ML040550587
| ML040550587 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 02/18/2004 |
| From: | Michael Webb NRC/NRR/DLPM/LPD4 |
| To: | |
| Webb M, NRR/DLPM, 415-1347 | |
| Shared Package | |
| ML040560491 | List: |
| References | |
| Download: ML040550587 (8) | |
Text
February 18, 2004 LICENSEE:
STP Nuclear Operating Company FACILITY:
South Texas Project Electric Generating Station (STP), Units 1 and 2
SUBJECT:
SUMMARY
OF A JANUARY 21, 2004, PUBLIC MEETING WITH STP NUCLEAR OPERATING COMPANY (STPNOC) ON RISK MANAGEMENT TECHNICAL SPECIFICATIONS INITIATIVE 4B On January 21, 2004, the U.S. Nuclear Regulatory Commission (NRC) staff held a meeting at the NRC Headquarters, One White Flint North, Rockville, Maryland, with representatives from STPNOC (the licensee) to discuss issues related to the Risk Management Technical Specifications (RMTS) Initiative 4b on Risk-Informed Completion Times (RICT). Pursuant to the Commissions Policy Statement on Enhancing Public Participation in NRC Meetings, (67 FR 36920), dated May 28, 2002, the meeting was open to the public for observation and opportunity to communicate with the NRC staff following the business portion of the meeting.
The meeting notice was issued on January 7, 2004. A list of discussion topics for the meeting is contained in Enclosure 1 and the list of meeting attendees is contained in Enclosure 2. The presentation slides used by the licensee are accessible on the NRC website www.nrc.gov at the Public Electronic Reading Room in the Agencywide Documents Access and Management System (ADAMS) under ADAMS accession number ML040410647 and are included as.
The discussions with STPNOC addressed the industry presentation on the RMTS guidelines/process for RMTS Initiative 4b determination of RICTs and the STPNOC response (Enclosure 4) to the NRC staff review impressions/comments on STPNOCs letter of March 18, 2003. Enclosure 4 may be found under ADAMS accession number ML040410657. The following are brief descriptions of the significant topics discussed during the meeting.
The review of the pilot will focus on, and the success of the pilot effort will be achieved with, the exportability of the approved process; that is, the ability of follow-on plants to utilize the generic RICT process approved for STPNOC. The Risk Management Guidance (RMG) Document being developed by the Nuclear Energy Institue and the Electric Power Research Institute, and the STPNOC Configuration Risk Management Program (CRMP) process must converge and be consistent at the end of the pilot effort.
The RMG needs to provide exportable guidance that is applicable, reliable, and repeatable in other follow-on plants.
The Technical Specifications (TSs) included in the scope of the STPNOC request includes only those systems that are currently in their CRMP, which is the Core Damage Frequency-based program. The staff proposed, and STPNOC accepted, that the CRMP will take into account Large Early Release Frequency (LERF) in cases for which LERF has the potential to change the results.
STPNOC takes exception to the proscription of the use of the CRMP/RMG process to determine an appropriate Allowed Outage Time for loss of function that requires entry into TS 3.0.3, the shutdown track. STPNOC is not requesting use of the CRMP/RMG process for voluntary loss of function; the staff suggests explicitly prohibiting use of the CRMP/RMG process for voluntary loss of function. The NRC staff must determine the acceptability of the STPNOC proposal and whether system-specific TS 3.0.3 entry times, derived from an Initiative 6 process, are needed. The wording of sample TS 3/4.7.4, Action b, needs to be revised or the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> provided to enter the CRMP/RMG process for voluntary loss of function needs to be justified.
The NRC staff suggests that the 4b risk assessment process needs to be utilized and applied to the for CRMP/RMG process situations in which there are entries into multiple Limiting Conditions Operation without exceeding any of the front stops.
The level of detail required by the NRC staff in the STPNOC LAR submittal includes the CRMP procedure, detailed data and documentation for staff selected cases in Table 2, specific cumulative risk and instantaneous risk limits and monitoring requirements be specified in the CRMP/RMG process, the Probabilistic Risk Assessment update/upgrade procedures utilized by STPNOC, that the STPNOC LAR not include requests that are not related to Initiative 4b (not include riders in Table 2), an explanation of when the STPNOC CRMP/RMG process would be utilized when equipment is Tech Spec inoperable yet is Probabilistic Risk Assessment functional and an explaination of the rational for those circumstances, a description of the level of documentation required for an Initiative 4b risk assessment, and adquate documentation for inspectors to verify the assumptions and results of the STPNOC CRMP process.
The Regulatory Guide 1.200 Pilot PRA Audit and Application-Specific PRA Audit for the Initiative 4b Pilot will be conducted after receipt of the STPNOC LAR submittal in June 2004.
Site visits for the audits and observation of the application of the CRMP process will be necessary.
/RA by R. Gramm for M. Webb/
Michael K. Webb, Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos: 50-498 and 50-499
Enclosures:
- 1. Agenda
- 2. List of Attendees
- 3. Licensees Presentation Material
- 4. STPNOCs Response to NRC staffs Comments cc w/encls: See next page
STPNOC takes exception to the proscription of the use of the CRMP/RMG process to determine an appropriate Allowed Outage Time for loss of function that requires entry into TS 3.0.3, the shutdown track. STPNOC is not requesting use of the CRMP/RMG process for voluntary loss of function; the staff suggests explicitly prohibiting use of the CRMP/RMG process for voluntary loss of function. The NRC staff must determine the acceptability of the STPNOC proposal and whether system-specific TS 3.0.3 entry times, derived from an Initiative 6 process, are needed. The wording of sample TS 3/4.7.4, Action b, needs to be revised or the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> provided to enter the CRMP/RMG process for voluntary loss of function needs to be justified.
The NRC staff suggests that the 4b risk assessment process needs to be utilized and applied to the for CRMP/RMG process situations in which there are entries into multiple Limiting Conditions Operation without exceeding any of the front stops.
The level of detail required by the NRC staff in the STPNOC LAR submittal includes the CRMP procedure, detailed data and documentation for staff selected cases in Table 2, specific cumulative risk and instantaneous risk limits and monitoring requirements be specified in the CRMP/RMG process, the Probabilistic Risk Assessment update/upgrade procedures utilized by STPNOC, that the STPNOC LAR not include requests that are not related to Initiative 4b (not include riders in Table 2), an explanation of when the STPNOC CRMP/RMG process would be utilized when equipment is Tech Spec inoperable yet is Probabilistic Risk Assessment functional and an explaination of the rational for those circumstances, a description of the level of documentation required for an Initiative 4b risk assessment, and adquate documentation for inspectors to verify the assumptions and results of the STPNOC CRMP process.
The Regulatory Guide 1.200 Pilot PRA Audit and Application-Specific PRA Audit for the Initiative 4b Pilot will be conducted after receipt of the STPNOC LAR submittal in June 2004.
Site visits for the audits and observation of the application of the CRMP process will be necessary.
/RA by R. Gramm for M. Webb/
Michael K. Webb, Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos: 50-498 and 50-499
Enclosures:
- 1. Agenda
- 2. List of Attendees
- 3. Licensees Presentation Material
- 4. STPNOCs Response to NRC staffs Comments cc w/encls: See next page DISTRIBUTION:
PUBLIC RidsNrrDlpmLpdiv (HBerkow) DJackson EDO/RIV Plants PDIV-1 Reading RidsNrrLADJohnson RidsRgn4MailCenter (AHowell)
RidsNrrPMDMWebb JAlbright DTerao RidsOgcRp RidsAcrsAcnwMailCenter RidsNrrDlpm (TMarsh/ELeeds)
RidsAcrsAcnwMailCenter RidsNrrDlpmLpdiv1(RGramm) Meeting Attendees (see Encl 2)
Package Access.No.ML040560491 Meeting Notice Access.No.ML040070462 Accession Number: ML040550587(Meeting Summary) Enclosure 3 Access.No.ML040560393 Accession No. ML040560390 OFFICE PM:PDIV-1 LA:PDIV-1 SC:IROB SC:PDIV-1 NAME RGramm for MWebb:mw DJohnson TBoyce RGramm DATE 2/12/2004 2/9/2004 2/13/04 2/17/2004 OFFICIAL RECORD COPY RMTS INITIATIVE 4b PILOT MEETING JANUARY 21, 2004
Discussion of the STP March 18, 2003, letter of intent and proposal.
Scope and content regarding which components/technical specifications will be included Initiative 4b RICT process Guidance and exceptions Proposal summary Tables 1 & 2; examples Level of detail needed for NRC staff review
Discussion of NRC Staff Impressions Identification of primary issues Process for approval of pilot request
Schedule for STP final submittal and NRC Staff review
Standby Diesel Generator 113 Day extended allowed outage time LIST OF ATTENDEES South Texas Project, Units 1 & 2 NAME AFFILIATION Rick Grantom STP NOC Drew Richards STP NOC Wayne Harrison STP NOC Biff Bradley Nuclear Energy Institute Tom Boyce NRC/NRR/DIPM/IROB/TSS T. R. Tjader NRC/NRR/DIPM/IROB/TSS Carl Schulten NRC/NRR/DIPM/IROB/TSS Kerri Kavanagh NRC/NRR/DIPM/IROB/TSS Mark Reinhart NRC/NRR/DSSA/SPSB Nick Saltos NRC/NRR/DSSA/SPSB Stephen Dinsmore NRC/NRR/DSSA/SPSB Millard Wohl NRC/NRR/DSSA/SPSB Jose Calvo NRC/NRR/DE/EEIB Ronaldo Jenkins NRC/NRR/DE/EEIB Om Chopra NRC/NRR/DE/EEIB Summer Sun NRC/NRR/DSSA/SRXB Wayne Scott NRC/NRR/DIPM/IEPB Roy Mathew NRC/NRR/DIPM/IIPB Dave Jaffe NRC/NRR/DLPM/PDIV-1 Mary Drouin NRC/RES/DRAA/PRAB
May 2003 South Texas Project, Units 1 & 2 cc:
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 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