NOC-AE-11002771, Response to Request for Additional Information to the License Renewal Application

Response to Request for Additional Information to the License Renewal Application

ML11362A081
Person / Time
Site:	South Texas
Issue date:	12/15/2011
From:	Rencurrel D South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME4936, TAC ME4937, G25, NOC-AE-11002771, STI: 33160530
Download: ML11362A081 (3)

Text

Nuclear Operating Company South Texas Pro/ertElectric Generatn*g Station PO.Bax 289 Wadsworth, Texas 77483 December 15, 2011 NOC-AE-1 1002771 10 CFR 54 STI: 33160530 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 Request for Additional Information to the South Texas Project License Renewal Application (TAC NOS. ME4936 and ME4937)

Reference:

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 November 21, 2011, from D. W. Rencurrel 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 1002742) (ML11335A131)

3. NRC Letter dated September 22, 2011, "Requests for Additional Information for the Review of the South Texas Project, Units 1 and 2 License Renewal Application -

Aging Management Review, Set 1 (TAC Nos. ME4936 and ME4937)"

(ML11250A043)

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 stated that a response to RAI 3.5.1.59-1 would be provided by a separate submittal. The response is provided in the enclosure to this letter.

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.

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

Executed on 12- I5' [-o. I. I Date D. W. Rencurrel Senior Vice President, Technical Support & Oversight KJT

Enclosure:

Response to RAI 3.5.1.59-1 47 0 ccc

NOC-AE-1 1002771 Page 2 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 Chris O'Hara U.S. Nuclear Regulatory Commission Jim von Suskil One White Flint North (MS 8B1) NRG South Texas LP 11555 Rockville Pike Rockville, MD 20852 Kevin Polio Senior Resident Inspector Richard Pena U. S. Nuclear Regulatory Commission City Public Service P. O. Box 289, Mail Code: MN116 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) 11555 Rockville Pike Rockville, MD 20852 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 O11F01) 11555 Rockville Pike Rockville, MD 20852

Enclosure NOC-AE-1 1002771 Page 1 of 1 Response to RAI 3.5.1.59-1 Stainless Steel (098B)

RAI 3.5.1.59-1 Backgqround:

GALL AMP XI.S3. "ASME Section XI, Subsection IWF," covers the inspection criteria for ASME Code Class 1, 2, and 3 component supports for license renewal and recommends visual inspection of a sample of supports.

LRA Table 3.5.2-11 includes AMR items for stainless steel ASME Class 1, 2, and 3 supports exposed to borated water leakage and plant indoor air which have no AERM assigned and no AMP proposed. The AMR items reference LRA Table 3.5.1, item 3.5.1-59. However, the staff has identified that these supports appear to be within the scope of ASME Code Section XI, Subsection IWF.

Issue:

The staff has identified examples of ASME Class 1, 2, and 3 supports in LRA Table 3.5.2-11 that appear to be within the scope of ASME Code Section XI, Subsection IWF; but have been inappropriately identified as having no AERM. As a result, the ASME-required inspections of these supports may not be performed.

Request:

Identify whether there are any ASME Class 1, 2, or 3 supports within the scope of license renewal which are not being managed by the ASME Code Section XI, Subsection IWF Program. Provide justification for why the supports are not being managed using the ASME Code Section XI, Subsection IWF Program; or provide an appropriate program to manage the aging effects.

STPNOC Response:

LRA Table 3.5.2-11 identifies all material/environment combinations associated with each component type and ensures that all aging effects that could be experienced by those material/environment combinations have been addressed by the appropriate aging management programs. If a component is constructed of more than one material (e.g., a carbon steel support with a stainless steel U-bolt), separate lines in Table 3.5.2-11 are necessary to address the multiple material/environment combinations. Therefore, a single support may correspond with multiple lines in Table 3.5.2-11.

The IWF aging management program scope and the samples selected for inspection are based on individual component supports. While part of a component support may be constructed of a material that does not require aging management, the support is still within the scope of IWF and will be inspected appropriately. All ASME Class 1, 2, and 3 supports are within the scope of license renewal and are being managed by the ASME Code Section XI, Subsection IWF Program.