ML17006A008

Review and Comment of License Renewal Application Safety Evaluation Report with Open Items

ML17006A008
Person / Time
Site:	South Texas
Issue date:	12/14/2016
From:	Marc-Anthony Murray South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-16003425, TAC ME4936, TAC ME4937
Download: ML17006A008 (10)

Text

Nuclear Operating Company South Texas Project Electric Generating Station P.O. Box 28.9 Wadsworth, Texas 77483 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 December 14, 2016 NOC-AE-16003425 10 CFR 54 File No. G25 STPNOC Review and Comment of License Renewal Application Safety Evaluation Report with Open Items (TAC NOS. ME4936 and ME4937)

References:

1. Letter; G. T. Powell to the NRC Document Control Desk; "License Renewal Application",

NOC-AE-10002607; dated October 25, 2010. (ML103010257)

2. Letter; NRC to STP Nuclear Operating Company; "Safety Evaluation Report With Open Items Related to STP Nuclear Operating Company, Units 1 and 2 (TAC No. ME4936 and ME4937)"; dated October 14, 2016. (ML16271A011)

By Reference 1, STP Nuclear Operating Company (STPNOC) submitted an application to the Nuclear Regulatory Commission (NRC) for the renewal of Facility Operating Licenses NPF-76 and NPF-80, for South Texas Project (STP) Units 1 and 2, respectively. In Reference 2, the NRC transmitted the Safety Evaluation Report (SER) with Open Items related to the license renewal of the South Texas Project, Units 1 and 2. STPNOC is providing review comments to the License Renewal Safety Evaluation Report, Reference 2.

There are no regulatory commitments in this letter.

STI: 34416560

NOC-AE-16003425 Page 2 of 3 Should you have any questions regarding this letter, please contact Arden Aldridge, STP License Renewal Project Lead, at (361) 972-8243, or Rafael Gonzales, STP License Renewal Project regulatory point-of-contact, at (361) 972-4779.

rjg

Enclosure:

Michael P. Murray Manager, Regulatory Affairs Comments Regarding the Safety Evaluation Report (SER) with Open Items Dated October 2016 Related to the License Renewal of South Texas Project, Units 1 and 2

cc:

(paper copy)

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington, TX 76011-4511 Lisa M. Regner Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North (MS 8 G9A) 11555 Rockville Pike Rockville, MD 20852 NRC Resident Inspector U. S. Nuclear Regulatory Commission P. 0. Box 289, Mail Code: MN116 Wadsworth, TX 77 483 Lois James License Renewal Project Manager (Safety)

One White Flint North (MS 011-F1)

U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Tam Tran License Renewal Project Manager (Environmental)

One White Flint North (MS 011 F01)

U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 (electronic copy)

NOC-AE-16003425 Page 3 of 3 Morgan, Lewis & Bockius LLP Steve Frantz U.S. Nuclear Regulatory Commission Lisa M. Regner Lois James Tam Tran NRG South Texas LP Chris O'Hara Jim van Suskil Skip Zahn CPS Energy Kevin Pollo Cris Eugster L. D. Blaylock City of Austin Elaina Ball John Wester Texas Dept. of State Health Services.

Helen Watkins Robert Free

NOC-AE-16003425 Enclosure Comments Regarding the Safety Evaluation Report (SER) with Open Items Dated October 2016 Related to the License Renewal of South Texas Project, Units 1 and 2

No.

1 2

3 4

NOC-AE-16003425 Enclosure Page 1of6 Comments Regarding the Safety Evaluation Report (SER) with Open Items Dated October 2016 Related to the License Renewal of South Texas Project, Units 1 and 2 SER Location Comment Suggested Resolution Section Page (suggested text is shown by underlining/strikethrough formatting) 1.4 1-12 In Table 1.4-1, Current Interim Staff SER Section Guidance Item "Wall Thinning Due to 3.0.3.2.10 Erosion Mechanisms" 3.0.3.2.4 3.0.3.2.6 The SER Section listed 3.0.3.2.10 should be 3.0.3.2.4 and 3.0.3.2.6 1.4 1-13 In Table 1.4-1, "Aging Management SER Section of Loss of Coating or Lining Integrity 3.0.3.2.6 for Internal Coating/Linings on In-3.0.3.2.10 Scope Piping, Piping Components, 3.0.3.2.18 Heat Exchangers and Tanks" Add SER Sections 3.0.3.2.6 and 3.0.3.2.18 3.0.3.2.10 3-86 Item (d) second paragraph, the The staff finds the applicant's response acceptable reference to the AMP should be AMP because the acceptance criteria for degraded coatings Xl.M42 as modified by LR-ISG-2013-now includes all the aging mechanisms recommended 01 in AMP Xl.M42 Xl.M27, as modified by LR-ISG-2013-Q1 LR ISG 2012 012, and repairing the coatings based on any indication of the mechanisms helps ensure that degraded coatings are repaired prior to potentially affecting the component's or downstream component's intended function.

3.1.2 3-265 Table 3.1-1 (3.1.1.22) does not show See STPNOC Letter NOC-AE-15003270 dated June the changes made to the Reactor 30, 2015. (ML15197A029)

(Rx) vessel internals AMP response 1'

in NOC-AE-15003270.

I

No.

SER Location Section Page 5

3.1.2 3-266 6

3.1.2 3-267 7

3.1.2 3-268 8

3.1.2 3-269 9

3.1.2 3-273 10 3.1.2 3-273 11 3.1.2 3-277 Comment Table 3.1-1 (3.1.1.27) does not show the changes made to the Rx vessel internals AMP response in NOC-AE-15003270.

Table 3.1-1 (3.1.1.30) does not show the changes made to the Rx vessel internals AMP response in NOC-AE-15003270.

Table 3.1-1 (3.1.1.33) does not show the changes made to the Rx vessel internals AMP response in NOC-AE-15003270.

Table 3.1-1 (3.1.1.37) does not show the changes made to the Rx vessel internals AMP response in NOC-AE-15003270.

Table 3.1-1 (3.1.1.60) does not show the changes made to the Rx vessel internals AMP response in NOC-AE-15003270.

Table 3.1-1 (3.1.1.63) does not show the changes made to the Rx vessel internals AMP response in NOC-AE-15003270.

Table 3.1-1 (3.1.1.80) does not show the changes made to the Rx vessel internals AMP response in NOC-AE-15003270.

l NOC-AE-16003425 Enclosure Page 2 of 6 Suggested Resolution (suggested text is shown by underlining/strikethrough formatting}

See STPNOC Letter NOC-AE-15003270 dated June 30, 2015. (ML15197A029)

See STPNOC Letter NOC-AE-15003270 dated June 30, 2015. (ML15197A029)

See STPNOC Letter NOC-AE-15003270 dated June 30, 2015. (ML15197A029)

See STPNOC Letter NOC-AE-15003270 dated June 30, 2015. (ML15197A029)

See STPNOC Letter NOC-AE-15003270 dated June 30, 2015. (ML15197A029)

See STPNOC Letter NOC-AE-15003270 dated June 30, 2015. (ML15197A029)

See STPNOC Letter NOC-AE-15003270 dated June 30, 2015. (ML15197A029)

No.

SER Location Section Page 12 3.1.1 3-264 13 3.1.1 3-272 14 4.1.2.1.2 4-7 15 4.4.2 4-107 16 4.5.2 4-109 Comment Table 3.1.1 (3.1.1.16) is applicable to STP for loss of material due to general, pitting and crevice corrosion of carbon steel. See AMR table 3.1.2.4. Since STP has Model Delta 94 steam generators the additional inspections for Westinghouse Model 44 and 51 steam generators are not applicable as stated in LRA Section 3.1.2.2.2.4.

Table 3.1.1 (3.1.1.57) is not applicable to STP. STP does not have any CASS that is susceptible to thermal aging embrittlement. See SER Section 3.1.2.1.6.

The SER section listed in the third paragraph last sentence on page 4-7 should be 3.0.3.2.22.

The SER section listed in the first paragraph on page 4-107 should be 3.0.3.1.7.

The SER section listed in the fourth paragraph last sentence on page 4~

109 shoulq pe 3.0.3.1.8.

NOC-AE-16003425 Enclosure Page 3 of 6 Suggested Resolution (suggested text is shown by underl i ni ng/strikethroug h formatti na)

Revise Staff Evaluation Column to read Consistent with NUREG-1801. See further evaluation in Section 3.1.2.2.2.4.

Revise Staff Evaluation Column to read Not am;~licable to STP (see SER Section 3.1.2.1.6}.

The staff's evaluation of the applicant's AMP 82.1.27 is provided in SER Section 3.0.3.1.9 3.0.3.2.22.

On the basis of the AMP audit and as documented in SER Section 3.0.3.1.8 3.0.3.1.7, "Environmental Qualification (EQ) of Electrical Components," the staff finds that the EQ Program is consistent with the GALL Report. The staff further concludes that the applicant's EQ of Electrical Equipment TLAA is implemented per the requirements in 10CFR54.21 (c)(1 )(iii).

The staff's review of the Concrete Containment Tendon Prestress Program is discussed in SER Section 3".0.3.1.9 3.0.3.1.8.

No.

SER Location Section Page 17 4.5.2 4-111 18 4.5.2 4-112 19 Appendix A A-2 Item No 4 20 Appendix A A-3 Item No 4 21 Appendix A A-9 Item No 13 22 Appendix A A-10 Item No 13 Comment The SER section listed in the second paragraph last sentence on page 4-111 should be 3.0.3.1.8.

The SER section listed in the second paragraph on page 4-112 should be 3.0.3.1.8.

The text "No later than the date the renewed operating license is issued" goes with commitment "Enhance the Open-Cycle Cooling Water System program procedures to:"

Revise (NOS) to (NCS).

Remove the added text "(procedures, inspections, or other, as appropriate) by doing the following". This text was not in the LRA or referenced letters.

Remove the following duplicate bullet "Use of excessive cathodic protection polarized potential on coated piping should be avoided. The limiting critical potential should not be more negative than 1200 mV relative to a copper/copper sulfate reference electrode (CSE)."

NOC-AE-16003425 Enclosure Page 4of6 Suggested Resolution (suggested text is shown by underlining/strikethrough formatting)

The results of the review are documented in the staff evaluation of the Concrete Containment Tendon Prestress ProQram in SER Section :3.G.3.1.9 3.0.3.1.8.

This issue is discussed further in SER Section 3.G.3.1.9 3.0.3.1.8, "Concrete Containment Prestress."

See STPNOC Letter NOC-AE-15003303 dated November 12, 2015. (ML15334A354 Require coating inspections and tests be performed by a qualified Nuclear Coating Specialist (NCS NGS) as defined by ASTM 07108 endorsed in RG 1.54.

Enhance plant specifications !QjpFOeeEl1:1Fes, inspeetions, OF otheF, as appFOpFiate) by doing the follmving:

Use of excessive cathodic protection polarized potential on coated piping should be avoided. The limiting critical potential should not be more negative than 1200 mV relative to a copper/copper sulfate reference electrode (CSE).

Use of exeessive eathodie pFOteetion polaFized potential on eoated piping sho1:1ld be avoided. +he limiting 6Fitieal potential sho1:1ld not be moFe negative

. than 12GG mV rnlative to a CSE.

23 Appendix A A-12 Fix the formatting of the second Item No 13 bulleted item. See STPNOC Letter NOC-AE-16003385 dated June 28, 2016. (ML16190A135)

NOC-AE-16003425 Enclosure Page 5 of 6 Specify that Category E inspections be used when the cathodic protection system has been installed but the portions of the piping covered by that system fail to meet the acceptance criteria.

Category E inspections are 5 percent, NTE 5. The following condition must be present.

0 Coatings and backfill are provided in accordance with STP backfill specification.

0 There have been no leaks in buried piping due to external corrosion and no significant coating degradation or metal loss in more than 10 percent of inspections conducted.

0 Soil has been demonstrated to be not corrosive for the material type using the following.

A minimum of three sets of soil samples will be obtained in the vicinity where the cathodic protection system fails to meet the acceptance criteria.

The soil will be tested for soil resistivity, corrosion accelerating bacteria, pH, moisture, chlorides, sulfates, and redox potential.

The potential soil corrosivity will be determined for each material type of buried in-scoQe QiQing in the vicinity of the failed cathodic Qrotection system. In addition to evaluating each individual Qarameter, the overall soil corrosivity will be determined.

If Qortions of the installed cathodic Qrotection system fail to meet the acceQtance criteria, soil testing will be conducted at a minimum of once in each 10-year Qeriod starting at the time when it was determined that the cathodic Qrotection svstem failed to meet the acceotance.

No.

SER Location Comment Section Page 24 Appendix A A-25 Revise Item 39 per STPNOC Letter Item No 39 NOC-AE-16003394 dated July 28, 2016. (ML16221A391)

NOC-AE-16003425 Enclosure Page 6 of 6 Suggested Resolution (suggested text is shown by underlining/strikethrough formattinal Enhance the Selective Leaching of Aluminum Bronze procedures to:

Visually examine aluminum bronze materials exposed during inspection of the buried essential cooling water piping for evidence of leaka§e coating degradation and If degradation is identified near a weld a volumetric examination will be gerformed to determine if cracking of the weld is occurring.

If a leak from buried aluminum bronze welds is discovered by surface water monitoring or during a buried ECW piping inspection, a section of each leaking weld will be removed for destructive metallurQical examination.