cooling Water System (B2.1.10)
External Surfaces Monitoring Program (B2.1.20)
Flow-Accelerated Corrosion (B2.1.6)
Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B2.1.22)
One-Time Inspection (B2.1.16)
Open-Cycle Cooling Water System (B2.1.9)
Selective Leaching of Aluminum Bronze (B2.1.37)
Selective Leaching of Materials (B2.1.17)
Water Chemistry (B2.1.2)
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 21 of 84 3.4.2.1.6 Auxiliary Feedwater System Environment The auxiliary feedwater system components are exposed to the following environments:
Atmosphere/ Weather Buried Concrete Dry Gas Encased in Concrete Lubricating Oil Plant Indoor Air Secondary Water Steam South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 22 of 84 Table 2.3.1-1 Reactor Vessel and Internals (Continued)
Component Type Intended Function RV Closure Head Pressure Boundary RV Closure Head Boltsin_
Assemblies Pressure Boundary RV Core Support Lugs Structural Support Table 2.3.3-17 Fire Protection System Component Type Intended Function Caulking and Sealant Pressure Boundary Closure Bolting Pressure Boundary
_LStructural Integ rity(att__hed )
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 23 of 84 Table 3.0-1 Mechanical Environments (Continued)
Mechanical Environments Evaluated Environment NUREG-1801 Environment Description Closed Cycle Cooling Water Closed Cycle Cooling Water Water for component cooling that is treated and monitored for quality Closed Cycle Cooling Water >60' C (140L F) under the Closed-Cycle Cooling Water System Program.
Treated Water Concrete Concrete Components, such as tanks, located directly on concrete, with inaccessible external surfaces, require inspection for loss of material due to corrosion.
Demineralized Water Treated Water Demineralized water or chemically purified water which is the source for water in all clean systems such as the primary or secondary coolant systems. Demineralized water is monitored for quality under the Water Chemistry program and depending on the system; demineralized water may require additional processing.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 24 of 84 Table 3.1.2-1 Reactor Vessel, Internals, and Reactor Coolant System - Summary of Aging Management Evaluation - Reactor Vessel and Internals (Continued)
Component Type Intended [Matra Environment Aging Effect [Aging Management NUREG-Table I Notes Function I
Requiring I.
Program
[1801 Vol.
I Item __
Management
[2ItemJ_
1PVI ( Inc " ira W-4 at!PR rnrhnn IPanrtrr (~n~innt Ii I ne f mntarini I AqKMF qratfin YI
'IVR A9-9r 11 1 1 AA A
RV Closure Head Bolteing
'Assemblies IRV Closure Head Boltsig Assemblies
'RV Closure Head BoltsinM
- Assemblies
!Steel with Stainless Steel oCladding PB i High Strength Low Alloy i Steel i (Bolting)
S HB igh I Strength i Low Alloy Steel
!P (l.B.ol~tin~g)_
IpB IHigh Strength Low Alloy Steel
- (Bolting)
I (Int)
Borated Water ILeakage (Ext)
Borated Water Leakage (Ext)
{Borated Water Leakage (Ext)
I II I I I
Inservice Inspection, Subsections IWB, IWC, and IWD (B2.1.1)
I Cracking S'Reactor Head Closure IV.A2-2 Studs (B2.1.3)
-- 3-..- 1 -.71 Loss of-material Reactor Head Closure IV.A2-3 Studs (B2.1.3)
Loss of material I Boric Acid Corrosion IV.A2-13 (B2.1.4) 3.1.1.71 3.1.1.58 B
TA South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 25 of 84 Table 3.1.2-1 Reactor Vessel, Internals, and Reactor Coolant System - Summary of Aging Management Evaluation - Reactor Vessel and Internals (Continued)
CopnetTyeIntended Material Environment Aging Effect Aging Management NUREG-Table I Notes RVComeuponet Te 1Function Requiring Program 1801 Vol.
Item Management 2 Item RV oreSuport SS Nickel Alloys Reactor Coolant 'Cracking Nickel-Alloy Aging IV.A2-1 2 3..'.1 E,1 Lugs
'(Ext)
Management (B2.11.37),
ASME Section XI Inservice Inspection
.Subsections IWB, IWC,
.and IWD (B2.1.1) for Class 1 components,
.Water Chemistry
((B2.1.2), and Comply
.with applicable NRC Orders and provide a commitment in the FSAR supplement to
.implement applicable (1) Bulletins and Generic Letters and (2) staff-accepted industry guidelines.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 26 of 84 f Air System NUREG-Table I Item 1801 Vol.
2 Item Notes Compressor
!Compressor Filter LBS LBS FIL, PB, SIA Cast Iron Lubricating Oil (Gray Cast (Int)
Iron)
Cast Iron Plant Indoor Air (Gray Cast (Ext)
Iron)
Carbon Plant Indoor Air Steel (Ext)
Loss of material I Inspection of Internal VII.D-2 Surfaces in
!Miscellaneous Piping
,and Ducting
.Components (B2-1.22)
Loss of material
,Lubricating Oil Analysis VIi.C2-13 i(B2.1.23) and One-Time Inspection (B2._
1..6)
Loss of material
'External Surfaces VII.I-8
- ,Monitoring Program
...B(B2.1.20)
Loss of material External Surfaces
'VII.l-8 Monitoring Program 1 (B2.1.20) 3.3.1.53 3.3.1.14 3.3.1.58 3.3.1.58 B
E, 2 T
i B.1 j
ýValve 1PB V-ale RPB South Texas Project License Renewal Application Amendment 7 iCarb6o-n.
Steel Cast Iron (Gray Cast J Iron).
!Plant Indoor Air i(Int)
-hLos-sof--m aterial-Inspectio n of In-ter-n.al Surfaces in Miscellaneous Piping land Ducting
,Components (B2.1.22)
Loss of material External Surfaces Monitoring Program (B2.-.20).
Loss of material Inspection of Internal VII. D-2 3.3.1.53 IE, 2 B
Plant Indoor Air
'(Ext)
.Plant Indoor Air (Int)
VII-1.IJ-8 13.3..
VI.G-23 3.3.1.71 Surfaces in Miscellaneous Piping
,and Ducting
!Components (1B2.1.22)
NOC-AE-1 1002750 Page 27 of 84 Valve PB, SIA Copper Alloy. Plant Indoor Air
.None (Ext)
None VIII.I-2 3.4.1.41 A
Table 3.3.2-9 Auxiliary Systems - Summary of Aging Management Evaluation - Chilled Water HVAC System Component Type Intended Material Environment Aging Effect IAging Management NUREG-Table I Notes Functi onni
_oo Requiring Program 11801 Vol. I Item
__________II______Management ______
Item Closure Bolting LBS, PB, 'Carbon Plant Indoor Air Loss of preload Bolting Integrity VlI.I_5
- 3.3.1.45 B
Compressor Compressor Eductor SIA
_Steel PB Cast Iron (Gray Cast Iron)
- PB Cast Iron
!(Gray Cast Iron) Cast SPB Copper Alloy
(>15% Zinc)
-(E xt)...............
Dry Gas (Int)
Plant Indoor Air (Ext)
Lubricating Oil (Int)
None Loss of material Loss of material (B2.1.7)
None External Surfaces Monitoring Program (B2.1..20)
Lubricating Oil Analysis (B2.1.23) and One-Time Inspection (132.1.16)
- B
- ....
6 )....
....... 1............
External Surfaces Monitoring Program (B2.11.20)
Closed-Cycle Cooling Water System
.(g2.1!0).
Selective Leaching of Materials (B2.1.17)
- Lubricating Oil Analysis (B2.1.23) and One-Time Inspection (B2.1.16)
VII.J-23 3.3.1.97 A
VII.I-8
.3.3.1.58 B
VII.C2-5
- 3.3.1.26 B
Pump Pump PumP Pump
- (Gray Cast I ron)
LBS Cast Iron
- (Gray Cast
.Iro n )
PB Cast Iron
'(Gray Cast Iron)
'Plant Indoor Air (Ext)
.Closed Cycle
!Cooling Water Closed Cycle Cooling Water (Int)
- Lubricating Oil
,(Int)
-Loss of material
.Loss of material Loss of material Loss of material VII.l-8
'3.3.1.58 B
VII. Q2-14.3.3.1.47 IB F2-18 VII.F2-16 13.3.1.85 1B V ii.c 2 - 3...........
VII.2-13 3.3.1.14 B
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 28 of 84 Pump Separator 7LBS, PB 7 5ast Iron -
P--1-nt Indoor Air Loss of material-Exiernal Surfaces I (Gray Cast (Ext)
'Monitoring Program Iron)
(B2.1.20) 1PB Stainless Dry Gas (Ext)
]Steel J
I I.I-8 13.3.1.58 EB VII.J-19 13.3.1.97 A
Table 3.3.2-11 Auxiliarv Systems - Summary of Acinc/ Manac/ement Evaluation - Fuel Handlina Buildinci HVAC System
,Component 1
,Intended Material Environment Aging Effect Aging Management NUREG-Table I I Notes IType JFunction Requiring Program J1801 Vol.1 I
j
.Management 2
2Item ]
i Closure Bolting PB I Damper
'PB Carbon Steel i Carbon Steel Plant Indoor Air (Ext)
Atmosphere/
Weather (Int)
Loss of materia Loss of materia I External Surfaces Monitoring Program
((B2.1.20) ilFI nspection of Internal I Surfaces in Miscellaneous Piping and Ducting Components (B2.1. 22)E--x-tea4 None VII.l-7
.3.3.1.55 1B VIII.1B1-6 VII.J-21 3.4.1.30 3..19 ID B
!~~~~~
~~
PB Carbon Steel Encased in None JConcrete (Ext)
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 29 of 84 Table 3.3.2-12 Auxiliary Systems - Summary of Aqinq Manaqement Evaluation - Mechanical Auxiliary Buildina HVAC System Component Intended Material Environment Aging Effect Aging Management NUREG-Table I Itm Notes Type Function Requiring I Program 1801 Vol.Itm Management 2Item Closure Bolting LBS, PB,
.PB Carbon Steel Carbon Steel Carbon Steel Plant Indoor Air (Ext)
Atmosphere/
Weather (Int)
Encased in Concrete (Ext)_
Loss of preload Tos sof-ma-erial.
[None Bolting Integrity (B2.1.7) VII.I-5
,3.3.1.45 B
I/Inspection of Internal VIII.B1-6 13.4.1.30 Surfaces in 9
- 3.
,3 48 Miscellaneous Pipina and Ducting Components (B2.1.22)E-xtem None VII.J-21 3.3.1.96 f
iv D
imB bDa'm -p e-r PB South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 30 of 84 Table 3.3.2-17 Auxiliary Systems - Summary of Aging Management Evaluation - Fire Protection System Component Intended 1Material Environment Aging Effect Aging Management NUREG-Table I Item Notes Type Function I11 Requiring I
Program 1801 Vol.
___ J ___ JManagement 2 2Item j_
'Caulking and Sealant IPB Elastomer Carbon Steel Atmosphere/
Weather (Ext)
Closure Bolting tPB Piping
'Piping Piping IPiping
[~n Pipng Pump Pump LBS, PB,
ýSIA 5PB carbon Stee (Galvanized Cast Iron (Gray Cast Iron)
Cast Iron (Gray Cast Iro_ )
Ductile Iron
)...
-At-mosph-ere....
Weather (Ext)
Raw Water (Int)
Plant Indoor Air (Ext)
Raw Water (Int)
- ,Hardening and loss of strength Loss of preload
- Loss of material Loss of material Loss of material External Surfaces None Monitoring Pro-gram (B2.1.20).....
Bolting Integrity (B2.17-)None-Fire Water System;
ýVII.G-24 (B2_1.13)
External Surfaces VII.1-8 Monitoring Program (B2_.1.20)
Fire Water System VII.G-24 (B2.1.13)
Selective Leaching of VII.G-14 Materials (B2.1.18)
Buried Piping and Tanks VIiLG-25 Inspection (B2.1.18) 3.3.1.68
-3.31.58 I3.3.1.68 None iG, 4 None H,
.P~7 Raw Water (Int)
Loss of material Buried (Ext)
Loss of material 3.3.1.85 3.3.1.19
ýB
!B
ýB B
B
'PB Stainless oSteel
- PB Cast Iron (Gray Cast
.....,Iro n)......
Plant Indoor Air (Ext)
Plant Indoor Air (Ext)
Raw Water (Int)
None
.Loss of material Loss of material External Surfaces Monitoring Program (P2.1..2-0)
Fire Water System (B2.1.13)
!VII.J-151 VI -
1-8 3.3.1.58 B
VIIG-24 3 3.1.68 B
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 31 of 84 PurnD JPB Cast Iron (Gray Cast Iron)
Ra Water (Int) i-Loss of material Selective Leaching of Materials (B2.1.17)
.VII.G-14 13.3.1.85
-B ---
] i Component Intended Material Environment Aging Effect Aging Management NUREG-TalIItm Notes Type fFunction 11Requiring Program 1801 Vol.
___J
]Management 2__
2Item Solenoid Valve PB Copper Alloy Atmosphere/
Weather (Ext)
Loss of material i
[Strainer Strainer
[ S-- - n e r-
[Strainer Strainer Element PB Carbon Steel (Galvanized)
PB, SIA Cast Iron (Gray Cast I ron).
B i
......i a t I o VPB, SIA Cast Iron I
'(Gray Cast
_____I Iron)
P Cast Iron (Gray Cast FlL f Copper Alloy Plant Indoor Air Loss of material (Int)
Plant Indoor Air Loss of material (Ext)
Raw Water (Int)
Loss of material Raw Water (Int)
Loss of material Raw Water (Ext)
I Loss of material Atmosphere/
i Loss of material Weather (Ext)
Concrete (Ext)
Loss of material External Surfaces Monitoring Program (B2.1.20)
,Inspection of Internal ISurfaces in
'Miscellaneous Piping
- and Ducting 0 om~ nents,(B2.1.22)
External Surfaces Monitoring Program
..(B2.1.20)
Fire Water System
((B2.1.13)
VII.G-23 3.3.1.71 None None VII.I-8 3.3.1.58 VII.G-24 B
-. B B
3.3.1.68 Selective Leaching of Materials (B2.1.17)
Fire Water System
_(B2.1.13)...
VII.G-14 13.3.1.85 VII.G-12
- 3.3.1.70 B
__ i.______
tank L___
1 PB Carbon Steel Carbon Steel
'External Surfaces VII.l-9 3.3.1.58 B
'Monitoring Program
((B2.1.20)
Inspection of Internal None None Surfaces in Miscellaneous Piping
,and Ducting
_ Components (B2.1.22) i South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 32 of 84 Tank IPB Carbon Steel Fuel Oil (Int)
Lioss of material Fuel Oil Chemistry i
(B2.1.14) and One-Time sp ection (B 2.1. 6),
VII.H2-24 3.3.1.20 B
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 33 of 84 Plant Specific Notes:
1 Loss of preload is conservatively considered to be applicable for all closure bolting.
2 The Fire Protection program (B2.1.12) is used to manage aging of the external surfaces of halon piping.
3 A visual inspection of the external surface of the bottom of tanks sitting directly on soil or concrete cannot be performed. A volumetric examination from the inside of the bottom of the tank is performed in lieu of an external inspection.
4 The External Surfaces Monitoring Program (B2.1.20) is used to manage the hardening and loss of strength of the caulking found between the firewater storage tank (FWST) bottom to concrete foundation interface to prevent water entry under the tank bottom.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 34 of 84 Table 3.3.2-19 Auxiliary Systems - Summary of Aging Management Evaluation - Chemical and Volume Control System Component Intended Material Environment Aging Effect Aging Management NUREG-Table I Item Notes Type Function Requiring Program 1801 Vol.
Management 2 Item Valve 1LBS, PB :Carbon Steel Plant Indoor Loss of material External Surfaces VII.I-8 3.3.1.58 B
Air (Ext)
Valve
!Valve I...
SI.A
.Cast Iron (Gray IL S
- Cast Iron)
LBS, SIA Cast Iron (Gray Cast Iron)
Closed Cycle Cooling Water (int)
Closed Cycle Cooling Water
.(Int)
Plant Indoor Air (Ext)
Monitoring Program
.(B2 1 0)..........
Selective Leaching of Materials (B2. 1.17)
Loss of material i
iVll.C2-8 3.3.1.85 B
Valve 1LBS, SIA ;Cast Iron (Gray
!Cast Iron)
Valve LBS, PB, Stainless Steel 1SIA Loss of material Closed-Cycle Cooling VII.C2-14
,Water System (21. 10)
Loss of material
'External Surfaces VII.l-8 Monitoring Program
((B2.1.20)
None
'None 1VII.J-16 T73-.3.1. 4 7-5 3 - i FW-3.3.1.58 B
Borated Water Leakage_(Ext)
[3.3.1.99 A
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 35 of 84 Table 3.3.2-20 Auxiliary Systems - Summary of Aging Management Evaluation - Standby Diesel Generator and Auxiliaries Component [Intended Material Environment Aging Effect 1 Aging Management NUREG-Table I Im Notes Type Function Requiring Program 1801 Vol.
.Management]
2 Item Accumulator Blower Blower
,HT PB Cast Iron (Gray Cast Iron)
Plant Indoor A (Ext)
[Closed Cycle-Cooling Water ir None None VII.J-15 3.3.1.94 Blower BTower HTPB Cast Iron (Gray Cast Iron)
SBlower PB Cast Iron Iron)
-ClosureBolting TLB sPB,-_
-Carbon Steel iSIA J
Closed Cycle Cooling Water Diesel Exhaus (Int)
-Pant Indoor Ai (Ext)
Plan-tIndoor A (Int) lant In.d.o.o.r Ai (Ext)
Loss of material (Int)
Loss of material (int) t Loss of material ir Loss of material ir Loss of material r
Loss of material Closed-Cycle Cooling VII.H2-23 3.3.1.47 Water System (B2.1.10)
Selective Leaching of
!VII.C2-8 3.3.1.85 Materials (B2.1.17)
Inspection of Internal iVII. H2-2 3.3.1.18 Surfaces in Miscellaneous Piping and Ducting Components (2.122L)
External Surfaces VII.I -8 3.3.1.58 Monitoring Program Inspection of Internal iVlI.H2-21 3.3.1.71 Surfaces in Miscellaneous Piping and Ducting Components (B2.1.22. )
Bolting Integrity (B2.1.7) VII1.I-4 13.3.1.43 B
DB B1 South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 36 of 84 Table 3.3.2-20 Auxiliary Systems - Summary of Aging Management Evaluation - Standby Diesel Generator and Auxiliaries Component Intended Material Environment Aging Effect Aging Management NUREG-Table I Item Notes Type Function Requiring Program 1801 Vol.
Management 2 Item Orifice Orifice Orifice iPB, SIA, Carbon Steel Plant Indoor Air TH (Ext)
I SIA lCast Iron Dry Gas (Int)
(Gray Cast Iron)
SIA cast Iron P Plant Indoor Air (Gray Cast (Ext)
!Lron)
LBS, SIA Stainless Close Cycle Steel Cooling Water j
(I )__..........
Loss of material I External Surfaces
!Monitoring Program (B2._1.20)
None VII.I-8
,3.3.1.58 INone VII.J-23 13.3.1.97 B
A B
Orifice Pump iPump
?PB Cast Iron (Gray Cast
'Iron)
PB ICast Iron (Gray Cast IIron) _.
SPB
'Cast Iron (Gray Cast
'Iron)
Plant Indoor Air (Ext)
Closed Cycle Cooling Water (Int)
Closed Cycle Cooling Water (Int)-- --
Plant Indoor Air (Ext)
Loss of materiaiWl mxternal Surfaces i Monitoring Program i(B2.1.20)
Loss of material Cosed-Cycle Cooling Water System (B2.1.10)
Loss of material --
External Surfaces Monitoring Program
_(B2.1.20)
Loss of material Closed-Cycle Cooling Water System (B2.1.10)
Loss of materia/l SelectiveLeaching of Materials (B2.1.17)
Loss of material i External Surfaces Monitoring Program J- (B2.1.20)
Loss of material !Lubricating Oil Analysis 1(B2.1.23) and One-Time
'Inspection (B2.1.16)
VII.I-8 3.3.1.58 VII.C2-10 3.3.1.50 B
VII.I-8 3.3.1.58 B
IVII.H2-23 13.3.1.47 VII.C2-8 3.3.1.85 VII.I-8 13.3.1.58 VII.H2-20 '3.3.1.14 B
B
!Lubricating Oil (Int)
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 37 of 84 Strainer Fb SteelPt I
rAir Loss of material External Surfaces (Ext)
Monitoring Program
[(B2.1.20)
!VI1. 1-8 a 33.1.58 B
... T....
- Strainer Strainer Strainer LBS, SIA
- Cast Iron Lubricating Oil Lossof material
-Lubricating Oil Analysis.
VII.H2-20.3.3.1.14
'(Gray Cast (Int)
I(B2.1.23) and One-Time
[Iron)
Inspection (B2.1.16) i LBS, SIA iCast Iron Plant Indoor Air Loss of material I External Surfaces iVII.l-8 3.3.1.58 SI(Gray Cast (Ext)
Monitoring Program
!Iron) 1 4(12 1-2 IFIL IStainless Lubricating Oi1 Loss of material Lubricating Oil Analysis II.H2-17 33,1.33 Steel (Ext)
(B2.1.23) and One-Time Iln.spection (B2._1.16) gB Valve
'Valve
'Valve PB fCarbon Steel Plant Indoor Air Loss of material
!i/I -.
kH L)
Inspection of Internal Surfaces in Miscellaneous
.Piping and Ducting PB Cast Iron (Gray Cast S PB ast Iron)
.;(Gray Cast PB
'Iron)
... P iB.........
C ast Iron...i (Gray Cast Iron)_ron Components (B2.1.22)
Dry Gas (Int)
None None Lubricating Oil Loss of material Lubricating Oil Analysis (Int)
(82.1.23) and One-Time Inspection (82.1.16)
Plant Indoor Air Lossof material External Surfaces (Ext) l Monitoring Program
_L__.
(12.1.20) 1__
-2 _
!VII.H2-21 3..1.71 VII.J-23 3.3.1.97 1VII.H2-20 33.1.14 A
B iVII. 1-8 3.3.1.58 B
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 38 of 84 Valve PB, SIA ICopperAlloy DryGas(Int).None o
VII.J-4 3.3.1.97 A
I _...
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 39 of 84 Table 3.3.2-22
-Pump.
LBk Pump
- LBB Pump
'LB-Pump LB Auxiliary Systems - Summay of Aginq Management Evaluation - Liquid Waste Processing System 3
1Carbon Steel Plant Indoor Air Loss of material-External Surfaces VII.1-8 3.3.1.58 (Ext)
Monitoring Program 3, SIA Cast Iron
!(Gray Cast Iron)
!Cast Iron
- (Gray Cast AIron).
Stainless ISteel Demineralized Loss of material Water (Int)
Demineralized Loss of material Water (Int)
Plant Indoor Air Loss of material (Ext)
Plant Indoor Air I None (Ext)
I Selective Leachinq of VII.E1-14 3.3.1.85 Materials (B2.1.17)
B B
Water Chemistry vIi.E-3i (B2.1.2) and One-Time Inspection (B2.1.16)
External Surfaces 1VII.I-8 Monitoring Program (B2.1.20).............
None
'VII.J-15 4
3.4.1.04 3.3.1.58 3.3.1.94 B
H South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 40 of 84 Table 3.3.2-24 Auxiliary Systems - Summary of Aging Management Evaluation - Nonradioactive Waste Plumbing and Sumps System Component Intended Material Environment Aging Effect 1Aging Management NUREG-Table I ItmNotes Type 1Function Requiring Program 1801 Vol.
Itm
___Management 2____
Iltem Piping
[i~ipng Piping Piping Piping
-Pi63 1n q Piping LBS, PB Carbon Steel (Galvanized)
!PB ICast Iron (Gray Cast
!LBS, PB Cast Iron
/ (Gray Cast PIron)
.iB-...... I'Cast Iron
-(Gray Cast Iron)
Raw Water (Int)
Encased in Concrete (Ext)
PIant In door, Air (Ext)
Plant Indoor Air (Int)
Raw Water (Int)
Loss of material None
[loss of material
' Loss of material
}Loss of material Inspection of Internal VII.C1-19 3.3.1.76 Surfaces in Miscellaneous Piping and Ducting Components (B2.1.22)-'
None
.VII.J-21 3.1.96 External Surfaces
- VII.I-8 13.3.1.58 Monitoring Program Inspection of Internal VIllG-23 13.3.1.71 Surfaces in Miscellaneous Piping I
and Ducting Components (B2.1.22) 1 Inspection of Internal -
VI1.C1-19 1-3i366 Surfaces in Miscellaneous Piping and Ducting Commponents (B2.1.22)
-2 Selective Leaching of VII.C1-11 3.31.8-5 Materials (B2.1.17)
E, 2
-A ttS Cast Iron (Gray Cast Iron)
B lB B
LBS
[Cast Iron
,(Gray Cast I ron)
LBS Polyvinyl Chloride (V).
Raw-ater(int)--]-Loss of Material PlIant Indoor Air'-
N-Ione (Ext)
L None
'None.
None.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 41 of 84 Valve IV v
I
[Valve Valve LBS 1PB Carbon Steel iRaw Water (Int)
PB Cast Iron (Gray Cast iCast Iron
.(Gray Cast Iron)
Copper Alloy Atmosphere/
Weather (Ext)
,Plant Indoor Air (Ext)
Plant Indoor Air (Int) i Plant Indoor Air I -(E 4 Y)_-
[Loss of material-tLoss of material
- Loss of material Loss of material None Inspection of Internal VI1.CI-19 J3.3.1.76 Surfaces in Miscellaneous Piping and Ducting Components (B2.1.22)
External Surfaces VII.I-9 Monitoring Program
((B2.1.20) i External Surfaces VII.I-8 Monitoring Program (B2.1.20)
Inspection of Internal VII.G-23 Surfaces in Miscellaneous Piping and Ducting Components (B2.1.22)
None.VIII.I-2 3.3.1.58 3.3.1.58 tff7fJ-1
'E, 2 B
A
~ii~
13.4.1.41 I
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 42 of 84 Table 3.3.2-25 Auxiliary Systems - Summary of Acqinq Manaqement Evaluation - Oily Waste System Component Intended Material Environmn Aging Effect Aging Management NUREG-Table I Item Notes Type Function I1Requiring Program 1801 Vol.
___ __ I__ _ _ ___
Management*
2 Item Piping Piping Piping Piping Piping PB Carbon Steel (Galvanized)
PB
!Cast Iron i(Gray Cast Jiron) 1PB Cast.Iron (Gray Cast
................ !Iro n )....
PB
-PB IStainless
..Steel.
Raw Water (Int)
Buried (Ext)
Loss of material Encased in Concrete (Ext)
Raw Water (Int)
Loss of material None Loss of material Loss of material Inspection of Internal Surfaces in Miscellaneous Piping
,and Ducting
-Components (B2.1.22)
Buried Piping and Tanks Inspection (B2.1.18)
- N n............
None Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B2.1.22)
,Selective Leaching of Materials (B2.1.17)
VIC1-18 I3.3*..19
.VI1.C1-19 3.3.1.76 E, 2 B
VII.J-21
.3.3.1.96 A
VII.C1-19 3.3.1.76 E, 2 VILC1-11 3.3.185 B
VII.J-15.3.3.1.94
- A
_______I Raw Water (Int)
Plant Indoor Air None (LEx None Piping I.-__-u~
1PB I1PB Stainless 1
Raw ater (Int)---Loss of--material
'Steel
!Cast Iron Raw Water (Ext)
Lioss iomaterial 1(Gray Cast i
- inspection of Internal V1.0C1-15 3.3.1.79 1E, 2
- Surfaces in Miscellaneous Piping land Ducting Components (B2.1.22)
.Externa* Surfaces VI1.C1-19 13.3.1.76 Monitoring Program (B 2.1.2 0)
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 43 of 84 Pum 1PB Cast Iron Raw Water (Ext)
Loss of material Selective Leaching of VII.C1-11 3.3.1.85 B
(Gray Cast Materials (B2.1.17)
I r o n )
Table 3.3.2-25 Auxiliary Systems - Summary of Aging Management Evaluation - Oily Waste System Requiring lanagement Program Pump PB
!Cast Iron (Gray Cast Ilron)
Loss of material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting CompOnents (1321.22)
Selective Leaching of Materials (B2.1.17)
VII.C1-19 PUMP PB Cast Iron (Gray Cast 1Iron)
Valve PB Copper Alloy Raw Water (Int)
'Loss of material
.V.I....
VI1.C1-1 1 13.3.1.85 VIII.I-2 13.4.1.41 o
'None B
A I Plant Indoor Air j(Ext)"
None South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 44 of 84 Table 3.3.2-27 Auxiliary Systems - Summary of Aging Management Evaluation - Miscellaneous Systems in scope ONLY for Criterion 10 CFR 54.4(a)(2)
Component Intended Material Environment Aging Effect Aging Management NUREG-Table I ItmNotes Type Function Requiring Program 11801 Vol.
Itm Management 2Item Piping Piping SIA ICarbon Steel Atmosphere/
I
ýWeather (Ext)
_§ibk
ýCarbon Ste~el Dry Gas (Int)
Loss of material Less of mAterial None External Surfaces VIII.H-8 3.4.1.28 Monitoring Program I(n2.1.20) i~~
Tn;pkRtVon HI-t D
B 1None VII.J-23
.3.13.97 A
Valve VaIveLValve SIA lCarbon Steel Atmosphere/
'Loss of material External Surfaces VIII.H-8 3.4.1.28
!Weather (Ext)
Monitoring Program IL4A L-eE-ef Buried Piping -and Tank=6l H4 A 22
..1.9 LBS, SIA ýCarbon Steel losed Cycle Loss of material Closed-Cycle Cooling
!V11.C2-14
.3.3.1.47
,Cooling Water (/nt)[
Water System (B2.1.10)
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 45 of 84 Table 3.3.2-27 Auxiliary Systems - Summary of Aging Management Evaluation - Miscellaneous Systems in scope ONLY for Criterion 10 CFR 54.4(a)(2)
Component Intended Material Environment Aging Effect Aging Management NUREG-Table I Item Notes Type Function Requiring I
Program 1801 Vol.
Management 2 Item Valve Valve Valve Valve Nav LBS Carbon Steel Secondary Water Plant Indoor Air (Ext)
Wall thinning LBS Cast Iron (Gray Cast
_ lron)
LBS Cast Iron I(Gray Cast Iron)
LBS Cast Iron (Gray Cast Iron)
Aloy IBS Copper Alloy Loss of material Potable Water (Int) Loss -f material Flow-Accelerated Corrosion((B2.1.6)
External Surfaces Monitoring Program (B2.120)
Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B2.1.22)
Selective Leaching of Materials (B2.1.17)
VIII.E-35 VI 1.1-8 3.3.1.58 3.4.1.29 B
None None Potable Water (Int) Loss of material i Non_.._*e iNone Plant Indoor Air (Ext__tt None None VIII.l-2 3.4.1.41 A
1 South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 46 of 84 Table 3.4.2-6 Steam and Power Conversion System - Summary of Aging Management Evaluation - Auxiliary Feedwater System Component Intended Material Environment Aging Effect jAging Management NUREG-TbeIIe Notes Type Function Requiring Program
- 1801V0, I
Tank StinlessManagement 2
__________*ItemI Tank PB Stainless Atmosphere/
None None None None G
Steel Weather (Ex t)
Tank IPB Stainless Concrete (Ext)
Loss of material ISnspection of Internal None None G 4 Steel Surfaces in Miscellaneous Piping and Ductinq Components (g2.1.22)
Tank TPB Stainless Dry Gas (Int)
'VIII.1-12 13.4.1.44 1A
,I J
I S t e e l -- -
Plant Specific Notes:
1 Loss of preload is conservatively considered to be applicable for all closure bolting.
2 The Water Chemistry program (B2.1.2) and the One-Time Inspection program (B2.1.16) manage loss of material due to pitting and crevice corrosion and cracking due to stress corrosion cracking. The One-Time Inspection program (B2.1.16) includes selected components at susceptible locations.
3 These items are assigned the environment of Atmosphere/ Weather (Internal). The items are vented or open to the outside atmosphere so the distinction between internal and external is not relevant for aging purposes.
These stainless steel components are located outside with an uncontrolled external air environment and are not exposed to aggressive chemical species. The STP plant outdoor environment is not subject to industry air pollution or saline environment.
Alternate wetting and drying has shown a tendency to "wash" the surface material rather than concentrate contaminants. Stainless steel does not experience any appreciable aging effects in this environment.
4 A visual inspection of the external surface of the bottom of tanks sitting directly on soil or concrete cannot be performed. A volumetric examination from the inside of the bottom of the tank is performed in lieu of an external inspection.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 45 of 84 Table 4.3-2 STP Units 1 and 2 Transient Cycle Count 60-year Projections Baseline Events Projected UFSAR Baseline Ent Events Transient Description Design Program Up to Year End 2008 for 60-Years Cycles Limiting value Unit I Unit 2 Unit I Unit 2 (1988-2008) (1989-2008)
- 37. Actuation of RCS Cold Over-pressurization 10 10 3
1 4
2 Mitigation System (COMS)
- 38. Normal Charging Letdown Shutoff and NS 60 7
18 16 54 Letdown Trip
- 39. Letdown Trip with Prompt Retum to NS 200 3
3 10 10 Service
- 40. Letdown Trip with Delayed Return to NS 20 3
0 9
1 Service
- 41. Charging Trip with Prompt Return to NS 20 10 0
15 1
Service
- 42. Charging Trip With Delayed Retum to NS 20 0
0 1
1 Service Test Conditions
- 43. Primary Side 10 1
1 1
1
_1 Hydrostatic Test
- 44. Secondary Side Hydrostatic Test 10 10 1
1 1
1 (each generator)
Auxiliary Conditions -Accumulator Safety Injections
- 45. Inadvertent RCS Depressurization with NS 20 0
0 1
1 H HSI
- 46. Inadvertent Accumulator NS 4
0 0
1 1
Blowdown
- 47. RHR Operation NS 200 44 27 89 76
- 48. High Head Safety NS 6448 1
0 3
Injection 4_88 1
0 3_
1 South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 46 of 84 A1.7 BOLTING INTEGRITY The Bolting Integrity program manages cracking, loss of material, and loss of preload for pressure retaining bolting and ASME component support bolting. The program includes preload control, selection of bolting material, use of lubricants/sealants consistent with EPRI NP-5067, Good Bolting Practices, and performance of periodic inspections for indication of aging effects.
The program also includes inservice inspection requirements established in accordance with ASME Section Xl, Subsections IWB, IWC, IWD, and IWF for ASME Class bolting.
STP good bolting practices are established in accordance with plant procedures. These procedures include requirements for proper disassembling, inspecting, and assembling of connections with threaded fasteners. In addition to the inspection activities noted above, the Bolting Integrity program includes activities for preload control, material selection and control, and use of lubricants/sealants. The general practices that are established in this program are consistent with EPRI TR-1 04213, Bolted Joint Maintenance and Applications Guide, EPRI NP-5769, Degradation and Failure of Bolting in Nuclear Power Plants, Volume 1 and 2, and the recommendations delineated in NUREG-1339.
AI.9 OPEN-CYCLE COOLING WATER SYSTEM The Open-Cycle Cooling Water System program manages eraeking, loss of material, and reduction of heat transfer for components within the scope of license renewal and exposed to the raw water of the essential cooling water system. Included are components of the essential cooling water system that are within the scope of license renewal, the component cooling water heat exchangers and the other safety related heat exchangers cooled by the essential cooling water system. The program includes chemical treatment and control of biofouling, periodic inspections, flushes and physical and chemical cleaning, and heat exchanger performance testing/inspections to ensure that the effects of aging will be managed during the period of extended operation. The program is consistent with STP commitments as established in responses to NRC Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Components.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 47 of 84 A1.13 FIRE WATER SYSTEM The Fire Water System program manages loss of material for water-based fire protection systems consisting of piping, fittings, valves, sprinklers, nozzles, hydrants, hose stations, standpipes and water storage tanks. Periodic hydrant inspections, fire main flushing, sprinkler inspections, and flow tests in accordance with National Fire Protection Association (NFPA) codes and standards ensure that the water-based fire protection systems are capable of performing their intended function. The fire water system pressure is continuously monitored such that loss of system pressure is immediately detected and corrective actions are initiated.
The Fire Water System program conducts an air or water flow test through each open head spray/sprinkler nozzle to verify the flow is unobstructed. The program 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. Non-intrusive volumetric examinations will be performed on representative samples of fire water piping to detect any loss of material due to corrosion, to ensure that aging effects are managed, wall thickness is within acceptable limits and degradation will be detected before the loss of intended function.
Otherwise, internal inspections are used to evaluate wall thickness to identify evidence of loss of material.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 48 of 84 A1.16 ONE-TIME INSPECTION The One-Time Inspection program conducts one-time inspections of plant system piping and components to verify the effectiveness of the Water Chemistry program (A1.2), Fuel Oil Chemistry program (A1.14), and Lubricating Oil Analysis program (A1.23). 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 based on the nmbeF population of components in a group sharing the same material, environment and aging 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, condition and operating 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. Inspoc"tiOns perFormond by other activities may be used if they satisfy the requr*ement*oFte the OTI pFegarm. The One-Time Inspection program specifies corrective actions 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, environmental, and aging combination that 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.
AI.17 SELECTIVE LEACHING OF MATERIALS The Selective Leaching of Materials program manages loss of material due to selective leaching for copper alloys with greater than 15 percent zinc and gray cast iron components exposed to treated water, raw water, and groundwater (buried) within the scope of license renewal.
The Selective Leaching of Materials program will be implemented during the 4-0 five years prior to the period of extended operation. The procedure will include a one-time inspection of a sample of components made from gray cast iron and copper alloys with greater than 15 percent zinc. This procedure will provide for visual and mechanical inspections for each system/material/environment combination, with exception of buried fire water piping. Aan engineering evaluation is performed if graphitization of gray cast iron or dezincification of copper alloy with greater than 15 percent zinc components is detected.
Flow testing of the fire miscoitetwith NF=PA 25, is credited for mnanagement of selective leaching of the buried cas t irn vles in the fire protection system.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 49 of 84 A1.19 ONE-TIME INSPECTION OF ASME CODE CLASS I SMALL-BORE PIPING The One-Time Inspection of ASME Code Class 1 Small-Bore Piping program manages cracking of ASME Code Class 1 piping less than or equal to four inches nominal pipe size (NPS 4). This program is implemented as part of the fourth interval of the STP Inservice Inspection (ISI) program.
For ASME Code Class 1 small-bore piping, the ISI program requires volumetric examinations on selected butt weld locations to detect cracking. Weld locations are selected based on the guidelines provided In EPRI TR-1 12657, Revised Risk-Informed Inservice Inspection Evaluation Procedure. Volumetric examinations of butt welds are conducted in accordance with ASME Section Xl with acceptance criteria from Paragraph IWB-3000 and IWB-2430. Unit 1 has 182 Class 1 small-bore butt welds and 49 Class 1 small-bore socket welds. The inspection sample for the Unit 1 Class 1 small-bore butt welds is 19 and the inspection sample for the Unit 1 Class 1 small-bore socket welds is 5, which is 10 percent of each population. In Unit 2, there are 190 Class 1 small-bore butt welds and 59 Class 1 small-bore socket welds. The inspection sample size for the Unit 2 Class 1 small-bore butt welds is 19 and the inspection sample size for Unit 2 Class 1 small-bore socket welds is 6, which is 10 percent for each population. if no socket welds aro in the sample population, then at least ten percent of the socket welds in eacdh 'unitt will11 be selected, up to a maximum of 25.
Socket welds that fall within the weld examination sample will be examined following ASME Section Xl Code requirements. If a qualified volumetric examination procedure for socket welds endorsed by the industry and the NRC is available and incorporated into the ASME Section Xl Code at the time of STP small-bore socket weld inspections, then this will be used for the volumetric examinations. If no volumetric examination procedure for ASME Code Class 1 small bore socket welds has been endorsed by the industry and the NRC and incorporated into ASME Section Xl at the time STP performs inspections of small-bore piping, a plant procedure for volumetric examination of ASME Code Class 1 small-bore piping with socket welds will be used.
The One-Time Inspection of ASME Code Class 1 Small-Bore Piping program is a new program and inspections will be completed and evaluated within six years prior to the period of extended operation.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 50 of 84 AI.20 EXTERNAL SURFACES MONITORING PROGRAM The External Surfaces Monitoring program manages loss of material for external surfaces of steel, stainless steel, aluminum, copper alloy components and elastomers, including protective paints, coatings, caulking, and sealants. The program also manages hardening and loss of strength for elastomers. The program includes those systems and components within the scope of license renewal that require external surface monitoring. Visual inspections of external surfaces conducted during engineering walkdowns will be used to identify aging effects and leakage. When appropriate for the component configuration and material, physical manipulation of at least 10 percent of the available surface area may-will be used to augment visual inspection to confirm the absence of elastomer hardening and loss of strength.
Loss of material for external surfaces is managed by the Boric Acid Corrosion program (A1.4) for components in a system with treated borated water or reactor coolant environment on which boric acid corrosion may occur, Buried Piping and Tanks Inspection program (A1.8) for buried components, and Structures Monitoring Program (A1.32) for civil structures, and other structural items which support and contain mechanical and electrical components.
The External Surfaces Monitoring program is a new program that will be implemented prior to the period of extended operation. Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 51 of 84 AI.22 INSPECTION OF INTERNAL SURFACES IN MISCELLANEOUS PIPING AND DUCTING COMPONENTS The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program manages cracking, loss of material, and hardening and loss of strength of the internal surfaces of piping, piping components, ducting, tanks and other components that are not inspected by other aging management programs.
The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program is a new program that uses the work control process for preventive maintenance and surveillance to conduct and document inspections. The program performs visual inspections to detect aging effects that could result in a loss of component intended function. Visual inspections of internal surfaces of plant components are performed by qualified personnel during the conduct of periodic maintenance, predictive maintenance, surveillance testing, and corrective maintenance. Supplemental inspections not performed concurrently with planned work activities will be performed. The locations and intervals for these supplemental inspections are based on assessments of the likelihood of significant degradation and on current industry and plant-specific operating experience.
Additionally, visual inspections may will be augmented by physical manipulation of at least 10 percent of available surface area of elastomers within the scope of the program, when appropriate for the component configuration and material, to detect hardening and loss of strength of beth-internal and exteMal surfaces of elastomersT* In cases where internal surfaces are not available for visual inspection, an internal visual inspection may be substituted with a volumetric examination. The program includes volumetric examination of the tank bottoms of the auxiliary feedwater storage tanks and the firewater storage tanks from inside the tanks to confirm the absence of loss of material due to corrosion. The program also includes and by volumetric evaluation to detect stress corrosion cracking of the internal surfaces of stainless steel components exposed to diesel exhaust.
The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program will be implemented prior to the period of extended operation. Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 52 of 84 A2
SUMMARY
DESCRIPTIONS OF TIME-LIMITED AGING ANALYSIS AGING MANAGEMENT PROGRAMS A2.1 METAL FATIGUE OF REACTOR COOLANT PRESSURE BOUNDARY The Metal Fatigue of Reactor Coolant Pressure Boundary program manages fatigue cracking caused by anticipated cyclic strains in metal components of the reactor coolant pressure boundary. The program ensures that actual plant experience remains bounded by the transients assumed in the design calculations and fatigque crack -qrowth analyses, or that appropriate corrective actions maintain the design and licensing basis by other acceptable means. The program tracks the number of transient cycles and cumulative fatigue usage at monitored locations. If a cycle count or cumulative usage factor value increases to a program action limit, corrective actions will be initiated to evaluate the design limits and determine appropriate specific corrective actions. Action limits permit completion of corrective actions before the design basis number of events is exceeded.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 53 of 84 B2.1.3 Reactor Head Closure Studs Program Description The Reactor Head Closure Studs program manages cracking and loss of material by conducting ASME Section Xl inspections of reactor vessel flange stud hole threads, reactor head closure studs, nuts, washers, and bushings. The program includes periodic visual, surface, and volumetric examinations of reactor vessel flange stud hole threads, reactor head closure studs, nuts, washers, and bushings and performs visual inspections of the reactor vessel flange closure during primary system leakage tests. The STP program implements ASME Section Xl code, Subsection IWB, 2004 Edition. Reactor vessel flange stud hole threads, reactor head closure studs, nuts, washers, and bushings are identified in ASME Section Xl Tables IWB-2500-1 and are within the scope of license renewal. The program implements recommendations in NUREG-1 339 and NRC Regulatory Guide 1.65, Material and Inspection for Reactor Vessel Closure Studs, to address reactor head stud bolting degradation except for yield strength of existing bolting materials. STP uses lubricants on reactor head closure stud threads after reactor head closure stud, nut, and washer cleaning and examinations are complete. The lubricants are compatible with the stud material and operating environment and do not include MoS 2 which is a potential contributor to stress corrosion cracking.
In conformance with 10 CFR 50.55a(g)(4)(ii), the STP ISI Program is updated during each successive 120-month inspection interval to comply with the requirements of the latest edition of the Code specified twelve months before the start of the inspection interval. STP will use the ASME Code Edition consistent with the provisions of 10 CFR 50.55a during the period of extended operation.
Potential cracking and loss of material conditions in reactor vessel flange stud hole threads, reactor head closure studs, nuts, washers, and bushings are detected through visual, surface, or volumetric examinations in accordance with ASME Section Xl requirements in STP procedures every ten years. These inspections are conducted during refueling outages.
Reactor vessel studs are removed from the reactor vessel flange each refueling outage. Studs, nuts, washers, and bushings are stored in protective racks after removal. Reactor vessel flange holes are plugged with water tight plugs during cavity flooding. These methods assure the holes, studs, nuts, washers, and bushings are protected from borated water during cavity flooding. Reactor vessel flange leakage is detected prior to reactor startup during reactor coolant system pressure testing each refueling outage. The STP program has proven to be effective in preventing and detecting potential aging effects of reactor vessel flange stud hole threads, closure studs, nuts, washers, and bushings.
NUREG-1801 Consistency The Reactor Head Closure Studs program is an existing program that is consistent, with exception to NUREG-1801,Section XI.M3, Reactor Head Closure Studs.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 54 of 84 Exceptions to NUREG-1801 Progqram Elements Affected:
Scope of Program (Element 1)
Regulatory Guide 1.65 states that the ultimate tensile strength of stud bolting material should not exceed 170 ksi. One closure head insert has a tensile strength of 174.5 ksi. 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 B-G-1 requirements, as the basis for managing cracking in these components. This is in accordance with the "parameters monitored or inspected" and "detection of aging effects" program elements in NUREG 1801,Section XI.M3. In addition, the studs, nuts and washers are coated with a lubricant which is compatible with the stud materials, and the studs, nuts, and washers are protected from exposure to boric acid by removing them and plugging the reactor vessel flange holes during cavity flooding. Replacement reactor head closure bolting obtained in the future (not currently installed or on site as spare parts) will be fabricated from material with an actual measured yield strength less than 150 ksi.
Corrective Actions (Element 7)
NUREG-1 801,Section XI.M3 specifies the use of Regulatory Guide 1.65 requirements for closure stud and nut material. STP uses SA-540, Grade B-24 (as modified by Code Case 1605) stud material. 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.
Enhancements Scope of Program (Element 1)None Procedures will be enhanced to preclude future use of replacement closure stud assemblies fabricated from material with an actual measured yield strength greater than or equal to 150 ksi.
The use of currently installed components and any spare components currently on site is allowed.
Operating Experience Review of plant-specific operating experience has not revealed any program adequacy issues with the Reactor Head Closure Studs program for reactor vessel closure studs, nuts, washers, bushings, and flange thread holes. No cases of cracking due to SCC or IGSCC have been identified with STP reactor vessel studs, nuts, washers, bushings, and flange stud holes.
Review of the Refueling Outage Inservice Inspection Summary Reports for Interval 2 indicates there were no repair/replacement items identified with reactor vessel closure studs, nuts, washers, bushings, or flange thread holes. None of the repair/replacement items indicate any implementation issues with the STP ASME Section Xl Program for reactor closure studs, nuts, washers, bushings, or flange thread holes.
The ISI Program at STP is updated to account for industry operating experience. ASME Section Xl is also revised every three years and addenda issued in the interim, which allows the code to be updated to reflect operating experience. The requirement to update the ISI Program South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 55 of 84 to reference more recent editions of ASME Section Xl at the end of each inspection interval ensures the ISI Program reflects enhancements due to operating experience that have been incorporated into ASME Section X1.
Conclusion The continued implementation of the Reactor Head Closure Studs program provides reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 56 of 84 B2.1.7 Bolting Integrity Program Description The Bolting Integrity program manages cracking, loss of material, and loss of preload for pressure retaining bolting and ASME component support bolting. The program includes preload control, selection of bolting material, use of lubricants/sealants consistent with EPRI NP-5067, Good Bolting Practices, and performance of periodic inspections for indication of aging effects.
The program also includes inservice inspection requirements established in accordance with ASME Section Xl, Subsections IWB, IWC, IWD, and IWF for ASME Class bolting.
STP good bolting practices are established in accordance with plant procedures. These procedures include requirements for proper disassembling, inspecting, and assembling of connections with threaded fasteners. In addition to the inspection activities noted above, the Bolting Integrity program includes activities for preload control, material selection and control, and use of lubricants/sealants. The general practices that are established in this program are consistent with EPRI TR-1 04213, Bolted Joint Maintenance and Applications Guide, EPRI NP-5769, Degradation and Failure of Bolting in Nuclear Power Plants, Volumes 1 and 2, and the recommendations delineated in NUREG-1339.
Following the review of the recommendations provided in NRC Geneiric Letter 91 17-,
NUREG 1339 and the EPRI reports, NP 5769 and NP 5067, STDP had identified and i mplemented the action items related to bolting degradation or failure. The guidance provided i EPRI NP 5067 and NUREG 1339, together with other industrial experience regarding bolting i ssues, was consolidated in EPRI TR 101213, Bolted Joint Maintonanco and Appliations G-"'o. Although the procedures for ensuring belting integrity do not directly reference EPRI TR 101213 rthrýey do reference EPRI NP 5769, EPRI 5067 and NUREG 1339. Implementation oe therecmmedatonsinEPRI NP 5067, EPRI NP 5769 and NUREG 1339 is, considered to be consistent with the recommnendations in EPRI T-R-101213.
The following STP aging management programs supplement the Bolting Integrity program with management of loss of preload, cracking, and loss of material:
(a) ASME Section Xl Inservice Inspection, Subsections IWB, IWC and IWD (B2.1.1) provides the requirements for inservice inspection of ASME Class 1, 2, and 3 safety-related pressure retaining bolting.
(b) ASME Section Xl, Subsection IWF (B2.1.29) provides the requirements for inservice inspection of safety-related component support bolting.
(c) External Surfaces Monitoring Program (B2.1.20) provides the requirements for inspection of pressure boundary closure bolting within the scope of license renewal.
(d) Structures Monitoring Program (B2.1.32) provides the requirements for inspection of structural bolting.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 57 of 84 NUREG-1801 Consistency The Bolting Integrity program is an existing program, that following enhancement, will be consistent, with exception to NUREG-1801,Section XI.M18, Bolting Integrity.
Exceptions to NUREG-1801 Program Elements Affected:
Scopo Of Pra gram (Element 1)
NUREG 1801 references EPRI TR 104213 as the indust3y's technical basis for the program assoGiated with neosafety related bolting. The bolted jeouint prcedure fco eonnurig boting ntegFrity idetifies preload requiroments and general pnaratmees fo in Scope botinsg but does not directiY referengc EpRR TR 1 t01213 as an applicable Soufre doluent fog these recommendatiens. However, this prcen durien dssrefoenoe and incrporate the good bolting practices identified in EEPRI NIP-50-67, ERPI 5769 and NUREG 1339. EPRI NP 5769 is very losely related with EPRI TeR 104213. Implementatioe of the i
cu ommendations in EPRI NP 5067 and EPRI NP 5769 and NUREGs t139 insconsidered to be
-consstent with the recsommendatens ion EPRI TR 101213 to meet NUREG 1801 reqtuiebents.
Parameters Monitored or Inspected (Element 3)
NUREG-1 801 states that bolting for safety-related pressure retaining components is inspected for loss of preload/loss of prestress. Loss of preload is net a parameter of inspection for the STP Bolting Integrity program. Atr STP, the application of good belting techniques provided in plant procedures and vendor instructions during assembly of bolted joints minimizes the possibility for a loss of preload/loss of prestress. The discussion of bolt preload in EPRI NP-5769, Vol. 2, Section 10, indicates that job inspection torque is non-conservative since for a given fastener tension more torque is required to restart the installed bolts. The techniques for measuring the amount of bolt tension in an assembled joint are both difficult and unreliable.
Inspection of preload is usually unnecessary if the installation method has been carefully followed. Torque values are provided in plant procedure if not provided by the vendor instructions, design documents or specifications. These torque values are based on the industrial experience that includes the consideration of the expected relaxation of the fasteners over the life of the joint and gasket stress in the application of pressure closure bolting.
Additionally, visual inspections for leakage would detect a loss of preload/loss of prestress in the connection prior to a loss of intended function.
Monitoring and Trending (Element 5)
NUREG-1 801,Section XI.M18 specifies that if bolting connections for pressure retaining components (not covered by ASME Section XI) are reported to be leaking, then they may be inspected daily. If the leak rate does not increase, the inspection frequency may be decreased to biweekly or weekly. STP procedures require the inspection frequency be adjusted as necessary based on the trending of inspection results to ensure there is not a loss of intended function between inspection intervals. For pressure retaining components reported to be leaking, STP procedures initiate the site corrective action process. Consideration is also given to adequate frequency of subsequent inspections to ensure the inspection interval is adequate to detect further aging degradation so that a loss of intended function is avoided.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 58 of 84 Enhancements Prior to the period of extended operation, the following enhancements will be implemented in the following program element:
Scope (Element 1)
Procedures will be enhanced to conform to the guidance contained in EPRI TR-104213.
Corrective Actions (Element 7)
Procedures will be enhanced to evaluate loss of preload of the joint connection, including bolt stress, gasket stress, flange alignment, and operating condition to determine the corrective actions consistent with EPRI TR-104213.
Operating Experience Both the industry and NRC have revealed a number of instances of bolting concerns from material control and certification (e.g. NRC Bulletin 87-02) to bolting practices, use of lubrication and injection sealants and its effect on SCC (e.g., NRC Bulletin 82-02, and INPO SOER 84-05).
The Bolting Integrity program incorporates the applicable industry experience on bolting issues into the program. Actions taken include confirmatory testing/analysis or inspections. Also included are the addition of procedures of inspection, material procurement and verification processes. NRC Information Notices, Bulletins, Circulars, and Generic Letters listed in Section 3 of NUREG-1 339 were evaluated for applicability to the STP Bolting Integrity program to ensure conformance with the recommendations of NUREG-1 339.
There is no reported case of cracking of bolting due to stress corrosion cracking.
A review of operating experience contained in STP condition reports (CRs) were evaluated for aging effects associated with the Bolting Integrity program. Of these CRs only 19 were determined to have applicable aging effects associated with the Bolting Integrity program. The following is a summary of the aging effects reported in these CRs.
Condensation has been observed to cause surface corrosion of bolting associated with chilled water bolted connections. The instances were evaluated and it was determined that the corrosion was limited to the surface and did not affect the integrity of the bolted joint. To prevent this corrosion from reoccurring the bolting was either painted to prevent water droplets coming in direct contact with carbon steel bolting or insulation was installed to prevent the cool surface temperatures from creating the condensation.
Leakage from fittings and pump mechanical seals has also caused corrosion of bolting when the leaking system fluid came in contact with bolting. The bolting was evaluated for each joint and replaced where required.
Boric acid accumulations have been observed on bolting. After the boric acid accumulations were removed the bolting was evaluated. The bolting was determined to be acceptable as found or replaced if the bolting material was degraded by boric acid corrosion.
Incorrect materials have been found in bolting connections during system walkdowns and inspections. The bolting was replaced with the correct material.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 59 of 84 Conclusion The continued implementation of the Bolting Integrity program provides reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 60 of 84 B2.1.9 Open-Cycle Cooling Water System Program Description The Open-Cycle Cooling Water (OCCW) System program manages iarakiing, loss of material, and reduction of heat transfer for components in scope of license renewal and exposed to the raw water of the essential cooling water (ECW) and essential cooling water screen wash system. The program includes surveillance techniques and control techniques to manage aging effects caused by biofouling, corrosion, erosion, protective coating failures and silting in components of the ECW system, and structures and components serviced by the ECW system, that are in scope of license renewal. The program also includes periodic inspections to monitor aging effects on the OCCW structures, systems and components, component cooling water heat exchanger performance testing, and inspections of the other safety related heat exchangers cooled by the ECW System, to ensure that the effects of aging on OCCW components are adequately managed for the period of extended operation. Components within the scope of the OCCW System program are: 1) components of the ECW system that are in scope of license renewal and 2) the safety-related heat exchangers cooled by the ECW system:
component cooling water heat exchangers, diesel generator jacket water heat exchangers, diesel generator lube oil coolers, diesel generator intercoolers, essential chiller condensers, and component cooling water pump supplementary coolers. The program is consistent with STPNOC commitments established in responses to NRC Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Components.
The surveillance techniques utilized in the Open-Cycle Cooling Water System program include visual inspection with thermal and hydraulic performance monitoring of heat exchangers. The control techniques utilized in the Open-Cycle Cooling Water System program include (1) water chemistry controls to mitigate the potential for the development of aggressive cooling water conditions, (2) flushes and (3) physical and/or chemical cleaning of heat exchangers and of the ECW pump suction bay to remove fouling and to reduce the potential sources of fouling.
Additional measures used to manage loss of material due to selective leaching for aluminum bronze components in the ECW system are detailed in the plant-specific aging management program Selective Leaching of Aluminum Bronze (B2.1.37).
NUREG-1801 Consistency The Open-Cycle Cooling Water System program is an existing program that, following enhancement, will be consistent with exception to NUREG-1801,Section XI.M20, Open-Cycle Cooling Water System.
Exceptions to NUREG-1801 Program Elements Affected:
Preventive Actions (Element 2), Parameters Monitored or Inspected (Element 3), Detection of Aging Effects (Element 4)
NUREG-1801,Section XI.M20, Elements 2, 3 and 4, provide for a program of flushing and inspection to confirm that fouling and degradation of surfaces is not occurring. An exception is taken to flushing the ECW train cross-tie dead legs and inspecting the interior of these lines.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 61 of 84 Instead, the external surfaces of the cross-tie lines are included in the six month dealloying visual external inspection walkdowns. The cross-tie valves and piping are also included in the essential cooling water system inservice pressure test, which includes VT-2 inspections of these components. Measures used to manage loss of material due to selective leaching are detailed in the Selective Leaching of Aluminum Bronze program (B2.1.37). These inspections and tests provide confidence in the ability to detect leakage in the piping and valves. The cross-tie lines do not have an intended function and are not required for any accident scenario within the design basis of the plant. The cross-tie valves are maintained locked closed.
Enhancements Prior to the period of extended operation, the following enhancements will be implemented in the following program elements:
Parameters Monitored or Inspected (Element 3) and Detection of Aging Effects (Element 4)
Procedures will be enhanced to include visual inspection of the strainer inlet area and the interior surfaces of the adjacent upstream and downstream piping. Material wastage, dimensional change, discoloration, and discontinuities in surface texture will be identified.
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. Procedures will also be enhanced to include the acceptance criteria for this visual inspection.
Operating Experience Industry operating experience evaluations, Maintenance Rule Periodic Assessments, and OCCW component performance testing results have shown that the effects of aging are being adequately managed.
A review of the STP plant specific operating experience indicates that macrofouling, general corrosion, erosion corrosion, and through-wall de-alloying have been observed in aluminum bronze components. STP has analyzed the effects of the through-wall de-alloying and found that the degradation is slow so that rapid or catastrophic failure is not a consideration, and determined that the leakage can be detected before the flaw reaches a limiting size that would affect the intended functions of the essential cooling water and essential cooling water screen wash system. A long range improvement plan and engineering evaluation were developed to deal with the de-alloying of aluminum bronze components. Based on these analyses, the approach has been to evaluate components, and schedule replacement by the corrective action program. Components with indications of through-wall de-alloying, greater than one inch, will be replaced by the end of the next refueling outage. A monitoring and inspection program provides confidence in the ability to detect the leakage.
NRC Generic Letter 89-13 was based on industry operating experience and forms the basis for the STP OCCW System program.
Conclusion The continued implementation of the Open-Cycle Cooling Water System program will provide reasonable assurance that aging effects will be managed such that the systems and South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 62 of 84 components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 63 of 84 B2.1.10 Closed-Cycle Cooling Water System Program Description The Closed-Cycle Cooling Water (CCCW) System program manages loss of material, cracking, and reduction of heat transfer for components within the scope of license renewal in the CCCW systems. The program provides for preventive measures to minimize corrosion including maintenance of corrosion inhibitor and biocide concentrations, and periodic system and component testing and inspection. Preventive measures include the monitoring and control of corrosion inhibitors and other chemical parameters, such as pH, in accordance with the guidelines of EPRI TR-107396, Revision 1. Periodic inspection and testing to confirm function and monitor corrosion is performed in accordance with EPRI TR-107396, Revision 1, and industry and plant operating experience.
The CCCW systems within the scope of license renewal scope are:
Component cooling water (CCW),
ESF diesel generator closed cooling water (a subsystem of the standby diesel generator and auxiliaries system),
BOP DG closed cooling water (a subsystem of the nonsafety-related diesel generator and auxiliary fuel oil system),
Fire pump diesel closed cooling water (a subsystem of the fire protection system), and Chilled water HVAC system consists of subsystems essential chilled water system, reactor containment building (RCB) chilled water system, mechanical auxiliary building (MAB) chilled water system and the technical support center (TSC) chilled water system These systems meet the definition of a CCCW system in NUREG-1801,Section XI.M21. Also in scope are portions of additional systems (heat exchangers or coolers) that are serviced by these systems.
The CCCW System program is based on the EPRI closed-cooling water chemistry guidelines.
Currently, the STP CCCW System program uses Closed Cooling Water Chemistry Guideline:
Revision I to TR-107396, Closed Cooling Water Chemistry Guideline (TR-1007820). The STP CCCW System program is updated as revisions to the EPRI guideline are released.
The program maintains water chemistry within the parameter limits specified in plant procedures and consistent (with exceptions) with those in EPRI TR-1 07396, Revision 1, in order to minimize corrosion and microbiological growth. STP employs two types of nitrite-based corrosion inhibitor treatment programs, tolyltriazole (TTA) as a copper corrosion inhibitor, and glutaraldehyde as a biocide. STP also utilizes glycol-based corrosion inhibitors.
The CCCW System program includes non-chemistry monitoring of components consistent with EPRI TR-107396, Revision 1, Section 8.4 (Non-Chemistry Monitoring). Periodic performance testing of the CCW heat exchangers is part of the STP Open-Cycle Cooling Water System program. Diesel engine performance parameters are monitored through periodic surveillance tests. The CCW pumps are periodically tested to verify pump performance. The extent and South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 64 of 84 schedule of testing and inspections of the CCCW systems assures detection of loss of material, cracking, and reduction of heat transfer prior to the loss of intended function of the system or component. In addition, representative samples of each combination of material and water treatment program are visually inspected at least every ten years and opportunistically.In addition, visual inspectioRs of selected components are used as an indicator of the condition ot internal surfaces exposed to the CGG System. These tests and inspections together with periodic sampling and control of water chemistry are adequate to ensure component intended functions are maintained.
NUREG-1801 Consistency The Closed-Cycle Cooling Water System program is an existing program that, following enhancement, will be consistent, with exception to NUREG-1801 Section XI.M21, Closed-Cycle Cooling Water System.
Exceptions to NUREG-1801 Progqram Elements Affected:
Preventive Actions (Element 2), Parameters Monitored or Inspected (Element 3), and Acceptance Criteria (Element 6)
EPRI TR-1 07396, Revision 1, Table 5-1, establishes chloride and fluoride as control parameters which should be monitored monthly. STP does not monitor or analyze chloride and fluoride as control parameters in the HVAC chilled water systems. At STP chloride and fluoride are monitored as diagnostic parameters in the HVAC chilled water systems with an Alert Value of 5 ppm for both chloride and fluoride which is more restrictive than the EPRI control parameter normal operating range of less than or equal to 10 ppm for both chloride and fluoride.
Chemistry control of chloride and fluoride in the HVAC chilled water systems is therefore consistent, but not identical, with the EPRI recommended approach. At STP, if the system contains no stainless steel or temperatures are less than 150 F, then chlorides and fluorides are diagnostic parameters due to general corrosion concerns. The makeup water to the HVAC chilled water systems is demineralized and there are no known pathways for chloride or fluoride to enter the HVAC chilled water systems cooling water.
Parameters Monitored or Inspected (Element 3), Detection of Aging Effects (Element 4), and Monitoring and Trending (Element 5)
NUREG-1 801 states that the Closed-Cycle Cooling Water System program should conduct performance/functional testing. At STP, performance/functional testing is not performed on the heat exchangers served by the in-scope CCCW Systems. EPRI TR-1 07396, Revision1, does not include performance monitoring and functional testing of heat exchangers or other components. The Closed-Cycle Cooling Water System program utilizes corrosion monitoring which includes component inspections to monitor program effectiveness in managing component degradation that could impact a passive function. Chemical analysis of iron and copper in the bulk water is performed to monitor the buildup of dissolved corrosion products.
Higher than expected concentration levels of total iron and copper indicate possible corrosion within the CCCW systems. Measurement of accumulated corrosion products such as iron and copper provides an indirect indication of system corrosion.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 65 of 84 Reductions in heat transfer are managed through a combination of chemistry controls and inspection activities. Chemistry controls are generally adequate to prevent buildup of significant fouling on heat exchanger surfaces.
Preventive Actions (Element 2), Parameters Monitored or Inspected (Element 3), Detection of Aging Effects (Element 4), Monitoring and Trending (Element 5), and Acceptance Criteria (Element 6)
The program described in NUREG-1801,Section XI.M21, is based on the 1997 version of the EPRI Closed Cooling Water Chemistry Guideline, TR-1 07396, Revision 0. The STP program currently uses the 2004 version of the EPRI Closed Cooling Water Chemistry Guideline, Revision 1. This exception is acceptable because the EPRI Closed Cooling Water Chemistry Guideline is a consensus document that is updated based on new operating experience, research data, and expert opinion. Incorporation of later versions of the guidance document ensures that the program addresses new information.
Enhancements Prior to the period of extended operation, the following enhancements will be implemented in the following program elements:
Parameters Monitored or Inspected (Element 3), Detection of Aging Effects (Element 4),
Monitoring and Trending (Element 5), and Acceptance Criteria (Element 6), and GCrreGtiv Actions (Element 7)
Procedures will be enhanced to include visual inspection of representative samples of each combination of material and water treatment program at least every ten years and opportunistically the
÷inter"io Of the piping that is attached to the excess letdown heat exchanger C-CIA return secoend-c~hock valves. This periodic-intern-al in-spection will detect loss of mnateria!
and fouling and serwe as a leading indicator-of the condition of the interior Of piping com~ponents otherwfise iinaccessible for visual inspectimo.
The procedures will also be enhanced to include acceptance criteria.
Operating Experience The Closed-Cycle Cooling Water System program is based on the guidance contained in EPRI TR-107396, Revision 1, which itself is based on industry-wide operating experience. The guideline is periodically updated and approved by the industry. STP operating experience is evaluated and corrective actions are implemented for chemical concentrations, monitoring and testing to ensure adherence to EPRI TR-1 07396, Revision 1. Industry operating experience and independent audits provide additional input to ensure that program operability is maintained at an optimum level.
Based on a review of STP operating experience, there is no history of chemistry related corrosion or fouling issues for the component cooling water system, ESF DG jacket water system, essential chilled water, RCB chilled water, MAB chilled water and BTRS chilled water systems. Past inspections of component cooling water system and ESF DG jacket water piping have indicated a clean and tight adherent passive oxide layer.
In 1999, Sure-Cool residue buildup was observed on the outside of a carbon steel flange in the component cooling water system return piping from the spent fuel pool heat exchanger.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 66 of 84 Investigation revealed a through-wall crack in the weld neck flange about 1.1-in. from the flange to pipe weld. The flange was weld repaired. The crack showed no signs of loss of material, verified by ultrasonic test.
In 2003, a leak occurred in a coil to header joint of a reactor containment fan cooler. Initial observations of the leak detected no indications of corrosion. The attempt to repair the leak, by brazing, melted the coil tubing. The damage prohibited further examination and determination of the actual cause of the leak. An evaluation of the event determined the cause of the leak was not attributed to an aging effect.
The BOP diesel jacket water system radiator has been replaced due to corrosion. The FPD jacket water system cores have been changed due to corrosion prior to using the current corrosion inhibitor.
MIC (Microbiologically-Influenced Corrosion) has not been observed in the in-scope CCCW systems.
Based on a review of 10 years of STP operating experience, any chemistry parameters outside of established limits have been identified and the appropriate actions taken. Corrective actions have included increasing sampling frequencies, chemical addition, feed and bleeds, system cleaning and fixing leaks.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 67 of 84 B2.1.16 One-Time Inspection Program Description The One-Time Inspection program manages loss of material, cracking, and reduction of heat transfer. The One-Time Inspection program conducts one-time inspections of plant system piping and components to verify the effectiveness of the Water Chemistry program (B2.1.2),
Fuel Oil Chemistry program (B2.1.14), and Lubricating Oil Analysis program (B2.1.23).
The One-Time Inspection program will be implemented by STP prior to the period of extended operation. Plant system piping and components identified in the one-time inspection procedure will be subject to one-time inspections on a sampling basis, using qualified inspection personnel, following established ASME Code Section V Non-Destructive Examination techniques appropriate to each inspection. The One-Time Inspection pro-gram determines non-destructive examination (NDE) sample sizes are based on the numbeF population of components in a group sharing the same material, environment, and aging 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 operating experience. The program will focus on bounding or lead components most susceptible to aping 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 ethei aGtivities mayualified inspectors. The program will not be used if-they-satisfy for component inspections with known age-related degradation mechanisms, or when the Feqiiement environment in the OTl-pr erOa. period of extended operation is not equivalent to that in the prior 40 years. The One-Time Inspection program specifies corrective actions and ireas sampling,f piping.components if aging effects are found dfing. 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 materiall, environmental, and aging combination inspeetiins that produced the aging effects.
The one-time inspections will be performed no earlier than 10 years prior to the period of extended operation. All one-time inspections will be completed prior to the period of extended operation. Completion of the One-Time Inspection program in this time period will assure that potential aging effects will be manifested based on at least 30 years of STP operation. Major elements of the STP One-Time Inspection program will include:
a) Identifying piping and component populations subject to one-time inspections based on common materials and environments, b) Determining the sample size of components to inspect for each material-environment group, c) Selecting piping and components within the material-environment groups for inspection based on criteria provided in the one-time inspection procedure, d) Conducting one-time inspections of the selected components within the sample using ASME Code Section V Non-Destructive Examination techniques and acceptance criteria consistent with the design codes/standards or ASME Section Xl as applicable to the component, e) Evaluating inspection results and initiating corrective action for any aging effects found.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 68 of 84 NUREG-1801 Consistency The One-Time Inspection program is a new program that, when implemented, will be consistent with NUREG-1801,Section XI.M32, One-Time Inspection.
Exceptions to NUREG-1801 None Enhancements None Operating Experience During the 10 year period prior to the period of extended operation, one-time inspections will be accomplished at STP using ASME Code Section V Non-Destructive Examination techniques to identify possible aging effects. ASME code techniques in the ASME Section Xl ISI Program have proven to be effective in detecting aging effects prior to loss of intended function. Review of STP plant-specific operating experience associated with the ISI Program has not revealed any ISI Program adequacy issues with the STP ASME Section Xl ISI Program. The same Non-Destructive Examination techniques used in the ASME Section Xl ISI Program will be used in the One-Time Inspection program. Using ASME Code Section V Non-Destructive Examination techniques will be effective in identifying aging effects, if present.
As additional industry and plant-specific applicable operating experience becomes available, it will be evaluated and incorporated into the program through the STP condition reporting and operating experience programs.
Conclusion The implementation of the One-Time Inspection program will provide reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 69 of 84 B2.1.17 Selective Leaching of Materials Program Description The Selective Leaching of Materials 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 water, raw water, and groundwater (buried) within the scope of license renewal.
The Selective Leaching of Materials program is a new program which includes a one-time inspection of a sample of components made from gray cast iron and copper alloys with greater than 15 percent zinc. 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. The program procedure provides for visual and mechanical inspections for each system/material/environment combination and for follow-up engineering evaluation in the event that graphitization of gray cast iron or dezincification of copper alloys with greater than 15 percent zinc components is detected. Sample sizes for selective leaching are based on 20 percent of the material/environment group population to a maximum of 25 components. The plant-specific Selective Leaching of Aluminum Bronze program (B2.1.37) covers aluminum bronze components. Inspection of buried components subject to selective leaching is covered in Buried Piping and Tanks Inspection (B2.1.18).
F lW testin oaf the fire main,
.cstent with NvEP-A 25, is, credmted for management of selective leaching of the buried cammt ir*on valves in the fiv potecvtion system. This is cen*istmnt with the Stratogy in the BUriod Piping and Tanks Inspectioprgm (132.1.18) for managing loss oe material in buried fire protection piping.
The Selective Leaching of Materials program will be implemented during the 40 five years prior to the period of extended operation.
NUREG-1801 Consistency The Selective Leaching of Materials program is a new program that, when implemented, will be consistent, with exception to NUREG-1801,Section XI.M33, Selective Leaching of Materials.
Exceptions to NUREG-1801 Program Elements Affected:
Scope of Program (Element 1)
NUREG-1801,Section XI.M33 states that the Selective Leaching of Materials program should include bronze or aluminum bronze components that may be exposed to a raw water, treated water, or groundwater environment. Aluminum bronze is not managed by the Selective Leaching of Materials program. STP currently has a plant specific Selective Leaching of Aluminum Bronze program (B2.1.37), which covers these aluminum bronze components.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 70 of 84 Scope of Program (Element 1), Parameters Monitored or Inspected (Element 3), and Detection of Aging Effects (Element 4)
NUREG-1801,Section XI.M33 recommends hardness testing of sample components in addition to visual inspections. However, a qualitative determination of selective leaching is used in lieu of Brinell hardness testing for components within the scope of the STP Selective Leaching of Materials program. The exception involves the use of examinations, other than Brinell hardness testing, identified in NUREG-1 801 to identify the presence of selective leaching of materials.
The exception is justified; because (1) hardness testing may not be feasible for most components due to form and configuration and (2) other mechanical means (e.g., scraping, or chipping) provide an equally valid means of identification.
Additionally, hardness testing only provides definitive results if baseline values are available for comparison purposes. Specific material contents for copper alloys may not be known and gray cast irons may not have published hardness numbers. Without specific numbers for comparison, hardness testing would yield unusable results. In lieu of hardness testing, visual and mechanical inspections will be performed on a sampling of components constructed of copper alloys with greater than 15 percent zinc and gray cast iron from various station system environments. Follow-up examinations or evaluations are performed on component material samples where indications of dezincification, de-alloying, or graphitization are visually detected and additional analysis, as part of the engineering evaluation, is required. The engineering evaluation may require confirmation with a metallurgical evaluation (which may include a microstructure examination).
NUREG 1801,Section XI.M33 requires visual inspection and hardness measurement of materials susceptible to selective leaching. HweveFr, Flow testing of the fi", mains, consistent with NlPA 25, is croditod for maRagement of selective leac-hing of the buried cast i-.r valves i the fire protection system.This is consistent with the strategy in the Buried Piping and Tanks Inspection program (B2.1.18) for managing loss of material in buried fire protection piping.
Enhancements None Operating Experience To date, there have been no reported cases of loss of material attributable to graphitization or dezincification.
Through-wall cracks have been identified in essential cooling water system piping initiated by pre-existing weld defects and propagated by a de-alloying phenomenon. The flaws evaluated appeared in welds with backing rings. STP has analyzed the effects of the cracking and found that the degradation is slow so that rapid or catastrophic failure is not a consideration and determined that the leakage can be detected before the flaw reaches a limiting size that would affect the intended function of the essential cooling water system. A monitoring and inspection program provides confidence in the ability to detect the leakage. In order to identify and evaluate future leaks, the accessible large bore piping welds with backing rings are visually inspected every six months for evidence of leakage. A walk down of the yard above buried essential cooling water system pipe is performed every six months for evidence of soil changes that may indicate pressure boundary leakage. The most susceptible components are cast aluminum bronze fittings (flanges and tees) with backing ring welds. A special VT-2 visual South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 71 of 84 examination of the system is performed every six months to identify new de-alloying locations.
An operability review and an NRC relief request are performed for all through-wall leaks in piping larger than one-inch in diameter. The long-term strategy for essential cooling water system piping de-alloying is to replace fittings when through-wall de-alloying is discovered. This strategy is acceptable based on the very slow degradation mechanism coupled with the preservation of structural integrity and is consistent with the EPRI Service Water Piping Guideline. These ongoing activities are detailed in the Selective Leaching of Aluminum Bronze program (B2.1.37) and are examples of where selective leaching was detected and plant procedures and inspection activities were implemented to ensure that the intended functions of the essential cooling water system are maintained.
As additional industry and plant-specific applicable operating experience becomes available, it will be evaluated and incorporated into the program through the STP condition reporting and operating experience programs.
Conclusion The implementation of the Selective Leaching of Materials program will provide reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 72 of 84 B2.1.19 One-Time Inspection of ASME Code Class I Small-Bore Piping Program Description The One-Time Inspection of ASME Code Class 1 Small-Bore Piping program manages cracking of ASME Code Class 1 piping less than or equal to four inches nominal pipe size (NPS 4). This piping is ASME examination category B-J. This program is implemented as part of the fourth interval of the ISI Program.
For ASME Code Class 1 small-bore piping, the ISI Program requires volumetric examinations (by ultrasonic testing) on selected butt weld locations to detect cracking. Weld locations are selected based on the guidelines provided in EPRI TR-1 12657, Revised Risk-Informed Inservice Inspection Evaluation Procedure. Ultrasonic examinations are conducted in accordance with ASME Section Xl with acceptance criteria from paragraph IWB-3000 and IWB-2430 for butt welds. Unit 1 has 182 Class 1 small-bore butt welds and 49 Class I small-bore socket welds. The inspection sample for the Unit 1 Class 1 small-bore butt welds is 19 and the inspection sample for the Unit 1 Class 1 small-bore socket welds is 5, which is 10 percent of each population. In Unit 2, there are 190 Class 1 small-bore butt welds and 59 Class 1 small-bore socket welds. The inspection sample size for the Unit 2 Class 1 small-bore butt welds is 19 and the inspection sample size for Unit 2 Class 1 small-bore socket welds is 6, which is 10 percent for each population.if no socket welds arc in the sample population, then at least 10 percent of the socket welds in each unit will be selected, up to a maximum of 25.
Socket welds that fall within the weld examination sample will be examined following ASME Section Xl Code requirements. If a qualified volumetric examination procedure for socket welds endorsed by the industry and the NRC is available and incorporated into the ASME Section XI Code at the time of STP small-bore socket weld inspections, then this will be used for the volumetric examinations. If no volumetric examination procedure for ASME Code Class 1 small-bore socket welds has been endorsed by the industry and the NRC and incorporated into ASME Section Xl at the time STP performs inspections of small-bore piping, a plant procedure for volumetric examination of ASME Code Class 1 small-bore piping with socket welds will be used.
The One-Time Inspection of ASME Code Class 1 Small-Bore Piping program inspections will be completed and evaluated within six years prior to the period of extended operation.
In conformance with 10 CFR 50.55a(g)(4)(ii), the STP ISI Program is updated during each successive 120-month inspection interval to comply with the requirements of the latest edition of the ASME Code specified 12 months before the start of the inspection interval. STP will use the ASME Code Edition consistent with the provisions of 10 CFR 50.55a during the 10 year period prior to the period of extended operation (fourth interval) and during the period of extended operation.
NUREG-1801 Consistency The One-Time Inspection of ASME Code Class 1 Small-Bore Piping program is a new program that, when implemented, will be consistent, with exception to NUREG-1801,Section XI.M35, One-Time Inspection of ASME Code Class 1 Small-Bore Piping.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 73 of 84 Exceptions to NUREG-1801 Program Elements Affected Scope of Program (Element 1)
The STP risk-informed process examination requirements are performed consistent with EPRI TR-1 12657, Revised Risk-Informed Inservice Inspection Evaluation Procedure, Revision B-A, instead of EPRI Report 1000701, Interim Thermal Fatigue Management Guidance (MRP-24).
Guidelines for identifying piping susceptible to potential effects of thermal stratification or turbulent penetration that are provided in EPRI Report 1000701 are also provided in EPRI TR-1 12657. The recommended inspection volumes for welds in EPRI Report 1000701 are identical to those for inspection of thermal fatigue in RI-ISI Programs; thus, the STP risk-informed process examination requirements meet the recommendations of NUREG-1801.
Enhancements None Operating Experience In order to estimate the extent of cracking in Class 1 piping socket welds, NEI conducted a review of LERs. Of 141 LERs reviewed, 48 were determined to be associated with failures of Class 1 socket welds. For the 46 LERs where a cause was identified, 42 of the failures were due to either vibration-induced high cycle fatigue or improper installation and are not age-related. Of the four remaining failures, one was due to randomly applied loads during maintenance and not age-related, and three were related to aging: two due to insulation contamination on the outside surface, and one associated with IGSCC, although there were other contributing factors not associated with aging (poor weld fit up, weld repair, nearby missing support, etc.).
The NEI review indicates that there have been a relatively small number of Class 1 socket weld failures of which only three were related to aging.
A review of plant-specific operating experience indicates that no cracking has been observed for ASME Code Class 1 small-bore pipe welds less than or equal to NPS 4.
Based on a review of operating experience, cracking of ASME Code Class 1 small-bore pipe welds less than or equal to NPS 4 has not been observed. This provides confidence that the One-Time Inspection of ASME Code Class 1 Small-Bore Piping program is adequate to manage cracking in ASME Code Class 1 small-bore piping.
As additional industry and plant-specific applicable operating experience becomes available, it will be evaluated and incorporated into the program through the STP condition reporting and operating experience programs.
Conclusion The implementation of the One-Time Inspection of ASME Code Class 1 Small-Bore Piping program will provide reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 74 of 84 intended functions consistent with the current licensing basis for the period of extended operation.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 75 of 84 B2.1.20 External Surfaces Monitoring Program Program Description The External Surfaces Monitoring Program manages loss of material for external surfaces of steel, stainless steel, aluminum, copper alloy components and elastomers, and hardening and loss of strength for elastomers. The program is a visual monitoring program that includes those systems and components within the scope of license renewal. Visual inspections are used to identify aging effects and leakage feF of steel, stainless steel, aluminum, and-copper alloy components, and hardening and loss Of strength for elastomers. When appropriate for the component configuration and material, physical manipulation of at least 10 percent of the available surface area of elastomers is used to augment visual inspections to confirm the absence of hardening or loss of strength. Personnel performing external surfaces monitoring inspections will be qualified in accordance with site controlled procedures and processes.
The External Surfaces Monitoring Program will be implemented by a new procedure. System inspections and walkdowns will be required and will consist of periodic visual inspections for indications of loss of material, leakage, elastomer hardening and loss of strengths, and aging effects of protective paints, coatings, caulking, and sealants.
The following aging management programs are used to manage aging for external surfaces that are not within the scope of the External Surfaces Monitoring Program.
- 1) Boric Acid Corrosion program (B2.1.4) for components in a system with treated borated water or reactor coolant environment in which boric acid corrosion may occur.
- 2) Buried Piping and Tanks Inspection program (B2.1.18) for buried components.
- 3) Structures Monitoring Program (B2.1.32) for civil structures, and other structural items which support and contain mechanical and electrical components.
The External Surfaces Monitoring Program is a new program that will be implemented prior to the period of extended operation. Within the ten year period prior to the period of extended operation, and continuing into the period of extended operation, periodic inspections will be performed.
NUREG-1801 Consistency The External Surfaces Monitoring program is a new program that, when implemented, will be consistent, with exception to NUREG-1801,Section XI.M36, External Surfaces Monitoring.
Exceptions to NUREG-1801 Program Elements Affected:
Scope of Program (Element 1) and Detection of Aging Effects (Element 4)
NUREG-1 801,Section XI.M36 requires the program to visually inspect the external surface of in-scope components and monitor external surfaces of steel components in systems within the scope of license renewal and subject to AMR for loss of material and leakage. The External South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 76 of 84 Surfaces Monitoring Program has expanded the materials inspected to include stainless steel, aluminum, copper alloy, and elastomer external surfaces within the scope of license renewal.
The use of visual inspection to detect loss of material and leakage of stainless steel, aluminum, copper alloy and elastomer external surfaces is an effective method for these materials.
NUREG-1801,Section XI.M36 requires the program to manage loss of material and leakage.
The External Surfaces Monitoring Program also includes, among the aging effects to be managed, elastomer hardening and loss of strength. This aging effect is managed by physical manipulation of elastomer components to detect hardening and loss of strength.
NUREG-1801,Section XI.M36 requires a program of visual inspection to detect loss of material and leakage. The External Surfaces Monitoring Program primarily uses visual inspection to detect loss of material and leakage and is augmented by physical manipulation of at least 10 percent of the available surface area of elastomers when appropriate to the component material and design. Manipulation of elastomers is an effective method to augment the visual inspection of elastomers in detecting the aging effect of hardening and loss of strength.
Enhancements None Operating Experience The External Surfaces Monitoring Program is a new program. Routine system walkdowns are performed as part of the systems engineering program. The STP condition reporting program is used in conjunction with the system walkdowns to identify and resolve issues to plant equipment. Industry operating experience that forms the basis for this program is included in the operating experience element of the corresponding NUREG-1801 aging management program. A review of plant condition reporting documents, as well as other STP current licensing basis documents, since 1998, was performed to ensure that there is no unique, plant-specific operating experience in addition to that in NUREG-1801. The review identified no unique operating experience. The condition reporting program was proven to be effective in maintaining the material condition of plant systems.
As additional industry and plant-specific applicable operating experience becomes available, it will be evaluated and incorporated into the program through the STP condition reporting and operating experience programs.
Conclusion The implementation of the External Surfaces Monitoring program will provide reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 77 of 84 B2.1.22 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program Description The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program manages cracking, loss of material, and hardening and loss of strength of the internal surfaces of piping, piping components, ducting tanks and other components that are not inspected by other aging management programs.
The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program is a new program that uses the work control process for preventive maintenance and surveillance to conduct and document inspections. The program performs visual inspections to detect aging effects that could result in a loss of component intended function. Visual inspections of internal surfaces of plant components are performed by qualified personnel during periodic maintenance, predictive maintenance, surveillance testing and corrective maintenance. Supplemental inspections, not performed concurrently with planned work activities will be performed. The locations and intervals for these supplemental inspections are based on assessments of the likelihood of significant degradation and on current industry and plant-specific operating experience.
Additionally, visual inspections may-will be augmented by physical manipulation of at least 10 percent of available surface area of elastomers within the scope of the program, when appropriate for the component configuration and material, to detect hardening and loss of strength of beth-internal and external surfaces of elastomers. In cases where internal surfaces are not available for visual inspection, an internal visual inspection may be substituted with a volumetric examination. The program includes volumetric examination of the tank bottoms of the auxiliary feedwater storage tanks and the firewater storage tanks from inside the tanks, to confirm the absence of loss of material due to corrosion. The program also includes volumetric evaluation (ultrasonic examination) to detect stress corrosion cracking of the internal surfaces of stainless steel components exposed to diesel exhaust.
This program will be initiated prior to entering the period of extended operation and provides for periodic inspection of a selected set of sample components within the scope of this program.
The internal surfaces inspections are normally performed through scheduled preventive maintenance and surveillance inspections such that work opportunities are sufficient to detect aging and provide reasonable assurance that intended functions are maintained. Supplemental inspections not performed concurrently with planned work activities will be performed. The locations and intervals for these supplemental inspections will be based on assessments of the likelihood of significant degradation and on current industry and plant-specific operating experience.
NUREG-1801 Consistency The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program is a new program that, when implemented, will be consistent with exception to NUREG-1801,Section XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 78 of 84 Exceptions to NUREG-1801 Pro-gram Elements Affected:
Scope of Program (Element 1), Parameters Monitored or Inspected (Element 3), Detection of Aging Effects (Element 4), and Monitoring and Trending (Element 5)
NUREG-1801 Section XI.M38 provides for a program of visual inspections of the internal surfaces of miscellaneous steel piping and ducting components to ensure that existing environmental conditions are not causing material degradation that could result in a loss of component intended functions. The exceptions to NUREG-1801 Section XI.M38 are an increase to the scope of the materials inspected to include stainless steel, aluminum, copper alloy, stainless steel-cast austenitic, nickel alloys, glass and elastomers, in addition to steel, and an increase to the scope of aging effects to include hardening and loss of strength for elastomers. Additionally, visual inspections my will be augmented (1) by physical manipulation of at least 10 percent of available surface area of elastomers within the scope of the program to detect hardening and loss of strength of elastomers when appropriate for the component configuration and material, (2) volumetric examinations of the tank bottoms of the auxiliary feedwater storage tanks and the firewater storage tanks from inside the tanks, to confirm the absence of loss of material due to corrosion, and (2) by volumetric evaluation to detect stress corrosion cracking of the internal surfaces of stainless steel components exposed to diesel exhaust.
Enhancements None Operating Experience The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program is a new program; therefore, plant-specific operating experience to verify the effectiveness of the program is not available. However, visual inspections were conducted during periodic maintenance, predictive maintenance, surveillance testing and corrective maintenance. These records provided evidence of STP using maintenance opportunities to conduct internal inspections during normal plant activities. Industry operating experience that forms the basis for this program is included in the operating experience element of the corresponding NUREG-1801 aging management program. A review of plant condition reporting documents, as well as other STP current licensing basis documents, since 1998, was performed to ensure that there is no unique, plant-specific experience in addition to that in NUREG-1 801. The review identified no unique operating experience.
Many of the plant condition reporting documents discussed above concerned corrosion found in HVAC systems. The corrective actions for these conditions generally included removal of the corrosion and painting to prevent recurrence.
As additional industry and plant-specific applicable operating experience becomes available, it will be evaluated and incorporated into the program through the STP condition reporting and operating experience programs.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 79 of 84 Conclusion The implementation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program will provide reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 80 of 84 B3 TLAA SUPPORT ACTIVITIES B31 METAL FATIGUE OF REACTOR COOLANT PRESSURE BOUNDARY Program Description The Metal Fatigue of Reactor Coolant Pressure Boundary program manages fatigue cracking caused by anticipated cyclic strains in metal components of the RCPB. The program ensures that actual plant experience remains bounded by the transients assumed in the design calculations, or that appropriate corrective actions maintain the design and licensing basis by other acceptable means.
The Metal Fatigue of Reactor Coolant Pressure Boundary program consists of cycle counting activities. The program will be enhanced to monitor and trend fatigue usage at selected locations in the reactor coolant pressure boundary. The program will be enhanced to include additional transients and locations identified by the evaluation of ASME Section III fatigue analyses, locations necessary to ensure accurate calculations of fatigue, and the NUREG/CR-6260 locations for a newer-vintage Westinghouse Plant. The supporting environmental life correction factor calculations were performed with NUREG/CR-6583 for carbon and low alloy steels and with NUREG/CR-5704 for austenitic stainless steels.
The Metal Fatigue of Reactor Coolant Pressure Boundary program tracks the occurrences of selected transients and will be enhanced to monitor the cumulative usage factors (CUFs) at selected locations using one of the following methods:
- 1) The Cycle Counting (CC) method does not periodically calculate CUF; however, transient event cycles affecting the location (e.g. plant heatup and plant cooldown) are counted to ensure that the numbers of transient events assumed by the design calculations are not exceeded.
- 2) The Cycle Based Fatigue (CBF) management method utilizes the CC results and stress intensity ranges generated with the ASME III methods that use six stress-tensors to perform periodic CUF calculations, consistent with NRC Requlatory Issue Summary 2008-30, Fatigu Analysis of Nuclear Power Plant Components for a selected location. The fatigue accumulation is tracked to determine approach to the ASME allowable fatigue limit of 1.0.
The Metal Fatigue of Reactor Coolant Pressure Boundary program continuously monitors plant data, and maintains a record of the data collected. The collected data are analyzed to identify operational transients and events, calculate usage factors for selected monitored locations, and compare the calculated usage factors to allowable limits. Periodic review of the calculations ensures that usage factors will not exceed the allowable value of 1.0 without an appropriate evaluation and any further necessary actions. If a cycle count or CUF value increases to a program action limit, corrective actions will be initiated to evaluate the design limits and determine appropriate specific corrective actions. Action limits permit completion of corrective actions before an assumed number of events in a fatigue analysis is exceeded.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 81 of 84 NUREG-1801 Consistency The Metal Fatigue of Reactor Coolant Pressure Boundary program is an existing program that, following enhancement, will be consistent with NUREG-1801,Section X.M1, Metal Fatigue of Reactor Coolant Pressure Boundary.
Exceptions to NUREG-1801 None Enhancements Prior to the period of extended operation, the following enhancements will be implemented in the following program elements:
Scope of Program (Element 1) and Monitoring and Trending (Element 5)
Procedures will be enhanced to include locations identified by the evaluation of ASME Section III fatigue analyses, locations necessary to ensure accurate calculations of fatigue, and the NUREG/CR-6260 locations for a newer-vintage Westinghouse Plant.
Scope of the Program (Element 1), and Parameters Monitored or Inspected (Element 3)
Procedures will be enhanced to include additional transients that contribute significantly to fatigue usage identified by the evaluation of ASME Section III fatigue analyses.
Scope of the Program (Element 1)
Procedures will be enhanced to ensure the fatigue crack growth analyses, which support the leak-before-break analyses and ASME Section Xl evaluations, remain valid by counting the transients used in the analyses.
Detection of Aging Effects (Element 4)
The procedures will be enhanced to 1) include additional transients necessary to ensure accurate calculations of fatigue, 2) fatigue usage monitoring 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. This review will compare the results against the corrective action limits to determine any approach to action limits and any necessary revisions to the fatigue analyses will be included in the corrective actions.
Preventive Actions (Element 2) and Acceptance Criteria (Element 6)
The 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. Action limits permit completion of corrective actions before the design limits are exceeded. The acceptance criteria associated with the NUREG/CR-6260 sample locations for a newer vintage Westinghouse plant will account for environmental effects on fatigue.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 82 of 84 Cycle Count Action Limits:
Cycle count action limits are selected to initiate corrective action when the cycle count for any of the critical thermal or pressure transients is projected to reach the design limit within the next three fuel cycles.
CUF Action Limits:
CUF action limits require corrective action when the calculated CUF for any monitored location is projected to reach 1.0 within the next three fuel cycles.
Corrective Actions (Element 7)
Procedures will be enhanced to include appropriate corrective actions to be invoked if a component approaches a cycle count or CUF action limit.
If a cycle count action limit is reached, acceptable corrective actions include:
- 1) Review of fatigue usage calculations:
a) To identify the components and analyses affected by the transient in question.
b) To determine whether the transient in question contributes significantly to CUF.
c) To ensure that the analytical bases of the high energy line break (HELB) locations are maintained.
- 2) Evaluation of remaining margins on CUF.
- 3) Review the fatigue crack growth and stability analyses which support the leak before break exemptions and relief from the ASME Section Xl flaw removal or inspection requirements to ensure that the analytical bases remain valid. Re-analysis of a fatigue crack growth analysis must be consistent with or reconciled to the originally submitted analysis and receive the same level of regulatory review as the original analysis.
- 4) Redefinition of the specified number of cycles (e.g., by reducing specified numbers of cycles for other transients and using the margin to increase the allowed number of cycles for the transient that is approaching its specified number of cycles).
- 5) Redefinition of the transient to remove conservatism in the pressure and temperature ranges.
S*,,-
the c
,unting action limits are based on a somewhat arbit*ray cycle count that dos not accuratoly indicate approach to the CUEF - 1.0 fatiguo limit, 4 These preliminary actions are designed to determine how close the approach is to the 1.0 limit, and from those determinations, set new action limits. If the CUF has approached 1.0 then further actions described below for cumulative fatigue usage action limits may be invoked.
If a CUF action limit is reached acceptable corrective actions include:
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 83 of 84
- 1) Determine whether the scope of the management programn must be enlarged to include additional affected reactor coolant pi.ssur. bounda," locsations. This determinatien will onSUre that other locations do not approach design lim~itS Without an aprpit action.
- 2) EnRhanc fatigue managing to confirm continued cnformanr e to the code limit.
31_)
Repair the component.
- 42) Replace the component. If a limiting component is replaced, assess the effect on locations monitored by the program. If a limiting component is replaced, resetting its cumulative fatigue usage factor to zero, a component which was previously bounded by the replaced component will become the limiting component and may need to be monitored.
,_) Perform a more rigorous analysis of the component to demonstrate that the design code limit will not be exceeded.
- 6) Modify plant operating practices to reduce the fatigue usage accuimulation rate-.
- 7) Pe.Form a flaw tolerance evaluation and impose component specific inspections, under ASM,-
Sec-tion Xl Appendices A or C (or thei Fucsos),
and obtafini required approVals by the NRC.
Operating Experience The STP industry operating experience program reviews industry experience, including experience that may affect fatigue management, to ensure that applicable experience is evaluated and incorporated in plant analyses and procedures. Any necessary evaluations are conducted under the plant corrective action program.
The Metal Fatigue of Reactor Coolant Pressure Boundary program was implemented in response to industry experience that indicated that the design basis set of transients used for fatigue analyses of the reactor coolant pressure boundary did not include some significant transients, and therefore might not be limiting for components affected by them. Examples:
Thermal stratification of pressurizer surge line piping:
In response to NRC Bulletin 88-11, Westinghouse performed a plant-specific evaluation of STP pressurizer surge lines. The surge line stratification analysis was based on STP design transients. It was concluded that thermal stratification does not affect the integrity of the pressurizer surge lines. STP responses to NRC Bulletin 88-1 1 describe the inspections, analyses, and procedural revisions made to ensure that thermal stratification does not affect the integrity of the pressurizer surge lines. In addition, the responses noted that fatigue analyses were updated to ensure compliance with applicable codes and license commitments.
Thermal fatigue cracking in normally-isolated piping:
In 1988, as identified in NRC Bulletin 88-08, there were several instances of thermal fatigue cracking in normally stagnant lines attached to reactor coolant system (RCS) piping. This issue was addressed by utilities by conducting evaluations and monitoring to ensure that further leakage would not occur. STP performed a complete analysis of systems connected to the RCS. The review concluded that the potential for the described thermal conditions existed only in the normal charging, alternate charging, and auxiliary spray lines. However, these systems South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 84 of 84 are separated and only hot water can leak through the charging and auxiliary spray lines, reducing the potential for thermal cycling.
Conclusion The continued implementation of the Metal Fatigue of Reactor Coolant Pressure Boundary program provides reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.
South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Revised Regulatory Commitments South Texas Project License Renewal Application Amendment 7 NOC-AE-1 1002750 Page 1 of 1 A4 License Renewal Commitments Table A4-1 identifies proposed actions committed to by STPNOC for STP Units 1 and 2 in its License Renewal Application. These and other actions are proposed regulatory commitments. This list will be revised, as necessary, in subsequent amendments to reflect changes resulting from NRC questions and STPNOC responses. STPNOC will utilize the STP commitment tracking system to track regulatory commitments. The Condition Report (CR) number in the Implementation Schedule column of the table is for STPNOC tracking purposes and is not part of the amended LRA.
Table A4-1 License Renewal Commitments Item #
Commitment LRA Implementation Section Schedule 3
Enhance the Bolting Integrity program procedures to:
B2.1.7 Prior to the period of conform to the guidance contained in EPRI TR-1 04213 extended operation evaluate loss of preload of the joint connection, including bolt stress, gasket stress, flange alignment, and operating condition 10-23255-1 to determine the corrective actions consistent with EPRI TR-104213.
5 Enhance the Closed-Cycle Cooling Water System program B2.1.10 Prior to the period of procedures to:
extended operation 0
include visual inspection of the interFior f the piping that is
.a;#.;,hed to the eXcess letdown heat eXchanger r-etrn 10-23257-1 second check valves. This periodic internalinpconil detect loss of material and fouling and srve as a leadP;ing idi";ctor of the condition of the interior of piping components othezrwise inaccessible for Visual inSPection representative samples of each combination of material and water treatment program at least every ten years and opportunistically, and include acceptance criteria.
38 Enhance the Reactor Head Closure Studs program procedures to:
B2.1.3 Prior to the period of preclude future use of replacement closure stud assemblies fabricated extended operation from material with an actual measure yield strength greater than or equal to 150 ksi. The use of currently installed components and any 11-22923-1 spare components currently on site is allowed.