ML20137Z365

Summary of 970403 Meeting W/Util in Rockville,Md to Discuss Staff Review of Licensee Pilot Submittal for Section 3.5 of Project Conversion Amend.List of Attendees & Staff Handouts Encl

ML20137Z365
Person / Time
Site:	South Texas
Issue date:	04/22/1997
From:	Kennedy J NRC (Affiliation Not Assigned)
To:	NRC (Affiliation Not Assigned)
References
NUDOCS 9704240119
Download: ML20137Z365 (9)

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• • • • • April 22, 1997 LICENSEE: HOUSTON LIGHTING & POWER COMPANY FACILITY: South Texas Project

SUMMARY

OF APRIL 3, 1997, MEETING ON THE SOUTH TEXAS PROJECT REQUEST TO CONVERT TO THE IMPROVED STANDARD TECHNICAL SPECIFICATIONS A meeting was held on Thursday, April 3,1997, for the Nuclear Regulatory Commission (NRC) staff and the licensee to discuss the staff's review of the licensee's pilot submittal for Section 3.5 of the South Texas Project (STP) conversion amendment. The meeting was held at the request of the staff at NRC headquarters in Rockville, Maryland. A notice of this meeting was issued on March 18, 1997. Attachment.1 is the list of attendees. Attachment 2 is the staff's handout used daring the meeting.

In a letter to the licensee dated November 27, 1996, te staff identified numerous deficiencies in the licensee's amendment request to convert the STP Technical Specifications (TS) to the improved Standard Technical Specification format. A meeting was held on December 12, 1996, to discuss how best to supplement the original application. During that meeting, the licensee stated that a pilot supplemental submittal for one section of the TS would be submitted for staff review prior to a full supplement for the entire conversion amendment. On February 11, 1997, the licensee submitted revised Section 3.5 of the TS for staff review.

During the April 3, 1997, meeting, the staff noted that the licensee's pilot submittal did attempt to address previous comments made by the NRC regarding the adequacy of the technical justification supporting the amendment.

However, the staff noted that there are still some areas for improvement.

Specifically, the key areas that need additional work are: (1) the philosophy behind which STP is converting TS for a standard 2-train plant to TS for the STP 3-train design; and (2) the issue of staggered test basis.

As identified in Attachment 2, the staff noted that the licensee's discussions in the February 11, 1997, submittal regarding the 3-train philosophy and staggered test basis were somewhat confusing and needed to be reworked. The licensee agreed to modify the table in the pilot submittal that contains proposed changes in allowed outage times (A0Ts) to make it more clear with respect to conformance with the standard TS A0Ts. Currently, the A0Ts for a number of systems with 2 trains inoperable are not consistent with the standard TS A0Ts for systems with I train inoperable. The staff indicated that the licensee needed to focus on consistency between the STP A0Ts and

those in the standard TS.

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The staff also noted that the licensee's discussion of staggered testing i requirements in the February 11, 1997, submittal was confusing. The licensee agreed to rewrite that discussion in more simple terms to identify the need for STP to have a longer interval in which to accomplish the staggered testing 9704240119 970422 PDR ADOCK 05000498

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> l requirements. The need for a larger interval stems f:om the fact that STP has 3 trains to test rather than the standard 2 trains at most other nuclear plants. Therefore, the time between tests will be langer.

The staff then proceeded to go through each of the ct.nversion packaging I examples identified in Attachment 2. The staff pointed cut that the wording in a number of the discussion of changes was confusing and could be more clear as to what was being changed, why it was being changed, and why that change .

was acceptable. The staff agreed to send the licensee a comprehensive listing l of the issues identified by the NRC's contractor who reviewed the licensee's j original conversion application. The staff noted that the contractor's report '

had not been reviewed by the staff for accuracy. I 1

At the end of the meeting, the licensee noted that they would be reworking the l discussions on 3-train conversion and staggered test basis and resubmitting them to the staff in the near future. In addition, the licensee is still on track to provido the remaining revised TS sections for staff review sometime in June 1997.

CRIGIfML SIGED BY:

Janet L. Kennedy, Project Manager Project Directorate IV-1 i Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499 Attachments: 1. List of fleeting Attendees

2. NRC Handout cc w/atts: See next page DISTRIBUTION:

HARD COPY E-MAIL Docket File SCollins/FMiraglia (SJC1/FJM) RZimmerman (RPZ)

PUBLIC JRoe (JWR) EAdensam (EGA1)

PD4-1 r/f TAlexion (TWA) CHawes (CMH2)

OGC WBeckner (WDB) PGwynn (TPG)

ACRS CSchulten (CSSI) JKennedy (JLK2)

CGrimes (CIG) ETomlinson (EBT)

Document Name: ST040397.MTS %db 0FC PM/PD4-1 ._ LA/PD4-1 TSB S

//_ D/PD4-1(M H NAME JKennedy/vw CHawesAGU CGrimedMk WBecknh[6 DATE il // 7/97 Y//8/97 &/M/97 9 /22/97 COPY DES /N0 YES/N0 dS'fN0 YES/(To>

0FFICIAL RECORD COPY gg3gCMTEBCDPV

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requirements. The need for a larger interval stems from the fact that STP has 3 trains to test rather than the standard 2 trains at most other nuclear

. plants. Therefore, the time between tests will be longer.

The staff then proceeded to go through each of the conversion packaging examples idontified in Attachment 2. The staff pointed out that the wording in a number of the discussion of changes was confusing and could be more clear as to what was being changed, why it was being changed, and why that change was acceptable. The staff agreed to send the licensee a comprehensive listing of the issues identified by the NRC's contractor who reviewed the licensee's original conversion application. The staff noted that the contractor's report had not been reviewed by the staff for accuracy.

At the end of the meeting, the licensee noted that they would be reworking the discussions on 3-train conversion and staggered test basis and resubmitting them to the staff in the near future. In addition, the licensee is still on

, track to provide the remaining revised TS sections for staff review sometime i

in June 1997.

s ie L /anwkp .,

Janet L. Kennedy, Project Manager Project Directorate IV-I Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499

! Attachments: 1. List of Meeting Attendees

2. NRC Handout 4

cc w/atts: See next page l

d 1

. Houston Lighting & Power Company South Texas, Units 1 & 2 cc:

Mr. David P. Loveless Jack R. Newman, Esq.

Senior Resident Inspector Morgan, Lewis & Bockius U.S. Nuclear Regulatory Commisrion 1800 M Street, N.W.

P. O. Box 910 Washington, DC 20036-5869 Bay City, TX 77414 Mr. Lawrence E. Martin Mr. J. C. Lanier/M. B. Lee General Manager, Nuclear Assurance Licensing City of Austin Houston Lighting and Power Company Electric Utility Department P. O. Box 289 721 Barton Springs Road Wadsworth, TX 77483 Austin, TX 78704 Rufus S. Scott Mr. M. T. Hardt Associate General Counsel Mr. W. C. Gunst Houston Lighting and Power Company City Public Service Board P. O. Box 61867 P. O. Box 1771 Houston, TX 77208 San Antonio, TX 78296 Joseph R. Egan, Esq.

Mr. G. E. Vaughn/C. A. Johnson Egan & Associates, P.C.

Central Power and Light Company 2300 N Street, N.W.

P. O. Box 289 Washington, DC 20037 Mail Code: N5012 Wadsworth, TX 74483 Office of the Governor ATTN: Andy Barrett, Director INP0 Environmental Policy Records Center P. O. Box 12428 700 Galleria Parkway Austin, TX 78711 Atlanta, GA 30339-3064 Arthur C. Tate, Director Regional Administrator, Region IV Division of Compliance & Inspection U.S. Nuclear Regulatory Commission Bureau of Radiation Control 611 Ryan Plaza Drive, Suite 400 Texas Department of Health Arlington, TX 76011 1100 West 49th Street Austin, TX 78756 Dr. Bertram Wolfe 15453 Via Vaquero Texas Public Utility Commission Monte Sereno, CA 95030 ATTN: Mr. Glenn k'. Dishong 7800 Shoal Creek Blvd.

Judge, Matagorda County Suite 400N Matagorda County Courthouse Austin, TX 78757-1024 1700 Seventh Street Bay City, TX 77414 Mr. William T. Cottle Executive VP & General Manager Nuclear Houston Lighting & Power Company South Texas Project Electric Generating Station P. O. Box 289 Wadsworth, TX 77483

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ATTENDEES AT MEETING OF APRIL 3. 1997 ON THE SOUTH TEXAS PROJECT CONVERSION PILOT SUBMITTAL 4

JME AFFILIATION

J. Kennedy NRR/DRPW/PD4-1 i C. Schulten NRR/TSB T. Alexion NRR/DRPW/PD4-1 W. Beckner NRR/DRPW/PD4-1 M. McBurnett HL&P/ Licensing W. Harrison HL&P/ Licensing j M. Felix HL&P/ Licensing J. Self HL&P/ Excel J. Pinzon HL&P/ Licensing

C. Grimes NRR/TSB

E. Tomlinson NRR/TSB 1

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ATTACHMENT 1 l

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i South Texas Conversion LCO 3.5 Pilot Comments  !

, Philosophy for incorporating Three-Train Design into improved Technical Specifications

-The objective of the conversion philosophy was intended to simply demonstrate comparability of the ITS for South Texas with the restrictions applicable to a two-train plant, to simply justify Completion. Times for one inoperable train or component. The philosophy described in the " pilot" package does not achieve this  ;

objective, and appears to introduce unnecessary complexity to justify being I different from both the CTS and the STS. A typical justification for the three-train conditions consists of: The new ITS Actions are designed to include consideration of the unique STP three train design Independent RHR subsystems which are utilized for normalshutdown cooling in this condition, and LTOP considerations. In addition, Tables 1 and 2 are not very clarifying, and the notes to Table 2 raise additional questions regarding the finality of the Completion Time values in the conversion application.

The "three-train" philosophy can be more efficiently accompIlshed for the conversion (separate from the "four train" instrumentation philosophy) by developing a simply deterministic comparison to "two-train" allowances for system or component functional capabilities.

STP Staggered Test Basis STS Definition: A STAGGEREO TEST BASIS shall consist of the testing of one of the systems, subsystems, channels, or othcr designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other designated components in the associated function.

STP proposes an adjustment in the intervals for staggered testing to accommodate the survelliance testing of three Engineered Safety Feature (ESF) trains instead of the standard two ESF trains. STP states that to manage the three safety train design, they use a twelve week maintenance and test (M&T) program to facilitate safe and effective plant operations. STP has the three safety trains and defines a j

" fourth train" comprised of safety related components such as RPS and ESF l l actuation logics. I

{ l l STP states that the current TS definition provides enough flexibility to adapt to the  ;

l three safety feature train design, while the definition in the ISTS does not provide '

the flexibility. The staff notes that for testing 3 trains at a 31 day frequency, CTS l

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ATTACMENT 2 -

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l C l staggered test basis would require one train tested once every 10 and one third i days (31 days divided bv 3 trains). For testing 3 trains at a 31 day frequency, l

! STS staggered test basis would require one train tested once every 31 days (31 l

days ilmaa 3 trains). STP states that the definition coupled with the surveillance  ;

intervals found in ISTS is the basis for requesting staggered test intervals that I differ from the ISTS. Using " staggered intervals" in a 12 week M&T program )

appears to be unrelated to the defined term STAGGEREI) TEST BASIS used in STS 1 for establishing frequency requirements for specified TS surveillances. l l l Conversion Packaging Examples i

1. The proposed LCO 3.5.3 includes four Notes. Note 1 states that more than ADa HHSl pump breaker may be racked ja until one or more cold leg l temperatures (s) is/are less than 325'F.

l DOC L.9 (the justification for the proposed changes) includes a statement l that all but one HHSI pump breaker is required to be racked gut after I entering Mode 4 from Mode 3 orior to one or more cold leg temperature (s) j decreasing below 325'F.

o Note 1 in ITS LCO 3.5.3 does not agree with DOC L.9, and it appears l

that the Note may be wrong. The LCO requires 2 OPERABLE HHSI i pumps with one (1) pump breaker racked in while Note 1 would allow all HHSI breakers to be racked in until all four cold leg temperatures are less than 325'F.

2. Note 3 to the proposed LCO 3.5.3 states that all HHS! breakers may be racked nut prior to entering Mode 4 from Mode 5 until one or more RCS cold ,

leg temperature (s) is/are greater than 225'F. (Note that the term "may be racked out" implies that the breakers may also be racked in.)

DOC L.9, which was added as part of the pilot package, includes a statement that all but one HHS1 pump breakers is required to be racked nul after entering Mode 4 from Mode 5 prior to one or more cold leg temperatures exceeding 225'F.

e Proposed Note 3 and DOC L.9 do not agree. As written, Note 3 would allow all HHSI breakers to be racked JD with the Unit in Mode 4 (with RCS cold legs less than 225'). This appears to contradict the LCO which reouires 2' OPERABLE HHSI pumps and nne pump breaker racked in.

Comment: DOC L.9 is more representative of CTS requirements than l- proposed Note 3. The proposed Note is different than the STS and it may l

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be easier to include SRs to verify appropriate HHSI pump breaker positions as a function of plant status.

! 3. DOC L.9 provides justification for changing LCO 3.5.3 to delete the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />

, requirement for restricting only one of the two operable HHSl pumps to have j lts breaker racked .1 for LTOP considerations and only allow abnormal

alignments basec purely on the temperature of the RCS cold legs. Part of DOC L.9 states, "The four hour limit did little to contribute to minimization of risk, rather it imposed an additional unnecessary restriction on plant operators requiring diversion of their attention from proceeding with the required operations to track a time limit of little significance."

The above statement is part of the justification for replacing CTS 3.5.3.1 l

, Actions a and b with proposed insert 5. The justification lacks substance. I in addition, there is no explanation regarding a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time limit in CTS '

Cond. a or b.

l 4. In the NUREG markup, parts of Cond. B and Action B.1 for LCO 3.5.3, l ECCS - Shutdown, are annotated with a reference to JFD 1 which, in turn,

says that brackets are removed and plant specific nomenclature is provided.

The change to the NUREG consists of replacing the ECCS high head

subsystem with one ECCS train, in this case, the annotated material is l deleted without explanation.

5. The licensee has proposed to delete the permissive in the Note to the STS SR 3.5.3.1. JFD 10 states that the STP design does not require any manual ,

alignment to change from RHR mode of operation to ECCS mode of I operation. It is not clear what is meant by manual alignment at STP, but i considering it is unlikely that there is LOCA signal when the plant is shutdown, alignment to the ECCS mode must at least require pushing a button, and probably much more. As a minimum, this STS deletion and the

associated JFD need to be expanded. It is not clear that the licenses understands the difference between remote manual operation and the manual capab3ity addressed the STS Note.

6. In SR 3.5.3.1, the STS SRs 3.5.2.4 and 3.5.2.8 are deleted from the list of applicable SRs. JFD 1 does not provide a justification for this deletion. l

7. STP added a new change to revise the pressure requirement above which power from the accumulator isolation valves must be removed, based on operational flexibility and alternate means of protection. The CTS requirement is 1000 psig. The proposed ITS requirement is 2000 psig. The change was not made consistently, for example, the change was made in the applicable SR (SR 3.5.1), but a Bases Background insert states, "Above

.- . .- . - . - . _ . . - - . . . . . . . - - . . = - . - . . . . . . . - .- - _ - . -

6 1000 psig in the pressurizer, the accumulator's discharge valve is open with electricalpower removed from the MOV. . . ". In addition, NUREG LCO 3.5.1 was not changed to reflect the new value of 2000 psig. -

8. The way in which the licensee has chosen to delineate the Justification for Deviations adds to the confusion of the package. Because the JFDs have been divided up into JFDs for the TS and JFDs for the Bases Section, it is hard to tell which JFD is being discussed. The problem is that the JFDs for the Bases and the JFDs for the TS each are numbered 1 through n. The

! JFDs should be numbered sequentially (i.e., the JFDs for the Bases should l start at JFD 11).

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