ML12124A227

Supplemental Response to Request for Additional Information Item B2.1.30-1 for License Renewal Application

ML12124A227
Person / Time
Site:	South Texas
Issue date:	04/26/2012
From:	Rencurrel D South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-12002839, STI: 33475236, TAC ME4936, TAC ME4937
Download: ML12124A227 (13)

Text

Nuclear Operating Company South Texas Project Electric Generating Station PO Box 289 Wadsworth. Texas 77483

%A April 26, 2012 NOC-AE-12002839 10 CFR 54 STI: 33475236 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 Supplemental Response to Request for Additional Information (RAI) Item B2.1.30-1 for the South Texas Project License Renewal Application (TAC Nos. ME4936 and ME4937)

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References:

1. STPNOC letter dated October 25, 2010, from G. T. Powell to NRC Document Control Desk, "License Renewal Application" (NOC-AE-1 0002607)

(ML103010257)

2. STPNOC letter dated October 10, 2011, from G. T. Powell to NRC Document Control Desk, "Response to Requests for Additional Information for the South Texas Project License Renewal Application (TAC Nos. ME4936 and ME4937)"

(NOC-AE-1 1002732) (ML11291A152)

3. Record of Teleconference between STPNOC and the NRC, "Request for Additional Information, STP Units 1 and 2 License Renewal Application -

Confirmatory Items April 16, 2012" (ML12115A272)

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, STPNOC provided a response to Request for Additional Information (RAI) Item B2.1.30-1. By Reference 3, STPNOC agreed to supplement the response to RAI Item B2.1.30-1. The supplemental response is provided in Enclosure 1 to this letter. Changes to the LRA described in Enclosure 1 are depicted as line-in/line-out pages provided in Enclosure 2.

There are no 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.

4L14 0k~z---

NOC-AE-12002839 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on W/2 6 ItOI 2-

' Date D. W. Rencurrel Chief Nuclear Offi(

KJT

Enclosure:

1.

2.

STPNOC Supplemental Response to RAI B2.1.30-1 STPNOC LRA Changes with Line-in/Line-out Annotations

NOC-AE-12002839 Page 3 cc:

(paper copy)

(electronic copy)

Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington, Texas 76011-4511 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. 0. Box 289, Mail Code: MN1 16 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-F1)

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

U. S. Nuclear Regulatory Commission One White Flint North (MS O11F01)

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-12002839 STPNOC Supplemental Response to RAI B2.1.30-1 NOC-AE-12002839 Page 1 of 5 RAI B2.1.30-1 in Reference 2 Backqround:

10 CFR Part 50, Appendix J, states that containment isolation valves are subject to Type C tests. By letters dated July 13, 1999, as supplemented October 14 and 22, 1999, January 26 and August 31, 2000, and January 15, 18, 23, March 19, May 8 and 21, 2001, (hereinafter, the submittal, Adams accession number ML011430090), STPNOC requested an exemption from 10 CFR Part 50, Appendix J, Option B, Section Ill.B, "Type B and C Tests," for the life of each unit (STPNOC has 2 PWR units) to the extent that this regulation imposes Type C leakage rate testing on certain containment isolation valves. The scope of the exemption includes containment isolation valves categorized as low safety significant (LSS) or non-risk significant (NRS).

The staff also noted that 10 CFR 54.4(a)1, states "Plant systems, structures, and components within the scope of this part are safety-related systems, structures, and components which are those relied upon to remain functional during and following design-basis events (as defined in 10 CFR 50.49 (b)(1)) to ensure the integrity of the reactor coolant pressure boundary; (and) the capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to those referred to in § 50.34(a)(1), § 50.67(b)(2), or § 100.11 of this chapter, as applicable."

Issue:

The staff reviewed the LRA, including the AMR Tables line items, but was not clear whether the containment isolation valves and associated penetrations which are exempt from 10 CFR Part 50, Appendix J testing are within the scope of license renewal.

In addition, the staff noted that the Operating Experience Community database indicates that containment isolation valves could be damaged by operating conditions. In 2006, NRC issued IN 2006-15 alerting licensees of possible vibration induced degradations and failures of containment isolation valves. According to the applicant's letter to NRC, dated August 31, 2000 (ML3749001 0), the applicant stated that its alternate reliability strategy for these valves and penetrations includes corrective actions and periodic feedbacks. It is not clear to the staff, however, what action(s) the applicant has taken in regards to IN 2006-15.

Request:

1. Indicate whether the containment isolation valves and associated penetrations, for which the exemption for Type B and C 10 CFR Part 50, Appendix J Tests was granted, are within the scope of license renewal. If not, provide justification.

2. Describe if any modifications or changes have taken place on the LSS/NRS valves/penetrations, including (but not limited to) those in response to IN 2006-15. If so, how did these modifications or changes impact the aging management of the components? If any valves/penetrations that once were exempt, but now because of corrective or other actions/modifications, are subject to aging management as NOC-AE-12002839 Page 2 of 5 recommended, for example, by GALL Report XI.S4, "10 CFR Part 50, Appendix J" Program, explain how the applicant will manage aging effects for these during the period of extended operation.

3. Discuss whether or not the applicant's specific management program/controls (see STPNOC letter to NRC referenced in Request 1 above and UFSAR section 13.7) will ensure the functionality of the valves and integrity of penetrations are adequate to provide aging management (e.g. cracking, loss of material, loss of leak tightness and sealing) during the period of extended operation.

4. Indicate if any other components that have been exempted under 10 CFR 50.12(a)(2)(vi) are subject to 10 CFR 54.4. If so, explain how these components are dispositioned within the LRA.

STPNOC Response in Reference 2

1. Isolation valves and penetrations that are part of the containment pressure boundary are within the scope of license renewal. Even those isolation valves and penetrations exempted from Type B and C testing are still subject to Type A testing and visual examination, if required, under the 10 CFR Part 50, Appendix J program.

2. Modifications or changes to LSS/NRS valves/penetrations, including (but not limited to) those in response to IN 2006-15, have not impacted the aging management of the components. No systems, structures, or components (SSCs) are exempt from the scope of license renewal based on risk significance. Any SSC classified as low safety significant (LSS) or non-risk significant (NRS) credited with performing a intended function will be managed for aging throughout the period of extended operation as referenced in implementing procedure OPSP1 1-ZA-0005 "Local Leakage Rate Test Calculations, Guidelines, and Program" section 4.11 and described in UFSAR Chapter 13.7 "Risk-informed Special Treatment Requirements" and Table 13.17-1, "Exemptions from Special Treatment Requirements".

3. The functionality of the valves and integrity of penetrations are ensured by managing the aging of these components with the appropriate aging management program. No SSCs are exempt from the scope of license renewal based on risk significance. Any SSC classified as low safety significant (LSS) or non-risk significant (NRS) credited with performing a intended function will be managed for aging throughout the period of extended operation as referenced in implementing procedure OPSP1 1-ZA-0005 "Local Leakage Rate Test Calculations, Guidelines, and Program" section 4.11 and described in UFSAR Chapter 13.7 "Risk-informed Special Treatment Requirements" and Table 13.17-1, "Exemptions from Special Treatment Requirements".

4. No SSCs are exempt from the scope of license renewal based on risk significance. Any SSC classified as low safety significant (LSS) or non-risk significant (NRS) credited with performing a intended function will be managed for aging throughout the period of extended operation as referenced in implementing procedure OPSP1 1-ZA-0005 "Local Leakage Rate Test Calculations, Guidelines, and Program" section 4.11 and described in UFSAR Chapter 13.7 "Risk-informed Special Treatment Requirements" and Table 13.17-1, "Exemptions from Special Treatment Requirements".

NOC-AE-12002839 Page 3 of 5 NRC RAI in Reference 3 The staff noted that the applicant has removed certain containment isolation valves from Type B and C testing under 10 CFR 50 Appendix J surveillances as a result of a license exemption; this exemption had been submitted to the staff and approved based upon a PRA analysis of risk significance, where these valves were designated as either "low safety significance" or "non-risk significant." However, it was not clear which aging management programs (AMPs), if any, would be used to manage aging for these components under license renewal for the period of extended operation.

The staff and the applicant agreed that the applicant would submit a statement that consolidates its aging management plan for these valves by noting that the applicant agrees they are within the scope of license renewal, that the applicant will manage their aging by means of appropriate AMPs (e.g., Water Chemistry, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, One-Time Inspection AMPs, Closed-Cycle Cooling Water System, Lubricating Oil Analysis). It was also agreed that the valves would be part of the pool of eligible components for sampling as per those programs for the applicable material and environment combination, and that the valves' entries in the LRA AMR Tables will be revised as necessary to reflect this approach. The applicant and staff agreed that this would be a supplemental response to RAI B2.1.30-1. The staff agreed to note this as a Confirmatory Item in the SER with Open Items. As a result, the staff and the applicant agreed that draft RAI B2.1.30-3 will be dropped.

STPNOC Supplemental Response The applicable material and environment combinations including aging management program(s) are listed below for containment isolation valves attached to containment penetrations exempted from 10 CFR 50 Appendix J Type B and C surveillance testing. The containment isolation valves attached to these containment penetrations are within the scope of License Renewal and are part of the pool of eligible components for sampling as per the program(s) listed. The applicable LRA 3.x.2 tables for each material and environment combination are listed below. LRA tables 3.2.2-4 and 3.3.2-22 are revised to age manage the valves with an internal environment of nitrogen using aging management program B2.1.22, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components. The environment for these valves is revised from dry gas to plant indoor air to conservatively manage internal condensation since these valves are exempt from 10 CFR 50 Appendix J Type B and C surveillance testing. provides the line-in/line-out revision to LRA Tables 3.2.2-4 and 3.3.2-22.

NOC-AE-12002839 Page 4 of 5

,Penetration LRA Material Environment AMP Internal Envirohnment AMP External No Table

Internal, External~

M-23 3.3.2-6 Carbon Closed Cycle B2.1.10-Closed-Plant Indoor B2.1.22, M-24 Steel Cooling Water Cycle Cooling Air External M-25 Water System Surfaces M-26 Monitoring M-27 Program M-28 M-34 M-36 M-38 M-39 M-40 M-75 3.1.2-2 Carbon Lubricating Oil B2.1.23 -

Plant Indoor B2.1.22, Steel Lubricating Oil Air External Analysis Surfaces B2.1.16-One-Time Monitoring Inspection Program M-68A 3.2.2-4 Carbon Plant Indoor B2.1.22, Plant Indoor B2.1.22, M-57 3.3.2-7 Steel Air Inspection of Air External M-58 Internal Surfaces Surfaces in Miscellaneous Monitoring Piping and Ducting Program Components M-12 3.1.2-2 Stainless Demineralized B2.1.2-Water Plant Indoor None M-16 3.4.2-4 Steel Water Chemistry Air M-45 3.4.2-5 B2.1.16-One-Time M-61 Inspection M-79 M-30 3.1.2-2 Stainless Plant Indoor B2.1.22 -

Plant Indoor None M-68C 3.3.2-7 Steel Air Inspection of Air M-80A 3.3.2-16 Internal M-80D 3.3.2-22 Surfaces in M-80E 3.3.2-26 Miscellaneous M-80F Piping and Ducting M-82A Components M-82D M-82E M-88 M-09 3.2.2-1 Stainless Treated B2.1.2-Water Borated None M-13 3.2.2-4 Steel Borated Water Chemistry Water M-17 3.3.2-8 B2.1.16-One-Time Leakage M-29 Inspection M-45 M-68E M-85A M-85B M-85E M-86 NOC-AE-12002839 Page 5 of 5 Penetration LRA

Material, Environment AMP Internal Environment AMP External No Table Internal External M-82A 3.3.2-22 Stainless Plant Indoor B2.1.22 -

Plant Indoor None Steel Air Inspection of Air Cast Internal Austenitic Surfaces in Miscellaneous Piping and Ducting Components M-56 3.3.2-22 Stainless Treated B2.1.2-Water Borated None Steel Borated Water Chemistry Water Cast B2.1.16-One-Time Leakage Austenitic Inspection I_

I NOC-AE-12002839 STPNOC LRA Changes with Line-inlLine-out Annotations NOC-AE-12002839 Page 1 of 3 List of Revised LRA Sections RAI Affected LRA Section B2.1.30-1 Table 3.2.2-4 Table 3.3.2-22 NOC-AE-12002839 Page 2 of 3 (Ext)

M' I II dl UI Id,,l,'

Monitoring Program (132.1.20)

Valve PB Carbon Steel Plant Indoor Air I(Int)

ILBS, PB, Stainless.

Borated Water S!A

. Steel L-eakage (Ext)

Loss of material

,nternal Surfaces in

'Miscellaneous Piping

,and Ducting Components (B2.1.22)

None INone V.A-19 3.2.1.32 B

Valve V.F-13 3.2.1.57 I A NOC-AE-12002839 Page 3 of 3 Table 3.3.2-22 Auxiliary Systems - Summary of Aging Management Evaluation - Liquid Waste Processing System

Componet, Intended Material Aging Effect Aging Management NIUREG-Table I Item Notes Type Function Requiring I

Program 1801Vol.

_____ IManagement.,

2 Itemr Valve Valve

• Valve LBS, PB,

!SIA

,LBS, PB, ISIA

'Stainless Steel tStainless 1 Steel Plant Indoor Air (Ext)

None

--- +I-i LBS, SIA jStamless Steel Plant indoor Air (Int)

Raw Water (Int)

Loss of material Loss of material None Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B2.1.22)

Inspection of Internal Surfaces in Miscellaneous Piping land Ducting

'Components (B21.1.22)

VII.J-15

.V.A-26 VII.C1-15 3.2.1.08 3.3.1.79 3.3.1.94 E

E, 2 A