NOC-AE-02001330, Commitment Change Summary Report
| ML021910254 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 07/02/2002 |
| From: | Jordan T South Texas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NOC-AE-02001330 | |
| Download: ML021910254 (5) | |
Text
Nuclear Operating Company South Texas Profect Electric Generatmn Stat'on P.. Box 289 Wadsworth, 7exas 77483 - v/w--
July 2, 2002 NOC-AE-02001330 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 South Texas Project Commitment Change Summary Report Gentlemen:
Attached is the South Texas Project (STP) Commitment Change Summary Report for the period June 10, 2001 through June 10, 2002. This report lists each commitment for which a change was made during the reporting period and provides the basis for each change.
The commitments were evaluated in accordance with the requirements of STP's Regulatory Commitment Change Process, which is consistent with the guidance in the Nuclear Energy Institute's "Guideline for Managing NRC Commitments", NEI 99-04. Additional documentation is available at STP for your review.
If there are any questions, please contact either Scott Head at 361-972-7136 or me at 361 972-8757.
Vice President, Engineering & Technical Services RDP : Commitment Change Summary Report wp/nlinrc-ap/misc-02/02001330.doc STI 31449454 / OD
NOC-AE-02001330 Page 2 of 2 cc:
(paper copy) (electronic copy)
Ellis W. Merschoff A. H. Gutterman, Esquire Regional Administrator, Region IV Morgan, Lewis & Bockius LLP U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 M. T. Hardt/W. C. Gunst Arlington, Texas 76011-8064 City Public Service U. S. Nuclear Regulatory Commission Mohan C. Thadani Attention: Document Control Desk U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike R. L. Balcom Rockville, MD 20852 Reliant Energy, Inc.
Richard A. Ratliff A. Ramirez Bureau of Radiation Control City of Austin Texas Department of Health 1100 West 49th Street C. A. Johnson Austin, TX 78756-3189 AEP - Central Power and Light Company Cornelius F. O'Keefe Jon C. Wood U. S. Nuclear Regulatory Commission Matthews & Branscomb P. 0. Box 289, Mail Code: MNL116 Wadsworth, TX 77483 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road
-Austin, TX 78704
ATTACHMENT 1 Commitment Change Summary Report wp/nl/nrc-ap/misc-02/02001330.doc STI 31449454
NOC-AE-02001330 ATTACHMENT 1 COMMITMENT CHANGE
SUMMARY
REPORT Page 1 of 2 Source Document Source Date of Original Commitment Description Revised Commitment Description Justification for Change Condition Report Date Change Number HL-AE-4220 09/23/92 07/15/01 A clear definition of TADOT will be formally The commitment was deleted because it STP originally completed this action by providing a 01-8130 HL-AE-4254 11/13/92 documented by October 15, 1992. was determined to be unnecessary. Technical Specification Interpretation (TSI-124). If 92-1324 questions arise in the future regarding what constitutes an adequate Trip Actuating Device Operability Test (TADOT), NRC Generic Letter 96-01 can be referenced for clarification.
STP completed the actions required in NRC Generic Letter 96-01, "Testing Of Safety-Related Logic Circuits". Generic Letter 96-01 requested that licensees:
- 1) Compare electrical schematic drawings and logic diagrams for the reactor protection system, emergency diesel generator load shedding and sequencing, and actuation logic for the engineered safety features systems against plant surveillance test procedures to ensure that all portions of the logic circuitry, including the parallel logic, interlocks, bypasses and inhibit circuits, are adequately covered in the surveillance procedures to fulfill the technical specification requirements, and
- 2) Modify the surveillance procedures as necessary for complete testing to comply with the technical specifications.
The completion of these actions make the clarification of the definition of a TADOT in Technucal Specifications unnecessary. If questions come up in the future regarding what constitutes an adequate TADOT, NRC Generic Letter 96-01 can be referenced.
Unknown Unknown 08/01/01 STP's IOCFR50.59 Evaluations procedure The commitment was deleted because it According to IOCFR50.59(c)(4), the provisions of 01-12331 indicated that STP made a commitment that all was determined to be unnecessary. All 10CFR50.59 do not apply to changes to the facility or changes to the Operations Quality Assurance changes to the Operations Quality procedures when the applicable regulations establish Plan (OQAP) would be evaluated pursuant to Assurance Plan are evaluated pursuant to more specific criteria for accomplishing such changes.
10CFR50.59. The origin of the commitment IOCFR50.54(a). All changes to the OQAP are subject to IOCFR50.54(a) was not determined. and 10CFR50, Appendix B.
99-11276 NOC-AE-01001028 02/08/01 08/30/01 Changes to the defensive strategy will be Revised commitment due date where The change in the defensive strategy represented a 01-2661 NOC-AE-01001018 completed by September 4, 2001. implementation of the new defensive significant set of enhancements that were the AE-NOC-01000780 strategy was to be completed by no later culmination of extensive planning, assessments, and than September 24, 2001. industry benchmarking. Although STPNOC determined that the new defensive strategy was an improvement, STPNOC's defensive strategy at the time, met security plan and regulatory requirements. Therefore, the slip in schedule of less than 30 days did not adversely impact the security program. The implementation of the new defensive strategy was actually completed on September 1 16, 2001.
wp/nl/nrc-ap/misc-02/02001330.doc STI131449454
NOC-AE-02001330 ATTACHMENT 1 COMMITMENT CHANGE
SUMMARY
REPORT Page 2 of 2 Source Document Source Date of Original Commitment Description Revised Commitment Description Justification for Change Condition Report Date Change Number HL-AE-2614 04/15/88 09/06/01 Various actions were taken to provide interim The Records Management Procedure, The station has matured to the point where department 01-12074 storage for Technical Specification (TS) OPGP07-ZA-0001 was revised to reflect personnel are responsible for records in their possession surveillance packages within Plant Engineering requirements for the protection and (including in-process documentation and completed Department in accordance with plant procedure storage of in-process documentation and records), site buildings have fire protection systems, and OPGP03-ZA-0042. (A) A lockable, one hour completed records. The specific processes governed by procedures that include approval fire rated filing cabinet has been provided. (B) requirements include: (A) Departments and routing of documentation. Proliferation of electronic A log has been established to track the removal generating required records are media also allows for regeneration.
of TS surveillance packages and provide an responsible for providing the appropriate index of what is maintained in the file. (C) A controls to ensure that in-process ANSI N45.2.9 states that a document is considered a records custodian has been designated. documentation and completed records quality assurance record when the document has been A memorandum was also issued from the Plant are afforded reasonable protection fiom completed. Applicable Regulatory Guides/ANSI Manager to Department/Division Management loss and degradation; and (B) these Standards do not define or describe the control of "active requiring that interim storage be provided for controls, as applicable, should provide QA records".
documents containing critical information, for adequate storage facilities or including TS Surveillance Packages, when equipment, designation of responsible TS Surveillance packages temporarily maintained in the credit is taken for them. Divisions within the personnel, and methods of records Control Rooms are being afforded reasonable protection Nuclear Plant Operations Department which inventory. (e.g. Control Room environment, manned 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s/day, process TS Surveillance Packages after test limited access, fire suppression system, shift supervisor's coordinator approval will provide interim log TS Surveillance package status).
storage protection in accordance with OPGP03 ZA-0042 for the TS Surveillance Package.
Plant procedure OPGP03-ZE-0004, "Plant Surveillance Program" has been revised to indicate the point at which TS Surveillance Packages are to be treated as Quality records.
Unknown Unknown 03/03/02 STP's procedures and correspondence indicate The commitment was deleted because it License Amendment 133 for Unit I and 122 for Unit 2 02-797 that there may have been a commitment to was determined to be unnecessary. deleted Technical Specification (TS) 6.8.3.d that notify the NRC Resident Inspector when the specified requirements for the Post Accident Sampling Post Accident Sampling System was out of System Program. Since there is no longer a TS service for greater than 7 days. The origin of requirement for PASS there is no need to notify the NRC the commitment was not determined. Resident Inspector.
ST-HL-AE-950 05/05/83 05/30/02 All structural steel for Category I and Non- The commitment to purchase structural The commitment was made years ago when the plant 01-123-41 Category I structures will utilize structural bolts bolts for Non-Category I structures to was under construction. The improper segregation of purchased to Category I requirements. Category I requirements was deleted Category I and Non-Category I structural steel bolts in because it was determined to be the field had allowed bolts purchased to a Non-Category unnecessary. I specification to be installed in Category I structures, contrary to project requirements. The conditions have changed, where only a fraction of the number of structural bolts that were used then, are being used today. Also, the warehouse has a better material controls program. The warehouse can segregate Category I and Non-Category I structural steel bolts just as it does any other Category I and Non-Category I material.
wp/nl/nrc-ap/misc-02/02001330.doc ST131449454