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Category:CORRESPONDENCE-LETTERS
MONTHYEARNOC-AE-000675, Forwards Clarification on Items Included in 990531 Response to RAI Re Proposed License Amend Associated with Operator Action for Sbloca,As Requested1999-10-21021 October 1999 Forwards Clarification on Items Included in 990531 Response to RAI Re Proposed License Amend Associated with Operator Action for Sbloca,As Requested NOC-AE-000680, Forwards Rev 5 to 0PGP03-ZV-0001, Severe Weather Plan1999-10-20020 October 1999 Forwards Rev 5 to 0PGP03-ZV-0001, Severe Weather Plan NOC-AE-000683, Forwards 30-day Rept Concerning Significant Changes to Accepted Large Break Loss of Coolant Accident ECCS Evaluation Model for South Tx Project,Units 1 & 2,IAW 10CFR50.46(a)(3)(ii)1999-10-19019 October 1999 Forwards 30-day Rept Concerning Significant Changes to Accepted Large Break Loss of Coolant Accident ECCS Evaluation Model for South Tx Project,Units 1 & 2,IAW 10CFR50.46(a)(3)(ii) ML20217K9341999-10-15015 October 1999 Forwards SER Accepting Util 990609 Relief Request RR-ENG-2-4 for Relief from ASME Code,Section XI, Nondestructive Exam Requirements Applicable to Stp,Units 1 & 2,reactor Vessel Closure Head Nuts ML20217K9091999-10-15015 October 1999 Forwards SER Accepting Util 990609 Relief Request RR-ENG-2-3 from ASME Code,Section Xi,Nondestructive Exam Requirements Applicable to South Texas Project,Units 1 & 2, Pressurizer Support Attachment Welds 05000498/LER-1999-008, Forwards LER 99-008-00 Re Turbine Trip That Occurred While Performing Main Turbine Emergency Trip Test.Commitments Made by Licensee Are Listed in Corrective Actions Section of LER1999-10-12012 October 1999 Forwards LER 99-008-00 Re Turbine Trip That Occurred While Performing Main Turbine Emergency Trip Test.Commitments Made by Licensee Are Listed in Corrective Actions Section of LER NOC-AE-000674, Forwards Requested Estimates of Needs for Operator Licensing Exams,Per AL-99-03, Operator Licensing National Exam Schedule1999-10-12012 October 1999 Forwards Requested Estimates of Needs for Operator Licensing Exams,Per AL-99-03, Operator Licensing National Exam Schedule NOC-AE-000625, Requests Partial Relief from ASME Section XI Visual Exam Requirements of IWA-5242(a).Relief Request Is Based on Provisions of Draft ASME Section XI Code Case N-616,which Is Expected to Be Published in Near Future1999-10-0707 October 1999 Requests Partial Relief from ASME Section XI Visual Exam Requirements of IWA-5242(a).Relief Request Is Based on Provisions of Draft ASME Section XI Code Case N-616,which Is Expected to Be Published in Near Future NOC-AE-000610, Requests Relief from ASME Section XI Code Nondestructive Exam Requirements of IWA-5250(a)(2) for Second Inservice Insp Interval,Per Provisions of 10CFR50.55a(3)(i)1999-10-0707 October 1999 Requests Relief from ASME Section XI Code Nondestructive Exam Requirements of IWA-5250(a)(2) for Second Inservice Insp Interval,Per Provisions of 10CFR50.55a(3)(i) NOC-AE-000653, Requests Relief from ASME Section XI Code Requirements of Table IWE-2500-1 for VT-3 Visual Exam of Seals & Gaskets on Airlocks,Hatches & Other Devices Required to Assure Containment leak-tight Integrity,Per 10CFR50.55a(a)(3)(i)1999-10-0707 October 1999 Requests Relief from ASME Section XI Code Requirements of Table IWE-2500-1 for VT-3 Visual Exam of Seals & Gaskets on Airlocks,Hatches & Other Devices Required to Assure Containment leak-tight Integrity,Per 10CFR50.55a(a)(3)(i) ML20217C3221999-10-0707 October 1999 Forwards Insp Repts 50-498/99-16 & 50-499/99-16 on 990808-0918.No Violations Noted.Insp Generally Characterized by safety-conscious Operations,Sound Engineering & Maint Practices & Careful Radiological Work Controls 05000499/LER-1999-006, Forwards LER 99-006-00,re Entry Into TS 3.0.3.Licensee Commitments Listed in Corrective Actions Section of Attachment1999-09-30030 September 1999 Forwards LER 99-006-00,re Entry Into TS 3.0.3.Licensee Commitments Listed in Corrective Actions Section of Attachment ML20212L1651999-09-30030 September 1999 Responds to STP Nuclear Operating Co 981012 & s Which Provided Update to TS Bases Pages B 3/4 8-14 Through B 3/4 8-17.NRC Staff Found Change Consistent with TS 3/4.8.2 DC Sources. Staff Found & Deleted Typographical Error NOC-AE-000664, Forwards Rev 1 to STP Electric Generating Station Unit 1 Cycle 9 COLR & Rev 1 to STP Electric Generating Station Unit 2 Cycle 7 Colr1999-09-30030 September 1999 Forwards Rev 1 to STP Electric Generating Station Unit 1 Cycle 9 COLR & Rev 1 to STP Electric Generating Station Unit 2 Cycle 7 Colr ML20212J7141999-09-29029 September 1999 Forwards Insp Repts 50-498/99-15 & 50-499/99-15 on 990920-24 at South Texas Project Electric Generating Station.No Violations Noted.Insp Covered Requalification Training Program & Observation of Requalification Activities NOC-AE-000646, Informs NRC That STP Nuclear Operating Co Is Y2K Ready IAW Nei/Nusmg 97-07 Guidelines & Also Provides Response to NRC Ltr1999-09-28028 September 1999 Informs NRC That STP Nuclear Operating Co Is Y2K Ready IAW Nei/Nusmg 97-07 Guidelines & Also Provides Response to NRC Ltr ML20212J0651999-09-27027 September 1999 Discusses Licensee 980330 Response to GL 97-06, Degradation of SG Internals. Concludes That Response to GL Provides Reasonable Assurance That Condition of SG Internals in Compliance with Current Licensing Bases for Facility ML20212F1791999-09-24024 September 1999 Discusses 990923 Meeting Conducted in Region IV Ofc Re Status of Activities to Support Confirmatory Order, ,modifying OL & to Introduce New Director,Safety Quality Concerns Program.List of Attendees Encl ML20212E9091999-09-23023 September 1999 Discusses GL 98-01, Year 2000 Readiness of Computer Sys at Npps, Supplement 1 & STP Nuclear Operating Co Response for STP Dtd 990629.Understands That at Least One Sys or Component Listed May Have Potential to Cause Transient ML20212F2111999-09-22022 September 1999 Forwards Review of SG 90-day Rept, South Texas Unit-2 Cycle 7 Voltage-Based Repair Criteria Rept, Submitted by Util on 990119 NOC-AE-000633, Forwards Rev 3 to SG-99-04-005, STP 1RE08 Outage Condition Monitoring Rept & Final Operational Assessment. Rept Satisfies Reporting Requirements of NEI 97-06,dtd Dec 19971999-09-21021 September 1999 Forwards Rev 3 to SG-99-04-005, STP 1RE08 Outage Condition Monitoring Rept & Final Operational Assessment. Rept Satisfies Reporting Requirements of NEI 97-06,dtd Dec 1997 NOC-AE-000634, Forwards Addl Info Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Povs. MOV design-basis Review Checklist,Encl1999-09-21021 September 1999 Forwards Addl Info Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Povs. MOV design-basis Review Checklist,Encl NOC-AE-000649, Forwards Current Annual Financial Data for STP Electric Generating Station Per 10CFR50.71(b),acting on Behalf of Central Power & Light Co,City of Austin,Tx,City Public Svc Board of San Antonio & Hl&P1999-09-21021 September 1999 Forwards Current Annual Financial Data for STP Electric Generating Station Per 10CFR50.71(b),acting on Behalf of Central Power & Light Co,City of Austin,Tx,City Public Svc Board of San Antonio & Hl&P 05000499/LER-1999-005, Forwards LER 99-005-00,re Esfa Following Loss of Power to Standby Transformer 2 Due to Electrical Fault.Licensee Commitments Are Listed in Corrective Actions Section of LER1999-09-20020 September 1999 Forwards LER 99-005-00,re Esfa Following Loss of Power to Standby Transformer 2 Due to Electrical Fault.Licensee Commitments Are Listed in Corrective Actions Section of LER ML20212D9171999-09-16016 September 1999 Informs That on 990818,NRC Completed Midcycle PPR of South Texas Project & Identified No Areas in Which Performance Warranted Insp Beyond Core Insp Program.Details of Insp Plan Through Mar 2000 & Historical Listing of Plant Issues,Encl ML20216F5471999-09-15015 September 1999 Discusses 990914 Meeting Conducted at Region Iv.Meeting Was Requested by Staff to Introduce New Management Organization to Region IV & to Discuss General Plant Performance & Mgt Challenges IR 05000498/19990121999-09-14014 September 1999 Forwards Insp Repts 50-498/99-12 & 50-499/99-12 on 990816-19.Three Violations Occurred & Being Treated as Ncvs. Areas Examined During Insp Included Portions of Access Authorization & Physical Security Programs 05000498/LER-1999-007, Forwards LER 99-007-00 Re Train 'B' CR Makeup & Cleanup Filtration Sys Being Inoperable for Greater than Aot.Util Intends to Append Addl Info Section of LER with Brief Description of Test Results,Rather than Submit Separate LER1999-09-13013 September 1999 Forwards LER 99-007-00 Re Train 'B' CR Makeup & Cleanup Filtration Sys Being Inoperable for Greater than Aot.Util Intends to Append Addl Info Section of LER with Brief Description of Test Results,Rather than Submit Separate LER ML20211P8201999-09-0909 September 1999 Forwards SE Authorizing 990224 Submittal of First 10-year Interval ISI Program Plan - Relief Request RR-ENG-24,from ASME Section XI Code,Table IWC-2500-1 NOC-AE-000638, Forwards License Renewal Applications & Certifications of Medical Exam for Seven Listed Licensed Operators at Stp,Per 10CFR55.57.Encl Withheld,Per 10CFR2.790(a)(6)1999-09-0909 September 1999 Forwards License Renewal Applications & Certifications of Medical Exam for Seven Listed Licensed Operators at Stp,Per 10CFR55.57.Encl Withheld,Per 10CFR2.790(a)(6) ML20211P7671999-09-0909 September 1999 Forwards SER Authorizing Licensee 990517 Alternative Proposed in Relief Request RR-ENG-2-8 to Code Case N-491-2 for Second 10-year Insp Interval of South Texas Project, Units 1 & 2,pursuant to 10CFR50.55a(a)(3)(i) ML20211P7871999-09-0909 September 1999 Forwards Safety Evaluation Re First 10-yr Interval Inservice Insp Program Plan Request for Relief RR-ENG-31 IR 05000498/19990141999-09-0303 September 1999 Forwards Insp Repts 50-498/99-14 & 50-499/99-14 on 990627-0807.Apparent Violations Identified & Being Treated as Noncited Violations Consistent with App C of Enforcement Policy NOC-AE-000562, Requests Relief from Contruction Code non-destructive Exam Requirements for Repair/Replacement Activities During Second Inservice Insp Interval of Units 1 & 2,IAW Provisions of 10CFR50.55a(a)(3)(i)1999-08-31031 August 1999 Requests Relief from Contruction Code non-destructive Exam Requirements for Repair/Replacement Activities During Second Inservice Insp Interval of Units 1 & 2,IAW Provisions of 10CFR50.55a(a)(3)(i) ML20212A4351999-08-27027 August 1999 Discusses Investigation Rept OI-4-1999-009 Re Activites at South Texas Project.Oi Investigation Initiated in Response to Alleged Employment Discrimination Complaint. Allegation Not Substantiated.No Further Action Planned NOC-AE-000617, Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d)1999-08-26026 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d) ML20211J2511999-08-26026 August 1999 Discusses Proposed TS Change on Replacement SG Water Level Trip Setpoint for Plant,Units 1 & 2 NOC-AE-000585, Provides Notification That South Texas Project Has Completed Integrity Evaluation of Units 1 & 2 Reactor Coolant Pump Casings Required by Paragraph (D) of Code Case N-4811999-08-25025 August 1999 Provides Notification That South Texas Project Has Completed Integrity Evaluation of Units 1 & 2 Reactor Coolant Pump Casings Required by Paragraph (D) of Code Case N-481 ML20211F4421999-08-24024 August 1999 Forwards SE Authorizing Licensee 990513 Request for Relief RR-ENG-2-13,seeking Relief from ASME B&PV Code Section Xi,Exam Vessel shell-to-flange Welds for Second ISI Intervals ML20211F5031999-08-23023 August 1999 Forwards SE Authorizing Licensee 990315 Request for Relief RR-ENG-30,seeking Relief from ASME B&PV Code,Section Xi,Nde Requirements Applicable to Stp,Unit 2 SG Welds ML20212A4391999-08-17017 August 1999 Discusses Investigation Rept OI-4-1999-023 Re Activities at South Texas Project.Oi Investigation Initiated in Response to Alleged Employment Discrimination for Initiating Condition Report to Document Unauthorized Work Practices ML20210U1271999-08-16016 August 1999 Forwards Insp Repts 50-498/99-08 & 50-499/99-08 on 990517-21 & 0607-10.No Violations Noted.Corrective Action Program Was Reviewed ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20211B7881999-08-10010 August 1999 Transmits Summary of Two Meetings with Risk-Informed TS Task Force in Rockville,Md on 990514 & 0714 ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams NOC-AE-000603, Informs of Addition of Restriction to SRO License 42658, for KM Espinoza,Effective 990721,per 10CFR50.74.Encl Info Withheld,Per 10CFR2.790(a)(6)1999-07-29029 July 1999 Informs of Addition of Restriction to SRO License 42658, for KM Espinoza,Effective 990721,per 10CFR50.74.Encl Info Withheld,Per 10CFR2.790(a)(6) NOC-AE-000470, Forwards Amend 12 to STP Fire Hazards Analysis Rept. Summary of Changes Made Under Provision of 10CFR50.59 Also Encl1999-07-28028 July 1999 Forwards Amend 12 to STP Fire Hazards Analysis Rept. Summary of Changes Made Under Provision of 10CFR50.59 Also Encl NOC-AE-000599, Forwards STP Unit 1,Cycle 9 Startup Testing Summary Rept. No New Licensing Commitments Contained in Ltr1999-07-28028 July 1999 Forwards STP Unit 1,Cycle 9 Startup Testing Summary Rept. No New Licensing Commitments Contained in Ltr NOC-AE-000589, Forwards Rev to 1RE08 ISI Summary Repts for Repairs & Replacements & for Sys Pressure Tests,Corecting Date of End of Insp Interval Provided in Item 9 of from NIS-1 from 09/24/99 to 09/24/20001999-07-26026 July 1999 Forwards Rev to 1RE08 ISI Summary Repts for Repairs & Replacements & for Sys Pressure Tests,Corecting Date of End of Insp Interval Provided in Item 9 of from NIS-1 from 09/24/99 to 09/24/2000 ML20210F3851999-07-26026 July 1999 Forwards Exam Repts 50-498/99-301 & 50-499/99-301 on 990706- 15.Exam Included Evaluation of 9 Applicants for SO Licenses & 8 Applicants for RO Licenses 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARNOC-AE-000675, Forwards Clarification on Items Included in 990531 Response to RAI Re Proposed License Amend Associated with Operator Action for Sbloca,As Requested1999-10-21021 October 1999 Forwards Clarification on Items Included in 990531 Response to RAI Re Proposed License Amend Associated with Operator Action for Sbloca,As Requested NOC-AE-000680, Forwards Rev 5 to 0PGP03-ZV-0001, Severe Weather Plan1999-10-20020 October 1999 Forwards Rev 5 to 0PGP03-ZV-0001, Severe Weather Plan NOC-AE-000683, Forwards 30-day Rept Concerning Significant Changes to Accepted Large Break Loss of Coolant Accident ECCS Evaluation Model for South Tx Project,Units 1 & 2,IAW 10CFR50.46(a)(3)(ii)1999-10-19019 October 1999 Forwards 30-day Rept Concerning Significant Changes to Accepted Large Break Loss of Coolant Accident ECCS Evaluation Model for South Tx Project,Units 1 & 2,IAW 10CFR50.46(a)(3)(ii) NOC-AE-000674, Forwards Requested Estimates of Needs for Operator Licensing Exams,Per AL-99-03, Operator Licensing National Exam Schedule1999-10-12012 October 1999 Forwards Requested Estimates of Needs for Operator Licensing Exams,Per AL-99-03, Operator Licensing National Exam Schedule 05000498/LER-1999-008, Forwards LER 99-008-00 Re Turbine Trip That Occurred While Performing Main Turbine Emergency Trip Test.Commitments Made by Licensee Are Listed in Corrective Actions Section of LER1999-10-12012 October 1999 Forwards LER 99-008-00 Re Turbine Trip That Occurred While Performing Main Turbine Emergency Trip Test.Commitments Made by Licensee Are Listed in Corrective Actions Section of LER NOC-AE-000625, Requests Partial Relief from ASME Section XI Visual Exam Requirements of IWA-5242(a).Relief Request Is Based on Provisions of Draft ASME Section XI Code Case N-616,which Is Expected to Be Published in Near Future1999-10-0707 October 1999 Requests Partial Relief from ASME Section XI Visual Exam Requirements of IWA-5242(a).Relief Request Is Based on Provisions of Draft ASME Section XI Code Case N-616,which Is Expected to Be Published in Near Future NOC-AE-000610, Requests Relief from ASME Section XI Code Nondestructive Exam Requirements of IWA-5250(a)(2) for Second Inservice Insp Interval,Per Provisions of 10CFR50.55a(3)(i)1999-10-0707 October 1999 Requests Relief from ASME Section XI Code Nondestructive Exam Requirements of IWA-5250(a)(2) for Second Inservice Insp Interval,Per Provisions of 10CFR50.55a(3)(i) NOC-AE-000653, Requests Relief from ASME Section XI Code Requirements of Table IWE-2500-1 for VT-3 Visual Exam of Seals & Gaskets on Airlocks,Hatches & Other Devices Required to Assure Containment leak-tight Integrity,Per 10CFR50.55a(a)(3)(i)1999-10-0707 October 1999 Requests Relief from ASME Section XI Code Requirements of Table IWE-2500-1 for VT-3 Visual Exam of Seals & Gaskets on Airlocks,Hatches & Other Devices Required to Assure Containment leak-tight Integrity,Per 10CFR50.55a(a)(3)(i) 05000499/LER-1999-006, Forwards LER 99-006-00,re Entry Into TS 3.0.3.Licensee Commitments Listed in Corrective Actions Section of Attachment1999-09-30030 September 1999 Forwards LER 99-006-00,re Entry Into TS 3.0.3.Licensee Commitments Listed in Corrective Actions Section of Attachment NOC-AE-000664, Forwards Rev 1 to STP Electric Generating Station Unit 1 Cycle 9 COLR & Rev 1 to STP Electric Generating Station Unit 2 Cycle 7 Colr1999-09-30030 September 1999 Forwards Rev 1 to STP Electric Generating Station Unit 1 Cycle 9 COLR & Rev 1 to STP Electric Generating Station Unit 2 Cycle 7 Colr NOC-AE-000646, Informs NRC That STP Nuclear Operating Co Is Y2K Ready IAW Nei/Nusmg 97-07 Guidelines & Also Provides Response to NRC Ltr1999-09-28028 September 1999 Informs NRC That STP Nuclear Operating Co Is Y2K Ready IAW Nei/Nusmg 97-07 Guidelines & Also Provides Response to NRC Ltr NOC-AE-000633, Forwards Rev 3 to SG-99-04-005, STP 1RE08 Outage Condition Monitoring Rept & Final Operational Assessment. Rept Satisfies Reporting Requirements of NEI 97-06,dtd Dec 19971999-09-21021 September 1999 Forwards Rev 3 to SG-99-04-005, STP 1RE08 Outage Condition Monitoring Rept & Final Operational Assessment. Rept Satisfies Reporting Requirements of NEI 97-06,dtd Dec 1997 NOC-AE-000634, Forwards Addl Info Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Povs. MOV design-basis Review Checklist,Encl1999-09-21021 September 1999 Forwards Addl Info Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Povs. MOV design-basis Review Checklist,Encl NOC-AE-000649, Forwards Current Annual Financial Data for STP Electric Generating Station Per 10CFR50.71(b),acting on Behalf of Central Power & Light Co,City of Austin,Tx,City Public Svc Board of San Antonio & Hl&P1999-09-21021 September 1999 Forwards Current Annual Financial Data for STP Electric Generating Station Per 10CFR50.71(b),acting on Behalf of Central Power & Light Co,City of Austin,Tx,City Public Svc Board of San Antonio & Hl&P 05000499/LER-1999-005, Forwards LER 99-005-00,re Esfa Following Loss of Power to Standby Transformer 2 Due to Electrical Fault.Licensee Commitments Are Listed in Corrective Actions Section of LER1999-09-20020 September 1999 Forwards LER 99-005-00,re Esfa Following Loss of Power to Standby Transformer 2 Due to Electrical Fault.Licensee Commitments Are Listed in Corrective Actions Section of LER 05000498/LER-1999-007, Forwards LER 99-007-00 Re Train 'B' CR Makeup & Cleanup Filtration Sys Being Inoperable for Greater than Aot.Util Intends to Append Addl Info Section of LER with Brief Description of Test Results,Rather than Submit Separate LER1999-09-13013 September 1999 Forwards LER 99-007-00 Re Train 'B' CR Makeup & Cleanup Filtration Sys Being Inoperable for Greater than Aot.Util Intends to Append Addl Info Section of LER with Brief Description of Test Results,Rather than Submit Separate LER NOC-AE-000638, Forwards License Renewal Applications & Certifications of Medical Exam for Seven Listed Licensed Operators at Stp,Per 10CFR55.57.Encl Withheld,Per 10CFR2.790(a)(6)1999-09-0909 September 1999 Forwards License Renewal Applications & Certifications of Medical Exam for Seven Listed Licensed Operators at Stp,Per 10CFR55.57.Encl Withheld,Per 10CFR2.790(a)(6) NOC-AE-000562, Requests Relief from Contruction Code non-destructive Exam Requirements for Repair/Replacement Activities During Second Inservice Insp Interval of Units 1 & 2,IAW Provisions of 10CFR50.55a(a)(3)(i)1999-08-31031 August 1999 Requests Relief from Contruction Code non-destructive Exam Requirements for Repair/Replacement Activities During Second Inservice Insp Interval of Units 1 & 2,IAW Provisions of 10CFR50.55a(a)(3)(i) NOC-AE-000617, Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d)1999-08-26026 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d) NOC-AE-000585, Provides Notification That South Texas Project Has Completed Integrity Evaluation of Units 1 & 2 Reactor Coolant Pump Casings Required by Paragraph (D) of Code Case N-4811999-08-25025 August 1999 Provides Notification That South Texas Project Has Completed Integrity Evaluation of Units 1 & 2 Reactor Coolant Pump Casings Required by Paragraph (D) of Code Case N-481 NOC-AE-000603, Informs of Addition of Restriction to SRO License 42658, for KM Espinoza,Effective 990721,per 10CFR50.74.Encl Info Withheld,Per 10CFR2.790(a)(6)1999-07-29029 July 1999 Informs of Addition of Restriction to SRO License 42658, for KM Espinoza,Effective 990721,per 10CFR50.74.Encl Info Withheld,Per 10CFR2.790(a)(6) NOC-AE-000599, Forwards STP Unit 1,Cycle 9 Startup Testing Summary Rept. No New Licensing Commitments Contained in Ltr1999-07-28028 July 1999 Forwards STP Unit 1,Cycle 9 Startup Testing Summary Rept. No New Licensing Commitments Contained in Ltr NOC-AE-000470, Forwards Amend 12 to STP Fire Hazards Analysis Rept. Summary of Changes Made Under Provision of 10CFR50.59 Also Encl1999-07-28028 July 1999 Forwards Amend 12 to STP Fire Hazards Analysis Rept. Summary of Changes Made Under Provision of 10CFR50.59 Also Encl 05000498/LER-1999-006, Forwards LER 99-006-00 Re Automatic Reactor Trip Due to over-temp delta-temp Actuation.Licensee Commitments Are Listed in Corrective Actions Section of LER1999-07-26026 July 1999 Forwards LER 99-006-00 Re Automatic Reactor Trip Due to over-temp delta-temp Actuation.Licensee Commitments Are Listed in Corrective Actions Section of LER NOC-AE-000589, Forwards Rev to 1RE08 ISI Summary Repts for Repairs & Replacements & for Sys Pressure Tests,Corecting Date of End of Insp Interval Provided in Item 9 of from NIS-1 from 09/24/99 to 09/24/20001999-07-26026 July 1999 Forwards Rev to 1RE08 ISI Summary Repts for Repairs & Replacements & for Sys Pressure Tests,Corecting Date of End of Insp Interval Provided in Item 9 of from NIS-1 from 09/24/99 to 09/24/2000 NOC-AE-000582, Forwards 1RE08 ISI Summary Rept for Welds & Component Supports of STP Electric Generating Station,Unit 1. Summary Rept Satisfies Reporting Requirements of IWA-6000 of Section XI for Welds & Component Supports1999-07-26026 July 1999 Forwards 1RE08 ISI Summary Rept for Welds & Component Supports of STP Electric Generating Station,Unit 1. Summary Rept Satisfies Reporting Requirements of IWA-6000 of Section XI for Welds & Component Supports NOC-AE-000597, Forwards voltage-based Criteria 90-day Rept for SG Tube Exam Performed Under NRC GL 95-05 During Refueling Outage 1RE08. Rept Contains Info Required by Section 6.b of Attachment 2 to GL 95-051999-07-23023 July 1999 Forwards voltage-based Criteria 90-day Rept for SG Tube Exam Performed Under NRC GL 95-05 During Refueling Outage 1RE08. Rept Contains Info Required by Section 6.b of Attachment 2 to GL 95-05 NOC-AE-000598, Forwards Four Copies of 1RE08 Refueling Outage ISI Summary Rept for Steam Generator Tubing1999-07-23023 July 1999 Forwards Four Copies of 1RE08 Refueling Outage ISI Summary Rept for Steam Generator Tubing NOC-AE-00586, Forwards Results of Control Rod Testing,In Response to NRC Bulletin 96-01, Control Rod Insertion Problems, Dtd 960308.Core Map Provided to Assist in Understanding Test Data1999-07-21021 July 1999 Forwards Results of Control Rod Testing,In Response to NRC Bulletin 96-01, Control Rod Insertion Problems, Dtd 960308.Core Map Provided to Assist in Understanding Test Data NOC-AE-000595, Forwards Chapters 1.0 & 16.0 to Operations QA Plan for South Texas Project.Rev Is Strictly Administrative & All Content Was Previously Submitted to NRC on 990503 & 9906151999-07-21021 July 1999 Forwards Chapters 1.0 & 16.0 to Operations QA Plan for South Texas Project.Rev Is Strictly Administrative & All Content Was Previously Submitted to NRC on 990503 & 990615 NOC-AE-000518, Requests Exemption from Various Special Treatment Requirements of 10CFR50,as Described in Encls to Ltr.Stp Believes That Pilot Application Will Assist NRC in Development & Implementation of risk-informed 10CFR501999-07-13013 July 1999 Requests Exemption from Various Special Treatment Requirements of 10CFR50,as Described in Encls to Ltr.Stp Believes That Pilot Application Will Assist NRC in Development & Implementation of risk-informed 10CFR50 NOC-AE-000536, Submits Request for Exemption from Requirements of 10CFR50.34(b)(11),10CFR50,App A,Gdc 2 & 10CFR100,App a, Section VI(a)(3) Re Maint of Seismic Instrumentation.Revised Page to Procedure OERP01-ZV-IN01 Included1999-07-13013 July 1999 Submits Request for Exemption from Requirements of 10CFR50.34(b)(11),10CFR50,App A,Gdc 2 & 10CFR100,App a, Section VI(a)(3) Re Maint of Seismic Instrumentation.Revised Page to Procedure OERP01-ZV-IN01 Included NOC-AE-000580, Forwards Response to NRC 990415 RAI Re Implementation of Commitments Related to GL 89-10, Safety-Related MOV Testing & Surveillance & GL 96-05, Periodic Verification of Design Basis Capability of Safety-Related Movs1999-07-13013 July 1999 Forwards Response to NRC 990415 RAI Re Implementation of Commitments Related to GL 89-10, Safety-Related MOV Testing & Surveillance & GL 96-05, Periodic Verification of Design Basis Capability of Safety-Related Movs NOC-AE-000574, Forwards ISI Summary Repts for Repairs & Replacements & for Sys Pressure Tests Performed Between 971004 & Completion of Eighth RO on 9904281999-07-0606 July 1999 Forwards ISI Summary Repts for Repairs & Replacements & for Sys Pressure Tests Performed Between 971004 & Completion of Eighth RO on 990428 NOC-AE-000557, Requests Relief from ASME Section XI Code Nondestructive Exam Requirements of App III,III-3410 for Second ISI Interval.Proposed Alternatives for Ultrasonic Exam of Piping Sys Welds,Attached1999-07-0606 July 1999 Requests Relief from ASME Section XI Code Nondestructive Exam Requirements of App III,III-3410 for Second ISI Interval.Proposed Alternatives for Ultrasonic Exam of Piping Sys Welds,Attached NOC-AE-000498, Requests Relief from ASME Section XI Code Nondestructive Exam Requirements Applicable to SG Main Steam Nozzle inside- Radius Sections.Attachment Includes Discussion of Basis & Justification for Request & Implementation Schedule1999-07-0606 July 1999 Requests Relief from ASME Section XI Code Nondestructive Exam Requirements Applicable to SG Main Steam Nozzle inside- Radius Sections.Attachment Includes Discussion of Basis & Justification for Request & Implementation Schedule NOC-AE-000573, Requests Relief from Requirements of ASME Section XI Code Case N-498,exempting Isolated Class 1 Reactor Vessel Head Vent Atmospheric Vent Piping & Valve from Being Tested at Full RCS Pressure1999-07-0606 July 1999 Requests Relief from Requirements of ASME Section XI Code Case N-498,exempting Isolated Class 1 Reactor Vessel Head Vent Atmospheric Vent Piping & Valve from Being Tested at Full RCS Pressure NOC-AE-000541, Submits Response to GL 98-01,Suppl 1, Y2K Readiness of Computer Systems at Npps. Readiness Disclosure for STP, Encl1999-06-29029 June 1999 Submits Response to GL 98-01,Suppl 1, Y2K Readiness of Computer Systems at Npps. Readiness Disclosure for STP, Encl NOC-AE-000571, Forwards Final Operating Exam Matls for STP Exam Scheduled for 990705.Revised Operating Exam Outline & post-validation Change Summary Has Been Included.Without Encls1999-06-24024 June 1999 Forwards Final Operating Exam Matls for STP Exam Scheduled for 990705.Revised Operating Exam Outline & post-validation Change Summary Has Been Included.Without Encls NOC-AE-000512, Responds to NRC 981201 Telcon Re Jco 93-0004,per Revised MSLB Analysis1999-06-23023 June 1999 Responds to NRC 981201 Telcon Re Jco 93-0004,per Revised MSLB Analysis NOC-AE-000560, Forwards LER 99-S02-00,re Failure to Maintain Positive Control of Vital Area Security Key.Licensee Commitments Are Found in Corrective Action Section of LER1999-06-23023 June 1999 Forwards LER 99-S02-00,re Failure to Maintain Positive Control of Vital Area Security Key.Licensee Commitments Are Found in Corrective Action Section of LER 05000498/LER-1999-005, Forwards LER 99-005-00,re Failure to Meet Requirements of TS Surveillance 3.7.1.2 Action B for Auxiliary FW Sys.Only Commitments Contained in Ltr Are Located in Corrective Action Section of LER1999-06-17017 June 1999 Forwards LER 99-005-00,re Failure to Meet Requirements of TS Surveillance 3.7.1.2 Action B for Auxiliary FW Sys.Only Commitments Contained in Ltr Are Located in Corrective Action Section of LER NOC-AE-000565, Forwards Amended Pages for Insertion Into South Texas Project Nuclear Operating Co Previously Submitted Response to NRC Rai.New Pages Include Expanded Answer to Question 4.b1999-06-16016 June 1999 Forwards Amended Pages for Insertion Into South Texas Project Nuclear Operating Co Previously Submitted Response to NRC Rai.New Pages Include Expanded Answer to Question 4.b NOC-AE-000548, Forwards Response to RAI Re Proposed Amends on Replacement SG Water Level Trip Setpoint Differences for Stp,Units 1 & 2.Nothing Contained in Response Should Be Considered Commitment Unless So Specified in Separate Correspondence1999-06-16016 June 1999 Forwards Response to RAI Re Proposed Amends on Replacement SG Water Level Trip Setpoint Differences for Stp,Units 1 & 2.Nothing Contained in Response Should Be Considered Commitment Unless So Specified in Separate Correspondence NOC-AE-000561, Forwards Change QA-042 to Operations QAP, Rev 13, Reflecting Current Organizational Alignment for STP & Culminating Organizational Realigment That Has Been Taking Place During Past Several Months1999-06-15015 June 1999 Forwards Change QA-042 to Operations QAP, Rev 13, Reflecting Current Organizational Alignment for STP & Culminating Organizational Realigment That Has Been Taking Place During Past Several Months NOC-AE-0559, Forwards STP Commitment Change Summary Rept for Period 981209-990610.Rept Lists Each Commitment for Which Change Was Made During Reporting Period & Provides Basis for Each Change1999-06-15015 June 1999 Forwards STP Commitment Change Summary Rept for Period 981209-990610.Rept Lists Each Commitment for Which Change Was Made During Reporting Period & Provides Basis for Each Change NOC-AE-000499, Forwards Relief Request RR-ENG-2-3,proposing to Perform Alternative Ultrasonic Examination from Outside Surface of Skirt Attachment Weld as Described in Encl,In Lieu of Surface Examination from Inside Pressurizer Skirt1999-06-0909 June 1999 Forwards Relief Request RR-ENG-2-3,proposing to Perform Alternative Ultrasonic Examination from Outside Surface of Skirt Attachment Weld as Described in Encl,In Lieu of Surface Examination from Inside Pressurizer Skirt NOC-AE-000502, Forwards Relief Request RR-ENG-2-6,proposing That Boroscopic VT-1 Visual Examination Be Allowed as Alternative to Section XI Surface Examination of Pump Casing Welds,Or Portions of Welds within Pits1999-06-0909 June 1999 Forwards Relief Request RR-ENG-2-6,proposing That Boroscopic VT-1 Visual Examination Be Allowed as Alternative to Section XI Surface Examination of Pump Casing Welds,Or Portions of Welds within Pits NOC-AE-000500, Forwards Relief Request RR-ENG-2-4,proposing to Perform Alternative Ultrasonic Examination from Outside & End Surfaces of Reactor Vessel Closure Head Nuts,As Described in Encl in Lieu of Surface Examination of Threaded Region1999-06-0909 June 1999 Forwards Relief Request RR-ENG-2-4,proposing to Perform Alternative Ultrasonic Examination from Outside & End Surfaces of Reactor Vessel Closure Head Nuts,As Described in Encl in Lieu of Surface Examination of Threaded Region NOC-AE-000545, Forwards Response to NRC 990416 RAI Re Util Proposed Amend on Operator Action for Small Break Loca, .Draft EOP Re Small Break Loca,Encl to Aid Discussion of Proposed Amend1999-05-31031 May 1999 Forwards Response to NRC 990416 RAI Re Util Proposed Amend on Operator Action for Small Break Loca, .Draft EOP Re Small Break Loca,Encl to Aid Discussion of Proposed Amend 1999-09-09
[Table view] |
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N am a r sam ramwseeaanmer sman m arm na.we roar 77m u July 13, 1999 NOC-AE-000580 File No.: G03.08 10CFR50 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 South Texas Pwject Units 1 and 2 -
Docket Nos. STN 50-498, STN 50-499 Response to Request for AdditionalInformation - Generic Letter 96-05,
" Periodic Verification of Design Basis Capability of Safety-Related Motor-Operated Valves"
References:
- 1. " Request for Additional Information - Generic Letter 96-05, South Texas Project, Units 1 and 2 (TAC Nos. M97102 and M97103)," NRC Letter to STP Nuclear Operating Company dated April 15,1999
- 2. Generic Letter 89-10, " Safety-Related Motor-Operated Valve Testing and Surveillance,"
dated June 28,1989
- 3. Generic I.etter 96-05, " Periodic Verification of Design Basis Capability of Safety-Related Motor-Operated Valves," dated September 18,1996 Pursuant to the request for additional information of tlie Nuclear Regulatory Commission (Reference 1), the South Texas Project submits this response regarding implementation of commitmete.s related to References 2 and 3.
If there are any questions, please contact either Mr. R. P. Murphy at (361) 972-8919 or me at (361) 972-7162.
I S. E. Thomas L
Manager, \
Design Engineering l
l i PLW
-Olp-r
Attachment:
Response to Request for AdditionalInformation dated April 15,1999 No'7200182990713 PDR ADOCK 05000498 !
p PDR !
< , J
NOC-AE-000580 File No.: G03.08 Page 2 cc:
Ellis W. Merschoff - Jon C. Wood Regional Administrator, Region IV Matthews & Branscomb
.U. S. Nuclear Regulatory Commission One Alamo Center 611 Ryan Plaza Drive, Suite 400 106 S. St. Mary's Street, Suite 700 Arlington, TX 76011-8064- San Antonio, TX 78205-3692 Thomas W. Alexion Institute of Nuclear Power Project Manager, Mail Code'13H3 ' Operations - Records Center U. S. Nuclear Regulatory Commission - 700 Galleria Parkway Washington, DC 20555-0001 Atlanta, GA 30339-5957 Cornelius F. O'Keefe Richard A. Ratliff Sr. Resident Inspector Bureau of Radiation Control c/o U. S. Nuclear Regulatory Commission Texas Department of Health P. O. Box 910 1100 West 49th Street Bay City, TX .77404-0910 Austin, TX 78756-3189 J. R. Newman, Esquire D. G. Tees /R. L. Balcom Morgan, Lewis & Bockius Houston Lighting & Power Co.
1800 M. Street, N.W. P. O, Box 1700.
Washington, DC 20036-5869 Houston,TX 77251 M. T. Hardt/W. C. Gunst Central Power and Light Company City Public Service A7TN: G. E. Vaughn/C. A. Johnson
- P. O. Box 1771 .
P. O. Box 289, Mail Code: N5012 San Antonio,TX 78296 Wadsworth,TX 77483 A. Ramirez/C. M. Canady U. S. Nuclear Regulatory Commission City of Austin - . Attention: Document Control Desk Electric Utility Department Washington, D.C. 20555-0001 721 Barton Springs Road Austin, TX 78704'
[ M .
O Attachment NOC-AE-000580 Page 1 of 9 South Texas Project l Units 1 and 2
! P==a== to Rean=* for Addide=1 Infor== tion datant Anril 15.1999 l
- 1. In NRC letter dated March 2,1995 (ACN 9503080315), the NRC staff closed its review of the motor-operated valve (MOV) program implemented at the South Texas Project (South Texas) in response to' Generic letter (GL) 89-10, " Safety-Related Motor Operated Valve Testing and Surveillance," based on the results of NRC Inspection Report No. 50-498 &
499/94-32 (dated November 10, 1994) and information contained in a letter from STP Nuclear Operating Company (the licensee) dated January 9,1995. In the inspection report, the NRC staff discussed certain aspects of the licensee's MOV program to be addressed over the long term. : For example, the inspectors noted that the licensee committed to apply results from the Electric Power Research Institute (EPRI) MOV Performance Prediction Model (PPM) for those MOVs that had no test data available to validate the assumed valve factor.
In addition, in the March 2,1995, letter, the staff noted that the licensee (1) committed to ,
dynamically test a minimum of eight MOVs (six gate valves, one globe valve, and one
. butterfly valve) with diagnostics each refueling outage; (2) agreed to revise the post maintenance test guidelines to review the need for dynamic testing regardless of valve type or achievable test differential pressure; and (3) committed to complete an MOV over-current protection review and to take appropriate actions, where necessary. The licensee should describe the actions taken to address the specific long-term aspects of the MOV program at South Texas noted in the NRC inspection report and the NRC staff's letter dated March 2, 1995.
Response
a) " Licensee committed to apply results from the Electric Power Research Institute (EPRI)
MOV Performance Prediction Model (PPlW) for those' MOVs that had no test data available to validate the assumed valve factor."
South Texas Project (STP) MOVs were evaluated using the EPRI Performance Prediction Model (PPM) for those MOVs that had no test data available to validate the assumed valve factor. The results of the PPM evaluation are being reviewed to assure that the assumed valve factors of the affected STP MOVs are acceptable. The STP Condition Reporting process will document the results. The review is expected to be complete by the end of 1999.
b) " Licensee committed to dynamically test a minimum of eight MOVs (six gate valves, one l globe valve, and one butterfly valve) with diagnostics each refueling outage."
The STP dynamic diagnostic testing program includes six gate valves, one globe valve, and one butterfly valve as mentioned above. At its own initiative, STP is also performing
{
dynamic diagnostic testing on three additional gate valves representing additional valve groups. Each valve is tested on a frequency of 18 months or less during a refueling outage or during power operation if conditions allow.
t Anachment NOC-AE-000580 Page 2 of 9 c) " Licensee agreed to revise the post maintenance test guidelines to review the need for dynamic testing regardless of valve type or achievable test differential pressure."
STP revised the post-maintenance test guidelines to review the need for dynamic testing regardless of valve type or achievable test differential pressure. The revised guidelines are incorporated into both the engineering guidelines and the post-maintenance test manual.
d) " Licensee committed to complete an MOV over-current protection review and to take 4 appropriate actions, where necessary."
STP completed an MOV over-current protection review that is documented by the j Condition Reporting Process. MOVs in the STP GL 89-10/96-05 Program were reviewed to assure over-current protection for locked-rotor current. Modifications are being implemented to assure that circuit breaker setpoints will prevent inadvertent actuation (circuit breaker trip) under design basis conditions.
In addition to the above commitments identified in the NRC RAI, the following commitments are included in the March 2,1995, letter:
l c) "We understand that you have committed to periodically verify the design-basis capability of motor-operated valves at South Texas Project within the scope of Generic Letter 89- !
- 10. This process willinclude a static diagnostic test of each motor-operated valve within j the scope of Generic Letter 89-10 at least every 5 years to verify an acceptable capability j margin." I l
The STP Generic letter 89-10/ 96-05 Motor Operated Valve Program implements this commitment. At STP diagnostic testing of each MOV is performed at least every five years to verify an acceptable capability margin. In Attachment I to Generic Letter 96-05, the South Texas Project is cited as an example as having established an acceptable periodic verification program (PVP). The letter goes on to identify an acceptable approach to periodic verification based on diagnostically testing each safety-related MOV l every five years (or every three refueling outages).
For additional information, see the response to RAI # 2.
f) "For motor-operated gate valves, we understand that a margin will be maintained to account for possible increases in valve factor over time. This margin will be in addition to the margin allowed for uncertainties associated with instrument error, torque switch j repeatability, load sensitive behavior, and stem lubrication degradation." l A margin in the determination of valve factor is maintained to account for possible increases in valve factor o'ver time. This margin is in addition to the margin allowed for !
uncertainties associated with instrument error, torque switch repeatability, load sensitive behavior, and stem lubrication degradation. Valve factors are monitored as a part of the evaluation of valve dynamic testing results.
Attachment NOC-AE-000580 Page 3 of 9
- 2. In a letter dated November 18,1998, the licensee updated its commitment to implement the JOG program. However, the licensee stated that it will " consider" the JOG program testing results. The NRC staff has determined that, when a licensee commits to the JOG Topical Report on the MOV Periodic Verification Program, the licensee is committing to implement each of the three phases of the described JOG program, including (1) JOG interim static diagnostic test program, (2) JOG 5-year dynamic test program, and (3) JOG long-term periodic test program. Where a licensee proposes to implement an approach different from any of these three phases of the JOG program, the licensee will be expected to notify the NRC and to provide justification for the proposed alternative approach. For example, if a licensee proposes not to implement the third phase of the JOG program (JOG long-term periodic test program) after the specific long-term test criteria have been established following the JOG 5-year dynamic test program, the licensee will be expected to notify the NRC and to justify its proposed alternative long-term test criteria. The South Texas licensee should discuss its commitment to the JOG long-term periodic test program and whether it is consistent with the NRC staff's interpretation of a commitment to all three phases of the JOG program.
Response
STP's commitme*t to the Joint Owners' Group (JOG) long-term periodic test program is consistent with tt NRC staff's interpretation of commitment to all three phases of the JOG program as it ht .en described above. STP will evaluate all data and specific long-term test criteria that ar- :stablished following the JOG five-year dynamic test plan for specific application to the iTP MOV program.
STP is committed to participation in the JOG five-year dynamic test program and is providing three sets of dynamic test results on each of four valves (a total of 12 tests) during this period. j To date, STP has provided the results of eight tests, and expects to complete this commitment in the year 2001, The South Texas Project is implementing diagnostic testing of its valves on a frequency of every five years or three refueling outages, which is consistent with the JOG interim static diagnostic test program. The STP program test frequencies will be adjusted, ifindicated, after the MOV risk categorization process is completed later this year.
STP will notify the NRC of any proposed alternatives or deviation from the JOG program and justify them.
The STP risk ranking approach is discussed in the response to question #3.
Anachment NOC-AE-000580 Page4 of 9
- 3. The licensee's updated commitment stated that the South Texas MOV risk-ranking approach differs in some respects from the program described in the Westinghouse Owners Group (WOG) Engineering Report V-EC-1658-A (Revision 2, dated August 13,1998), " Risk Ranking Approach for Motor-Operated Valves in Response to Generic 1.etter 90-05," and the NRC safety evaluation dated April 14,1998, on Revision 1 of WOG Engineering Report V-EC-1658. The licensee intends to substitute its own risk-informed performance-based approach to address the safety significance of MOVs at South Texas. The licensee should describe the methodology used for risk rankmg MOVs at South Texas in more detail, -
including (1) a description of how the South Texas methodology differs from the method described in WOG Engineering Report V-EC-1658-A and the NRC safety evaluation; (2) a
- discussion of the applicability of the' conditions and limitations contained in the NRC safety evaluation of WOG Engineering Report V-EC-1658-A; (3) the process used to develop a sample list of high-risk MOVs from other Westinghouse plants; (4) how expert panels were used to evaluate MOV risk significance; and (5) a discussion of the static test frequency that will result from application of the South Texas risk-ranking methodology.
Response
(a)"The licensee should describe the methodology used for risk ranking.MOVs at South Texas in more detail, including . . . a description of how the South Texas methodology differs from the method described in WOG Engineering Report V-EC-1658-A and the NRC safety evaluation."
The STP Probabilistic. Safety Assessment (PSA) is a fully integrated, detailed Level 2 analysis of plant risk incorporating large early release frequency and core damage frequency. The STP PSA includes an integrated and detailed analysis of common cause events, containment bypass (interfacing systems LOCA), and internal and external events (fires, internal and external floods, seismic events, high winds (including tornado),
tsunami, spatial interactions, and other initiators). The PSA uses plant specific data for equipment failure rates, which are updated periodically. Intra- and intersystem common cause failures resulting from maintenance and testing activities are also integrated. As such, the STP PSA is substantially more comprehensive in its analysis and modeling than the more high level methodologies developed specifically -for Independent Plant Examination (IPE) and external events IPE (IPEEE) used to satisfy Generic Letter 88-20.
The STP PSA pre-dates the regulatory requirement for performing a separate internal events IPE and IPEEE, was used to satisfy IPE and IPEEE requirements, and is maintained as a "living PRA." Safety evaluations of the STP PSA are documented by Refemnces 1 through 4.
' The STP PSA, along with deterministic evaluations and assessments, has been used to enhance STP licensing basis documents based on a comprehensive risk management philosophy, including changes to technical specifications and plant changes. Some of these are documented in References 5 and 6.
]
4 Attachment NOC-AE-000580 Page 5 of 9 4
Since 1995, the South Texas Project has worked closely with the NRC on an industry initiative to- allow an approach to quality. assurance' for grading the application of previously approved ' quality assurance controls to safety-related plant structures, systems and components (SSCs). The NRC issued a safety evaluation '(Reference 7) which approved changes to the STP Operations Quality Assurance Plan (OQAP) to address Graded Quality Assurance (GQA) concepts.
- A graded approach to quality assurance requires a well-documented, proceduralized, and i reviewed and _ accepted program for determining equipment safety significance. The STP program, which has been reviewed by the NRC, is documented in procedures related to the_ Probabilistic Risk Assessment . Program (Reference 8), Comprehensive Risk Management (Reference 9), Probabilistic Safety Assessment Risk Rankmg (ref.10), and
-_ Station' Performance Data Collection, Categorization, and Reporting (Reference 11).
Current revisions of these procedures are attached.
With the exception of the actual criteria used in the risk categorization process, the methods described in the Westinghouse document and the STP program documents are identical. Section 3 of the Westinghouse document describes a risk ranking approach that is similar to that used in the STP Maintenance Rule program and is identical to the process
- used by the Graded QA working group (Reference 9).
The actual risk ranking criteria used at STP are based on information provided in the Probabilistic Safety Assessment Risk Ranking Program (Reference 10). Use of plant actual criteria is consistent with the process described in the Westinghouse document (Section 3.0). The NRC safety evaluation on Graded Quality Assurance reviews STP's quantitative and qualitative categorization process, including the PSA ranking and expert panel review processes in detail, and finds that "the licensee has developed an acceptable methodology to determine the relative safety significance of plant SSCs."
(b)'The licensee should describe the methodology used for risk rankmg MOVs at South Texas in more detail, including . . . a discussion of the applicability of the conditions and limitations contained in the NRC safety evaluation of WOG Engineering Report V-EC-1658-A."
STP considers the conditions and limitations contained in the NRC safety evaluation on pages 9 and 10 of WOG Engineering Report V-EC-1658-A to be applicable.
The STP PSA is a fully _ integrated, detailed Level 2 analysis of plant risk. Based on a j review of the NRC's expressed concerns noted in the conditions and limitations, it appears ;
that those concerns follow from a set of assumptions that are not applicable to the STP j PSA by virtue ofits methods and detail. However, STP believes that the issues identified l by the NRCare, .in general, appropriate for consideration by the Expert Panel. '
Containment bypass and the potential for radioactive release, data accuracy and the use of generic failure rates, the potential for intra- and intersystem common-cause failures, and MOVs identified as medium to high risk in other plant PRAs/IPEs will be considered as a i
Attachment NOC-AE-000580 Page 6 of 9 l
l part of the panel review. An approach to documentation similar to that suggested in the Engineering Report V-EC-1658-A, Revision 2, will be utilized at STP.
)
l l Note: Additional discussion of Condition (c) on page 9 of WOG Engineering Report V-EC-1658-A, Revision 2, is provided in part C below. Additional discussion of Condition 1
(g) on page 10 of WOG Engineering Report V-EC-1658-A, Revision 2, is provided in part E below.
(c) 'The licensee should describe the methodology used for risk ranking MOVs at South Texas in more detail, including . . . the process used to develop a sample list of high-risk MOVs from other Westinghouse plants."
)
The list of risk-significant MOVs in Westinghouse NSSS plants identified in Appendix A to V-EC-1658-A, Revision 2, will be reviewed and evaluated by the STP MOV working group and Expert Panet The NRC in its Safety Evaluation dated April 14,1998, of the WOG report stated that it "did not identify any additional MOVs to be included in the WOG generallist."
(d)'The licensee should describe the methodology used for risk ranking MOVs at South Texas in more detail, including . . . how expert panels were used to evaluate MOV risk significance."
STP is in the process of completing a risk-informed performance-based evaluation of i MOVs in the STP PVP, including the use of an expert panel that will determine the safety significance categorization of MOVs. The process of categorization will be completed in 1999, and will provide an optimized MOV testing strategy.
The process used at STP for safety significance categorization, including the use of an expert panel, is discussed in section (a) of this RAI.
(e) 'The licensee should describe the methodology used for risk ranking MOVs at South Texas in more detail, including. . . a discussion of the static test frequency that will result from application of the South Texas risk-ranking methodology."
STP is implementing the JOG interim static diagnostic test program in lieu of the earlier commitment to test each MOV at least every five years after the MOV risk categorization process is completed later this year. Specifically, Table 4-1 of the JOG Program Document MPR 1807, Rev. 2, allows static testing of STP MOVs on a frequency from once every cycle to once every six cycles, depending on their margin and risk category.
STP expects that the application of its risk-ranking methodology will result in a testing ;
frequency for a few valves on a more frequent basis, and on a number of valves it may extend to every six cycles (not to exceed 10 years). STP's testing frequencies are expected to be similar to other plants in the program.
As noted by the NRC in its Safety Evaluation of the JOG program dated October 30, 1997, the South Texas Project must evaluate information obtained from diagnostic MOV
I- ..
Attachment NOC-AE-000580 Page 7 of 9 testing conducted during the first five-year period to validate assumptions made in
. justifying the longer test interval where a selected test interval extends beyond five years.
h h.
l I
/
)
< a Auachment NOC-AE-000580 Page 8 of 9
- 4. The JOG program focuses on the potential age-related increase in the thmst or teque required to operate valves under their design-basis conditions. In the NRC safety evaluation dated October, 30,1997, on the JOG program, the NRC staff specified that licensees are responsible for addressing the thrust or torque delivered by the MOV motor actuator and its potential degradation. The licensee should describe the plan at South Texas for ensuring adequate ac and de MOV motor actuator output capability, including consideration of recent guidance in Limitorque Technical Update 98-01 and its Supplement I dated July 17. IN8.
l Resnonse:
{
The STP MOV program ensures systematic monitoring and evaluation of MOV motor actuator capability by diagnostically testing each program MOV as provided by the program (currently every five years). Additionally, the motor actuator mechanical condition and lubrication is routinely inspected and maintained to enhance the continued satisfactory performance of the MOVs.
Diagnostic test results are input to the STP MOV Tracking and Trending Progr .m to evaluate for adverse trends and predict valve performance. Performance of an MOV outside the acceptance criteria of the Diagnostic Testing Program or the Tracking and Trending program requires an ' engineering evaluation to determine if the MOV is degraded. The engineering j evaluation will result in an initiation of corrective actions or a justification to allow continued {
operation based on adequate operating margin.
Engineering evaluation and/or calculation is used to determine motor actuator capability as an input to calculate deterministic MOV margin used in the Diagnostic Test and Tracking and Trending Programs. As new industry information becomes available, it is evaluated and applied to motor actuator capability.
The output capability of DC motor MOVs at STP was evaluated considering Limitorque Technical Update 98-01 with supplement I dated July 17,1998. The potential temperature-related DC motor performance degradation shown in the Idaho National Engineering and Environmental Laboratory preliminary test result presentation, " Preliminary Results of Direct Current Motor Actuator Testing," by Kevin G. DeWall and John C. Watkins was also !
considered. In all cases, output capability for the STP DC motors is acceptable.
The output capability of AC motor MOVs at STP was evaluated using the results of the Commonwealth Edison MOV AC Motor Test Program (Comed methodology). Specific validated engineering data as allowed by the methodology and pullout efficiency were utilized for the evaluation. In all cases, output capability for the STP AC motors is acceptable. i i
p a :.
Attachment NOC-AE-000580 Page 9 of 9
References:
- 1. " Safety Evaluation by the OfHee of Nuclear Reactor Regulation Related to the Probabilistic
~ Safety Analysis Evaluation,".sent to the Houston Lighting & Power Company under cover letter dated January 21,1992.
- 2. - " Safety Evaluation by the Office of Nuclear Reactor Regulation Related to the Probabilistic Safety Assessment - External Events," sent to the Houston Lighting & Power Company L under cover letter dated August 31,1993.
- 3. " Staff Evaluation of South Texas Project Individual Plant Examination (Internal Events Only)," sent to the Houston Lighting & Power Company under cover letter dated August 9, 1995.
- 4. " Staff Evaluation Report of Individual Plant Examination of External Events (IPEEE) submittal on South Texas Project (STP), Units 1 and 2," sent to the Houston Lighting &
Power Company under cover letter dated December 15,1998.
- 5. Ietter ST-HL-AE-5076 dated 5/1/1995 from Houston Lighting & Power to USNRC requesting changes to Technical Specification 3.10.8 to allow extension of the Standby Diesel Generator Allowed Outage Time for a cumulative 21 days on each Standby Diesel Generator once per fuel cycle.
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- 6. Letter ST-HL-AE-3283 dated 2/1/1990 from Houston Lighting & Power to USNRC requesting changes to 22 Technical Specifications.
- 7. . " Safety Evaluation by the Office of Nuclear Reactor Regulation, Houston Lighting and Power Company, South Texas Project, Units 1 and 2, Graded Quality Assurance Program, Dockets Nos. 50-498 & 50-499," sent to the Houston Lighting & Power Company under cover letter dated November 6,1997.
- 8. OPGPO4-ZA-0604, Rev. 3. "Probabilistic Risk Assessment Program."
- 9. OPGP02-ZA-0003, Rev. 4, " Comprehensive Risk Management." l
- 10. OPGP01-ZA-0304, Rev. 2, "Probabilistic Safety Assessment Risk Ranking."
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- 11. OPGP02-ZA-0004, Draft, '" Station Performance Data Collection, Categorization, and l Reporting."
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