ML032461333
| 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
SUBJECT:
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
Enclosure 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
May 2003 South Texas Project, Unit 1 and Unit 2 cc:
Mr. Cornelius F. OKeefe Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 910 Bay City, TX 77414 A. Ramirez/C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704 Mr. L. K. Blaylock Mr. W. C. Gunst City Public Service Board P. O. Box 1771 San Antonio, TX 78296 Mr. C. A. Johnson/A. C. Bakken AEP Texas Central Company P. O. Box 289 Mail Code: N5022 Wadsworth, TX 77483 INPO Records Center 700 Galleria Parkway Atlanta, GA 30339-3064 Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 D. G. Tees/R. L. Balcom Texas Genco, LP P. O. Box 1700 Houston, TX 77251 Judge, Matagorda County Matagorda County Courthouse 1700 Seventh Street Bay City, TX 77414 A. H. Gutterman, Esq.
Morgan, Lewis & Bockius 1111 Pennsylvania Avenue, NW Washington, DC 20004 Mr. T. J. Jordan, Vice President Engineering & Technical Services STP Nuclear Operating Company P. O. Box 289 Wadsworth, TX 77483 S. M. Head, Manager, Licensing Nuclear Quality & Licensing Department STP Nuclear Operating Company P. O. Box 289, Mail Code: N5014 Wadsworth, TX 77483 Environmental and Natural Resources Policy Director P. O. Box 12428 Austin, TX 78711-3189 Jon C. Wood Matthews & Branscomb 112 East Pecan, Suite 1100 San Antonio, TX 78205 Arthur C. Tate, Director Division of Compliance & Inspection Bureau of Radiation Control Texas Department of Health 1100 West 49th Street Austin, TX 78756 Brian Almon Public Utility Commission William B. Travis Building P. O. Box 13326 1701 North Congress Avenue Austin, TX 78701-3326
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