ML11335A140
ML11335A140 | |
Person / Time | |
---|---|
Site: | South Texas |
Issue date: | 11/30/2011 |
From: | Rencurrel D South Texas |
To: | Document Control Desk, Office of Nuclear Reactor Regulation |
References | |
NOC-AE-1 1002758, TAC ME4936, TAC ME4937 | |
Download: ML11335A140 (88) | |
Text
ILMAIF" Nuclear Operating Company South Texas Project Electric GeneratingStation P/. Ba, 289 Wdsworth. Texas 77483 November 30, 2011 NOC-AE-1 1002758 10 CFR 54 STI: 33044344 File: G25 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Annual Update to the South Texas Project License Renewal Application (TAC NOS. ME4936 and ME4937)
Reference:
STPNOC Letter dated October 25, 2010, from G. T. Powell to NRC Document Control Desk, "License Renewal Application" (NOC-AE-1 0002607) (ML103010257)
By Reference 1, STP Nuclear Operating Company (STPNOC) submitted an application to the Nuclear Regulatory Commission (NRC) for the renewal of Facility Operating Licenses NPF-76 and NPF-80, for South Texas Project (STP) Units 1 and 2, respectively. The application included the License Renewal Application (LRA), and the Applicant's Environmental Report -
Operating License Renewal Stage. As required by 10 CFR 54.21(b), each year following submittal of the LRA, an amendment to the LRA must be submitted that identifies any change to the current licensing basis (CLB) that materially affects the contents of the LRA, including the Updated Final Safety Analysis Report (UFSAR) supplement. identifies STP LRA changes that are being made to: (1) reflect the CLB that materially affect the LRA; and (2) reflect completed enhancements and commitments. contains the affected LRA page with changes shown as mark-ups (deletions crossed out and insertion underlined). The LRA update covers the period from April 29, 2010 through August 31, 2011. As a reviewer aid, all pages of the Appendix B Aging Management Program are provided, including the unchanged pages, when there is a change to any of the pages for the affected program.
Changes to existing commitments are contained in the changes to LRA Table A4-1 in Enclosure
- 3. 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.
4v.q7 IKAuL
NOC-AE-1 1002758 Page 2 I declare under penalty of perjury that the foregoing is true and correct.
Executed on i/i/ o+/-9:,
' Date eD. W. Rencurrel Senior Vice President, Technical Support & Oversight KJT
Enclosure:
- 1. STPNOC License Renewal Application (LRA) Changes Reflected in Annual LRA Update
- 3. Revised Regulatory Commitments
NOC-AE-1 1002758 Page 3 cc:
(paper copy) (electronic copy)
Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission Kathryn M. Sutton, Esquire 612 East Lamar Blvd, Suite 400 Morgan, Lewis & Bockius, LLP Arlington, Texas 76011-4125 Balwant K. Singal John Ragan Senior Project Manager Catherine Callaway U.S. Nuclear Regulatory Commission Jim von Suskil One White Flint North (MS 8B1) NRG South Texas LP 11555 Rockville Pike Rockville, MD 20852 Senior Resident Inspector Kevin Polio U. S. Nuclear Regulatory Commission Richard Pena P. O. Box 289, Mail Code: MN116 City Public Service Wadsworth, TX 77483 C. M. Canady Peter Nemeth City of Austin Crain Caton & James, P.C.
Electric Utility Department 721 Barton Springs Road C. Mele Austin, TX 78704 City of Austin John W. Daily Richard A. Ratliff License Renewal Project Manager (Safety) Alice Rogers U.S. Nuclear Regulatory Commission Texas Department of State Health Services One White Flint North (MS O11-Fl)
Washington, DC 20555-0001 Tam Tran Balwant K. Singal License Renewal Project Manager John W. Daily (Environmental) Tam Tran U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission One White Flint North (MS O11F01)
Washington, DC 20555-0001
Enclosure 1 NOC-AE-1 1002758 Enclosure I STPNOC License Renewal Application (LRA)
Changes Reflected in Annual LRA Update
Enclosure 1 NOC-AE-1 1002758 Page 1 of 2 STPNOC License Renewal Application (LRA)
Changes Reflected in Annual LRA Update Following Changes Materially Affect the LRA Reason for Change Affected LRA Sections or Tables New Aging Management Appendix Al.39 Program added to monitor and Appendix B2.1.39 maintain protective coatings Appendix B13.5 Section B2 includes:
- editorial change of "XI.S.8" to XI.S8")
" to reflect that AMP B2.1.38 is not used The Lighting Diesel was added to Table 2.2-1 the Scope of LRA Section 2.3.3 Section 2.3.3.28 Section 2.4.6 Table 2.4-6 Section 2.4.7 Section 3.3.1 Section 3.3.2 Section 3.3.2.1.28 Table 3.3.2-28 Section 3.5.2.1.6 Table 3.5.2-6 Appendix Al.14 Table A4-1 (See Enclosure 3)
Appendix B2.1.14.
Revised Description of Metal Appendix A2.1 Fatigue of Reactor Coolant Pressure Boundary Program to ensure that actual plant experience remains bounded by transients assumed by "fatigue crack growth analysis" as well as in design calculations.
UFSAR Change Notice 2997 - Table 4.3-2 revised the total number of primary side hydrostatic test cycles to a limit of 1 for Unit 1 that is now limited by the BMI half nozzle repair.
Change in In-core Capsule A1.15 testing order B2.1.15 Change to reflect agreement that Appendix B2.11.17 if buried gray cast iron valves are removed from the fire protection system, then at least one of them will be evaluated to determine the extent of selective leaching of the valve.
Enclosure 1 NOC-AE-1 1002758 Page 2 of 2 UFSAR Change Notice 3005 - Appendix A1.33 revised the survey frequency of Appendix B2.1.33 the Essential Cooling Pond Table A4-1 (See Enclosure 3) sediment from every 5 years to every 10 years.
UFSAR Change Notice 3006 - Section 3.1.2.1.2 revised the allowable material Table 3.1.2-2 that can be used in the Reactor Coolant Pump closure bolting.
Addition of Solenoid Valves to Table 2.3.3-6 scope of LRA Table 2.3.4-6 Section 3.4.2.1.6 Table 3.4.2-6 Section 3.3.2.1.6 Table 3.3.2-6 Table 2.3.3-19 Section 3.3.2.1.19 Table 3.3.2-19 Table 2.3.4-2 Section 3.4.2.1.2 Table 3.4.2-1 Table 3.4.2-2 Following Changes are Editorial Changes to the LRA Reason for Change Affected LRA Sections or Tables For the column "Aging Table 3.1.2-1 Management Program" in the affected tables, reference to the "Nickel-Alloy Management" program corrected to read AMP "B2.1.34"."
Typo in Section B2.1.13 B2.1.13 Corrected the NUREG Environmental Report, Section 2.17, Page 77 of 84 reference number to "1171" for the 1986 Final Environmental Statement related to operation of the South Texas Project, Units 1 & 2
Enclosure 2 NOC-AE-1 1002758 Enclosure 2 STP LRA Changes with Line-in/Line-out Annotations
Enclosure 2 NOC-AE-1 1002758 Page 1 of 78 CHANGE NEW AGING MANAGEMENT PROGRAM ADDED TO MONITOR AND MAINTAIN PROTECTIVE COATINGS A1.39 PROTECTIVE COATING MONITORING AND MAINTENANCE PROGRAM The Protective Coating Monitoring and Maintenance Pro-gram manages loss of coating integrity for Service Level 1 coatings inside containment so that the intended functions of post-accident safety systems that rely on water recycled through the containment sump/drain system are maintained consistent with the current licensing basis. The program includes a visual examination of all reasonably accessible Service Level 1 coatings inside containment, including those applied to the steel containment liner, structural steel, supports, penetrations, uninsulated equipment, and concrete walls and floors receiving epoxy surface systems. This program does not include coating of surfaces that are insulated or otherwise enclosed in normal service and concrete receiving a non-film forming clear sealer coat only.
Enclosure 2 NOC-AE-1 1002758 Page 2 of 78 B2.1.39 Protective Coating Monitoring and Maintenance Program Program Description The Protective Coating Monitoring and Maintenance Program manages loss of coating integrity for Service Level 1 coatings inside containment so that the intended functions of post-accident safety systems that rely on water recycled through the containment sump/drain system are maintained consistent with the current licensing basis. The program includes a visual examination of all reasonably accessible Service Level 1 coatings inside containment, including those applied to the steel containment liner, structural steel, supports, penetrations, uninsulated equipment, and concrete walls and floors receiving epoxy surface systems. This program does not include coating of surfaces that are insulated or otherwise enclosed in normal service and concrete receiving a non-film forming clear sealer coat only.
General visual inspections of the containment building Service Level 1 coatings are conducted as part of the ASME Section Xl, Subsection IWE program and the Structures Monitoring Program at intervals not exceeding five years. Additional inspections may be necessary depending on inspection results. Thorough visual inspections are performed on previously designated areas and on areas noted as deficient during the inspection. Characterization of deficient areas is performed to allow evaluation of the deficiency for future surveillance or repair, and prioritization of repairs. Characterization of blistering, cracking, flaking, peeling, de-lamination, and rusting is consistent with applicable ASTM standards. Physical testing may be performed when directed by the evaluator. Examinations are conducted by qualified personnel.
Service Level I coatings are not credited for managing loss of material of the steel containment liner.
Aging Management Program Elements The results of an evaluation of each element against the 10 elements described in Appendix A of NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants are provided below.
Scope of Program (Element 1)
The Protective Coating Monitoring and Maintenance Program includes a visual examination of all reasonably accessible Service Level 1 coatings inside containment, including those applied to the steel containment liner, structural steel, supports, penetrations, uninsulated equipment, and concrete walls and floors receiving epoxy surface systems. This program pertains to the containment interior and equipment, structures or components which are permanently located inside containment. This program does not include coating of surfaces that are insulated or otherwise enclosed in normal service and concrete receiving a non-film forming clear sealer coat only.
Service Level I coatings are not credited for preventing loss of material due to corrosion for the steel containment liner. (See AMP XI.S1, ASME Section Xl, Subsection IWE)
Enclosure 2 NOC-AE-1 1002758 Page 3 of 78 Preventive Actions (Element 2)
The Protective Coating Monitoring and Maintenance Program does not prevent degradation due to aging effects but provides measures for monitoring to detect the degradation prior to loss of intended function. Coatings are not credited for preventing loss of material.
Parameters Monitored or Inspected (Element 3)
The Protective Coating Monitoring and Maintenance Program inspects coated surfaces for flaking, blistering, cracking., de-lamination, peeling, or rusting. Any areas of coating discoloration or areas where corrosion has formed under the coating system are documented and evaluated.
Detection of Aging Effects (Element 4)
The South Texas Project (STP) periodically conducts condition assessments of Service Level 1 coatings inside containment as part of the ASME Section Xl, Subsection IWE program and the Structures Monitoring Program at intervals not exceeding five years. Additional inspections may be necessary depending on inspection results. Visual inspection of coatings in containment is intended to characterize the condition of the coating systems. In some cases, a complete inspection is not possible due to inaccessibility. For these cases, the coating systems are characterized based on an inspection of coating systems that are reasonably accessible or based on a representative sample. If localized areas of degraded coatings are identified, those areas are evaluated and scheduled for repair/replacement, as necessary. The periodic condition assessments, and the resulting repair/replacement activities, assure that the amount of Service Level 1 coatings which may be susceptible to detachment from the substrate during a loss-of-coolant accident design basis event is minimized.
Monitoring and Trending (Element 5)
Prior to performing the inspection, the inspector reviews previous coating condition assessment reports. The inspection reports prioritize repair areas as either needing repair during the same outage or as postponed to future outages.
The containment liner plate is inspected as part of the ASME Section Xl, Subsection IWE inspection program. The results of this inspection are reviewed to assist in identifying areas of degraded or damaged coating.
Acceptance Criteria (Element 6)
Potentially defective coating surfaces identified during the course of an inspection are documented, their severity is evaluated, and corrective actions are taken to ensure there is no loss of intended functions between the inspections. Defective or deficient coating surfaces are prioritized as either needing repair during the same outage or as postponed to future outages.
The evaluation covers blistering, cracking, flaking, peeling, de-lamination, and rustinq as specified below.
Enclosure 2 NOC-AE-1 1002758 Page 4 of 78 Blisterin.q-Compare any blistering found to the blistering pictorial standards of coatings defects and record size and frequency. If the blisters are larger than those on the comparison photographs, measure, record size and extent, and photograph. Report if blistered portions are intact.
Cracking-Cracking may be limited to the one layer of coating or extend through to the substrate. Measure the length of the crack or if extensive cracking has occurred, measure the size of the area affected. Determine if the cracking is isolated or is part of a pattern.
Record measurements and describe crack depth and pattern on the inspection report.
Photograph the area affected.
Flaking/Peeling/De-lamination-Measure the approximate size of the degraded coating area and note the pattern formed. Carefully test to see if lifting can be easily achieved beyond the obvious peeled area. Note all observations including location of failure within the coating film, whether the failure is cohesive or adhesive, etc., on the inspection report and photograph the area affected.
Rusting-Compare with the pictorial standards to determine the degree of rusting. Try to determine the source of rusting (that is, is it surface stain caused by rusting elsewhere, or is it a failure of the coating allowing the substrate to rust). Photograph the affected area and record observations on the inspection report.
If no defects are found, mark "Coating Intact, No Defects" on the inspection report.
If portions of the coating cannot be inspected, note the specific areas on the inspection report, along with the reason why the inspection cannot be conducted.
Written or photographic documentation, or both, of coating inspection areas, failures, and defects shall be made and the process of documentation standardized by the facility owner/operator.
For coating surfaces determined to be suspect, defective, or deficient, physical tests, such as dry film thickness and adhesion may be performed when directed by the Nuclear Coating Specialist. Samples may be gathered, and the size and extent of defective patterns may be described.
Corrective Actions (Element 7)
STP site Quality Assurance (QA) procedures, review and approval process, and administrative controls are implemented in accordance with the requirements of 10 CFR 50 Appendix B and are acceptable in addressing corrective actions. The QA program includes elements of corrective action, and is applicable to the safety-related and nonsafety-related systems, structures and components that are subiect to aging management review.
Enclosure 2 NOC-AE-1 1002758 Page 5 of 78 Confirmation Process (Element 8)
STP site QA procedures, review and approval process, and administrative controls are implemented in accordance with the requirements of 10 CFR 50 Appendix B and are acceptable in addressing confirmation processes and administrative controls. The QA program includes elements of corrective action, and is applicable to the safety-related and nonsafety-related systems, structures and components that are subject to aging management review.
Administrative Controls (Element 9)
STP site QA procedures, review and approval process, and administrative controls are implemented in accordance with the requirements of 10 CFR 50 Appendix B and are acceptable in addressing confirmation processes and administrative controls. The QA program includes elements of corrective action, and is applicable to the safety-related and nonsafety-related systems, structures and components that are subject to aging management review.
Operating Experience (Element 10)
STP has implemented controls for the procurement, application, and maintenance of Service Level 1 protective coatings used inside containment in a manner that is consistent with the licensing basis and regulatory requirements applicable to STP. The requirements of 10 CFR 50 Appendix B are implemented through specification of appropriate technical and quality requirements for the Service Level 1 coatings program which includes ongoing maintenance activities.
For STP, Service Level 1 coatings have been tested, selected, and applied to assure that they will withstand nuclear, chemical, and physical conditions of a Design Basis Accident, as required by Nuclear Regulatory Commission Regulatory Guide (RG) 1.54, Rev. 0, and ANSI N101.2- 1972. Coatin-qs used inside the containment have been established as safety-related, thus imposing the quality assurance requirements of Appendix B to 10 CFR Part 50.
The South Texas Proiect periodically conducts condition assessments of Service Level 1 coatings inside containment. Coating condition assessments are conducted as part of the structures monitoring program. The structures monitoring program covers the baseline inspection and subsequent inspections that are conducted at intervals not exceeding five years.
Enhancements None Conclusion The continued implementation of the Protective Coating Monitorinq and Maintenance 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.
Enclosure 2 NOC-AE-1 1002758 Page 6 of 78 B1.5 AGING MANAGEMENT PROGRAMS The following aging management programs are described in the sections listed in this appendix.
The programs are either discussed in NUREG-1801 or are plant-specific.
- ASME Section Xl Inservice Inspection, Subsections IWB, IWC, and IWD (Section B2.1.1)
" Water Chemistry (Section B2.1.2)
- Reactor Head Closure Studs (Section B2.1.3)
- Boric Acid Corrosion (Section B2.1.4)
- Nickel-Alloy Penetration Nozzles Welded To The Upper Reactor Vessel Closure Heads of Pressurized Water Reactors (Section B2.1.5)
" Flow-Accelerated Corrosion (Section B2.1.6)
" Bolting Integrity (Section B2.1.7)
- Steam Generator Tube Integrity (Section B2.1.8)
" Open-Cycle Cooling Water System (Section B2.1.9)
- Closed-Cycle Cooling Water System (Section B2.1.10)
- Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems (Section B2.1.11)
- Fire Protection (Section B2.1.12)
- Fire Water System (Section B2.1.13)
- Fuel Oil Chemistry (Section B2.1.14)
- Reactor Vessel Surveillance (Section B2.1.15)
" One-Time Inspection (Section B2.1.16)
- Selective Leaching of Materials (Section B2.1.17)
- Buried Piping and Tanks Inspection (Section B2.1.18)
- One-Time Inspection of ASME Code Class 1 Small-Bore Piping (Section B2.1.19)
- External Surfaces Monitoring Program (Section B2.1.20)
- Flux Thimble Tube Inspection (Section B2.1.21)
Enclosure 2 NOC-AE-1 1002758 Page 7 of 78
- Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (Section B2.1.22)
- Lubricating Oil Analysis (Section B2.1.23)
- Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements (Section B2.1.24)
- Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements (Section B2.1.25)
- Metal Enclosed Bus (Section B2.1.26)
- ASME Section Xl, Subsection IWE (Section B2.1.27) 0 ASME Section Xl, Subsection IWL (Section B2.1.28)
- ASME Section Xl, Subsection IWF (Section B2.1.29)
- 10 CFR 50, Appendix J (Section B2.1.30) 0 Masonry Wall Program (Section B2.1.31)
- Structures Monitoring Program (Section B2.1.32) 0 RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants (Section B2.1.33) 0 Nickel-Alloy Aging Management Program (Section B2.1.34)
- PWR Reactor Internals (Section B2.1.35)
- Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements (Section B2.1.36)
- Selective Leaching of Aluminum Bronze (82.1.37) 0 Protective Coating Monitoring and Maintenance Program B2.1.39
Enclosure 2 NOC-AE-1 1002758 Page 8 of 78 B2 AGING MANAGEMENT PROGRAMS The correlation between NUREG-1 801, Generic Aging Lessons Learned programs and STP programs is shown below. For STP programs, links to appropriate sections of this appendix are provided.
.... PRG.
PLANT PROGRAM EXISTING APPENDIX B 1801 PROGRAM OR NEW REFERENCE
.NUMBER RG 1.127, Inspection RG 1.127, Inspection of Water-Control of Water-Control XI.S7 Structures Associated Structures Associated Existing B2.1.33 with Nuclear Power with Nuclear Power Plants Plants Protective Coating XI.S8 Monitoring and Not Credited N/A N/A Maintenance Program Metal Fatigue of Metal Fatigue of X.MI Reactor Coolant Reactor Coolant Existing B3.1 Pressure Boundary Pressure Boundary Environmental Environmental X.E1 Qualification (EQ) of Qualification (EQ) of Existing B3.2 Electrical Components Electrical Components Concrete Containment Concrete Containment Existing X.S1_____ Tendon Prestress Tendon Prestress B3.3 N/A Plant-Specific ManagementAging Nickel-Alloy Program Existing 82.1.34 N/A Plant-Specific PWR Reactor Internals New B2.1.35 N/A Plant-Specific Selective Leaching of Existing B2.1.37 Aluminum Bronze N/A Plant-Specific Not used N/A B2.1.38 Protective Coatinq N/A Plant-Specific Monitoring and Existing B2.1.39 Maintenance Proqram ,_I_ I
Enclosure 2 NOC-AE-1 1002758 Page 9 of 78 CHANGE THE LIGHTING DIESEL WAS ADDED TO THE SCOPE OF LRA Table 2.2-1 STP Scoping Results SystemlStructure In-Scope Section 2 Scoping Results Reactor Vessel, Internals, and Reactor Coolant System Pressurizer Yes 2.3.1.3 Reactor Coolant Yes 2.3.1.2 Reactor Core Yes 2.3.1.5 Reactor Vessel and Internals Yes 2.3.1.1 Steam Generator also includes: Yes 2.3.1.4 Steam Generator Secondary Side Engineered Safety Features Containment Spray Yes 2.3.2.1 Integrated Leak Rate Test Yes 2.3.2.2 Residual Heat Removal Yes 2.3.2.3 Safety Injection Yes 2.3.2.4 Auxiliary Systems Chemical and Volume Control Yes 2.3.3.19 Chilled Water HVAC Yes 2.3.3.9 Component Cooling Water Yes 2.3.3.6 Compressed Air Systems also includes: Yes 2.3.3.7 Breathing Air Instrument Air Service Air Containment Hydrogen Monitoring and Combustible Gas Control Yes 2.3.3.16
Enclosure 2 NOC-AE-1 1002758 Page 10 of 78 Table 2.2-1 STP Scoping Results (Continued)
System/Structure In-Scope Section 2 Scoping Results Cranes and Hoists Yes 2.3.3.3 Nonsafety-related Diesel Generators and Auxiliary Fuel Oil, Yes 2.3.3.21 includes:
BOP Diesel Auxiliary Fuel Oil Diesel Generator Building HVAC Yes 2.3.3.15 Electrical Auxiliary Building and Control Room HVAC Yes 2.3.3.10 Essential Cooling Water and Essential Cooling Water Screen Yes 2.3.3.4 Wash Fire Protection Yes 2.3.3.17 Fuel Handling Yes 2.3.3.1 Fuel Handling Building HVAC Yes 2.3.3.11 Lighting Diesel Generator Yes 2.3.3.28 Liquid Waste Processing Yes 2.3.3.22 Mechanical Auxiliary Building HVAC Yes 2.3.3.12 Miscellaneous HVAC, includes: Yes 2.3.3.13 Essential Cooling Water Intake Structure Fire Pump House Miscellaneous systems in-scope ONLY for Criterion a(2) Yes 2.3.3.27 Includes:
Boron Recycling Condensate Storage Condensate includes:
- BOP Chemical Feed
- Condensate Polisher
- Condenser Air Removal Essential Cooling Pond Makeup Gaseous Waste Processing Low Pressure Nitrogen MAB Plant Vent Header (Radioactive)
Nonradioactive Chemical Waste Open Loop Auxiliary Cooling Potable Water and Well Water Secondary Process Sampling Solid Waste Processing Turbine Vents and Drains Nonradioactive Waste Plumbing Drains and Sumps Yes 2.3.3.24 Oily Waste Yes 2.3.3.25
Enclosure 2 NOC-AE-1 1002758 Page 11 of 78 Table 2.2-1 STP Scoping Results (Continued)
SystemlStructure In-Scope Section 2 Scoping Results Primary Process Sampling also includes: Yes 2.3.3.8 Post Accident Sampling Radiation Monitoring (area and process) Mechanical Yes 2.3.3.26 Radioactive Vents and Drains Yes 2.3.3.23 Reactor Containment Building HVAC Yes 2.3.3.14 Reactor Makeup Water Yes 2.3.3.5 Spent Fuel Pool Cooling and Cleanup Yes 2.3.3.2 Standby Diesel Generator and Auxiliaries also includes: Yes 2.3.3.20 Standby Diesel Generator Air Intake Standby Diesel Generator Exhaust Standby Diesel Jacket Water Standby Diesel Generator Lube Oil Standby Diesel Generator Starting Air Standby Diesel Generator Fuel Oil Storage and Transfer Yes 2.3.3.18 Chemical Injection Monitoring and Control No N/A Closed Loop Auxiliary Cooling Water No N/A Fresh Water and Service Water Supply also includes: No N/A Sodium Hypochlorite Fresh Water Service Water Circulating Water also includes: No N/A Seal Water and Priming (Circulating Water)
Circulating Water Screen Wash Turbine Generator Building HVAC No N/A Gas Storage and Supply includes: No N/A Gas CO 2 Storage Gas H 2 Storage Gas N2 High Pressure Supply Miscellaneous HVAC (Not In Scope) No N/A Nonradioactive Waste also includes: No N/A Sewage Treatment Reservoir Makeup and Blowdown also includes: No N/A Reservoir Makeup Pumping RMPF Seal Water RMPF Screen Wash Cooling Water Reservoir Spillway Gates and Blowdown Facilities Water Processing also includes: No N/A Acid Storage and Transfer Caustic Storage and Transfer
Enclosure 2 NOC-AE-1 1002758 Page 12 of 78 Table 2.2-1 STP Scoping Results (Continued)
SystemlStructure In-Scope Section 2 T Scoping
.Results
_________
Steam and Power Conversion System Auxiliary Feedwater Yes 2.3.4.6 Auxiliary Steam System and Boilers Yes 2.3.4.2 Demineralizer Water (Make-up) Yes 2.3.4.4 Electrohydraulic Control Yes 2.3.4.7 Feedwater Yes 2.3.4.3 Main Steam also includes: Yes 2.3.4.1 Main Steam Vents and Drains Header Drain Downstream -
Steam Generator Blowdown also includes: Yes 2.3.4.5 Steam Generator Sludge Lancing and Chemical Cleaning Feed Pump Turbine Lube Oil No N/A Lube Oil Purification Storage and Transfer also includes: No N/A Lube Oil Conditioner Main Turbine No N/A Turbine/Generator Auxiliaries also includes: No N/A Extraction Steam Stator Cooling Water Generator CO 2 and H2 Turbine Gland Seal Heater Drip Heater Vent Main Turbine Lube Oil Turbine Vents and Drains Generator Hydrogen Seal Oil Containments, Structures, and Component Supports Auxiliary Feedwater Storage Tank Foundation and Shell Yes 2.4.10 Containment Building Yes 2.4.1 Control Room Yes 2.4.2 Diesel Generator Building Yes 2.4.3 Electrical Foundations and Structures Yes 2.4.7 Essential Cooling Water Structures also includes: Yes 2.4.9 Essential Cooling Water Intake Structure Essential Cooling Pond and ECW Discharge Fuel Handling Building Yes 2.4.8
Enclosure 2 NOC-AE-1 1002758 Page 13 of 78 Table 2.2-1 STP Scoping Results (Continued)
System/Structure In-Scope Section 2 Scoping Results Mechanical-Electrical Auxiliary Building (MEAB) also includes: Yes 2.4.5 Electrical Auxiliary Building Mechanical Auxiliary Building Isolation Valve Cubicle (Building)
Miscellaneous Yard Areas and Buildings (In-Scope) also includes: Yes 2.4.6 East Gate House Fire pump house Fire water storage tanks foundations Fire water valve structures Lighting Diesel Generator Building and tank buildingq Supports Yes 2.4.11 Turbine Generator Building Yes 2.4.4
Enclosure 2 NOC-AE-1 1002758 Page 14 of 78 Table 2.2-1 STP Scoping Results (Continued)
System/Structure In-Scope Section 2 Scoping Results Miscellaneous Structures includes: No N/A Administration Building Ambulance Building Aux Fuel Oil Transfer Pump Station, tank foundation, and dike Bulk Gas Storage Facility Chemical and Gas Storage Circulating Water Intake Structure Circulating Water Discharge Structure Cold Chemistry Lab East Gate House Electrical Load Center Buildings Emergency Operations Facility Foam Equipment House Fuel Storage Facility Guard Facility, Gates, and Fences Hot Shop and Decontamination Facility Hypochlorination Building Inverter Building Lighting Diesel Generator Building Machine Shop Main Cooling Reservoir Maintenance Coatings Storage Structure Maintenance Lubrication Storage Structure Maintenance Operations Facility Makeup Demineralizer Building Microwave Building NPMM Product Staging Structure North Gate House Nuclear Training Facility (Training and Simulator Building)
Old Reactor Vessel Head Storage Building Old Steam Generator Storage Facility On-Site Staging Facility Refueling Equipment Building (Cement Unloading Building)
Sewage Treatment Building Spillway and Blowdown Facilities Storm Water Drainage System (Including the roof drains)
TSC Diesel Generator Building Temporary Gate House Unit 1 Stop Shop Unit 2 Change Facility Unit 2 Stop Shop Warehouse Annex Warehouse No. 29 (Includes Outage Facility West Gate House Electrical and Instrumentation and Controls 120 VAC Class 1 E Vital Yes N/A 120 VAC Non-IE Vital Yes N/A
Enclosure 2 NOC-AE-1 1002758 Page 15 of 78 Table 2.2-1 STP Scoping Results (Continued)
System/Structure In-Scope Section 2 Scoping Results 125 VDC Class 1E Yes N/A 125 VDC Non-Class 1E Yes N/A 480 VAC Non-i E Load Centers Yes N/A 480 VAC Class 1E Load Centers Yes N/A 480 VAC Class 1E MCC and Distribution Panels Yes N/A 480 VAC Non-lE MCC and Distribution Panels Yes N/A 4K VAC 1E Power Yes N/A 13.8K VAC Aux Power Yes N/A 7300 Processor Support Yes N/A Communication Yes N/A Emergency AC Lighting Yes N/A Emergency DC Lighting Yes N/A Engineered Safety Features Actuation Yes N/A Fire Alarm and Detection Yes N/A Incore Instrumentation Yes N/A Main and Auxiliary Transformers Yes N/A Nuclear Instrumentation Yes N/A Panels and Cabinets Yes N/A Post Accident Monitoring Yes N/A Radiation Monitoring (Area and Process) Yes N/A Rod Control Yes N/A Solid State Protection Yes N/A Standby Transformer (Startup) Yes N/A Switchyard Yes N/A 208/120 VAC Non Class 1E Non-Vital System - No N/A
Enclosure 2 NOC-AE-1 1002758 Page 16 of 78 Table 2.2-1 STP Scoping Results (Continued)
SystemlStructure In-Scope Section 2 Scoping Results 250 VDC Non-Class 1E No N/A 48 VDC Non-Class 1 E No N/A 4K VAC Non-class 1E Power No N/A 13.8K V Emergency Power No N/A Annunciator No N/A Cathodic Protection No N/A Diesel Generator (Lighting) NG N/A Electrical Miscellaneous. No N/A Emergency Transformer No N/A Environmental (Meteorological Tower) No N/A ESF Status Monitoring No N/A Freeze Protection No N/A Generator Isophase Bus and Aux No N/A Grounding and Lightning Protection No N/A Integrated Computer No N/A Loose Parts Monitoring No N/A Main Generator (w/o Aux) No N/A Main Generator Exciter No N/A Normal AC Lighting No N/A Plant Computer No N/A River Services, Transformer and Switchgear No N/A Rod Position Indicator No N/A Seismic Monitoring No N/A Vibration Monitoring No N/A
Enclosure 2 NOC-AE-1 1002758 Page 17 of 78 2.3.3 Auxiliary Systems This section addresses scoping and screening results for the following systems:
- Fuel handling (Section 2.3.3.1)
- Spent fuel pool cooling and cleanup (Section 2.3.3.2)
" Cranes and hoists (Section 2.3.3.3)
" Essential cooling water and ECW screen wash (Section 2.3.3.4)
- Reactor makeup water (Section 2.3.3.5)
" Component cooling water (Section 2.3.3.6)
- Compressed air (Section 2.3.3.7)
- Primary process sampling (Section 2.3.3.8)
- Chilled water HVAC (Section 2.3.3.9)
- Electrical auxiliary building and control room HVAC (Section 2.3.3.10)
- Fuel handling building HVAC (Section 2.3.3.11)
- Mechanical auxiliary building HVAC (Section 2.3.3.12)
- Miscellaneous HVAC (In Scope) (Section 2.3.3.13)
- Reactor containment building HVAC (Section 2.3.3.14)
- Standby diesel generator building HVAC (Section 2.3.3.15)
- Containment hydrogen monitoring and combustible gas control (Section 2.3.3.16)
- Fire protection (Section 2.3.3.17)
- Standby diesel generator fuel oil storage and transfer (Section 2.3.3.18)
- Chemical and volume control (Section 2.3.3.19)
- Standby diesel generator and auxiliaries (Section 2.3.3.20)
- Nonsafety-related diesel generators and auxiliary fuel oil (Section 2.3.3.21)
" Liquid waste processing (Section 2.3.3.22)
" Radioactive vents and drains (Section 2.3.3.23)
" Nonradioactive waste plumbing drains and sumps (Section 2.3.3.24)
- Oily waste (Section 2.3.3.25)
- Radiation monitoring (area and process) mechanical (Section 2.3.3.26)
- Miscellaneous systems in-scope ONLY for Criterion a(2) (Section 2.3.3.27)
Includes:
Boron recycling Condensate storage Condensate, also includes:
- BOP chemical feed
- Condensate polisher
- Condenser air removal Essential cooling pond makeup Gaseous waste processing Low pressure nitrogen MAB plant vent header (radioactive)
Nonradioactive chemical waste Open loop auxiliary cooling Potable water and well water Secondary process sampling Solid waste processing
Enclosure 2 NOC-AE-1 1002758 Page 18 of 78 Turbine vents and drains Liihtinq diesel ienerator (Section 2.3.3.28)
Enclosure 2 NOC-AE-1 1002758 Page 19 of 78 2.3.3.28 Lighting Diesel Generator System
System Description
The purpose of the lighting diesel generator system is to provide lightingq to operator access routes to various safe shutdown components requiring travel outside of buildings. This lighting is powered from the lighting diesel generator during loss of offsite power.
The lighting diesel generator system consists of piping, tanks, and valves.
System Intended Functions Portions of the lighting diesel -generator system are within the scope of license renewal to SUDDOrt fire protection reauirements based UoOn criteria of 10 CFR 54.4(a)(3).
STP UFSAR References None License Renewal Boundary Drawings The license renewal drawing for the lighting diesel generator system is listed below:
LR-STP-DB-6Q170F0001 1-1 Component-Function Relationship Table The component types subiect to aging management review are indicated in Table 2.3.3 Liqhtinq Diesel Generator System.
ThhI~ 9 .~ ~-9R I inhtinn fli1 ~ c~) (4~n~rntnr ~
Component Type Intended Function I Closure Bolting Pressure Boundary
. . ... .............. .......-------
.......... r Boun-a- . . . .. . .... . .. .......... . . . . .. .
lFilame Arrestor---..... 'Pressure Boundary Flexible Hoses 'PressureBoundary
..... . .... .. .. . P r s s r B..... o n..........
d r ..................
........ . . . . . .
Pressure Boundary Silencer - _ressuij Boundary Tank Pressure Boundary ,,
STubing Pressure Boundary
.......... Pressure oun ary ..............
Valve
Enclosure 2 NOC-AE-1 1002758 Page 20 of 78 The AMR results for these component types are provided in Table 3.3.2-28, Auxiliary Systems -
Summary of Aging Management Evaluation - Lighting Diesel Generator System.
2.4.6 Miscellaneous Yard Areas and Buildings (In Scope)
Structure Description The miscellaneous yard areas and buildings (in scope) include the following structures:
- east gate house
- fire pump house
- fire water storage tanks foundations
- fire water valve structures
- lighting diesel generator building and tank building The east gate house is a steel-framed building with a metal roof and a concrete foundation. It houses administrative offices and various mechanical and electrical support systems.
The fire pump house is a metal building with a sheet metal roof on a concrete foundation housing three fire pumps, each separated by reinforced concrete walls. The structure is common to both Units 1 and 2.
The fire water storage tanks foundations are reinforced concrete ring foundations. The fire water storage tanks are evaluated separately with their respective system. These two foundations are common to both Units 1 and 2.
The fire water valve structures are metal buildings with sheet metal roofing on a concrete foundation. There are three valve structures per unit.
The lighting diesel generator buildinq and tank buildinq are masonry buildings with metal roofs and concrete foundations. They house the lighting diesel generator, the diesel fuel supply tank, and various mechanical and electrical support systems.
Structure Intended Function The miscellaneous yard areas and buildings (in scope) shelter and protect nonsafety-related SSCs whose failure could prevent performance of a safety-related function. Therefore, the miscellaneous yard areas and buildings (in scope) are within the scope of license renewal based on the criterion of 10 CFR 54.4(a)(2).
The fire pump house provides fire barriers and structural support for fire suppression components. The fire water storage tank foundations and fire water valve structures provide structural support and shelter/protection for fire protection components. The lighting diesel generator building, the tank buildingq, and the east gate house provide structural support and shelter/protection for SSCs required to meet fire protection commitments. Therefore, these structures are within the scope of license renewal based on the criteria of 10 CFR 54.4(a)(3).
Enclosure 2 NOC-AE-1 1002758 Page 21 of 78 STP UFSAR References Additional details of the miscellaneous yard areas and buildings (In Scope) are included in UFSAR Sections 9.5.1.2.1, 9.5.1.2.17.2 and Tables 1.1-3, 3.2.A-1.
Enclosure 2 NOC-AE-1 1002758 Page 22 of 78 Component-Functional Relationship Table The components types subject to aging management review are indicated in Table 2.4-6 0 Miscellaneous Yard Areas and Buildings (In Scope)
Table 2.4-6 Miscellaneous Yard Areas and Buildings (In Scope)
I Component Type I Intended Function Caulking and Sealant .Flood Barrier
!Shelter, Protection lCompressible Joints and Seals Shelter, Protection
.- I Concrete Block (Masonry Walls) Shelter, Protection Structural Support Concrete Elements Fire Barrier Flood Barrier Missile Barrier
!Shelter, Protection
- Structural Support Doors ýShelter, Protection Fire Barrier Doors 'Fire Barrier
-Shelter, Protection Fire Seals Fire Barrier
.Gypsum and Plaster Barrier Shelter, Protection Metal Siding ;Shelter, Protection Penetrations Electrical ... -!Structural Support Penetrations Mechanical Structural Support
,Structural Metals :Shelter, Protection
~ic!Structural Support iStructural Steel iShelter, Protection
'Structural Support ..
The AMR results for these components types are provided in Table 3.5.2-6, Containments, Structures, and Component Supports - Summary of Aging Management Evaluation-Miscellaneous Yard Areas and Buildings (In Scope).
Enclosure 2 NOC-AE-1 1002758 Page 23 of 78 2.4.7 Electrical Foundations and Structures Structure Description The foundations for the main, auxiliary, and standby transformers are reinforced concrete pads founded on undisturbed soil and/or engineered structural backfill. All oil-filled transformers are provided with pits to catch any transformer oil which may be released due to a leak or rupture.
Outdoor switchgear, in the 345 kV switchyard, and all equipment from the main and standby transformers up to the first circuit breakers in the 345 kV switchyard, are supported on reinforced concrete pads founded on undisturbed soil and/or engineered structural backfill.
The switchyard control building is a single story metal-sided structure with a sheet metal roof.
The building is supported by a reinforced concrete foundation on structural backfill. The switchyard control building houses equipment required by SBO requirements.
All of the transmission towers up to the first circuit breakers in the 345 kV switchyard are steel towers. The transmission towers are founded on reinforced concrete bases supported on undisturbed soil and/or engineered structural backfill.
The yard lightin.q is mounted on high mast steel poles founded on reinforced concrete bases supported on undisturbed soil and/or engineered structural backfill.
The Class 1 E underground electrical raceway system provides electrical distribution from the MEAB to the essential cooling water intake structure. The raceway system consists of banks of PVC conduits in a spaced arrangement encased in reinforced concrete. Manholes are provided along these duct banks for cable installation and access.
The main and auxiliary transformers are separated by concrete fire barrier walls.
Structure Intended Function The Class 1 E underground electrical raceway system provides structural support and shelter/protection of components relied upon to provide the capability to shutdown the reactor and maintain it in a safe shutdown condition. Therefore, it is within the scope of license renewal based on the criteria of 10 CFR 54.4(a)(1).
The concrete pads for the main transformers, auxiliary transformers, standby transformers, the concrete pads for the outdoor switchgear, the switchyard control building, and concrete bases for the transmission towers, provide structural support for SSCs required for station blackout recovery. The concrete fire barrier walls separating the main and auxiliary transformers provide spatial separation and fire barriers to meet the requirements for fire protection. The concrete duct banks and manholes provide structural support, shelter and protection for SSCs required for fire protection. The high mast yard lighting poles provide structural support for SSCs required to meet fire protection commitments. Therefore, they are within the scope of license renewal based on the criteria of 10 CFR 54.4(a)(3).
Enclosure 2 NOC-AE-1 1002758 Page 24 of 78 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS 3.3.1 Introduction Section 3.3 provides the results of the aging management reviews (AMRs) for those component types identified in Section 2.3.3, Auxiliary Systems, subject to AMR. These systems are described in the following sections:
- Fuel handling system (Section 2.3.3.1)
- Spent fuel pool cooling and cleanup system (Section 2.3.3.2)
- Cranes and hoists (Section 2.3.3.3)
- Essential cooling water and ECW screen wash system (Section 2.3.3.4)
- Reactor makeup water system (Section 2.3.3.5)
- Component cooling water system (Section 2.3.3.6)
- Compressed air system (Section 2.3.3.7)
- Primary process sampling system (Section 2.3.3.8)
- Chilled water HVAC system (Section 2.3.3.9)
- Electrical auxiliary building and control room HVAC system (Section 2.3.3.10)
- Fuel handling building HVAC system (Section 2.3.3.11)
- Mechanical auxiliary building HVAC system (Section 2.3.3.12)
- Miscellaneous HVAC systems (In Scope) (Section 2.3.3.13)
- Containment building HVAC system (Section 2.3.3.14)
- Standby diesel generator building HVAC system (Section 2.3.3.15)
- Containment hydrogen monitoring and combustible gas control system (Section 2.3.3.16)
- Fire protection system (Section 2.3.3.17)
- Standby diesel generator fuel oil storage and transfer system (Section 2.3.3.18)
- Chemical and volume control system (Section 2.3.3.19)
- Standby diesel generator and auxiliaries system (Section 2.3.3.20)
- Nonsafety-related diesel generators and auxiliary fuel oil system (Section 2.3.3.21)
- Liquid waste processing system (Section 2.3.3.22)
- Radioactive vents and drains system (Section 2.3.3.23)
- Nonradioactive waste plumbing drains and sumps system (Section 2.3.3.24)
Enclosure 2 NOC-AE-1 1002758 Page 25 of 78
- Oily waste system (Section 2.3.3.25)
- Radiation monitoring (area and process) mechanical system (Section 2.3.3.26)
- Miscellaneous Systems in scope ONLY for Criterion 10 CFR 54.4(a)(2) (Section 2.3.3.27) includes:
Boron recycling Condensate storage Condensate Essential cooling pond makeup Gaseous waste processing Low pressure nitrogen MAB plant vent header (radioactive)
Nonradioactive chemical waste Open loop auxiliary cooling Potable water and well water Secondary process sampling Solid waste processing Turbine vents and drains Lighting diesel generator system (Section 2.3.3.28)
Table 3.3.1, Summary of Aging Management Evaluations in Chapter VII of NUREG-1801 for Auxiliary Systems, provides the summary of the programs evaluated in NUREG-1801 that are applicable to the component types in this section. Table 3.3.1 uses the format of Table 1 described in Section 3.0.
3.3.2 Results The following tables summarize the results of the AMR for the systems in the Auxiliary Systems area:
0 Table 3.3.2-1 Auxiliary Systems - Summary of Aging Management Evaluation
- Fuel Handling System
- Table 3.3.2-2 Auxiliary Systems - Summary of Aging Management Evaluation
- Spent Fuel Pool Cooling and Cleanup System
& Table 3.3.2-3 Auxiliary Systems - Summary of Aging Management Evaluation
- Cranes and Hoists
- Table 3.3.2-4 Auxiliary Systems - Summary of Aging Management Evaluation
- Essential Cooling Water and ECW Screen Wash System
- Table 3.3.2-5 Auxiliary Systems - Summary of Aging Management Evaluation
- Reactor Makeup Water System
- Table 3.3.2-6 Auxiliary Systems - Summary of Aging Management Evaluation
- Component Cooling Water System
- Table 3.3.2-7 Auxiliary Systems - Summary of Aging Management Evaluation
- Compressed Air System
Enclosure 2 NOC-AE-1 1002758 Page 26 of 78
- Table 3.3.2-8 Auxiliary Systems - Summary of Aging Management Evaluation
- Primary Process Sampling System
- Table 3.3.2-9 Auxiliary Systems - Summary of Aging Management Evaluation
- Chilled Water HVAC System
- Table 3.3.2-10 Auxiliary Systems- Summary of Aging Management Evaluation
- Electrical Auxiliary Building and Control Room HVAC System 0 Table 3.3.2-11 Auxiliary Systems - Summary of Aging Management Evaluation
- Fuel Handling Building HVAC System
- Table 3.3.2-12 Auxiliary Systems - Summary of Aging Management Evaluation
- Mechanical Auxiliary Building HVAC System
- Table 3.3.2-13 Auxiliary Systems - Summary of Aging Management Evaluation
- Miscellaneous HVAC Systems (In Scope)
- Table 3.3.2-14 Auxiliary Systems - Summary of Aging Management Evaluation
- Containment Building HVAC System 0 Table 3.3.2-15 Auxiliary Systems - Summary of Aging Management Evaluation
- Standby Diesel Generator Building HVAC System
- Table 3.3.2-16 Auxiliary Systems - Summary of Aging Management Evaluation
- Containment Hydrogen Monitoring and Combustible Gas Control System
- Table 3.3.2-17 Auxiliary Systems - Summary of Aging Management Evaluation
- Fire Protection System 0 Table 3.3.2-18 Auxiliary Systems - Summary of Aging Management Evaluation
- Standby Diesel Generator Fuel Oil Storage and Transfer System
- Table 3.3.2-19 Auxiliary Systems - Summary of Aging Management Evaluation
- Chemical and Volume Control System 0 Table 3.3.2-20 Auxiliary Systems - Summary of Aging Management Evaluation
- Standby Diesel Generator and Auxiliaries System
- Table 3.3.2-21 Auxiliary Systems - Summary of Aging Management Evaluation
- Nonsafety-related Diesel Generators and Auxiliary Fuel Oil System
- Table 3.3.2-22 Auxiliary Systems - Summary of Aging Management Evaluation
- Liquid Waste Processing System
- Table 3.3.2-23 Auxiliary Systems - Summary of Aging Management Evaluation
- Radioactive Vents and Drains System
- Table 3.3.2-24 Auxiliary Systems - Summary of Aging Management Evaluation
- Nonradioactive Waste Plumbing Drains and Sump System
- Table 3.3.2-25 Auxiliary Systems - Summary of Aging Management Evaluation
- Oily Waste System
- Table 3.3.2-26 Auxiliary Systems - Summary of Aging Management Evaluation
- Radiation Monitoring (area and process) Mechanical System
- 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)
Enclosure 2 NOC-AE-1 1002758 Page 27 of 78 0 Table 3.3.2-28 Auxiliary Systems - Summary of Aging Management Evaluation
- Lighting Diesel Generator System These tables use the format of Table 2 discussed in Section 3.0.
3.3.2.1.28 Lighting Diesel Generator Materials The materials of construction for the lighting diesel generator component types are:
- Carbon Steel
- Elastomer
- Stainless Steel Environment The lighting diesel generator component types are exposed to the following environments:
- Atmosphere/ Weather
- Buried
- Closed Cycle Cooling Water
- Diesel Exhaust
- Fuel Oil
- Lubricating Oil
- Plant Indoor Air Aging Effects Requiring Management The following lighting diesel generator aging effects require management:
- Cracking
- Hardening and loss of strength
- Loss of material
- Loss of preload Aging Management Programs The following aging management programs manage the aging effects for the lighting diesel generator component types:
- Bolting Integrity (B2.1.7)
Enclosure 2 NOC-AE-1 1002758 Page 28 of 78
- Buried Piping and Tanks Inspection (B2.1.18)
- 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)
- Selective Leachina of Materials (B2.1.17)
Enclosure 2 NOC-AE-1 1002758 Page 29 of 78
. Weather (Ext)
Closure Boltin- !Atmosphere/ !Loss of material 'Bolting Integrity Vll.I-1 . 3.3.143 B
!Weather (Ext) (132.1.7)
- Closure Bolting Plant Indoor Air Loss of material Boltinq Integrity Vll.l-4 .3.3.1.43 B
(Ext) - _(B2.1.7)
,Closure Bolting Plant Indoor Air Loss of preload 'Bolting Integrity VII -5 '3.3.1.45 B
_L_(B2..7) I 7 Flame Arrestor Fuel Oil (Int) Loss of material Fuel Oil Chemistry VII.H1-10 3.3.1.20 B (B2.1.14) and One-iTime Inspection
-- +--I
((B2.1.16)
Flame Arrestor tareon Plant Indoor Air Loss of material i.External Surfaces VII.I-8 3.3.1.58 lB (Ext) Monitoring Program
((B2.1.20)
I FTexible Hoses F=astomer- Lubricating Oil None INone None None ... [2 Flexible Hoses .P-B Hastomer Plant Indoor Air Hardening and External Surfaces - VII.F1-7 - .3.3.1.11 E (Ext) loss of strength Monitoring Program Carbon
_____
Atmosphere Loss of 7~te~ii(132.1.20)
External Surfaces
__
MVII.H1-8 3.3.1.60 _B Steel Weather (Ext) Monitoring Program Pin PB . ... . . . . .(B2.1.20)
Carbon Buried (Ext) Loss of material iBuried Piping and VII.H1-9 3.3.1.19 1 Steel 'Tanks Inspection Pn 1PB _(B2.!.18) _ _ _ _
Carbon Diesel Exhaust Loss of material Inspection of Internal VII.H2-2 3.3.1.18 E Steel Int) Surfaces in Miscellaneous Piping iand Ducting - I
__Components .(B2. 1.22)
Enclosure 2 NOC-AE-1 1002758 Page 30 of 78 Table 3.3.2-28Auxiliarv Svstems - Summarv of Aaina Manaaement Evaluation - Liahtina Diesel GeneratorSystem Component TYpO Intended Material Environment AMina Effect Aning Manaaement NUREG Table I Notes Function Requirina Prouram 1801 Vol Item Manaumn~t 12 Item I Piping 'PB Carbon Fuel Oil (Int) ,Loss of material Fuel Oil Chemistry VII.H1-10 3.3.1.20 B Steel (B2.1.14) and One-Time Inspection 1(B2.1.16)
- pj~j~g .Loss of material Lubricatinq Oil Analysis VII.H2-20 PB Carbon Lubricating Oil 3.3.1.14 i Steel (Int) (B2.1.23) and One-i Time Inspection of (B2.1.16)
Pining PB. Carbon Plant Indoor Air Loss of material External Surfaces VAi.-1-8 3.3.1.58 B Steel (Ext) Monitorinq Pro-gram (B2.1.20) ........
V~ing Stainless Diesel Exhaust Crackingq ;Inspection of Internal VII.H2-1 .3.3.1.06 Steel j(Int) Surfaces in Miscellaneous Piping and Ducting Components (B2.1.22)_
PB Stainless Diesel Exhaust Loss of material Inspection of Internal VII.H2-2 .3.3.1.8 E ISteel (Int) Surfaces in Miscellaneous Piping and Ducting Components (B2.1.22)
'PB Stainless Plant Indoor Air r.
None None VII.J-15 3.3.1.94 A_
__ ~ Steel (Ext) __
Silencer PB Carbon Atmosphere/ Loss of material External Surfaces VI 1.l-9 .3.3.1.58 ISteel Weather (Ext) :Monitoring Program i ' .- i..........
... (B2.1.20)
Silencer B Carbon Diesel Exhaust Loss of material Inspection of Internal VII.H2-2 3.3.1.18 E Steel (Int) Surfaces in
.Miscellaneous Piping and Ducting
.CormPonents (g2.1.22)
Enclosure 2 NOC-AE-1 1002758 Page 31 of 78 Table 3.3.2-28Auxiliary Systems - Summary of Aging Management Evaluation- Lýghting Diesel GeneratorSystem Component Type I Intended Material Environment I Agina Effect Aging Management NUREG I Table I Notes Function Reauirina Program 1801 Vol Item Management 2 Item j
'Tank IPB Carbon Fuel Oil (Int) Loss of material Fuel Oil Chemistry 'VII.H1-10 3.3.1.20 B Steel ((B2.1.14) and One-Time Inspection Tank ........ PB iCaro Lubricating Oil ((B2.1.16)
!Loss of material -Lubricating Oil Analysis VI1.-12-20 3.3.1.14 11
- Steel ý(Int) (B2.1.23) and One-Time Inspection
- (B2.1.16)
Tank PPB Carbon iPlant Indoor Air Loss of material External Surfaces .VIl.1-8 3.3.1.58 B Steel E(Ext) Monitoring Program
.Tank PB Carbon Plant Indoor Air (B2.1.20)
Loss of material Inspection of Internal VII.H2-21 3.3.1.71 B Steel !(Int) Surfaces in Miscellaneous Piping
- and Ducting Components (B2.1.22)
Tlubing PStainless Fuel Oil (Int) Loss of material Fuel Oil Chemistry VII.1H2-16 3j3. 132 B ..
Steel .(B2.1.14) and One-Time Inspection
_. !.~~~(B2.:1. 16_)
.. ...... ..... . . B-
- Tubin .......... ...-5B"...........[ a~n ........1*
.. ~ n o Pr Tubing - PB Stainless IPlant Indoor Air *None iNone VII.J-15 3.3.1.94
- __ 'Steel E.t.
Valve PBrbon Fuel Oil (Int)
Loss of material zFuel Oil Chemistry VII.H1-10 .3.3.1.20 Steel (B2.1.14) and One-
. ....... ..... ...... _ -. .i --.- '-~L . . -
- Time Inspection (B2.1.16)
Valve PB Carbon Lubricating Oil Loss of material -Lubricating Oil Analysis .VII.1H2-20 3.3.1.14
!Steel (Int) (B2.1.23) and One-Time Inspection (B2.1.16)
Valve PB ICarbon Plant Indoor Air .Loss of material External Surfaces VII.l-8 3.3.1.58 I BTh Steel (Ext) Monitoringq Program (B2.1.20).
Enclosure 2 NOC-AE-1 1002758 Page 32 of 78 Table 3.3.2-28Auxiliary Systems - Summary of Aging Management Evaluation - LLghting Diesel GeneratorSystem Component Type Intended Material Environment Aging Effect I Agina Management NUREG I Table I Notes IFunction IRequiring I Proaram 1801 Vol I Item
___J ] ~Manaaement 2 I~tem _ _ __ _
Valve 1PB Carbon IPlant Indoor Air Loss of material Inspection of Internal VII.H2-21 3.3.1.71 IB Steel (Int) Surfaces in Miscellaneous Piping and Ducting Components (B2.1.22)
Valve Loss of material Closed-Cycle Cooling VII.F1-15 .3.3.1.51 Alloy (>1 5 %,Coolingq Water Water System (B2. 1.10) . . .
Valve PB Copper Closed Cycle 'Loss of material .Selective Leaching of VII.H1-4 3.3.1.84 B AIIoy(> 15% Cooling Water Materials (B2.1.17)
, Zinc) ___(Int)
Valve PB Copper Lubricating Oil Loss of material Lubricating Oil Analysis VII.H2-10 :3.3.1.26
!Alloy (> 15% O(nt)
((B2.1.23) and One-i Zinc) Time Inspection (B2.V Ne 16).
- None IVIII.I-2 A Valve 1PB3 Copper -Plant Indoor Air None 3.4.1.41 Alloy (> 15% (Ext)
...
,. .... .. .. z~in c) _ ...... . .. . . .
Notes for Table 3.3.2-28 Standard Notes A Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.
B Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.
E Consistent with NUREG-1801 for material, environment, and aging effect, but a different aging management program is credited or NUREG-1801 identifies a plant-specific aging management program.
G Environment not in NUREG-1 801 for this component and material.
H Aging effect not in NUREG-1801 for this component, material and environment combination.
Plant Specific Notes 1 Loss of Preload is conservatively considered to be applicable for all closure bolting.
2 This non NUREG-1 801 line item was created because there is no line item for a component made of elastomer with a lubricating oil internal environment.
Enclosure 2 NOC-AE-1 1002758 Page 33 of 78 3.5.2.1.6 Miscellaneous Yard Areas and Buildings (In Scope)
Materials The materials of construction for the miscellaneous yard areas and buildings component types are:
- Carbon Steel
- Concrete
- Concrete Block (Masonry Walls)
- Elastomer
- Gypsum/Plaster Environment The miscellaneous yard areas and buildings component types are exposed to the following environments:
- Atmosphere/ Weather (Structural)
- Buried (Structural)
- Encased in Concrete
- Plant Indoor Air (Structural)
Aging Effects Requiring Management The following miscellaneous yard areas and buildings aging effects require management:
- Concrete cracking and spalling
- Cracking
- Cracking due to expansion
- Cracking, loss of bond, and loss of material (spalling, scaling)
- Cracks and distortion
- Increase in porosity and permeability, cracking, loss of material (spalling, scaling)
- Increased hardness, shrinkage and loss of strength
- Loss of material
- Loss of material (spalling, scaling) and cracking
- Loss of sealing
Enclosure 2 NOC-AE-1 1002758 Page 34 of 78 Aging Management Programs The following aging management programs manage the aging effects for the miscellaneous yard areas and buildings component types:
- Fire Protection (B2.1.12)
- Masonry Wall Pro-gram (B2.1.31)
- Structures Monitoring Program (B2.1.32)
Enclosure 2 NOC-AE-1 1002758 Page 35 of 78 Table 3.5.2-6 Containments, Structures, and Component Supports - Summary of Aging Management Evaluation-Miscellaneous Yard Areas and Buildings Component Intended Material Environment Aging Effect Type Function Requiring
!!_[ _Management Caulking and iFLB, SH ýElastomer Atmosphere/ Loss of sealing ztructures monitoring Sealant !Weather Program (B2.1.32) j(Structural) (Ext) ,
-Caulking'andF-l..... iLE 31Sjj Elastomer !Plant Indoor Air Loss of sealing Structures Monitoring . I.A6-12 I :3.5.1.44 A J............ l(Structural)_(Ext)_j_2 !Program (132.1.32)
'Sealant iCompressible !SH SElastomer 'Plant Indoor Air Loss of sealing Structures Monitoring III.A6-12 3.5.1.44 A Joints and 1(Structural) (Ext) Program (82.1.32)
Seals Atmosphere/ 13.5.1.43 __
Cooncrete Block-**S*..
(Masonry Concrete Weather br-a-cking 1Masonry (B2.1.31)
Wall Program III.A3-11 Walls) (Masonry !(Structural) (ED IWalls.).
3.5.1.43 A Concrete Block SH SS Concrete Plant Indoor Air Cracking hMasonryWall Proqram II1.A3-11 (Masonry Block (Structural) (Ext) (B2.1.31)
(Masonry Concrete iFB, MB, -Concrete iAtmosphere/ Cracking due to Structures Monitoring II1.A3-2 :3.5.1.27 Elements ýSH, SS Weather expansion Program (B2.1.32)
(_Structural) (Ext) .
Enclosure 2 NOC-AE-1 1002758 Page 36 of 78 AI.14 FUEL OIL CHEMISTRY The Fuel Oil Chemistry program manages loss of material on the internal surface of components in the standby diesel generator (SDG) fuel oil storage and transfer system, diesel fire pump fuel oil system, lighting diesel generator system, and balance of plant (BOP) fuel oil system. The program includes (a) surveillance and monitoring procedures for maintaining fuel oil quality by controlling contaminants in accordance with the Technical Specifications and applicable ASTM Standards, (b) periodic draining of water from fuel oil tanks, (c) visual inspection of internal surfaces during periodic draining and cleaning, (d) ultrasonic wall thickness measurement or pulsed eddy current wall thickness measurement of fuel oil tank bottoms during periodic draining and cleaning, and (e) inspections of new fuel oil before it is introduced into the fuel oil tanks.
The effectiveness of the program is verified under the One-Time Inspection program (Al.16).
Enclosure 2 NOC-AE-1 1002758 Page 37 of 78 B2.1.14 Fuel Oil Chemistry Program Description The Fuel Oil Chemistry program manages loss of material on the internal surface of components in the standby diesel generator (SDG) fuel oil storage and transfer system, diesel fire pump fuel oil system, lighting diesel generator system, and balance of plant (BOP) fuel oil system. The program includes (a) surveillance and monitoring procedures for maintaining fuel oil quality by controlling contaminants in accordance with the Technical Specifications and applicable ASTM Standards, (b) periodic draining of water from fuel oil tanks, (c) visual inspection of internal surfaces during periodic draining and cleaning, (d) ultrasonic wall thickness measurement or pulsed eddy current wall thickness measurement of fuel oil tank bottoms during periodic draining and cleaning, and (e) inspection of new fuel oil before it is introduced into the fuel oil tanks.
Fuel oil quality is maintained by monitoring and controlling fuel oil contaminants in accordance with the Technical Specifications and applicable ASTM Standards. This is accomplished by periodic sampling and chemical analysis of the fuel oil inventory at the plant, and sampling, testing, and analysis of new fuel oil prior to introduction into the fuel oil storage tanks. Initial samples of new fuel oil are inspected for water and entrained foreign material as precautions during the delivery process to avoid introducing contaminants. If a sample appears unsatisfactory, delivery is discontinued or not allowed.
The One-Time Inspection program (B2.1.16) is used to verify the effectiveness of the Fuel Oil Chemistry program.
NUREG-1801 Consistency The Fuel Oil Chemistry program is an existing program that, following enhancement, will be consistent, with exception to NUREG-1801,Section XI.M30, Fuel Oil Chemistry.
Exceptions to NUREG-1801 Program Elements Affected:
Scope of Program (Element 1) and Acceptance Criteria(Element 6)
NUREG-1801 states that fuel oil quality is maintained in accordance with ASTM Standards D1796, D2276, D2709, D6217, and D4057; ASTM Standards D6217 and Modified D2276, Method A are used for guidance for determination of particulates. The modification to D2276 consists of using a filter with a pore size of 3.0 microns, instead of 0.8 micron. STP program specifies fuel oil particulate concentrations are measured using a 0.8 micron nominal pore size filter, in accordance with ASTM-D2276. STP Technical Specification 6.8.3.i.3 specifies using a test method based on ASTM-D2276 to assure total particulate concentration is < 10mg/l.
The basis for use of ASTM-D2276 instead of ASTM-D6217 is the following: ASTM-D2276 provides guidance on determining particulate contamination using a field monitor. It provides for rapid assessment of changes in contamination level without the time delay required for rigorous laboratory procedures. ASTM-D6217 provides guidance on determining particulate
Enclosure 2 NOC-AE-1 1002758 Page 38 of 78 contamination by sample filtration at an off-site laboratory. Neither method contains acceptance criteria or is more stringent than the other. ASTM-D2276 is an accepted method of determining particulates, a method recommended by ASTM-D975, and STP is committed by Technical Specification to follow its guidance.
Scope of Program(Element 1), ParametersMonitored or Inspected (Element 3), and Acceptance Criteria(Element 6)
NUREG-1 801 states that ASTM-D2709 is used for guidance in determining water and sediment contamination in diesel fuel. STP uses only ASTM-D1 796, not ASTM-D2709, for determining water and sediment contamination in diesel fuel. The testing conducted using ASTM-D1 796 gives quantitative results, whereas ASTM-D2709 testing gives only pass-fail results. Therefore, the ASTM-D1796 method gives more descriptive information about the fuel oil condition than the ASTM-D2709 method.
NUREG-1801 states that ASTM-D4057 is used for guidance on oil sampling. This standard requires that multilevel sampling be performed for tanks the size of the SDG fuel oil storage tanks. The Fuel Oil Chemistry program is focused on managing the conditions that cause general, pitting, and microbiologically-influenced corrosion (MIC) of the diesel fuel tank internal surfaces. The fuel oil contaminants settle at the bottom of the tank and are removed along with the water that has settled on the bottom. The fuel oil contaminants settle to the bottom of the tank, so only the bottom is sampled for contaminant concentrations. The fuel oil in the other levels of the tank contains less contaminants per volume than the bottom, making sampling away from the bottom ineffective in managing fuel oil contaminants.
ParametersMonitored or Inspected (Element 3) and Acceptance Criteria(Element 6)
NUREG-1 801 states that a filter with a pore size of 3.0 microns will be used in the determination of particulates. STP uses a filter with a pore size of 0.8 micron per ASTM-D2276. STP Technical Specifications provide for the use of ASTM-D2276 for the analysis of fuel oil. Using a smaller pore size is a more conservative inspection, since more contaminants will be captured when using a filter with a smaller pore size. Thus, a filter with a smaller pore size than 3.0 microns is acceptable in the inspection of fuel oil contaminant concentrations.
Enhancements Prior to the period of extended operation, the following enhancements will be implemented in the following program elements:
Scope of Program(Element 1)
Procedures will be enhanced to extend the scope of the program to include the SDG fuel oil drain tanks.
Enclosure 2 NOC-AE-1 1002758 Page 39 of 78 Scope of Program(Element 1) and Preventive Actions (Element 2)
Procedures will be enhanced to check and remove the accumulated water from the fuel oil drain tanks, day tanks, and storage tanks associated with the SDG, BOP, lighting diesel -generator, and fire water pump diesel generators. A minimum frequency of water removal from the fuel oil tanks will be included in the procedure.
Preventive Actions (Element 2), ParametersMonitored or Inspected (Element 3), and Detection of Aging Effects (Element 4)
Procedures will be enhanced to include 10-year periodic draining, cleaning, and inspection for corrosion of the SDG fuel oil drain tanks, li-ghting diesel generator fuel oil tank, and diesel fire pump fuel oil storage tanks.
Procedures will be enhanced to inspect the BOP diesel generator fuel oil day tanks and the li-ghtingq diesel generator fuel oil tank for internal corrosion.
Procedures will be enhanced to require periodic testing of the lighting diesel generator fuel oil tank and the SDG and diesel fire pump fuel oil storage tanks for microbiological organisms.
ParametersMonitored or Inspected (Element 3), Monitoring and Trending (Element 5), and Acceptance Criteria(Element 6)
Procedures will be enhanced to require analysis for water, biological activity, sediment, and particulate contamination of the diesel fire pump fuel oil storage tanks, lighting diesel generator fuel oil tank, and the BOP diesel generator fuel oil day tanks on a quarterly basis.
Detection of Aging Effects (Element 4)
Procedures will be enhanced to conduct ultrasonic testing or pulsed eddy current thickness examination to detect corrosion-related wall thinning once on the tank bottoms for the SDG and diesel fire pump fuel oil storage tanks, and the BOP diesel generator fuel oil day tanks.
Monitoring and Trending (Element 5)
Procedures will be enhanced to incorporate the sampling and testing of the diesel fire pump fuel oil storage tanks for particulate contamination and water and to incorporate the trending of water, particulate contamination, and microbiological activity in the SDG and diesel fire pump fuel oil storage tanks, lighting diesel generator fuel oil tank, and the BOP diesel generator fuel oil day tanks.
Operating Experience STP work orders, condition reports, and the chemistry database from 1999 to 2009 related to fuel oil chemistry were reviewed. None were found which documented any type of corrosion.
Several occurrences were found in the chemistry database which documented the need to add biocide to the fuel oil due to finding microbiological growth. Condition reports have documented that fuel oil chemistry was out of specification in the following instances:
Enclosure 2 NOC-AE-1 1002758 Page 40 of 78 Water and fine sediment intrusion in the auxiliary fuel oil storage tank, diesel generator fuel oil storage tank, fire pump fuel oil storage tank, and the vendor fuel oil trailer tanks have been found approximately annually due to various reasons including the tank cleaning work and a predisposition of a floating tank roof to allow water to pass through and into tank. Corrective actions for fuel oil tanks, including additional inspections and the draining from the bottom of tanks after allowing the water and sediment to settle, have been effective in bringing the fuel oil chemistry back into specification limits, as proven during inspection procedures.
As additional industry and plant-specific applicable operating experience becomes available, it will be evaluated and incorporated into the program through the Condition Reporting Process or the Operating Experience program.
Conclusion The continued implementation of the Fuel Oil Chemistry program, supplemented by the One-Time Inspection program (B2.1.16), 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.
Enclosure 2 NOC-AE-1 1002758 Page 41 of 78 CHANGE Revised Description of Metal Fatigue of Reactor Coolant System Pressure Boundary Program to Ensure that Actual Plant Experience Remains Boundary by Transients Assumed by "Fatigue Crack Growth Analysis" as well as in Design Calculations A2
SUMMARY
DESCRIPTIONS OF TIME-LIMITED AGING ANALYSIS AGING MANAGEMENT PROGRAMS A21.1 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 fatigue crack -growthanalyses, 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. The program will also consider the effects of the reactor water environment for a set that includes the NUREG/CR-6260 sample locations for a newer-vintage Westinghouse Plant, and plant-specific bounding EAF locations. If a cycle count or cumulative usage factor value increases to a program action limit, corrective actions include fatigue reanalysis, repair, or replacement. Any re-analysis of a fatigue crack growth analysis will be consistent with or reconciled to the originally submitted analysis and will receive the same level of regulatory review as the original analysis. Action limits permit completion of corrective actions before the design basis number of events is exceeded.
Enclosure 2 NOC-AE-1 1002758 Page 42 of 78 CHANGE UFSAR Change Notice 2997 Revised the total number of primary side hydrostatic test cycles to a limit of I for Unit I that is now limited by the BMI half nozzle repair..
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 Unit I Unit 2 (1988-2008) (1989-2008) Unit I Unit 2
- 38. Normal Charging Letdown Shutoff and NS 60 7 18 16 54 Letdown Trip
- 39. Letdown Trip with Prompt Return 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 Return to NS 20 0 0 1 1 Service Test Conditions
- 43. Primary Side Hydrostatic Test 01 1 1
- 44. Secondary Side Hydrostatic Test 10 10 1 1 1 1 (each generator) I I Auxiliary Conditions - Accumulator Safety Injections
- 45. Inadvertent RCS Depressunzation 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 30 1 0 3 1 Injection
Enclosure 2 NOC-AE-1 1002758 Page 43 of 78 CHANGE CHANGE IS INCORE CAPSULE TESTING ORDER A1.15 REACTOR VESSEL SURVEILLANCE The Reactor Vessel Surveillance program manages loss of fracture toughness of the reactor vessel beltline material. The Reactor Vessel Surveillance program for STP is designed to ASTM E 185 and complies with 10 CFR 50 Appendix H. Actual reactor vessel coupons are used. The surveillance coupons are tested by a qualified offsite vendor, to its procedures. The testing program and reporting conform to the requirements of ASTM E 185-82.
The removal schedule of the surveillance coupons will yield data with exposures greater than that expected in 60 years of operation. This withdraw schedule therefore meets the ASTM E 185-82 criterion which states that capsules may be removed when the capsule neuron fluence is between one and two times the limiting fluence calculated for the vessel at the end of expected life.
Vessel fluence for both units will be determined by ex-vessel dosimetry after all the capsules with a fluence qreater than 60 years have been removed.
Enclosure 2 NOC-AE-1 1002758 Page 44 of 78 B2.1.15 Reactor Vessel Surveillance Program Description The Reactor Vessel Surveillance program manages loss of fracture toughness of the reactor vessel beltline material. The Reactor Vessel Surveillance program is designed to ASTM E 185 and complies with 10 CFR 50 Appendix H. Actual reactor vessel coupons are used, but an exemption in the original license permits use of other than beltline weld material for the weld coupons. The surveillance coupons are tested by a qualified offsite vendor, to its procedures.
The testing program and reporting conform to the requirements of ASTM E 185-82.
The results are used to project the end-of-life fluence, and demonstrate compliance with Charpy upper-shelf energy requirements in 10 CFR 50 Appendix G and pressurized thermal shock screening criteria in 10 CFR 50.61, using the methodologies in Regulatory Guide 1.99 Revision
- 2. The results are also used to verify the plants' operating restrictions implemented through the P-T curves.
For both Units, T-he the removal schedule, approved by the NRC, wil exposes the emaining capsules to a fluence greater than that expected at the beltline wall at 60 years. This withdrawal therefore meets the ASTM E 185-82 criterion which states that capsules may be removed when the capsule neutron fluence is between one and two times the limiting fluence calculated for the vessel at the end of expected life. The remaining untested capsules will remain in the vessel to experience higher fluences in support of industry initiatives will also be withdrawn at this time and stored in the cpe.t fuel pool as spares. Vessel fluence will be determined by ex-vessel dosimetry once all the capsules with a fluence greater than 60 years are removed.
NUREG-1801 Consistency The Reactor Vessel Surveillance program is an existing program that, following enhancement, will be consistent to NUREG-1 801,Section XI.M31, Reactor Vessel Surveillance.
Exceptions to NUREG-1801 None Enhancements Prior to the period of extended operation, the following enhancements will be implemented in the following NUREG-1801 "items":
NUREG-1801 Item 7 NUREG-1801 states "Applicants without in-vessel capsules use alternative dosimetry to monitor neutron fluence during the period of extended operation, as part of the aging management program for reactor vessel neutron embrittlement."
Procedures will be enhanced to include the withdrawal schedule and analysis of the ex-vessel dosimetry chain.
Enclosure 2 NOC-AE-1 1002758 Page 45 of 78 NUREG-1801 Item 8 NUREG-1 801 suggests that "The applicant may choose to demonstrate that the materials in the inlet, outlet, and safety injection nozzles [extended beltline materials] are not controlling, so that such materials need not be added to the material surveillance program for the license renewal term."
STP will demonstrate that the reactor vessel inlet and out nozzles are exposed to a fluence of less than 1017 n/cm 2 , or will incorporate the adjusted reference temperature (ART) for the inlet and outlet nozzles with bounding chemistry and fluence values into the P-T limit curves.
The program will be enhanced to include the Unit 2 bottom head torus in the Reactor Vessel Surveillance program. This involves including the Unit 2 bottom head torus in the evaluations for P-T limit curves and compliance with the PTS rule. The program will address the surveillance coupon materials in one of the following manners: (1) add coupon material from the Unit 2, bottom head torus, if available; or (2) use data from similar material at another plant, if available. (3) If inclusion of material from the Unit 2 the bottom head torus in the surveillance program is not practical or if data from another plant is not available, Regulatory Guide 1.99 provides methods that can be used, with increased margins to account for uncertainties.
Operating Experience The latest capsule to be withdrawn from STP Unit 1 was Capsule V in 2007 at 11.13 EFPY with a capsule equivalent age of 34 EFPY. The latest capsule to be withdrawn from STP Unit 2 was Capsule U in 2007 at 10.31 EFPY with a capsule equivalent age of 33 EFPY. The last-tested capsule specimens satisfy the upper-shelf energy criterion and pressurized thermal shock temperature screening criteria. The adjusted reference temperatures have been shown to be less than that used in the P-T limit curves, thereby demonstrating margin in the operating limits.
The current withdrawal schedule calls for the last capsules in each unit to be withdrawn at approximately 18 EFPY, which is equivalent to a vessel exposure of approximately 59 EFPY.
This EOLE exposure is greater than the anticipated 54 EFPY end of life fluence.
Conclusion The continued implementation of the Reactor Vessel Surveillance 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.
Enclosure 2 NOC-AE-1 1002758 Page 46 of 78 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. If buried pray cast iron valves are removed from the fire Protection system, then at least one of them will be evaluated to determine the extent of selective leachinq of the valve. 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).
The Selective Leaching of Materials program will be implemented during the 10 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-1 801,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.
Scope of Program (Element 1), ParametersMonitored 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
Enclosure 2 NOC-AE-1 1002758 Page 47 of 78 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. 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 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
Enclosure 2 NOC-AE-1 1002758 Page 48 of 78 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.
Enclosure 2 NOC-AE-1 1002758 Page 49 of 78 CHANGE UFSAR Change Notice 3005 Revised the survey frequency of the Essential Cooling Water Pond sediment from year 5 years to every 10 years A1.33 RG 1.127, INSPECTION OF WATER-CONTROL STRUCTURES ASSOCIATED WITH NUCLEAR POWER PLANTS The RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants program manages cracking, loss of bond, loss of material (spalling, scaling), cracking due to expansion, increase in porosity and permeability, loss of strength, and loss of form by performing inspection and surveillance activities for all water control structures associated with emergency cooling water systems. The RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants program is implemented as part of the Structures Monitoring Program. STP is committed to conform to the intent of RG 1.127 with respect to the essential cooling pond (ultimate heat sink). The Structures Monitoring Program includes all water control structures within the scope of RG 1.127, as evaluated in NUREG-1801. The essential cooling pond, the essential cooling pond intake structure, and the essential cooling pond discharge structure are the water-control structures within the scope of license renewal that are monitored by this program. The essential cooling pond (ultimate heat sink) receives periodic monitoring of its hydraulic and structural condition, which includes evaluation of erosion inhibiting structures, conditions of benchmarks and piezometers, and measuring the essential cooling pond volume as indicative of any sediment accumulation,_and. ,Additionally, STP peFfF-ms-a seepage rate evaluation. Inspections of f-f the essential cooling pond are performed every five years except sediment monitoring, which is performed every ten years.
Enclosure 2 NOC-AE-1 1002758 Page 50 of 78 B2.1.33 RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program Description The RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants program, which is implemented as part of the Structures Monitoring Program (SMP), manages cracking, loss of bond, loss of material (spalling, scaling), cracking due to expansion, increase in porosity and permeability, loss of strength, and loss of form by performing inspection and surveillance activities for all water control structures associated with emergency cooling water systems. STP is committed to conform to the intent of RG 1.127 with respect to the essential cooling pond (ultimate heat sink). The Structures Monitoring Program (B2.1.32) in compliance with 10 CFR 50.65, The Maintenance Rule, includes all water control structures within the scope of RG 1.127, as evaluated in NUREG-1801. The essential cooling pond, the essential cooling pond intake structure, and the essential cooling pond discharge structure are the water-control structures within the scope of license renewal that are monitored by this program. The essential cooling pond (ultimate heat sink) receives periodic monitoring of its hydraulic and structural condition, which includes evaluation of erosion inhibiting structures, conditions of benchmarks and piezometers, and measuring the essential cooling pond volume as indicative of any sediment accumulation,. and..Additiona4ly, STP poforms a seepage rate evaluation.
Inspections of feF the essential cooling pond are performed every five years except sediment monitoring, which is performed every ten years.
NUREG-1801 Consistency The RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants program, is an existing program that, following enhancement, will be consistent with NUREG-1801,Section XI.S7, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants.
Exceptions to NUREG-1801 NGeA-Program Elements Affected:
Detection of Aqing Effects (Element 4)
NUREG-1801 cites Regulatory Guide 1.127 for describing periodic inspections to be performed at least once every five years. STP has extended the frequency interval for sediment monitoring of the Essential Coolinq Pond (ECP) to every 10 years. (Ref. Licensing Basis Document Change Request CN-3005) The makeup to the ECP is either through the well water system or from the Main Cooling Reservoir. Each source of makeup is relativity free of sediment. There are no external sources draining into the pond to promote sediment buildup, and it is isolated from the external sources by the outer embankment which completely surrounds the pond. Sediment level was measured by soundings performed every year from 1987 to 1997, with subsequent surveys performed in 2002 and 2009. There has been no measureable accumulation of sediment. Therefore, extending the frequency interval for sediment surveys from every 5 years to every 10 years will have no affect on the ECP design to
Enclosure 2 NOC-AE-1 1002758 Page 51 of 78 perform its intended function of supplying water for a minimum of 30 days of heat removal without outside makeup.
Enhancements Prior to the period of extended operation, the following enhancements will be implemented in the following program elements:
Preventive Actions (Element 2)
For ASTM A325, ASTM F1 852, and/or ASTM A490 structural bolts, plant procedures will be revised to specify the preventive actions for storage, protection and lubricants recommended in Section 2 of Research Council for Structural Connections publication "Specification for Structural Joints Using ASTM A325 or A490 Bolts."
Detection of Aging Effects (Element 4)
Procedures will be enhanced to specify inspections at intervals not to exceed five years or to immediately follow significant natural phenomena except sediment monitoring, which is performed every ten years.
Procedures will be enhanced to specify ACI 349.3R-96 and ACI 201.1 R-68 as the basis for defining quantitative acceptance criteria.
Operating Experience A review of the structures monitoring inspection documents shows that the water control structures at STP including the essential cooling pond, ECW intake and ECW discharge structures have been subject to relatively few aging effects. These inspections include scheduled structures monitoring inspections and detailed visual inspections of the essential cooling pond. All structures have always been in acceptable condition and met engineering functional requirements including performance, maintainability, and safety.
Essential cooling pond inspection report from 1997 states measurements of pond volume over the years have indicated virtually no accumulation of sediments within the pond. The differential settlements of the ECW intake structure and ECW discharge structure were well within the allowable limit of 3/4 in. The deflections measured along buried ECW pipe routes using benchmark elevations were found to be well within allowable of 1.5 in. All of the essential cooling pond benchmarks and piezometers were found to be fully functional and measurements were being taken as specified in the UFSAR. There was an array of shrinkage cracks running longitudinal along the soil-cement and concrete paved exterior slopes of embankments, however, this was attributed due to the fluctuating moisture contents of the soil within and as such did not exhibit any signs of erosion Two minor potential consequences of growing vegetation around the essential cooling pond slopes have been identified. The potential for cracking of areas with soil-cement and concrete leading to soil erosion and the issue of clogging (owing to soil and vegetation) possibly leading to entrapping of debris near the trash racks of the ECWIS was identified. These conditions are non-aging related and could easily be fixed by regular herbicide application.
Enclosure 2 NOC-AE-1 1002758 Page 52 of 78 Conclusion The continued implementation of the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants 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.
Enclosure 2 NOC-AE-1 1002758 Page 53 of 78 CHANGE UFSAR Change Notice 3006 Revised the Allowable Material that can be used in the Reactor Coolant Pump Closure Bolting 3.1.2.1.2 Reactor Coolant System Materials The materials of construction for the reactor coolant system component types are:
" Carbon Steel
- Insulation Calcium Silicate
" Insulation Fiberglass
- Nickel Alloy
" Stainless Steel
" Stainless Steel Cast Austenitic
Enclosure 2 NOC-AE-1 1002758 Page 54 of 78 Table 3.1.2-2 Reactor Vessel, Internals, and Reactor Coolant System - Summary of Aging Management Evaluation - Reactor Coolant System (Continued)
Intended Material Aging Effect Aging Management NUREG- Table I Item Notes Component Type Function [ Environment W
__________
Requiring Management __________
Program 1801 Vol.
2 Item_____
- Closure Bolting: PB 'Carbon Steel IBorated Water 'Cumulative Time-Limited Aging :IV.C2-1O ;3.1.1.07 IA iLeakage(Ext) fatigue damage ,Analysis evaluated for
- ,the period of extended Boperation Integrity......7).No ClIosu~r~e 66,oIin q ýP-B Nickel Alloy Borated Water Cracking 'Bolting Integrity (B2.1.7)
- None None EF4 Leakage (Ext)
!Bolting Integrity (B2.1.7) None
- Closure Bolting 1PB Nickel Alloy iBorated water Loss of preload None
.Leakage (Ext) -
Closure Bolting PB Stainless !Borated Water Cracking 'Bolting Integrity (B2.1.7) 'IV.C2-7 '3.1.1.52 B Steel . L.eage (Ext) Cra.king Closure Bolting PB Stainless IBorated Water Loss of preload -Bolting Integrity (B2.1.7) IV.C2-8 13.1.1.52 B Steel Leakage_ (Ext)_.
Closure Bolting PlB Stainless iBorated Water lCumulative Time-Limited Aging IV.C2-1 0 ,3.1.1.07 A Steel Leakage (Ext) fatigue damage Analysis evaluated for the period of extended
,!.operation Flame Arrestor PB Carbon Steel Lubricating Oil L..oss of material Lubricating Oil Analysis ;VII.G-26 3.3.1.15 (Int) i ((B2.1.33)and One-Time
'Inspection (B12.1.16)
Flame Arrestor :PB Carbon Steel :Plant Indoor Air Loss of material 'External Surfaces V.C-1 3.2.1.31 D,3 (Ext) IMonitoring Program J1B2.1.2o) . . . . .
iFlIow Element LBS !Stainless . Borated Water tNo0ne None IV.E-3 :3.1.1.86 A Steel Leakage (Ext) j
!Flow Element LBS Stainless Treated Borated Loss of material Water Chemistry V.D1-30 3.2.1.49 Steel i .. .. .. ...
Water (Int)
_ _. . . .. ..... . . .. . . . ..
(B2.1.2) and One-Time
........... ___.k.
Inspection_B2.1.16)
Notes for Table 3.1.2-1:
Standard Notes:
Enclosure 2 NOC-AE-1 1002758 Page 55 of 78 A Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.
B Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.
C Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.
E Consistent with NUREG-1 801 for material, environment, and aging effect, but a different aging management program is credited or NUREG-1801 identifies a plant-specific aging management program.
F Material not in NUREG-1 801 for this component.
G Environment not in NUREG-1801 for this component and material.
I Aging effect in NUREG-1801 for this component, material and environment combination is not applicable.
Plant Specific Notes:
1 Water Chemistry (B2.1.2) and ASME Section Xl, Inservice Inspection, Subsections IWB, IWC, and IWD (B2.1.1) are used to manage this aging effect for Cast Austenitic Stainless Steel (CASS) components.
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 Component is part of RCP oil collection system.
4 This non NUREG-1801 line item was created because there is no line item for a component made of nickel alloy with borated water leakage (Ext) with an aging effect of cracking/ stress corrosion cracking.
5 Loss of Preload is conservatively considered to be applicable for all closure bolting.
Enclosure 2 NOC-AE-1 1002758 Page 56 of 78 CHANGE SOLENOID VALVES WERE ADDED TO THE SCOPE OF THE LRA FOR VARIOUS SYSTEMS Table 2.3.3-6 Component Cooling Water System Component Type Intended Function ISight Gauge !Leakage Boundary (spatial)
Pressure Boundary
... Structural Integrity (attached)
....
'Solenoid Valve Pressure Boundary Tank Leakage Boundary (spatial)
Pressure Boundary
__ ___Structu ral Integrity.(attached) ..........
Table 2.3.4-6 Auxiliary FeedwaterSystem Component Type I Intended Function Piumn Pr~csurr Bounry I
'Pressure Boundary Solenoid Valve
,Pressure Boundary Tank
Enclosure 2 NOC-AE-1 1002758 Page 57 of 78 3.4.2.1.6 Auxiliary Feedwater System Materials The materials of construction for the auxiliary feedwater system component types are:
- Carbon Steel
- Stainless Steel
- Stainless Steel Cast Austenitic Environment The auxiliary feedwater system components are exposed to the following environments:
- Atmosphere/ Weather
- Buried
- Dry Gas
- Encased in Concrete
- Lubricating Oil
- Plant Indoor Air
- Secondary Water
- Steam Aging Effects Requiring Management The following auxiliary feedwater system aging effects require management:
- 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 auxiliary feedwater system component types:
- Flow Accelerated Corrosion (B2.1.6)
- Bolting Integrity (82.1.7)
Enclosure 2 NOC-AE-1 1002758 Page 58 of 78
- 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)
- Lubricating Oil Analysis (B2.1.23)
- One-Time Inspection (B2.1.16)
- Selective Leachingi of Materials (B2.1.17)
- Water Chemistry (B2.1.2)
Enclosure 2 NOC-AE-1 1002758 Page 59 of 78 Table 3.4.2-6 Steam and Power Conversion System - Summary of Aging Management Evaluation- Auxiliary FeedwaterSystem Type 1Function CmoetIntended Material
_____
______
Environmen
_________.Management Aging Effect Requiring AgingProgram
__________
Management INUREG- Table I Itm 1801 Vol.Itm 2 Item _____I____
Notes Piping LBS, PB, !Stainless Atmosphere/ INone None None None G
ýSIA iSteel Weather (Ext) -.None
'Piping - Stainless Atmosphere/ None N Nl-one None
- BSIA Steel Weather (Int)
Piping IStainless IBuried (Ext) Loss of material Buried Piping and Tanks VIII.G-31 3.4.1.17
'Steel I ... inspection_(B2.1.18) I-
,Pump PB :Stainless ISecondary Water
.Steel Cast ý(Int)
Loss of material !Water Chemistry (B2.1.2) and One-Time VIII.G-32 3.4.1 .16 A ~1 Austenitic spection (B2. 1.16)
'Solenoid Valve PB Copper Alloy Plant Indoor Air Loss _of mater ialI Selective Leaching of None None G,2
. (>15%
. Zinc) i(Int). Materials (B22 1. 7)
- Solenoid Valve PB 'Copper Alloy !Plant Indoor Air None V.F-3 3.2.1.53 A
.(>5%Zinc)_ (Ext) ____
None Tank PB 'Stainless Atmosphere/ None None None iG
............
ISteel !Weather (Ext)
Turbine PB 'Carbon Steel !Plant Indoor Air !Loss of material External Surfaces VIII.H-7 3.4.1.28 B (Ext) Monitoring Program i(B2.1-,2_O )_ .. . . .......
Turbine 'PB !Carbon Steel Steam (Int) Loss of material iWater Chemistry VIII.B1-8 3.4.1.37 E, 23 (B2.1.2) and One-Time
- inspection (_B_2.16)
Valve ,PB Carbon Steel Lubricating Oil Loss of material Lubricating Oil Analysis VIII.G-35 13.4.1.07 B S(Int) ((B2.1.23)and One-Time S..............- III..LIUII '.. IIV)
Plant Specific Notes:
1 Loss of preload is conservatively considered to be applicable for all closure bolting.
2 Non-inhibited copper alloy >15% zinc SSCs with surfaces exposed to ventilation atmosphere (internal) or plant indoor air (internal) are subiect to wetting due to condensation and thus are subiect to loss of material due to selective leaching.
Enclosure 2 NOC-AE-1 1002758 Page 60 of 78 23 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.
34 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.
Enclosure 2 NOC-AE-1 1002758 Page 61 of 78 3.3.2.1.6 Component Cooling Water System Materials The materials of construction for the component cooling water system component types are:
- Carbon Steel
- Copper Alloy
- Glass
- Stainless Steel
- Titanium Environment The component cooling water system component types are exposed to the following environments:
- Closed-Cycle Cooling Water
- Demineralized Water
- Dry Gas
- Lubricating Oil
- Plant Indoor Air
- Raw Water
- Treated Borated Water Aging Effects Requiring Management The following component cooling water system aging effects require management:
- Cracking
- Loss of material
- Loss of preload
- Reduction of heat transfer Aging Management Programs The following aging management programs manage the aging effects for the component cooling water system component types:
0 Bolting Integrity (B2.1.7)
- Closed-Cycle Cooling Water System (B2.1.10)
Enclosure 2 NOC-AE-1 1002758 Page 62 of 78
- External Surfaces Monitoring Program (B2.1.20)
- 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)
- Water Chemistry (B2.1.2)
Enclosure 2 NOC-AE-1 1002758 Page 63 of 78 Table 3.3.2-6 Auxiliary Systems - Summary of Aging Management Evaluation - Component Cooling Water System Component Intended Material Environment Aging Effect Aging Management NUREG- Table I Item Notes Type Function Requiring " Program 1801 Vol.
Management "2 Item Sight Gauge LBS, SIA Glass Plant Indoor Air None None VII.J-8 3.3.1.93 A (E x t) ................
Solenoid Valve PB CoPi~er Alloy 'Plant Indoor Air Loss of material ,Selective Leaching of None None G, 3
.(>15% Zinc) (Int) I'Materials (B2.1.17)
Solenoid Valve PB Copper Alloy Plant Indoor Air None None 'VIII.l-2 3.4.1.41 A
(>15% Zinc)
.LBS, PB, Carbon Steel (Ext)
Tank Closed Cycle ..... Loss of material .Closed-Cycle Cooling VII.C2-14 3.3.1.47 B SIA Cooling Water (Int) Water System (B2.1.*10)
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 Non-inhibited copper alloy >15% zinc SSCs with surfaces exposed to ventilation atmosphere (internal) or plant indoor air (internal) are subject to wetting due to condensation and thus are subiect to loss of material due to selective leaching.
Enclosure 2 NOC-AE-1 1002758 Page 64 of 78 Table 2.3.3-19 Chemical and Volume Control System Component Type ] Intended Function
!Strainer Leakage Boundary (spatial)
Solenoid Valve !Pressure Boundary Tank !Leakage Boundary (spatial)
Pressure Boundary
-I____ Structural Integrity (attached)
Enclosure 2 NOC-AE-1 1002758 Page 65 of 78 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:
- Carbon Steel
- Copper Alloy
- Insulation Calcium Silicate
- Insulation Fiberglass
- Nickel Alloys
- Stainless Steel
- 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
- Secondary Water
- Steam
- Treated Borated Water
- Zinc Acetate Aging Effects Requiring Management The following chemical and volume control system aging effects require management:
- Cracking
Enclosure 2 NOC-AE-1 1002758 Page 66 of 78
- 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 (B2.1.20)
- 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 (B2.1.16)
- One-Time Inspection of ASME Code Class 1 Small-Bore Piping (B2.1.19)
- Selective Leaching of Materials (B2.1.17)
- Water Chemistry (B2.1.2)
Enclosure 2 NOC-AE-1 1002758 Page 67 of 78 Water Chemistry None (B2.1.2) and One-Time 1 ii ...............
...
..... 11ý1. 1!nspection (B2.I.16)___
1.- ...,................
Solenoid Valve ;PB !CopperAlloy Plant Indoor Loss of material 'Selective Leaching of None None G 3
- (>15% Zinc) _ Air (Ext) ! Materials (B2.1.17) _ ...............
1 AA3.2.1.53
_
iolenoid Valve Strainer
- PB
__
LBS Copper Alloy i(>15% Zinc) iCopper Alloy Plant Indoor Air (Int)
None
-Closed Cycle Loss of material
___----.----
7None Closed-Cycle Coolng
--
V.F-3 viE----- t3.3.1.51 I B
,Cooling Water Water System
__ ,(!n ~t)_ý.. . . . . .. (13 2 .1 .1 .0.). . . ............ . .. ... ... ..... i.. .. . . . . . . .. .. .
Plant Specific Notes:
1 NUREG-1 801 does not address the aging effect of nickel-alloys in borated water leakage. Nickel-alloys subject to an air with borated water leakage environment are similar to stainless steel in a borated water leakage environment and do not experience aging effects due to borated water leakage.
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 Non-inhibited copper alloy > 15% zinc SSCs with surfaces exposed to ventilation atmosphere (internal) or plant indoor air (internal) are subject to wetting due to condensation and thus are subject to loss of material due to selective leaching.
Enclosure 2 NOC-AE-1 1002758 Page 68 of 78 Table 2.3.4-2 Auxiliary Steam System and Boilers I Component Type I Intended Function Piping ,Leakage Boundary (spatial)
'Pressure Boundary Structural Integrity(attached)
Solenoid Valve Pressure Boundary iTubing Leakage Boundary (spatial)
Pressure Boundary
'Structural Integrity_(attached) ....._
Enclosure 2 NOC-AE-1 1002758 Page 69 of 78 3.4.2.1.2 Auxiliary Steam System and Boilers Materials The materials of construction for the auxiliary steam system and boilers component types are:
- Carbon Steel
- Stainless Steel Environment The auxiliary steam system and boilers components are exposed to the following environments:
- Plant Indoor Air
- Steam Aging Effects Requiring Management The following auxiliary steam system and boilers aging effects require management:
- Cracking
- Loss of material
- Loss of preload
- Wall thinning Aging Management Programs The following aging management programs manage the aging effects for the auxiliary steam system and boilers component types:
- Bolting Integrity (B2.1.7)
- External Surfaces Monitoring Program (B2.1.20)
- Flow-Accelerated Corrosion (B2.1.6)
- One-Time Inspection (B2.1.16)
- Selective Leaching of Materials (B2.1.17)
- Water Chemistry (B2.1.2)
Enclosure 2 NOC-AE-1 1002758 Page 70 of 78 Table 3.4.2-1 Steam and Power Conversion System - Summary of Aging Management Evaluation - Main Steam System Component Typo Intended Function
_
Material 11 Environment
__Management Aging Effect Requiring I Aging Management
__2 Program NUREO Tl 1801 Vo .
Item bl. tm IemoNotes oe Solenoid Valve ,PB Aluminum Lubricating Oil !Loss of material 1Lubricating Oil Analysis None ýNone iG (Int) (B2.1.23) and One-Time Inspection (32.1.16) -
Solenoid Valve PB Aluminum Plant Indoor Air iNone None iV.F-2 3.2.1.50 n .... Plant)
Al+,*uminum Plant INone Indoor Air iNone Nn
- Solenoid Valve PB
. . . ..
+L..... L(.Ex )... ...... ............. V.F-2 t
3.2.1.50 1,
.....
......
......
Enclosure 2 NOC-AE-1 1002758 Page 71 of 78 Table 3.4.2-2 Steam and Power Conversion System - Summary of Aging Management Evaluation - Auxiliary Steam System and Boilers Component______ Intended_ Material___ Enirnen _AigffcAinangeet____ Tbl Item1 Nte Type Function Requiring Program 1801 Vol.
__Management 2 Item Piping ýLBS, PB, jCarbon Steel Steam (Int) :Wall thinning Flow-Accelerated VIII.B1-9 13.4.1.29 1B
- SIA !Lorroson (B2.1 .6) .i None ........ ... n ........ .. .
.Solenoid Valve PB. Copper Alloy 'Plant Indoor Air Loss of material Selective Leaching of None None G, 2
,(>15%%Zinc) (Int) Materials(B2.1.17) VI-&
..........
.I- .4.1 ... ..........
Solenoid Valve 1P3B Copper Alloy , Plant Indoor Air None None VII1.l-2 3.4.1.41
!(>15% Zinc) jE . .)
'Tubing ILBS, PB, -Stainless "Plant Indoor Air 1None None VIII. 1-10 3.4.1.41 iSIA ISteel - E Notes for Table 3.4.2-2:
Standard Notes:
A Consistent with NUREG-1 801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1 801 AMP.
B Consistent with NUREG-1 801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.
D Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.
E Consistent with NUREG-1 801 for material, environment, and aging effect, but a different aging management program is credited or NUREG-1801 identifies a plant-specific aging management program.
G Environment not in NUREG-1801 for this component and material.
Plant Specific Notes:
1 The Water Chemistry program (B2.1.2) and the One-Time Inspection program (B2.1.16) manages 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.
2 Non-Inhihited conner alloy >15% zinc SSCs with surfaces exnosed to ventilation atmosphere (internafl or olant indoor air (internal'/are subject to wetting due to condensation and thus are subject to loss of material due to selective leaching.
Enclosure 2 NOC-AE-1 1002758 Page 72 of 78 EDITORIAL CHANGES TO THE LRA 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 Function Material
____ _____
[Requiring Environment
_______Management Aging Effect
_
Aging Management Program
______j2 NUREG-11801 Vol.
Item Table I Item
________
Notes RV BMI Nozzle and IPB Nickel Alloys i Reactor Coolant Loss of material Water Chemistry IV.A2-14 3.1.1.83 !A Welds (B2.1.2)
RV BMI Nozzle and: PB NickelAllos Reactor Coolant Cracking Nickel-Alloy Aging IV.A2-19 3.1.1.31 IE,I Welds 1(Int) Management (0221-7 B2.1.34),
'ASME Section Xl 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 Cumulative guidelines.
RV BM iNozzie-andi PB- Nickel Alloys Reactor Coolant .Time-Limited Aging IV.A2-21 13.1.1.09 Welds (Int) fatigue damage :Analysis evaluated for the period of extended
- -
operation _ J
Enclosure 2 NOC-AE-1 1002758 Page 73 of 78 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 Material Environment Aging Effect Aging Management NUREG- Table I Notes Function Requiring Program 1801 Vol. Item
________________ ______ _________ Management __________ 2 Item ______ _ _ _ _
RV Closure Head PB 1High Borated Water Loss of material Boric Acid Corrosion IV.A2-13 13.1.1.58 1A Bolts Strength Low Alloy Leakage (Ext) (132.1.4) iI Steel ,
.(Bolting)___ __ _
RV Core Support SS Nickel Alloys 1Reactor Coolant Cracking g9 .....~Nickel-Alloy
........... - li~ Aging g i g .. . . IV.A2-12 .*-.31 E, 1
'Lugs (Ext) Management (021 B712.1.34),
.ASME Section Xl 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. IV.A2-14 1..
31 1.83 ... .. .......
!RV Core Support SS . Nickel Alloys-Reactor Coolant Loss of material Water Chemistry
,Lugs ___ (Ext) : (132.1.2) . ...
Enclosure 2 NOC-AE-1 1002758 Page 74 of 78 Table 3.1.2-1 Reactor Vessel, Internals, and Reactor Coolant System - Summary of Aging Management Evaluation - Reactor Vessel and Internals (Continued)
ComponentType Intended Function
________ ____
Material
____I_______
[Requiring Environment Aging Effect Management Aging Management Program UREG-1801 Vol.
2 Item Table I
____
Item Notes RV Nozzle Safe PB Nickel Alloys Reactor Coolant Loss of material 'Water Chemistry :IV.A2-14 13.1.1.83 A IEnd Welds i (Int) (B2.1.2) _
RV Nozzle Safe jNickel Alloys 0React-orCo-olant Cracking Nickel-Alloy Aging IV.A2-15 3.1.1.69 E, 1 I
iManagement End Welds l(Int)
(12..371B2.1.34),
'ASME Section Xl 1Inservice 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 i implement applicable
,(1) Bulletins and
- Generic Letters and (2
'staff-accepted industry Nickel Alloys. Reactor Coolant zguidelines.
RV Nozzle Safe !PB3 !Cumulative Time-Limited Aging IV.A2-21 3.1.1.09
'End Welds I(Int) fatigue damage !Analysis evaluated for Ithe period of extended
_operati~on ... .. . .....
S...................
Plant Specific Notes:
1 Includes the plant specific Nickel-Alloy Aging Management Program (1241371B2.1.34) in addition to the programs identified in NUREG-1801.
Enclosure 2 NOC-AE-1 1002758 Page 75 of 78 B2.1.13 Fire Water System Program Description 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 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 Fire Water System program will replace sprinklers prior to 50 years in service or the program 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.
Volumetric examinations will be performed on fire water piping. As an alternative, internal inspections will be performed on accessible exposed portions of fire water piping during plant maintenance activities. The inspections detect loss of material due to corrosion, ensure that aging effects are managed, ensure wall thickness is within acceptable limits, and detect degradation before the loss of intended function. If a representative number of inspections have not been completed prior to the period of extended operation, the fire protection coordinator determines that additional inspections or examinations are required, locations will be selected based on system susceptibility to corrosion or fouling and evidence of performance degradation during system flow testing or periodic flushes. If material and environment conditions for above grade and below grade piping are similar, the results of the inspections of the internal surfaces of the above grade fire protection piping can be extrapolated to evaluate the condition of the internal surfaces of the below grade fire protection piping. If not, additional inspection activities are needed to ensure that the intended function of below grade fire protection piping will be maintained consistent with the current licensing basis.
NUREG-1801 Consistency The Fire Water System program is an existing program that, following enhancement, will be consistent, with exception to NUREG-1 801,Section XI.M27, Fire Water System.
Exceptions to NUREG-1801 Program Elements Affected:
Scope of Program (Element 1)
NUREG-1801 provides a program for managing carbon steel and cast iron components in fire water systems. The fire water system contains additional materials of construction, specifically, copper alloy and stainless steel. The Fire Water System program manages aging effects of copper alloy and stainless steel fire water system components with an internal environment of water.
Enclosure 2 NOC-AE-1 1002758 Page 76 of 78 Detection of Aging Effects (Element 4)
NUREG-1 801 requires inspection of fire protection systems in accordance with the guidance of NFPA-25. STP performs power block hose station gasket inspections at least once every 18 months, rather than annually as specified by NFPA-25. STP has been inspecting at an 18 month frequency for over 10 years, and no degradation leading to a loss of function has occurred. A visual inspection of hose stations is conducted every six months for accessible locations and 18 months for stations that are not accessible during normal operations. These hoses are also hydrostatically tested every three years. Hoses are replaced when indications of deterioration are observed either by visual inspection or failure of a hydrostatic test, this replacement includes inspection of the gasket. Since aging effects are typically manifested over several years, differences in inspection and testing frequencies are insignificant.
Enhancements Prior to the period of extended operation, the following enhancements will be implemented in the following program elements:
Preventive Actions (Element 2), ParametersMonitored or Inspected (Element 3,) and Detection of Aging Effects (Element 4)
Procedures will be enhanced to include volumetric examinations or direct measurement on representative locations of the fire water system to determine pipe wall thickness.
Detection of Aging Effects (Element 4)
Procedures will be enhanced to replace sprinklers prior to 50 years in service or field service test a representative sample and test every 10 years thereafter to ensure signs of degradation are detected in a timely manner.
Monitoring and Trending (Element 5)
Procedures will be enhanced for trending of fire water piping flow parameters recorded during fire water flow tests.
Operating Experience A review of the past 12 years of plant operating experience showed no signs of gasket degradation or fire hose degradation due to inspection intervals of 18 months and three years, respectively.
The review of operating experience contained in STP condition reports (CRs) were evaluated for aging effects associated with the Fire Water System program. Of these CRs, 45 were determined to have applicable aging effects associated with the Fire Water System program.
The following is a summary of the aging effects reported in these CRs.
Leakage has been discovered coming from supply line piping connections. The associated connections were repaired by replacing the gasket and no further leakage has been observed from these locations. Leakage from fire hydrants has been observed at hydrant barrel connections. The hydrants were evaluated and replaced. Drain valves have leaked by causing corrosion to the associated surface. The valves were replaced and the problem was corrected.
Enclosure 2 NOC-AE-1 1002758 Page 77 of 78 Leakage has been observed from the threaded connections to installed relief valves. These connections were repaired and no further leakage has been observed from the threaded connections. Valve packing leakage in supply line valves has caused corrosion of the associated packing follower and retaining bolts. The leakage was corrected and degraded components were evaluated and replaced where required.
While performing the fie-five-year inspection of a fire water storage tank it was noted that the base of the tank needed repainted, that a weld located at the top of the tank between the roof and sidewall needed to be repaired and a recirculation line pipe hanger needed to be replaced.
The base of the tank was repainted, the weld was repaired and the hanger was replaced. No loss of intended function occurred.
Based on this review of STP operating experience, the Fire Water System program effectively identifies and corrects the fire water system components aging effects prior to the loss of intended function.
Conclusion The continued implementation of the Fire Water System 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.
Enclosure 2 NOC-AE-1 1002758 Page 78 of 78
[From Appendix E of the LRA - Applicant's Environmental Report]
Section 2.17 References NRC (U.S. Nuclear Regulatory Commission) 1975. Final Environmental Statement related to the proposed South Texas Project Units 1 & 2, NUREG 75/019, Docket Nos. 50-498 and 50-499. Office of Nuclear Reactor Regulation, Washington, DC. March.
NRC (U.S. Nuclear Regulatory Commission) 1986. Final Environmental Statement related to the operation of South Texas Project, Units 1 & 2, NUREG-1 17:71, Docket Nos. 50-498 and 50-499. Office of Nuclear Reactor Regulation, Washington, DC. August.
NUS (NUS Corporation) 1976. Final Report Colorado River Entrainment Monitoring Program, Phase One Studies April 1975-March 1976. Prepared for South Texas Project by Ecological Sciences Division, NUS Corporation, Rockville, MD. December.
South Texas Project Units 1 & 2 Environmental Report for License Renewal Page 77 of 84
Enclosure 3 NOC-AE-1 1002758 Enclosure 3 Revised Regulatory Commitments
Enclosure 3 NOC-AE-1 1002758 Page 1 of 2 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 9 Enhance the Fuel Oil Chemistry program procedures to: B2.1.14 Prior to the period of
" extend the scope of the program to include the SDG fuel oil drain tanks, extended operation
" check and remove the accumulated water from the fuel oil drain tanks, day tanks, and storage tanks associated with the SDG, BOP, lighting diesel generator, and fire water CR 10-23261 pump diesel generators. A minimum frequency of water removal from the fuel oil tanks will be included in the procedure,
- include 10-year periodic draining, cleaning, and inspection for corrosion of the SDG fuel oil drain tanks, lighting diesel generator fuel oil tank, and diesel fire pump fuel oil storage tanks,
- inspect the BOP diesel generator fuel oil day tanks and the lighting diesel generator fuel oil tank for internal corrosion,
" require periodic testing of the lighting diesel generator fuel oil tank and the SDG and diesel fire pump fuel oil storage tanks for microbiological organisms,
" require analysis for water, biological activity, sediment, and particulate contamination of the diesel fire pump fuel oil storage tanks, lighting diesel generator fuel oil tank, and the BOP diesel generator fuel oil day tanks on a quarterly basis,
" conduct ultrasonic testing or pulsed eddy current thickness examination to detect corrosion-related wall thinning once on the tank bottoms for the SDG and diesel fire pump, and the BOP diesel generator fuel oil day tanks, and
- incorporate the sampling and testing of the diesel fire pump fuel oil storage tanks for particulate contamination and water and to incorporate the trending of water, particulate contamination, and microbiological activity in the SDG and diesel fire pump fuel oil storage tanks, lighting diesel generator fuel oil tank, and the BOP diesel generator fuel oil day tanks.
Enclosure 3 NOC-AE-1 1002758 Pale 2 of 2 26 Enhance the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power B2.1.33 Prior to the period of Plants program procedures to: extended operation
- specify inspections at intervals not to exceed five years or to immediately follow significant natural phenomena except sediment monitoring, which is performed every CR 10-23601 ten years.
- specify the preventive actions for storage, protection and lubricants recommended in Section 2 of Research Council for Structural Connections publication "Specification for Structural Joints Using ASTM A325 or A490 Bolts" for ASTM A325, ASTM F1852 and/or ASTM 490 bolts.
" specify ACI 349.3R-96 and ACI 201.1 R-68 as the basis for defining quantitative acceDtance criteria.