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#REDIRECT [[NOC-AE-12002897, Response to Requests for Additional Information for License Renewal Application Aging Management Program, Set 22 (TAC Nos. ME4936 and ME4937)]]
| number = ML12248A148
| issue date = 08/21/2012
| title = South Texas Project, Units 1 and 2, Response to Requests for Additional Information for License Renewal Application Aging Management Program, Set 22 (TAC Nos. ME4936 and ME4937)
| author name = Powell G T
| author affiliation = South Texas Project Nuclear Operating Co
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000498, 05000499
| license number =
| contact person =
| case reference number = NOC-AE-12002897, TAC ME4936, TAC ME4937
| document type = Letter
| page count = 30
| project = TAC:ME4936, TAC:ME4937
| stage =
}}
 
=Text=
{{#Wiki_filter:Nuclear Operating CompanySouth Texas Project Electric GeneratinS Station PO. Box 282 Wadsworth, 7exas 77483 /August 21, 2012NOC-AE-1 200289710 CFR 54File: G25STI: 33582020U. S. Nuclear Regulatory CommissionAttention: Document Control DeskWashington, DC 20555-0001South Texas ProjectUnits 1 and 2Docket Nos. STN 50-498, STN 50-499Response to Requests for Additional Information for theSouth Texas Project License Renewal ApplicationAging Management Program, Set 22 (TAC Nos. ME4936 and ME4937)References: 1. STPNOC letter dated October 25, 2010, from G. T. Powell to NRC DocumentControl Desk, "License Renewal Application" (NOC-AE-10002607)(ML103010257)2. NRC letter dated July 12, 2012, "Requests for Additional Information for theReview of the South Texas Project, Units 1 and 2 License Renewal Application -Aging Management, Set 22(TAC Nos. ME4936 and ME 4937)"(ML12185A031)By Reference 1, STP Nuclear Operating Company (STPNOC) submitted a License RenewalApplication (LRA) for South Texas Project (STP) Units 1 and 2. By Reference 2, the NRC staffrequests additional information for review of the STP LRA. STPNOC's response to therequests for additional information is provided in Enclosure 1 to this letter. Changes to LRApages described in Enclosure 1 are depicted as line-in/line-out pages provided in Enclosure 2.One regulatory commitment in Table A4-1 of the LRA is revised and is provided in Enclosure 3to this letter. There are no other regulatory commitments in this letter.Should you have any questions regarding this letter, please contact either Arden Aldridge, STPLicense Renewal Project Lead, at (361) 972-8243 or Ken Taplett, STP License Renewal Projectregulatory point-of-contact, at (361) 972-8416.AuC~4ik I 44L NOC-AE-12002897Page 2I declare under penalty of perjury that the foregoing is true and correct.Executed onDatýG. T. PowellVice President,GenerationKJTEnclosures:1.2.3.STPNOC Response to Requests for Additional InformationSTPNOC LRA Changes with Line-in/Line-out AnnotationsSTPNOC Revised Regulatory Commitment NOC-AE-12002897Page 3cc:(paper copy)(electronic copy)Regional Administrator, Region IVU. S. Nuclear Regulatory Commission1600 East Lamar BoulevardArlington, Texas 76011-4511Balwant K. SingalSenior Project ManagerU.S. Nuclear Regulatory CommissionOne White Flint North (MS 8B1)11555 Rockville PikeRockville, MD 20852Senior Resident InspectorU. S. Nuclear Regulatory CommissionP. 0. Box 289, Mail Code: MNl16Wadsworth, TX 77483C. M. CanadyCity of AustinElectric Utility Department721 Barton Springs RoadAustin, TX 78704John W. DailyLicense Renewal Project Manager (Safety)U.S. Nuclear Regulatory CommissionOne White Flint North (MS 011-Fl)Washington, DC 20555-0001Tam TranLicense Renewal Project Manager(Environmental)U. S. Nuclear Regulatory CommissionOne White Flint North (MS O11F01)Washington, DC 20555-0001A. H. Gutterman, EsquireKathryn M. Sutton, EsquireMorgan, Lewis & Bockius, LLPJohn RaganChris O'HaraJim von SuskilNRG South Texas LPKevin PolioRichard PenaCity Public ServicePeter NemethCrain Caton & James, P.C.C. MeleCity of AustinRichard A. RatliffAlice RogersTexas Department of State Health ServicesBalwant K. SingalJohn W. DailyTam TranU. S. Nuclear Regulatory Commission
 
==Enclosure==
1NOC-AE-12002897Enclosure ISTPNOC Response to Requests for Additional Information
 
==Enclosure==
1NOC-AE-12002897Page 1 of 8SOUTH TEXAS PROJECT, UNITS 1 AND 2REQUEST FOR ADDITIONAL INFORMATIONAGING MANAGEMENT, SET 22(TAC NOS. ME4936 AND ME4937)RAI B2.1.9-3c (021)Back-ground:During a telephone conference call on April 24, 2012, NRC staff and South Texas ProjectNuclear Operating Company (the applicant) discussed Draft RAI B2.1.9-3b, which addressedaging management activities associated with internal coatings where intended functions ofdownstream components could be affected by coating failures. The Draft RAI cited theapplicant's previous responses to RAI B2.1.9-3 that noted operating experience fromCR 07-16847, and stated that a) foreign material was found in one of the intercoolers, b) theengineering evaluation determined that some of the foreign material was consistent witherosion of the coating material used for the intercooler ribs, and c) the majority of the particleswere smaller than the 3/8-inch tube diameter. The Draft RAI also cited the applicant's previousresponse to RAI B2.1.9-3 that noted operating experience from CR 11-1218, and stated thatpieces of coatings were found in the ends of some tubes in the reactor containment buildingchiller 11 B.The draft RAI also noted recent industry operating experience that revealed some internallinings or coatings are considered limited-life installations with a service life of less than20 years, and noted that as the end of service life is approached, past performance of thecoating may not accurately predict the coating's future behavior. Further, the draft RAIdiscussed inspection techniques in addition to visual inspections to detect delamination, suchas some form of physical manipulation, and increasing the frequency of inspections as theservice life of the coating is approached. After discussions during the telephone conference,the applicant and the staff agreed that the draft RAI was not needed, and by letter datedMay 10, 2012, the applicant subsequently supplemented its previous responses to RAIB2.1.9-3.The May 10, 2012, response provides the aging management review (AMR) items that areused to manage the heat exchangers exposed to raw water which have a potential formacroscopic fouling due to coating degradation. These include component cooling water(CCW) heat exchangers, the CCW pump room heat exchangers, the air handling unit (AHU)condenser heat exchangers, and the three heat exchangers associated with each standbydiesel generator, all of which are managed for reduction of heat transfer.The response states that the vendor's application data sheets do not specify the use of aphysical-mechanical contact type of test for cure or adhesion verification, and that althoughtesting, such as a pull-off adhesion test, can be used to prove that the coating has not lost anyadhesive or cohesive properties, such testing results in destruction of the coating. Regardingthe need to increase the frequency of inspections as the service life of a coating isapproached, the response does not specifically address whether the coatings are consideredlimited-life installations, but in summarizing, it refers to them as "permanent coatings" appliedat South Texas Project. The response states that the coatings are not expected to delaminatein large flakes or sheets between inspection intervals and that operating experience
 
==Enclosure==
INOC-AE-1 2002897Page 2 of 8demonstrates that the effects of aging are being adequately managed by the Open CycleCooling Water System program.Based on the staff's review of plant-specific operating experience, coatings hav) degradedand released material into the system. Although the applicant does not believe coatings willdelaminate in large flakes, plant-specific operating experience exists which indicates that somecoatings have broken off in pieces that apparently were too large to pass though thedownstream heat exchanger tubes. The staff acknowledges that, to date, the amount ofmaterial has not adversely affected heat exchanger intended function.Issue:The staff has identified three issues:1) The inspection frequency of the coatings should consider the service life of the installedcoating as well as the trending of ongoing coating inspections. As the end of servicelife approaches, past performance of the coating may not accurately predict thecoating's future behavior. Recent industry operating experience reviews indicate thatcoating failures were caused by operation of the coatings beyond their qualified servicelife without appropriate justification. In that regard, the service life, as described inEPRI 1019157, "Guideline on Safety-Related Coatings," should initially be identifiedfrom the process that installed the coating, and if, during the period of extendedoperation, the coatings will be operated beyond the qualified service life, then anappropriate justification should be provided. Since the applicant's response refers tothe coatings as "permanent coatings," the applicant should document what thatexpected life is (e.g., whether for 10 years, 20 years, the remaining life of the unit, etc.).Furthermore, if the coatings in question have a finite life (otherwise known as a servicelife), it is not clear to the staff how operation that approaches or exceeds the service lifewill be adequately managed during the period of extended operation.2) Although visual examination of coatings can identify degradation indicative ofdelamination, EPRI 1019157, states that "lightly tapping the exposed coating mayindicate disbondment that may not be evident with visual inspection." In addition, withregard to adhesion testing, ASTM D4541, "Test Method for Pull-Off Strength ofCoatings Using Portable Adhesion Testers," which is discussed in EPRI 1019157,indicates that the testing determines either the force that a surface area can bearbefore a plug of material is detached or whether the surface remains intact at aprescribed force. As such, adhesion testing does not necessarily result in thedestruction of the coating as stated in the applicant's response. Since the vendor'sapplication data sheets did not specify the use of a physical-mechanical contact type oftest for adhesion verification, it is not clear to the staff how adhesion degradation will beadequately identified, other than being revealed after the fact.3) For visual inspections of the coatings performed through this program, EPRI 1019157states that Coatings Surveillance Personnel should meet applicable plant licensingcommitments and be approved by the utility Nuclear Coating Specialist. Thequalification recommendations of a Nuclear Coating Specialist are defined inASTM D7108, "Standard Practice for Establishing Qualifications for a Nuclear CoatingSpecialist." It is not clear to the staff whether the personnel performing the coatingsassessment visual inspections are properly qualified to industry recommendations.
 
==Enclosure==
1NOC-AE-12002897Page 3 of 8RAI Request:For those locations where coating failures may adversely affect the safety function ofdownstream components, or result in an 10 CFR 54(a)(2)function not being met:1) For each location, provide the service life as established by the coating vendor or by anengineering evaluation for the first installation of the coating, and for locations where thecoating may be operated approaching or beyond the qualified service life during the periodof extended operation, explain the actions that the current program contains to ensuredownstream components are not adversely affected.STPNOC Response:Locations where coating failures may adversely affect the safety function of downstreamcomponents, or result in an 10 CFR 54(a)(2) function not being met, are listed in Table 1below:* The essential chiller water box covers, standby diesel generator (SDG) lube oilcoolers, SDG jacket water coolers, and SDG intercooler water boxes could affectheat exchanger performance and are currently inspected every five years.* Interconnecting piping between SDG intercooler water boxes could affectdownstream heat exchanger performance and is currently inspected every fiveyears as part of the periodic intercooler inspection.Table IComponent Coating Service Initial CoatingLife In-serviceDate3V111VCH004 BeIzona 20yr 4/28/93ESSENTIAL CHILLED WATER CHILLER WATER BOXCOVERS UNIT 12A3V111VCH005 Belzona 20yr 3/18/95ESSENTIAL CHILLED WATER CHILLER WATER BOXCOVERS UNIT 12B3V111VCH006 Belzona 20yr 3/21/95ESSENTIAL CHILLED WATER CHILLER WATER BOXCOVERS UNIT 12C3V1 12VCH004 Belzona 20yr 10/10/91ESSENTIAL CHILLED WATER CHILLER WATER BOXCOVERS UNIT 22A
 
==Enclosure==
1NOC-AE-1 2002897Page 4 of 8Component Coating Service Initial CoatingLife In-serviceDate3V112VCH005 Belzona 20yr 11/2/91ESSENTIAL CHILLED WATER CHILLER WATER BOXCOVERS UNIT 22B3V1 12VCH006 Belzona 20yr 9/28/91ESSENTIAL CHILLED WATER CHILLER WATER BOXCOVERS UNIT 22C3Q151MHX0136 Belzona 20yr 9/3/93SDG LUBE OIL COOLER3Q152MHX0136 Belzona 20yr 5/13/93SDG LUBE OIL COOLER3Q151MHX0236 Belzona 20yr 5/14/91SDG LUBE OIL COOLER3Q152MHX0236 Belzona 20yr 3/18/93SDG LUBE OIL COOLER3Q151MHX0336 Belzona 20yr 1/22/91SDG LUBE OIL COOLER3Q152MHX0336 BeIzona 20yr 6/2/93SDG LUBE OIL COOLER3Q151MHX0134 Belzona 20yr 9/3/93SDG JACKET WATER COOLER3Q152MHX0134 Belzona 20yr 5/6/93SDG JACKET WATER COOLER3Q151MHX0234 Belzona 20yr 5/14/91SDG JACKET WATER COOLER (Note 1)3Q152MHX0234 Belzona 20yr 3/11/93SDG JACKET WATER COOLER3Q151 MHX0334 Belzona 20yr 4/2/91SDG JACKET WATER COOLER3Q152MHX0334 Belzona 20yr 6/2/93SDG JACKET WATER COOLER
 
==Enclosure==
1NOC-AE-1 2002897Page 5 of 8Component Coating Service Initial CoatingLife In-serviceDate3Q151MDG0134 BeIzona 20yr 2/14/91DIESEL GENERATOR #11INTERCOOLER WATER BOXES3Q152MDG0134 Belzona 20yr 10/16/91DIESEL GENERATOR #21INTERCOOLER WATER BOXES3Q151MDG0234 Belzona 20yr 03/06/91DIESEL GENERATOR #12INTERCOOLER WATER BOXES3Q152MDG0234 BeIzona 20yr 11/20/91DIESEL GENERATOR #22INTERCOOLER WATER BOXES3Q151MDG0334 Belzona 20yr 01/23/91DIESEL GENERATOR #13INTERCOOLER WATER BOXES3Q152MDG0334 BeIzona 20yr 10/21/91DIESEL GENERATOR #23INTERCOOLER WATER BOXES3Q151MDG0134 Plasticap with 12 to 15 yrs 02/89DIESEL GENERATOR #11 Plasite 7122 (Note 2)INTERCOOLER WATER BOX INTERCONNECTING PIPING repair3Q152MDG0134 Plasticap with 12 to 15 yrs 02/89DIESEL GENERATOR #21 Plasite 7122 (Note 2)INTERCOOLER WATER BOX INTERCONNECTING PIPiNG repair3Q151MDG0234 Plasticap with 12 to 15 yrs 02/89DIESEL GENERATOR #12 Plasite 7122 (Note 2)INTERCOOLER WATER BOX INTERCONNECTING PIPING repair3Q152MDG0234 Plasticap with 12 to 15 yrs 02/89DIESEL GENERATOR #22 Plasite 7122 (Note 2)INTERCOOLER WATER BOX INTERCONNECTING PIPING repair3Q151MDG0334 Plasticap with 12 to 15 yrs 02/89DIESEL GENERATOR #13 Plasite 7122 (Note 2)INTERCOOLER WATER BOX INTERCONNECTING PIPING repair3Q152MDG0334 Plasticap with 12 to 15 yrs 02/89DIESEL GENERATOR #23 Plasite 7122 (Note 2)INTERCOOLER WATER BOX INTERCONNECTING PIPING repairTable notes:(1) Record of application of coating could not be located. However, similar records indicatethat the coating to the component jacket water cooler was applied at approximately thesame timeframe as coating application to the component lube oil cooler.(2) Record of application of coating could not be located. Modification for replacing theinterconnecting piping was approved in July 1987. Requisition for coating services for thereplaced piping was approved in February 1989. STP is reasonably certain that coatingswere applied in 1989 following the approval of the requisition. February 1989 isconservatively established as the date of the application of initial coating.The service life of Belzona products utilized in the Essential Cooling Water system thatservices the components in Table 1 has been established by the vendor to be approximately20 years. Updated Belzona inspection guidance, recently received, recommends the following
 
==Enclosure==
INOC-AE-12002897Page 6 of 8expanded inspection and testing protocol for in-service coatings of 12 years and beyond at asix year frequency:-Visual-Low voltage holiday test (based on ASTM D5162 requirements)-Dry film thickness test (based on ASTM D7091 & SSPC PA-2 requirements)-Pull off adhesion test (based on ASTM D4541 requirements)Following inspection, testing and required repairs, the coating can be recertified for anadditional six years of service.Plasticap 400 Epoxy Phenolic was originally applied to the internals of the interconnectingpiping for the SDG intercooler water boxes. Plasticap 400 does not have a documentedservice life. The interconnecting piping was modified with piping coated with Plasite 7122. Thevendor provides average expected service life for Plasite 7122 of 12-15 years.To provide assurance that coatings for the components listed in Table I will not adverselyaffect the safety function of downstream components, or result in an 10 CFR 54(a)(2)functionnot being met, the following expanded inspection and testing protocol for in-service coatings of12 years and beyond will be performed at a six year frequency:-Visual-Low voltage holiday test (based on ASTM D5162 requirements)-Dry film thickness test (based on ASTM D7091 & SSPC PA-2 requirements)-Pull off adhesion test (based on ASTM D4541 requirements)The current inspection interval of five years is being revised to a six-year interval. This revisionis based on industry and STP operating experience to align with six-year major equipmentoutage and inspection intervals. The six-year inspection interval aligns with vendor inspectionguidance for the in-service coatings.LRA Sections 3.3.2.1.9 and 3.3.2.1.20 and Tables 2.3.3.9, 2.3.3.20, 3.3.2.9, and 3.3.2.20 arerevised to add aging management review (AMR) line items for component type "Coating" thatis managed for loss of coating integrity.LRA Appendix A1.9, Appendix B2.1.9, Table A4-1 Commitment No.4 and LRA BasisDocument AMP X.M20 (B2.1.9), Open Cycle Cooling Water System program are revised torequire in-scope coatings be visually inspected every six years, and tested after 12 years ofservice at a six year frequency. The coating tests performed are low voltage holiday test perASTM D5162, dry film thickness test per ASTM D7091 and Steel Structures Painting Council(SSPC) PA-2, and pull off adhesion test per ASTM D4541. Coating inspections and tests willbe performed by a qualified Nuclear Coating Specialist (NCS), as defined by ASTM D7108, orby Coatings Surveillance Personnel (CSP) under the technical direction of the NCS.Enclosure 2 provides the line-in/line-out revision to LRA Sections 3.3.2.1.9 and 3.3.2.1.20,Tables 2.3.3.9, 2.3.3.20, 3.3.2.9, and 3.3.2.20, Appendix A1.9, and Appendix B2.1.9Enclosure 3 provides the line-in/line-out revision to Commitment No.4
 
==Enclosure==
1NOC-AE-1 2002897Page 7 of 8RAI Request:2) Since physical-mechanical testing was not initially performed to verify cure or adhesion ofcoatings and the current program does not include any physical-mechanical testing,provide information justifying why some type of physical test does not need to beperiodically performed to verify coating adhesion, during the period of extended operation.STPNOC Response:As discussed in response 1) above, the Open Cycle Cooling Water System program will beenhanced to include additional inspections and tests (including physical-mechanical testing) ofcoatings whose failures may adversely affect the safety 1unction of downstream components,or result in an 10 CFR 54(a)(2)function not being met.The enhanced program will ensure downstream components are not adversely affectedthrough the following attributes:The use of internal component coatings is controlled by the South Texas Project (STP)design configuration control process and is managed by the preventive maintenance orcorrective action programs.On-going NRC Generic Letter 89-13 heat exchanger performance monitoring andtrending surveillances.On-going operating experience related to coating challenges is evaluated andenhancements made to the Open-Loop Cooling Water System aging managementprogram, as appropriate.Six year periodic inspections of the coating and heat exchanger tubeso Damaged coatings are repaired or replace coatings that are degraded.o Trending is documented in the periodic inspectionsFollowing 12 years of service, use of an expanded inspection and inspection protocoldescribed in the response to 1) above.RAI Request:3) Provide information regarding the qualifications of individuals that will perform coatingsassessment during the period of extended operation. In addition, state whether coatings inthis program will be under the technical direction of a Nuclear Coating Specialist, withresponsibilities and qualifications as described in EPRI 1019157, or provide technicalbases describing why oversight by such an individual is not needed.STPNOC Response:Coating inspections during PMs will be performed by a qualified Nuclear Coating Specialist(NCS) as defined by ASTM D7108 or by a Coatings Surveillance Personnel (CSP) under thetechnical direction of the NCS.
 
==Enclosure==
1NOC-AE-12002897Page 8 of 8The AMP Implementation procedure OPMP06-ZD-0001 will be revised to reflect NCS and CSPqualification recommendations. The coating PMs will be revised to require coatings inspectionby NCS or CSP under supervision of NCS.Enclosure 3 provides the line-in/line-out revision to Commitment No.4.
 
==Enclosure==
2NOC-AE-1 2002897Enclosure 2STPNOC LRA Changes with Line-in/Line-out Annotations
 
==Enclosure==
2NOC-AE-12002897Page 1 of 14List of Revised LRA SectionsAffected LRA SectionsLRA Table 2.3.3.9LRA Table 2.3.3.20LRA Section 3.3.2.1.9LRA Section 3.3.2.1.20LRA Table 3.3.2.9LRA Table 3.3.2.20Appendix A1.9Appendix B2.1.9
 
==Enclosure==
2NOC-AE-1 2002897Page 2 of 14Table 2.3.3-9Chilled Water HVAC System"Cor..onent Iy e -A- ntended Function~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ; nn:rp ed Uhcti...oh.. I...... .: -.........Closure Bolting Leakage Boundary (spatial)Pressure BoundaryStructural Integriy attachedL_Coatings Maintain Coating IntegrityCompressor Pressure BoundaryTable 2. 3.3-20 Standby Diesel Generator and Auxiliaries SystemsI Closure Bolting Leakage Boundary (spatial)Pressure Boundary___oatin__qsStructural (attached)Maintain Coating IntegrityExpansion Joint Pressure Boundary
 
==Enclosure==
2NOC-AE-12002897Page 3 of 143.3.2.1.9 Chilled Water HVAC SystemMaterialsThe materials of construction for the chilled water HVAC system component types are:BelzonaCarbon SteelCarbon Steel (Galvanized)Cast Iron (Gray Cast Iron)Copper AlloyCopper Alloy (> 15 percent Zinc)GlassStainless SteelTitaniumEnvironmentThe chilled water HVAC system component types are exposed to the following environments:Borated Water LeakageClosed-Cycle Cooling WaterDemineralized WaterDry GasLubricating OilPlant Indoor AirRaw WaterAging Effects Requiring ManagementThe following chilled water HVAC system aging effects require management:Loss of coating integrityLoss of materialLoss of preloadReduction of heat transferWall ThinningAging Management ProgramsThe following aging management programs manage the aging effects for the chilled waterHVAC system component types:Flow-Accelerated Corrosion (B2.1.6)
 
==Enclosure==
2NOC-AE-1 2002897Page 4 of 14Bolting Integrity (B2.1.7)Boric Acid Corrosion (B2.1.4)Closed-Cycle Cooling Water System (B2.1.10)External Surfaces Monitoring Program (B2.1.20)Lubricating Oil Analysis (B2.1.23)One-Time Inspection (B2.1.16)Open-Cycle Cooling Water System (B2.1.9)Selective Leaching of Materials (B2.1.17)Water Chemistry (B2.1.2)
 
==Enclosure==
2NOC-AE-12002897Page 5 of 143.3.2.1.20 Standby Diesel Generator and Auxiliaries SystemMaterialsThe materials of construction for the standby diesel generator and auxiliaries systemcomponent types are:* Aluminum* Belzona* Carbon Steel* Cast Iron (Gray Cast Iron)* Copper Alloy* Glass* Plasticap/Plasite* Stainless Steel* TitaniumEnvironmentThe standby diesel generator and auxiliaries system component types are exposed to thefollowing environments:* Closed-Cycle Cooling Water* Diesel Exhaust* Dry Gas* Fuel Oil* Lubricating Oil* Plant Indoor Air* Raw WaterAging Effects Requiring ManagementThe following standby diesel generator and auxiliaries system aging effects requiremanagement:* Cracking* Loss of coating integrity* Loss of material* Loss of preload* Reduction of heat transfer
 
==Enclosure==
2NOC-AE-1 2002897Page 6 of 14Aging Management ProgramsThe following aging management programs manage the aging effects for the standby dieselgenerator and auxiliaries system component types:* Bolting Integrity (B2.1.7)* Closed-Cycle Cooling Water System (B2. 1.10)* External Surfaces Monitoring Program (B2.1.20)* Fuel Oil Chemistry (B2.1.14)* Inspection of Internal Surfaces in Miscellaneous Piping and DuctingComponents (B2.1.22)* Lubricating Oil Analysis (B2.1.23)* One-Time Inspection (B2.1.16)* Open-Cycle Cooling Water System (B2.1.9)* Selective Leaching of Materials (B2.1.17)
 
==Enclosure==
2NOC-AE-12002897Page 7 of 14Table 3.3.2-9 Auxiliary Systems -Summary of Aging Management Evaluation -Chilled Water HVAC SystemýC omptonent Type Inteed M'ateia Enviro'nm~en't-i:.,,ý'A AgngEffec Aging, Mangmn NUE TbeI No-tesFunction j --Pýrogram .81VI~Ie~management ______ _ _ v_ 2 2-Item _________Closure Bolting LBS, PB, Carbon Plant Indoor Air Loss of material Bolting Integrity VII.I-4 3.3.1.43 BSIA Steel (EX) __ (B2.1.7 _Coating MCI Belzona Raw Water Loss of Coating Open-Cycle Cooling None None J, 2Integrity Water System (B2.1.9)Compressor PB Cast Iron Dry Gas (Int) None None VII.J-23 3.3.1.97 A(Gray CastIron) _Notes for Table 3.3.2-9:Standard Notes:A Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.B Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801AMP.E Consistent with NUREG-1 801 for material, environment, and aging effect, but a different aging management program is:.credited orNUREG-1801 identifies a plant-specific aging management program.F Material not in NUREG-1801 for this component.H Aging effect not in NUREG-1801 for this component, material and environment combination.J Neither the component nor the material and environment combination is evaluated in NUREG-1 801Plant Specific Notes:1 Wall thinning due to erosion-corrosion is managed by the Flow-Accelerated Corrosion program (B2.1.6)2 Coatings are managed for loss of coating integrity to provide assurance that the coatings will not adversely affect the safety function ofdownstream heat exchangers due to fouling. No credit is taken for the coatings to protect the base metal from loss of material. NUREG-1801 does not provide a line to manage coating for loss of coating integrity.
 
==Enclosure==
2NOC-AE-12002897Page 8 of 14Table 3.3.2-20 Auxiliary Systems -Summary of Aging Management Evaluation -Standby Diesel Generator and Auxiliaries(Continued).Compionent Inteded Material._ Environmnt'[.Agn .-ec ..,Aging Managemnent: -NRG ~beIIe otesTyp- -Function.' tRequiig- -Porm_10'Vl________-I -I:- __________ anagement", .J2le I -_ _ _Closure Bolting LBS, PB, Stainless Plant Indoor Air Loss of preload Bolting Integrity (B2.1.7) None None H, 1SIA Steel (E)-_Coatinc MCI Belzona Raw Water Loss of Coating Open-Cycle Cooling Water None None J 4_ntecrity System (B2.1.9)Coating MCI Plasticap/ Raw Water Loss of Coating Open-Cycle Cooling Water None None J4___ ______Plasite ___ ___Integrity System (B32. 1.9) __ _____ ___ _Expansion PB Carbon Steel Closed Cycle Loss of material Closed-Cycle Cooling VII.H2-23 3.3.1.47Joint Cooling Water Water System (B2.1.10)17- _(Int)__--Notes for Table 3.3.2-20:Standard Notes:A Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.B Consistent with NUREG-1 801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1 801AMP.C Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP is consistent withNUREG-1801 AMP.D Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP takes some exceptions toNUREG-1801 AMP.E Consistent with NUREG-1 801 for material, environment, and aging effect, but a different aging management program is credited orNUREG-1801 identifies a plant-specific aging management program.F Material not in NUREG-1801 for this componentG Environment not in NUREG-1801 for this component and material.H Aging effect not in NUREG-1 801 for this component, material, and environment combination.J Neither the component nor the material and environment combination is evaluated in NUREG-1801.Plant Specific Notes:1 Loss of preload is conservatively considered to be applicable for all closure bolting.2 Reduction in heat transfer due to fouling is a potential aging effect/mechanism for cast iron (gray cast iron) turbocharger components inclosed cycle cooling water.
 
==Enclosure==
2NOC-AE-1 2002897Page 9 of 143 B2.1.22, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, is used because this is an aging mechanismwhich occurs on the internal surfaces of these components.4 Coatings are managed for loss of coating integrity to provide assurance that the coatings will not adversely affect the safety function ofdownstream heat exchangers due to fouling. No credit is taken for the coatings to protect the base metal from loss of material. NUREG-1801 does not provide a line to manage coating for loss of coating integrity.
 
==Enclosure==
2NOC-AE-1 2002897Page 10 of 14A1.9 OPEN-CYCLE COOLING WATER SYSTEMThe Open-Cycle Cooling Water System program manages loss of material and reduction ofheat transfer for components within the scope of license renewal and exposed to the raw waterof the essential cooling water system. Included are components of the essential cooling water(ECW) system that are within the scope of license renewal, the component cooling water heatexchangers and the other safety related heat exchangers cooled by the essential cooling watersystem. The program includes chemical treatment and control of biofouling, periodicinspections, flushes and physical and chemical cleaning, and heat exchanger performancetesting/inspections to ensure that the effects of aging will be managed during the period ofextended operation. The program also includes inspections of a sample of ECW piping forwall thickness prior to the period of extended operation. Subsequent inspections will bescheduled based on the results of the initial inspections. The plant specific configuration of thealuminum-bronze piping inserted inside the slip-on flange downstream of the ComponentCooling Water (CCW) heat exchanger is inspected at a nominal 216 week interval. Anengineering evaluation is performed after each inspection. Corrective action in accordancewith the corrective action program will be initiated if the calculated wear over the nextinspection interval indicates that the aluminum-bronze piping wall will reduce to a thickness ofless than minimum wall thickness plus margin (four years of wear at the actual yearly wearrate). The program is consistent with STP commitments as established in responses to NRCGeneric Letter 89-13, Service Water System Problems Affecting Safety-Related Components.Coating installed to mitigate corrosion of the essential chiller water box covers, standby dieselgenerator (SDG) iacket water coolers, SDG lube oil coolers, SDG intercooler water boxes andinterconnection piping are inspected and tested to assure coating integrity. The coatings arevisually inspected every six years, and tested after 12 years of service at a six year frequency.The coating tests performed are low voltage holiday test, dry film thickness test and pull offadhesion test. Coatinq inspections and tests are performed by a gualified Nuclear CoatingSpecialist (NCS) or by Coatings Surveillance Personnel under the technical direction of theNCS.
 
==Enclosure==
2NOC-AE-12002897Page 11 of 14B2.1.9 Open-Cycle Cooling Water SystemProgram DescriptionThe Open-Cycle Cooling Water (OCCW) System program manages loss of material andreduction of heat transfer for components in scope of license renewal and exposed to the rawwater of the essential cooling water (ECW) and essential cooling water screen wash system.The program includes surveillance techniques and control techniques to manage aging effectscaused by biofouling, corrosion, erosion, cavitation erosion, protective coating failures andsilting in components of the ECW system, and structures and components serviced by theECW system, that are in scope of license renewal. The program also includes periodicinspections to monitor aging effects on the OCCW structures, systems and components,component cooling water heat exchanger performance testing, and inspections of the othersafety related heat exchangers cooled by the ECW System, to ensure that the effects of agingon OCCW components are adequately managed for the period of extended operation. Theprogram also includes inspections of a sample of ECW piping for wall thickness prior to theperiod of extended operation. Subsequent inspections will be scheduled based on the resultsof the initial inspections. The plant specific configuration of the aluminum-bronze pipinginserted inside the slip-on flange downstream of the CCW heat exchanger is inspected at anominal 216 week interval. An engineering evaluation is performed after each inspection. Ifthe calculated wear over the next inspection interval indicates that the aluminum-bronze pipingwall will reduce to a thickness of less than minimum wall thickness plus margin (four years ofwear at the actual yearly wear rate), then the pipe will be repaired or replaced in accordancewith the corrective action program. Components within the scope of the OCCW Systemprogram are: 1) components of the ECW system that are in scope of license renewal and2) the safety-related heat exchangers cooled by the ECW system: component cooling waterheat exchangers, standby diesel generator (SDG) iacket water heat exchangers, (SDG) dieselgene~atGF lube oil coolers, (SDG) die6e- geiwatOF intercoolers, essential chiller condensers,and component cooling water pump supplementary coolers. The program is consistent withSTPNOC commitments established in responses to NRC Generic Letter 89-13, Service WaterSystem Problems Affecting Safety-Related Components.The surveillance techniques utilized in the Open-Cycle Cooling Water System program includevisual inspection, volumetric inspection, and thermal and hydraulic performance monitoring ofheat exchangers. The control techniques utilized in the Open-Cycle Cooling Water Systemprogram include (1) water chemistry controls to mitigate the potential for the development ofaggressive cooling water conditions, (2) flushes and (3) physical and/or chemical cleaning ofheat exchangers and of the ECW pump suction bay to remove fouling and to reduce thepotential sources of fouling.Coating installed to mitigate corrosion of the essential chiller water box covers, SDG iacketwater coolers, SDG lube oil coolers, SDG intercooler water boxes and interconnection pipingare inspected and tested to assure coating integrity. The coatings are visually inspected everysix years, and tested after 12 years of service at a six year frequency. The coating testsperformed are low voltage holiday test per ASTM D5162, dry film thickness test per ASTMD7091 and Steel Structures Painting Council (SSPC) PA-2 and pull off adhesion test perASTM D4541. Coating inspections and tests are performed by a qualified Nuclear CoatingSpecialist (NCS) as defined by ASTM D7108 or by Coatings Surveillance Personnel (CSP)under the technical direction of the NCS.
 
==Enclosure==
2NOC-AE-1 2002897Page 12 of 14Additional measures used to manage loss of material due to selective leaching for aluminumbronze components in the ECW system are detailed in the plant-specific aging managementprogram Selective Leaching of Aluminum Bronze (82.1.37).NUREG-1801 ConsistencyThe Open-Cycle Cooling Water System program is an existing program that, followingenhancement, will be consistent with exception to NUREG-1 801, Section XI.M20, Open-CycleCooling Water System.Exceptions to NUREG-1801Program Elements Affected:Preventive Actions (Element 2), Parameters Monitored or Inspected (Element 3), Detection ofAging Effects (Element 4)NUREG-1 801, Section XI.M20, Elements 2, 3 and 4, provide for a program of flushing andinspection to confirm that fouling and degradation of surfaces is not occurring. An exception istaken to flushing the ECW train cross-tie dead legs and inspecting the interior of these lines.Instead, the external surfaces of the cross-tie lines are included in the six month dealloyingvisual external inspection walkdowns. The cross-tie valves and piping are also included in theessential cooling water system inservice pressure test, which includes VT-2 inspections ofthese components. Measures used to manage loss of material due to selective leaching aredetailed in the Selective Leaching of Aluminum Bronze program (B2.1.37). These inspectionsand tests provide confidence in the ability to detect leakage in the piping and valves. Thecross-tie lines do not have an intended function and are not required for any accident scenariowithin the design basis of the plant. The cross-tie valves are maintained locked closed.EnhancementsPrior to the period of extended operation, the following enhancements will be implemented inthe following program elements:Parameters Monitored or Inspected (Element 3) and Detection of Aging Effects (Element 4)Procedures will be enhanced to include visual inspection of the strainer inlet area and theinterior surfaces of the adjacent upstream and downstream piping. Material wastage,dimensional change, discoloration, and discontinuities in surface texture will be identified.These inspections will provide visual evidence of loss of material and fouling in the ECWsystem and serve as an indicator of the condition of the interior of ECW system pipingcomponents otherwise inaccessible for visual inspection. Procedures will also be enhanced toinclude the acceptance criteria for this visual inspection.Scope (Element 1), Parameters Monitored or Inspected (Element 3), Detection of AgingEffects (Element 4), and Monitoring and Trending (Element 5)Procedures will be enhanced to require a minimum of 25 ECW piping locations be measuredfor wall thickness. Selected areas will include locations that are considered to have thehighest corrosion rates, such as areas with stagnant flow.
 
==Enclosure==
2NOC-AE-1 2002897Page 13 of 14Procedures will be enhanced to require an engineering evaluation after each inspection of thealuminum-bronze piping inserted inside the slip-on flange downstream of the CCW heatexchanger. The engineering evaluation will calculate wear over the next inspection intervalusing a margin of four years of wear at the actual yearly wear rate. Corrective action inaccordance with the corrective action program will be initiated if the calculated wear indicatesthat the aluminum-bronze piping wall will reduce to a thickness of less than minimum wallthickness plus margin (four years of wear at the actual yearly wear rate).Corrective Actions (Element 7)Procedures will be enhanced to require loss of material in piping and protective coating failuresbe documented in the corrective action program. The resolution will include an engineeringevaluation of the condition.Prior to the next scheduled inspection in 2013 the following enhancements to coatings will beimplementedParameters Monitored or Inspected (Element 3) and Detection of Aging Effects (Element 4)Procedures will be enhanced to inspect and test coatings for loss of coating integrity. Thecoatin-gs installed to mitigate corrosion of the essential chiller water box covers, SDG iacketwater coolers, SDG lube oil coolers, SDG intercooler water boxes and interconnection pipingare visually inspected every six years, and tested after 12 years of service at a six yearfrequency. The coating tests performed are low voltage holiday test per ASTM D5162, dry filmthickness test per ASTM D7091 and Steel Structures Painting Council.(SSPC) PA-2 and pull off adhesion test per ASTM D4541. Coating inspections and tests areperformed by a qualified Nuclear Coatinq Specialist (NCS) as defined by ASTM D7108 or byCoatings Surveillance Personnel (CSP) under the technical direction of the NCS.Operating ExperienceIndustry operating experience evaluations, Maintenance Rule Periodic Assessments, andOCCW component performance testing results have shown that the effects of aging are beingadequately managed.A review of the STP plant specific operating experience indicates that macrofouling, generalcorrosion, erosion corrosion, and cavitation erosion have been observed in aluminum bronzecomponents.In 2001, plant inspections of the ECW pumps revealed signs of flow erosion and corrosion onthe pump internal and external surfaces. The pump vendor recommended application ofBelzona coating to provide protection against erosion and corrosion and the coating wasapplied to the internal wetted surfaces of all ECW pumps. Use of Belzona has improved pumpperformance and service life of the components.In May 2005, damage was discovered in the slip-on flange immediately downstream of thecomponent cooling water heat exchanger 1 B ECW return throttle valve. The damage was due
 
==Enclosure==
2NOC-AE-1 2002897Page 14 of 14to cavitation erosion. The corresponding locations in the other ECW trains were inspected.The damaged areas of all six trains were replaced or reworked in accordance with theapplicable codes and piping specifications. A design modification was performed to coat theaffected areas with Belzona, and PMs were generated to perform regular inspections. Theuse of Belzona for mitigating cavitation erosion has been successful in prolonging service lifeof the components.The OCCW System program operating experience information provides objective evidence tosupport the conclusion that the effects of aging are adequately managed so that the structureand component intended functions are maintained during the period of extended operation.NRC Generic Letter 89-13 was based on industry operating experience and forms the basis forthe STP OCCW System program.ConclusionThe continued implementation of the Open-Cycle Cooling Water System program will providereasonable assurance that aging effects will be managed such that the systems andcomponents within the scope of this program will continue to perform their intended functionsconsistent with the current licensing basis for the period of extended operation.
 
==Enclosure==
3NOC-AE-1 2002897Enclosure 3Revised Regulatory Commitment
 
==Enclosure==
3NOC-AE-12002897Page 1 of 2A4 LICENCE RENEWAL COMMITMENTSTable A4-1 identifies proposed actions committed to by STPNOC for STP Units 1 and 2 in its License Renewal Application. Theseand other actions are proposed regulatory commitments. This list will be revised, as necessary, in subsequent amendments toreflect changes resulting from NRC questions and STPNOC responses. STPNOC will utilize the STP commitment tracking systemto track regulatory commitments. The Condition Report (CR) number in the Implementation Schedule column of the table is forSTPNOC tracking purposes and is not part of the amended LRA.Table A4-1License Renewal CommitmentsItem ... .. -..cement. -. ..-. .... .I mpla io-,~~~me m .. eto cedulei4 Enhance the Open-Cycle Cooling Water System program procedures to: B2.1.9 Prior to the period of* include visual inspection of the strainer inlet area and the interior surfaces of the extended operationadjacent upstream and downstream piping. Material wastage, dimens'onal change,discoloration, and discontinuities in surface texture will be identified. These inspections CR 10-23256will provide visual evidence of loss of material and fouling in the ECW system and serveas an indicator of the condition of the interior of ECW system piping componentsotherwise inaccessible for visual inspection." include the acceptance criteria for this visual inspection.* require a minimum of 25 ECW piping locations be measured for wall thickness prior tothe period of extended operation. Selecied areas will include locations considered tohave the highest corrosion rates, such as areas with stagnant flow.* require an engineering evaluation after each inspection of the aluminum-bronze pipinginserted inside the slip-on flange downstream of the CCW heat exchanger,o require the engineering evaluation calculated wear over the next inspectioninterval using a margin of four years of wear at the actual yearly wear rate,o require corrective action in accordance with the corrective action program beinitiated .if the calculated wear indicates that the aluminum-bronze piping wallwill reduce to a thickness of less than minimum wall thickness plus margin(four years of wear at the actual yearly wear rate),* require loss of material in piping and protective coating failures be documented in the
 
==Enclosure==
3NOC-AE-1 2002897Page 2 of 2Table A4-1 License Renewal Commitments-Item , # j ' , , t, .... ,..Commitment plmentAtion-.S~ection._.ý. Schedule.Scorrective action program, and*require an engineering evaluation be performed when loss of material in piping orprotective coating failures is identified.Prior to the nextEnhance the Open-Cycle Cooling Water System program procedures to: scheduled inspection* visually inspect every six years. and test after 12 years of service at a six year frequency in 2013the coating applied on the essential chiller water box covers, standby diesel generator(SDG) iacket water coolers. SDG lube oil coolers. SDG intercoolers and interconnectionpiping. The coating test performed are low voltage holiday test per ASTM D5162. drfilm thickness test per ASTM D7091 and Steel Structures Painting Council (SSPC) PA-2and pull off adhesion test per ASTM D4541.* require coating inspections and tests be performed by a qualified Nuclear CoatingSpecialist (NOS) as defined by ASTM D7108 or by Coatings Surveillance Personnel(CSP) under the technical direction of the NCS.__________
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