ML083450162
| ML083450162 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 12/24/2008 |
| From: | Thadani M Plant Licensing Branch IV |
| To: | Halpin E South Texas |
| Thadani, M C, NRR/DORL/LP4, 415-1476 | |
| References | |
| TAC MD9523, TAC MD9524 | |
| Download: ML083450162 (18) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001
. December 24, 2008 Mr. Edward D. Halpin Chief Nuclear Officer STP Nuclear Operating Company South Texas Project P. O. Box 289 Wadsworth, TX 77483
SUBJECT:
SOUTH TEXAS PROJECT, UNITS 1 AND 2 - RE: REGULATORY COMMITMENTS MANAGEMENT PROGRAM AUDIT REPORT (TAC NOS.
MD9523 AND MD9524)
Dear Mr. Halpin:
In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the U.S. Nuclear Regulatory Commission (NRC) informed licensees that the Nuclear Energy Institute document (NEI) 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to /\IRC.
In Office Instruction L1C-105, the NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, regulatory commitments are being effectively implemented, and changes to regulatory commitments are appropriately reported to NRC.
On August 19, 2008, the NRC staff performed an audit of the STP Nuclear Operating Company's (STPNOC's) South Texas Project (STP), Units 1 and 2, regulatory commitments management program.
The purpose of the audit was to examine STPNOC's regulatory commitments management program and regulatory commitments change process. The audit was conducted by examining the STPNOC commitments management records including a sample of regulatory commitments that have not been previously inspected or otherwise audited by the NRC staff, that are risk significant, and that were important to the NRC staff's decision-making process on the licensing actions for which respective commitments were made by STPNOC.
Based on the results of the on-site audit of STPNOC's procedures, processes, and records for managing regulatory commitments, and review of the identified sample of regulatory commitments and regulatory commitments change report, the NRC staff concludes that STPNOC has implemented the regulatory commitments management program effectively, and implemented regulatory commitment changes appropriately in accordance with NRC staff's Office Instruction L1C-105, and generally consistent with NEI 99-04.
E. Halpin -2 Details of the audit and the NRC staff's conclusions are set forth in the enclosed audit report.
The NRC staff appreciates the resources that were made available by your staff, both before and during the audit. If there are any questions, I can be contacted at (301) 415-1476 or by electronic mail at mohan.thadani@nrc.gov.
Sincerely, 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:
As stated cc w/encl: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE REGULATORY COMMITMENTS MANAGEMENT PROGRAM STP NUCLEAR OPERATING COMPANY SOUTH TEXAS PRO..IECT, UNITS 1 AND 2 DOCKET NOS. 50-498 AND 50-499
1.0 INTRODUCTION AND BACKGROUND
In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the U.S. Nuclear Regulatory Commission (NRC) informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to NRC.
On May 27, 2003, the Office of Nuclear Reactor Regulation (NRR) issued Office Instruction L1C-105, "Managing RegUlatory Commitments Made by Licensees to the NRC." L1C-105 is publicly available electronically from the Internet at the NRC web site, from the Agencywide Documents Access and Management System (ADAMS), Public Electronic Reading Room, ADAMS Accession No. ML022750041. L1C-105 provides the NRC staff and its stakeholders a reference for handling regulatory commitments made by the licensees for commercial nuclear power reactors. The guidance provided in L1C-105 is consistent with industry guidance prepared by NEI in NEI 99-04, "Guidelines for Managing NRC Commitment Changes."
As defined in NEI 99-04 and according to L1C-105, a "regulatory commitment" is an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to NRC. L1C-1 05 directs the NRR staff to audit the licensee's commitment management program by assessing the adequacy of the licensee's implementation of commitments made to the NRC in past licensing actions (amendments, relief requests, exemptions, etc.) and activities (bulletins, generic letters, etc.). L1C-105 instructs the NRR project managers to perform audits of the licensees' commitments every 3 years.
On August 19, 2008, the NRC staff performed an audit of the STP Nuclear Operating Company (STPNOC) South Texas Project (STP), Units 1 and 2, regulatory commitments management program.
Enclosure
-2 STPNOC has implemented Procedure OPGP 05-ZN-0002, Revision 4, "Licensing Commitments Management and Administration," which identifies its methods for establishing commitments, commitment identification and tracking, protecting commitments, commitments changes, and interfaces of the commitment management program with the licensee's Corrective Action Program databases.
The procedure specifies the purpose, definition of terms, responsibilities, requirements for effective management of regulatory commitments, and procedures for implementing changes to regulatory commitments.
A summary of the NRC staff's activities, reviews, and conclusions is outlined below.
2.0 AUDIT As stated above, on August 19, 2008, the NRC staff performed the regulatory commitments management audit at the STP, Units 1 and 2, site. L1C-105 limits the audit of commitments to those made by the licensees in writing to the NRC as a result of licensing actions (e.g.,
amendments, relief requests, exemptions, etc.) or licensing activities (e.g., bulletins, generic letters, etc.).
In preparation for the audit, the NRC staff searched ADAMS for the licensing actions, licensing activity, and other reports involving regulatory commitments and regulatory commitment changes during past 3 years or so. The staff also contacted STPNOC and obtained its list of regulatory commitments reported to the NRC staff during the past 3-year period. From the collected information, the NRC staff selected a representative sample of regulatory commitments that met the selection criteria identified in L1C-105 for the audit. The NRC staff asked STPNOC to provide the requisite documentation related to the commitments sample selected to support the audit.
The NRC staff also reviewed STPNOC's commitments change report, dated August 11, 2008 (ADAMS Accession No. ML082310641), and culled supplemental information for inclusion in this report as a selected sample of STPNOC's regulatory commitments change process.
The documents furnished by STPNOC included summary sheets providing the status of the commitments, source documents, and appropriate backup documentation as needed (i.e., plant procedures, examination records, and/or other plant documentation). The regulatory commitments management records reviewed by the NRC are: (1) summary of regulatory commitments implementation records, and (2) summary of regulatory commitments change reports.
2.1 Verification of Licensee's Programs for Implementation of Regulatory Commitments The NRC staff's audit was intended to confirm that the licensee has documented its implementation of its regulatory commitments made to the NRC staff in past licensing communications.
The NRC staff found that the Licensing Commitment Management and Administration procedure for managing the regulatory commitments provides an acceptable tool to capture the
- 3 NRC guidance on regulatory commitments management programs, and generally meets the acceptable guidance in NEI 99-04.
The licensee enters the regulatory commitments made to the NRC, that are explicit statements to take a specific action agreed to or volunteered by a licensee and submitted in writing on docket to NRC, into a commitment database. Each commitment is numbered and described by a commitment title and brief description. Comments and implementation dates are captured.
The licensee's staff is regularly trained in procedures for entering and updating the regulatory commitments in its regulatory commitments management program. The regulatory commitments program Procedure OPGP 05-ZN-0002, Revision 4, is followed in documenting, tracking, and implementing the regulatory commitments.
The sources of the commitments are documented in a source document. Incorporating documents provide the procedures or processes for maintaining and implementing the commitments. Closing documents provide the procedure or process for assuring that each regulatory commitment was properly completed, appropriately closed, and well documented. summarizes the representative sample of selected regulatory commitments that were evaluated for this audit. Based on the review of the selected sample of the regulatory commitments, the NRC staff concludes that the licensee's regulatory commitments management program generally conforms to the NRC accepted guidance in NEI 99-04, and is acceptable.
2.2 Verification of Licensee's Processes for Changes to Regulatory Commitments The regulatory commitments changes are evaluated in accordance with provisions of Nuclear Energy Institute's guidance in NEI 99-04, "Guidelines for Managing NRC Commitments." The changes are reported to NRC biannually. provides the latest STPNOC report regarding changes to regulatory commitments reported to NRC. The report lists the changes to regulatory commitments for the period from August 1, 2006, through July 30, 2008. The report includes a brief summary of the original regulatory commitment, a summary of the revised regulatory commitment, and justification for the change to the regulatory commitment.
Based on its review, the NRC staff concludes that the changes to regulatory commitments are being reported to NRC consistent with the NRC guidance,
3.0 CONCLUSION
Based on the results of the on-site audit of STPNOC procedures, processes, and documentation for managing regulatory commitments; and review of a selected list of regulatory commitments and regulatory commitments changes reported in the licensee's August 11,2008, report, the NRC staff concludes that STPNOC has implemented the regulatory commitments management program effectively, and implemented regulatory commitment changes appropriately, in accordance with L1C-105 and generally consistent with the NRC accepted guidance in NEI 99-04.
- 4 4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Jamie Paul Scott M. Head Wayne Harrison Principal Contributors: Mohan Thadani Glenna Lappert Date: December 24, 2008 Attachments:
As stated
ATTACHMENT 1 REGULATORY COMMITMENTS -
SUMMARY
OF AUDIT RESULTS AUDIT PERFORMED AUGUST 19, 2008 SOUTH TEXAS PROJECT, UNITS 1 AND 2
REGULATORY COMMITMENTS -
SUMMARY
OF AUDIT RESULTS AUDIT PERFORMED AUGUST 19, 2008 SOUTH TEXAS PROJECT, UNITS 1 AND 2 Commitment I Letter Number Subject CR Action No. Description of Commitment Implementation Status NOC-AE-0600 1985 South Texas Project, Unit 1 - 06-360-3 Repair of the defect will be deferred until CLOSED - Commitment closed with Work Request for Relief from ASME adequate time is available for the repair, but no Action Number 311247, completion date Boiler and Pressure Vessel Code, later than the next Unit 1 refueling outage, 10/26/06 by Steven D. Blossom. Commitment Section XI Requirements for the provided the condition continues to meet the completion date 11/17/06.
Essential Cooling Water System acceptance criteria of Generic Letter 90-05 (Relief Request RR-ENG-2-44)
NOC-AE-06001985 South Texas Project, Unit 1 - 06-360-4 Augmented monthly inspections have been CLOSED - Implemented and closed with the Request for Relief from ASME implemented to detect changes in the size of the replacement of the flange completed on Boiler and Pressure Vessel Code, discolored area or leakage. Structural integrity 10/12/06 which completed the commitment.
Section XI Requirements for the and the monitoring frequency will be re Essential Cooling Water System evaluated if the significant changes in the (Relief Request RR-ENG-2-44) condition of the dealloyed area are found during this monitoring.
Original LAR South Texas Project, Units 1 and 2 04-12263-15 Surveillance Requirements 4.8.2.1(c) and CLOSED - Completion date of commitment to NOC-AE-05001837, - Response to Request for 4.8.2.2(b) will comply with the 12-hour criterion change TS accordingly was completed 2/28/06 NOC-AE-0500 1913 Additional Information: Proposed for recharging. The TS amendment request will with RAI response. Commitments revised in incorporates changes Amendment to TS 3/4.8.2 to be revised accordingly. RAI response to LAR NOC-AE-05001837.
initiated in the RAI. Modify Requirements Related to Expected completion date in RAI of change Batteries and DC Systems stated 3/1/06.
Original LAR South Texas Project, Units 1 and 2 04-12263-19 The minimum float voltage allowed per cell is CLOSED - Completion date of commitment to NOC-AE-0500 1837, - Response to Request for 2.17 vdclcell. The minimum voltage per cell will change TS accordingly was completed 2/28/06 NOC-AE-0500 1913 Additional Information: Proposed be included in the Bases as background with RAI response. Commitments revised in incorporates changes Amendment to TS 3/4.8.2 to information for TS 3/4.8.2, "DC Sources." RAI response to LAR NOC-AE-05001837.
initiated in the RAI. Modify Requirements Related to Expected completion date in RAI of change Batteries and DC Systems stated 3/1106.
Original LAR South Texas Project, Units 1 and 2 04-12263-16 The modified performance discharge test CLOSED - Completion date of commitment to NOC-AE-0500 1837, - Response to Request for envelopes both the performance discharge test change TS accordingly was completed 2/28/06 NOC-AE-0500 1913 Additional Information: Proposed and the service discharge test. References to with RAI response. Commitments revised in incorporates changes Amendment to TS 3/4.8.2 to the performance discharge test as a substitute RAI response to LAR NOC-AE-05001837.
initiated in the RAI. Modify Requirements Related to for the service discharge test will be revised to Expected completion date in RAI of change Batteries and DC Systems specify the modified performance discharge test. stated 3/1106.
Original LAR South Texas Project, Units 1 and 2 04-12263-20 The E1B11 calculation used a final cell voltage CLOSED - Completion date of commitment to NOC-AE-0500 1837, - Response to Request for of 1.81 vdc which reduced the one-minute rate change TS accordingly was completed 2/28/06 NOC-AE-05001913 Additional Information: Proposed to 98.75 amps. This voltage value used should with RAI response. Commitments revised in incorporates changes Amendment to TS 3/4.8.2 to have been 1.78 vdc, consistent with the other RAI response to LAR NOC-AE-05001837.
initiated in the RAI. Modify Requirements Related to battery calculations. The calculations are to be Expected completion date in RAI of change Batteries and DC Systems updated accordingly. stated 3/1/06.
-2 Commitment /
Letter Number Subject CR Action No. Description of Commitment Implementation Status Original LAR South Texas Project, Units 1 and 2 04-12263-17 Until sufficient justification is available CLOSED - Completion date of commitment to NOC-AE-05001837, - Response to Request for supporting the 18-month interval, the South change TS accordingly was completed 2/28/06 NOC-AE-05001913 Additional Information: Proposed Texas Project will use the 12-month intervals with RAI response. Commitments revised in incorporates changes Amendment to TS 3/4.8.2 to between battery performance tests of batteries RAI response to LAR NOC-AE-05001837.
initiated in the RAt. Modify Requirements Related to that show degradation or that reach 85% of the Expected completion date in RAI of change Batteries and DC Systems service life for the application. stated 3/1/06.
Original LAR South Texas Project, Units 1 and 2 04-12263-18 A surveillance requirement will be added to CLOSED - Completion date of commitment to NOC-AE-0500 1837, - Response to Request for require performance discharge tests at least change TS accordingly was completed 2/28/06 NOC-AE-05001913 Additional Information: Proposed once per 24 months for any battery reaching with RAI response. Commitments revised in incorporates changes Amendment to TS 3/4.8.2 to 85% of the service life expected for the RAI response to LAR NOC-AE-05001837.
initiated in the RAI. Modify Requirements Related to application and capacity is equal to or greater Expected completion date in RAI of change Batteries and DC Systems than 100% of the manufacturer's rating. stated 3/1/06.
Original LAR South Texas Project, Units 1 and 2 04-12263-21 A spare non-class 1E battery charger may be CLOSED - Completion date of commitment to NOC-AE-05001837, - Response to Request for provided in the future to serve as an altemate change TS accordingly was completed 2/28/06 NOC-AE-05001913 Additional Information: Proposed means of restoring the associated battery with RAI response. Commitments revised in incorporates chang8s Amendment to TS 3/4,8.2 to terminal voltage if the affected batteries have RAI response to LAR NOC-AE-05001837.
initiated in the RAt. Modify Requirements Related to less than the minimum established float voltage Expected completion date in RAI of change Batteries and DC Systems and they are to be considered operable after 2 stated 3/1/06.
hours. The spare non-class 1E battery charger will be diesel-backed. This provision will be included in the STP Technical Specification Bases. If this modification is made, it will need to be included in STP UFSAR.
Original LAR South Texas Project, Units 1 and 2 04-12263-27 STPNOC will continue to use specific gravity CLOSED - Completion date of commitment to NOC-AE-05001837, - Response to Request for monitoring to measure electrolyte strength in change TS accordingly was completed 2/28/06 NOC-AE-05001913 Additional Information: Proposed addition to float current monitoring. The with RAI response. Commitments revised in incorporates changes Amendment to TS 3/4.8.2 to STPNOC will relocate the current battery RAI response to LAR NOC-AE-05001837.
initiated in the RAt. Modify Requirements Related to parameter for specific gravity from the TS to the Expected completion date in RAI of change Batteries and DC Systems Battery Monitoring and Maintenance Program. stated 3/1/06.
Original LAR South Texas Project, Units 1 and 2 04-12263-28 Maintain a 5% design margin allowing use of 2 CLOSED - Completion date of commitment to NOC-AE-0500 1837, - Response to Request for amps as the float current limit. This margin will change TS accordingly was completed 2/28/06 NOC-AE-05001913 Additional Information: Proposed be included in the TS Bases and in the battery with RAI response. Commitments revised in incorporates changes Amendment to TS 3/4.8.2 to sizing calculation. RAI response to LAR NOC-AE-05001837.
initiated in the RAt. Modify Requirements Related to Expected completion date in RAI of change Batteries and DC Systems stated 3/1/06.
Original LAR South Texas Project, Units 1 and 2 04-12263-29 STPNOC Commits to incorporate the Battery CLOSED - Completion date of commitment to NOC-AE-0500 1837, - Response to Request for Monitoring and Maintenance Program into the change TS accordingly was completed 2/28/06 NOC-AE-05001913 Additional Information: Proposed STP Technical Requirements Manual (TRM). with RAJ response. Commitments revised in incorporates changes Amendment to TS 3/4.8.2 to RAI response to LAR NOC-AE-05001837.
initiated in the RAI. Modify Requirements Related to Expected completion date in RAJ of change Batteries and DC Systems stated 3/1/06
-3 Commitment I letter Number Subject CR Action No. Description of Commitment Implementation Status Original LAR South Texas Project, Units 1 and 2 04-12263-25 The Battery Monitoring and Maintenance CLOSED - Completion date of commitment to NOC-AE-0500 1837, - Response to Request for Program provides for battery restoration and change TS accordingly was completed 2/28/06 NOC-AE-0500 19 13 Additional Information: Proposed maintenance which requires the following with RAI response. Commitments revised in incorporates changes Amendment to TS 3/4.8.2 to actions: RAI response to LAR NOC-AE-05001837.
initiated in the RAI. Modify Requirements Related to ./ Restore battery cells discovered with float Expected completion date in RAI of change Batteries and DC Systems voltage <2.13V. stated 3/1/06
./ Equalize and test battery cells discovered with electrolyte level below top of the plates.
./ Verify that the remaining cells are ?2.07V when a cell or cells are found to be <2.13V.
./ Take specific gravity readings prior to each discharge test.
Original LAR South Texas Project, Units 1 and 2 04-12263-23 Relocate to the Battery Monitoring and CLOSED - Completion date of commitment to NOC-AE-05001837, - Response to Request for Maintenance program (from 4.8.2.1.b): At least change TS accordingly was completed 2/28/06 NOC-AE-0500 1913 Additional Information: Proposed once per 92 days, verify: with RAI response. Commitments revised in incorporates changes Amendment to TS 3/4.8.2 to ./ There is no visible corrosion at either cell RAI response to LAR NOC-AE-05001837.
. initiated in the RAI. Modify Requirements Related to to-Ocell or terminal connections, or the Expected completion date in RAI of change Batteries and DC Systems connection resistance is no greater than stated 3/1/06 150x10*6 ohm; and
./ The average cell electrolyte temperature at six connected cells is above 65°F.
Original LAR South Texas Project, Units 1 and 2 04-12263-26 Relocate to the Battery Monitoring and CLOSED - Completion date of commitment to NOC-AE-05001837, - Response to Request for Maintenance Program (from 4.8.2.1.b): Within 7 change TS accordingly was completed 2/28/06 NOC-AE-05001913 Additional Information: Proposed days after a severe battery discharge with with RAI response. Commitments revised in incorporates changes Amendment to TS 3/4.8.2 to battery terminal voltage below 1.6 volts per cell, RAI response to LAR NOC-AE-05001837.
initiated in the RAJ. Modify Requirements Related to or severe battery overcharge with battery Expected completion date in RAI of change Batteries and DC Systems voltage above 2.5 volts per cell, verify that: stated 3/1/06
./ There is no visible corrosion at either cell to-cell or terminal connections, or the connection resistance of these items is less than or equal to 40x1 O~ ohm; and
./ The average electrolyte temperature of six connected cells is above 65°F.
Original LAR South Texas Project, Units 1 and 2 04-12263-24 Relocate to the Battery Monitoring and CLOSED - Completion date of commitment to NOC-AE-05001837, - Response to Request for Maintenance Program (from 4.8.2.1.c): At least change TS accordingly was completed 2/28/06 NOC-AE-05001913 Additional Information: Proposed once per 18 months, verify that: with RAI response. Commitments revised in incorporates changes Amendment to TS 3/4.8.2 to ./ The cells, cell plates, and battery racks RAI response to LAR NOC-AE-05001837.
initiated in the RAI. Modify Requirements Related to show no visual indication of physical Expected completion date in RAI of change Batteries and DC Systems damage or abnormal deterioration; stated 3/1/06
./ Cell-to-cell and terminal connections are clean, tight, and coated with anti-corrosion material; and
./ The resistance of each cell-to-cell and terminal connection is less than or equal to 150x1 O~ ohm.
ATTACHMENT 2 REGULATORY COMMITMENTS CHANGES SAMPLE -
SUMMARY
OF AUDIT RESULTS AUDIT PERFORMED AUGUST 19, 2008 SOUTH TEXAS PROJECT, UNITS 1 AND 2
REGULATORY COMMITMENTS CHANGES SAMPLE -
SUMMARY
OF AUDIT RESULTS AUDIT PERFORMED AUGUST 19, 2008 SOUTH TEXAS PROJECT, UNITS 1 AND 2 Condition Report Source Date of Number Source Document Date Change Original Commitment Description Revised Commitment Description Justification for Change 04-3365 NOC-AE-04001758 08/05/2004 12/05/2006 NOC-AE-04001758, 08/05/04 Altemative: The vendor for the analyses could not Response to Request for Information produce their deliverables on the Response to on NRC Generic Letter 2003 Revise the control room dose accident needed schedule.
Generic Letter Control Room Habitability analyses to reflect the results of the 2003-01 control room inleakage testing. Due Revise the control room dose accident Date April 30, 2007.
analyses to reflect the results of the control room inleakage testing. Due Date December 31, 2005 04-12498 NOC-AE-07002237 12/10/2007 07109/2008 NOC-AE-07002237, 12/10/2007 Submittal of letter verifying completion Extension of date to adopt revised
, Request for Extension for Final and confirming compliance will be ECCS sump strainer design basis is Response to Response to Generic Letter 2004-02 submitted to the NRC by December an administrative change and has no Generic Letter and Implementation of Revised Design 12,2008. effect on plant operations. NRC 2004-02 Basis for ECCS Sump approval was provided by telephone July 1, 2008, and by correspondence Following completion of the 10 CFR dated July 2, 2008.
50, Appendix B activities described above and the associated changes to the STP licensing basis, STPNOC will submit a letter verifying completion of all GL 2004-02 corrective actions and confirming compliance with the regulatory requirements listed in GL 2004-02.
06-6838 NOC-AE-O 1001196 12/03/2001 05/25/2006 Commitment for SDG allowed outage Implementation of risk management The existing requirements for time extension: actions will be based on reaching or implementing risk management action Proposed expecting to reach the 1E-06 (RMA) is simply based on being the Amendment to The NRC Safety Evaluation (SE) incremental core damage probability configuration beyond a prescribed Technical lists the compensatory actions for risk threshold instead of a prescribed time. For the Standby Diesel Specification 3.7.1.2 extending the allowed outage times time. This approach is consistent with Generator, Essential Cooling Water, for the Standby Diesel Generators the Risk Managed Technical and Essential Chilled Water, the RMA (TS 3.8.1.1), Essential Cooling specification (RMTS) Guidelines. The is implemented if the SSC will be Water(TS 3.7.4) and Essential specific requirement in the RMTS inoperable for longer than the duration Water(TS3.7.14). Theintemal Guidelines reads: of the allowed outage time prior to memo (HS-HS-35345) documents a approval of Amendment 85/72. For phone call with the NRC that For plant configurations in which one inoperable MD Auxiliary confirms that the intent of the SE the RMAT (Risk Management Feedwater pump, the RMA will be was that the compensatory actions Action Threshold) either has been implemented if the duration of the
-2 Condition Report Source Date of Number Source Document Date Change Original Commitment Description Revised Commitment Description Justification for Change 06-6838 would be required if the outage exceeded (emergent event) or is inoperable condition will exceed 14 (Cont'd) duration would be longer than the anticipated to be exceeded (either days. These times are prescriptive original allowed outage time (i.e., planned condition or emergent and do not take into account the actual longer than 72 hours3 days <br />0.429 weeks <br />0.0986 months <br />). event), appropriate compensatory quantified risk of the plant risk management actions shall be configuration when the SSC is Commitment for AFW motor-driven identified and implemented. For removed from service or becomes pump allowed outage time extension preplanned maintenance activities inoperable for an emergent condition.
(ref. NOC-AE-01001196): for which the RMAT is anticipated to be exceeded, RMAs shall be Implementation of the Maintenance Compensatory measures will be implemented at the earliest Rule (MR) as described in used to offset the increased risk of appropriate time. 10CFR50.65(a)(4) requires an allowing a 28-day AOT and will be assessment of risk for maintenance implemented when it is recognized The RMAT is the risk management and that the risk be managed.
that maintenance on a motor-driven action threshold and is established at STPNOC has established a AFW pump will last for more than 1E-06 incremental core damage configuration risk management 14 days. probability or 1E-07 incremental large program (CRMP) to comply with the early release probability. RMAs are MR. Consistent with NUMARC 93-01, Both commitments to implement risk management actions (i.e., it establishes specific risk thresholds compensatory actions are based on a compensatory action). that require compensatory action if the prescriptive time. configuration risk exceeds the These thresholds are consistent with threshold. The Non-Risk-Significant Procedure OPOP01-Z0-0006 is the the thresholds used by STPNOC in Threshold is established at an implementing procedure for the implementing Maintenance Rule incremental core damage probability compensatory action requirements. requirements. (ICDP) of 1E-06. RMA is required for configurations where the risk exceeds that threshold.
STPNOC is an industry pilot for a risk-informed process for determining allowed outage times for the STP Technical Specifications (TS). The risk-informed process involves the application of the STP Configuration Risk Management Program (CRMP) to calculate a risk-informed completion time (RICT) based on the time required for the risk calculated for a plant configuration to attain a threshold. The risk thresholds, the process for calculating the configuration risk, and the requirements for PRA quality are
-3 Condition Report Source Date of Number Source Document Date Change Original Commitment Description Revised Commitment Description Justification for Change 06-6838 described in the Electric Power (Cont'd) Research Institute (EPRI) Risk Managed Technical Specification Guidelines (RMTS Guidelines). The RMTS Guidelines applies the same ICOP threshold for RMA as the MR.
The RMTS Guidelines also establishes a incremental large early release probability (ILERP) threshold of 1E-07.
These thresholds are known as risk management action thresholds (RMAT). The RMTS Guidelines specifically requires RMAs for conditions that exceed the RMAT:
For plant configurations in which the RMAT either has been exceeded (emergent event) or is anticipated to be exceeded (either planned condition or emergent event),
appropriate compensatory risk management actions shall be identified and implemented. For preplanned maintenance activities for which the RMAT is anticipated to be exceeded, RMAs shall be implemented at the earliest appropriate time.
This commitment change is described in the license amendment request for the risk-informed TS (NOC-AE 06002005).
Revising the STP procedure to apply thresholds consistent with the MR and the RMTS Guidelines will establish an internally consistent risk-informed process with one set of criteria that are firmly grounded in industry and regulatory precedent.
- 4 Condition Report Source Date of Number Source Document Date Change Original Commitment Description Revised Commitment Description Justification for Change 07-457-66 NOC-AE-07002114 02/22/2007 12/12/2007 NOC-AE-07002114, Attachment 1, For both the SFP External Makeup During revision of implementing Page 4 of 18, Table A.2-3, SFP (Table A.2-2) and SFP External Spray procedures it was determined that the Phase 2 and 3 External Spray Strategy General (Table A.2-3) strategies the preferred backup method of connecting the Mitigation Strategies Description, states in part: source of water will be firewater from a portable pump to draw from the yard fire hydrant, if available, since it is identified Circulating Water locations NOC-AE-07002150 05/14/2007 '" the preferred source of water will more easily deployed. Water can also in the procedure would take more than be firewater from a yard fire be supplied by pumping water from the 2 hours0.0833 days <br />0.0119 weeks <br />0.00274 months <br />. Therefore two other locations Phase 2 and 3 hydrant. if available, since it is more Circulating Water System below where it was deemed feasible to meet Mitigation Strategies easily deployed. Water can also be ground piping located West of each the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> deployment time were
- RAI Response supplied by pumping water from the Fuel Handling Building using the diesel identified. The Demineralized Water Circulating Water System below driven portable pump. Other sources Storage Tank has a capacity of up to AE-NOC-07001653 07111/2007 ground piping located West of each are the Demineralized Water Storage 1 million gallons. The Organics Basin Fuel Handling Building using the Tank located east of the Unit 1 Fuel contains water from outage activities Safety Evaluation diesel driven portable pump. Handling Building or the Organics and rain water.
for EA-02-026 Basin located southeast of the Unit 2
... The strategy will be deployed Fuel Handling Building . The capability to deploy the strategies within 2 hours0.0833 days <br />0.0119 weeks <br />0.00274 months <br /> when fuel is stored in within 2 hours0.0833 days <br />0.0119 weeks <br />0.00274 months <br /> and for at least 12 an undispersed configuration. ...The SFP External Makeup (Table hours with onsite water sources will be A.2-2) and SFP External Spray (Table met by the revised strategy. The Similar commitments were made for A.2-3) strategies will be capable of preferred source of water will continue the SFP External Makeup Strategy being deployed within 2 hours0.0833 days <br />0.0119 weeks <br />0.00274 months <br />. to be the firewater system from a yard (Table A.2-2) on, Page 2 of 18, where fire hydrant, if available. There are it stated that the portable diesel driven Water Source & Capacity: "... there options in the strategies for long term pump can be supplied from several is available over 1.2E7 gallons from water supply by connecting the different long term sources and the Circulating Water System and portable pump to draw water from the supplement the existing fire water approximately 1 million gallons from Demineralized Water Storage Tank, system" to include ..." the Demineralized Water Storage the Organics Basin, or the Circulating Tank." Water System (CWS) below ground Water Source & Capacity"... 1.2E7 piping to charge the fire header gallons from the Circulating Water through a yard hydrant. The capability System." to set-up the portable pump to draw water from the Demineralized Water In addition, in NOC-AE-07002150, Tank into the SFP within the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Attachment 1, Page 2 of 5, RAls #5 requirement has been validated (CR and #8, STP clarified that both the 07-457-65). The alternate water SFP External Makeup (Table A.2-2) supplies are necessary because there and SFP External Spray (Table A.2-3) may be competing needs for the strategies will be developed to deploy firewater system. The equipment within 2 hours0.0833 days <br />0.0119 weeks <br />0.00274 months <br /> in accordance with NEI necessary to use these sources is guidance. staged and available. CREE
- 5 Condition Report Source Date of Number Source Document Date Change Original Commitment Description Revised Commitment Description Justification for Change 07-457-66 07-457-63 validates the flow rates (Cont'd) using the Demineralized Water Tank as the water source. CREE 07-457-37 and 07-457-38 validate flow rates and capacities using the CWS which can be still be deployed but will require additional set-up time to access the CWS piping if the CWS is determined to be necessary.
The commitment in NOC-AE 07002150, Attachment 1, RAI 8 Page 2 of 7, Table A.2-3 (SFP External Spray Strategy) further clarified that the strategy will be developed to deploy within 2 hours0.0833 days <br />0.0119 weeks <br />0.00274 months <br />. The (implementing procedures) guidance will require that the strategy be deployed within 2 hours0.0833 days <br />0.0119 weeks <br />0.00274 months <br /> when fuel is not dispersed and no later than 5 hours0.208 days <br />0.0298 weeks <br />0.00685 months <br /> when fuel is dispersed.
While the spray strategy has been developed to ensure deployment within 2 hours0.0833 days <br />0.0119 weeks <br />0.00274 months <br />, it can be deployed no later than 5 hours0.208 days <br />0.0298 weeks <br />0.00685 months <br /> when fuel is in a dispersed configuration.
These commitments were reflected in the Safety Evaluation for AE-NOC 07001653, Appendix 8 sections, 2.3.1 and section 2.3.2; however, the specific sources of water were not specified in the "Evaluation" section. It is acceptable to make this change without prior NRC notification and approval.
The change will be reflected in the next periodic report of commitment changes and the NRC will be advised of the change during their 2008 inspection of 85b implementation under NRC TI 2515/171.
-6 Condition Report Source Date of Number Source Document Date Change Original Commitment Description Revised Commitment Description Justification for Change 07-491 NOC-AE-02001320 04/25/2002 07/30/2008 Licensee Event Report 02-001 - CRE Revised OPOP02-HE-001. Electrical Replacing the damper tables and Ventilation System Failed to Maintain Auxiliary Building HVAC System to description in the addendum to the Control Room Positive Pressure in the Control Room remove the description and list procedure with the instructions for Envelope described above and to add procedure communication with the control room Ventilation Corrective Action #2: Revised the precautions section to state: provides Operations with positive and System Electrical Auxiliary Building HVAC immediate configuration control of System procedure to include a During normal (non-emergency) system boundaries rather than relying description of the CRE HVAC modes of operation. system registers on a lengthy table of information.
boundary, a list of fire dampers that or access panels may be removed to can affect CRE HVAC operability and facilitate inspection provided the The use of the dedicated individual for general precautions reminding following precautions are in place. control of the damper configuration is personnel that surrounding HVAC consistent with the guidance for systems can affect CRE HVAC A. Communications are established manual actions in Regulatory Issue operability. between the control room and the Summary 2005-20 (now in Part 9900 I
working group. of the NRC Inspection Manual). The restoration process is simple and there B. In the event of an HVAC actuation are no environmental conditions that to an emergency mode, the would impact the ability of a dedicated register or access panel is to be individual to reinstall an access cover reinstalled immediately and or register.
secured in place.
Incorporation of the guidance into the C. Notify the Control Room that the operating procedure makes future access panel or register has been changes subject to a codified change reinstalled. process (i.e., 10 CFR 50.59). In accordance with NEI 99-04, this corrective action need not be tracked as a commitment.
Note that this commitment change was not documented initially, and this justification was performed after the fact as a Condition Report action.
December 24, 2008 E. Halpin -2 Details of the audit and the NRC staff's conclusions are set forth in the enclosed audit report.
The NRC staff appreciates the resources that were made available by your staff, both before and during the audit. If there are any questions, I can be contacted at (301) 415-1476 or by electronic mail at mohan.thadani@nrc.gov.
Sincerely, IRAI 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:
As stated cc w/encl: Distribution via Listserv DISTRIBUTION:
PUBLIC LPLIV Reading RidsAcrsAcnw_MailCTR Resource RidsNrrDorlLpl4 Resource RidsNrrPMSouthTexas Resource RidsNrrLAJBurkhardt Resource RidsOgcRp Resource RidsRgn4MailCenter Resource ADAMS Accession No. Ml083450162 OFFICE NRR/LPL4/P NRRlLPL4/LA NAME MThadani JBurkhardt DATE I'" /1 ~~ 12/16/08