nuclear operating company december 6, 2011 · 2012. 12. 6. · december 6, 2011 noc-ae-1 1002763 10...

Nuclear Operating Company

South Tcas Proet Edlectrik Generatin$ Station P.. Box 289 Wadsworth. Tess 77483 A AA A

December 6, 2011NOC-AE-1 100276310 CFR 54STI: 33091622File: G25

U. S. Nuclear Regulatory CommissionAttention: Document Control DeskOne White Flint North11555 Rockville PikeRockville, MD 20852-2738

South Texas ProjectUnits 1 and 2

Docket Nos. STN 50-498, STN 50-499Response to Requests for Additional Information for the

South Texas Project License Renewal ApplicationAging Management Program, Set 7 (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) (ML1 03010257)

2. NRC letter dated November 3, 2011, "Requests for Additional Information for theReview of the South Texas Project, Units 1 and 2 License Renewal Application -Aging Management Program, Set 7 (TAC Nos. ME4936 and ME 4937)(AE-NOC-1 1002188) (ML1 1299A1 05)

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 the request foradditional information is provided in Enclosure 1 to this letter. Changes to the LRA described inEnclosure 1 are depicted in line-in/line-out pages provided in Enclosure 2.

Enclosure 3 provides a revised regulatory commitment to the LRA. There are no other regulatorycommitments provided 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.

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

Executed on 12,/)- 1; Dante I

W RencurrelSenior Vice President,Technical Support & Oversight

KJTEnclosure: 1. STPNOC Response to Requests for Additional Information

2. STP LRA Changes with Line-in/Line-out Annotations3. Revised LRA Regulatory Commitments A4-IfrQ

0dpk

NOC-AE-1 1002763

cc:

(paper copy) (electronic copy)

Regional Administrator, Region IVU. S. Nuclear Regulatory Commission612 East Lamar Blvd, Suite 400Arlington, Texas 76011-4125

Balwant K. SingalSenior Project ManagerU.S. Nuclear Regulatory CommissionOne White Flint North (MS 8B1)11555 Rockville PikeRockville, MD 20852

Senior Resident InspectorU. S. Nuclear Regulatory CommissionP. O. Box 289, Mail Code: MN116Wadsworth, TX 77483

C. M. CanadyCity of AustinElectric Utility Department721 Barton Springs RoadAustin, TX 78704

John W. DailyLicense Renewal Project Manager (Safety)U.S. Nuclear Regulatory CommissionOne White Flint North (MS 011-Fl)Washington, DC 20555-0001

Tam TranLicense Renewal Project Manager(Environmental)U. S. Nuclear Regulatory CommissionOne White Flint North (MS OllF01)Washington, DC 20555-0001

A. H. Gutterman, EsquireKathryn M. Sutton, EsquireMorgan, Lewis & Bockius, LLP

John RaganChris O'HaraJim von SuskilNRG South Texas LP

Kevin PolioRichard PenaCity Public Service

Peter NemethCrain Caton & James, P.C.

C. MeleCity of Austin

Richard A. RatliffAlice RogersTexas Department of State Health Services

Balwant K. SingalJohn W. DailyTam TranU. S. Nuclear Regulatory Commission

Enclosure 1NOC-AE-1 1002763

Enclosure I

STPNOC Response to Requests for Additional Information


Page 1 of 9

STPNOC Response to Requests for Additional Information

SOUTH TEXAS PROJECT, UNITS I AND 2REQUEST FOR ADDITIONAL INFORMATION -

AGING MANAGEMENT PROGRAM, SET 7(TAC NOS. ME4936 AND ME4937)

Fuel Oil Chemistry (031)

RAI B2.1.14-1

Background:

The updated final safety analysis report (UFSAR) Supplement description contained in theStandard Review Plan for License Renewal (SRP-LR), Table 3.0-1, "FSAR Supplement forAging Management of Applicable Systems," provides an acceptable program description whichincludes the specific American Society for Testing and Materials International (ASTM)standards to be used for the monitoring and controlling of fuel oil contamination to maintain fueloilquality. License renewal application (LRA) Section A1.14, "Fuel Oil Chemistry," states "Theprogram includes (a) surveillance and monitoring procedures for maintaining fuel oil quality bycontrolling contaminants in accordance with the Technical Specifications and applicable ASTMStandards..."

Issue:

The specific ASTM standards used in the program are not specified. Specifying the ASTMstandards to be used ensures that there is an adequate description of the critical elements ofthe Fuel Oil Chemistry Aging Management Program to provide assurance that the program willbe properly executed during a period of extended operations.

Request:

Discuss why the specific ASTM standards utilized in the program are not listed in the FSARSupplement provided in the LRA Appendix A. Describe the procedures and testing that will beused in lieu of the ASTM standards. Alternatively, provide a revision to your FSAR supplementto add the specific ASTM standards.

S7PNOC Response:

LRA Appendices A1.14 and B2.1.14 have been revised to include ASTM Standards D1796,D2276, and D4057. South Texas Project uses only ASTM Standard D1796, not ASTMStandard D2709, for determining water and sediment contamination in diesel fuel. AppendixB2.1.14, Exceptions to NUREG-1801, Scope of Program (Element 1), Parameters Monitored orInspected (Element 3), and Acceptance Criteria (Element 6), documents the technicaljustification for using ASTM Standard D1796 and not ASTM Standard D2709.

Enclosure 2 provides the revision to LRA Appendices Al.14 and B2.1.14.


Page 2 of 9

RAI B2.1.14-2:

Back-ground:

After the issuance of Revision 1 of the NUREG-1 801, "Generic Aging Lessons Learned (GALL)Report," the U.S. Nuclear Regulatory Commission (NRC) issued Information Notice (IN)200902, "Biodiesel in Fuel Oil Could Adversely Impact Diesel Engine Performance," This INdiscusses potential issues that may occur with the use of B5 blend fuel oil, such as suspendedwater particles, biodegradation of B5, material incompatibility, and so on.

Issue:

The LRA does not provide information discussing the concerns of IN 2009-02 and theacceptable or unacceptable use of biodiesel at South Texas Project (STP).

Request:

1. Provide a summary of the actions taken to determine the impact of IN 2009-02 and the useof biodiesel fuel oil at STP; particularly, whether issues of suspended water particles andbiodegradation introduce a new aging environment to be considered.

2. If biodiesel is currently being used at STP, please describe any problems that STP hasencountered with the use of biodiesel and the associated corrective actions to preventreoccurrence in the future.

3. If biodiesel has been determined to be not acceptable for use at STP, please describe theactions taken and/or will be taken to prevent its addition into fuel oil supply. Please alsodescribe actions that will be taken if it is determined that biodiesel has been added into thefuel oil supply.

STPNOC Response:

1. Summary of actions taken to determine the impact of IN 2009-02:

a) The impact of using a biodiesel blend in the STP diesel engines within the scope of licenserenewal has not been fully evaluated. The current STP strategy is to prevent allconcentrations of the biodiesel blends from entering the fuel oil system. The impact of long-term storage of biodiesel fuel oil and impact of biodiesel fuel oil on full engine operationsmust both be considered if this type of fuel oil is implemented. See the response to Item 3for more information.

b) STP performed an engineering evaluation of the impact of NRC Information Notice (IN)2009-02 with the conclusion of the evaluation stated below. This evaluation specificallyreviewed and evaluated the Cooper-Bessemer Owners Group (CBOG) sponsored documentMPR - 2980 "Evaluation of Ultra Low Sulfur and B5 Diesel Fuel for Use in EDGs."


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"Biodiesel has inherent characteristics that are problematic for storage and could impactthe functionality of the STP diesel systems due to an increase in particulate matter in thefuel. Fuel containing measurable amounts of biodiesel is not acceptable due to potentialdeleterious effects on reliability."

c) The Diesel Fuel Oil Group (DFOG) position paper "Biodiesel Remediation" recommends thatabsolutely no biodiesel (zero percent) shall be intentionally received into diesel fuel oilstorage tanks. The DFOG position paper discusses that if biodiesel levels of less than onepercent are present in the main storage tanks, it is likely there will be no impact to the fuel oilor fuel oil system. At or above biodiesel levels of one percent, the DFOG position paperrecommends remediation testing and compensatory measures of filtering, diluting, orchanging out the entire fuel supply depending on fuel properties.

The STP Chemistry Department performed an evaluation of IN 2009-02 and concluded thatthe field instruments to be used in evaluating shipments of fuel oil shall have a lowerdetection level of 0.5 percent biodiesel. If the biodiesel level in a shipment is at themaximum undetectable limit, the concentrations of biodiesel would be diluted toapproximately 0.015 percent or approximately 67 times lower than the proposed one percentlimit (acceptable limit from IN 2009 - 02) once added to the auxiliary fuel oil storage tank. Itwas also noted that STP has an external filtration skid that is used to remove water andparticulates.

2. Biodiesel is currently not being used at STP.

3. As stated in the response to item 1 above, the impact of using a biodiesel blend in the STPdiesel engines within the scope of license renewal has not been fully evaluated. The long termstorage and the full engine operational impacts must both be considered.

The following actions have been taken to prevent the introduction of biodiesel blends into the

fuel oil system.

a. The STP fuel oil supplier (Thomas Petroleum) was contacted. STP was informed that:

i. Deliveries to STP always are with Thomas Petroleum fleet trucks. Thomas Petroleumdoes not carry biodiesel in the trucks that supply fuel to our site.

ii. Diesel fuel for the Flint Hills rack location comes solely from the Corpus Christi Flint Hillsrefinery. Additionally, there is no biodiesel processed at the refinery or stored at theracks.

b. STP blanket contract number B02348 was changed to prohibit the fuel oil supplier fromsupplying biodiesel in any concentration.

c. Before off-load to the Auxiliary Fuel Oil Storage Tank (AFOST), each fuel trailer is tested forbiodiesel with the Herguth field kit (0.5 percent biodiesel lower limit of detection)


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The following actions will be taken if biodiesel is inadvertently added to the fuel oil system:

The actions that will be taken will depend upon the quantity of biodiesel inadvertently added.The quantity of biodiesel added may be so small in comparison to the AFOST fuel oilvolume that no action may be required.

If one truck of biodiesel fuel oil (approximately 7,000 gallons) was inadvertently off-loadedand added to the average fuel oil level maintained in the AFOST (approximately 170,460gallons), the resulting concentration of biodiesel in the AFOST would be approximately 0.21percent biodiesel. This is less than 4 times below the 1 percent biodiesel levels discussed inthe "DFOG Biodiesel Paper" - a level where it is likely there is no impact to the fuel oil or fueloil system.

If biodiesel contamination is detected in the STP AFOST or other diesel engine fuel oil tankswithin the scope of license renewal, then the following actions will be performed:

(a) A representative fuel oil sample is sent offsite for comprehensive and independentanalysis and biodiesel testing (0.1 percent biodiesel lower limit of detection). Additionalactions required will be determined by the measured percentage of biodiesel.

(b) If required, additional fuel oil filtration is performed through the Unit 1 or Unit 2 fuel oilfiltration skid. The Unit 1 and Unit 2 fuel oil filtration skids include a 5.0 micron pre-filter,a separator/coalescer (removes water and particulates), and a 0.5 micron post-filter.

(c) If required, additional (shorter than current periodicities) de-watering is performed of theAFOST and the FOSTs.

(d) If required, perform (shorter than current periodicities) testing of the fuel oil is performed.

(e) If required, fuel oil supplies are treated with biocide, water dispersant, fuel stabilizer, orother chemical additions.

RAI B2.1.14-3

Background:

The LRA states that condition reports have documented that fuel oil chemistry was out ofspecification in regards to water and fine sediment intrusion into the auxiliary fuel oil storagetank, diesel generator fuel oil storage tank, fire pump fuel oil storage tank, and the vendor fueloil trailer tanks during the period of 1999-2009. The applicant also stated that corrective actionswere taken and that fuel oil chemistry was brought back into specification limits.

Issue:

The LRA does not provide information on when and why water and fine sediment intrusion intostorage tanks were found and identified.


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Reguest:

Please discuss whether the trending of water and sediment measurements have remained thesame, increased, or decreased as a result of corrective actions.

STPNOC Response:

Auxiliary Fuel Oil Storage Tank (AFOST) Fuel Oil

Vendor fuel oil storage trailer tanks are used to deliver new fuel oil to the AFOST. ASTMD4176 clear and bright analysis is performed on the new fuel oil prior to offload to verify fueloil quality. The fuel oil shipment is rejected if the clear and bright analysis fails theacceptance criteria. A condition report is written and corrective action is taken with the fueloil vendor.

Since 2009, the clear and bright test of vendor delivered fuel failed on November 11, 2009,December 21, 2010, April 18, 2010, and April 19, 2010. All of the failures were due toparticles. These fuel oil shipments were rejected. The fuel oil chemistry of the AFOSTremained in specification throughout this period. The fuel oil supplier to the fuel oil vendorhas changed twice due to South Texas Project (STP) concerns with fuel oil quality. Thelatest change occurred in April 2011. Since this change, no additional failures of vendordelivered fuel have occurred.

Analyses of water and sediment in the AFOST (1997 to present) have been 0.0 percent.Analyses of particulate contamination in the AFOST (1997 to present) have been withinspecification (i.e., less than 10 parts per million (ppm)) with actual values of less than 6ppm.

Fire Pump Fuel Oil Storage Tank Fuel Oil

Beginning in 2009, the clear and bright analyses of ASTM D4176 have been used fortesting of the Fire Pump diesel fuel. There were no analyses failures due to water.Previous to 2009, water analyses were performed by the Karl Fischer titration method. Allanalyses results met specification.

The particulate contamination method of ASTM D2276 is used for sediment determination.On three occasions, particulate measured high out-of-specification in Fire Pump Fuel OilStorage Tank Fuel Oil samples. The cause of two out-of-specification samples in 2004 wasattributed the addition of biocide that resulted in a release of rust particles. The third out-of-specification sample result occurred in 2007 when the fuel oil particulate sample in one FirePump Fuel Oil Storage Tank measured 13.5 ppm. Corrective action was taken to drain thefuel oil and clean the tank.

Since 2007, all fuel oil particulate sample results for the Fire Pump Fuel Oil Storage Tank

have been within specification.

Diesel Generator Fuel Oil Storage Tank (DGFOST) Fuel Oil

In 2004, the particulate sample result of the fuel oil in DGFOST #11 was high out-of-specification (36 ppm). The tank was re-circulated through a filter skid and the fuel oil


Page 6 of 9

returned to within specification. The particulate was primarily carbonaceous in natureresulting from the normal deterioration of stored fuel oil over time. The corrective action isperiodic scheduled fuel oil cleaning using the permanently installed fuel oil filtration skid.

The DGFOSTs have the capability to be re-circulated through a filter skid. The filter skidincludes two particulate filters and a filter to remove water. The preventive maintenanceitem to re-circulate and filter the fuel oil from the DGFOSTs was changed in early 2005 tore-circulate the tanks from 24 hours to 72 hours. In mid 2005, the fuel oil sample point wasalso changed to a local point on the bottom of the tank. Since 2006, the DGFOST fuel oilparticulate sample results have remained within specification of less than 10 ppm withactual values of less than 6 ppm.

Conclusion

Corrective actions have been effective in maintaining fuel oil chemistry in specification.

RAI B2.1.14-4

Back ground:

Periodic draining and cleaning of diesel fuel tanks is performed so that internal surfaces can bevisually and volumetrically inspected allowing for detection of corrosion and other degradationinside the tanks. Regulatory Guide (RG) 1.137, "Fuel Oil Systems for Standby DieselGenerators," Revision 1, Regulatory Position C.2.f, as documented in the GALL ReportRevision 2, recommends draining and cleaning of diesel fuel tank internal surfaces at leastonce every 10 years during the period of extended operation.

LRA aging management program (AMP) B2.1.14, "Fuel Oil Chemistry Program," states that theprogram procedures will be enhanced to include 10-year periodic draining, cleaning, andinspection for corrosion of the standby diesel generator (SDG) fuel oil drain tanks and diesel firepump fuel oil storage tanks.

Issue:

The LRA does not indicate whether the program enhancement will include the balance of plant(BOP) day tanks.

Request:

Provide the frequency for draining, cleaning, and inspection of the BOP day tanks. If thefrequency is greater than 10 years, please discuss how it is consistent with the GALL Reportrecommendation of draining and cleaning of diesel fuel tank internal surfaces at least onceevery 10 years during the period of extended operation.

STPNOC Response:

The BOP Diesel Fuel Oil Day Tanks were inadvertently omitted from the first procedureenhancement in LRA Appendix B2.1.14, Fuel Oil Chemistry Program, for Preventive Actions


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(Element 2), Parameters Monitored or Inspected (Element 3), and Detection of Aging Effects(Element 4) regarding the 10-year periodic draining, cleaning, and inspection of the tanks forcorrosion.

The first procedure enhancement to Preventive Actions (Element 2), Parameters Monitored orInspected (Element 3), and Detection of Aging Effects (Element 4) in LRA Appendix B2.1.14,Fuel Oil Chemistry Program, is revised to read:

Procedures will be enhanced to include 10-year periodic draining, cleaning, and inspectionfor corrosion of the SDG fuel oil drain tanks, lighting diesel generator fuel oil tank, BOPdiesel fuel oil day tanks, and diesel fire pump fuel oil storage tanks.

The second procedure enhancement to Preventive Actions (Element 2), Parameters Monitoredor Inspected (Element 3), and Detection of Aging Effects (Element 4) in LRA Appendix B2.1.14,Fuel Oil Chemistry Program, has been combined with the first enhancement and is notrequired. This enhancement is deleted.

See Enclosure 2 for the revision to the LRA. Enclosure 3 provides a revised LRA regulatorycommitment.

XI.S8-1 Protective Coating Monitoring and Maintenance (048)

Back~ground:

The GALL Report states that proper maintenance of protective coatings inside containment(defined as Service Level I in NRC RG 1.54, Revision 1) is essential to ensure operability ofpost-accident safety systems that rely on water recycled through the containment sump/drainsystem. Degradation of coatings can lead to clogging of strainers, which reduces flow throughthe sump/drain system. The STP LRA does not credit the protective coating monitoring andmaintenance program for aging management.

Issue:

Although the applicant does not credit the program for aging management, the applicant needsto provide adequate assurance that proper management and maintenance of the protectivecoatings in containment is occurring, such that coatings will not degrade and become a debrissource that may challenge the Emergency Core Cooling Systems performance.

Request:

1. Discuss why XI.S8, "Protective Coating Monitoring and Maintenance Program," is notcredited for aging management.

2. Discuss in detail whether the applicant has a coatings monitoring and maintenanceprogram. Describe the program if one is used.

3. Describe how the applicant will ensure that there will be proper maintenance of theprotective coatings inside containment such that they will not become a debris source that


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could impact the operability of post-accident safety systems that rely on water recycledthrough the containment sump or drain system during the period of extended operation.

a. Provide the 10 elements of the AMP for coating, (i.e., scope of program, preventiveactions, parameters monitored or inspected, detection of aging effects, monitoring andtrending, acceptance criteria, corrective actions, confirmation process, administrativecontrols, and operating experience).

STPNOC Response:

1. South Texas Project (STP) does not credit coatings for managing the aging of structuralcomponents. Visual inspections of coated surfaces are performed to identify coatingdegradation as an indicator of the condition of underlying material. These visual inspectionsare conducted as part of the ASME Section Xl, Subsection IWE program and the StructuresMonitoring Program. Appendix B2.1.32, Structures Monitoring Program, states, STP doesnot take credit for any coatings to manage the aging of structural components, and coatingdegradation is used only as an indicator of the condition of underlying material.

2. STP implemented a Service Level 1 coatings program in response to NRC Generic Letter98-04 (Ref. NOC-AE-000350) that provides controls for the procurement, application, andmaintenance of Service Level 1 protective coatings used inside containment. Thesecontrols ensure that protective coatings inside containment will not become a debris sourcethat could affect the operability of post-accident safety systems. Coatings used inside thecontainment have been established as safety-related, thus imposing the quality assurancerequirements of 10 CFR Part 50, Appendix B to the Service Level 1 coatings program,which includes ongoing maintenance activities. Appendix B2.1.39, Protective CoatingMonitoring and Maintenance Program provide the details of this existing plant-specific agingmanagement program (see STPNOC NOC-AE-1 1002758 dated November 30, 2011,ML1 1335A140).

3. The existing Service Level 1 coatings program B2.1.39, Protective Coating Monitoring andMaintenance Program, was added to the LRA as part of the annual update. STPNOCLetter NOC-AE-1 1002758 dated November 30, 2011, provides the addition of AppendicesA1.39 and B2.1.39. Revisions to LRA Tables 2.1-1, 2.4-1, and 3.5.2-1, LRA Sections 2.1.6and 3.5.2.1.1 are provided to show an aging management review line for coatings.

See Enclosure 2 for revision to LRA Tables 2.1-1, 2.4-1, and 3.5.2-1, LRA Sections 2.1.6 and3.5.2.1.1.

Steam Generator Tube Integrity (020)

RAI B2.1.8-1

Background:

SRP-LR Section 3.1.2.2.11 and the GALL Report identify that cracking due to primary waterstress-corrosion cracking (PWSCC) could occur in steam generator (SG) nickel alloy tube-to-tubesheet welds exposed to reactor coolant. The GALL Report recommends the WaterChemistry AMP to manage this aging effect. This aging effect is addressed in GALL Report,


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item IV.D1.RP-385, and is applicable to recirculating SGs. In addition, the GALL Report andSRP-LR indicate that unless the NRC has approved a redefinition of the pressure boundary inwhich the tube-to-tubesheet weld is no longer included, the effectiveness of the primary waterchemistry program should be verified to ensure cracking is not occurring. The need for aprogram depends, in part, on the materials used in joining the tube to the tubesheet.

In LRA Table 3.1.1, the applicant stated that LRA item 3.1.1.35 is not applicable because STPdoes not have once-through SGs, and therefore do not have the components associated withthis model of SGs. In LRA Section B2.1.8, the applicant stated that the STP replacement SGshave thermally treated Alloy 690 tubes.

Issue:

The LRA was developed prior to the finalization of Revision 2 of the SRP-LR and the GALLReport. The LRA does not provide information on the tubesheet clad material or the tube-to-tubesheet weld region.

Request:

For STP Model Delta 94 SGs, confirm that the tube-to-tubesheet weld is part of the reactorcoolant pressure boundary and clarify the materials used in forming the tube-to-tubesheet joins(welds). If the tube-to-tubesheet weld is part of the reactor coolant pressure boundary and thecladding material has a chemical composition similar to Alloy 600 (e.g., Alloy 82 or Alloy 182),provide a plant-specific AMP, along with the Primary Water Chemistry Program, to manage thispotential aging effect and ensure that cracking due to PWSCC is not occurring in tube-to-tubesheet welds. Alternatively, justify why no AMP is needed.

STPNOC Response:

The tube-to-tubesheet weld is part of the reactor coolant pressure boundary for the STP ModelDelta 94 SGs. The South Texas Project Model Delta 94 replacement steam generatortubesheets are made of carbon steel clad with Alloy 690. The steam generator tubes arethermally treated Alloy 690 as indicated in LRA Section B2.1.8. The tube-to-tubesheet weldsare flush-fusion welds with Alloy 690 cladding. The material does not have a chemicalcomposition similar to Alloy 600 (Alloy 82 or Alloy 182).

Plant Specific Note # 2 was added to LRA Table 3.1.2-4 to clarify the material of steamgenerator tubesheets and tube-to-tubesheet welds (see Amendment 2 to STP LRA -ML1 1172A096 ) The aging management evaluation for steam generator tubesheets and tube-to-tubesheet welds is addressed as part of the line for component type SG Tubesheet withmaterial of Nickel Alloy in Table 3.1.2-4. The aging management programs credited formanaging primary water stress corrosion cracking are B2.1.8, Steam Generator TubingIntegrity program and B2.1.2, Water Chemistry program.

NUREG 1801, Revision 2, Section 3.1.2.2.11.2: states that for plants with Alloy 690 thermallytreated steam generator tubes with Alloy 690 tubesheet cladding the water chemistry programis sufficient and no further action or plant-specific aging management program is required. Theaging effect of PWSCC is effectively managed by B2.1.8, Steam Generator Tubing Integrityprogram, and B2.1.2, Water Chemistry program, as addressed in LRA Table 3.1.2-4. Nofurther action or plant-specific aging management program is required.


Enclosure 2

STP LRA Changes with Line-in/Line-out Annotations


Page 1 of 12

List of Revised LRA Sections

RAI Affected LRA SectionB2.1.14-1 Appendix Al.14

Appendix B2.1.14B2.1.14-4 Appendix B2.1.14XI.S8-1 Table 2.1-1

Table 2.4-1Table 3.5.2-1Section 2.1.6

Section 3.5.2.1.1.


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Al.14 FUEL OIL CHEMISTRY

The Fuel Oil Chemistry program manages loss of material on the internal surface ofcomponents in the standby diesel generator (SDG) fuel oil storage and transfer system, dieselfire pump fuel oil system, lighting diesel generator system, and balance of plant (BOP) fuel oilsystem. The program includes (a) surveillance and monitoring procedures for maintaining fueloil quality by controlling contaminants in accordance with the Technical Specifications andapp"'ab'e ASTM Standards Dl 796, D2276, and D4057, (b) periodic draining of water from fueloil tanks, (c) visual inspection of internal surfaces during periodic draining and cleaning, (d)ultrasonic wall thickness measurement or pulsed eddy current wall thickness measurement offuel oil tank bottoms during periodic draining and cleaning, and (e) inspections of new fuel oilbefore it is introduced into the fuel oil tanks.

The effectiveness of the program is verified under the One-Time Inspection program (Al.16).


Page 3 of 12

B2.1.14 Fuel Oil Chemistry

Program Description

The Fuel Oil Chemistry program manages loss of material on the internal surface ofcomponents in the standby diesel generator (SDG) fuel oil storage and transfer system, dieselfire pump fuel oil system, lighting diesel generator system, and balance of plant (BOP) fuel oilsystem. The program includes (a) surveillance and monitoring procedures for maintaining fueloil quality by controlling contaminants in accordance with the Technical Specifications andapplieable ASTM Standards D1796, D2276, and D4057, (b) periodic draining of water from fueloil tanks, (c) visual inspection of internal surfaces during periodic draining and cleaning,(d) ultrasonic wall thickness measurement or pulsed eddy current wall thickness measurementof fuel oil tank bottoms during periodic draining and cleaning, and (e) inspection of new fuel oilbefore it is introduced into the fuel oil tanks.

Fuel oil quality is maintained by monitoring and controlling fuel oil contaminants in accordancewith the Technical Specifications and appliable-ASTM Standards D1796, D2276, and D4057.This is accomplished by periodic sampling and chemical analysis of the fuel oil inventory at theplant, and sampling, testing, and analysis of new fuel oil prior to introduction into the fuel oilstorage tanks. Initial samples of new fuel oil are inspected for water and entrained foreignmaterial as precautions during the delivery process to avoid introducing contaminants. If asample appears unsatisfactory, delivery is discontinued or not allowed.

The One-Time Inspection program (B2.1.16) is used to verify the effectiveness of the Fuel OilChemistry program.

NUREG-1801 Consistency

The Fuel Oil Chemistry program is an existing program that, following enhancement, will beconsistent, with exception to NUREG-1801, Section XI.M30, Fuel Oil Chemistry.

Exceptions to NUREG-1801

Program Elements Affected:

Scope of Program (Element 1) and Acceptance Criteria (Element 6)

NUREG-1801 states that fuel oil quality is maintained in accordance with ASTM StandardsD1796, D2276, D2709, D6217, and D4057; ASTM Standards D6217 and Modified D2276,Method A are used for guidance for determination of particulates. The modification to D2276consists of using a filter with a pore size of 3.0 microns, instead of 0.8 micron. STP programspecifies fuel oil particulate concentrations are measured using a 0.8 micron nominal pore sizefilter, in accordance with ASTM-D2276. STP Technical Specification 6.8.3.i.3 specifies using atest method based on ASTM-D2276 to assure total particulate concentration is < 10mg/I.

The basis for use of ASTM-D2276 instead of ASTM-D6217 is the following: ASTM-D2276provides guidance on determining particulate contamination using a field monitor. It providesfor rapid assessment of changes in contamination level without the time delay required forrigorous laboratory procedures. ASTM-D6217 provides guidance on determining particulatecontamination by sample filtration at an off-site laboratory. Neither method contains

Enclosure 2NOC-AE-11002763

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acceptance criteria or is more stringent than the other. ASTM-D2276 is an accepted method ofdetermining particulates, a method recommended by ASTM-D975, and STP is committed byTechnical Specification to follow its guidance.

Scope of Program (Element 1), Parameters Monitored or Inspected (Element 3), andAcceptance Criteria (Element 6)

NUREG-1801 states that ASTM-D2709 is used for guidance in determining water and sedimentcontamination in diesel fuel. STP uses only ASTM-D1796, not ASTM-D2709, for determiningwater and sediment contamination in diesel fuel. The testing conducted using ASTM-D1796gives quantitative results, whereas ASTM-D2709 testing gives only pass-fail results. Therefore,the ASTM-D1796 method gives more descriptive information about the fuel oil condition thanthe ASTM-D2709 method.

NUREG-1801 states that ASTM-D4057 is used for guidance on oil sampling. This standardrequires that multilevel sampling be performed for tanks the size of the SDG fuel oil storagetanks. The Fuel Oil Chemistry program is focused on managing the conditions that causegeneral, pitting, and microbiologically-influenced corrosion (MIC) of the diesel fuel tank internalsurfaces. The fuel oil contaminants settle at the bottom of the tank and are removed along withthe water that has settled on the bottom. The fuel oil contaminants settle to the bottom of thetank, so only the bottom is sampled for contaminant concentrations. The fuel oil in the otherlevels of the tank contains less contaminants per volume than the bottom, making samplingaway from the bottom ineffective in managing fuel oil contaminants.

Parameters Monitored or Inspected (Element 3) and Acceptance Criteria (Element 6)

NUREG-1801 states that a filter with a pore size of 3.0 microns will be used in thedetermination of particulates. STP uses a filter with a pore size of 0.8 micron per ASTM-D2276. STP Technical Specifications provide for the use of ASTM-D2276 for the analysis offuel oil. Using a smaller pore size is a more conservative inspection, since more contaminantswill be captured when using a filter with a smaller pore size. Thus, a filter with a smaller poresize than 3.0 microns is acceptable in the inspection of fuel oil contaminant concentrations.

Enhancements

Prior to the period of extended operation, the following enhancements will be implemented inthe following program elements:

Scope of Program (Element 1)

Procedures will be enhanced to extend the scope of the program to include the SDG fuel oildrain tanks.


Page 5 of 12

Scope of Program (Element 1) and Preventive Actions (Element 2)

Procedures will be enhanced to check and remove the accumulated water from the fuel oil draintanks, day tanks, and storage tanks associated with the SDG, BOP, lighting diesel generator,and fire water pump diesel generators. A minimum frequency of water removal from the fuel oiltanks will be included in the procedure.

Preventive Actions (Element 2), Parameters Monitored or Inspected (Element 3),and Detectionof Aging Effects (Element 4)

Procedures will be enhanced to include 10-year periodic draining, cleaning, and inspection forcorrosion of the SDG fuel oil drain tanks, lighting diesel generator fuel oil tank, BOP dieselgenerator fuel oil day tanks, and diesel fire pump fuel oil storage tanks.

Proc~edures will be enhanced to finspect the BOP diesel generator fu8l oil day tanksca ndthelighting dliesel generator fuel oil tank for internal corsin

Procedures will be enhanced to require periodic testing of the lighting diesel generator fuel oiltank and the SDG and diesel fire pump fuel oil storage tanks for microbiological organisms.

Parameters Monitored or Inspected (Element 3), Monitoring and Trending (Element 5), andAcceptance Criteria (Element 6)

Procedures will be enhanced to require analysis for water, biological activity, sediment, andparticulate contamination of the diesel fire pump fuel oil storage tanks, lighting diesel generatorfuel oil tank, and the BOP diesel generator fuel oil day tanks on a quarterly basis.

Detection of Aging Effects (Element 4)

Procedures will be enhanced to conduct ultrasonic testing or pulsed eddy current thicknessexamination to detect corrosion-related wall thinning once on the tank bottoms for the SDG anddiesel fire pump fuel oil storage tanks, and the BOP diesel generator fuel oil day tanks.

Monitoring and Trending (Element 5)

Procedures will be enhanced to incorporate the sampling and testing of the diesel fire pumpfuel oil storage tanks for particulate contamination and water and to incorporate the trending ofwater, particulate contamination, and microbiological activity in the SDG and diesel fire pumpfuel oil storage tanks, lighting diesel generator fuel oil tank, and the BOP diesel generator fueloil day tanks.

Operating Experience

STP work orders, condition reports, and the chemistry database from 1999 to 2009 related tofuel oil chemistry were reviewed. None were found which documented any type of corrosion.Several occurrences were found in the chemistry database which documented the need to addbiocide to the fuel oil due to finding microbiological growth. Condition reports have documentedthat fuel oil chemistry was out of specification in the following instances:


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Water and fine sediment intrusion in the auxiliary fuel oil storage tank, diesel generator fuel oilstorage tank, fire pump fuel oil storage tank, and the vendor fuel oil trailer tanks have beenfound approximately annually due to various reasons including the tank cleaning work and apredisposition of a floating tank roof to allow water to pass through and into tank. Correctiveactions for fuel oil tanks, including additional inspections and the draining from the bottom oftanks after allowing the water and sediment to settle, have been effective in bringing the fuel oilchemistry back into specification limits, as proven during inspection procedures.

As additional industry and plant-specific applicable operating experience becomes available, itwill be evaluated and incorporated into the program through the Condition Reporting Process orthe Operating Experience program.

Conclusion

The continued implementation of the Fuel Oil Chemistry program, supplemented by theOne-Time Inspection program (B2.1.16), provides reasonable assurance that aging effects willbe managed such that the systems and components within the scope of this program willcontinue to perform their intended functions consistent with the current licensing basis for theperiod of extended operation.


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Table 2.1-1 Intended Functions: Abbreviations and Definitions (Continued)

ES Expansion/ Separation Provide for thermal expansion and/orseismic separation

FB Fire Barrier Provide rated fire barrier to confine orretard a fire from spreading to or fromadjacent areas of the plant

FIL Filter Provide filtration

FLB Flood Barrier Provide flood protection barrier (internaland external flooding event)

GR Gaseous Release Path Provide path for release of filtered andunfiltered gaseous discharge

HLBS HELB Shielding Provide shielding against high energy linebreaks

HS Heat Sink Provide heat sink during SBO or designbasis accidents

HT Heat Transfer Provide heat transfer

IN Insulate (electrical) Insulate and support an electricalconductor

INS Insulate Control heat loss

LBS Leakage Boundary (Spatial) Nonsafety-related component thatmaintains mechanical and structuralintegrity to prevent spatial interactions thatcould cause failure of safety-related SSCs

MB Missile Barrier Provide missile barrier (internally orexternally generated)

MCI Maintain Coating Integrity Maintain coatinq integrity to preventclogging of the Emergency Core CoolingSystems

PB Pressure Boundary Provide pressure-retaining boundary sothat sufficient flow at adequate pressure isdelivered, or provide fission product barrierfor containment pressure boundary, orprovide containment isolation for fissionproduct retention

PR Pressure Relief Provide over-pressure protection

PWR Pipe Whip Restraint Provide pipe whip restraint


Page 8 of-I 2

Table 2.4-1 Containment Buildina

________________________________~ ~ ~4N

Bellows !Expansion/SeparationStructural Pressure BoundaryStructural Support ..Shlte,-•ProtectionCaulking and Sealant

Coatina

Cornpressible Joints and Seals

Concrete Block (Masonry Walls)

Concrete Elements

Fire Barrier Coatings and Wraps

Fire Barrier Doors

IGate

IMaintain Coating Integrity

S§helter, Protection4Structural Pressure Boundary

Fire BarrierStructural SupportFire BarrierFlood BarrierHELB ShieldingMissile BarrierShelter, Protection

,Shielding'Structural Pressure BoundaryStructural Support

1

!Fire Barrier

.Fire Barrier

.Structural Pressure Boundaryi

Hatch - Auxiliary Airlock

Hatch - Equipment

Hatch - Personnel Airlock

Hatches and Plugs

• iner Containment

(ShieldingStructural Pressure Boundary

!.Structural SuppOrt .. . . .Structural Pressure BoundaryStructural Support---------.Fire Barrier, ShieldingStructural Pressure Boundary

'StructuralSu ppo-----------------..Missile Barrier

Shelter, ProtectionStructural Pressure Boundary


Page 9 of 12

Table 3.5.2-1 CorBuil

.Com-p-oneOnt -Ienc•

Type unct ic

'Caulking and :SHSealant

tainments, Structures, and Component Supports - Summary of Aging Management Evaluation - Containment

Coatings

CompressibleJoints andSeals

MCI Coatings

ldicit. IIUUUI /'%I LUbj U1 Sbdlilly, MI" Vlr" ,.LtUII Al, IIQ.'Q. O.0. D.I0

'(Structural) (Ext) Leakage through 'Subsection IWE1containment i(B2.1.27) and

110 CFR 50,!Appendix J B2.1.30)

Plant Indoor Air Loss of coating Protective Coating None None J 4(Structural) (Ext) integrity Monitoring and

J Maintenance (B2.1.39)PlantIndoorAir ..... ;Loss-ofseaIiin-g . ASME SectionXI, II.A3.7 -3... 16 .(Structural) (Ext) Leakage through {Subsection IWE

'containment ((B2.1.27) and i10 CFR 50,... . ... . . . .. . .... . ... .. . ..... . . . . .... . .... ..... . .

:SH, SPB Elastomer

Notes for Table 3.5.2-1:

Plant Specific Notes:

1 NUREG-1 801 does not provide a line in which concrete masonry is inspected per the Fire Protection program (B2.1.12).2 NUREG-1 801 does not provide a line in which fire barriers (ceramic fiber or cementitious coating) are inspected per the Fire Protection

program (B2.1.12).3 NUREG-1801 does not have this combination for the containment building, therefore, NUREG-1801, line II1.A6-12 is used4 NUREG-1801 does not provide a line in which coatinas are inspected Der the Protective Coatina Monitoring and Maintenance program

(B2.1.39).


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2.1.6 Generic Safety Issues

In accordance with the guidance in NEI 95-10 and Appendix A.3 of NUREG-1 800,Standard Review Plan for the Review of License Renewal Applications for NuclearPower Plants, review of NRC Generic Safety Issues (GSIs) as part of the licenserenewal process is required to satisfy a finding per 10 CFR 54.29. GSIs that involveissues related to license renewal aging management reviews or time-limited aginganalyses are to be addressed in the LRA. As a result of the review of NUREG-0933,Supplement 32, dated July 2008, the following GSIs have been evaluated for licenserenewal:

1. GSI-163, Multiple Steam Generator Tube Leakage

This GSI involves the potential multiple steam generator tube leaks during a main steamline break that cannot be isolated. Steam generator tubes are part of the reactorcoolant pressure boundary and are the subject of an AMR and TLAA evaluation asdocumented in Section 3.1 and Chapter 4 respectively. Aging management of steamgenerator tubes is addressed within the CLB of the plant and will continue to beaddressed during the period of extended operation by the Steam Generator TubeIntegrity program discussed in Section B2.1.8.

2. GSI-190, Fatigue Evaluation of Metal Components for 60-year Plant Life

This GSI addresses fatigue life of metal components and was closed by the NRC.However, the NRC concluded that license renewal applicants should address the effectsof reactor coolant environment on component fatigue life. Accordingly, the issue ofenvironmental effects on component fatigue life is addressed in Section 4.3.

3. GSI-1 91, Assessment of Debris Accumulation on PWR Sump Performance

GSI-191 addresses the potential for blockage of containment sump strainer assemblythat filters debris from cooling water supplied to the safety injection and containmentspray pumps following a postulated LOCA. The issue is based on containment strainerdesign and on the identification of new potential sources of debris that may block thesump strainers. STPNOC submitted to the NRC a response to Generic Letter (GL)2004-02 by STPNOC NOC-AE- 05001862, 90-Day Response to Generic Letter 2004-02: Potential Impact of Debris Blockage on Emergency Recirculation during DesignBasis Accidents at Pressurized-Water Reactors, dated March 8, 2005, South TexasProject, Units 1 and 2 - Supplement 1 to the Response to Generic Letter 2004-02 (TACNos. MC4719 and MC4720), and later supplements. The issues identified in GSI-191and GL 2004-2 are not aging-related issues. Also, the issues are not related to the 40-year term of the current operating license, and therefore, are not time-limited aginganalyses. The containment sump strainer assemblies are evaluated in Section 2.3.2.4,Safety Injection-. CoatinQs and the containment sumps are evaluated in Section 2.4.1,Containment Building. The Protective Coatingq Monitoring and Maintenance Program isdiscussed in Section B2.1.39, Protective Coating Monitoring and Maintenance Program.


Page 11 of 12

3.5.2.1.1 Containment Building

Materials

The materials of construction for the containment building component types are:

* Carbon Steel

* Coatings

* . Concrete

* Concrete Block (Masonry Walls)

* Elastomer

* Fire Barrier (Cementitious Coating)

* Stainless Steel

* Stainless Steel; Dissimilar Metal Welds

Environment

The containment building component types are exposed to the following environments:

* Atmosphere/ Weather (Structural)

• Buried (Structural)

* Encased in Concrete

* Plant Indoor Air (Structural)

* Submerged (Structural)

Aging Effects Requiring Management

The following containment building aging effects require management:

* Concrete cracking and spalling

* Cracking

* Cracking due to expansion

* Cracking, loss of bond, and loss of material (spalling, scaling)

* Cracks and distortion

• Increase in porosity and permeability, cracking, loss of material (spalling,scaling)

* Increase in porosity, permeability

* Loss of coating integrity

* Loss of leak tightness

* Loss of material


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0 Loss of material (spalling, scaling) and cracking

& Loss of material, cracking

0 Loss of sealing

* Loss of sealing; Leakage through containment

Aging Management Programs

The following aging management programs manage the aging effects for thecontainment building component types:

* 10 CFR Part 50, Appendix J (B2.1.30)

0 ASME Section Xl, Subsection IWE (B2.1.27)

0 ASME Section XI, Subsection IWL (B2.1.28)

* Fire Protection (B2.1.12)

* Masonry Wall Program (B2.1.31)

0 Protective Coatinq Monitoring and Maintenance (B2.1.39)

0 Structures Monitoring Program (B2.1.32)

0 Water Chemistry (B2.1.2)


Enclosure 3

Revised LRA Regulatory Commitments


Page 1 of 1

A4 LICENSE RENEWAL COMMITMENTS

Table 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 A4-1 License Renewal Commitments•Itmm -. .... .. .. ... •`:`:•`.•:K.`t;•-•.-`-. > mI enntat`ion .

it G-M-:' nPII

9 Enhance the Fuel Oil Chemistry program procedures to: B2.1.14 Prior to the period of* extend the scope of the program to include the SDG fuel oil drain tanks, extended operation* check and remove the accumulated water from the fuel oil drain tanks, day tanks, and

storage tanks associated with the SDG, BOP, lighting diesel generator, and fire water CR 10-23261pump diesel generators. A minimum frequency of water removal from the fuel oil tankswill be included in the procedure,

• include 10-year periodic draining, cleaning, and inspection for corrosion of the SDG fueloil drain tanks, lighting diesel generator fuel oil tank, BOP diesel generator fuel oil daytanks, and diesel fire pump fuel oil storage tanks,

* nspect the BOP diesel generator fuel oil day tanks And the; lighting diesel generator fueloil tank for internal corrosion,

* require periodic testing of the lighting diesel generator fuel oil tank and the SDG anddiesel fire pump fuel oil storage tanks for microbiological organisms,

• require analysis for water, biological activity, sediment, and particulate contamination ofthe diesel fire pump fuel oil storage tanks, lighting diesel generator fuel oil tank, and theBOP diesel generator fuel oil day tanks on a quarterly basis,

• conduct ultrasonic testing or pulsed eddy current thickness examination to detectcorrosion-related wall thinning once on the tank bottoms for the SDG and diesel firepump, and the BOP diesel generator fuel oil day tanks, and

* incorporate the sampling and testing of the diesel fire pump fuel oil storage tanks forparticulate contamination and water and to incorporate the trending of water, particulatecontamination, and microbiological activity in the SDG and diesel fire pump fuel oilstorage tanks, lighting diesel generator fuel oil tank, and the BOP diesel generator fueloil day tanks.

nuclear operating company december 6, 2011 · 2012. 12. 6. · december 6, 2011 noc-ae-1 1002763 10...

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