NOC-AE-11002716, Response to Request for Additional Information for the South Texas Project License Renewal Application (TAC ME4936 and ME4937)

Response to Request for Additional Information for the South Texas Project License Renewal Application (TAC ME4936 and ME4937)

ML11238A071
Person / Time
Site:	South Texas
Issue date:	08/18/2011
From:	Gerry Powell South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-11002716, TAC ME4936, TAC ME4937
Download: ML11238A071 (6)

Text

Nuclear Operating Company South Texas ProjectElectric Geneating Station PO.Box289 Wadsworth, Texas 77483 August 18, 2011 NOC-AE-1 1002716 10CFR54 STI: 32916347 File: G25 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2746 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Response to Request for Additional Information for the South Texas Proiect License Renewal Application (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. STPNOC letter dated June 23, 2011, from G. T. Powell to NRC Document Control desk, "Response to Request for Additional Information for the South Texas Project License Renewal Application" (NOC-AE-1 1002683) (ML11181A037)

3. Teleconference between the STPNOC and the NRC on August 8, 2011 (ML11222A001)

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, STP provided a response to a request for additional information by the Nuclear Regulatory Commission regarding the future use of operating experience to identify aging issues, evaluate them, and, as necessary, enhance Aging Management Programs (AMP) or develop new AMPs for license renewal. During a teleconference with the Nuclear Regulatory Commission staff on August 8, 2011 (Reference 3),

STP agreed to provide additional clarification to the response provided in Reference 2. The clarification is provided in the enclosure to this letter. LRA Amendment 3 resulting from the response is included with the enclosure.

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.

4ILVY

NOC-AE-1 1002716 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on .,#iml Date G. T. Powell Vice President, Technical Support & Oversight KJT

Enclosure:

Clarification to STPNOC Response to Request for Additional Information (includes Amendment 3 to the LRA)

NOC-AE-1 1002716 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 Ed Alarcon 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 011-Fl)

Washington, DC 20555-0001 Balwant K. Singal Tam Tran John W. Daily License Renewal Project Manager Tam Tran (Environmental) U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission One White Flint North (MS 011 F01)

Washington, DC 20555-0001

Enclosure NOC-AE-1 1002716 Page 1 of 1 Clarification to STPNOC Response to Request for Additional Information SOUTH TEXAS PROJECT LICENSE RENEWAL APPLICATION REQUESTS FOR ADDITIONAL INFORMATION REGARDING THE USE OF OPERATING EXPERIENCE

References:

1. STPNOC letter dated June 23, 2011, from G. T. Powell to NRC Document Control desk, "Response to Request for Additional Information for the South Texas Project License Renewal Application", (NOC-AE-1 1002683)

(ML11181A037)

2. Teleconference between the STPNOC and the NRC on August 8, 2011 (ML11222A001)

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

(ML103010257)

NRC Reauested Information:

By Reference 1, STP provided a response to a request for additional information by the Nuclear Regulatory Commission regarding the future use of operating experience to identify aging issues, evaluate them, and, as necessary, enhance Aging Management Programs (AMP) or develop new AMPs for license renewal. During a teleconference with the Nuclear Regulatory Commission staff on August 8, 2011 (Reference 2), STP agreed to provide additional clarification to the responses provided in Reference 1. Specifically, the staff requested that STP clarify the intended location within its Updated Final Safety Analysis Report supplement that describes how STP will use future operating experience to inform and modify, as required, its aging management programs.

STPNOC Response:

STP revised Section Al of the Updated Final Safety Analysis Report supplement to describe how future operating experience will be used to inform and modify, as required, its aging management programs. This revision is attached to this enclosure as Amendment 3 to the License Renewal Application.

Attachment to Enclosure NOC-AE- 1l002716 Attachment to Enclosure Amendment 3 to the South Texas Project License Renewal Application Note: Changes to the License Renewal Application are annotated by lined-in information and a change bar.

Attachment to Enclosure NOC-AE-1 1002716 Page 1 of 1 Appendix A Final Safety Analysis Report Supplement Al

SUMMARY

DESCRIPTIONS OF AGING MANAGEMENT PROGRAMS The integrated plant assessment and evaluation of time-limited aging analyses (TLAA) identified existing and new aging management programs necessary to provide reasonable assurance that components within the scope of license renewal will continue to perform their intended functions consistent with the current licensing basis (CLB) for the period of extended operation. Sections Al and A2 describe the programs and their implementation activities.

Three elements common to all aging management programs discussed in Sections Al and A2 are corrective actions, confirmation process, and administrative controls. The STP Quality Assurance Program includes the elements of corrective action, confirmation process, and administrative controls, and is applicable to the safety-related and nonsafety-related systems, structures, and components that are subject to aging management activities.

Operating experience is applied to all aging management programs discussed in Sections Al and A2. Plant-specific and industry operating experience is continuously reviewed to confirm the effectiveness of aging management programs and is utilized, as necessary, to enhance each aging management program or to develop new aging management programs in order to adequately manage the effects of aging so that the intended function(s) of structures and components are met.

South Texas Project License Renewal Application Amendment 3