ML080840001
| ML080840001 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/08/2008 |
| From: | Thadani M NRC/NRR/ADRO/DORL/LPLIV |
| To: | Sheppard J South Texas |
| Thadani, M C, NRR/DORL/LP4, 415-1476 | |
| References | |
| TAC MD7058, TAC MD7059 | |
| Download: ML080840001 (7) | |
Text
April 8, 2008 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
SUBJECT:
SOUTH TEXAS PROJECT, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION RE: LICENSE AMENDMENT REQUEST RELATED TO RISK-INFORMED INITIATIVE 5b (TAC NOS. MD7058 AND MD7059)
Dear Mr. Sheppard:
By application dated October 23, 2007, STP Nuclear Operating Company (the licensee) requested the U.S. Nuclear Regulatory Commission (NRC) staff approval of an amendment to the South Texas Project, Units 1 and 2, technical specifications to relocate surveillance test intervals to a licensee-controlled program (risk-informed initiative 5b).
The NRC staff has reviewed the information provided in your submittal and determined that additional information is required in order to complete its review. Please provide a response to the enclosed questions by June 6, 2008.
The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRCs goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-1476.
Sincerely,
/RA/
Mohan C. Thadani, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499
Enclosure:
Request for Additional Information cc w/encl: See next page
(*) memo dated OFFICE NRR/LPL4/PM NRR/LPL4/LAiT NRR/LPL4/LA APLA/BC NRR/LPL4/BC NAME MThadani GLappert JBurkhardt MRubin (*)
THiltz DATE 4/7/08 4/7/08 4/7/08 3/18/08 4/8/08
South Texas Project, Units 1 and 2 12/5/2007 cc:
Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 289 Wadsworth, TX 77483 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704 J. J. Nesrsta/R. K. Temple E. Alercon/Kevin Pollo CPS Energy P.O. Box 1771 San Antonio, TX 78296 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 Steve Winn/Christie Jacobs Eddy Daniels/Marty Ryan NRC Energy, Inc.
211 Carnegie Center Princeton, NJ 08540 Mr. Nate McDonald County Judge for Matagorda County
\\1700 7th Street, Room 301 Bay City, TX 77414 A. H. Gutterman, Esq.
Morgan, Lewis & Bockius 1111 Pennsylvania Avenue, NW Washington, DC 20004 E. D. Halpin, Site Vice President STP Nuclear Operating Company South Texas Project Electric Generating Station P.O. Box 289 Wadsworth, TX 77483 S. M. Head, Manager, Licensing STP Nuclear Operating Company P.O. Box 289, Mail Code: N5014 Wadsworth, TX 77483 C. T. Bowman, General Manager, Oversight STP Nuclear Operating Company P.O Box 289 Wadsworth, TX 77483 Ms. Marilyn Kistler Senior Staff Specialist, Licensing STP Nuclear Operating Company P.O. Box 289, Mail Code 5014 Wadsworth, TX 77483 Environmental and Natural Resources Policy Director P.O. Box 12428 Austin, TX 78711-3189 Mr. Jon C. Wood Cox, Smith, & Matthews 112 East Pecan, Suite 1800 San Antonio, TX 78205 Director, Division of Compliance & Inspection Bureau of Radiation Control Texas Department of State Health Services 1100 West 49th Street Austin, TX 78756 Mr. Ted Enos 4200 South Hulen Suite 422 Ft. Worth, TX 76109 Mr. Brian Almon Public Utility Commission of Texas P.O. Box 13326 Austin, TX 78711-3326
2 South Texas Project, Units 1 and 2 12/5/2007 Ms. 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. Ken Coates, Plant General Manager STP Nuclear Operating Company South Texas Project Electric Generating Station P.O. Box 289 Wadsworth, TX 77483 Mr. Anthony P. Jones, Chief Boiler Inspector Texas Department of Licensing and Regulation Boiler Division E.O. Thompson State Office Building P.O. Box 12157 Austin, TX 78711
ENCLOSURE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST STP NUCLEAR OPERATING COMPANY SOUTH TEXAS PROJECT, UNITS 1 AND 2 DOCKET NOS. 50-498 AND 50-499 The Nuclear Regulatory Commission (NRC) staff has reviewed the STP Nuclear Operating Company (STPNOC) request dated October 23, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML073050348), for approval of an amendment to the South Texas Project, Units 1 and 2, technical specifications (TS) to relocate surveillance test intervals to a licensee-controlled program (risk-informed initiative 5b). The staff has determined that additional information is necessary to complete its review of the request. Please provide a response which addresses the following request for additional information questions from the PRA Licensing Branch.
- 1.
The staff has reviewed the scope of surveillance test intervals (STI) proposed to be relocated, and has identified several for which additional justification is required. The licensee is requested to address the following issues associated with specific STIs, or delete the STIs from the scope of the proposed TS changes.
- a.
Two surveillances, 4.1.1.1.1.a (which requires a 12-hour periodic verification of shutdown margin when one or more control rods are inoperable) and 4.4.8 Table 4.4-4 item 4a (which requires a 4-hour periodic isotopic analysis when the dose-equivalent iodine-131 activity exceeds prescribed limits) have equivalents in the Westinghouse Standard TS (STS), NUREG-1431, Rev. 3.1, as action requirements.
Specifically, STS 3.1.4 required action B.2.3 provides for a once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shutdown margin verification with inoperable control rod(s), and STS 3.4.16, required action A.1 provides for a once per 4-hour isotopic analysis with does-equivalent iodine-131 exceeding limits. These STS actions are not subject to relocation to the Surveillance Frequency Control Program (SFCP) under TS Task Force (TSTF) traveler TSTF-425 referenced in the submittal.
- b.
Several surveillances require more frequent performance during abnormal plant conditions involving inoperable equipment:
Surveillance 4.1.1.4.b requires a 30-minute periodic verification of the Reactor Coolant System average temperature (Tavg) when a monitoring alarm is not reset.
Surveillance 4.1.3.1.1 requires a 4-hour periodic verification of individual rod positions when the rod position deviation monitor is inoperable.
Surveillance 4.1.3.6 requires a 4-hour periodic verification of control rod bank positions compared with insertion limits when the rod insertion limit monitor is inoperable.
Surveillance 4.2.1.1.b requires a 60-minute and ultimately 30-minute monitoring and logging of the axial flux difference (AFD) when the AFD Monitor Alarm is inoperable.
Surveillance 4.2.4.1.b requires a 12-hour periodic calculation of the quadrant power tilt ratio when the alarm is inoperable.
None of these surveillances is found in the current revision of the STS; however, these surveillances are similar to the required actions identified in item a, which are not in the scope of TSTF-425. The staffs initial view is that these event-driven surveillance frequencies should not be relocated since they are not simply periodic requirements, but are condition-based.
- c.
Surveillance 4.8.1.2.1.b requires an 8-hour periodic verification of the alternate onsite emergency power source when it is used as a standby diesel generator in substitution for one of the required diesels, limited by a footnote to no more than 14 consecutive days. Although this requirement is not part of the standard TS, this surveillance is a plant-specific required action for an inoperable diesel generator, similar to the STS actions identified in item a. Therefore, the staffs initial view is that this surveillance frequency should not be relocated since it is an action requirement rather than a periodic surveillance.