ML11346A012

Response to Requests for Additional Information for the License Renewal Application Aging Management Program, Set 7

ML11346A012
Person / Time
Site:	South Texas
Issue date:	12/06/2011
From:	Rencurrel D South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-11002763, TAC ME4936, TAC ME4937
Download: ML11346A012 (27)

Text

Nuclear Operating Company South Tcas Proet Edlectrik Generatin$ Station P.. Box 289 Wadsworth. Tess 77483 A AA A December 6, 2011 NOC-AE-1 1002763 10 CFR 54 STI: 33091622 File: G25 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Response to Requests for Additional Information for the South Texas Project License Renewal Application Aging Management Program, Set 7 (TAC Nos. ME4936 and ME4937)

References:

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

2. NRC letter dated November 3, 2011, "Requests for Additional Information for the Review of the South Texas Project, Units 1 and 2 License Renewal Application -

Aging Management Program, Set 7 (TAC Nos. ME4936 and ME 4937)

(AE-NOC-1 1002188) (ML11299A105)

By Reference 1, STP Nuclear Operating Company (STPNOC) submitted a License Renewal Application (LRA) for South Texas Project (STP) Units 1 and 2. By Reference 2, the NRC staff requests additional information for review of the STP LRA. STPNOC's response to the request for additional information is provided in Enclosure 1 to this letter. Changes to the LRA described in are depicted in line-in/line-out pages provided in Enclosure 2. provides a revised regulatory commitment to the LRA. There are no other regulatory commitments provided in this letter.

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

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

Executed on 12,/)-

1

Dante I

W Rencurrel Senior Vice President, Technical Support & Oversight KJT

Enclosure:

1. STPNOC Response to Requests for Additional Information

2. STP LRA Changes with Line-in/Line-out Annotations

3. Revised LRA Regulatory Commitments A4-IfrQ 0dpk

NOC-AE-1 1002763 Page 2 cc:

(paper copy)

(electronic copy)

Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 612 East Lamar Blvd, Suite 400 Arlington, Texas 76011-4125 Balwant K. Singal Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North (MS 8B1) 11555 Rockville Pike Rockville, MD 20852 Senior Resident Inspector U. S. Nuclear Regulatory Commission P. O. Box 289, Mail Code: MN116 Wadsworth, TX 77483 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704 John W. Daily License Renewal Project Manager (Safety)

U.S. Nuclear Regulatory Commission One White Flint North (MS 011-Fl)

Washington, DC 20555-0001 Tam Tran License Renewal Project Manager (Environmental)

U. S. Nuclear Regulatory Commission One White Flint North (MS OllF01)

Washington, DC 20555-0001 A. H. Gutterman, Esquire Kathryn M. Sutton, Esquire Morgan, Lewis & Bockius, LLP John Ragan Chris O'Hara Jim von Suskil NRG South Texas LP Kevin Polio Richard Pena City Public Service Peter Nemeth Crain Caton & James, P.C.

C. Mele City of Austin Richard A. Ratliff Alice Rogers Texas Department of State Health Services Balwant K. Singal John W. Daily Tam Tran U. S. Nuclear Regulatory Commission NOC-AE-1 1002763 Enclosure I STPNOC Response to Requests for Additional Information NOC-AE-1 1002763 Page 1 of 9 STPNOC Response to Requests for Additional Information SOUTH TEXAS PROJECT, UNITS I AND 2 REQUEST FOR ADDITIONAL INFORMATION -

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

Fuel Oil Chemistry (031)

RAI B2.1.14-1

Background:

The updated final safety analysis report (UFSAR) Supplement description contained in the Standard Review Plan for License Renewal (SRP-LR), Table 3.0-1, "FSAR Supplement for Aging Management of Applicable Systems," provides an acceptable program description which includes the specific American Society for Testing and Materials International (ASTM) standards to be used for the monitoring and controlling of fuel oil contamination to maintain fuel oilquality. License renewal application (LRA) Section A1.14, "Fuel Oil Chemistry," states "The program includes (a) surveillance and monitoring procedures for maintaining fuel oil quality by controlling contaminants in accordance with the Technical Specifications and applicable ASTM Standards..."

Issue:

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

Request:

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

S7PNOC Response:

LRA Appendices A1.14 and B2.1.14 have been revised to include ASTM Standards D1796, D2276, and D4057. South Texas Project uses only ASTM Standard D1796, not ASTM Standard D2709, for determining water and sediment contamination in diesel fuel. Appendix B2.1.14, Exceptions to NUREG-1801, Scope of Program (Element 1), Parameters Monitored or Inspected (Element 3), and Acceptance Criteria (Element 6), documents the technical justification for using ASTM Standard D1796 and not ASTM Standard D2709. provides the revision to LRA Appendices Al.14 and B2.1.14.

NOC-AE-1 1002763 Page 2 of 9 RAI B2.1.14-2:

Back-ground:

After the issuance of Revision 1 of the NUREG-1 801, "Generic Aging Lessons Learned (GALL)

Report," the U.S. Nuclear Regulatory Commission (NRC) issued Information Notice (IN) 200902, "Biodiesel in Fuel Oil Could Adversely Impact Diesel Engine Performance," This IN discusses potential issues that may occur with the use of B5 blend fuel oil, such as suspended water particles, biodegradation of B5, material incompatibility, and so on.

Issue:

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

Request:

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

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

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

STPNOC Response:

1. Summary of actions taken to determine the impact of IN 2009-02:

a) The impact of using a biodiesel blend in the STP diesel engines within the scope of license renewal has not been fully evaluated. The current STP strategy is to prevent all concentrations of the biodiesel blends from entering the fuel oil system. The impact of long-term storage of biodiesel fuel oil and impact of biodiesel fuel oil on full engine operations must both be considered if this type of fuel oil is implemented. See the response to Item 3 for more information.

b) STP performed an engineering evaluation of the impact of NRC Information Notice (IN) 2009-02 with the conclusion of the evaluation stated below. This evaluation specifically reviewed and evaluated the Cooper-Bessemer Owners Group (CBOG) sponsored document MPR - 2980 "Evaluation of Ultra Low Sulfur and B5 Diesel Fuel for Use in EDGs."

NOC-AE-1 1002763 Page 3 of 9 "Biodiesel has inherent characteristics that are problematic for storage and could impact the functionality of the STP diesel systems due to an increase in particulate matter in the fuel. Fuel containing measurable amounts of biodiesel is not acceptable due to potential deleterious effects on reliability."

c) The Diesel Fuel Oil Group (DFOG) position paper "Biodiesel Remediation" recommends that absolutely no biodiesel (zero percent) shall be intentionally received into diesel fuel oil storage tanks. The DFOG position paper discusses that if biodiesel levels of less than one percent are present in the main storage tanks, it is likely there will be no impact to the fuel oil or fuel oil system. At or above biodiesel levels of one percent, the DFOG position paper recommends remediation testing and compensatory measures of filtering, diluting, or changing out the entire fuel supply depending on fuel properties.

The STP Chemistry Department performed an evaluation of IN 2009-02 and concluded that the field instruments to be used in evaluating shipments of fuel oil shall have a lower detection level of 0.5 percent biodiesel. If the biodiesel level in a shipment is at the maximum undetectable limit, the concentrations of biodiesel would be diluted to approximately 0.015 percent or approximately 67 times lower than the proposed one percent limit (acceptable limit from IN 2009 - 02) once added to the auxiliary fuel oil storage tank. It was also noted that STP has an external filtration skid that is used to remove water and particulates.

2. Biodiesel is currently not being used at STP.

3. As stated in the response to item 1 above, the impact of using a biodiesel blend in the STP diesel engines within the scope of license renewal has not been fully evaluated. The long term storage and the full engine operational impacts must both be considered.

The following actions have been taken to prevent the introduction of biodiesel blends into the fuel oil system.

a. The STP fuel oil supplier (Thomas Petroleum) was contacted. STP was informed that:

i. Deliveries to STP always are with Thomas Petroleum fleet trucks. Thomas Petroleum does not carry biodiesel in the trucks that supply fuel to our site.

ii. Diesel fuel for the Flint Hills rack location comes solely from the Corpus Christi Flint Hills refinery. Additionally, there is no biodiesel processed at the refinery or stored at the racks.

b. STP blanket contract number B02348 was changed to prohibit the fuel oil supplier from supplying biodiesel in any concentration.

c. Before off-load to the Auxiliary Fuel Oil Storage Tank (AFOST), each fuel trailer is tested for biodiesel with the Herguth field kit (0.5 percent biodiesel lower limit of detection)

NOC-AE-1 1002763 Page 4 of 9 The following actions will be taken if biodiesel is inadvertently added to the fuel oil system:

The actions that will be taken will depend upon the quantity of biodiesel inadvertently added.

The quantity of biodiesel added may be so small in comparison to the AFOST fuel oil volume that no action may be required.

If one truck of biodiesel fuel oil (approximately 7,000 gallons) was inadvertently off-loaded and added to the average fuel oil level maintained in the AFOST (approximately 170,460 gallons), the resulting concentration of biodiesel in the AFOST would be approximately 0.21 percent biodiesel. This is less than 4 times below the 1 percent biodiesel levels discussed in the "DFOG Biodiesel Paper" - a level where it is likely there is no impact to the fuel oil or fuel oil system.

If biodiesel contamination is detected in the STP AFOST or other diesel engine fuel oil tanks within the scope of license renewal, then the following actions will be performed:

(a) A representative fuel oil sample is sent offsite for comprehensive and independent analysis and biodiesel testing (0.1 percent biodiesel lower limit of detection). Additional actions required will be determined by the measured percentage of biodiesel.

(b) If required, additional fuel oil filtration is performed through the Unit 1 or Unit 2 fuel oil filtration skid. The Unit 1 and Unit 2 fuel oil filtration skids include a 5.0 micron pre-filter, a separator/coalescer (removes water and particulates), and a 0.5 micron post-filter.

(c) If required, additional (shorter than current periodicities) de-watering is performed of the AFOST and the FOSTs.

(d) If required, perform (shorter than current periodicities) testing of the fuel oil is performed.

(e) If required, fuel oil supplies are treated with biocide, water dispersant, fuel stabilizer, or other chemical additions.

RAI B2.1.14-3

Background:

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

Issue:

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

NOC-AE-1 1002763 Page 5 of 9 Reguest:

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

STPNOC Response:

Auxiliary Fuel Oil Storage Tank (AFOST) Fuel Oil Vendor fuel oil storage trailer tanks are used to deliver new fuel oil to the AFOST. ASTM D4176 clear and bright analysis is performed on the new fuel oil prior to offload to verify fuel oil quality. The fuel oil shipment is rejected if the clear and bright analysis fails the acceptance criteria. A condition report is written and corrective action is taken with the fuel oil vendor.

Since 2009, the clear and bright test of vendor delivered fuel failed on November 11, 2009, December 21, 2010, April 18, 2010, and April 19, 2010. All of the failures were due to particles. These fuel oil shipments were rejected. The fuel oil chemistry of the AFOST remained in specification throughout this period. The fuel oil supplier to the fuel oil vendor has changed twice due to South Texas Project (STP) concerns with fuel oil quality. The latest change occurred in April 2011. Since this change, no additional failures of vendor delivered fuel have occurred.

Analyses of water and sediment in the AFOST (1997 to present) have been 0.0 percent.

Analyses of particulate contamination in the AFOST (1997 to present) have been within specification (i.e., less than 10 parts per million (ppm)) with actual values of less than 6 ppm.

Fire Pump Fuel Oil Storage Tank Fuel Oil Beginning in 2009, the clear and bright analyses of ASTM D4176 have been used for testing of the Fire Pump diesel fuel. There were no analyses failures due to water.

Previous to 2009, water analyses were performed by the Karl Fischer titration method. All analyses results met specification.

The particulate contamination method of ASTM D2276 is used for sediment determination.

On three occasions, particulate measured high out-of-specification in Fire Pump Fuel Oil Storage Tank Fuel Oil samples. The cause of two out-of-specification samples in 2004 was attributed the addition of biocide that resulted in a release of rust particles. The third out-of-specification sample result occurred in 2007 when the fuel oil particulate sample in one Fire Pump Fuel Oil Storage Tank measured 13.5 ppm. Corrective action was taken to drain the fuel oil and clean the tank.

Since 2007, all fuel oil particulate sample results for the Fire Pump Fuel Oil Storage Tank have been within specification.

Diesel Generator Fuel Oil Storage Tank (DGFOST) Fuel Oil In 2004, the particulate sample result of the fuel oil in DGFOST #11 was high out-of-specification (36 ppm). The tank was re-circulated through a filter skid and the fuel oil NOC-AE-1 1002763 Page 6 of 9 returned to within specification. The particulate was primarily carbonaceous in nature resulting from the normal deterioration of stored fuel oil over time. The corrective action is periodic scheduled fuel oil cleaning using the permanently installed fuel oil filtration skid.

The DGFOSTs have the capability to be re-circulated through a filter skid. The filter skid includes two particulate filters and a filter to remove water. The preventive maintenance item to re-circulate and filter the fuel oil from the DGFOSTs was changed in early 2005 to re-circulate the tanks from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In mid 2005, the fuel oil sample point was also changed to a local point on the bottom of the tank. Since 2006, the DGFOST fuel oil particulate sample results have remained within specification of less than 10 ppm with actual values of less than 6 ppm.

Conclusion Corrective actions have been effective in maintaining fuel oil chemistry in specification.

RAI B2.1.14-4 Back ground:

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

LRA aging management program (AMP) B2.1.14, "Fuel Oil Chemistry Program," states that the program procedures will be enhanced to include 10-year periodic draining, cleaning, and inspection for corrosion of the standby diesel generator (SDG) fuel oil drain tanks and diesel fire pump fuel oil storage tanks.

Issue:

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

Request:

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

STPNOC Response:

The BOP Diesel Fuel Oil Day Tanks were inadvertently omitted from the first procedure enhancement in LRA Appendix B2.1.14, Fuel Oil Chemistry Program, for Preventive Actions NOC-AE-1 1002763 Page 7 of 9 (Element 2), Parameters Monitored or Inspected (Element 3), and Detection of Aging Effects (Element 4) regarding the 10-year periodic draining, cleaning, and inspection of the tanks for corrosion.

The first procedure enhancement to Preventive Actions (Element 2), Parameters Monitored or Inspected (Element 3), and Detection of Aging Effects (Element 4) in LRA Appendix B2.1.14, Fuel Oil Chemistry Program, is revised to read:

Procedures will be enhanced to include 10-year periodic draining, cleaning, and inspection for corrosion of the SDG fuel oil drain tanks, lighting diesel generator fuel oil tank, BOP diesel fuel oil day tanks, and diesel fire pump fuel oil storage tanks.

The second procedure enhancement to Preventive Actions (Element 2), Parameters Monitored or Inspected (Element 3), and Detection of Aging Effects (Element 4) in LRA Appendix B2.1.14, Fuel Oil Chemistry Program, has been combined with the first enhancement and is not required. This enhancement is deleted.

See Enclosure 2 for the revision to the LRA. Enclosure 3 provides a revised LRA regulatory commitment.

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

Back~ground:

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

Issue:

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

Request:

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

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

3. Describe how the applicant will ensure that there will be proper maintenance of the protective coatings inside containment such that they will not become a debris source that NOC-AE-1 1002763 Page 8 of 9 could impact the operability of post-accident safety systems that rely on water recycled through the containment sump or drain system during the period of extended operation.

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

STPNOC Response:

1. South Texas Project (STP) does not credit coatings for managing the aging of structural components. Visual inspections of coated surfaces are performed to identify coating degradation as an indicator of the condition of underlying material. These visual inspections are conducted as part of the ASME Section Xl, Subsection IWE program and the Structures Monitoring Program. Appendix B2.1.32, Structures Monitoring Program, states, STP does not take credit for any coatings to manage the aging of structural components, and coating degradation is used only as an indicator of the condition of underlying material.

2. STP implemented a Service Level 1 coatings program in response to NRC Generic Letter 98-04 (Ref. NOC-AE-000350) that provides controls for the procurement, application, and maintenance of Service Level 1 protective coatings used inside containment. These controls ensure that protective coatings inside containment will not become a debris source that could affect the operability of post-accident safety systems. Coatings used inside the containment have been established as safety-related, thus imposing the quality assurance requirements of 10 CFR Part 50, Appendix B to the Service Level 1 coatings program, which includes ongoing maintenance activities. Appendix B2.1.39, Protective Coating Monitoring and Maintenance Program provide the details of this existing plant-specific aging management program (see STPNOC NOC-AE-1 1002758 dated November 30, 2011, ML11335A140).

3. The existing Service Level 1 coatings program B2.1.39, Protective Coating Monitoring and Maintenance Program, was added to the LRA as part of the annual update. STPNOC Letter NOC-AE-1 1002758 dated November 30, 2011, provides the addition of Appendices A1.39 and B2.1.39. Revisions to LRA Tables 2.1-1, 2.4-1, and 3.5.2-1, LRA Sections 2.1.6 and 3.5.2.1.1 are provided to show an aging management review line for coatings.

See Enclosure 2 for revision to LRA Tables 2.1-1, 2.4-1, and 3.5.2-1, LRA Sections 2.1.6 and 3.5.2.1.1.

Steam Generator Tube Integrity (020)

RAI B2.1.8-1

Background:

SRP-LR Section 3.1.2.2.11 and the GALL Report identify that cracking due to primary water stress-corrosion cracking (PWSCC) could occur in steam generator (SG) nickel alloy tube-to-tubesheet welds exposed to reactor coolant. The GALL Report recommends the Water Chemistry AMP to manage this aging effect. This aging effect is addressed in GALL Report, NOC-AE-1 1002763 Page 9 of 9 item IV.D1.RP-385, and is applicable to recirculating SGs. In addition, the GALL Report and SRP-LR indicate that unless the NRC has approved a redefinition of the pressure boundary in which the tube-to-tubesheet weld is no longer included, the effectiveness of the primary water chemistry program should be verified to ensure cracking is not occurring. The need for a program depends, in part, on the materials used in joining the tube to the tubesheet.

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

Issue:

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

Request:

For STP Model Delta 94 SGs, confirm that the tube-to-tubesheet weld is part of the reactor coolant pressure boundary and clarify the materials used in forming the tube-to-tubesheet joins (welds). If the tube-to-tubesheet weld is part of the reactor coolant pressure boundary and the cladding material has a chemical composition similar to Alloy 600 (e.g., Alloy 82 or Alloy 182),

provide a plant-specific AMP, along with the Primary Water Chemistry Program, to manage this potential aging effect and ensure that cracking due to PWSCC is not occurring in tube-to-tubesheet welds. Alternatively, justify why no AMP is needed.

STPNOC Response:

The tube-to-tubesheet weld is part of the reactor coolant pressure boundary for the STP Model Delta 94 SGs. The South Texas Project Model Delta 94 replacement steam generator tubesheets are made of carbon steel clad with Alloy 690. The steam generator tubes are thermally treated Alloy 690 as indicated in LRA Section B2.1.8. The tube-to-tubesheet welds are flush-fusion welds with Alloy 690 cladding. The material does not have a chemical composition similar to Alloy 600 (Alloy 82 or Alloy 182).

Plant Specific Note # 2 was added to LRA Table 3.1.2-4 to clarify the material of steam generator tubesheets and tube-to-tubesheet welds (see Amendment 2 to STP LRA -

ML11172A096 ) The aging management evaluation for steam generator tubesheets and tube-to-tubesheet welds is addressed as part of the line for component type SG Tubesheet with material of Nickel Alloy in Table 3.1.2-4. The aging management programs credited for managing primary water stress corrosion cracking are B2.1.8, Steam Generator Tubing Integrity program and B2.1.2, Water Chemistry program.

NUREG 1801, Revision 2, Section 3.1.2.2.11.2: states that for plants with Alloy 690 thermally treated steam generator tubes with Alloy 690 tubesheet cladding the water chemistry program is sufficient and no further action or plant-specific aging management program is required. The aging effect of PWSCC is effectively managed by B2.1.8, Steam Generator Tubing Integrity program, and B2.1.2, Water Chemistry program, as addressed in LRA Table 3.1.2-4. No further action or plant-specific aging management program is required.

NOC-AE-1 1002763 STP LRA Changes with Line-in/Line-out Annotations NOC-AE-1 1002763 Page 1 of 12 List of Revised LRA Sections RAI Affected LRA Section B2.1.14-1 Appendix Al.14 Appendix B2.1.14 B2.1.14-4 Appendix B2.1.14 XI.S8-1 Table 2.1-1 Table 2.4-1 Table 3.5.2-1 Section 2.1.6 Section 3.5.2.1.1.

NOC-AE-1 1002763 Page 2 of 12 Al.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 app"'ab'e ASTM Standards Dl 796, D2276, and D4057, (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).

NOC-AE-1 1002763 Page 3 of 12 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 applieable ASTM Standards D1796, D2276, and D4057, (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 appliable-ASTM Standards D1796, D2276, and D4057.

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/I.

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 contamination by sample filtration at an off-site laboratory. Neither method contains NOC-AE-11002763 Page 4 of 12 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), Parameters Monitored or Inspected (Element 3), and Acceptance Criteria (Element 6)

NUREG-1801 states that ASTM-D2709 is used for guidance in determining water and sediment contamination in diesel fuel. STP uses only ASTM-D1796, not ASTM-D2709, for determining water and sediment contamination in diesel fuel. The testing conducted using ASTM-D1796 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.

Parameters Monitored or Inspected (Element 3) and Acceptance Criteria (Element 6)

NUREG-1801 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.

NOC-AE-1 1002763 Page 5 of 12 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), Parameters Monitored 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, lighting diesel generator fuel oil tank, BOP diesel generator fuel oil day tanks, and diesel fire pump fuel oil storage tanks.

Proc~edures will be enhanced to finspect the BOP diesel generator fu8l oil day tanksca ndthe lighting dliesel generator fuel oil tank for internal corsin 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.

Parameters Monitored 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:

NOC-AE-1 1002763 Page 6 of 12 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.

NOC-AE-1 1002763 Page 7 of 12 Table 2.1-1 Intended Functions: Abbreviations and Definitions (Continued)

ES Expansion/ Separation Provide for thermal expansion and/or seismic separation FB Fire Barrier Provide rated fire barrier to confine or retard a fire from spreading to or from adjacent areas of the plant FIL Filter Provide filtration FLB Flood Barrier Provide flood protection barrier (internal and external flooding event)

GR Gaseous Release Path Provide path for release of filtered and unfiltered gaseous discharge HLBS HELB Shielding Provide shielding against high energy line breaks HS Heat Sink Provide heat sink during SBO or design basis accidents HT Heat Transfer Provide heat transfer IN Insulate (electrical)

Insulate and support an electrical conductor INS Insulate Control heat loss LBS Leakage Boundary (Spatial)

Nonsafety-related component that maintains mechanical and structural integrity to prevent spatial interactions that could cause failure of safety-related SSCs MB Missile Barrier Provide missile barrier (internally or externally generated)

MCI Maintain Coating Integrity Maintain coatinq integrity to prevent clogging of the Emergency Core Cooling Systems PB Pressure Boundary Provide pressure-retaining boundary so that sufficient flow at adequate pressure is delivered, or provide fission product barrier for containment pressure boundary, or provide containment isolation for fission product retention PR Pressure Relief Provide over-pressure protection PWR Pipe Whip Restraint Provide pipe whip restraint NOC-AE-1 1002763 Page 8 of-I 2 Table 2.4-1 Containment Buildina

________________________________~

~

~4N Bellows

!Expansion/Separation Structural Pressure Boundary Structural Support.

.Shlte,-*Protection Caulking and Sealant Coatina Cornpressible Joints and Seals Concrete Block (Masonry Walls)

Concrete Elements Fire Barrier Coatings and Wraps Fire Barrier Doors IGate IMaintain Coating Integrity S§helter, Protection 4Structural Pressure Boundary Fire Barrier Structural Support Fire Barrier Flood Barrier HELB Shielding Missile Barrier Shelter, Protection

,Shielding

'Structural Pressure Boundary Structural Support 1

!Fire Barrier

.Fire Barrier

.Structural Pressure Boundary i

Hatch - Auxiliary Airlock Hatch - Equipment Hatch - Personnel Airlock Hatches and Plugs

• iner Containment (Shielding Structural Pressure Boundary

!.Structural SuppOrt..

Structural Pressure Boundary Structural Support---------.

Fire Barrier, Shielding Structural Pressure Boundary

'StructuralSu ppo-----------------..

Missile Barrier Shelter, Protection Structural Pressure Boundary NOC-AE-1 1002763 Page 9 of 12 Table 3.5.2-1 Cor Buil

.Com-p-oneOnt -Ienc*

Type unct ic

'Caulking and

SH Sealant tainments, Structures, and Component Supports - Summary of Aging Management Evaluation - Containment Coatings Compressible Joints and Seals MCI Coatings ldicit. IIUUUI /'%I LUbj U1 Sbdlilly, MI" Vlr",.LtUII Al, IIQ.'Q.

O.0.

D.I0

'(Structural) (Ext)

Leakage through

'Subsection IWE 1containment i(B2.1.27) and 110 CFR 50,

!Appendix J B2.1.30)

Plant Indoor Air Loss of coating Protective Coating None None J 4 (Structural) (Ext) integrity Monitoring and J Maintenance (B2.1.39)

PlantIndoorAir..... ;Loss-ofseaIiin-g.

ASME SectionXI, II.A3.7

-3...

16.

(Structural) (Ext)

Leakage through

{Subsection IWE

'containment

((B2.1.27) and i

10 CFR 50,

SH, SPB Elastomer Notes for Table 3.5.2-1:

Plant Specific Notes:

1 NUREG-1 801 does not provide a line in which concrete masonry is inspected per the Fire Protection program (B2.1.12).

2 NUREG-1 801 does not provide a line in which fire barriers (ceramic fiber or cementitious coating) are inspected per the Fire Protection program (B2.1.12).

3 NUREG-1801 does not have this combination for the containment building, therefore, NUREG-1801, line II1.A6-12 is used 4

NUREG-1801 does not provide a line in which coatinas are inspected Der the Protective Coatina Monitoring and Maintenance program (B2.1.39).

NOC-AE-1 1002763 Page 10 of 12 2.1.6 Generic Safety Issues In accordance with the guidance in NEI 95-10 and Appendix A.3 of NUREG-1 800, Standard Review Plan for the Review of License Renewal Applications for Nuclear Power Plants, review of NRC Generic Safety Issues (GSIs) as part of the license renewal process is required to satisfy a finding per 10 CFR 54.29. GSIs that involve issues related to license renewal aging management reviews or time-limited aging analyses are to be addressed in the LRA. As a result of the review of NUREG-0933, Supplement 32, dated July 2008, the following GSIs have been evaluated for license renewal:

1. GSI-163, Multiple Steam Generator Tube Leakage This GSI involves the potential multiple steam generator tube leaks during a main steam line break that cannot be isolated. Steam generator tubes are part of the reactor coolant pressure boundary and are the subject of an AMR and TLAA evaluation as documented in Section 3.1 and Chapter 4 respectively. Aging management of steam generator tubes is addressed within the CLB of the plant and will continue to be addressed during the period of extended operation by the Steam Generator Tube Integrity program discussed in Section B2.1.8.

2. GSI-190, Fatigue Evaluation of Metal Components for 60-year Plant Life This GSI addresses fatigue life of metal components and was closed by the NRC.

However, the NRC concluded that license renewal applicants should address the effects of reactor coolant environment on component fatigue life. Accordingly, the issue of environmental effects on component fatigue life is addressed in Section 4.3.

3. GSI-1 91, Assessment of Debris Accumulation on PWR Sump Performance GSI-191 addresses the potential for blockage of containment sump strainer assembly that filters debris from cooling water supplied to the safety injection and containment spray pumps following a postulated LOCA. The issue is based on containment strainer design and on the identification of new potential sources of debris that may block the sump strainers. STPNOC submitted to the NRC a response to Generic Letter (GL) 2004-02 by STPNOC NOC-AE- 05001862, 90-Day Response to Generic Letter 2004-02: Potential Impact of Debris Blockage on Emergency Recirculation during Design Basis Accidents at Pressurized-Water Reactors, dated March 8, 2005, South Texas Project, Units 1 and 2 - Supplement 1 to the Response to Generic Letter 2004-02 (TAC Nos. MC4719 and MC4720), and later supplements. The issues identified in GSI-191 and GL 2004-2 are not aging-related issues. Also, the issues are not related to the 40-year term of the current operating license, and therefore, are not time-limited aging analyses. The containment sump strainer assemblies are evaluated in Section 2.3.2.4, Safety Injection-. CoatinQs and the containment sumps are evaluated in Section 2.4.1, Containment Building. The Protective Coatingq Monitoring and Maintenance Program is discussed in Section B2.1.39, Protective Coating Monitoring and Maintenance Program.

NOC-AE-1 1002763 Page 11 of 12 3.5.2.1.1 Containment Building Materials The materials of construction for the containment building component types are:

Carbon Steel Coatings

. Concrete Concrete Block (Masonry Walls)

Elastomer Fire Barrier (Cementitious Coating)

Stainless Steel Stainless Steel; Dissimilar Metal Welds Environment The containment building component types are exposed to the following environments:

Atmosphere/ Weather (Structural)

Buried (Structural)

Encased in Concrete Plant Indoor Air (Structural)

Submerged (Structural)

Aging Effects Requiring Management The following containment building 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)

Increase in porosity, permeability Loss of coating integrity Loss of leak tightness Loss of material NOC-AE-1 1002763 Page 12 of 12 0

Loss of material (spalling, scaling) and cracking Loss of material, cracking 0

Loss of sealing Loss of sealing; Leakage through containment Aging Management Programs The following aging management programs manage the aging effects for the containment building component types:

10 CFR Part 50, Appendix J (B2.1.30) 0 ASME Section Xl, Subsection IWE (B2.1.27) 0 ASME Section XI, Subsection IWL (B2.1.28)

Fire Protection (B2.1.12)

Masonry Wall Program (B2.1.31) 0 Protective Coatinq Monitoring and Maintenance (B2.1.39) 0 Structures Monitoring Program (B2.1.32) 0 Water Chemistry (B2.1.2)

NOC-AE-1 1002763 Revised LRA Regulatory Commitments NOC-AE-1 1002763 Page 1 of 1 A4 LICENSE RENEWAL COMMITMENTS Table A4-1 identifies proposed actions committed to by STPNOC for STP Units 1 and 2 in its License Renewal Application. These and other actions are proposed regulatory commitments. This list will be revised, as necessary, in subsequent amendments to reflect changes resulting from NRC questions and STPNOC responses. STPNOC will utilize the STP commitment tracking system to track regulatory commitments. The Condition Report (CR) number in the Implementation Schedule column of the table is for STPNOC tracking purposes and is not part of the amended LRA.

Table A4-1 License Renewal Commitments

• Itmm

....... *`:`:*`.*:K.`t;*-*.-`-.

mI enntat`ion.

it G-M-:'

nPII 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, BOP diesel generator fuel oil day tanks, and diesel fire pump fuel oil storage tanks,

• nspect 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.