ML15026A110

Plan for the 2015 Selective Leaching of Aluminum-Bronze Aging Management Program Regulatory Audit Regarding the South Texas Project, Units 1 & 2, License Renewal Application Review

ML15026A110
Person / Time
Site:	South Texas
Issue date:	02/23/2015
From:	Daily J License Renewal Projects Branch 1
To:	Gerry Powell South Texas
Daily J, NRR/DLR/RPB1, 301-415-3873
References
TAC ME4936, TAC ME4937
Download: ML15026A110 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 23, 2015 Mr. G.T. Powell Site Vice President STP Nuclear Operating Company P.O. Box 289 Wadsworth, TX 77483

SUBJECT:

PLAN FOR THE 2015 SELECTIVE LEACHING OF ALUMINUM-BRONZE AGING MANAGEMENT PROGRAM REGULATORY AUDIT REGARDING THE SOUTH TEXAS PROJECT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION REVIEW (TAC NOS. ME4936 AND ME4937)

Dear Mr. Powell:

By letter dated October 25, 2010, STP Nuclear Operating Company (STPNOC or the applicant) submitted an application for renewal of operating licenses NPF-76 and NPF-80 for South Texas Project (STP), Units 1 and 2. The staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing this application in accordance with the guidance in NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants.

The staff plans to conduct a follow-up regulatory audit of your Selective Leaching of Aluminum Bronze aging management program and associated issues at your facility from March 9, 2015, to March 13, 2015, in accordance with the enclosed regulatory audit plan. If you have any questions, please contact me by telephone at 301-415-3873 or by e-mail at john.daily@nrc.gov.

Sincerely,

/RA/

John W. Daily, Senior Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499

Enclosure:

As stated cc w/encl: Listserv

ML15026A110

• Concurred via email OFFICE LA:RPB1:DLR*

PM:DLR/RPB1 PM:DLR/RERB PM:DLR/RARB*

NAME YEdmonds JDaily DMorey WHolston DATE 2/4/15 2/5/15 2/23/15 2/19/15 OFFICE BC:DLR/RPB1 PM:DLR/RPB1 NAME YDiaz-Sanabria JDaily DATE 2/5/15 2/23/15

Letter to G.T. Powell from John W. Daily dated February 23, 2015

SUBJECT:

PLAN FOR THE 2015 ALUMINUM-BRONZE AGING MANAGEMENT PROGRAM REGULATORY AUDIT REGARDING THE SOUTH TEXAS PROJECT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION REVIEW (TAC NOS. ME4936 AND ME4937)

DISTRIBUTION:

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ENCLOSURE Audit Plan 2015 Followup Audit on Selective Leaching of Aluminum-Bronze Aging Management Program for the South Texas Project, Units 1 and 2 License Renewal Application March 9-13, 2015 Division of License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission License Renewal Aging Management Program Audit Plan South Texas Project

1. Background

By letter dated October 25, 2010, STP Nuclear Operating Company (STPNOC or the applicant),

submitted to the U.S. Nuclear Regulatory Commission (NRC or the staff) its application for renewal of Operating License Nos. NPF-76 and NPF-80 for South Texas Project (STP), Units 1 and 2, respectively. The applicant requested renewal of the operating licenses for an additional 20 years beyond the 40-year current license terms, which expire on August 20, 2027, for Unit 1 and December 15, 2028, for Unit 2. The staff from the Division of License Renewal will lead a follow-up regulatory audit to gain a better understanding of the applicants response to request for additional information (RAI) B2.1.37-5, which was issued as part of Open Item OI 3.0.3.3.3-1, Insufficient details provided regarding applicants Selective Leaching of Aluminum Bronze Aging Management Program (AMP), in the safety evaluation report (SER) with Open Items (ADAMS Accession No. ML13045A356). The audit will cover Aging Management Program (AMP) B2.1.37, "Selective Leaching of Aluminum Bronze" (Aluminum Bronze AMP) and associated aging management reviews, bases, and documentation as applicable.

2. Regulatory Audit Bases License renewal requirements are specified in Title 10 of the Code of Federal Regulations (10 CFR), Part 54 (10 CFR Part 54), Requirements for Renewal of Operating Licenses for Nuclear Power Plants. Guidance is provided in NUREG-1800, Revision 2, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR), dated December 2010, and in NUREG-1801, Revision 2, Generic Aging Lessons Learned (GALL)

Report, dated December 2010.

3. Regulatory Audit Scope and Methodology The scope of this audit is to examine the applicants RAI response, associated materials, and supporting documentation for the AMP. Note that since this program is a plant-specific AMP, it is evaluated on an individual basis for all 10 program elements, along with any associated issues. This follow-up audit will primarily focus on materials and issues concerning the RAI response as needed in order for the staff to complete its review. Results of this audit will be ultimately documented in the staffs SER.

The SRP-LR states that an applicant can choose to establish one or more plant-specific AMPs.

For a plant-specific AMP, it is incumbent on the applicant to ensure that the plant program contains adequate descriptions and depth of bases for all 10 elements of an AMP, in accordance with Branch Technical Position RLSB-1 in the SRP-LR, Appendix A.1. The applicants evaluations and bases for this program shall be documented and maintained in an auditable, retrievable form.

During this audit, the staff will utilize the following Scope and Agenda as a guide. The staff may also examine the applicants program basis documents and related references for this AMP, review background calculations and evaluations as needed, and interview applicant representatives to obtain additional clarification related to the AMP.

SCOPE AND AGENDA

1. Entrance meeting, introduction of personnel, review overall purpose of meeting.

2. Review Analysis Confirmatory Test (ACT) and Profile Examination (PE) test results dating back as far as 1994 to determine adequacy of the results for use as data points.

Discuss ACT test results with applicant to ensure common understanding.

3. Review data and test results associated with the correlation of outside indication size to internal flaw size.

4. Review demonstration(s) (walk-throughs) given by the applicant showing how degree of dealloying is determined. Review fracture samples provided by applicant. Discuss degree of sensitivity resolution of test equipment used.

5. Review the structural integrity analyses with the applicant. The applicant should be prepared to conduct a step-by-step walk-through of each of the analyses with the staff.

6. Review site procedures for determining operability specific to selective leaching when a leaking component is detected.

7. Review acceptance criteria and trending data to be used during the period of extended operation.

8. Decision trees provided in RAI response, Enclosure 1, pages 21-38:

a. Walk through each of the decision trees with the applicant to ensure a common understanding of actions.

b. Understand how these actions will be integrated into the program or into implementing procedures.

9. Discuss STP plans to complete the initial PE and ACT testing prior to issuance of the SER.

10. Based on the results of the audit, resolve what information will need to be submitted on the docket subsequent to the audit.

11. Exit meeting and wrap-up.

4. Information and Other Material Necessary for the Regulatory Audit The project team will review the RAI response, background materials and supporting documentation, as well as the license renewal application (LRA) and other AMP-related basis documents, as appropriate. The project team needs at least one hard-copy set of the RAI responses for aluminum bronze, RAI response references and background materials, the Aluminum Bronze AMP and AMP basis documents, condition reports related to degradation of the aluminum bronze components, documents on repair/replacement of the subject components, flaw evaluation reports, and all other supporting background documentation (including but not limited to items such as calculations, engineering evaluations, 10 CFR 50.59 evaluations, and so on) to be available in the teams work room. If possible, the staff also needs the physical specimens that have been tested, to be available for review.

5. Special Requests The staff emphasizes that, for a successful outcome, the applicant should make every effort to have available at the audit site: (a) copies of relevant materials; (b) management; and (c) technical personnel with expertise in site aluminum bronze issues.

6. Team Assignments NRC Staff participation is projected as follows (some deletions, additions or substitutions may occur on an as-needed basis). Site access is requested; however unescorted access is not expected to be necessary as long as the meeting place is outside of the protected area fence.

Area of Review Assigned Auditor Project Manager John Daily Technical Lead William Holston Technical Reviewer Margaret Audrain Technical Reviewer Chris Hovanec Technical Reviewer Dave Rudland Technical Reviewer Matthew Homiack

7. Logistics The audit will be conducted on location at the STPNOC site, with rooms and space to be supplied by STPNOC.

Work space and team support logistics:

Audit timeframe: 7:30 AM - 4:00 PM.

One general team work area with seating and laptop space for up to 10 people.

One or more break-out rooms for question/answer/small group sessions and meetings, so that work in the main room is not disrupted.

Telephone access for outside business-related calls. The break-out rooms should also have speaker phone capability for conference calls. External internet access as applicable.

Internet access if possible (external only, no access needed to applicants site/business internets)

Access to printers for printing out files, drafts, draft requests for additional information (RAIs), review comments, schedules, and so on.

Access to a copier for making duplicates for team use, meeting agendas.

Lunch arrangement-information is requested; staff members normally pay for any lunches or meals in accordance with NRC policies.

8. Deliverables RAI(s) may be issued as deemed necessary by the staff.

An audit summary report will be issued to the applicant, normally within 90 days from the end of the audit. Final evaluation of the RAI response, the Aluminum Bronze AMP, and related issues will be presented in the staffs SER for the STP license renewal application.