ML060130029

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Enclosure 3: STP Risk - Informed Tech Specifications Viewgraph to Summary of Meeting on December 14 & 15, 2005 with STP and Nei/Epri to Discuss RMTS I4b
ML060130029
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 12/12/2005
From: Tjader T
NRC/NRR/ADRO/DIRS
To:
Tjader T, 415-1187
References
Download: ML060130029 (24)
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Text

ENCLOSURE 3

STP Risk-Informed Technical Specifications STPNOC Meeting with NRC Staff to Discuss RAI Responses December 14 -15, 2005

STP Participants

- Rick Grantom

- Scott Head

- Wayne Harrison

- Evans Heacock

-Jim Morris

- Drew Richards

- Bill Stillwell Risk Management Manager Licensing Manager Licensing Elec. Design Engineering Licensing Risk Management Risk Management 12/12/2005 2

Desired Outcomes 13 Status/Resolve RAls. Identify all remaining significant issues.

2. Demonstrate STP's Configuration Risk Management Program (CRMP).
3. Agree on content of next STP submittal.
4. Establish actions required for Risk Managed Technical Specifications (RMTS) guide and how it will be approved.
5. Agree on schedule for NRC visits.
6. Establish milestone plan for completion with target dates and deliverables.

12/12/2005 3

Agenda

  • Introduction and agreement on desired outcomes
  • STP Overview and brief demonstration of CRMP
  • Review responses to RAIs / Identify remaining issues
  • Agree on content of next STP submittal
  • Establish action required for the RMTS guide
  • Establish tentative scope and schedule for NRC site visits
  • Establish milestone plan for completion with target dates and deliverables 12/12/2005 4

STP RITS DRAFT 3/4.13 RISK MANAGEMENT 3/4.13.1 ALLOWED OUTAGE TIME DETERMINATIONS LIMITING CONDITION FOR OPERATION 3.13.1 When referred to this specification, equipment that has been declared inoperable shall be evaluated for its impact on plant risk and allowed outage times determined accordingly.

APPLICABILITY:

As re uired by the referencing specification(s) xm M~

ACTION:

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determine that the configuration is acceptable for continued operation beyond the allowed outage time for the referencing specification(s) whenever configuration changes occur that may affect plant risk, AND

3.

Restore required inoperable subsystem, component to OPERABLE status within the acceptable allowed outage time extension or 30 days, whichever is shorter.

Note: The 30-day limitation may be applied individually to each specification for which Speifiatin.131 hs een entered koiet!tIO n

OR Take the ACTION(s) required in the referencing specification(s) for required action or completion time not met SURVEILLANCE REQUIREMENTS 4.13.1 As required by the referencing specification(s)

SOUTH TEXAS - UNITS 1 & 2 3/4 13-1 Unit 1 - Amendment No.

Unit 2 - Amendment No.

5

STP RITS l DRAFT l

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SOUTH TEXAS - UNITS 1 & 2 3/4 13-2 Unit 1 - Amendment No.

Unit 2 - Amendment No.

6

lSTP RITSl lDRAFT l

Bases for Specification 3.13.1 Specification 3.13.1 establishes provisions for performing a risk assessment to determine required actions and allowed outage times for specifically identified specifications for structures, systems, and components. Application of the risk assessment is consistent with the requirements of the Maintenance Rule, 10CFR50.65(a)(4), to assess and manage the increase in risk that may result from maintenance activities. The process to manage the risk assesses the rate of accumulation of risk in plant configurations and determines the allowed outage time (AOT) by calculating the time required to cross a Potentially Risk-significant Threshold (1.OE-05).

Application of the risk assessment to manage allowed outage time in different plant configurations is complemented by the station's programs to monitor performance indicators for long-term availability of risk-significant components. The requirement to achieve acceptable long-term performance indicators provides a significant disincentive to the potential to regularly extend baseline AOTs to the detriment of availability.

TS 3.13.1.a establishes the conditions for performance of the risk assessment. The LCOs subject to the Configuration Risk Management Program (CRMP) specifically reference TS 3.13.1. The baseline AOT or required completion time specified in the LCO may be used to apply the TS 3.13.1 to determine an alternate AOT and compensatory actions.

The requirement to continuously determine the acceptability of the plant means that once the subject LCO has exceeded the baseline AOT, the risk assessment must be reperformed as needed to determine the required action and time limits for any TS component that subsequently becomes inoperable. This requirement provides assurance that the configuration risk is adequately assessed. In a configuration with multiple LCOs not met, the risk assessment may determine that the AOT is shorter than what would be allowed by the baseline time in the affected LCOs. With more than one LCO not met, the baseline time for a subsequent inoperable TS component might also be a non-conservative time to perform a risk assessment to determine the appropriate required action and time. Consequently, the risk assessment process may also be applied to determine how much time is available to perform a risk assessment for subsequent inoperable TS components.

TS 3.13.1 is applied with the referencing specification and the ACTION required by the referencing specification must be taken if the configuration risk exceeds the Potentially Risk-significant Threshold. It recognizes that the plant is in an extended AOT that has a specified required action if the required action time is exceeded. In a configuration where the risk exceeds the Potentially Risk-significant Threshold, the calculated AOT has been exceeded and the action required at the expiration of LCO AOT must be taken. If more than one LCO is beyond its frontstop time, the LCO with the most limiting required action must be followed.

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uanulect TS 3.13.1 establishes a backstop, ACIT of 30 days. This backstop AOT prevents allowing a component with little or no risk significance from being inoperable indefiniteY and resulting in a defacto chan e

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m m1 Bases for Technical Specification 3.13.2 Technical Specification 3.13.2 requires confirmation that the specified allowed outage times are acceptable when ACTIONs are entered for components on different safety trains. The allowed outage momes for SSCs are often based on no other SSC being inoperable at the same time.

Some configurations where the plant is in two or more LCO ACTION statements could potentially impose an unacceptable level of risk. This is particularly the case if the affected components are in different safety trains because the redundancy of accident mitigation capability could be adversely affected.

8

STPEGS UNIT I Operations Report November 28, 2005

1. A. GENERATION LAST 24 HOURS Reactor Power: 100%

Hourly Electrical Output (MW-hrs) 24 Hour Total (MW-hrs)

Thermal Power:

Gross.... 1344 Gross.... 32270 3853 MWt Net....1293 Net....31035 B. RCS Integrity / Risk RCS Identified Leak Rate is <0.12 gpm.

RCS Unidentified Leak Rate is <0.12 gpm.

Planned maintenance risk for the week is 3.34 E-09 Actual maintenance risk as of 06:00 is 0.0 Planned BOP trip risk for the week is 0%.

Actual BOP trip risk as of 06:00 is 0%.

C. TRAIN STATUS All required equipment is operable.

D. BOP STATUS All required equipment is available.

2. REGULATORY NOTIFICATIONS None
3. PRIORITY CONDITION REPORTS DURING PAST 24 HOURS.

None

4. CONDITION REPORTS DURING THE PAST 24 HOURS WITH A PENDING OPERABILITY OR REPORTABILITY REVIEW.

None

5. LIMITING CONDITION FOR OPERATION ACTION STATEMENT.

None Submitted by: Klay Klimple 9

STPEGS UNIT 2 Operations Report November 28,2005

1. A. GENERATION LAST 24 HOURS Reactor Power: 100%

Thermal Power:

3853 MWt Hourly Electrical Output (MW-hrs)

Gross.... 1344 Net.... 1293 24 Hour Total (MW-hrs) Gross.... 32249 Net.... 31038 B. RCS Integrity / Risk RCS Identified Leak Rate is <0.12 gpm.

RCS Unidentified Leak Rate is <0.12 gpm.

Planned maintenance risk for the week is 3.73 E-07 Actual maintenance risk as of 06:00 is 1.65 E-08 Planned BOP trip risk for the week is 0.1%.

Actual BOP trip risk as of 06:00 is 0%.

UNIT 2 is the Load Control Unit C. TRAIN STATUS Train "A" Essential Cooling Water, Essential Chill Water, Component Cooling Water and Emergency Diesel #21 are removed from service for planned maintenance.

All other required equipment is operable.

D. BOP STATUS Low Pressure Heater Drip Pump #23 and Condenser Air Removal Pump #23 are removed from service for planned maintenance.

All other required equipment is available.

2. REGULATORY NOTIFICATIONS None
3. PRIORITY CONDITION REPORTS DURING PAST 24 HOURS.

None

4. CONDITION REPORTS DURING THE PAST 24 HOURS WITH A PENDING OPERABILITY OR REPORTABILITY REVIEW.

None

5. LIMITING CONDITION FOR OPERATION ACTION STATEMENT.

OAS 10310 Component Cooling Water Train "A" declared inoperable for planned maintenance. Entered Tech Spec 3.7.3 that requires restoration within 7 days (12/4/05 @ 22:00) or a plant shutdown is required.

OAS 10311 Essential Chill Water Train "A" declared inoperable for planned maintenance. Entered Tech Spec 3.7.14 that requires restoration within 7 days (12/4/05 @ 22:00) or a plant shutdown is required.

OAS 10312 Emergency Diesel #21 declared inoperable for planned maintenance. Entered Tech Spec 3.8.1.1 that requires restoration within 14 days (12/12/05 @ 01:00) or a plant shutdown is required.

OAS 10313 Essential Cooling Water Train "A" declared inoperable for planned maintenance. Entered Tech Spec 3.7.4 that requires restoration within 7 days (12/4/05 @ 22:00) or a plant shutdown is required.

Submitted by: Robert Brinkley 10

Planned Risk Profiles for Unit 1 Week of 11/28/2005 Baseline Trip Risk = 0.036 tripshweek 1 e 3.34E-09 P 10% -

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Duration PRA BOP PRA Maint State BOP Maint. State Start End (hh:mm)

Norm.

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No Risk-Significant Maintenance No Risk-Significant Maintenance 11/28 00:00 11/30 07:00 055:00 0.79 1.00 PZPRVB No Risk-Significant Maintenance 11/30 07:00 11/30 10:00 003:00 1.86 1.00 No Risk-Significant Maintenance No Risk-Significant Maintenance 11/30 10:00 12/05 00:00 110:00 0.79 1.00 11

Planned Risk Profiles for Unit 2 Week of 11/28/2005 le.j 9e *= 8e 2 7e °. 6e 0 5e Q 4e E 3e. 2e < le Oe+O

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PRA Maint. State CHA CHA EWA CCA CHA DGA EWA CCA CHA DGA EWA CCA CHA DGA EWA CHA DGA DGA DGA No Risk-Significant Maintenance BOP Maint. State No Risk-Significant Maintenance No Risk-Significant Maintenance CAR13/23 AC13123 CAR13/23 CAR13/23 CAR13/23 CAR13/23 No Risk-Significant Maintenance No Risk-Significant Maintenance Start 11/28 00:00 11/28 01:00 11/28 03:00 11/30 07:00 11/30 09:00 12/01 01:00 12/01 12:00 12/01 21:00 12/03 12:00 End 11/28 01:00 11/28 03:00 11/30 07:00 11/30 09:00 12/01 01:00 12101 12:00 12/01 21:00 12/03 12:00 12/05 00:00 Duration (hh:mm) 001:00 002:00 052:00 002:00 016:00 011:00 009:00 039:00 036:00 PRA Norm.

0.93 3.94 3.94 3.94 3.94 3.13 3.02 3.01 0.79 BOP Norm.

1.00 1.00 1.00 1.01 1.00 1.00 1.00 1.00 1.00 i

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12

Actual Risk Profiles for Unit 1 Week of 11/28/2005 e-7 13.34E-09 P B e-B-Uz~r 8e M 7e °0 6e 4) 5e o 4e 0 3e L) 2e " 1e Oe+O

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04 PRA Component CHA NOTE 1 PZPRVB BOP Component CAR1 1/21 NOTE 2 Planned Time Non-Functional N/A 1 1130/2005 07:00 Planned Time Non-Functional N/A Planned Time Functional N/A 11/30/2005 10:00 Planned Time Functional N/A Duration (hh:mm)

N/A 003:00 Duration (hh:mm)

N/A Actual Time Non-Functional 12/01/2005 07:40 11/30/2005 06:25 Actual Time Non-Functional 11t28/2005 22:00 Actual Time Functional 12102/2005 05:45 11/30/2005 15:20 Actual Time Functional 11/29/2005 04:24 Duration (hh:mm) 022:05 008:55 Duration (hh:mm) 006:24 NOTE I - Essential chiller 12A tripped. CR# 05-15756 NOTE 2 - CARS pump cooling water temperature control valve failed. CR# 05-15612.

13

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PRA Component CCA CHA Note I CHA DGA Note 2 DGA EWA BOP Component ACt3/23 CAR13/23 Planned Time Non-Functional 11/28/2005 03:00 N/A 11/28/2005 00:00 N/A 11/28/2005 01:00 11/28/2005 01:00 Planned Time Non-Functional 11/30/2005 07:00 11/2812005 03:00 Planned Time Functional 12/01/2005 01:00 N/A 12/01/2005 12:00 N/A 12/03/2005 12:00 12/01/200501:00 Planned Time Functional 11/30/2005 09.00 12/01/2005 21:00 Duration (hh:mm) 070:00 N/A 084:00 N/A 131:00 072:00 Duration (hh:mm) 002:00 090:00 Actual Time Non-Functional 11/28/2005 01:00 12/04/2005 12:15 11/28/2005 00:00 12/03/2005 21:26 11/28/2005 01:00 11/28/2005 01:00 Actual Time Non-Functional 11/30/2005 17:45 11/28/2005 04:00 Actual Time Functional 12/01/200520:15 12/05/200500:00 12/01/2005 22:39 12/04/2005 05:27 12103/2005 16:09 12/01/2005 20:15 Actual Time Functional 11/30/2005 18:00 11/30/2005 11:20 Duration (hh:mm) 091:15 011:45 094:39 008:01 135:09 091:15 Duration (hh:mm) 000:15 055:20 Note I - Essential chiller 22A has excessive excess purge, hi discharge pressure and abnormal vibrations. CR#

05-15864.

Note 2 - DG 21 declared functional after EAOT PMT commenced. The DG is declared non-functional for scheduled governor oil change after PMT run. Original Risk profile did not declare functionality between these two maintenance states.

Note 3 - DG 21 exceeded it's planned out of service time due to expanded scope of maintenance (multiple WAN's). EW, CH, and CC exceeded their out of service time due to expanded scope of maintenance on EW-0019 (WAN 195735) and EW-0016 (WAN 195734).

14

STP RITS RAI Response Discussion Summary Response acceptable.

2 10/27/05 STP doesn't credit operator actions for functionality when calculating RICTs. For calculation of Maint. Rule a(4) functionality, operator action is credited in accordance with the guidelines of NUMARC 93-01.

Need to revise to state "never will be credited" unless in PRA.

RICTs are based on inoperability, even though may be functional per MR.

3a 10/11/05, Staff asked whether consistent STP will confirm determination 10/17/05 with GL 91-18.

of operability is consistent with GL 91-18.

Additionally, STP will recommend EPRI RMTS guidance document be revised to reflect GL 91-18.

3b 10/17/05 See 3a above.

3c 10/17/05 Need to revise our response to STP response will be revised clarify. Answer is not really "no."

to state that if the operability determination identifies the same degraded or non-conforming condition exists in the redundant train components, they will be declared inoperable.

3d 10/17/05 STP needs to look at context to STP will change "components see if we need to revise RAI to "component failure modes."

response.

STP will clarify that insights are not used in calculation of RICTs.

3e 10/17/05 Response acceptable. No STPNOC will recommend additional information needed.

revising the RMTS Guidance to reflect that failure rates need not be adjusted for a single failure.

3f 10/17/05 Response acceptable. No STP will revise response to additional information needed.

more emphatically state that approved TS will require action when threshold exceeded.

4 10/11/05, Need additional information.

Need additional discussion Page 1 of 8

STP RITS RAI Response Discussion Summary with NRC regarding whether staff wants to review results of Level 2 update.

5 Discussed controls on what actions should be taken if exceed 1 E-6 threshold. Actions need "more teeth." Will address "residual functionality." Controls could be put in to place to document occurrences, including corrective actions and notification to plant management. Also need to clarify use of RICTs for multiple equipment in TS LCOs, and "planned" vs "emergent" thresholds.

Need additional discussion with NRC regarding planned vs. emergent exceedance of 1 E-6 threshold.

6 10/17/05 Need to send augmented Table 2 STP to revise Table 2 as that shows / discuss stated.

asymmetries.

(Meeting discussion topic) 7 10/17/05 Response acceptable. No STP will provide risk additional information needed.

calculation program demonstration.

8a 10/11/05, Discussed possible use of SFDP-STP proposes revised TS 10/17/05 like tool, which evaluates whether 3.13.1 and 3.13.2, and Bases.

function is lost. Can proposed Initiative 6 changes be used?

Discussed concept of "residual functionality."

8b 10/11/05, Staff asked whether PRA STP to identify where PRA 10/17/05 modeled all TS functions.

does not model specific TS functions.

STP will provide example Safety Injection system table at meeting.

8c 10/17/05 Need to identify / clarify STP to provide requested functionality vs. operability.

clarifications. STP will tie Discussed that CRMP is oriented answers to 8c with answer to towards a(4), and not always 8a.

compatible with RICTs. Need to clarify how these would differ.

9 10/17/05 No discussion. Placekeeper -

refers to RAI questions 25 through 38.

10a 10/27/05 As stated, STP will remove RTBs STP to remove TS 3.3.1 Unit from submittal.

20 from scope of application.

1 Ob 10/27/05 Will discuss at December meeting.

Page 2 of 8

STP RITS RAI Response Discussion Summary Question Telecon Discussion Notes STP Follow-up Action Date 10c 10/27/05 Will discuss at December meeting.

10d 10/27/05 Will discuss at December meeting.

11 10/27/05 STP does model cooldown STP to confirm Main transition (Steam Line Breaks),

Feedwater Isolation Valves but small contribution.

(MFIVs) are only TS equipment not modeled.

1 2a 10/27/05 As stated, STP will remove STP will remove PZR safeties subject TS from submittal.

from submittal.

12b 10/27/05 Response acceptable. No additional information needed.

12c 10/27/05 Response acceptable. No additional information needed.

13 10/27/05 Response acceptable. No additional information needed.

1 4a 10/27/05 Response acceptable. No additional information needed.

1 4b 10/27/05 If outside boron limits, then non-functional and therefore inoperable.

15 10/27/05 Need to change "and" to mor."

STP will make wording change.

16 10/27/05 RCFCs are credited if containment is intact. This is a plant-specific calculation. No further information needed.

17 10/27/05 STP will adjust wording to agree STP will make wording with NRC comment. STP will changes. Also see Question look at MFIVs.

11 follow-up action above.

18 10/27/05 Model assumes normal summer conditions throughout year.

Coolers are modeled with associated system functions.

19 10/27/05, Response acceptable. No 12/07/05 additional information needed.

20 10/27/05, TS 3.13.2 would replace TS STP to correct wording.

12/07/05 3.8.1.1.d. Typo in ACTION. RAI response states "OPERABLE status within or..." Should state "OPERABLE status within the calculated Allowed Outage Time or..."

NRC to look at further.

21 10/27/05, If inoperable, will be included in Will be shown in program 12/07/05 RICT. NRC to look at this further. demonstration.

22 10/27/05 Will discuss further at December Page 3 of 8

STP RITS RAI Response Discussion Summary Question Telecon Discussion Notes STP Follow-up Action Date meeting.

23 10/27/05, STP will propose Note in TS STP will propose Note in TS 12/07/05 3.8.2.1 to restrict use of TS 3.8.2.1 to restrict use of TS 3.13.1. SeeAttachment1.

3.13.1.

Reviewer requested that STP will revise response to response be revised to include RAI 23 to remove channel-additional information regarding specific information.

Channel II and IV batteries.

STP will bring cross-train feed Reviewer asked for additional procedures to meeting.

clarification on cross-train feed procedures.

24 10/17/05 RG 1.200 requirements are met STP will provide detailed by current model. Following response.

completion of Rev. 5, then will have resources to provide detailed answers on how we comply.

25 10/17/05

'A's and 'B's will be signed off as STP to proved additional detail part of Rev. 5. Will do peer as discussed.

review w.r.t HRA methodology.

Won't be able to answer fully until final report.

Individual Table 1 items discussed:

EH-05 Need to provide more detailed answer.

DE-09 Discussed whether 1 E-7 screening criteria is small enough.

QU-03 NRC will evaluate when Rev. 5 completed.

L2-06 Need to provide more detail.

26 10/17/05 Key sources of uncertainty / key STP expects will provide first assumptions will be included in quarter of 2006.

Rev. 5 update.

27 10/17/05 RG 1.200 Self-Assessment will Need to discuss NRC be submitted.

expectations for documentation.

28 10/17/05 Documentation will be upgraded Need to discuss NRC Page 4 of 8

STP RITS RAI Response Discussion Summary Question Telecon Discussion Notes STP Follow-up Action Date as part of Rev. 5 documentation.

expectations for documentation.

29 10/17/05 Will be provided following completion of Rev. 5 30a 10/17/05 No additional information

.Arequested.

30b 10/17/05 Not an issue for STP.

30c 10/17/05 STP model automatically adjusts for maintenance impact.

30d 10/17/05 No initiator frequency adjustments.

30e 10/17/05 Seasonal adjustments not used in STP model - use summer for entire year.

30f 10/17/05 Need additional information Response will be revised to regarding how equipment repair state that STP's PRA model is credited.

does not take credit repair of out-of-service equipment as a recovery action for configuration risk calculations.

There is limited credit for repair of standby diesel generator failures after an initiating event.

31 a 10/17/05 Being addressed in Level 2 PRA Response will be provided update, currently in progress.

upon completion of update.

31 b

  • 10/17/05 Being addressed in Level 2 PRA Response will be provided update, currently in progress.

upon completion of update.

31 c 10/17/05 Being addressed in Level 2 PRA Response will be provided update, currently in progress.

upon completion of update.

31 d 10/17/05 Being addressed in Level 2 PRA Response will be provided update, currently in progress.

upon completion of update.

31 e 10/17/05 Being addressed in Level 2 PRA Response will be provided update, currently in progress.

upon completion of update.

31f 10117/05 Being addressed in Level 2 PRA Response will be provided update, currently in progress.

upon completion of update.

32a 12/07/05 Reviewer questioned how 3.13.1 Additional note to 3.13.1 has would apply in case of excessive been proposed which battery discharge.

addresses use for batteries.

STP will bring referenced procedures to meeting.

32b No additional Reviewer comments at this time. Will discuss at meeting as needed.

32c No additional Reviewer comments at this time. Will discuss at meeting as needed.

Page 5 of 8

STP RITS RAI Response Discussion Summary Question Telecon Discussion Notes STP Follow-up Action Date 33a 12/07/05 Reviewer asked about procedural STP will bring procedures for controls which address degraded response to degraded DC bus DC power.

and station blackout.

33b No additional Reviewer comments at this time. Will discuss at meeting as needed.

33c No additional Reviewer comments at this time. Will discuss at meeting as needed.

33d No additional Reviewer comments at this time. Will discuss at meeting as needed.

34a 12/08/05 Refer to Attachment 1 General Need to discuss possible Comments.

regulatory commitment to stabilize plant. Should statement be added to RM guidance document?

STP will add discussion to 34a response regarding STP's 7-day train-specific work weeks, and that STP does not typically plan for work to extend into the following work week.

34b 12/08/05 Reviewer would like to discuss STP will bring example further how risk profile information showing how information is maintained and electrical TS entries which how 3.13.1 entries will be affected RASCAL are tracked.

documented.

34c No additional Reviewer comments at this time. Will discuss at meeting as needed.

35 No additional Reviewer comments at this time. Will discuss at meeting as needed.

36a No additional Reviewer comments at this time. Will discuss at meeting as needed.

36b No additional Reviewer comments at this time. Will discuss at meeting as needed.

36c 12/08/05 Discussed independence of losq Refer to!8a response.

of-power instrumentation & how STP will add detail to 36c possible common cause issues response which clarifies that would be addressed. Also TS 3.0.4 would prevent mode Page 6 of 8

STP RITS RAI Response Discussion Summary Question Telecon Discussion Notes STP Follow-up Action Date discussed use of TS 3.13.1 for an change with an inoperable inoperable SDG and mode SDG.

changes.

37 No additional Reviewer comments at this time. Will discuss at meeting as needed.

38 No additional Reviewer comments at this time. Will discuss at meeting as needed.

39 No additional Reviewer comments at this time. Will discuss at meeting as needed.

40 No additional Reviewer comments at this time. Will discuss at meeting as needed.

41 10/27/05 No additional information requested.

42a 10/27/05 Discussed that times are driven STP will discuss proposed by TS. If AOT is a few days, can wording for TS 3.13.1 Actions calculate ahead of time; if at meeting.

shorter, can calculate quickly.

No additional information requested.

42b 10/27/05 Similar. Driven by TS. No further Need to discuss further with info needed.

industry.

43a 10/27/05 STP believes current tools support timely calculation capability. If RICT not calculated, then will use TS limit.

43b 10/27/05 Don't believe so, but if they do exist, can promptly calculate prior. Typically, 20 to 25 minutes to perform calc.

44 10/27/05 No new TS. Standard types of compensatory measures have been developed already, but are not tied to specific TS. STP's process for developing/applying compensatory measures has been proceduralized.

NRC may look at this further when do plant visit.

45 10/27/05 Table 2 shows that not all short STP to address loss of duration AOTs are high-risk.

function in revised 3.13.1, STP will discuss this in detail at 3.13.2 (refer to Question 8a).

meeting. NRC will look at on a case-by-case basis. NRC will Page 7 of 8

STP RITS RAI Response Discussion Summary Question Telecon Discussion Notes STP Follow-up Action Date evaluate possible ties to Industry Initiative 6.

46 10/27/05 Response acceptable. No additional information needed.

Attach 1 12/07/05 General Comments - Discussed that de-energized bus" refers to DC power.

Attach 1 12/07/05 3.8.1.1 Action a - Att 1 states that Action a can be entered for either planned or emergent work.

Reviewer asked for details on how 3.8.1.1.a entry is made for planned maintenance. Reviewer asked if compensatory measures are pre-defined.

Attach 1 12/07/05 3.8.1.1.e - Discussed how 72-hr action in 3.8.1.1.e is redundant with actions of 3.8.1.1.a.

Attach 1 12/07/05 3.8.2.1 - Reviewer requested STP will bring requested example risk results for multiple information to meeting.

batteries inoperable and that battery charger design information be brought to meeting.

Page 8 of 8

STP RITS Proposed Schedule RAI w/o PRA Mid-January STP Submit revised RMTS and RAI responses Mid-January EPRI & NEI RAI PRA and Table 2 March 6 STP

  • Q 24 - Fire I External Events
  • Q 25 - F&O Status
  • Q 26 - Key uncertainties
  • Q 27 - Capability Categories
  • Q 28 - PRA Documentation
  • Q 29 - Common Cause Failure Modes
  • Q 30 - Changes to Baseline
  • Q 31 - Level 2 Update Revised application May30 STP NRC site visit March - April NRC NRC STP SE June 30 NRC NRC RMTS SE (?)

June 30 NRC (How will this be endorsed?)

Amendment Issued July NRC Questions and exposures:

ACRS before SE and amendment Follow-up meeting(s) with NRC Additional RAls Page 1 of I

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