ML11234A045
| ML11234A045 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 08/09/2011 |
| From: | Powell G T South Texas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NOC-AE-11002702, TAC ME4936, TAC ME4937 | |
| Download: ML11234A045 (32) | |
Text
Nuclear Operating CompanySouth Texas Prolect Electric Generating Station P0. Box 289 Wadsworth. Txas 77483 --A/-Av--August 9, 2011NOC-AE-1 100270210CFR54STI: 32902449File: G25U. S. Nuclear Regulatory CommissionAttention: Document Control DeskOne White Flint North11555 Rockville PikeRockville, MD 20852-2746South Texas ProjectUnits 1 and 2Docket Nos. STN 50-498, STN 50-499Response to Request for Additional Information for the Review of theSouth Texas Project License Renewal Application (TAC Nos. ME4936 and ME4937)
Reference:
1. STPNOC Letter from G. T. Powell to NRC Document Control Desk, "LicenseRenewal Application," dated October 25, 2010 (NOC-AE-10002607) (ML103010257)2. NRC letter, "Request for Additional Information for South Texas Project, Units 1 and2 License Renewal Application -Scoping and Screening Balance of Plant,' datedJuly 12, 2011 (ML11166A239)By Reference 1, STP Nuclear Operating Company (STPNOC) submitted the License RenewalApplication (LRA) for South Texas Project (STP) Units 1 and 2. By Reference 2, the NRC staffrequested additional information for the review of the STP LRA. STPNOC's response to therequest for additional information is included in Enclosure 1 to this letter.There are no regulatory commitments in this letter.Should you have any questions regarding this letter, please contact either Arden Aldridge, STPLicense Renewal Project Lead, at (361) 972-8243 or Ken Taplett, STP License Renewal Projectregulatory point-of-contact, at (361) 972-8416.I declare under penalty of perjury that the foregoing is true and correct.Executed on Au,. q, 2oIIDCateG. T. PowellVice President,Technical Support & OversightKJT
Enclosure:
STPNOC Response to Request for Additional Information AC.35--'
NOC-AE-1 1002702Page 2cc:(paper copy)(electronic copy)Regional Administrator, Region IVU. S. Nuclear Regulatory Commission612 East Lamar Blvd, Suite 400Arlington, Texas 76011-4125Balwant K. SingalSenior Project ManagerU.S. Nuclear Regulatory CommissionOne White Flint North (MS 8B1)11555 Rockville PikeRockville, MD 20852Senior Resident InspectorU. S. Nuclear Regulatory CommissionP. 0. Box 289, Mail Code: MN116Wadsworth, TX 77483C. M. CanadyCity of AustinElectric Utility Department721 Barton Springs RoadAustin, TX 78704John W. DailyLicense Renewal Project Manager (Safety)U.S. Nuclear Regulatory CommissionOne White Flint North (MS 011-Fl)Washington, DC 20555-0001Tam TranLicense Renewal Project Manager(Environmental)U. S. Nuclear Regulatory CommissionOne White Flint North (MS O11F01)Washington, DC 20555-0001A. H. Gutterman, EsquireKathryn M. Sutton, EsquireMorgan, Lewis & Bockius, LLPJohn RaganCatherine CallawayJim von SuskilNRG South Texas LPEd AlarconKevin PolioRichard PenaCity Public ServicePeter NemethCrain Caton & James, P.C.C. MeleCity of AustinRichard A. RatliffAlice RogersTexas Department of State Health ServicesBalwant K. SingalJohn W. DailyTam TranU. S. Nuclear Regulatory Commission EnclosureNOC-AE-1 1002702Page 1 of 30STPNOC Response to Request for Additional InformationPlant Level Scoping ResultsRAI 2.2-1
Background:
The license renewal scoping criteria were described in License Renewal Application (LRA)Section 2.1. LRA Section 2.2, Table 2.2-1, "Scoping Results," provides the results of applyingthe license renewal scoping criteria to the systems, structures, and components.Issue:The following system, as described in the Updated Final Safety Analysis Report (UFSAR), couldnot be located in LRA Table 2.2-1.UFSAR Section System7.5.7 Emergency Response Facilities Data Emergency Response Facilities Data AcquisitionAcquisition and Display System (ERFDADS) and Display SystemRequest:The staff requests that the applicant provide the basis for excluding the "Emergency ResponseFacilities Data Acquisition and Display System" from Table 2.2-1.STPNOC ResponseThe Emergency Response Facilities Data Acquisition and Display System is within the scope oflicense renewal and is a subsystem of the Post Accident Monitoring System. The Post AccidentMonitoring System is shown on Table 2.2-1 as being within the scope of license renewal.Auxiliary Systems Requests for Additional InformationRAI 2.3-01
Background:
LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included in scope of license renewal. The staff confirms theinclusion of all components subject to aging management review (AMR) by reviewing the resultsof the screening of components within the license renewal boundary.
EnclosureNOC-AE-1 1002702Page 2 of 30Issue:Continuation Issue: For the drawing locations identified in the table below, the continuation ofpiping in scope for license renewal could not be found.LRA Section/Drawing Number & Location Continuation Piping/Drawing Number2.3.4.4 Demineralizer Water (Make-up) SystemLR-STP-DW-5S1999F05034#1 AND #2 2"DW1503WD9 / 2"DW2503WD9 continuing tocoordinates E-6 drawing 9B00143 coordinates D-4. Thecontinuation drawing (9B00143) could not befound in the information provided.LRA Section/Drawing Number & Location Continuation Piping/Drawing Number2.3.3.27 Miscellaneous Systems in scope ONLY for Criterion 10 CFR 54.4 (a)(2)LR-STP-NL-6S190F0009 coordinates H-2 2"NLOO38WN7 line continuation from drawing0F00015 (not provided).LR-STP-OC-6T249F00033#1 and #2 4"WL1 165WG7/4"WL2165WG7 continuationscoordinates G-3 from drawing 9F90001 (Liquid RadwasteSystem).LR-STP-PW-9M889B0148#1 and #2, under 2" line from drawing 9F5034."Demineralized Water P&ID"LR-STP-PW-9Q130F00013 coordinates F-4 1"PW1086WU9, 1"PW1087WU9,and F-7 1"PW1088WU9, 1"PW2086WU9,1 "PW2087WU9, 1 "PW2088WU9 continuing todrawing 9B0171.LR-STP-MD-6T1 69F00055#1 and #2 1 "MD1 235HC9/1 "MD2235HC9 lines fromcoordinates A-8 drawing 9F00024 (Main Steam Drain from AuxFPT).Request:The staff requests that the applicant provide sufficient information for the continuation issuesidentified above to permit the staff to review all portions of the systems within the license renewalboundary.STPNOC ResponseItem #1 -LR-STP-DW-5S1999F05034#1/#2, E-6 continuation:Boundary drawings LR-STP-DW-5S1999F05034#1 & #2 (E-6) for piping 2"DW1503WD9 &2"DW2503WD9 continue to isometric drawing 6M-06 B-0143 for showers, heaters, andsink details. Isometric drawing 6M-06 B-0143 was not used as a boundary drawing.Plumbing drawing 9M-88 B-0148 was used as the boundary drawing for in-scope showers,heaters, and sinks. The continuation from boundary drawings LR-STP-DW-5S1999F05034#1 & #2 (E-6) downstream of valves PDO091 goes to boundary drawing LR-STP-PW-9M889B0148#1 & #2. See approximate coordinate E-2 for valves PD-091.
EnclosureNOC-AE-1 1002702Page 3 of 30Item #2 -LR-STP-NL-6S190F00009, H-2 continuation issue:Various sections of buried piping were removed from the scope of license renewal followinga re-evaluation of buried piping in February, 2011. As a result of that review, boundarydrawing LR-STP-NL-6S190F00009 is no longer needed since the highlighted piping on thedrawing is no longer in-scope. Piping 2"NL0038WN7 and the continuation to drawingOF00015 are no longer in-scope.Item #3 -LR-STP-OC-6T249F00033#1 & #2, G-3 continuation:Piping 4"WL1 165WG7 & 4"WL2165WG7 continues from boundary drawings LR-STP-OC-6T249F00033#1 & 2 (G-3) to boundary drawings LR-STP-WL-7R309F90001#1 & #2 (D-1)as 10 CFR 54.4(a)(2) spatial interaction. Boundary drawing LR-STP-WL-7R309F90001#2correctly depicts the 4"WL2165WG7 piping and valves highlighted red with an spatialinteraction (SI) termination symbol shown. However, boundary drawing LR-STP-WL-7R309F90001#1 inadvertently omits the red highlighting but the SI termination symbol isshown. The piping and valves are in-scope and should be highlighted red.Boundary drawing LR-STP-WL-7R309F90001#1 (D-1) will be updated to highlight the4"WL1 165WG7 piping and valves red. The drawing will be consistent with boundary drawingLR-STP-WL-7R309F90001#2 (D-1).Item #4 -LR-STP-PW-9M889B0148#1 & #2 continuation:See response to Item #1. This is the same piping and continuation.Item #5 -LR-STP-PW-9Q130F00013, F-4 & F-7 continuation:The continuation drawing from boundary drawing LR-STP-PW-9Q130F00013 (F-4 & F-7) isa plumbing detail drawing (9D-06 B-01 71) that is considered to be below the level of detailfor a boundary drawing. The piping to the shower/eye wash stations is in-scope as 10 CFR54.4 (a)(2) spatial interaction in the diesel generator buildings but is not detailed on aboundary drawing.Item #6 -LR-STP-MD-6T169F00055#1 & #2, A-8 continuation:Boundary drawings LR-STP-MD-6T169F00055#1 & #2 (A-8) continuation for piping1"MD1235HC9 & 1"MD2235HC9 lead to boundary drawing LR-STP-AF-5S141F00024-1(H-8) which leads to LR-STP-MS-5S141F00024-2 (D-8). Piping 1"MD1235HC9 &1"MD2235HC9 is in-scope as 10 CFR 54.4(a)(2) spatial interaction and structural integrityattached and is correctly shown on boundary drawings LR-STP-MD-6T169F00055#1 & #2and LR-STP-MS-5S141 F00024-2.Section 2.3.3.3 Cranes and HoistsRAI 2.3.3.3-01LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included in the scope of license renewal. The staff confirmsthe inclusion of all components subject to AMR by reviewing the results of the screening ofcomponents within the license renewal boundary.
EnclosureNOC-AE-1 1002702Page 4 of 30UFSAR Section 3.8.4.1.1, Mechanical-Electrical Auxiliaries Building (MEAB), states that the 7.5-ton overhead bridge crane necessary for handling radioactive solid waste is not within the scopeof license renewal. This crane is located in the MEAB which is in scope for Title 10 of the Codeof Federal Regulations (10 CFR) 54.4(a)(1), 10 CFR 54.4(a)(2) and 10 CFR 54.4(a)(3).The staff requests the applicant provide the basis for not including the MEAB 7.5-ton overheadbridge crane within the scope of license renewal.STPNOC ResponseCranes and hoists are included within the scope of license renewal if they carry heavy loads oversafety-related components or over irradiated fuel in the reactor vessel or spent fuel pool. Thesolid waste processing 7-1/2 ton gantry cranes (7R321XCM101A and 7R322XCM201A) are inan area of the MEAB that does not contain safety-related components or irradiated fuel in theload path of these cranes. Further, as shown in the Master Equipment Database, these cranesare Quality Class 9, which indicates that they are not Seismic Il/I components. Therefore, thesolid waste processing 7-1/2 ton gantry cranes are not within the scope of license renewal.Section 2.3.3.4 Essential Cooling Water and ECW Screen WashRAI 2.3.3.4-01LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included in scope of license renewal. The staff confirms theinclusion of all components subject to AMR by reviewing the results of the screening ofcomponents within the license renewal boundary.LRA drawings LR-STP-EW-5R289F05038 #1-1 & #1-2 and LR-STP-EW-5R289F05038 #2-1,#2-2, & #2-3, coordinates C-4, depict a section of 6"EW1 122WF7 piping to the essential coolingwater discharge structure as not within the scope of license renewal. However, LR-STP-EW-5R289F05038 #1-3, coordinates C-4, depicts this section of 6"EW1 122WF7 piping to theessential cooling water discharge structure as within the scope of license renewal for 10 CFR54.4(a)(2).The staff requests the applicant provide the basis for the differences in the scoping of the pipingdownstream of the termination symbol within the scope of license renewal.STPNOC ResponseBoundary drawing LR-STP-EW-5R289F05038#1-3 inadvertently shows the portion of pipinghighlighted downstream of the F.4.e termination symbol. The red highlighting should stop at theF.4.e termination symbol. The other five boundary drawings are correctly highlighted. Boundarydrawing LR-STP-EW-5R289F05038#1 -3 (location C-4 will be updated to remove the redhighlighting. Therefore, the section of 6"EW1 122WF7 piping to the essential cooling waterdischarge structure discussed above is not within the scope of license renewal.
EnclosureNOC-AE-1 1002702Page 5 of 30RAI 2.3.3.4-02LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included within the scope of license renewal. The staffconfirms the inclusion of all components subject to AMR by reviewing the results of thescreening of components within the license renewal boundary.LRA drawing LR-STP-EW-5R289F05038 #2-1 coordinates E-4, depicts a section of 10 CFR54.4 (a)(1) 4"EW2126WD8 piping continued to LR-STP-DR-F20005 #2 coordinates F-6, where itis shown within scope of license renewal for 10 CFR 54.4(a){2).The staff requests the applicant provide the basis for the scoping classification change from 10CFR 54.4(a)(1) to 10 CFR 54.4(a)(2).STPNOC ResponseThe piping shown on boundary drawing LR-STP-EW-5R289F05038#2-1 at location E-4 indicatesa safety-related to non-safety-related interface at valve FV6935. Drawing LR-STP-EW-5R289F05038#2-1, location E-4 inadvertently shows the non-safety-related portion as green, butit should have been highlighted red. This agrees with the piping interface to drawing LR-STP-DR-6Q069F20005#2 (this is the same drawing as LR-STP-DR-F20005 #2 referred to in the RAIabove), location F-6 which shows the interfacing piping highlighted red for 10 CFR 54.4(a)(2).However, drawing LR-STP-DR-6Q069F20005#2, location F-6 shows an SI termination symbolwhich should be an F.4.1 triangle symbol to terminate structural integrity attached from drawingLR-STP-EW-5R289F05038#2-1, location E-4.Drawing LR-STP-EW-5R289F05038#2-1 (location E-4) will be updated to change the greenhighlighting of the non safety-related piping to red 10 CFR 54.4(a)(2) highlighting as discussedabove. Also, drawing LR-STP-DR-6Q069F20005#2 (location F-6) will be updated to change theSI termination symbol to an F.4.1 triangle symbol for termination of structural integrity attachedfrom drawing LR-STP-EW-5R289F05038#2-1 (location E-4).RAI 2.3.3.4-03LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included in scope of license renewal. The staff confirms theinclusion of all components subject to AMR by reviewing the results of the screening ofcomponents within the license renewal boundary.LRA drawing LR-STP-EW-5R289F05038 #1-3 coordinates C-4, depicts a piping section6"EW1322WF7 into the Essential Cooling Water Discharge Structure. The license renewalboundary for comparable piping sections 6"EW1 122WF7 and 6"EW1222WF7 on LRA drawingsLR-STP-EW-5R289F05038 #1-1 and LR-STP-EW-5R289F05038 #1-2 coordinates C-4,respectively, stops at the 10 CFR 54.4(a)(2) termination symbols.The staff requests the applicant provide the basis for the difference in license renewalboundaries.
EnclosureNOC-AE-1 1002702Page 6 of 30STPNOC ResponseBoundary drawing LR-STP-EW-5R289F05038#1-3 inadvertently shows the portion of pipinghighlighted downstream of the F.4.e termination symbol. The red highlighting should stop at theF.4.e termination symbol. The other two boundary drawings discussed above are correctlyhighlighted.Boundary drawing LR-STP-EW-5R289F05038#1 -3, location C-4 will be updated to remove thered highlighting downstream of the F.4.e termination symbol.Section 2.3.3.5 Reactor Makeup WaterRAI 2.3.3.5-01LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included within the scope of license renewal. The staffconfirms the inclusion of all components subject to AMR by reviewing the results of thescreening of components within the license renewal boundary.The applicant indicated, on LRA drawings LR-STP-RM-5R279F05033 #1 and #2 coordinatesG-4, a floating seal of the reactor makeup water storage tanks 1A & 1 B as not within the scopeof license renewal. LRA Table 2.3.3-5 does not list this floating seal. This component appears tobe part of the reactor makeup water system, which is depicted as being within the scope oflicense renewal for 10 CFR 54.4(a)(1).The staff requests that the applicant provide the basis for excluding the floating seal from withinthe scope of license renewal.STPNOC ResponseThe reactor makeup water storage tank (RMWST) is safety-related and in scope for 10 CFR54.4(a)(1). The floating seals for the RMWSTs shown on drawingsLR-STP-RM-5R279F05033#1 & #2 (location G-4) were inadvertently not highlighted. Theseseals are not safety-related and do not perform any safety function but are within the scope oflicense renewal for non-safety affecting safety per 10 CFR 54.4(a)(2). The non-safety functionof the seals is to control oxygen levels in the makeup water. The dissolved oxygen levels of thewater are monitored to indicate degradation of the seals. When the levels exceed the threshold,the seals are replaced. The seals are short-lived components and therefore do not requireaging management review. Operating experience has demonstrated that using dissolvedoxygen as a replacement indicator will provide reasonable assurance that the seals are replacedprior to any effect on the RMWST safety function.Boundary drawings LR-STP-RM-5R279F05033#1 & #2 will be revised to highlight the seals redfor 10 CFR 54.4(a)(2) scoping.RAI 2.3.3.5-02In LRA Section 2.1.2.2, the applicant indicated that nonsafety-related SSCs attached to safety-related SSCs are within the scope of license renewal for 10 CFR 54.4(a)(2) up to the firstseismic anchor past the safety/nonsafety interface.
EnclosureNOC-AE-1 1002702Page 7 of 30On LRA drawings LR-STP-RM-5R279F05033 #1 & #2 at coordinates G-7, the staff could notlocate seismic anchors on the 10 CFR 54.4(a)(2) non-safety related lines connected tosafety-related lines downstream of valves FV7664.The staff requests that the applicant provide the location of the seismic anchors.STPNOC ResponseDashed piping (designates interfacing piping from another plant system) is shown to the left ofvalve FV 7663 on drawings LR-STP-RM-5R279F05033#1 & #2, location G-7. Dashed piping isnot highlighted on boundary drawings. The continuation flag calls out drawing "9Z00047" gridlocation F-i, which corresponds to boundary drawing LR-STP-PS-9Z329Z00047. Thecontinuation shows a connection to the primary sample panel (ZLP131), which is credited as anequivalent anchor, indicated by the "F.4.3" triangle at grid location H-3.Section 2.3.3.6 Component Coolina WaterRAI 2.3.3.6-01LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included within the scope of license renewal. The staffconfirms the inclusion of all components subject to AMR by reviewing the results of thescreening of components within the license renewal boundary.LRA drawings LR-STP-CC-5R209F05017 #1 and #2 coordinates G-6, depict short pipeextensions off of valve CC0746 that are within the scope of license renewal for 10 CFR54.4a)(2). The short pipe extensions have no identification, anchor,.or boundary locationestablished.The staff requests the applicant provide the identification, anchor, or boundary location for thesepipe section extensions.STPNOC ResponseDrawings LR-STP-CC-5R209F05017#1 & #2 show the correct configuration of the piping andvalves. Isometric drawing 3M379PCC7561 confirms the configuration as a 6" pipe stub attachedto valve CC0746. The pipe stub is non-safety-related and is included within the scope of licenserenewal for spatial interaction and structural integrity attached. As a general rule, terminalcomponent symbols (triangles and/or hexagons) are not depicted at obvious pipe terminationson boundary drawings since that would add clutter to drawings.RAI 2.3.3.6-02LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included in scope of license renewal. The staff confirms theinclusion of all components subject to AMR by reviewing the results of the screening ofcomponents within the license renewal boundary.LRA drawings LR-STP-CC-5R209F05020 #1 and #2 coordinates E-1, depict pipe sections 1"CC1647XC7 and 1" CC2647XC7 within the scope of license renewal under 10 CFR 54.4(a)(2)
EnclosureNOC-AE-1 1002702Page 8 of 30continued to LRA drawings LR-STP-SB-5S209F20002 #1 and #2 coordinates D-4, where theyare shown as not within the scope of license renewal.The staff requests the applicant provide a basis for not including the pipe sections on LRAdrawings LR-STP-SB-5S209F20002 #1 and #2 within the scope of license renewal.STPNOC ResponsePiping sections 1"CC1647XC7 and 1"CC2647XC7 on boundary drawings LR-STP-CC-5R209F05020#1 & #2 (location E-1) are in-scope for spatial interaction and are highlighted red.However, the drawings do not have the "SI" terminal component hexagon symbol depictedbefore the continuation to boundary drawings LR-STP-SB-5S209F20002#1 & #2. Thetermination of spatial interaction before the continuation is based on the piping leaving an areawith safety-related components. The piping sections continued on drawings LR-STP-SB-5S209F20002#1 & #2 are not in-scope.Boundary drawings LR-STP-CC-5R209F05020#1 & #2 will be revised to add spatial interactiontermination symbols on lines 1"CC1647XC7 and 1"CC2647XC7 before the continuation to thenext drawing.RAI 2.3.3.6-03LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included within the scope of license renewal. The staffconfirms the inclusion of all components subject to AMR by reviewing the results of thescreening of components within the license renewal boundary.LRA drawings LR-STP-CC-5R209F05020 #1 and #2 coordinates B-i, depict 10 CFR 54.4(a)(2)pipe sections 1 "CC1649XC7 and 1 "CC2649XC7 continued from LRA drawings LR-STP-SB-5S2099F20002 #1 and #2 coordinates D-4, where they are shown as not within the scope oflicense renewal.The staff requests the applicant provide the basis for not including the pipe sections within thescope of license renewal on LRA drawings LR-STP-SB-5S2099F20002 #1 and #2.STPNOC ResponsePiping sections 1"CC1649XC7 and 1"CC2649XC7 on boundary drawings LR-STP-CC-5R209F05020#1 & #2 (location B-i) are in-scope for spatial interaction and are highlighted red.However, the drawings do not have the "Sr" terminal component hexagon symbol depictedbefore the continuation to boundary drawings LR-STP-SB-5S209F20002#1 & #2. Terminationof spatial interaction before the continuation is based on the piping leaving an area with safety-related components. The piping sections continued on drawings LR-STP-SB-5S209F20002#1  are not in-scope.Boundary drawings LR-STP-CC-5R209F05020#1 & #2 will be revised to add spatial interactiontermination symbols on lines 1"CC1649XC7 and 1"CC2649XC7 before the continuation to thenext drawing.
EnclosureNOC-AE-1 1002702Page 9 of 30Section 2.3.3.7 Compressed AirRAI 2.3.3.7-01LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included within the scope of license renewal. The staffconfirms the inclusion of all components subject to AMR by reviewing the results of thescreening of components within the license renewal boundary.LRA drawing LR-STP-IA-8Q1 19F00048 #1-1 coordinates G/H-6, 7, and 8, depicts an instrumentair compressor (8Q1 11 MCO0014), including the check valves and continuation lines, as withinthe scope of license renewal for 10 CFR 54.4(a)(3). However, for the standby unit instrument aircompressors (8Q1 11 MCO001 1, 8Q1 11 MCO001 2 and 8Q1 11 MCO001 3), the license renewalboundary is shown to end at ball valves IA9813 (coordinates F-6), IA9814 (coordinates G-5) andIA9821 (coordinates F-6). Ball valves IA9813 and IA9821 are normally open valves and do notprevent any backflow into the standby unit instrument air compressors. A similar condition existson the Unit 2 drawing LR-STP-IA-8Q119F00048 #2-1.The staff requests the applicant provide the basis for the license renewal boundary at the openball valves.STPNOC ResponseThe main compressed air flow path from instrument air compressors 8Q1 11 MCO0014 &8Q112MC00024 is in-scope to support a 10 CFR 54.4(a)(3) fire protection intended function asshown on boundary drawings LR-STP-IA-8Q119F00048#1-1 & LR-STP-IA-8Q1 19F00048#2-1.The scoping boundary ends at ball valves IA9813 (location F-6), IA9821 (location F-6) andIA9814 (location G-5) because each valve represents the first closable valve off the maininstrument air flow path from instrument air compressors 8Q1 1 1MCO0014 & 8Q1 12MC00024.These valves are not required to be normally closed, but are only required to have the capabilityto be closed in order to support the 10 CFR 54.4(a)(3) fire protection intended function.RAI 2.3.3.7-02LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included within the scope of license renewal. The staffconfirms the inclusion of all components subject to AMR by reviewing the results of thescreening of components within the license renewal boundary.LRA drawings LR-STP-IA-8Q1 19F00048 #1-1 and LR-STP-IA-8Q1 19F00048 #2-1 coordinatesE-5, depict wet air tanks (8Q1 11 MTS0161, and 8Q1 12MTS0161) within the scope of licenserenewal for 10 CFR 54.4(a)(3). However, the relief valves (PSV 8571) on these tanks are shownas not within the scope of license renewal. Similar air tanks (8Q111MTS0163 and8Q1 12MTS0163 at coordinates E/F-2) on these LRA drawings show the relief valves as withinthe scope of license renewal.The staff requests the applicant provide the basis for not including the relief valves on wet airtanks 8Q111MTS0161, and 8Q112MTS0161 within the scope of license renewal.
EnclosureNOC-AE-1 1002702Page 10 of 30STPNOC ResponseRelief valve PSV8571 on boundary drawings LR-STP-IA-8Q1 19F00048#1-1 and LR-STP-IA-8Q1 19F00048#2-1 (location E-5) were inadvertently not included in-scope of license renewaland are not highlighted on the boundary drawings. These valves should be in-scope for 10 CFR54.4(a)(3).Relief valve PSV8571 will be included in-scope and boundary drawings LR-STP-IA-8Q1 19F00048#1-1 and LR-STP-IA-8Q1 19F00048#2-1 (location E-5) will be updated to highlightthese valves "green" for 10 CFR 54.4(a)(3).RAI 2.3.3.7-03LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included within the scope of license renewal. The staffconfirms the inclusion of all components subject to AMR by reviewing the results of thescreening of components within the license renewal boundary.LRA drawings LR-STP-IA-8Q1 19F00048 #1-1 and LR-STP-IA-8Q1 19F00048 #2-1 coordinatesG-2, depict 1" drain lines (IA1237UD8 and IA2237UD8) attached to the instrument air receivertanks (8Q1 11 MTS0162, and 8Q1 12MTS0162) as within the scope of license renewal for 10 CFR54.4(a)(3). However, for similar 1" drain lines (IA1238UDS and IA2238UD8) on instrument airreceiver tanks (8Q1 1 1MTS0163, and 8Q1 12MTS0163) at coordinates E-2, the license renewalboundary is shown to end at valves IA9980 and the line continuing after the valve is shown asnot within scope of license renewal.The staff requests the applicant provide a basis for the different scoping classifications for thelines downstream of the drain valves.STPNOC ResponseThe 1" drain line piping attached to the instrument air receiver tanks (8Q111 MTS0162, and8Q1 12MTS0162) and downstream of valves IA9979 is inadvertently highlighted "green". Thepiping is not within the scope of license renewal. The 10 CFR 54.4(a)(3) boundary is at valveIA9979 since it is a closable valve. The piping downstream of valve IA9980 is depicted correctlyand is not within the scope of license renewal since it is downstream of a closable valve(IA9980). Ending the 10 CFR 54.4(a)(3) scoping boundary at valves IA9979 & IA9980 isappropriate because the valves can be closed to support the 10 CFR 54.4(a)(3) fire protectionintended function of maintaining main flow path integrity.Boundary drawing LR-STP-IA-1 19F00048#1 (location G-2) will be updated to remove the greenhighlighting discussed above.RAI 2.3.3.7-04LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included within the scope of license renewal. The staffconfirms the inclusion of all components subject to AMR by reviewing the results of thescreening of components within the license renewal boundary.
EnclosureNOC-AE-1 1002702Page 11 of 30LRA drawing LR-STP-IA-8Q1 19F00048 #2-2 coordinates B-6, depict a line with a capped end,upstream of a 4"x3" reducer, as within the scope of license renewal for 10 CFR 54.4(a)(3).However, a similar line on drawing LR-STP-IA-8Q119F00048 #1-2 coordinates B-6, is shown asnot within the scope of license renewal.The staff requests the applicant provide a basis for not including the line on LRA drawing LR-STP-IA-8Q1 19F00048 #1-2 coordinates B-6 within the scope of license renewal.STPNOC ResponseThe Unit 2 boundary drawing (LR-STP-IA-8Q 19F00048#2-2) correctly shows the small piece ofpiping with a capped end in the scope of license renewal. Boundary drawing LR-STP-IA-8Q1 19F00048#1-2 at location B-6 inadvertently shows this piece of pipe as out-of-scope, andshould have been highlighted green.Boundary drawing LR-STP-IA-8Q1 19F00048#1-2 at location B-6 will be updated to highlight thecapped end piping green for 10 CFR 54.4(a)(3) as discussed above.RAI 2.3.3.7-05LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included within the scope of license renewal. The staffconfirms the inclusion of all components subject to AMR by reviewing the results of thescreening of components within the license renewal boundary.For the LRA drawing locations identified in the table below, the piping on the main drawing isshown as within the scope of license renewal but is shown as not within the scope of licenserenewal on the continuation drawing.LRA SectionlDrawing Number & Location Continuation PipinglDrawing NumberLR-STP-IA-8Q1 19F05050#1 and #2 Lines 1"1A1826WK8/1"IA2826WK8 to LR-coordinates G/F-2 STP-WL-7R309F05026#1 and #2coordinates G-4, (incorrectly shown as9F05050 G-2)LR-STP-IA-8Q1 19F05050#1 and #2 Lines 1"1A1829WK8/1 "IA2829WK8 to LR-coordinates F-2 STP-BR-7R189F0501 1#1 and #2 coordinatesF-6The staff requests the applicant provide the basis for not including the continuation piping withinthe scope of license renewal.STPNOC ResponseItem 1 -The green highlighting on boundary drawings LR-STP-IA-8Q1 19F05050#1 & #2,location G-2 should stop after the first closable valve to indicate termination of 10 CFR 54.4(a)(3)scoping. LR-STP-IA-8Q1 19F05050#1 & #2 inadvertently continues the green highlighting to thecontinuation flag. The continuation piping downstream of valve IA0827 is depicted correctly andis not within the scope of license renewal since it is downstream of a closable valve (IA0827).Boundary drawings LR-STP-IA-8Q1 19F05050#1 & #2, location G-2 will be updated to removethe green highlighting downstream of IA0827 and show the piping as not in-scope.
EnclosureNOC-AE-1 1002702Page 12 of 30Item 2 -The green highlighting on boundary drawings LR-STP-IA-8Q1 19F05050#1 & #2,location F-2 should stop after the first closable valve to indicate termination of 10 CFR 54.4(a)(3)scoping. LR-STP-IA-8Q1 19F05050#1 & #2 inadvertently continues the green highlighting to thecontinuation flag. The continuation piping downstream of valve IA0832 is depicted correctly andis not within the scope of license renewal since it is downstream of a closable valve (IA0832).Boundary drawings LR-STP-IA-8Q1 19F05050#1 & #2, location F-2 will be updated to removethe green highlighting downstream of IA0832 and show the piping as not in-scope.Section 2.3.3.8 Primary Process SamplingRAI 2.3.3.8-01LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included within the scope of license renewal. The staffconfirms the inclusion of all components subject to AMR by reviewing the results of thescreening of components within the license renewal boundary.LRA drawings LR-STP-PS-5Z329Z00045 #1 and #2 coordinates H-4, depict piping within thescope of license renewal under 10 CFR 54.4(a)(2) continuing to valve XPS0327 on the sameLRA drawings coordinates at C-6, where it is shown as not within the scope of license renewal.The staff requests the applicant provide the basis for the difference in scoping classification.STPNOC ResponseThe pipe continuation from boundary drawings LR-STP-PS-5Z329Z00045#1 & #2 (location H-4)to location C-6 should be highlighted red with an SI symbol at valves XPS0327. The pipecontinuation is in-scope for spatial interaction until it connects to valves XPS0327 which islocated on the primary sample panel.Boundary drawings LR-STP-PS-5Z329Z00045#1 & #2 (location C-6) will be updated to highlightthe piping to valve XPS0327 red and an SI symbol will be added at valve XPS0327 to terminatethe spatial interaction.RAI 2.3.3.8-02LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included in scope of license renewal. The staff confirms theinclusion of all components subject to AMR by reviewing the results of the screening ofcomponents within the license renewal boundary.LRA drawings LR-STP-PS-5Z329Z00045 #1 and #2 coordinates D-4, depict piping continuing tovalves XPS0330 within the scope of license renewal under 10 CFR 54.4(a)(2). On the same LRAdrawings at coordinates C-6, the piping is not shown within the scope of license renewal.The staff requests the applicant provide the basis for the differing scoping classifications.
EnclosureNOC-AE-1 1002702Page 13 of 30STPNOC ResponseThe continuation of piping on boundary drawings LR-STP-PS-5Z329Z0045#1 & #2 (location D-4)downstream of valve XPS0330 to location B-2 is within the primary sample panel and is notin-scope for spatial interaction. Red highlighting inadvertently applied to the piping at locationB-2 and the SI symbol should be removed.Boundary drawings LR-STP-PS-5Z329Z0045#1 & #2 (location B-2) will be updated to removethe red highlighting on the piping from valve XPS0330 and to remove the SI symbol downstreamof valve XPS0209.RAI 2.3.3.8-03LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included within the scope of license renewal. The staffconfirms the inclusion of all components subject to AMR by reviewing the results of thescreening of components within the license renewal boundary.LRA drawings LR-STP-PS-5Z329Z00045 #1 and #2 coordinates D-1, depict piping within thescope of license renewal for 10 CFR 54.4(a)(2) with a continuation from valve CV0273coordinates E-8 on LRA drawings LR-STP-CV-SR179F05008 #1 and #2, where it is shown asnot within the scope of license renewal from valve CV0273.The staff requests the applicant provide the basis for the difference in scope classification.STPNOC ResponseThe piping associated with valve CV0273 on boundary drawings LR-STP-CV-5R179F05008 (thisis the same drawing as LR-STP-CV-SR179F05008 referred to in the RAI) #1 and #2, location D-8 is not within the scope of license renewal and is not highlighted on the drawings. The pipingcontinuation from boundary drawings LR-STP-CV-5R179F05008#1 and #2 to boundarydrawings LR-STP-PS-5Z329Z0045#1 and #2, location D-1 is incorrectly highlighted red. Thispiping is not within the scope of license renewal and should not be highlighted red.Boundary drawings LR-STP-PS-5Z329Z0045#1 and #2 (location D-1) will be updated to removethe red highlighting discussed above.RAI 2.3.3.8-04LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included within the scope of license renewal. The staffconfirms the inclusion of all components subject to AMR by reviewing the results of thescreening of components within the license renewal boundary.LRA drawings LR.STP-PS-5Z329Z00045 #1 and #2 coordinates B-I, depict piping within thescope of license renewal under 10 CFR 54.4(a)(2). The pipe continuations on drawings LR-STP-ED-7Q069F90012 #1 and #2 coordinates H-8, are depicted as not within the scope of licenserenewal.
EnclosureNOC-AE-1 1002702Page 14 of 30The staff requests the applicant provide the basis for the continuation piping not being within thescope of license renewal.STPNOC ResponseThe continuation from boundary drawings LR-STP-PS-5Z329Z00045#1 & #2 (location B-i) goesto boundary drawings LR-STP-ED-7Q069F90012#1 & #2 (locations H-8). However, boundarydrawings LR-STP-ED-7Q069F90012#1 & #2 (locations H-8) do not depict an off-sheet connectorcoming from boundary drawings LR-STP-PS-5Z329Z00045#1 & #2 (location B-I). Thecontinuation is shown on drawings LR-STP-ED-7Q069F90012#1 & #2 (location H-8) as comingfrom "Sample Room Reactor Grade Sampler." The continued piping is correctly highlighted"red" for spatial interaction on drawings LR-STP-ED-7Q069F90012#1 & #2 (location H-8). Nochanges are required.RAI 2.3.3.8-05LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included within the scope of license renewal. The staffconfirms the inclusion of all components subject to AMR by reviewing the results of thescreening of components within the license renewal boundary.LRA drawing LR-STP-PS-5Z329Z00045 #1 coordinates F-7, depict a 10 CFR 54.4(a)(2) pipeline1"PS1020BD7 within the scope of licensing renewal for 10 CFR 54.4(a)(2) that ends at theintersection with the inside primary sample panel. No spatial interaction symbol is shown.The staff requests the applicant provide the basis for the license renewal boundary at theintersection of the pipe and the panel.STPNOC ResponseThe spatial interaction termination symbol on boundary drawing LR-STP-PS-5Z329Z00045#1(location F-7) is inadvertently omitted. The symbol is correctly shown on the corresponding Unit2 drawing LR-STP-PS-5Z329Z00045#2 (location F-7).Boundary drawing LR-STP-PS-5Z329Z00045#1 (location F-7) will be updated to add the "Sr"termination symbol.RAI 2.3.3.8-06LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included within the scope of license renewal. The staffconfirms the inclusion of all components subject to AMR by reviewing the results of thescreening of components within the license renewal boundary.LRA drawings LR-STP-PS-5Z329Z00045 #1 and #2 coordinates G-4, depict a digital pressureindicator (dpi) located in a 10 CFR 54.4(a)(2) pipeline. The dpi is shown as not within the scopeof license renewal, and has been disconnected electrically and spared in place according to thenotes. The dpi appears to provide a pressure boundary function for a portion of the 10 CFR 54.4(a)(2) pipelines.
EnclosureNOC-AE-1 1002702Page 15 of 30The staff requests the applicant provide the basis for the dpi casing not being in scope for 10CFR 54.4(a)(2).STPNOC ResponseDigital pressure indicator P10659 is a leakage boundary component and should be includedin-scope and highlighted red on boundary drawings LR-STP-PS-5Z329Z00045#1 & #2. P10659is spared in-place and disconnected electrically but the piping has not been cut and capped andis therefore in-scope for 10 CFR54.4(a)(2) spatial interaction.A leakage boundary component for P10659 will be included in-scope for 10 CFR 54.4(a)(2)spatial interaction. Boundary drawings LR-STP-PS-5Z329Z00045#1 & #2 (location G-4) will beupdated to highlight P10659 red for spatial interaction. LRA Table 2.3.3-8 and 3.3.2-8 will beupdated to add the housing of the pressure indicator.RAI 2.3.3.8-07In LRA Section 2.1.2.2 the applicant indicates that nonsafety-related SSCs attached to safety-related SSCs are within the scope of license renewal for 10 CFR 54.4(a)(2) up to the firstseismic anchor past the safety/nonsafety interface.LRA drawings LR-STP-PS-5Z549Z47501 #1 and #2 coordinates C-4, depict a waste collectionunit that is within the scope of license renewal for 10 CFR 54.4(a)(2) which containsnonsafety-related attached to safety-related components.The staff requests the applicant provide the basis for why the waste collection unit and containedcomponents within the scope of license renewal for 10 CFR 54.4(a)(2) do not depict equivalentanchoring like F.4.3 shown on the sample condition rack and the liquid and gas sample panel onthe same drawing.STPNOC ResponseThe waste collection unit and contained components in scope for 10 CFR 54.4(a)(2) do not showequivalent anchoring because a seismic anchor is credited prior to the piping attaching to thewaste collection unit. A seismic anchor is indicated at grid location C-3 to the left of valveAP0006, serving the safety-related/non-safety-related (SR/NSR) interface at grid location C-3 (atFV2458). Therefore, the waste collection unit is not being credited for anchoring anysafety-related piping. The other piping connections to the waste collection unit are in-scope forspatial interaction only.
EnclosureNOC-AE-1 1002702Page 16 of 30RAI 2.3.3.8-08LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included within the scope of license renewal. The staffconfirms the inclusion of all components subject to AMR by reviewing the results of thescreening of components within the license renewal boundary.LRA drawings LR-STP-PS-9Z329Z00047 #1 and #2 coordinates F-5, depict a pipeline within thescope of license renewal for 10 CFR 54.4(a)(2) with a continuation to coordinates B-2 on LRAdrawings LR-STP-CV-PS-5Z329Z00045 #1 and #2, where it is shown as not within the scope oflicense renewal to the drain header.The staff requests the applicant provide the basis for the change in scoping classification of thispipe section.STPNOC ResponseBoundary drawings LR-STP-PS-9Z329Z00047#1 & #2 (location F-5) inadvertently depict a redhighlighted pipe and an SI symbol. The red highlighting and SI symbol are incorrect and shouldbe removed. The piping is within the panel and is not in-scope for 10 CFR 54.4(a)(2) spatialinteraction.Boundary drawings LR-STP-PS-9Z329Z00047#1 & #2 (location F-5) will be updated to removethe red highlighted pipe and SI symbol.RAI 2.3.3.8-09LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included within the scope of license renewal. The staffconfirms the inclusion of all components subject to AMR by reviewing the results of thescreening of components within the license renewal boundary.LRA drawings LR-STP-PS-9Z329Z00047 #1 and #2 coordinates C-2, depict a 10 CFR 54.4(a)(2)piping intersecting XPS0120 which is not depicted as being in the scope of licensing renewal.The staff requests the applicant provide the basis for the scope change at the intersection of thetwo pipes.STPNOC ResponseLR-STP-PS-9Z329Z00047 #1 & #2 inadvertently omit an SI termination symbol at grid locationC-2. The spatial interaction scoping ends upstream of the continuation where it intersects thepiping leading to valve XPS0120.Boundary drawings LR-STP-PS-9Z329Z00047 #1 & #2 (location C-2) will be updated to add the"SI" termination symbol at the intersection of the deminerilized water line and the line to valveXPS0120.
EnclosureNOC-AE-1 1002702Page 17 of 30Section 2.3.3.9 Chilled Water HVACRAI 2.3.3.9-01In LRA Section 2.1 the applicant states that its screening process was used to identify thepassive, long-lived structures and components within the scope of license renewal and subject toAMR. The staff confirms inclusion of all components subject to an AMR by reviewing componenttypes within the license renewal boundary.LRA drawings LR-STP-CH-3V1 19V1 0003 #1 and #2 coordinates B-2, depict the RadwasteControl Room AHUs as abandoned in place. The AHU coils are shown on LR-STP-HM-5V109V00008 #1 and #2 coordinates B-5, as within the scope of license renewal for 10 CFR54.4(a)(2). Connected piping to the AHU coils is shown within the scope of license renewal for10 CFR 54.4(a)(1). There is no change in safety class indicated at the coil/piping interface. Thestaff questions if the coils provide a safety-related function, e.g. pressure boundary, and shouldbe within the scope of license renewal for 10 CFR 54.4(a)(1).The staff requests the applicant provide the basis for the scoping classification of the AHU coils.STPNOC ResponseThe piping to the abandoned-in-place chillers (i.e the AHUs referred to in the RAI above)depicted in 3V101VAH018 and 3V102VAH018 (location B-2) is safety-related as shown onboundary drawings LR-STP-CH-3V1 19V1 0003#1 and #2. Prior to being abandoned-in-place, thechillers were also safety-related. However, since the chillers are taken out of service andabandoned-in-place they no longer have an 10 CFR 54.4(a)(1) intended function.Since the chillers could not be verified to have been drained and cut and capped to isolate thechillers from water sources, the chillers have been included within the scope of license renewalas 10 CFR 54.4(a)(2) for spatial interaction considerations (red piping on boundary drawings LR-STP-HM-5V109V00008#1 and #2, location B-5). The chillers are also in-scope for structuralintegrity attached since the chillers are attached to safety-related piping. The drawings arecorrect as shown and the abandoned-in-place chillers are correctly scoped as 10 CFR54.4(a)(2).RAI 2.3.3.9-02LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included in scope of license renewal. The staff confirms theinclusion of all components subject to AMR by reviewing the results of the screening ofcomponents within the license renewal boundary.LRA drawings LR-STP-CH-5V149V00021 #1 and #2 coordinates G-8, depict an expansion tankvent line 1"CH1193XC7/1"CH2193XC7 and relief line 1"CH1193XC7/1"CH2193XC7 as notwithin the scope of license renewal.The staff requests the applicant provide the basis for the exclusion of the expansion tank ventand relief piping and associated isolation valves from the scope of license renewal.
EnclosureNOC-AE-1 1002702Page 18 of 30STPNOC ResponseThe reactor containment building chilled water expansion tanks (9V141VTS004 &9V142VTS004) shown on LR-STP-CH-5V149V00021 #1 and #2 (.G-8) have nitrogen blanketsinside the tanks, and therefore the vent and relief lines contain a dry gas. Componentscontaining dry gas are not within the scope of license renewal for 10 CFR 54.4(a)(2) spatialinteraction.RAI 2.3.3.9-03LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included within the scope of license renewal. The staffconfirms the inclusion of all components subject to AMR by reviewing the results of thescreening of components within the license renewal boundary.LRA drawings LR-STP-CH-6V109V00010 #1 and #2 coordinates B-5, depict an expansion tankwithin the scope of license renewal for 10 CFR 54.4(a)(2). The expansion tank has vent lines1"CH1288XC7/1"CH2188XC7 and relief line 1"CH1 194XC7/1"CH2194XC7 which are depictedas not within the scope of license renewal.The staff requests the applicant provide the basis for the exclusion of the expansion tank ventand relief piping and associated isolation valves from the scope of license renewal.STPNOC ResponseReactor containment building chilled water expansion tanks (9V141VTS003 & 9V142VTS003)shown on LR-STP-CH-6V109V00010 #1 and #2, location B-5 have nitrogen blankets inside thetanks, and therefore the vent and relief lines contain a dry gas. Components containing dry gasare not within the scope of license renewal for 10 CFR 54.4(a)(2) spatial interaction.Section 2.3.3.20 Standby Diesel Generator and AuxiliariesRAI 2.3.3.20-01In LRA Section 2.1 the applicant states that its screening process was used to identify thepassive, long-lived structures and components within the scope of license renewal and subject toAMR. The staff confirms inclusion of all components subject to an AMR by reviewing componenttypes within the license renewal boundary.LRA drawings LR-STP-DG-5Q159F22540 #1 and #2 coordinates E-3, E-5, and E-8, depict turbohousing components within the scope of license renewal for 10 CFR 54.4(a)(1). The turbohousing component was not included in AMR Table 2.3.3-20.The staff requests the applicant provide the basis for excluding the turbo housing componenttype from LRA Table 2.3.3-20.
EnclosureNOC-AE-1 1002702Page 19 of 30STPNOC ResponseThe turbocharger housings ( 3Q151 MTU0134, 3Q151MTU0234, 3Q151MTU0334,3Q152MTU0134, 3Q152MTU0234, 3Q152MTU0334, and subcomponents -1 & -2) are evaluatedas component type "Blower" in LRA Tables 2.3.3-20 and 3.3.2-20 with a pressure boundary (PB)intended function.RAI 2.3.3.20-02In LRA Section 2.1 the applicant states that its screening process was used to identify thepassive, long-lived structures and components within the scope of license renewal and subject toAMR. The staff confirms inclusion of all components subject to an AMR by reviewing componenttypes within the license renewal boundary.LRA drawings LR-STP-DG-5Q159F22540 #1 and #2 coordinates F-2, F-5, and F-7, depictstandpipe tank components within the scope of license renewal for 10 CFR 54.4(a){1) thatprovide a pressure boundary function. The standpipe tank component was not included in LRATable 2.3.3-20.The staff requests the applicant provide the basis for excluding the standpipe tank componenttype from LRA Table 2.3.3-20.STPNOC ResponseThe standpipe components (3Q151MTS0138, 3Q151MTS0238,3Q151 MTS0338,3Q152MTS01 38, 3Q152MTS0238, 3Q152MTS0338) are evaluated as component type "piping"in LRA Tables 2.3.3-20 and 3.3.2-20 with a pressure boundary (PB) intended function.RAI 2.3.3.20-03In LRA Section 2.1 the applicant states that its screening process was used to identify thepassive, long-lived structures and components within the scope of license renewal and subject toAMR. The staff confirms inclusion of all components subject to an AMR by reviewing componenttypes within the license renewal boundary.LRA drawings LR-STP-DG-5Q159F22546 #1 and LR-STP-DG-5Q159F22546 #2 coordinatesF-2, F-5, and F-7, depict starter air receiver tank components within the scope of license renewalfor 10 CFR 54.4(a)(1) that provide a pressure boundary function. The starter air receiver tankcomponent was not included in AMR Table 2.3.3-20.The staff requests the applicant provide the basis for excluding the starter air receiver tankcomponent from LRA Table 2.3.3-20.
EnclosureNOC-AE-1 1002702Page 20 of 30STPNOC ResponseStarting air receivers (3Q151 MTS0134, 3Q151 MTS0234, 3Q151 MTS0334, 3Q151 MTS0434,3Q 151 MTS0534, 3Q151 MTS0634, 3Q 1 52MTS0134, 3Q 1 52MTS0234, 3Q 1 52MTS0334,3Q152MTS0434, 3Q152MTS0534, 3Q152MTS0634) are evaluated as component type"accumulator" in LRA Tables 2.3.3-20 and 3.3.2-20 with a pressure boundary (PB) intendedfunction.RAI 2.3.3.20-04In LRA Section 2.1 the applicant states that its screening process was used to identify thepassive, long-lived structures and components within the scope of license renewal and subject toAMR. The staff confirms inclusion of all components subject to an AMR by reviewing componenttypes within the license renewal boundary.The staff reviewed LRA drawings LR-STP-DG-5Q159F22542 #1 and #2 and LR-STP-DG-5Q19F22543 #1 and #2 to locate the diesel lube oil reservoir tanks. The staff was unable tolocate them.The staff requests the applicant clarify whether or not there are diesel lube oil reservoir tanks inthe system, and if they are, explain if they are in scope and where they are located.STPNOC ResponseThe diesel generator lube oil system is a wet sump oiling system, and does not contain separatelube oil reservoir tanks.RAI 2.3.3.20-05In LRA Section 2.1.2.2, the applicant indicates that it utilized the method of designatingbase-mounted components (e.g., pump, heat exchanger, tank, etc.) as equivalent anchors toestablish the license renewal boundary as described in NEI 95-10, Appendix F. The applicantuses the termination symbol, F.4.a, on the LRA drawings to identify the seismic endpoints atthese components.LRA drawings LR-STP-DG-5Q159F22546 #1 and #2 coordinates E-2, E-4, E-5, and E-7, depictmembrane dryers attached to 1" stainless steel piping within the scope of license renewal, withthe termination symbols of F.4.a. However, during the Scoping and Screening Audit on May 16through May 20, 2011, the staff identified 1/"' copper piping attached downstream of the 1"stainless steel piping. The Y" copper piping is attached to the membrane dryers. Theconfiguration of the 1A" copper piping on the membrane dryers does not appear to meet thedescription of base-mounted components as described in NEI-95-10, Appendix F.The staff requests the applicant provide the basis for designating the membrane dryers as base-mounted components with the physical configuration as described above.
EnclosureNOC-AE-1 1002702Page 21 of 30STPNOC ResponseThe LRA incorrectly designates the membrane dryers as F.4.a, base-mounted terminalcomponents shown on boundary drawings LR-STP-DG-5Q159F22546 #1 and #2. The 1/2-inchcopper tubing will be credited as a flexible connection per NEI 95-10 F.4.b, such that loads arenot transferred through the tubing to the downstream safety-related piping. As a result, themembrane dryers will be removed from the scope of license renewal.Boundary drawings LR-STP-DG-5Q159F22546 #1 and #2 will be revised to correctly show the10 CFR 54.4(a)(2) terminations at the 1-inch stainless steel piping to 1/2-inch copper tubing.LRA Tables 2.3.3-20 and 3.3.2-20, and Section 2.3.3.20 will also be revised to remove thecomponent type "dryer", and Section 2.3.3.20 will be revised to remove air dryers from thesystem description.RAI 2.3.3.22-01LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included in scope of license renewal. The staff confirms theinclusion of all components subject to aging management review (AMR) by reviewing the resultsof the screening of components within the license renewal boundary.For the drawing locations/lines identified in the table below, the pipe sections on the maindrawings are shown as within the scope of license renewal but are shown as not within thescope of license renewal on the continuation drawings.(LRA) Section/Drawing Number & Continuation Piping/Drawing NumberLocationLR-STP-WL-7R309F05024#1 and #2 2" piping (CV1259UD7 and CV2259UD7) oncoordinates G-6 LR-STP-CV-5R1 79F05009#1 and #2coordinates A-8LR-STP-WL-5R309F05022#1 and #2 1" piping on LR-STP-RC-5R149F05004#1 andcoordinates E-6 #2 coordinates F-6LR-STP-WL-7R309F05023#1 and #2 3" piping (WL1048WG7/3"WL2048WG7) oncoordinates A-2 LR-STP-WL-7R309F90001#1 and #2coordinates E-8The staff requests the applicant to provide the basis for the change in scoping classification forthese pipe sections.STPNOC ResponseItem #1 -LR-STP-WL-7R309F05024#1/#2, G-6 continuation:Boundary drawings LR-STP-WL-7R309F05024#1 & #2 (G-6) inadvertently omit an SItermination symbol. The downstream components shown on boundary drawings LR-STP-CV-5R179F05009#1 & #2 (A-8) are in a room that does not contain safety-relatedcomponents. The components are correctly not highlighted on boundary drawings LR-STP-CV-5R179F05009#1 & #2 (A-8).
EnclosureNOC-AE-1 1002702Page 22 of 30Boundary drawings LR-STP-WL-7R309F05024#1 & #2 (G-6) will be updated to add an SItermination symbol prior to the continuation to boundary drawings LR-STP-CV-5R179F05009#1 & #2 (A-8).Item #2 -LR-STP-WL-5R309F05022#1/#2, E-6 continuation:Boundary drawings LR-STP-WL-5R309F05022#1 & #2 (E-6) incorrectly highlight the pipingdownstream of valve WL1501 red for spatial interaction. The piping is not in-scope and anSI termination symbol should be located at valve WL1501. The piping is not in-scope basedon both the Reactor Coolant Drain Tank (RCDT) and Pressure Relief Tank (PRT) havingnitrogen blankets and being evacuated by the connections to the vacuum degassing systemthereby establishing a dry gas atmosphere as an internal environment.Boundary drawings LR-STP-WL-5R309F05022#1 & #2 (E-6) will be updated to remove thered highlighting from the piping downstream of valve WL1501 and to add an SI terminationsymbol at valve WL1501.Item #3 -LR-STP-WL-7R309F05023#1/#2, A-2 continuation:Boundary drawings LR-STP-WL-7R309F05023#1 & #2 (A-2) 3" pipingWL1048WG7/3"WL2048WG7 continuation to boundary drawings LR-STP-WL-7R309F90001#1 & #2 (E-8) should be highlighted red until terminated for spatial interaction.Boundary drawing LR-STP-WL-7R309F90001#2 (E-8) correctly shows the piping highlightedred with an SI termination symbol; however, boundary drawing LR-STP-WL-7R309F90001#1(E-8) inadvertently omits the red highlighted piping. The components on boundary drawingLR-STP-WL-7R309F90001#1 (E-8) are in-scope for 10 CFR 54.4(a)(2) spatial interaction.Boundary drawing LR-STP-WL-7R309F90001#1 (E-8) will be updated to highlight the in-scope components red for 10 CFR 54.4(a)(2) spatial interaction.RAI 2.3.3.22-02In LRA Section 2.1, the applicant indicates that nonsafety-related SSCs attached to safety-related SSCs are within the scope of license renewal for 10 CFR 54.4(a)(2) up to the firstseismic anchor beyond the safety/nonsafety interface.During its review of the liquid waste processing system drawings, the staff could not locateseismic anchors on the following nonsafety-related piping sections, which are depicted as inscope of license renewal for 10 CFR 54.4(a)(2), and directly connected to safety-related valves.Non-Safety/Safety Interface Location DescriptionLR-STP-WL-7R309F05024#1 and #2 2" piping (WL1401WG7/2"WL2401WG7)coordinates H-6 connected to 3" line piping(WL1081WG7/WL2081WG7) which in turn isconnected to safety-related piping including2"CV1 034PB3/2"CV2034PB3LR-STP-WL-5R309F05022#1 and #2 Piping from drawing LR-STP-RC-coordinates E-6 5R149F05001#1 and #2 connected to valvesFV3400 EnclosureNOC-AE- 11002702Page 23 of 30The staff requests the applicant provide the locations of the seismic anchors for the aboveexamples.STPNOC ResponseItem 1Piping 2"CV1 034PB3 to safety-related valve CV1 33A connects to non safety-related piping2"WL1089WG7 & 2"WL2089WG7 on boundary drawings LR-STP-WL-7R309F05024#1 & #2(location G-7). All structural integrity attached terminations on drawingsLR-STP-WL-7R309F05024#1 & #2 (location G-7) for valve CV1 33A were evaluated andfound to be correct except for the following 10 CFR 54.4(a)(2) lines:* 2"WL1093WG7/2"WL2093WG7* 2"WL1094WG7/2"WL2094WG7, and* 2"WL1401WG7/2"WL2401WG7.No structural integrity attached terminations are shown on the drawings for these lines.After further review of these piping lines, equivalent anchors (per "F.4.4" of NEI 95-10Appendix F) were found along pipe 3"WL1081WG7/3"WL2081WG7 between the branchlines of 2"WL1093WG7/2"WL2093WG7 and 2"WL1094WG7/2"WL2094WG7 and on pipe2"WL1094WG7/2"WL2094WG7. Piping downstream of these equivalent anchors will nolonger be in scope for structural integrity attached; therefore, the seismic anchor symbolscurrently shown are no longer required and will be removed from the drawings.The piping downstream of the equivalent anchor on 3"WL1081WG7/3"WL2081WG7 remainswithin the scope of license renewal for spatial interaction. Spatial interaction terminationsymbols (hexagons) were inadvertently omitted from piping lines2"WL1093WG7/2"WL2093WG7, 2"WL1094WG7/2"WL2094WG7, and2"WL1401WG7/2"WL2401WG7.Boundary drawings LR-STP-WL-7R309F05024#1 & #2 will be revised to depict structuralintegrity attached terminations for pipe lines 2"WL1094WG7/2"WL2094WG7 and2"WL1081WG7/2"WL2081WG7. The boundary drawings will also be revised to add thespatial interaction termination symbols (hexagons) to piping lines2"WL1093WG7/2"WL2093WG7, 2"WL1094WG7/2"WL2094WG7, and2"WL1401WG7/2"WL2401WG7.Item 2The NSR portion of the SR/NSR interface on LR-STP-WL-5R309F05022#1 at F-7 beginswith the solid line next to the dashed valve FV3400. Continuing along the NSR portion of thispiping, all branches are appropriately terminated with an equivalent anchor except twolocations. These locations are C-8 (pipe 4"RC1041UD7) and B-2 (pipe 3RC1034UD7), withpiping 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-mountedcomponent. The PRT and the associated piping are in-scope for license renewal, but aterminal component was inadvertently omitted at the PRT.
EnclosureNOC-AE-1 1002702Page 24 of 30Boundary drawings LR-STP-RC-5R149F05004#1 & #2 will be updated to add an F.4.atermination symbol (base-mounted component) to the PRT.RAI 2.3.3.22-03License renewal rule 10 CFR 54.21(a)(1) requires applicants to list all components subject to anAMR. The staff confirms inclusion of all components subject to an AMR by reviewing componenttypes within the license renewal boundary.License renewal drawing LR-STP-WL-7R309F90001 #2 coordinates D-1, C-4, C-7, E-7 and E-8,depict portions of several lines as within the scope for license renewal for 10 CFR 54.4(a)(2).However, similar lines on LRA drawing LR-STP-WL-7R309F90001 #1 are shown as not withinthe scope of license renewal.The staff requests the applicant to clarify the difference in scoping classification of the lines inquestion.STPNOC ResponseThe Unit 1 boundary drawing LR-STP-WL-7R309F90001#1 inadvertently omits the redhighlighting between the SI termination symbols for spatial interaction. The Unit 2 boundarydrawing correctly shows the scoping boundaries for license renewal, and the components fromboth units are in scope.Boundary drawing LR-STP-WL-7R309F90001#1 will be updated to highlight the six pipingsections (locations D-1, C-4, C-7, E-7, E-8, and H-8) red for 10 CFR 54.4(a)(2) spatial interactionto agree with boundary drawing LR-STP-WL-7R309F90001#2.RAI 2.3.3.22-04LRA drawing LR-STP-SYMBOLS contains a component coloring scheme for identifying the pipesections that are within the scope of license renewal. This drawing also contains symbols toidentify 10 CFR 54.4(a)(2) terminations.LRA drawing LR-STP-WL-7R309F90001#1 contains 10 CFR 54.4(a)(2) termination symbols.However, no pipe sections or equipment are identified as within the scope of license renewal.The staff requests the applicant to identify the pipe sections and any components that are withinthe scope of license renewal.STPNOC ResponseThe Unit 1 boundary drawing LR-STP-WL-7R309F90001#1 inadvertently omits the redhighlighting between the SI termination symbols for spatial interaction. The Unit 2 boundarydrawing correctly shows the scoping boundaries for license renewal, and the components fromboth units are in scope.Boundary drawing LR-STP-WL-7R309F90001#1 will be updated to highlight the six pipingsections (locations D-1, C-4, C-7, E-7, E-8, and H-8) red for 10 CFR 54.4(a)(2) spatial interactionto agree with boundary drawing LR-STP-WL-7R309F90001#2.
EnclosureNOC-AE-1 1002702Page 25 of 30Section 2.3.3.23 Radioactive Vents and DrainsRAI 2.3.3.23-01LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included in scope of license renewal. The staff confirms theinclusion of all components subject to AMR by reviewing the results of the screening ofcomponents within the license renewal boundary.LRA drawings LR-STP-ED-5Q069F05030 #1 and #2 coordinates A-7 and F-4 depict Mech. Aux.Bldg. Elevator No. 5 Sump Pump 90061 NPA1 15A and Fuel Handling Building Sump No.3 sumppump 90061 NPA1 09A casing and discharge piping as not within the scope of license renewal.However, the same drawings depict similar sump pumps and their associated casings anddischarge piping as within the scope of license renewal for 10 CFR 54.4(a)(2).The staff requests the applicant provide the basis for excluding the pump No. 90061 NPA1 15Acasings and discharge piping from the scope of license renewal.STPNOC ResponseMechanical Auxiliary Building elevator No. 5 sump pump 9Q061 NPA1 15A is located in a roomthat contains no safety-related components, so no 10 CFR 54.4(a)(2) spatial interaction exists inthat sump area. The SI hexagon is appropriately shown.The Fuel Handling Building Sump No. 3 sump pump 9QO61NPA109A is located in a room thatcontains no safety-related components so no 10 CFR 54.4(a)(2) spatial interaction exists in thatsump area. The SI hexagon is appropriately shown.RAI 2.3.3.23-02LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included in scope of license renewal. The staff confirms theinclusion of all components subject to AMR by reviewing the results of the screening ofcomponents within the license renewal boundary.LRA drawings LR-STP-ED-7Q069F90016 #1 and #2 coordinates D-1, depict ten 3" pipe sections(ED1 120TC7) within the scope of license renewal continuing to LRA drawings LR-STP-ED-5Q069F05030 #1 and #2 coordinates E-4, where they are shown as not within the scope oflicense renewal.The staff requests the applicant provide the basis for the difference in scoping classification ofthese pipe sections.STPNOC ResponseThe green highlighting shown on boundary drawings LR-STP-ED-7Q069F90016#1 & #2indicates drain components within the scope of license renewal for 10 CFR 54.4(a)(3) only.Therefore, a 10 CFR 54.4(a)(2) evaluation is not required for structural integrity attached.
EnclosureNOC-AE-1 1002702Page 26 of 30The continuation piping on boundary drawings LR-STP-ED-7Q069F90016#1 & #2 (locationC-l/D-1) is inadvertently highlighted red for spatial interaction. Boundary drawingsLR-STP-ED-5Q069F05030#1 and #2 (location E-5) correctly show an SI hexagon indicatingtermination of spatial interaction prior to the piping continuation to boundary drawingsLR-STP-ED-7Q069F90016#1 & #2 (location C-l/D-l) because the piping is routed from a roomcontaining safety-related equipment to a room that does not contain safety-related equipment.Boundary drawings LR-STP-ED-7Q069F90016#1 & #2 (location C-l/D-l) will be updated toremove the red highlighting from lines 3ED1 120TC7 and 3ED2120TC7.Section 2.3.3.26 Radiation Monitoring (Area and Process) MechanicalRAI 2.3.3.26-01In LRA Section 2.1 the applicant states that its screening process was used to identify thepassive, long-lived structures and components within the scope of license renewal and subject toAMR. The staff confirms inclusion of all components subject to an AMR by reviewing componenttypes within the license renewal boundary.LRA drawings LR-STP-HE-5V1 19V250003 #1 and #2 coordinates F-5, D-5, and B-5, depictcarbon filter spray nozzles. The spray nozzle component type is not included in AMR Table2.3.3-26.The staff requests the applicant provide the basis for excluding the spray nozzle component typefrom LRA Table 2.3.3-26.STPNOC ResponseThe carbon filter spray nozzles are in-scope for fire protection. The nozzles are not included inTables 2.3.3-26 or 2.3.3-10 but have been scoped as fire protection and are included in Table2.3.3-17. The carbon filter spray nozzles are generic components with a component type of"piping" with an intended function of "spray."2.3.4 Steam and Power Conversion SystemsSection 2.3.4.1 Main SteamRAI 2.3.4.1-01LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included within the scope of license renewal. The staffconfirms the inclusion of all components subject to AMR by reviewing the results of thescreening of components within the license renewal boundary.LRA drawings LR-STP-MS-5S109F00016 #1 and #2 coordinates C-6, E-6, F-6, and H-6, depictpiping downstream of the silencers as not within the scope of license renewal (total of 8examples). These pipe sections appear to be part of the main steam system, which is depictedas being within the scope of license renewal for 10 CFR 54.4(a)(2).
EnclosureNOC-AE-1 1002702Page 27 of 30The staff requests the applicant provide the basis of the scoping classification of these pipesections.STPNOC ResponseBoundary drawings LR-STP-MS-5S109F00016#1/#2 inadvertently do not show the small pieceof piping that extends from the silencers as in scope for 10 CFR 54.4(a)(2). The silencer pipingboth inside and outside the building is within the scope of license renewal.Boundary drawings LR-STP-MS-5S109F00016#1 & #2 (locations C-6, E-6, F-6, and H-6) will beupdated to highlight the piping downstream of the silencers red for 10 CFR 54.4(a)(2).RAI 2.3.4.1-02LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included within the scope of license renewal. The staffconfirms the inclusion of all components subject to AMR by reviewing the results of thescreening of components within the license renewal boundary.LRA drawings LR-STP-MS-5S101Z51002 and LR-STP-MS-5S 102Z51002, lists manycomponents of the main steam power operated relief valve -hydraulic system along the bottomof the drawing. However, the desiccant breather is not listed in LRA Table 2.3.4-1.The staff requests that the applicant provide the basis for excluding the desiccant breathercomponent type from LRA Table 2.3.4-1.STPNOC ResponseThe desiccant breather is included in the scope of license renewal. Component type "filter"includes the dessicant breather component which is included in Table 2.3.4-1. However, uponfurther review it was noted that the breather was inadvertently identified as steel. The breatheris actually made of stainless steel. Adding a stainless steel filter with a lube oil internalenvironment and plant indoor air external environment will change Table 3.4.2-1.A new component line will be added for a "stainless steel filter with a lube oil internalenvironment and plant indoor air external environment" for the main steam system.Table 3.4.2-1 will be updated to reflect the additional filter component.Section 2.3.4.2 Auxiliary Steam System and BoilersRAI 2.3.4.2-01LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included within the scope of license renewal. The staffconfirms the inclusion of all components subject to AMR by reviewing the results of thescreening of components within the license renewal boundary.LRA drawing LR-STP-WL-5R309F05027 #2 coordinates G-4, depicts 2" piping WL2586XC7within the scope of license renewal under 10 CFR 54.4(a)(2) continuing to EnclosureNOC-AE-1 1002702Page 28 of 30LR-STP-WL7R309F05026 #2 coordinates E-6, where it is depicted as not within the scope oflicense renewal.The staff requests the applicant provide the basis for the different scoping classifications for thispipe section.STPNOC ResponseBoundary drawing LR-STP-WL-5R309F05027#2 inadvertently omits a spatial interactiontermination symbol at location G-4 at the continuation for the 2" piping WL2586XC7. The piping(2" WL2586XC7) leaves room 67C that contains safety-related components and enters room53B with no safety-related components.Boundary drawing LR-STP-WL-5R309F05027#2 (location G-4) will be updated to add an SIhexagon terminal component symbol to 2" piping WL2586XC7 prior to the off sheet connector toboundary drawing LR-STP-WL-7R309F05026#2.Section 2.3.4.4 Demineralizer Water (Make-Up)RAI 2.3.4.4-01LRA drawing LR-STP-SYMBOLS contains a note for the 10 CFR 54.4 (a)(2) termination symbol,F.4.e, which states: "Point where Buried piping exits the ground -buried portion of pipe inscope."LRA drawings LR-STP-DW-5S1999F05034 #1 and #2 coordinates B-6 depict 10 CFR 54.4(a)(2)lines 4" DWO018WD9 continuing to drawing LR-STP-NL-6S190F00009 coordinates E-2 andB-2, where the underground piping is shown as not within the scope of license renewal. Thetermination symbol F.4.e at coordinates B-6 indicates that all underground piping is within thescope of license renewal. Also, during the Scoping and Screening Audit on May 16 through May20. 2011, the applicant indicated that there were similar instances in which portions of buriedpiping in other systems were removed from scope of license renewal.The staff requests the applicant provide the basis for not including the entire undergroundportion of the pipe section described above within the scope of license renewal. The staff alsorequests the applicant identify and provide the basis for the other portions of buried pipingremoved from scope of license renewal.STPNOC ResponseThe termination symbol and location used for pipe 4DWO018WD9 on boundary drawingLR-STP-DW-5S199F05034#1 & #2 (location B-6) is incorrect. The piping and components inthis pipe line are not in-scope for 10 CFR 54.4(a)(2). The termination should be a hexagonal"SI" symbol where the piping enters the ground in the MEAB. Therefore, the termination locationand termination symbol on boundary drawings LR-STP-DW-5S199F05034#1 & #2 are incorrect.Boundary drawings LR-STP-DW-5S199F05034#1 & #2 (location B-6) will be updated to replacethe F.4.e triangle with the hexagon "Sr" symbol and show the termination at the point the pipinggoes underground. Pipe 4DWO018WD9 will be changed to black indicating it is not within thescope of license renewal.
EnclosureNOC-AE-1 1002702Page 29 of 30Buried piping was re-evaluated in February 2011 as part of implementing buried pipingrequirements associated with GALL Rev 2 AMP XI.M41. The re-evaluation allowed removal ofseveral sections of buried piping from the scope of license renewal. As a result, boundarydrawing LR-STP-NL-6S190F00009 is no longer needed since the highlighted piping on thedrawing is no longer in-scope.Section 2.3.4.6 Auxiliary FeedwaterRAI 2.3.4.6-01LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included within the scope of license renewal. The staffconfirms the inclusion of all components subject to AMR by reviewing the results of thescreening of components within the license renewal boundary.LRA drawing LR-STP-AF-5S142F00024-1 coordinates H-7 depicts Auxiliary Feedwater PumpNo. 24 3S142MPA04 1" vent piping and associated isolation valves AF0129 and AF0130 as notwithin the scope of license renewal. However, the same drawing depicts the pump vent lines andassociated isolation valves coordinates F-7. D-7, and B-7, for Auxiliary Feedwater Pumps No. 213S142MPA01, No. 22 3S142MPA02, and No. 23 3S142MPA03 as within the scope of licenserenewal for 10 CFR 54.4(a)(1) or (a)(3).The staff requests the applicant provide the basis for excluding pump No. 24 3S142MPA04 ventpiping and associated isolation valves from the scope of license renewal.STPNOC ResponseThe auxiliary feedwater Pump No. 24 3S142MPA04 1" vent piping and associated isolationvalves AF0129 and AF0130 shown on Boundary Drawing LR-STP-AF-5S142F00024-1 aresafety-related but are inadvertently highlighted black (denotes not in scope). Safety-relatedvalves AF0129 and AF0130 and upstream piping are currently in scope as 10 CFR 54.4(a)(1)and should be highlighted green. The non-safety-related vent piping downstream of valvesAF0129 and AF0130 is in scope as 10 CFR 54.4(a)(2) and should be highlighted red.Boundary drawing LR-STP-AF-5S142F00024-1 (location H-7) will be updated to highlight valvesAF0129 and AF0130 and upstream piping "green" for 10 CFR 54.4(a)(1) and highlight the non-safety-related vent piping downstream of valves AF0129 and AF0130 "red" for10 CFR 54.4(a)(2).RAI 2.3.4.6-02LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included within the scope of license renewal. The staffconfirms the inclusion of all components subject to AMR by reviewing the results of thescreening of components within the license renewal boundary.LRA drawing LR-STP-AF-5S142F00024-1 coordinates H-7, F-7, D-7, and B-7, depict AuxiliaryFeedwater Pump 1" vent piping and associated isolation valves. However, Unit 1 LRA drawingLR-STP-AF-5S141F00024-1 coordinates H-7, F-7, D-7 and B-7 do not include AuxiliaryFeedwater Pump vent piping details.
EnclosureNOC-AE-1 1002702Page 30 of 30The staff requests the applicant to confirm that there are no vent piping and associated isolationvalves on the Unit 1 Auxiliary Feedwater Pumps.STPNOC ResponseThere are no vent valves installed on the Unit 1 Auxiliary Feedwater Pumps. The Unit 1 pipingand instrumentation drawing 5S141 F00024 confirms that the vent piping and valves for theAuxiliary Feedwater Pumps are not installed. In addition, the South Texas Project MechanicalEquipment Database (MED) confirms that the vent valves are not installed.RAI 2.3.4.6-03LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems orcomponents were determined to be included within the scope of license renewal. The staffconfirms the inclusion of all components subject to AMR by reviewing the results of thescreening of components within the license renewal boundary.LRA drawings LR-STP-AF-5S141F00024-1 and LR-STP-AF-5S142F00024-1 coordinates G-7,depict the auxiliary feedwater pump turbine attached to the turbine-driven auxiliary feedwaterpump, which are both within the scope of license renewal under 10 CFR 54.4(a)(1). However,the LRA drawings also depict solid black lines in between the two components, which are nothighlighted in scope of license renewal.The staff requests the applicant provide the basis for excluding these black lines from the scopeof license renewal.STPNOC ResponseBoundary drawings LR-STP-AF-5S141F00024-1 and LR-STP-AF-5S142F00024-1 (G-7) depictthe auxiliary feedwater pump turbine attached to the turbine-driven auxiliary feedwater pump bya mechanical shaft. The pump, turbine, and mechanical shaft are all safety-related and are in-scope as 10 CFR 54.4(a)(1). The shaft is integral to the pump and is scoped as part of thepump. The shaft is an active non-pressure boundary component, and therefore does not requireaging management review. The shaft should have been highlighted green but the greenhighlight was inadvertently omitted. Boundary drawings LR-STP-AF-5S141F00024-1 and LR-STP-AF-5S142F00024-1 will be revised to highlight the in-scope turbine-driven auxiliaryfeedwater pump shaft green for10 CFR 54.4(a)(1).