NOC-AE-11002737, Supplement to License Renewal Application (TAC Nos. ME4936 and ME4937)

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Supplement to License Renewal Application (TAC Nos. ME4936 and ME4937)
ML11298A082
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 10/18/2011
From: Gerry Powell
South Texas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-11002737, TAC ME4936, TAC ME4937
Download: ML11298A082 (50)
v • d • e


Text

Nuclear Operating Company South Texas ProjectElectric Generatin$Station PO Box 289 Wadsworth, Texas 77483 AAAA October 18, 2011 NOC-AE-1 1002737 10 CFR 54 STI: 32959151 File: G25 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Supplement to the South Texas Project License Renewal Application (TAC NOS. ME4936 and ME4937)

References:

1. STPNOC Letter dated October 25, 2010, from G. T. Powell to NRC Document Control Desk, "License Renewal Application," (NOC-AE-10002607)

(ML103010257)

2. STPNOC Letter dated May 12, 2011, from G. T. Powell to NRC Document Control Desk, "Response to Request for Additional Information for the South Texas Project License Renewal Application" (NOC-AE-1 1002672)

(ML11145A090)

3. STPNOC Letter dated August 9, 2011, from G. T. Powell to NRC Document Control Desk, "Response to Request for Additional Information for the Review of the South Texas Project License Renewal Application" (TAC Nos. ME4936 and ME4937) (NOC-AE-1 1002702) (ML11234A045)
4. STPNOC Letter dated August 23 2011, from G. T. Powell to NRC Document Control Desk, "Response to Requests for Additional Information for the South Texas Project License Renewal Application" (TAC Nos. ME4936 and ME4937)

(NOC-AE-1 1002714) (ML11238A072)

5. STPNOC Letter dated October 10, 2011, from G. T. Powell to NRC Document Control Desk, "Response to Requests for Additional Information for the the South Texas Project License Renewal Application" (TAC Nos. ME4936 and ME4937)

(NOC-AE-1 1002732)

By Reference 1, STP Nuclear Operating Company (STPNOC) submitted a License Renewal Application (LRA) for South Texas Project (STP) Units 1 and 2. This letter supplements responses to requests for information regarding the LRA. Changes to previous STPNOC responses to requests for additional information in References 2, 3 and 5 are provided in . Changes to the LRA previously discussed in References 2, 3, 4 and 5 and in to this letter are provided in Enclosure 2.

A revised regulatory commitment to Table A4-1 of the LRA in provided in Enclosure 3.

There are no other regulatory commitments in this letter.

NOC-AE-1 1002737 Page 2 Should you have any questions regarding this letter, please contact either Arden Aldridge, STP License Renewal Project Lead, at (361) 972-8243 or Ken Taplett, STP License Renewal Project regulatory point-of-contact, at (361) 972-8416.

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

Executed on &-6.r IS . Zoll Date G. T. Powell Vice President, Generation KJT

Enclosures:

1. Supplemental Responses to RAIs
2. Changes to the STPNOC LRA
3. Revised Regulatory Commitments

NOC-AE-1 1002737 Page 3 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission Kathryn M. Sutton, Esquire 612 East Lamar Blvd, Suite 400 Morgan, Lewis & Bockius, LLP Arlington, Texas 76011-4125 Balwant K. Singal John Ragan Senior Project Manager Chris O'Hara U.S. Nuclear Regulatory Commission Jim von Suskil One White Flint North (MS 8B1) NRG South Texas LP 11555 Rockville Pike Rockville, MD 20852 Kevin Polio Senior Resident Inspector Richard Pena U. S. Nuclear Regulatory Commission City Public Service P.O. Box 289, Mail Code: MN116 Wadsworth, TX 77483 C. M. Canady Peter Nemeth City of Austin Crain Caton & James, P.C.

Electric Utility Department 721 Barton Springs Road C. Mele Austin, TX 78704 City of Austin John W. Daily Richard A. Ratliff License Renewal Project Manager (Safety) Alice Rogers U.S. Nuclear Regulatory Commission Texas Department of State Health Services One White Flint North (MS O11-Fl) 11555 Rockville Pike Rockville, MD 20852 Balwant K. Singal Tam Tran John W. Daily License Renewal Project Manager Tam Tran (Environmental) U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission One White Flint North (MS O11F01) 11555 Rockville Pike Rockville, MD 20852

Enclosure 1 NOC-AE-1 1002737 Enclosure I Supplemental Responses to RAI's

Enclosure 1 NOC-AE-1 1002737 Page 1 of 5 Supplemental Responses to RAI's

References:

1. STPNOC Letter dated May 12, 2011, from G. T. Powell to NRC Document Control Desk, "Response to Request for Additional Information for the South Texas Project License Renewal Application" (NOC-AE-1 1002672)

(ML11145A090)

2. STPNOC Letter dated August 9, 2011, from G. T. Powell to NRC Document Control Desk, "Response to Request for Additional Information for the Review of the South Texas Project License Renewal Application" (TAC Nos. ME4936 and ME4937) (NOC-AE-1 1002702) (ML11234A045)
3. STPNOC Letter dated October 10, 2011, from G. T. Powell to NRC Document Control Desk, "Response to Requests for Additional Information for the the South Texas Project License Renewal Application" (TAC Nos. ME4936 and ME4937)

(NOC-AE-1 1002732)

The following table lists the affected Request for Additional Information numbers from the referenced correspondence where the response has been supplemented with additional information. The supplement information is formatted in a "line-out" (i.e. text being deleted from the RAI response) and "line-in" (i.e. text being added to the RAI response) structure.

Referenced RAI Reason for Change Letter Number 1 4.3.2.11-3 Revise LRA Appendix B section B3.1 Corrective Actions (Element

7) to delete LBB wording 2 2.3.3.7-02 Revise LRA table 3.3.2-7 to include valves with copper alloy > 15 percent zinc in plant indoor air internal and external environments 2 2.3.3.22-02 LRA Table 3.1.2-2 will be revised to add the SIA intended function to the PRT.

3 B2.1.32-04 Response previously not provided RAI 4.3.2.11-3 (Supplemental Response)

Note: The referenced letter inadvertently "lined-in/lined-out" more changes to the LRA Appendix B Section B3.1 Corrective Actions (Element 7) than should have been reflected as changes. For the "line-in/line-out" changes reflected on Page 27 of Enclosure 1 to the referenced letter, only item (3) was an addition to the LRA.

3) Review of fatigue crack growth and stability analyses support the leak before break exemptions and relief from the ASME Section Xl flaw removal or inspection requirements to ensure that the analytical bases remain valid. Re-analysis of a fatigue crack growth analysis must be consistent with or reconciled to the originally submitted analysis and receive the same level of regulatory review as the original analysis.

Enclosure 1 NOC-AE-1 1002737 Page 2 of 5 Although not reflected in the referenced letter, item (1)(c) will be changed as follows and Item (1)(d) will be deleted from the LRA.

c) To ensure that the analytical bases of the lea_"k beforo break (LBB) fatigue crack propagation analy...a*nd of the high energy line break (HELB) locations are maintained.

d) To ensure that the analytical bases of a fatigue*rFak g"ev*h and stability analysis in support Of relief fromA ASME Section Xl flaw romoval.

(Enclosure 2 to this letter provides the line-in and line-out changes to LRA Appendix B3. 1.]

RAI 2.3.3.7-02 (Supplemental Response)

Relief valve PSV8571 on boundary drawings LR-STP-IA-8Q119F00048#1-1 and LR-STP-IA-8Q1 19F00048#2-1 (location E-5) were inadvertently not included in-scope of license renewal and are not highlighted on the boundary drawings. These valves should be in-scope for 10 CFR 54.4(a)(3).

Relief valve PSV8571 will be included in-scope and boundary drawings LR-STP-IA-8Q119F00048#1-1 and LR-STP-IA-8Q119F00048#2-1 (location E-5) will be updated to highlight these valves "green" for 10 CFR 54.4(a)(3).

During the review boundary drawing review relief valve PSV8571 was determined to utilize valve material with >15 percent zinc with an internal and external environment of plant indoor air.

LRA Table 3.3.2-7 will be revised to include additional AMR line items for a valve with >15 percent zinc with internal and external environments of plant indoor air.

[Enclosure 2 to this letter provides the line-in and line-out changes to LRA Table 3.3.2-7.]

RAI 2.3.3.22-02 (Supplemental Response)

Item 1 No change is made to previous response.

Item 2 The NSR portion of the SR/NSR interface on LR-STP-WL-5R309F05022#1 at F-7 begins with the solid line next to the dashed valve FV3400. Continuing along the NSR portion of this piping, all branches are appropriately terminated with an equivalent anchor except two locations. These locations are C-8 (pipe 4"RC1041UD7) and B-2 (pipe 3"RC1034UD7), with piping continuing to the pressurizer relief tank (PRT) on boundary drawings LR-STP-RC-5R149F05004#1 & #2 (E-5). The PRT serves as an appropriate F.4.a base-mounted component. The PRT and the associated piping a. e is in-scope for license renewal for

Enclosure 1 NOC-AE-1 1002737 Page 3 of 5 spatial interaction, but structural integrity attached (SIA) was inadvertently omitted as an intended function. In addition, but-a the terminal component symbol was inadvertently omitted at the PRT.

LRA Table 3.1.2-2 will be revised to add the SIA intended function to the PRT. Also, Bboundary drawings LR-STP-RC-5R149F05004#1 & #2 will be updated to add an F.4.a termination symbol (base-mounted component) to the PRT.

[Enclosure 2 to this letter provides the line-in and line-out to changes to LRA Table 3.1.2-2.]

RAI B2.1.32-04 (Supplemental Response)

Background:

In GALL AMP XI.S6, in program element 3 "parameters monitored or inspected" and program element 4, "detection of aging effects," notes that the structures monitoring program addresses detection of aging effects for inaccessible, below-grade concrete structural elements, and for plants with non-aggressive ground water/soil (pH > 5.5, chlorides < 500 ppm, and sulfates

<1500 ppm), the program recommends: (a) evaluating the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas and (b) examining representative samples of the exposed portions of the below-grade concrete, when excavated for any reason. The GALL Report also notes that for plants with aggressive ground water/soil (pH < 5.5, chlorides > 500 ppm, or sulfates > 1500 ppm) and/or where the concrete structural elements have experienced degradation, a plant-specific AMP accounting for the extent of the degradation experienced should be implemented to manage the concrete aging during the period of extended operation.

Issue:

The LRA and element 3 of the LRA basis document state that plant procedures will be enhanced to monitor at least two groundwater samples every five years for pH, sulfates, and chlorides, but no results are provided to demonstrate that the groundwater is either aggressive or non-aggressive. Also in element 4 of the LRA basis documents for the Structures Monitoring Program and the Reg. Guide 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program, no mention is made of opportunistic inspections of below-grade structures or a plant-specific program to address the below-grade structures if the ground water is aggressive. It is unclear to the staff how inaccessible concrete structures subjected to groundwater will be managed for aging.

Request:

1. Provide historical results, including seasonal variations, for groundwater chemistry (i.e., pH, sulfates, and chlorides) to demonstrate that the groundwater is either aggressive or non-aggressive.
2. If historical results indicate that the groundwater is considered to be non-aggressive, demonstrate that opportunistic inspections of exposed portions of the below-grade concrete,

Enclosure 1 NOC-AE-1 1002737 Page 4 of 5 when excavated for any reason, will be performed under both the Structures Monitoring Program and the Reg. Guide 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program, or explain why the inspections are not needed.

3. If historical results indicate that the ground water is aggressive, or where accessible concrete structural elements have experienced degradation, identify the plant-specific program that will be used to manage aging of these structures, or explain why the existing programs are adequate.

STPNOC Response:

STIPNOC will provide response a to this RAI by October 21, 2011 under a separate oVcrr le-tcr.

Samples taken from sample well B-1 B in 1989 and 1990 indicate the STP site -groundwateris non-aqggressive. Chlorides and sulfates were measured at 120ppm/34ppm and 124ppm/32ppm respectively. (Reference letters ST-P2-HL-557 & ST-HS-HL-7472) Direct measurements of chloride and sulfate levels have not been routinely taken, therefore seasonal variances and current groundwater insights cannot be determined. Operating experience at STP has not identified any degradation of structures that would be attributable to aggressive groundwater.

To validate that groundwater remains non-aggressive, STP will analyze the site groundwater for pH, sulfates, and chlorides in samples taken at multiple locations around the site every three months for at least 24 consecutive months. This sampling plan will begin no later than September 2012.

Opportunistic inspections of exposed portions of the below-grade concrete, when excavated for any reason, will be performed using aging management program B2.1.32, Structures Monitoring Program. The Structures Monitoring Program includes water-control structures.

If the results of the 24-month groundwater sampling plan discussed in Part 1 in response to this RAI identifies that the ground water is aggressive or it is identified that accessible concrete structural elements have experienced degradation, an evaluation will be performed to determine the appropriate actions necessary to assure that the affected structures will continue to perform their intended function. These actions may include increased visual inspections or other examination techniques.

LRA Appendix B2.1.32, LRA Basis Document AMP XI.S6 (B2.1.32), Structures Monitoring program will be revised to include the following enhancements:

Groundwater samples will be taken at multiple locations around the site every three months for at least 24 consecutive months. The samples will be analyzed for pH, sulfates, and chlorides. This sampling plan will begin no later than September 2012.

1. Procedures will be enhanced to perform opportunistic inspections of exposed portions of the below-grade concrete, when excavated for any reason.
2. Procedures will be enhanced to require an evaluation should ground water be determined to be aggressive or inspections of accessible concrete structural elements identify degradation. The evaluation will be performed to determine the appropriate actions necessary to assure that the affected structures will continue to perform their

Enclosure 1 NOC-AE-1 1002737 Page 5 of 5 intended function. These actions may include increased visual inspections or other examination techniques.

The procedure enhancements will be added to revise Commitment 25 (B2.1-32) to LRA Table A4-1. The 24-month sampling plan enhancement will be added as new Commitment 37 (B2.1-32) to LRA Table A4-1.

[Enclosures 2 and 3 provide the mark-in/mark-out sections of the License Renewal Application.]

Enclosure 2 NOC-AE-1 1002737 Enclosure 2 Changes to the STPNOC LRA

Enclosure 2 NOC-AE-1 1002737 Page 1 of 37 Changes to the STPNOC LRA

References:

1. STPNOC Letter dated August 9, 2011, from G. T. Powell to NRC Document Control Desk, "Response to Request for Additional Information for the Review of the South Texas Project License Renewal Application" (TAC Nos. ME4936 and ME4937) (NOC-AE-1 1002702) (ML11234A045)
2. STPNOC Letter dated August 23 2011, from G. T. Powell to NRC Document Control Desk, "Response to Requests for Additional Information for the South Texas Project License Renewal Application" (TAC Nos. ME4936 and ME4937)

(NOC-AE-1 1002714) (ML11238A072)

3. STPNOC Letter dated October 10, 2011, from G. T. Powell to NRC Document Control Desk, "Response to Requests for Additional Information for the the South Texas Project License Renewal Application" (TAC Nos. ME4936 and ME4937)

(NOC-AE-1 1002732)

4. STPNOC Letter dated May 12, 2011, from G. T. Powell to NRC Document Control Desk, "Response to Request for Additional Information for the South Texas Project License Renewal Application" (NOC-AE-1 1002672)

(ML11145A090)

The following table lists the affected STPNOC LIA Sections and Tables and provides the reason for each change. The LRA changes following the table are formatted in a "line-out" (i.e.

text being deleted from the LRA) and "line-in" (i.e. text bein9 added to the LRA) structure.

Referenced RAI Affected Reason for Change Letter Number Section of LRA 2 2.1-1 Section LRA section 2.1.2.1 will be revised to include 2.1.2.1 Quality Class 4 (QC-4) SSCs are witi,,.in the scope of license renewal for 10 CFR 50.54(a)(..'),

2 2.1-3 Table LRA will be changed to include previously 2.3.3-1 unidentified nonsafety-related SSC within the scope of license renewal.

1 2.3.3.8-06 Table LRA Table 2.3.3-8 will be updated to add the 2.3.3-8 housing of the pressure indicator.

1 2.3.3.20-05 Section Section 2.3.3.20 will be revised to remove air 2.3.3.20 dryers from the system description.

1 2.3.3.20-05 Table LRA Table 2.3.3-20 will be revised to remove the 2.3.3-20 component type "dryer".

2 2.1-3 Table LRA will be changed to include previously 2.3.3-27 unidentified nonsafety-related SSC within the scope of license renewal.

Enclosure 2 NOC-AE-1 1002737 Page 2 of 37 Referenced RAI Affected Reason for Change Letter Number Section of LRA 2 2.1-3 Section LRA will be changed to include previously 2.3.4.5 unidentified nonsafety-related SSC within the scope of license renewal.

2 2.1-3 Table LRA will be changed to include previously 2.3.4-5 unidentified nonsafety-related SSC within the scope of license renewal.

1 2.3.3.22-02 Table LRA Table 3.1.2-2 will be revised to add the SIA 3.1.2-2 intended function to the PRT.

2 2.1-3 Section LRA will be changed to include previously 3.3.2.1.1 unidentified nonsafety-related SSC within the scope of license renewal.

2 2.1-3 Section LRA will be changed to include previously 3.3.2.1.19 unidentified nonsafety-related SSC within the scope of license renewal..

2 2.1-3 Section LRA will be changed to include previously 3.3.2.1.27 unidentified nonsafety-related SSC within the scope of license renewal..

2 2.1-3 Table LRA will be changed to include previously 3.3.2-1 unidentified nonsafety-related SSC within the scope of license renewal..

1 2.3.3.7-02 Table LRA table 3.3.2-7 will be revised to include valves 3.3.2-7 with copper alloy > 15 percent zinc in plant indoor air internal and external environments 1 2.3.3.8-06 Table LRA Table 3.3.2-8 will be updated to add the 3.3.2-8 housing of the pressure indicator..

2 2.1-3 Table LRA will be changed to include previously 3.3.2-19 unidentified nonsafety-related SSC within the scope of license renewal..

1 2.3.3.20-05 Table LRA Table 3.3.2-20 will be revised to remove the 3.3.2-20 component type "dryer",

2 2.1-3 Table LRA will be changed to include previously 3.3.2-22 unidentified nonsafety-related SSC within the scope of license renewal..

2 2.1-3 Table LRA will be changed to include previously 3.3.2-27 unidentified nonsafety-related SSC within the scope of license renewal.

Enclosure 2 NOC-AE-1 1002737 Page 3 of 37 Reason for Change A new component line will be added for a "stainless steel filter with a lube oil internal environment and plant indoor air external environment" for the main steam system.

LRA will be changed to include previously unidentified nonsafety-related SSC within the scope of license renewal.

To add enhancements to the Structures Monitoring Program Revise LRA Appendix B section B3.1 Corrective Actions (Element 7) to delete LBB wording

Enclosure 2 NOC-AE-1 1002737 Page 4 of 37 2.1.2.1 10 CFR 54.4(a)(1) - Safety-related 10 CFR 54.4(a)(1) requires that plant SSCs within the scope of license renewal include safety-related SSCs which are those relied upon to remain functional during and following design-basis events (as defined in 10 CFR 50.49(b)(1)) to ensure the following functions:

(i) The integrity of the reactor coolant pressure boundary; (ii) The capability to shutdown the reactor and maintain it in a safe shutdown condition; or, (iii) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposure comparable to those referred to in 50.34(a)(1), 50.67(b)(2), or 100.11, as applicable.

S TP Safety-related Classifications Safety-related design classifications for systems, structures, and components are described in the UFSAR and in plant specification Quality Classificationof Structures, Systems and Components. Safety-related classifications for components are documented on engineering drawings and in the master equipment database. The safety-related classification as described in these source documents was used to identify SSCs satisfying one or more of the criteria of 10 CFR 54.4(a)(1) and include them within the scope of license renewal.

STP-specific definitions for safety-related in UFSAR Section 3.2 are consistent with the definition of safety-related provided in 10 CFR 54.4(a)(1).

UFSAR Section 3.2.A states that certain structures, components, and systems of the nuclear plant are considered safety-related because they perform safety functions required to prevent or mitigate the consequences of abnormal operational transients or accidents. Safety-related plant structures, systems, and components are designed to withstand the effects of a Safe Shutdown Earthquake (SSE) and remain functional if they are necessary to assure:

1. The integrity of the reactor coolant pressure boundary (RCPB).
2. The capability to shut down the reactor and maintain it in a safe shutdown condition.
3. The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to the guideline exposures of 10 CFR 100.

UFSAR Section 3.2.B states that for nuclear steam supply system SSCs, Westinghouse Electric Corporation, in lieu of the requirements of RG 1.26 and 1.29, applies a rule that each component classified as safety class (SC) 1, 2, or 3 shall be qualified to remain functional in the event of the SSE except where exempted by meeting all of the following conditions. Portions of systems required to perform the same safety function required of any SC component, which is a part of that system shall be likewise qualified or granted exemption.

South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 5 of 37 Provisions to be met for exemption are:

1. Failure would not directly cause a Condition III or IV event (as defined in UFSAR Reference 3.2.B-4).
2. There is no safety function to perform nor could failure prevent mitigation of the consequences of a Condition III or IV event.
3. Failure during or following any Condition II event would result in consequences no more severe than allowed for a Condition III event.

Quality group classification, safety class terminology is utilized for the classification of components and structures. This terminology correlates to the NRC Quality Group designations for water, steam, and radioactive waste-containing mechanical components as follows:

STP Classification NRC RG 1.26 SC 1 Quality Group A SC 2 Quality Group B SC 3 Quality Group C NNS (Non-Nuclear Safety) Quality Group D Combination Quality Classification Quality Class 4 is used to classify safety-related SSCs havinq different primary quality Class designations that do not fall within the specific definitions of Quality Class Groups 1, 2, and 3 for pressure-retaining components. Some examples are seismic Category I safety-related Structures: Class IE safety-related electrical equipment: and safety related materials and components not within the pressure boundary of a system as defined in NRC Regulatory Guide 1.26, Quality Group Classificationsand Standardsfor Water-,

Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants.

Components and structures with quality group classifications SCl, SC2, and SC3 and Combination Class Quality Class 4 (QC 4) are within the scope of license renewal for (a)(1).

South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 6 of 37 Table 2.3.3-1 Table 2.3.3-1 Fuel Handling System I Component Type I Intended Function

Blank Flange Pressure Boundary Closure Bolting Pressure Boundary Crane Structural Support Elevator Structural Support iFilter Leakage Boundary (spatial)

Fuel Handling Equipment Structural Support Fuel Storage Racks Structural Support Load Test Fixture Structural Support Piping Pressure Boundary Structural Support PumP Leakage Boundary (spatial)

Tank Leakaqe Boundary (spatial)

Valve Structural Integrity (attached)

S....

........... . . .

Leakage Boundary (spatial)

South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 7 of 37 Table 2.3.3-8 Table 2.3.3-8 PrimaryProcess Sampling System I Component Type I Intended Function IU * -vk,*** MDA CC C'

  • C 1\ 1 *
  • Ab * * ;1 VO~L LAt, idi IVI k PCJOI C3.1dI PiUj LvdarIcl DQUIUd",I y kL~p,',,,

Indica-to-r Leakage Boundary (s asial)

Piping Leakage Boundary (spatial)

Pressure Boundary StructuralInt egrity (attached)

South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 8 of 37 Section 2.3.3-20 2.3.3-20 Standby Diesel Generator and Auxiliaries

System Description

The purpose of the standby diesel generator system is to provide onsite standby electrical power for Class 1 E loads in the event that the offsite power sources become unavailable.

The standby diesel generator system contains several subsystems. These include the diesel generator cooling water system, diesel generator starting system, diesel generator lubrication system, diesel generator combustion air intake and exhaust system.

Diesel Generator Cooling Water System The purpose of the diesel generator cooling water system is to circulate sufficient quantities of cooling water to dissipate heat given off by the air coolers, governor oil and lube oil cooler, and engine water jackets, under full load conditions.

The system consists of engine driven jacket water pumps, electric jacket water pumps, jacket water heat exchanger, lube oil heat exchangers, governor oil heat exchanger, heaters, associated piping and valves.

Diesel Generator Starting System The purpose of the diesel generator starting system is to start the diesel engine using compressed air. Each diesel generator is provided with two starting air systems.

The diesel starting system consists of aiF d~yers, air accumulators, associated piping and valves.

South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 9 of 37 Table 2.3.3-20 Table 2.3.3-20 Standby Diesel Generatorand Auxiliaries Systems Component Type Intended Function

'Closure Bolting Leakage Boundary (spatial)

Pressure Boundary Structural .ntegrity (attached)

Structurl,* ,,lne-mtv (ataced Expansion Joint Pressure Boundary South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 10 of 37 Table 2.3.3-27 Table 2.3.3-27 Miscellaneous Systems In scope ONLY based on Criterion 10 CFR 54.4(a)(2)

Component Type Intended Function Closure Bolting Leakage Boundary (spatial)

Structural Integrity(attached)

Demineralizer Leakage Boundary (spatial)

Filter Leakage Boundary (spatial)

South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 11 of 37 Section 2.3.4.5 2.3.4.5 Steam Generator Blowdown System License Renewal Boundary Drawings The license renewal boundary drawings for the steam generator blowdown system are listed below:

LR-STP-AF-5S 141 F00024-1 LR-STP-FW-5S1 39F00063#1 LR-STP-PS-9Z329Z00047#1 LR-STP-SB-5S209F05057#1 LR-STP-SB-5S209F20001#1 LR-STP-SB-5S209F20002#1 LR-STP-AF-5S142F00024-1 LR-STP-SB-7S209F20003#1 LR-STP-FW-5S 139F00063#2 LR-STP-PS-9Z329Z00047#2 LR-STP-SB-5S209F05057#2 LR-STP-SB-5S209F20001 #2 LR-STP-SB-5S209F20002#2 LR-STP-SB-7S209F20003#2 South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 12 of 37 Table 2.3.4-5 Component Type ]

Table 2.3.4 Steam GeneratorBlowdown System Intended Function Closure Bolting Leakage Boundary (spatial)

Pressure Boundary

!Structural Integrity (attached)

Demineralizer L*eakaqe Boundarv (spatial)

F low Element Leakage Boundary (spatial)

... Integrity (attached) tStructural South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 13 of 37 Table 3.1.2-2 Table 3.1.2-2 Reactor Vessel, Internals, and Reactor Coolant System - Summary of Aging Management Evaluation - Reactor Coolant System Component Intended Material Environment Aging Effect 1.Aging Management NUREG- Table I Notes Type Function Requiring I Program 1801 Vol.

Management 2 Item Tank ;LBS, PB, Carbon Steel Plant IndoorAir Loss of material External Surfaces V.C-1 3.2.1.31 B SIA (Ext) Monitoring Program (B2.1.20) . ....

Tank LBS, SIA 'Stainless Borated Water None 'None IV.E-3 3.1.1.86 C ISteel Leakage_(Ext) i i Ta nk LBS, SIA Stainless Treated Borated Loss of material ;Water Chemistry V.D1-30 3.2.1.49 E, 2

!Steel Water (Int) ((B2.1.2) and One-Time Inspection (B2.1.16)

Tank LBS, SIA SStainless-- Treated Borated Cracking Water Chemistry iV.D1-31 3.2.1.48 Steel Water (Int) (B2.1.2) and One-Time Inspection (B2.1.16)

Tubing :LBS, PB, Stainless Borated Water None None IV.E-3 3.1.1.86 A SIA Steel Leakage_(Ext)_... L ........

South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 14 of 37 Section 3.3.2.1.1 3.3.2.1.1 Fuel Handling System Environment The fuel handling system components are exposed to the following environments:

  • Borated Water Leakage
  • Demineralized Water
  • Plant Indoor Air

Enclosure 2 NOC-AE-1 1002737 Page 15 of 37 Section 3.3.2.1.19 3.3.2.1.19 Chemical and Volume Control System Materials The materials of construction for the chemical and volume control system component types are:

  • Insulation Fiberglass
  • Stainless Steel
  • Stainless Steel Cast Austenitic

Enclosure 2 NOC-AE-1 1002737 Page 16 of 37 Section 3.3.2.1.27 3.3.2.1.27 Miscellaneous Systems In-Scope ONLY based on Criterion 10 CFR 54.4(a)(2)

Materials The materials of construction for the miscellaneous systems in scope ONLY based on Criterion 10 CFR 54.4(a)(2) component types are:

  • Glass
  • Nickel-Alloys
  • Stainless Steel
  • Stainless Steel Cast Austenitic Environment The miscellaneous systems in scope ONLY based on Criterion 10 CFR 54.4(a)(2) component types are exposed to the following environments:
  • Atmosphere/ Weather
  • Borated Water Leakage
  • Buried
  • Closed-Cycle Cooling Water
  • Demineralized Water
  • Dry Gas
  • Plant Indoor Air
  • Potable Water

Enclosure 2 NOC-AE-1 1002737 Page 17 of 37

  • Treated Borated Water Aging Effects Requiring Management The following miscellaneous systems in-scope ONLY based on Criterion 10 CFR 54.4(a)(2) aging effects require management:
  • Cracking
  • Loss of material
  • Loss of preload
  • Bolting Integrity (B2.1.7)
  • Buried Piping and Tanks Inspection (B2.1.18)
  • Closed-Cycle Cooling Water System (B2.1.10)
  • External Surfaces Monitoring Program (B2.1.20)
  • Flow-Accelerated Corrosion (B2.1.6)
  • Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B2.1.22)
  • One-Time Inspection (B2.1.16)
  • Open-Cycle Cooling Water System (B2.1.9)
  • Selective Leaching of Aluminum Bronze (B2.1.37)
  • Selective Leaching of Materials (B2.1.17)
  • Water Chemistry (B2.1.2)

South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 18 of 37 Table 3.3.2-1 Table 3.3.2-1 Auxiliary Systems - Summarv.of Aaina Manaaement Evaluation- Fuel HandlinaSvstem Component Type Intended IMaterial

______

Function

___j IRequiring Environment

______

Aging Effect IAging Management Management Program NUREG-1801 Vol.

  • itemF_____

2_____

Table I Item Notes Elevator Is.S Stainless Treated Borated Loss of material Water Chemistry VII.A2-1 3.3.1.91 E, 2 Steel Water (Ext) ((B2.1.2) and One-Time Inspection (B2.1.16) 3S jStainless Dernineralized Loss of material IWater Chemistry VIII.E-29 3.4.1.16 C Steel Water (Int) i(B2.1.2) and One-Time

. IInnoetion (B? 1 161 I -- I Filter 3S Stainless Plant Indoor Air None !None VII.J-15 3.3.1.94 Steel (Ext)

Fuel Handling Is 3_ -1 Car bo IPlant Indoor Air Loss of material !External Surfaces V11.l-8 3.3.1.58 Equip SSteel (Ext) Monitoring Program

..........

.......... I ___ (B2.1.20) __! . .

Piping PB eStainlessTreated Borated FLoss of materrial ,Water Chemistry 'VII.A2-1 3.3.1.91 E, 2 Steel Water (Int) ((B2.1.2)and One-Time Inspection (B2.1.16)

PUMP LBS Stainless Dernineralized Loss-ofmate rial !Water Chemistry VIII.E-29 3.4.1.16 A i

Steel ;Water (Int) (B2.1.2) and One-Time i

!Purno Inspection (B2.1.16) ,

LBS . Stainless .Plant Indoor Air INone None VII.J-15 3.3.1.94 A Steel (Ext)

ITank LBS Stainless *Demineralized Loss of materrial Water Chemistry VIII.E-29 3.4-. 1.116 Steel Water (Int) (B2.1.2) and One-Time Inspection (B2.1.16)

'Tank LBS Stainless ,Plant Indoor Air None None VII J-15 3.3.1.94 'A iSteel (Ext)

Valve LBS 'Stainless Demineralized Loss of materrial Water Chemistry ýVIII.E-29 3.4.1.16 IA iLBS Steel Water (Int) (B2.1.2) and One-Time Inspection (B2.1.16) lValve Stainless Plant Indoor Air None None ýVII.J.15 3.3.1.94 iA Steel (Ext)

South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 19 of 37 Valve SIA Stainless Borated Water -None None Ivii.J-16 13.3.1.99 [A;

.[Leakage(Ext) .j_

South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 20 of 37 Table 3.3.2-7 Table 3.3.2-7 Auxiliary Systems - Summary of Aging Management Evaluation - CompressedAir System Component Type Intended Material Environment Aging Effect Aging Management NUREG- Table I Notes Function Requiring Program 1801 Vol. Item Management 2 Item Valve PB, SIA  !Copper Alloy ýPlant Indoor Air ILoss of material IInspection of Internal VII.G-9 3.3.1.28 E i(Int) Surfaces in

'Miscellaneous Piping and Ducting Components (B2.1.22)

Valve P-BB ... .. Copper Alloy Plant Indoor Air Loss of material Selective Leaching of None None G,3

(>15% Zinc) (Int) 'Materials (R2 1171 S- .--- - - - - ________ 4- -~

Valve "PB Copper Alloy Plant Indoor Air None 1None VIII 1-2 3.4.1.41 A Valve PB, SIA (> 15% Zinc) (Ext)

+

Stainless Plant Indoor ,Air None None JVII.J-15 3.3.1.94 A

!

Steel (Ext) . . .

South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 21 of 37 Table 3.3.2-8 Table 3.3.2-8 Auxiliary Systems - Summary of Aging Management Evaluation - PrimaryProcess Sampling System Component Type Intended Function Material

_________________Management Environment

[ Aging Effect Requiring Aging Management Program NUREG-1801 Vol.

2 Item Table I Item

_____

Notes

____

Heat LBS Carbon Steel Plant Indoor Air Loss of material External Surfaces ;VII.l-8 '3.3.1.58 iB Exchanger (Ext) Monitoring Program (PASS Spare (B2.1.20)

Sample)

Indicator LBS Stainless Borated Water None None VlI.J-16 3.3.1.99 A Steel .Leaka.. e (.E xt.) ... ..... .... ... .... . ..... .

iIndicator LBS Stainless Treated Borated Loss of material 'Water Chemistry i..VII.E1-17 .... ...3.3.1.91

. .... ......... ........ .

Steel .Water (Int) (12.1.2) and One-Time

. .............

'Ilnspection (B2.1.16) EA Piping :LBS, PB, *Stainless , Borated Water None None -VII.J-16 3319 S!A Steel Leakage (Ext)

South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 22 of 37 Table 3.3.2-19 Table 3.3.2-19 Auxiliary Systems - Summary of Aging Management Evaluation - Chemical and Volume Control System Component Type Intended Material Environment Aging Effect Aging management NUREG- Table I Notes Function Requiring Program 1801 Vol. Item

_ Management 2 Item Valve LBS Stainless Steel lZinc Acetate Loss of material Water Chemistry None 'None G

ý(Int) (B2.1.2) and One-Time Inspection (B2.1.16)

Valve LBS Stainless Steel Borated Water None None VII.J-16 :3.3.1.99 A Cast Austenitic ;Leakage (ext) ..........

Valive LBS Stainless Steel Treated Cracking Water Chemr-istn.. VII.E1-20 13.3.1.90 ýE Cast Austenitic Borated Water (B2.1.2) and One-Time (Int) Inspection (B2.1.16)

South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 23 of 37 Table 3.3.2-20 Table 3.3.2-20 Auxiliary Systems - Summary of Aging Management Evaluation - Standby Diesel Generatorand Auxiliaries Component Intended Material Environment Aging Effect Aging Management NUREG- Table 1.Item Notes Type Function Requiring Program 1801 Vol.

Management. 2 Item

,Closure Bolting; LBS, PB, Stainless Plant Indoor Air Loss of preload Bolting Integrity (B2.1.7) None None iH, 1 i ....

. . . ...... . S...' .................. e .. . .. . .. . ... .. ....... .... . . . .. ..............

.... ........ .. ......................

.t ......

.*

....

DyrSIA Stai4ee ~ Gas-(k4t) Non one3.A9 '

D ~~SIA Sanes Pla;nt IndoorAir_Nne NQA P_ V!l41-5 3.3.4.4 'A

..te el..

S... . ... . . . . . . . . .. . . .. . . . . . . . . . .. . . . .

Expansion PB :Carbon Steel Closed Cycle Loss of material Closed-Cycle Cooling VII.H2-23 3.3.1.47 B Joint Cooling Water Water System (B2.1.10)

( Int ) .. ..... .........

.. .. . .. .. .......

South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 24 of 37 Table 3.3.2-22 Table 3.3.2-22 Auxiliary Systems - Summary of Agqinq Management Evaluation - Liquid Waste ProcessingSystem Component Intended Material Environment Aging Effect Aging Management NUREG- Table I Item Notes Ty _ _ Function Requiring Program 1801 Vol.

Management 2 Item Piping LBS, SIA Stainless Raw Water (Int) Loss of material Inspection of Internal IVII.C1-15 3.3.1.79 E, 3 Steel Surfaces in iMiscellaneous Piping land Ducting

Components (B2.1.22) _

LBS Stainless Secondary Water Loss of material "Water Chemistry iVIII.E-29 3.4.1.16 _A Steel (Int) ,(B2.1.2) and One-Time

'Inspection (B2.1.16) i

'None G, 2 Piping LBS Stainless Sodium Hydroxide Loss of material Water Chemistry None Steel (Int) (B2.1.2) and One-Time

'!nspection (B2_.!.16)

Pump iBSSIA 'Stainless Plant IndoorFAir[*None- None ,VII.J-15 3.3.1.94 A Steel (Ext)Q _ _....

.

ýPump 1BS, SIA !Stainless Raw Water (Int) rl-oss-ofmateriaI Inspection of InternaI .V.I.C1 -15 3.3.1.79 E, 3

'Steel 'Surfaces in

'Miscellaneous Piping and Ducting

!Components(1B2.1 .22)

Pump LBS Stainless Secondary Water Loss of material water Chemistry VIII.E- .29 13.4.1.16 Steel (Int)  !(B2.1.2) and One-Time Inspection (B2.l.116)

South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 25 of 37 Table 3.3.2-27 Table 3.3.2-27 Auxiliary Systems - Summary of Aging Management Evaluation - Miscellaneous Systems in scope ONLY for Criterion 10 CFR 54.4(a)(2)

I Type Function Component Intended Material 1Requiring Environment Management Aging Effect Program Aging Management 1801 Vol.

2 Item NUREG- Table I Item Notes Closure Bolting LBS, SIA Stainless ;Plant Indoor Air 'Loss of preload Bolting Integrity (B2.1.7) None None 1H, 1 Steel (Ext)

Demineralizer LBS }Stainless Borated Water None None VII.J-16 :3.31.99 A

Steel Leakage (Ext)

Demineralizer LBS Stainless Demineralized Loss of material 'Water Chemistry VIII.E-29 .3.4.1.16 A Steel Water (Int) (B2.1.2) and One-Time LBS Inspection (B2.1.16) .. ... ...

. .. . .. .

Demineralizer Stainless Plant Indoor Air None None VII.J-15 .3.3.1.94 ýA LBS Steel Treated Borated ... ...........

...... ...

Demineralizer Stainless Cracking Water Chemistry Vii.Ei-20 3.3.1.90 EA4 Steel .Water (Int) (B2.1.2) and One-Time Inspection (B2.1.16) ... . ........ ........ ........ A.....

VII.J-15 .3.3.1.94 'A Filter LBS Stainless '!Plant Indoor Air None None Steel............ i(Ext)

Pump LBS Stainless Plant Indoor Air :None None VII.J-15 '3.3.1.94 A

  • Steel (Ext)

Pump LBS Stainless Raw Water (Int) Loss of material Inspection of Internal VII.C1-15 :3.3.1.79 E, 4 Steel .Surfaces in

.Miscellaneous Piping

and Ducting

.Components (B2.1 .22)

Pump _LBS Stainless .Sodium Hydroxide .Loss of material .Water Chemistry None None G, 2 Steel i(Int) (B2.1.2) and One-Time Inspection (B2. .16)

South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 26 of 37 Valve LBS, SIA Stainless 'Treated Borated Loss of material ýWater Chemistry VII.El-17 3.3.1.91 :E, 7 Steel Water (Int) (B2.1.2) and One-Time Inspection (132.1.16)

Valve LBS  :.Stainless 'Borated Water None 'None VII.J-16 3.3.1.99 A

.Steel Cast Leaka-ge (Ext)

Austenitic 'Loss of material Valve LBS Stainless Demineralized lWater Chemistry VIII.E-29 .3.4.1.16 'A Steel Cast ;Water (Int) ,(B2.1.2) and One-Time Austenitic !nspection (B2.1.16) . ....... . ...

. ; . . . .. ... . . . .... i.... ...............

Valve LBS Stainless Plant Indoor Air None None VII.J-15 :3.3.1.94 A

.Steel Cast (Ext)

.Austenitic Valve LBS Stainless Raw Water (Int) Loss of material Inspection of Internal VII.C1-15 3.3.1.79 IE 4

.Steel Cast Surfaces in Austenitic :Miscellaneous Piping

.and Ducting

.Components (B2.1.22) ra n......

....

!Cracking ..

Valve LBS Stainless .Treated Borated ,Water Chemistry VII.E1-20 :3.3.1.90 E, 4 Steel Cast Water (Int) ((B2.1.2)and One-Time Austenitic Inspection (B2.1.16)

South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 27 of 37 Table 3.4.2-1 TTohW U S. . OaaI 0

.LcI1 rA n~54Qf D^VO ruan rIJsn n~~ nrhn

.iJII .,.a QJ.l~lofn -Q n Q.LIl~el ,onýAfit f., Ai, ;n FVl" h no-nm 0 nICf~~ .,otaoen-R IcILIIII i - 0 nOaoQenn AA-;-l f-L #ll Component Intended Material Environment Aging Effect [ Aging Management NUREG- Table I Item Notes Type .Function Requiring Program 1801 Vol.

__________________ JManagement 2 Item ____ ___

'Closure Bolting LBS, PB, Carbon Steel Plant Indoor Air Loss of preload Bolting Integrity (B2.1.7) VIII.H-5 3.4.1.22 B SA P.BB Loss of material Lubricatingq Oil Analysis VIII.A-9 13.4.1.1 9 VFiIter SStainless Lubricating Oil Steel I(Int) (B2.1.23) and One-Time

. .. . . .. ... .. . ... . .. .. . .!. .. . ........... . ... ..... ... ..........

Inspection (B2.1.16)

Filter Stainless Plant Indoor Air None None VIII. 1-10 3.4.1.41 IPB Steel  !(Ext)

Filter Carbon Steel Lubricating Oil TLoss ofaerial Lubric-ating-oil-Analysis VIII.A-14 3.4.1.07

'(Int) (B2.1.23) and One-Time InsPeiction(B2.1.16)

South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 28 of 37 Table 3.4.2-5 Table 3.4.2-5 Steam and Power Conversion System - Summary of Aging ManagementEvaluation - Steam GeneratorBlowdown System Component Intended Material Environment Aging Effect Aging Management NUREG- Table I Item Notes Type Function Requiring Program 1801 Vol.

Management 2 Item Closure Bolting ;LBS, PB, Stainless Plant Indoor Air Loss of preload Bolting Integrity (B2.1.7) None None H, 1 SIA Steel (Ext)

Demineralizer 'LBS Stainless Plant Indoor Air None None VIII.l-10 _3.4.1.41 A Steel Demineralizer 'LBS Stainless Secondary Water Loss of material Water Chemistry VIII.F-23 3.4.1.16 Steel (Int) j(B2.1.2) and One-Time Inspection (B2.1.16) A Flow Element .LBS' SIA Stainless Plant Indoor Air None None VIII.I-10 3.4.1.41 Steel _______________________________________

- - _____________ ___________________

A(E__)___ _.......... . .. l Ji

.LBS, SIAiStainless Secondary Water *Loss of material Water Chemistry VIII.F-23 13.4.1.16 IA ISteel Cast (Int) (B2.1.2) and One-Time ý1 It Austenitic Inspection (B12.1.6)

LBS Carbon Steel Plant Indoor Air iLoss of material External Surfaces VIII.H-7 3.4.1.28 -B Strainer (Ext) Monitoring Program

  • I(B2.1.20)

LBS Carbon Steel Secondary Water Losof material Water Chemistry IVIII.F-25 F' 1.....4 A St raine*r. (Int) (B2.1.2) and One-Time I

ýSt -air 1-BS, SIA Stainless ISteel Plant Indoor Air (Ext)

None None 7 lnspection (g2.1.16)

None

,I VIII.l-10 3.4.1.41 A EalvSecondanA W es S e-co6n d'ary Water- Lo 'of_fmaterial f Water Chemistry te -Lo6s~s 'VIII.F-23 3.4.1.16 ic6ý,ý-A--!,--a--ness Steel I(Int) '(B2.1.2) and One-Time

- - - iInspection (B2.1.16) ___

,Valve LBS Stainless Plant Indoor Air 1None None iVlll.1-10 '3.4.1.41

- Steel Cast (Ext) I -

___ . . . Austenitic . ................. ........--- - -.... ...

South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 29 of 37 Vialive- LBs Stainless Secondary Water Loss of Material Water Chemistry iVIII.F-23 3.4.1.16 A Steel Cast I(In (132.1.2) and One-Time

!Austenitic nspection I-_______ (132.1.16) __

South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 30 of 37 B2.1.32 Structures Monitoring Program Program Description The Structures Monitoring Program (SMP) monitors the condition of structures and structural supports that are within the scope of license renewal to manage the following aging effects:

  • 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 and permeability, loss of strength
  • Loss of material
  • Loss of material (spalling, scaling) and cracking
  • Loss of mechanical function
  • Loss of sealing
  • Reduction of concrete anchor capacity The SMP implements the requirements of 10 CFR 50.65, The Maintenance Rule, consistent with guidance of NUMARC 93-01, Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 2 and Regulatory Guide 1.160, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 2.

The SMP provides inspection guidelines and walk-down checklists for structural steel, roof systems, reinforced concrete, masonry walls and metal siding. Electrical duct banks and manholes, valve pits, access vaults, and structural supports are inspected as part of the SMP.

STP is committed to Regulatory Guide 1.127 and the scope of the SMP includes water-control structures. The scope of SMP also includes masonry walls. The SMP monitors settlement for each major structure utilizing geotechnical monitoring techniques, with benchmarks installed on major structures to allow for monitoring of heave and settlement movements during plant operation. The SMP will monitor groundwater, at least two samples every five years for pH, excessive chlorides and sulfates. STP does not take credit for any coatings to manage the aging of structural components, and coating degradation is used only as an indicator of the condition of underlying material.

NUREG-1801 Consistency The Structures Monitoring Program is an existing program that, following enhancement, will be consistent with NUREG-1 801,Section XI.S6, Structures Monitoring Program.

Exceptions to NUREG-1801 None South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 31 of 37 Enhancements Prior to the period of extended operation, the following enhancements will be implemented in the following program elements:

Preventive Actions (Element 2)

For ASTM A325, ASTM F1 852, and/or ASTM A490 structural bolts, plant procedures will be revised to specify the preventive actions for storage, protection and lubricants recommended in Section 2 of Research Council for Structural Connections publication "Specification for Structural Joints Using ASTM A325 or A490 Bolts."

ParametersMonitored or Inspected (Element 3)

Groundwater samples will be taken at multiple locations around the site every three months for at least 24 consecutive months. The samples will analyze for pH, sulfates, and chlorides. This sampling plan will begin no later than September 2012.

Procedures will be enhanced to specify inspections of seismic gaps, caulking and sealants, duct banks and manholes, valve pits and access vaults, doors, electrical conduits, raceways, cable trays, electrical cabinets/enclosures and associated anchorage.

Procedures will be enhanced to monitor at least two groundwater samples every five years for pH, sulfates, and chloride concentrations. This sampling will follow the initial 24 month monitoring activity.

Procedures will be enhanced to require the performance of a periodic visual inspection of the spent fuel pool and transfer canal tell-tale drain lines for blockage every five years. The first inspection will be performed within the 5 years before entering the period of extended operation.

Detection of Aging Effects (Element 4)

Procedures will be enhanced to specify that the inspection frequency for structures within the scope of license renewal will be in accordance with ACI 349.3R, Table 6.1, which specifies:

" For below-grade structures and structures in controlled interior environment (except inside primary containment), all accessible areas of both units will be inspected every 10 years.

" For all other structures (including inside primary containment), all accessible areas of both units will be inspected every 5 years.

Procedures will be enhanced to specify inspector qualifications in accordance with ACI 349.3R-96.

Procedures will be enhanced to specify ACI 349.3R-96 and ACI 201.1 R-68 as the bases for defining quantitative acceptance criteria.

Procedures will be enhanced to perform opportunistic inspections of exposed portions of the below-grade concrete, when excavated for any reason.

South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 32 of 37 Procedures will be enhanced to require an evaluation should qround water be determined to be acgqressive or inspections of accessible concrete structural elements identify degradation. The evaluation will be performed to determine the appropriate actions necessary to assure that the affected structures will continue to perform their intended function. These actions may include increased visual inspections or other examination techniques.

Operating Experience The STP SMP began with a baseline walkdown inspection in 1997. The examination included a careful walkdown and visual examination of accessible areas in the scoped structures. All the structures were found to be acceptable with the exception of the Unit 1 fuel handling building, room 011, which had a significant water leak resulting in corrosion of structural steel columns.

The columns were recoated in 1997. The area of the fuel handling building was classified as "acceptable with deficiencies" because the structure continued to function as designed, but was subject to periodic inspections to verify water level was being adequately controlled and structural coatings had been reapplied to control corrosion.

Subsequent Maintenance Rule structures inspections in 2002-03 concluded that all Maintenance Rule scoped structures were meeting their established (a)(2) performance criteria.

The only aging related condition report noted an inundation problem in Unit 2 similar to the one that was found in the Unit I fuel handling building, room 011, during the baseline inspections.

The problem persisted through 2004; and in 2005 gravity drains were installed similar to the ones installed in Unit 1.

At STP, all areas of degradation identified during the structures monitoring inspections are documented in condition reports and work orders issued prior to any loss of intended functions or invalidation of licensing basis. The STP Structures Monitoring Program Bernhoft, Sherry

[Sherry. Bernhoft@luminant.com]operating experience information provides objective evidence to support the conclusion that the effects of aging will be managed adequately so that the intended functions will be maintained during the period of extended operation.

Conclusion The continued implementation of the Structures Monitoring Program provides reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 33 of 37 B3 TLAA SUPPORT ACTIVITIES Ba1 METAL FATIGUE OF REACTOR COOLANT PRESSURE BOUNDARY Program Description The Metal Fatigue of Reactor Coolant Pressure Boundary program manages fatigue cracking caused by anticipated cyclic strains in metal components of the RCPB. The program ensures that actual plant experience remains bounded by the transients assumed in the design calculations, or that appropriate corrective actions maintain the design and licensing basis by other acceptable means.

The Metal Fatigue of Reactor Coolant Pressure Boundary program consists of cycle counting activities. The program will be enhanced to monitor and trend fatigue usage at selected locations in the reactor coolant pressure boundary. The program will be enhanced to include additional transients and locations identified by the evaluation of ASME Section III fatigue analyses, locations necessary to ensure accurate calculations of fatigue, and the NUREG/CR-6260 locations for a newer-vintage Westinghouse Plant. The supporting environmental life correction factor calculations were performed with NUREG/CR-6583 for carbon and low alloy steels and with NUREG/CR-5704 for austenitic stainless steels.

The Metal Fatigue of Reactor Coolant Pressure Boundary program tracks the occurrences of selected transients and will be enhanced to monitor the cumulative usage factors (CUFs) at selected locations using one of the following methods:

1) The Cycle Counting (CC) method does not periodically calculate CUF; however, transient event cycles affecting the location (e.g. plant heatup and plant cooldown) are counted to ensure that the numbers of transient events assumed by the design calculations are not exceeded.
2) The Cycle Based Fatigue (CBF) management method utilizes the CC results and stress intensity ranges generated with the ASME III methods that use six stress-tensors to perform periodic CUF calculations for a selected location. The fatigue accumulation is tracked to determine approach to the ASME allowable fatigue limit of 1.0.

The Metal Fatigue of Reactor Coolant Pressure Boundary program continuously monitors plant data, and maintains a record of the data collected. The collected data are analyzed to identify operational transients and events, calculate usage factors for selected monitored locations, and compare the calculated usage factors to allowable limits. Periodic review of the calculations ensures that usage factors will not exceed the allowable value of 1.0 without an appropriate evaluation and any further necessary actions. If a cycle count or CUF value increases to a program action limit, corrective actions will be initiated to evaluate the design limits and determine appropriate specific corrective actions. Action limits permit completion of corrective actions before an assumed number of events in a fatigue analysis is exceeded.

South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 34 of 37 NUREG-1801 Consistency The Metal Fatigue of Reactor Coolant Pressure Boundary program is an existing program that, following enhancement, will be consistent with NUREG-1801,Section X.M1, Metal Fatigue of Reactor Coolant Pressure Boundary.

Exceptions to NUREG-1 801 None Enhancements Prior to the period of extended operation, the following enhancements will be implemented in the following program elements:

Scope of Program(Element 1) and Monitoring and Trending (Element 5)

Procedures will be enhanced to include locations identified by the evaluation of ASME Section III fatigue analyses, locations necessary to ensure accurate calculations of fatigue, and the NUREG/CR-6260 locations for a newer-vintage Westinghouse Plant.

Scope of the Program (Element 1), and ParametersMonitored or Inspected (Element 3)

Procedures will be enhanced to include additional transients that contribute significantly to fatigue usage identified by the evaluation of ASME Section III fatigue analyses.

Scope of the Program (Element 1)

Procedures will be enhanced to ensure the fatigue crack growth analyses, which support the leak-before-break analyses and ASME Section Xl evaluations, remain valid by counting the transients used in the analyses.

Detection of Aging Effects (Element4)

The procedures will be enhanced to 1) include additional transients necessary to ensure accurate calculations of fatigue, 2) fatigue usage monitoring at specified locations, and 3) specify the frequency and process of periodic reviews of the results of the monitored cycle count and CUF data at least once per fuel cycle. This review will compare the results against the corrective action limits to determine any approach to action limits and any necessary revisions to the fatigue analyses will be included in the corrective actions.

PreventiveActions (Element 2) and Acceptance Criteria(Element 6)

The procedures will be enhanced to include additional cycle count and fatigue usage action limits, which will invoke appropriate corrective actions if a component approaches a cycle count action limit or a fatigue usage action limit. Action limits permit completion of corrective actions before the design limits are exceeded. The acceptance criteria associated with the NUREG/CR-6260 sample locations for a newer vintage Westinghouse plant will account for environmental effects on fatigue.

South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 35 of 37 Cycle Count Action Limits:

Cycle count action limits are selected to initiate corrective action when the cycle count for any of the critical thermal or pressure transients is projected to reach the design limit within the next three fuel cycles.

CUF Action Limits:

CUF action limits require corrective action when the calculated CUF for any monitored location is projected to reach 1.0 within the next three fuel cycles.

Corrective Actions (Element 7)

Procedures will be enhanced to include appropriate corrective actions to be invoked if a component approaches a cycle count or CUE action limit.

If a cycle count action limit is reached, acceptable corrective actions include:

1) Review of fatigue usage calculations:

a) To identify the components and analyses affected by the transient in question.

b) To determine whether the transient in question contributes significantly to CUE.

c) To ensure that the analytical bases of tho leak boefor broak (L=BB)*

3 fatigue crack propagation analysis and of the high energy line break (HELB) locations are maintained.

d) To ensure that the analytical bases of a fatigue crack gFovh and stability analysis in support of relief from ASME Section X flaw removal.

2) Evaluation of remaining margins on CUF.
3) Review of fatigue crack growth and stability analyses support the leak before break exemptions and relief from the ASME Section Xl flaw removal or inspection requirements to ensure that the analytical bases remain valid. Re-analysis of a fatigue crack growth analysis must be consistent with or reconciled to the originally submitted analysis and receive the same level of regulatory review as the original analysis.
4) Redefinition of the specified number of cycles (e.g., by reducing specified numbers of cycles for other transients and using the margin to increase the allowed number of cycles for the transient that is approaching its specified number of cycles).
5) Redefinition of the transient to remove conservatism in the pressure and temperature ranges.

Since the counting action limits are based on a somewhat-arbitrary cycle count that does not accurately indicate approach to the CUE = 1.0 fatigue limit, these preliminary actions are designed to determine how close the approach is to the 1.0 limit, and from those South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 36 of 37 determinations, set new action limits. If the CUF has approached 1.0 then further actions described below for cumulative fatigue usage action limits may be invoked.

If a CUF action limit is reached acceptable corrective actions include:

1) Determine whether the scope of the management program must be enlarged to include additional affected reactor coolant pressure boundary locations. This determination will ensure that other locations do not approach design limits without an appropriate action.
2) Enhance fatigue managing to confirm continued conformance to the code limit.
3) Repair the component.
4) Replace the component. If a limiting component is replaced, assess the effect on locations monitored by the program. If a limiting component is replaced, resetting its cumulative fatigue usage factor to zero, a component which was previously bounded by the replaced component will become the limiting component and may need to be monitored.
5) Perform a more rigorous analysis of the component to demonstrate that the design code limit will not be exceeded.
6) Modify plant operating practices to reduce the fatigue usage accumulation rate.
7) Perform a flaw tolerance evaluation and impose component specific inspections, under ASME Section Xl Appendices A or C (or their successors), and obtain required approvals by the NRC.

Operating Experience The STP industry operating experience program reviews industry experience, including experience that may affect fatigue management, to ensure that applicable experience is evaluated and incorporated in plant analyses and procedures. Any necessary evaluations are conducted under the plant corrective action program.

The Metal Fatigue of Reactor Coolant Pressure Boundary program was implemented in response to industry experience that indicated that the design basis set of transients used for fatigue analyses of the reactor coolant pressure boundary did not include some significant transients, and therefore might not be limiting for components affected by them. Examples:

Thermal stratification of pressurizer surge line piping:

In response to NRC Bulletin 88-11, Westinghouse performed a plant-specific evaluation of STP pressurizer surge lines. The surge line stratification analysis was based on STP design transients. It was concluded that thermal stratification does not affect the integrity of the pressurizer surge lines. STP responses to NRC Bulletin 88-1 1 describe the inspections, analyses, and procedural revisions made to ensure that thermal stratification does not affect the integrity of the pressurizer surge lines. In addition, the responses noted that fatigue analyses were updated to ensure compliance with applicable codes and license commitments.

Thermal fatigue cracking in normally-isolated piping:

In 1988, as identified in NRC Bulletin 88-08, there were several instances of thermal fatigue cracking in normally stagnant lines attached to reactor coolant system (RCS) piping. This issue South Texas Project License Renewal Application Amendment 5

Enclosure 2 NOC-AE-1 1002737 Page 37 of 37 was addressed by utilities by conducting evaluations and monitoring to ensure that further leakage would not occur. STP performed a complete analysis of systems connected to the RCS. The review concluded that the potential for the described thermal conditions existed only in the normal charging, alternate charging, and auxiliary spray lines. However, these systems are separated and only hot water can leak through the charging and auxiliary spray lines, reducing the potential for thermal cycling.

Conclusion The continued implementation of the Metal Fatigue of Reactor Coolant Pressure Boundary program provides reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

South Texas Project License Renewal Application Amendment 5

Enclosure 3 NOC-AE-1 1002737 Enclosure 3 Revised Regulatory Commitments

Enclosure 3 NOC-AE-1 1002737 Page 1 of 2 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. These and other actions are proposed regulatory commitments. This list will be revised, as necessary, in subsequent amendments to reflect changes resulting from NRC questions and STPNOC responses. STPNOC will utilize the STP commitment tracking system to track regulatory commitments. The Condition Report (CR) number in the Implementation Schedule column of the table is for STPNOC tracking purposes and is not part of the amended LRA.

Table A4-1 License Renewal Commitments Item # Commitment LRA Implementation Section Schedule 25 Enhance the Structures Monitoring Program procedures to: B2.1.32 Prior to the period

  • specify inspections of seismic gaps, caulking and sealants, duct banks and of extended manholes, valve pits and access vaults, doors, electrical conduits, raceways, operation cable trays, electrical cabinets/enclosures and associated anchorage,

" monitor at least two groundwater samples every five years for pH, sulfates, and CR 10-23600-1 chloride concentrations,

" specify that the inspection frequency for structures within the scope of license renewal will be in accordance with ACI 349.3R, Table 6.1, which specifies:

o For below-grade structures and structures in controlled interior environment (except inside primary containment), all accessible areas of both units will be inspected every 10 years.

o For all other structures (including inside primary containment), all accessible areas of both units will be inspected every 5 years.

  • specify inspector qualifications in accordance with ACl 349.3R-96.
  • require the performance of a periodic visual inspection of the spent fuel pool and transfer canal tell-tale drain lines for blockage every five years. The first inspection will be performed within the 5 years before entering the prior of extended operation.

Enclosure 3 NOC-AE-1 1002737 Page 2 of 2 Table A4-1 License Renewal Commitments Item # Commitment LRA Implementation Section Schedule

  • specify the preventive actions for storage, protection and lubricants recommended in Section 2 of Research Council for Structural Connections publication "Specification for Structural Joints Using ASTM A325 or A490 Bolts" for ASTM A325, ASTM F1 852 and/or ASTM 490 bolts.
  • Procedures will be enhanced to perform opportunistic inspections of exposed portions of the below-grade concrete, when excavated for any reason.
  • Procedures will be enhanced to require an evaluation should ground water be determined to be aqqressive or inspections of accessible concrete structural elements identify degradation. The evaluation will be performed to determine the appropriate actions necessary to assure that the affected structures will continue to perform their intended function. These actions may include increased visual inspections or other examination techniques.

37 Groundwater samples will be taken at multiple locations around the site every three B2.1.32 September 2012 months for at least 24 consecutive months. The samples will analyze for pH, sulfates, and chlorides. This sampling plan will begin no later than September 2012. CR 11-20856-1 South Texas Project License Renewal Application Amendment 5

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