ML033421309

Stars - Summary of Meeting Held on 10/30/03 - Integrated Regulatory Affairs Group for the Licensees of Callaway, Comanche Peak, Diablo Canyon, South Texas and Wolf Creek

ML033421309
Person / Time
Site:	Wolf Creek, Diablo Canyon, Callaway, South Texas, Comanche Peak
Issue date:	12/08/2003
From:	Donohew J NRC/NRR/DLPM/LPD4
To:
Donohew J N, NRR/DLPM,415-1307
Shared Package
ML033421343	List: ML033421309
References
Download: ML033421309 (20)

Text

December 8, 2003 LICENSEES: Union Electric Company TXU Electric Pacific Gas and Electric Company STP Nuclear Operating Company Wolf Creek Nuclear Operating Corporation FACILITIES: Callaway Plant Comanche Peak Steam Electric Station Diablo Canyon Power Plant South Texas Project Electric Generating Station Wolf Creek Generating Station

SUBJECT:

MEETING WITH STRATEGIC TEAMING AND RESOURCE SHARING -

INTEGRATED REGULATORY AFFAIRS GROUP FOR THE LICENSEES OF CALLAWAY, COMANCHE PEAK, DIABLO CANYON, SOUTH TEXAS, AND WOLF CREEK A meeting was held on Thursday, October 30, 2003, between the NRC staff and the licensees for the above facilities. The meeting was held at the request of the Strategic Teaming and Resource Sharing - Integrated Regulatory Affairs Group (STARS-IRAG) that has been formed by the licensees. The IRAG is a group within STARS to interact with the NRC staff on common regulatory issues for the facilities. The goal of STARS-IRAG is to reduce the overall financial/manpower costs of licensing actions to the licensees and to the NRC staff by developing common licensing action requests. The notice for the meeting was issued on October 15, 2003. is the list of attendees and Attachment 2 is the handout provided by the NRC staff at the meeting. The licensees did not provide a handout at the meeting. Attachment 3 is the list of the follow-up items from the June 10-11, 2003, STARS/NRC workshop. There was no discussion of any current licensing actions under NRC staff review for any of the above facilities.

BACKGROUND On June 10 and 11, 2003, the NRC conducted a workshop with the STARS-IRAG in which the NRC discussed the following issues with the licensees to help each other understand the others perspective:

 NRC Work Controls

 Managing Schedules to Support Plant Activities

 NRC Fees

 Quality of Licensing Actions Submittals

 Quality and Role of NRC Safety Evaluations

 NRC Task Interface Agreements

 NRC Bulletin 2002-01 Request for Additional Information

 Safety Conscious Work Environment

 Informal Communications Between NRC and Licensees

 Submittals Associated with Security Issues

 Making Changes to Orders

 Perry Decision

 10 CFR 50.59 Revised Rule The summary of the workshop was issued by the NRC staff on July 18, 2003 (ADAMS Accession No. ML031980013). In the meeting summary, the NRC staff listed seven items identified at the workshop that the NRC and licensees staffs agreed to pursue as follow-up items. These items are given on the second page in Attachment 2 and, in more detail, in from the summary of the workshop issued July 18, 2003.

MEETING The purpose of the meeting was to address the seven follow-up items from the June 10 and 11, 2003, workshop. The licensees had requested that a discussion on the license amendment process for their common applications be added to the seven follow-up items. Therefore, the agenda for the meeting, given in the meeting notice, was the following:

 Introduction

 STARS Items from June 10-11, 2003, Workshop

 NRC Items from June 10-11, 2003, Workshop

 License Amendment Process for STARS Common Applications

 Conclusion A brief discussion of each of the seven follow-up items follows.

1. NRC Requests for Additional Information (RAIs): The process for generating RAIs within the NRC technical branches will be codified within the Office of Nuclear Reactor Regulation (NRR)/NRC procedures to assure that the NRC staffs questions in RAIs have a regulatory basis. The licensees may, at any time, question the regulatory basis for RAIs and the meaning of the RAI questions by contacting their plant project managers with their questions. These questions will be answered promptly and to the satisfaction of the licensees, or the licensees may contact the project mangers section chief within the Division of Licensing Project Management (DLPM)/NRR/NRC. This item is closed.

2. Legal Status of Licensees E-mail Restriction Footer: E-mails are being used by the NRC and the licensees to promptly exchange information used to clarify licensees (1) submittals on proposed licensing actions, and (2) responses to generic communications issued by the NRC. The licensees stated that they did not intend the footers, which have language restricting the use of the information, to prevent the NRC from using the information. Also, not all of the STARS-IRAG licensees are using such a footer in their e-mails to NRC. One licensee has removed the footer when information is being e-mailed to NRC. In another licensees case, the footer refers to the information as being intended only for the "intended recipient" (i.e., the NRC in the case of information

being sent to the NRC) and the use of "intended recipient" in the footer should allow the NRC to use the information freely with no restrictions. However, the licensee may state this in a letter to the NRC so that there is no confusion on the NRCs part. This item is not closed while the one licensee is considering sending a letter to NRC about the footer in its e-mails to the NRC.

3. Current Guidance on Sensitive Unclassified Information: The NRC has included some additional material in this class of information since the events of September 11, 2001; however, the NRC has not issued any guidance to licensees on this subject. There is a Regulatory Information Summary (RIS) in the works which is waiting for decisions by the Commission before it may be issued. This RIS would also refer to information restrictions affecting nuclear power plants from other Federal Government agencies, including the Federal Energy Regulatory Commission and the Environmental Protection Agency. This item is closed.

4. Spent Fuel Project Office (SFPO) Use of Office Instructions: The SFPO has decided not to make its office instructions publicly available; however, the office will discuss their review process with licensees in a public meeting requested by a licensee. This item is closed.

5. Design Basis Threat (DBT) Order More Restrictive Than Interim Compensatory Measures (ICMs) in Security Plan Orders: Paragraph D of the ICM Order issued February 25, 2002, states that "Notwithstanding the provisions of 10 C.F.R. § 50.54(p),

all measures implemented or actions taken in response to this Order shall be maintained pending notification from the Commission that a significant change in the threat environment occurs, or until the Commission determines that other changes are needed following a comprehensive reevaluation of current safeguards and security programs." The requirements in the ICM Order were not made part of the security plan (i.e., the order did not require changes to security plans) and, therefore, do not come under the provisions of 10 CFR 50.54(p) for changes to security plans. Licensees' security plans, including the ICMs as may be modified by later orders, are to be submitted in accordance with the DBT Order to be reviewed and approved by the NRC.

Following NRC approval of the revised security plans, the security plans may then be changed in accordance with 10 CFR 50.54(p). This item is closed.

6. Relaxation of Security Plan Orders per 10 CFR 50.54(p): See the previous discussion on Item 5 on the ICM Security Plan Order. The regulation, 10 CFR 50.54(p)(2), allows a licensee to make changes to its safeguards contingency, or security, plan without prior Commission approval "if the changes do not decrease the safeguards effectiveness of the plan." The use of the word "relaxation" in the description of this item is incorrect because "relaxation" implies the change could decrease the safeguards effectiveness of the plan and, by 10 CFR 50.54(p)(2), the change would require prior Commission approval to be implemented. This item is better stated as "Modification of Security Plans Orders per 10 CFR 50.54(p)." An order by the Commission, per 10 CFR 2.202, modifies, suspends, or revokes a license. The modification may be to the security plan for the licensee's plant(s). The implementation of a security plan order is required, like any order, unless the Commission approves changes to that order; however, once the order has been implemented and the implementation is by a change to the security plan,

the security plan may then be changed in accordance with 10 CFR 50.54(p)(2). This item is closed.

7. NRC Concerns on Implementation of Revised 10 CFR 50.59 Rule: The 50.59 Rule, "Changes, tests, and experiments," was revised in 1999 to allow licensees, among other things, to apply safety evaluations, which had been issued by the NRC staff to approve licensing actions for other plants, to their plants if the evaluations could be shown to apply to their plants. In discussions held in February 2003 among Region IV, NRC headquarters, and the licensee for the Palo Verde Nuclear Generating Station on the upgrade modification of the spent fuel pool (SFP) crane so that it could carry the spent fuel casks for the transport of spent fuel from the SFP to the onsite independent spent fuel storage installation (ISFSI), the NRC accepted the licensees use of 10 CFR 50.59 applying amendments issued to other licensees for the similar upgrade of the SFP crane. However, NRC individuals on the conference call also expressed an interest (1) to further investigate the licensees use of 10 CFR 50.59 for what in the past (particularly before the revised 50.59 rule) has been an amendment request that had to be reviewed and approved by the NRC and (2) perhaps issue a generic communication addressing the current use of the new 50.59 rule, using the Palo Verde SFP crane upgrade modification as an example. Since the discussions in February 2003, the NRC staff has conducted internal discussions on the Palo Verde example of using 50.59 and decided not to issue such generic communication. This item is closed.

Item 2 remains open.

The last part of the meeting was a discussion on the STARS-IRAG joint submittals whereby several or all the licensees request the same or similar license amendments. Examples of this are the following:

 Changes to Technical Specification (TS) 3.8.1/3.8.4, "AC/DC Sources - Operating,"

submitted by Callaway, Diablo Canyon, Palo Verde, and Wolf Creek.

 Changes to TS 5.5.6, "Containment Tendon Surveillance Program," and TS 5.5.16, "Containment Leakage Rate Testing Program," submitted by Palo Verde and Wolf Creek, with Callaway to submit an amendment request in December 2003.

The licensees requested suggestions for them to make the submittal and review process more efficient (i.e., fewer resources needed) for both themselves and the NRC staff. The NRC staff stated that the lead project manager (LPM) for STARS-IRAG is myself, Jack Donohew, and I should be kept aware of when future joint submittals will be made. The NRC will consider having an LPM assigned for each joint submittal to have either (1) one point of contact with the technical branches doing the review, or (2) that person do the review, write the evaluation, and seek concurrence from the appropriate technical branches. For the first joint submittal review listed above, there is a LPM working with the electrical branch. For the second joint submittal review, there is a LPM who will do the review and write the evaluation for the license amendments.

The licensees and the NRC staff completed their presentations and the meeting was adjourned.

/RA/

Jack N. Donohew, Senior Project Manager, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-275, 50-323, 50-445, 50-446, 50-482, 50-483, 50-498, and 50-499 Attachments: 1. List of Meeting Attendees

2. NRC Handout

3. Follow-up Items from June 10-11, 2003, STARS/NRC Workshop cc w/atts: See next page

The licensees and the NRC staff completed their presentations and the meeting was adjourned.

/RA/

Jack N. Donohew, Senior Project Manager, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-275, 50-323, 50-445, 50-446, 50-482, 50-483, 50-498, and 50-499 Attachments: 1. List of Meeting Attendees

2. NRC Handout

3. Follow-up Items from June 10-11, 2003, STARS/NRC Workshop cc w/atts: See next page DISTRIBUTION:

PUBLIC PDIV-2 Reading RidsNrrDlpmPdiv (HBerkow)

RidsNrrSCRGramm RidsNrrPMJDonohew RidsNrrPMMThadani RidsNrrPMDJaffe RidsNrrPMGShukla RidsNrrLaEPeyton WReckley SMorris, NSIR DGraves, RIV WJohnson, RIV LSmith, RIV RidsOgcRp RidsACRSACNWMailCenter JClark, EDO TMensha JGoldberg, OGC, reviewed the meeting summary and provided comments.

PKG. ML033421343 MEETING NOTICE: ML032870296 ACCESSION NO. ML033421309 NRC-001 OFFICE PDIV-2/PM PDIV-2/LA NSIR/RSS/SC PDIV-1/SC PDIV-2/SC NAME JDonohew EPeyton SMorris* RGramm SDembek DATE 11/13/03 11/14/03 11/06/2003 11/14/03 11/14/03 DOCUMENT NAME: C:\ORPCheckout\FileNET\ML033421309.wpd OFFICIAL RECORD COPY

LIST OF ATTENDEES AT MEETING OF OCTOBER 30, 2003 STARS-IRAG/NRC MEETING NAME AFFILIATION J. Donohew NRC/NRR/PDIV-2 H. Berkow NRC/NRR/PDIV R. Gramm NRC/NRR/PDIV-1 S. Dembek NRC/NRR/PDIV-2 G. Shukla NRC/NRR/PDIV-2 M. Thadani NRC/NRR/PDIV-1 D. Jaffe NRC/NRR/PDIV-1 W. Reckley NRC/NRR/PDIV-1 S. Morris NRC/NSIR/RSS D. Woodlan STARS-IRAG D. Shafer Ameren UE S. Ketelson PG&E K. Tapuett STPNOC F. Madden TXU Electric Where: NRC = Nuclear Regulatory Commission NRR = Office of Nuclear Reactor Regulation NSIR = Office of Nuclear Security and Incident Response PDIV-x = Project Directorate IV- Section x RSS = Reactor Security Section AmerenUE = Ameren Union Electric Company PG&E = Pacific Gas and Electric Company STPNOC = South Texas Project Electric Generating Station STARS-IRAG = Strategic Teaming And Resource Sharing - Integrated Regulatory Affairs Group ATTACHMENT 1

AGENDA - STARS/NRC MEETING OCTOBER 30, 2003

• Introduction

• STARS Items From June 10-11, 2003, Workshop*

• NRC Items From June 10-11, 2003, Workshop PUBLIC COMMENT

• License Amendment Process for STARS Common Applications PUBLIC COMMENT

• Conclusion

• The workshop meeting summary was issued July 18, 2003 (ADAMS No. ML031980013).

ATTACHMENT 2

October 14, 2003 STARS/NRC WORKSHOP FOLLOW-UP ITEMS No. Description Lead Person

1. NRC Request for Additional Information Gramm (RAI) Process: The licensees stated that they wanted to better understand the RAI process followed at the NRC on the approval of information to be requested from licensees.

2. Legal Status of Licensees E-mail STARS Restriction Footer: The NRC staff pointed out that e-mails from licensees to the NRC may have an automatic footer that provides a statement similar to the following: "The information contained in this message may be privileged and/or confidential and protected from disclosure. Note that any views or opinions presented in this message are solely those of the author and do not necessarily represent those of

[the licensee]."

3. Current Guidance on Sensitive Unclassified Jaffe Homeland Security Information (SUSHI):

The licensees requested that there be guidance provided to the licensees on the identification and handling of SUSHI.

4. Spent Fuel Project Office (SFPO) Use of Dembek Office Instructions: During discussions, it was noted by the licensees that SFPO does not use the same type of office instructions used by the Office of Nuclear Reactor Regulation (NRR).

5. Design Basis Threat (DBT) Order More Donohew Restrictive than Interim Compensatory RIS soon on "Licensee Changes to Measures (ICMs) in Security Plan Orders: Safeguards and Security The licensees stated that there are conflicts Compensatory Measures introduced by the security orders in that the Implementation" to provide conditions language of the later DBT Order may be under which licensees may modify more restrictive than the earlier ICM Order. site-specific actions for implementation.

6. Relaxation of Security Plan Orders per Donohew 10 CFR 50.54(p): The licensees suggested that changes should be able to be made to these Orders under 10 CFR 50.54(p)(2), in that the regulation allows for security plans to be changed without prior Commission approval if the changes do not reduce the effectiveness of the plan.

7. NRC Concerns on Implementation of Donohew Revised 10 CFR 50.59 Rule: STARS-IRAG stated that it thought the NRC staff had concerns about how licensees had implemented and were using the revised rule.

FOLLOW-UP ITEMS FROM JUNE 10-11, 2003, STARS/NRC WORKSHOP

1. Follow-up on the NRC Request for Additional Information (RAI) Process: The licensees stated that they wanted to better understand the RAI process followed at the NRC on the approval of information to be requested from licensees. The licensees asked if it is appropriate for the reviewer and the PM, or a higher level within NRC, to approve information being requested. As part of this action, the licensees asked what the effect is of whether the RAI was documented in an e-mail to the licensee, or formally requested in a letter to the licensee. This was assigned to the NRC.

2. Legal Status of Licensees E-mail Restriction Footer: The NRC staff pointed out that e-mails from licensees to the NRC may have an automatic footer that provides a statement similar to the following: "The information contained in this message may be privileged and/or confidential and protected from disclosure. Note that any views or opinions presented in this message are solely those of the author and do not necessarily represent those of [the licensee]." The NRC staff stated that this causes problems with docketing information and with other activities the NRC is required to perform when information is received from licensees. The NRC staff requested that these footers not be attached to e-mails that are providing information from the licensee to the NRC. Also, the NRC staff stated that e-mails should not be used to send proprietary or confidential information on licensing actions to the NRC. This was assigned to the STARS.

3. Current Guidance on Sensitive Unclassified Homeland Security Information (SUSHI):

The licensees requested that there be guidance provided to the licensees on the identification and handling of SUSHI. The NRC staff stated that it understood that a Regulatory Information Summary involving SUSHI will be issued in the near future by the NRC. This was assigned to the NRC.

4. Spent Fuel Project Office (SFPO) Use of Office Instructions: During discussions, it was noted by the licensees that SFPO does not use the same type of office instructions used by the Office of Nuclear Reactor Regulation (NRR). It was suggested by the licensees that the SFPOs use of guidance similar to the NRR office instructions, which are well known, would help the licensees understand what is expected of them. This was assigned to the NRC.

5. Design Basis Threat (DBT) Order More Restrictive than Interim Compensatory Measures (ICMs) in Security Plan Orders: The licensees stated that there are conflicts introduced by the security orders in that the language of the later DBT Order may be more restrictive than the earlier ICM Order. The licensees explained that they believed that this restricts their ability to implement the DBT Order without NRC providing some sort of relief from the ICM Order. This was assigned to the NRC.

ATTACHMENT 3

6. Relaxation of Security Plan Orders per 10 CFR 50.54(p): The licensees suggested that changes should be able to be made to these Orders under 10 CFR 50.54(p)(2), in that the regulation allows for security plans to be changed without prior Commission approval if the changes do not reduce the effectiveness of the plan. Therefore, it appears that regulations provide a mechanism for the licensees to revise their security plans rather than to request a change to the Order. The NRC staff stated that the licensees would have to implement the Security Order and then may make a change that does not reduce the effectiveness of the security plan. It was also pointed out that a relaxation of a Security Order would not meet 10 CFR 50.54(p)(2). The licensees requested further clarification on the possible use of 10 CFR 50.54(p) to revise security plan requirements imposed through a Security Order. This was assigned to the NRC.

7. NRC Concerns on Implementation of Revised 10 CFR 50.59 Rule: STARS-IRAG stated that it thought the NRC staff had concerns about how licensees had implemented and were using the revised 10 CFR 50.59 rule. It is believed that a concern had been expressed by the NRC staff about the appropriateness of implementation of 10 CFR 50.59 in the discussions in February-March 2003 on the Palo Verde 50.59 modifications of its spent fuel pool crane to handle spent fuel to be transported to the site Independent Spent Fuel Storage Installation. The STARS-IRAG requested that if such concerns existed that they be discussed with the licensees. This was assigned to both the NRC and the STARS.

Callaway Plant, Unit 1 cc:

Professional Nuclear Consulting, Inc. Mr. Rick A. Muench 19041 Raines Drive President and Chief Executive Officer Derwood, MD 20855 Wolf Creek Nuclear Operating Corporation P.O. Box 411 John ONeill, Esq. Burlington, KA 66839 Shaw, Pittman, Potts & Trowbridge 2300 N. Street, N.W. Mr. Dan I. Bolef, President Washington, D.C. 20037 Kay Drey, Representative Board of Directors Coalition for the Mr. Mark A. Reidmeyer, Regional Environment Regulatory Affairs Supervisor 6267 Delmar Boulevard Regulatory Affairs University City, MO 63130 AmerenUE P.O. Box 620 Mr. Lee Fritz, Presiding Commissioner Fulton, MO 65251 Callaway County Court House 10 East Fifth Street U.S. Nuclear Regulatory Commission Fulton, MO 65151 Resident Inspector Office 8201 NRC Road Mr. David E. Shafer Steedman, MO 65077-1302 Superintendent, Licensing Regulatory Affairs Mr. Chris Younie AmerenUE Manager, Quality Assurance P.O. Box 66149, MC 470 AmerenUE St. Louis, MO 63166-6149 P.O. Box 620 Fulton, MO 65251 Mr. Keith D. Young Manager, Regulatory Affairs Manager - Electric Department AmerenUE Missouri Public Service Commission P.O. Box 620 301 W. High Fulton, MO 65251 P.O. Box 360 Jefferson City, MO 65102 Mr. Scott Clardy, Director Section for Environmental Public Health Regional Administrator, Region IV P.O. Box 570 U.S. Nuclear Regulatory Commission Jefferson City, MO 65102-0570 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Mr. Garry L. Randolph Vice President and Mr. Ronald A. Kucera Chief Nuclear Officer Deputy Director for Public Policy Union Electric Company Department of Natural Resources Post Office Box 620 P.O. Box 176 Fulton, MO 65251 Jefferson City, Missouri 65102

Comanche Peak Steam Electric Station cc:

Mr. Brian Almon Senior Resident Inspector Public Utility Commission U.S. Nuclear Regulatory Commission William B. Travis Building P. O. Box 2159 P. O. Box 13326 Glen Rose, TX 76403-2159 1701 North Congress Avenue Austin, TX 78701-3326 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Ms. Susan M. Jablonski 611 Ryan Plaza Drive, Suite 400 Office of Permitting, Remediation Arlington, TX 76011 and Registration Texas Commission on Environmental Mr. Roger D. Walker Quality Regulatory Affairs Manager MC-122 TXU Generation Company LP P. O. Box 13087 P. O. Box 1002 Austin, TX 78711-3087 Glen Rose, TX 76043 Terry Parks, Chief Inspector George L. Edgar, Esq. Texas Department of Licensing Morgan Lewis and Regulation 1111 Pennsylvania Avenue, NW Boiler Program Washington, DC 20004 P. O. Box 12157 Austin, TX 78711 County Judge P. O. Box 851 Mr. M. R. Blevins Glen Rose, TX 76043 Senior Vice President

& Principal Nuclear Officer Environmental and Natural TXU Energy Resources Policy Director ATTN: Regulatory Affairs Office of the Governor P. O. Box 1002 P. O. Box 12428 Glen Rose, TX 76043 Austin, TX 78711-3189 Mr. Richard A. Ratliff, Chief Bureau of Radiation Control Texas Department of Health 1100 West 49th Street Austin, TX 78756-3189 0DUFK

Diablo Canyon Power Plant, Units 1 and 2 cc:

NRC Resident Inspector Richard F. Locke, Esq.

Diablo Canyon Power Plant Pacific Gas & Electric Company c/o U.S. Nuclear Regulatory Commission P.O. Box 7442 P.O. Box 369 San Francisco, CA 94120 Avila Beach, CA 93424 Mr. David H. Oatley, Vice President Mr. Pete Wagner and General Manager Sierra Club California Diablo Canyon Power Plant 2650 Maple Avenue P.O. Box 56 Morro Bay, California 93442 Avila Beach, CA 93424 Ms. Nancy Culver City Editor San Luis Obispo The Tribune Mothers for Peace 3825 South Higuera Street P.O. Box 164 P.O. Box 112 Pismo Beach, CA 93448 San Luis Obispo, CA 93406-0112 Chairman Mr. Ed Bailey, Radiation Program Director San Luis Obispo County Board of Radiologic Health Branch Supervisors State Department of Health Services Room 370 P.O. Box 942732 (MS 178)

County Government Center Sacramento, CA 94234-7320 San Luis Obispo, CA 93408 Mr. James D. Boyd, Commissioner Mr. Truman Burns California Energy Commission Mr. Robert Kinosian 1516 Ninth Street (MS 31)

California Public Utilities Commission Sacramento, CA 95814 505 Van Ness, Room 4102 San Francisco, CA 94102 Mr. James R. Becker, Vice President Diablo Canyon Operations Diablo Canyon Independent Safety and Station Director Committee Diablo Canyon Power Plant ATTN: Robert R. Wellington, Esq. P.O. Box 3 Legal Counsel Avila Beach, CA 93424 857 Cass Street, Suite D Monterey, CA 93940 Mr. Gregory M. Rueger Senior Vice President, Generation and Regional Administrator, Region IV Chief Nuclear Officer U.S. Nuclear Regulatory Commission Pacific Gas and Electric Company Harris Tower & Pavillion Diablo Canyon Power Plant 611 Ryan Plaza Drive, Suite 400 P.O. Box 3 Arlington, TX 76011-8064 Avila Beach, CA 93424

South Texas Project, Units 1 & 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, Units 1 & 2 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 0U-DPHV-6KHSSDUG 3UHVLGHQWDQG&KLHI([HFXWLYH 2IILFHU 6731XFOHDU2SHUDWLQJ&RPSDQ\

6RXWK7H[DV3URMHFW(OHFWULF

*HQHUDWLQJ6WDWLRQ 32%R[

DGVZRUWK7;

Wolf Creek Generating Station cc:

Jay Silberg, Esq. Site Vice President Shaw, Pittman, Potts & Trowbridge Wolf Creek Nuclear Operating Corporation 2300 N Street, NW P.O. Box 411 Washington, D.C. 20037 Burlington, KS 66839 Regional Administrator, Region IV Superintendent Licensing U.S. Nuclear Regulatory Commission Wolf Creek Nuclear Operating Corporation 611 Ryan Plaza Drive, Suite 400 P.O. Box 411 Arlington, TX 76011-7005 Burlington, KS 66839 Senior Resident Inspector U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Resident Inspectors Office P.O. Box 311 8201 NRC Road Burlington, KS 66839 Steedman, MO 65077-1032 Chief Engineer, Utilities Division Mr. Rick A. Muench Kansas Corporation Commission President and Chief Executive Officer 1500 SW Arrowhead Road Wolf Creek Nuclear Operating Corporation Topeka, KS 66604-4027 Post Office Box 411 Burlington, KS 66839 Office of the Governor State of Kansas Topeka, KS 66612 Attorney General 120 S.W. 10th Avenue, 2nd Floor Topeka, KS 66612-1597 County Clerk Coffey County Courthouse 110 South 6th Street Burlington, KS 66839 Vick L. Cooper, Chief Air Operating Permit and Compliance Section Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson, Suite 310 Topeka, KS 66612-1366