ML17025A123

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Response to Request for Additional Information on Revised Applicability Matrix for Questions Regarding Risk-Informed GSI-191 Licensing Application
ML17025A123
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 01/19/2017
From: Connolly J
South Texas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-17003434, TAC MF2400, TAC MF2401
Download: ML17025A123 (4)


Text

......

Nuclear Operating Company South Texas Project Electric Generating Station P.O Box 289 Wadsworth. Te>(as 77483 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001.

South Texas Project Units 1and2 Docket Nos. STN 50-498, STN 50-499 January 19, 2017 NOC-AE-17003434 10 CFR 50.90 Revised Applicability Matrix for Response to Request for Additional Information Questions STSB 1 and 2 Regarding STP Risk-Informed GSl-191 Licensing Application (TAC Nos MF2400 and MF2401)

Reference:

Letter; J. Connolly to USNRC Document Control Desk; "Applicability of Application Supplement 1 Correspondence to Supplement 2 to STP Risk-Informed GSl-191 Licensing Application"; June 9, 2016; (NOC-AE-16003369) (ML16176A148).

In the above Reference, STP Nuclear Operating Company (STPNOC) provided information regarding request for additional information (RAI) responses that are no longer relevant to the STPNOC Risk-Informed GSl-191 application. Specifically, in Table 1 of Attachment 2 to the above Reference, STPNOC provided information related to the applicability of RAI Questions STSB 1 and 2 regarding use of Risk Managed Technical Specifications (RMTS). A revised applicability basis for this item is provided in the Enclosure to this letter.

There are no commitments in this letter.

If there are any questions or if additional information is needed, please contact Drew Richards at (361) 972-7666 or me at (361) 972-7344.

I declare under penalty of perjury that the foregoing is true and correct.

Executed 00 Ii.201 7 Site Vice President awh

Enclosure:

Revised Applicability Matrix for RAI Questions STSB 1 and 2 STI: 34428617

cc:

(paper copy)

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington, TX 76011-4511 Lisa M. Regner Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North (08H04) 11555 Rockville Pike Rockville, MD 20852 NRC Resident Inspector U.S. Nuclear Regulatory Commission P. 0. Box 289, Mail Code: MN116 Wadsworth, TX 77 483 (electronic copy)

NOC-AE-17003434 Page 2 of 2 Morgan. Lewis & Bockius LLP Steve Frantz, Esquire U.S. Nuclear Regulatory Commission Lisa M. Regner NRG South Texas LP Chris O'Hara Jim van Suskil Skip Zahn CPS Energy Kevin Pollo Cris Eugster L. D. Blaylock City of Austin Elaina Ball John Wester Texas Dept. of State Health Services Helen Watkins Robert Free

ENCLOSURE Enclosure NOC-AE-17003434 Page 1of2 Revised Applicability Matrix for RAI Questions STSB 1 and 2

Enclosure NOC-AE-17003434 Page 2 of 2 The response in the original Applicability Letter (ML16176A148) stated that although the description of the application of RMTS is correct in the RAI responses, the RMTS RAls are not applicable because RMTS is not required for the proposed 90-day completion time. STPNOC subsequently determined that there are circumstances where RMTS may apply in conjunction with the 90-day completion time of the proposed debris-specific TS and changed the applicability assessment to "Applicable".

Applicability and Letter Reference for

Response

Applicable ML14149A434 RAI Applicability Basis STSB: Questions 1 and 2 The description of the application of RMTS in RAI responses is

correct, but clarification would enhance understanding regarding how the application is affected by the proposed 90-day debris-specific TS action.

The proposed 90-day debris-specific TS action added to the ECCS and CS TS applies only to the effects of LOCA-generated debris. Because the 90-day required completion time exceeds the 30-day maximum allowed risk-informed completion time (RICT) for RMTS, use of RMTS for this action is not necessary and is not part of the action. However, if a condition unrelated to debris arises where a train of ECCS or CS is declared inoperable while the debris-specific action is being applied, the non-debris ECCS or CS TS Action (a) or Action (b) must also be applied. ECCS and CS TS Actions (a) and (b) permit the application of RMTS and calculation of a RICT. The RICT must include the risk contribution from the debris issue and is limited to a maximum completion time of 30 days. Action c for the debris still applies from the time it was entered and may not be extended by the RICT.

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