ML11137A092

Request for Additional Information for the Review of the South Texas Project, Units 1 and 2, License Renewal Application Future Consideration of Operating Experience

ML11137A092
Person / Time
Site:	South Texas
Issue date:	05/24/2011
From:	Daily J License Renewal Projects Branch 1
To:	Gerry Powell South Texas
Daily J
References
TAC ME4936, TAC ME4937
Download: ML11137A092 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 May 24,2011 Mr. G. T. Powell Vice President, Technical Support and Oversight STP Nuclear Operating Company P.O. Box 289 VVadsworth, TX 77483 SUB..IECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEVV OF THE SOUTH TEXAS PROJECT, UNITS 1 AND 2, LICENSE RENEVVAL APPLICATION - FUTURE CONSIDERATION OF OPERATING EXPERIENCE (TAC NOS. ME4936 AND ME4937)

Dear Mr. Powell:

By letter dated October 25, 2010, South Texas Project Nuclear Operating Company (STP) submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54), to renew Operating Licenses NPF-76 and NPF-80 for STP, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, per the enclosure, an area where additional information is needed to complete the review.

This request for additional information was discussed with Mr. Arden Aldridge, and a mutually agreeable date for the response is by June 27, 2011. If you have any questions, please contact me at (301) 415-3873 or bye-mail at john.daily@nrc.gov.

Sincerely,

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John Daily, Sr. Project Manager

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Projects Branch 1 I

Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499

Enclosure:

As stated cc w/encl: Listserv

SOUTH TEXAS LICENSE RENEWAL APPLICATION SECTION B1.4, "OPERATING EXPERIENCE" RAI81.4-1

Background:

Pursuant to 10 CFR 54.21 (a)(3), a license renewal applicant is required to demonstrate that the effects of aging on structures and components subject to an aging management review are adequately managed so that their intended functions will be maintained consistent with the current licensing basis for the period of extended operation. Section 3.0.1 of NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants,"

Revision 2 (SRP-LR), defines an aging management review as the identification of the materials, environments, aging effects, and aging management programs (AMPs) credited for managing the aging effects. In turn, SRP-LR Section A.1.2.3 defines an acceptable AMP as consisting of ten elements. Element 10, "Operating Experience," in part, is described in SRP-LR Section A.1.2.3.10, paragraph 1, as follows:

Consideration of future plant-specific and industry operating experience relating to aging management programs should be discussed. Reviews of operating experience by the applicant in the future may identify areas where aging management programs should be enhanced or new programs developed. An applicant should commit to a future review of plant-specific and industry operating experience to confirm the effectiveness of its aging management programs or indicate a need to develop new aging management programs (emphasis added). This information should provide objective evidence to support the conclusion that the effects of aging will be managed adequately so that the structure and component intended function(s) will be maintained during the period of extended operation.

In addition, 10 CFR 54.21 (d) requires the application to contain a final safety analysis report (FSAR) supplement. This supplement must contain a summary description of the programs and activities for managing the effects of aging and the evaluation of time-limited aging analyses for the period of extended operation.

Based on its review of the South Texas Project. Units 1 and 2, license renewal application (LRA), the staff determined that Section B1.4 provides a general description of how the applicant gathered and considered operating experience in preparing its LRA, and Sections B2.1.1 through B2.1.37 and B3.1 through B3.3 summarize the specific operating experience considered for each AMP.

Issue:

Although LRA Sections B 1.4, B2.1.1 through B2.1.37, and B3.1 through B3.3 describe how the applicant incorporated operating experience into its AMPs, they do not fully describe how the applicant will use future operating experience to ensure that the AMPs will remain effective for managing the aging effects during the period of extended operation. The main focus of these LRA sections is on how the applicant evaluated operating experience available at the time the ENCLOSURE

- 2 application was prepared to justify the adequacy of its proposed AMPs. Some of the program descriptions, particularly those for new programs, contain statements indicating that future plant-specific and industry operating experience will be used to adjust the programs as appropriate. However, for the majority of the AMPs, it is not clear whether the applicant currently has or intends to implement actions to monitor operating experience on an ongoing basis and use it to ensure the continued effectiveness of the AMPs. The LRA also does not state whether new AMPs will be developed, as necessary. Further, the majority of the AMP descriptions do not provide the staff reasonable assurance that ongoing operating experience reviews will continue to inform AMP updates for license renewal.

Request:

Describe the programmatic activities that will be used to continually identify aging issues, evaluate them, and, as necessary, enhance the AMPs or develop new AMPs for license renewal. In this description, address the following:

Describe the sources of plant-specific and industry operating experience that are monitored on an ongoing basis to identify potential aging issues. Indicate whether these plant-specific sources require monitoring: corrective action program, system health reports, licensee event reports (LERs), and the results of inspections performed under the AMPs. Similarly, indicate whether these industry sources require monitoring: vendor recommendations, revisions to industry standards on which the AMPs are based, LERs from other plants, NRC Bulletins, Generic Letters, Regulatory Issue Summaries, Information Notices, Regulatory Guides, License Renewal Interim Staff Guidance, and revisions to NUREG-1801, "Generic Aging Lessons Learned (GALL) Report." Describe the criteria used to classify a particular piece of information as aging related and outline the training provided to plant personnel so that they can adequately make such classifications.

Describe how the identified aging issues are further evaluated to determine their potential impact on the plant aging management activities. Indicate whether the affected structures and components and their materials, environments, aging effects, aging mechanisms, and AMPs are identified and documented consistent with the methods used to prepare the LRA. Describe how the results of AMP inspections are considered to adjust the frequency of future inspections, establish new inspections, and ensure an adequate depth and breadth of component, material, environment, and aging effect combinations. Describe the records of these evaluations and indicate whether they are maintained in an auditable and retrievable form.

Describe the process and criteria used to ensure that the identified enhancements are implemented in a timely manner.

Describe the administrative controls over these programmatic activities.

- 3 Provide a summary description of these activities for the FSAR supplement required by 10 CFR 54.21(d). If enhancements for license renewal are necessary, also provide the updates for the FSAR supplement.

If such an operating experience program is determined to be unnecessary, provide a detailed explanation of the bases for this determination.

May 24,2011 Mr. G. T. Powell Vice President, Technical Support and Oversight STP Nuclear Operating Company P.O. Box 289 VVadsworth, TX 77483

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEVV OF THE SOUTH TEXAS PROJECT, UNITS 1 AND 2, LICENSE RENEVVAL APPLICATION - FUTURE CONSIDERATION OF OPERATING EXPERIENCE (TAC NOS. ME4936 AND ME4937)

Dear Mr. Powell:

By letter dated October 25, 2010, South Texas Project Nuclear Operating Company (STP) submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54), to renew Operating Licenses NPF-76 and NPF-80 for STP, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, per the enclosure, an area where additional information is needed to complete the review.

This request for additional information was discussed with Mr. Arden Aldridge, and a mutually agreeable date for the response is by June 27, 2011. If you have any questions, please contact me at (301) 415-3873 or bye-mail at john.daily@nrc.gov.

Sincerely, IRA!

John Daily, Senior Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499

Enclosure:

As stated cc w/encl: Listserv DISTRIBUTION:

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~IDaily BPham JDaily DATE 05/23/11 E11 05/24/11 05/24/11 OFFICIAL RECORD COpy

Letter to G.T. Powell 'from J. Daily dated May 24,2011

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE SOUTH TEXAS PROJECT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION - FUTURE CONSIDERATION OF OPERATING EXPERIENCE (TAC NOS. ME4936 AND ME4937)

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