ML032461333

Meeting with South Texas Project, Units 1 & 2 Staff Review Issues with STP Proposed Risk-Informed Inservice Testing Program

ML032461333
Person / Time
Site:	South Texas
Issue date:	09/02/2003
From:	Gramm R NRC/NRR/DLPM/LPD4
To:
Jaffe D, NRR/DLPM, 415-1439
References
TAC MB8948, TAC MB8949
Download: ML032461333 (8)

Text

September 2, 2003 LICENSEE: STP Nuclear Operating Company FACILITY: South Texas Project, Unit 1and Unit 2

SUMMARY

OF HEADQUARTERS AND SOUTH TEXAS PROJECT NUCLEAR OPERATING COMPANY TELEPHONE CONFERENCE CALL OF JULY 31, 2003, REGARDING STAFF REVIEW ISSUES WITH THE SOUTH TEXAS PROJECT PROPOSED RISK-INFORMED INSERVICE TESTING PROGRAM (TAC NOS. MB8948 AND MB8949)

On July 31, 2003, the U. S. Nuclear Regulatory Commission (NRC) Headquarters staff held a telephone conference call with STP Nuclear Operating Company (STPNOC), the licensee for South Texas Project (STP), Units 1 and 2. Enclosed is a list of participants. The purpose of the telephone conference call was to provide STP with the substantive review concerns that the staff has identified with their Risk-Informed Inservice testing (RI-IST) submittal.

The first major concern relates to the methodology that STP has employed to determine the safety-significance of components within the scope of inservice testing. Based on the information provided in the November 8, 2002, submittal, the staff does not feel that the STP approach conforms with existing staff guidance in Regulatory Guide (RG) 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," nor with RG 1.175, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Inservice Testing." In addition, the STP approach is not consistent with the American Society of Mechanical Engineers Code Case OMN3, "Requirements for Safety Significance Categorization of Components using Risk Insights for Inservice Testing of LWR Power Plants" and the latest Nuclear Energy Institute (NEI) draft (revision C) of NEI 00-04, "10 CFR 50.69 SSC Categorization Guideline." The STP proposed approach is substantially different from what the staff has previously approved, as the staff has endorsed component level categorization, that collectively considers the importance of the applicable component failure modes, but not categorization based on the individual failure mode importance as proposed by STP. Furthermore, the STP RI-IST submittal does not reconcile the different component categorization results arrived at by the exemption expert panel as opposed to the RI-IST expert panel, especially when the components categorization was not based on the risk analysis.

The second major concern relates to the treatment that will be applied to RI-IST low safety significant components to provide confidence that the components will remain functional throughout the proposed test interval. RG 1.175, the other approved RI-IST pilot plant programs, and the STP special treatment exemption all dictate that the assumption of presumed functionality needs to be substantiated through the conduct of testing that collects data or information that allows evaluation of operating characteristics to support the extended test intervals.

The staff also explained to STP that several other concerns exist with the proposed RI-IST program as communicated via the NRC letter dated May 29, 2003 (ADAMs ML031490352),

which would also need to be satisfactorily resolved. The more significant of these concerns were discussed with STP during a telephone conference call on July 2, 2003.

The NRC then outlined that there are 3 paths to move forward on this licensing action: 1) for STP to withdraw the submittal, 2) for STP to make substantive modifications to the submittal to address the staffs concerns, or 3) for STP to request the staff to continue to review the amendment as it currently stands. The NRC informed STP that if option 3 were chosen, this would encounter major difficulties in continued review and would not likely result in the staff finding the proposed RI-IST program acceptable. STP indicated that they would probably desire to hold a meeting with the staff as a next step.

The telephone conference call ended with the STP staff indicating that the RI-IST concerns would be dealt with once the unit had recovered from the bottom mounted instrumentation penetration outage. The STP personnel indicated they would make a decision in the next couple of weeks as to how they intended to respond to the NRC staffs issues.

/RA/

Robert A. Gramm, Chief, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499

Enclosure:

As stated cc w/encl: See next page

ML032461333 NRC-001 OFFICE PDIV-1/SECY PDIV-1/SC PDIV NAME DBaxley RGramm HBerkow DATE 9 / 02 /2003 9 / 02 /2003 9 / 02 /2003 LIST OF PARTICIPANTS STPNOC/NRC TELEPHONE CONFERENCE JULY 31, 2003 Licensees Participants S. Head G. Schinzel M. Lashley W. Stilwell P. Walker B. Scott NRC Participants L. Marsh R. Gramm E. Imbro D. Harrison D. Fischer M. Thadani T. Scarbrough D. Terao M. TSchiltz Enclosure

South Texas Project, Unit 1 and Unit 2 cc:

Mr. Cornelius F. OKeefe A. H. Gutterman, Esq.

Senior Resident Inspector Morgan, Lewis & Bockius U.S. Nuclear Regulatory Commission 1111 Pennsylvania Avenue, NW P. O. Box 910 Washington, DC 20004 Bay City, TX 77414 Mr. T. J. Jordan, Vice President A. Ramirez/C. M. Canady Engineering & Technical Services City of Austin STP Nuclear Operating Company Electric Utility Department P. O. Box 289 721 Barton Springs Road Wadsworth, TX 77483 Austin, TX 78704 S. M. Head, Manager, Licensing Mr. L. K. Blaylock Nuclear Quality & Licensing Department Mr. W. C. Gunst STP Nuclear Operating Company City Public Service Board P. O. Box 289, Mail Code: N5014 P. O. Box 1771 Wadsworth, TX 77483 San Antonio, TX 78296 Environmental and Natural Resources Mr. C. A. Johnson/A. C. Bakken Policy Director AEP Texas Central Company P. O. Box 12428 P. O. Box 289 Austin, TX 78711-3189 Mail Code: N5022 Wadsworth, TX 77483 Jon C. Wood Matthews & Branscomb INPO 112 East Pecan, Suite 1100 Records Center San Antonio, TX 78205 700 Galleria Parkway Atlanta, GA 30339-3064 Arthur C. Tate, Director Division of Compliance & Inspection Regional Administrator, Region IV Bureau of Radiation Control U. S. Nuclear Regulatory Commission Texas Department of Health 611 Ryan Plaza Drive, Suite 400 1100 West 49th Street Arlington, TX 76011 Austin, TX 78756 D. G. Tees/R. L. Balcom Brian Almon Texas Genco, LP Public Utility Commission P. O. Box 1700 William B. Travis Building Houston, TX 77251 P. O. Box 13326 1701 North Congress Avenue Judge, Matagorda County Austin, TX 78701-3326 Matagorda County Courthouse 1700 Seventh Street Bay City, TX 77414 May 2003

South Texas Project, Unit 1 cc:

Susan M. Jablonski Office of Permitting, Remediation and Registration Texas Commission on Environmental Quality MC-122 P.O. Box 13087 Austin, TX 78711-3087 Mr. Terry Parks, Chief Inspector Texas Department of Licensing and Regulation Boiler Division P. O. Box 12157 Austin, TX 78711 Mr. Ted Enos 4200 South Hulen Suite 630 Ft. Worth, Texas 76109 Mr. James J. Sheppard President and Chief Executive Officer STP Nuclear Operating Company South Texas Project Electric Generating Station P. O. Box 289 Wadsworth, TX 77483