NOC-AE-12002848, Response to Request for Additional Information (RAI) 3.3.2.2.12.2-1 License Renewal Application

Response to Request for Additional Information (RAI) 3.3.2.2.12.2-1 License Renewal Application

ML12135A224
Person / Time
Site:	South Texas
Issue date:	05/03/2012
From:	Richards K South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-12002848, TAC ME4936, TAC ME4937, G25, STI: 33514541
Download: ML12135A224 (7)

Text

Nuclear Operating Company South Texas ProlectElectricGeneratingStation PO.Box 289 Wadsworth. Texas 77483 AAAA May 3, 2012 NOC-AE-12002848 10 CFR 54 STI: 33514541 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 (RAI) 3.3.2.2.12.2-1 for the South Texas Proiect License Renewal ADDlication (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. Record of Teleconference of April 26, 2012 between STPNOC and the NRC Regarding Request for Additional Information (RAI) 3.3.2.2.12.2-1 for the South Texas Project, Units 1 and 2, License Renewal Application (TAC Nos. ME4936 and ME4937) (ML121220190)

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 received RAI 3.3.2.2.12.2-1. The response to the request for additional information is provided in Enclosure 1 to this letter. Changes to LRA pages described in Enclosure 1 are depicted in 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.

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

Executed on __-__- 1W_-_

Kevin D. Richards President & Chief Executive Officer KJT

Enclosure:

1. STPNOC Supplemental Response to RAI 3.3.2.2.12.2-1

2. STPNOC LRA Changes with Line-in/Line-out Annotations ILILvi

~L~24C

NOC-AE-12002848 Page 2 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission Kathryn M. Sutton, Esquire 1600 East Lamar Boulevard Morgan, Lewis & Bockius, LLP Arlington, Texas 76011-4511 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 Senior Resident Inspector Kevin Polio U. S. Nuclear Regulatory Commission Richard Pena P. 0. Box 289, Mail Code: MN1 16 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 Tam Tran Balwant K. Singal License Renewal Project Manager John W. Daily (Environmental) Tam Tran U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission One White Flint North (MS O11F01)

Washington, DC 20555-0001

Enclosure 1 NOC-AE-12002848 Enclosure I STPNOC Supplemental Response to RAI 3.3.2.2.12.2-1

Enclosure 1 NOC-AE-12002848 Page 1 of 1 RAI 3.3.2.2.12.2-1 LRA Section B2.1.23 describes the existing Lubricating Oil Analysis program as consistent, with exceptions to GALL Report AMP XI.M39.

LRA Section 3.3.2.2.12.2, associated with LRA Table 3.3.1, item 3.3.1.33, addresses loss of material due to pitting, crevice, and microbiologically influenced corrosion for stainless steel piping, piping components, and piping elements exposed to lubricating oil. It further states that the reactor coolant pump lube oil collection system is managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program (B2.1.22).

Issue The staff notes that lubricating oil systems are in scope of GALL AMP XI.M39. It is not clear to the staff why the RCP lube oil collection system is in scope of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program.

Request Please justify the use of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program in managing loss of material due to pitting, crevice, and microbiologically influenced corrosion for stainless steel components exposed to lubricating oil in the reactor coolant pump lube oil collection system.

STPNOC Response LRA Section 3.3.2.2.12.2 incorrectly stated that the loss of material due to pitting, crevice, and microbiologically-influenced. corrosion for stainless steel components exposed to lubricating oil in the reactor coolant pump (RCP) lube oil collection system is managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Components program. Instead, management is provided by the Lubricating Oil Analysis program and the One-Time Inspection Program. provides the line-in/line-out revision to LRA Section 3.3.2.2.12.

Enclosure 2 NOC-AE-12002848 Enclosure 2 STPNOC LRA Changes with Line-inlLine-out Annotations

Enclosure 2 NOC-AE-12002848 Page 1 of 2 List of Revised LRA Sections RAI Affected LRA Section 3.3.2.2.12.2-1 3.3.2.2.12

Enclosure 2 NOC-AE-12002848 Page 2 of 2 3.3.2.2.12 Loss of Material due to Pitting, Crevice, and Microbiologically-Influenced Corrosion 3.3.2.2.12.1 Stainless steel, aluminum, and copper alloy piping and components exposed to fuel oil The Fuel Oil Chemistry program (B2.1.14) and the One-Time Inspection program (B2.1.16) manage loss of material due to pitting, crevice and microbiologically influenced corrosion for stainless steel and copper components exposed to fuel oil. The one-time inspection will include selected components at susceptible locations where contaminants could accumulate (e.g. stagnant flow locations).

3.3.2.2.12.2 Stainless steel piping and components exposed to lubricating oil The Lubricating Oil Analysis program (B2.1.23) and the One-Time Inspection program (B2.1.16) manage loss of material due to pitting, crevice, and microbiologically influenced corrosion for stainless steel components exposed to lubricating oil. The one-time inspection will include selected components at susceptible locations where contaminants such as water could accumulate.

For the RCP lube oil coellection system, the Inspection of Internal Su~faces in MiscOellaneous Piping and Ducting Components preFgam (B2.1 '22) manages loss of material due to pitting, crvie In IMicobiolo0gically influenced cr~erorsionen for stainless steel components exposedt