NOC-AE-0382, Commitment Change Summary Rept for Period 970107-981208, Per 10CFR50.5(b)(2).Rept Lists Each Commitment for Which Change Was Made During Reporting Period & Provides Basis for Each Change.With

Commitment Change Summary Rept for Period 970107-981208, Per 10CFR50.5(b)(2).Rept Lists Each Commitment for Which Change Was Made During Reporting Period & Provides Basis for Each Change.With

ML20198E855
Person / Time
Site:	South Texas
Issue date:	12/08/1998
From:	Cloninger T HOUSTON LIGHTING & POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NOC-AE-0382, NOC-AE-382, NUDOCS 9812240160
Download: ML20198E855 (22)

Text

. _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

_ . _ opere MW s - , - e n EY ,a - , - - m a, n December 14,1998 NOC-AE-0382 File No.: G01 10CFR50.59(b)(2)

U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 South Texas Project Units 1 and 2

, Docket Nos. STN 50-498, STN 50-499 South Texas Project Commitment Change Summary Report 1

Gentlemen:

Attached is the South Texas Project (STP) Commitment Change Summary Report for the -

period January 1,1997 through December 8,1998 as required by 10CFR50.59(b)(2). This report lists each commitment for which a change was made during the reporting period and provides a basis for each change.

Each commitment was 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". Additional documentation is available at STP for your review.

If there are any questions, please contact either Scott Head at 512/972-7136 or me at 512/972-8787.

T.H. Clo nger Vice Pr ident Engin rin and 9812240160 981208 Technical S ices PDR ADOCK 05000498 g}

R PDR , ,,a PLA r

Attachment 1 Commitment Change Summary Report

-Attachment 2 Condition Report Engineering Evaluation Form CR 97-5740

</& >

l wp/nt/ntc-aphnisc 98V)382. doc STI: 30783903 i

)

j

. l NOC-AE-000382 File No.: G01

, Page 2 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 Cperations - Records Center U. S. Nuclear Regulatory Commission 700 Galleria Parkway Washington, DC 20555-0001 Atlanta, GA 30339-5957 Comelius 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.

I800 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 ATTN: 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

ATTACHMENT 1 Commitment Change Summary Report e3w wp/nthawapW98V)382. doc STI: 30783903

P ATTACHMENT 1 .*

COMMITMENT CHANGE

SUMMARY

REPORT Page 1 of 12 Comhtmn Seura Dooment saura Date of Change Original Conmutment Deaription Revised f>==r~at Desmption Justification for Giange Report Dae Number -

89-20 LER 89-001 2/6/89 1/2968 This event (Partial loss d OfIsite Pbwer due to a This event will be incnrporated into lessons The Pyrotrotucs SysternIII fire detection system AE-2965 Fre Protection System Aduation) willbe teamed training of the Reactor Plant Operatcr was upgraded and regdaced with the Notifia Fire inctzprated into lessons learned training of the requalification pogram by June 1,1989. DetecianSystern Theconfiguranondthe new Reactor Plant Operator requalification pogram systempdiibits the - dthe event by June 1,1989 and into initial training d the described in LER 89401.

next dass of RPO's 91-22 IIR 91-001 42/8/91 2/19/97 Operational pohlem investigation d power None - Commitment has been deleted. The event docuormted by 1ER 9140lis.aolved A E3683 supplies will be inccrprated into the licensed and direct troubleshoming of a FWIV hydraulic unit am-liansed gersta training programs. by Unit 2 Operations Dqt. personnel These etfcuts suffetal from pow supervisory oversight and cxxrdination, and as a result, a plant trip occurred. Camtive Action 7 of LER 91401 was to provide additional training fa publem investigation dpower surplies to licensed and non-liansed operators. The need for this

- - - - - - is nolonger valid. The work control poasses at the station have substantially dianged since 1991. OPGP03-ZA4090, Work Control, details the pacess fw curective maintenanw and M'Mng, as well as degmtmental responsibilities. Opesations Department has a significantly different role in

• these pacesses today than they did den the event oaurrect Additionally, oversigls of these activities has inaeased substmanntly timough a combination of p=abral @-. and

- y-as ey-We_ None of the arrent pocedures governing maintenance and troubleshooting contain guidana or instructions for Operations personnel to perfwm problem investigation of power sugplies. As such, there is no pacedural cr goass foundation for this type of training information and its Fesence could be misconsemed as intent or expectation 9I-237 IR 9I-009-V-01 5/15/91 2/4/98 ST-III AE-3764 states that the following actions sina the time of the criginal . - n.- a. added Committed actions are essentially peserved in AE-3764 were inccrporated into the Waste Shipments in part to OPRP07-ZR4009. Perfctmance of another pucedure (OPRP07-ZR-0009 verses Procedure OPRP03-ZR4002. liigh Expmure Work. IIcalth Physics is revising OPRF07-ZR-0007). Thelocation of the both OPRP03-ZR-0002 and OPRP07-ZR4009 amunitted actions in the revised location is nxre A. Acass to areas outside of the normally posted and has determined that it is most agirgriate to apprognate because the high exposure work Radiologically Controlled Area in which transient retain the committed action in the latter guideline is in pactia used in hand during the radiation areas may exist while the IIIC is Focedure Spedfically Ibrm i1, Guideline for newement of the high integrity metainer, while unshielded wir he controlled. Ifigh Integrity Container Slupment, contains the the radioactive waste shigrit:g pucedure is used spirit of the committed actions as follows: In subsequent to this activity to ensure the material B. The radioactive waste truck bay telephone section C of Form i1, items 2,3, and 4 address is paperly offered fcr tranyxstation and disposal.

number will be included on the posting on the the committed action item a) as follows: It is believed that the original wmnatment is no wpfnLinrc-ap%nisc-980382. doc STI: 307839t:3 i

ATTACHMENT 1 .-

COMMITMENT CHANGE

SUMMARY

REPORT Page 2 of 12 Condition Source Document Source Date of nance OriginalCommitment Desaipuon Revised Comnatment Desaigmon Justification fw Diange Repat Dme Number -

truck bay dow w a Radiation grotection longer -**=y in that the plant page teduucian will be posted at the dow if the dow is 2. Evaluate the need to monita dose rates hwia grior to and upon conpletion of required to be posted as a liigh Radiation Area. outside the rad-waste truck bay fence cr the Ibel IIIC nuvement is sufficient to inform affected IIandling Building truck bay doms (outsde the pasonnel d the lilC transfer, and that the wcrk C Semrity, Ileahh Physics Operations, and normally posted radiologically controlled area.) groups cited in item e are aggrised of the transfer Plant Operations permanel will be notified guia during high intgrity cxmtainer movement, based on grict awrdination necessary to effect the to removing the 111C from the shielded coner evolution.

and after the IIIC is returned to a shielded 3. Survey the trangsut vehides travel path contamer during traa3xut outside the restricted area to ensure rn member of the public reaives more D. A plant ===% is made to inform than 2 t. rem.

personnel grim to transfer of the IIIC and upon ccurpletionof transfer. 4. Survey area outside the dosem RCA boundary during movement of the unshielded IIIC.

Section D, item 5 directly refies.ts committed action (b) above. Section D, item 6 diredly reflects cxxnmitted adion (d) above. Committed action 9c) above is not specifically translated to OPRP07-ZR-0009.

95-1155 LER 2-95-002 3SS5 1I/23S8 Design Engineering will revise the scaling Commitment deleted. His Corrective Action was dosed on Quality Monitwing database to allow fw the input of tranunittu 12/1585 with an owner comment stating in Repmt 98-00397 serial number and static shift ccurections fa part *CR adion dosed. Planners guide affected tranunittera. revised to inacrpwate requirement to transmit static zero shift information and serial number to DED as required for indumon in the Scaling Database". A QA

..udit determined that the carective action was to modify the Scaling Database to add an adfitional field fa tramunitter static zero shift data and model number infctmation.

Using the " Remarks" field did not literally ausply with the desaibed adion. He Apparent Cause Investigation performed conduded that the action had been erroneously artpleted'doned-out on 12/1585. Ilowever, use of the " Remarks" field is adequate to reard the grescribed infwmation. Therefare, it is unneassary to nxxhfy the Saling Database to include additional fields. Based on the above discussion, it has been determined that this commitment is rW required.

96-12938 IR 92-26-V-02; 10/16s 1/3067 he alarm setpoint will be revised to indicate that Commitment was deleted; Letter to the NRC The violation cited in the NOV was fcr a failure IIL.93218, 2, the battery bus voltage is below the Tedmical 1/3087 "Oiange inenn-en , fcr Reply to to have grocedures appropriate to the AP 4254, 11/13 S Specification mininuam value. His will be Notice of Violation 9226-02 circumwances. The conmutment to be deleted wpful/nrc-apVnisc-98Y1382. doc STI: 30783903

ATTACHMENT 1 -

COMMITMENT CHANGE

SUMMARY

REPORT Page 3 of 12 Condition Smrce Document Sowce Dete of Gange Origmal Conunitment Demipion Revised Conmutnent Description .lustification fw Ga. ge Reput Date Numtwr -

AE 5562 2, completed by Mard 31,1993,in toth Units. does not Fovide a awredive action that will 1/30/97 rectify the adual violation (i.e. failure to have pocedures anigriate to the drci.netances).

Deleting the ,---- . - . will ad result in a failure to conply with the .y ma cited in the NOV. De fad that the un&rvoltage alarm l was wiginally set at i17 VDC, whidi is below the Ted nical Specification minimum value for ,

float voltage (129 VDC),is nd a violation fa the desien basis a any regulatwy -.m.s.

97-2978 ST-III AE-5586 2/216 7 9/30/98 Fw subsequent steam generator eddy current Fw subsequent steam generata eddy current ne - .Jems was initially made to monita ST-IIL.AE-5603 3/13S7 inspections on the currently installed generatus ia3xdions on the currently installed generatus the possible recurrence d tube flaws at tube-to. l maducted to satisfy Tedinical Spedfication cmducted to satisfy Tedinical Specification sugport plate intersedians and in the straight tube Surveillanw Requirements 4.4.5.1 and 4.4.5.2, Surveillance Requirements 4.4.5.1 and 4.4.5.2, cold leg freespan region. He reference to bobbin the first sanple will be a 100% bobbin the first sample will be a 100% bobbin inspedian was to darify that we were NOT i examinationdthefulllengthof allin-service examination dthe fulllength of allin-serviw mmmitting to do the inspertion with a rotating  !

tubes. tubes. Other quahfied eddy current tediniques pancake coil gobe or a + point pobe If we may be substituted fa bottin as appquiate (e.g. d oose to do a pition of the inspection with a

+ point inspedian of row I and 2 U-bends). qualifiedFabe (whether RPC, + point, w something else), it will be at least as good an inspedian as if we used bobbin as arnmined.

Fw example, it has been demonstrated in the industry that the + Point coil is nure sensitive than the tobbia coil for the detection of the types of flaws shidi typically owur in the Row I and 2 U-bends. In these tight radius U-bends, a small pube transt be used in order to make it around the  ;

bend. A paperly sized + point probe will do a better job, while the straight legs can be ingwcted using a Fabe Foperly sized fa the straight legs without consideration fa the U-bends. Other similar inspedian (ptions may be oesirable in the future, so the -- 2 wording is regirased, while maintaining the wiginal intent. i 97-5382 Revised Station 7/24S5 3/13S 7 Quarterly engine analyses are perfwmed to Engine analyses are perfwmed in acxxrdance with la ST-III AE-5010 to the NRC (Revised Blackout Position fw povide diagnostic information for possible the SDG venar reconunend2tions. Additional Position on 10CFR50.63, loss of All Alternating STP su' sequent carective action. analyses may be soieduled and perfumed at the Ourent Power), dated 3/ISS, S1? described HL-94257 disactionof theSystemEngineer. some of the adions whida were currently being AE-5010 perfwmed relating to SDG reliability. He quarterly engine analysis as statext was never intended to be a m Jbmd to perform engine analysis at that frequency; rather, it was a statement of the current STP pactice at that tine. ,

Originally, Standby Diesel Generator engine analysis was invienented on a quarterly basis in opfal/nrc-ap\ misc-980382.&r STI: 30783903

ATTACHMENT 1 .

COMMITMENT CHANGE

SUMMARY

REPORT Page 4 of12 Condition Source Document Sowce Date d Giange Original Commitnent Desmptam PM Corrmutment Desmntion Justification fw Girige Reput Date Number -

1994 fw the Niowieg reasons:

1) To obtain baseline anairJis on all the SDGs over a number of runr.

2) To familiarize new yrsonnel with the existing engine edysis equqnwns.

3) To familiari2 all prsorn! with new engine analysis eytupment.

All of these goals have been met. Cmtinued peafwmana of quarterly engine analysis does not grovide any significant new data, as on a quarterly basis, there are typically only 12 to 20 engine gerating hours between analyses. The quarterly analyses also require significant expenditures in maintenana and engineering manpower. Additionally,=. -. -- y SDG starts may result from being required to perfen analyses if the surveillana runs occmar when analysis personnel are not available. The vendor W% are to perform engine analysis on an 18 to 24 month frequency (pior to a major SDG outage), and then again coming out of the maja SDG outage. The typicalindustry gractice is to nret the vendor re W and to also perfwm an relitional ending analysis wvady mid way between majw SDG outages. STI's quarterly engine analysis gractim is obviously a far cmsetvative outfier from what the vends requires and what the industry

'I gractias. The bases fw the NRC review of STI's SBO submittal are its compliana with RG I.155 and NUMARC 87-00. Engine analysis is not discrissed w described in either of these documents.

97-5740 Claure of NRC 3/2/95 6/6/97 Excerpted frorn letter: "We understand that you Fcr this conmutment evaluation, the ------ --- --t See Attadumnt 2 Review d South have committed to pmcshcally verify the design- will not be permanently changed. This Texas Generic Letter basis capability of motorgerated valves at South - - - - - - evaluation involves one-time 89-10 Program Texas Project within the smpe of Genetic Letter exceptions to the 5 year periaficity fa static IIL-94133 89-10.1his process will include n static diagnostac tests of C2CCCMOV0404 and diagnostic test of eads mota-operated valve C2CSMOV0001C.

within the smpe of Generic Letter 894 at least every 5 years to verify an acceptable capbility margin. Your staff stated that one exception to this commitnient is that certain butterfly valves might be dynamically tested without diagnostics, in lieu d static diagnostic testine".

'T nl/nrc4

/ phase-980332. doc STI: 30783903

ATTACHMENT 1 .

COMMITMENT CHANGE

SUMMARY

REPORT Page 5 of 12 Condition Source Documect Sotate Date of Change Original Commitment Descripion Revised Commitment Desmpion Junification for Giange Repott D8e Nunter 97-6905 Response to Generic 10/26/9 4/24/97 1. Respmse Page 2,: "An interdepartmental 1. Ven&w Quahty Assurance (QA) manual 1. Ven&w Quahty Assurance manuals were not Letter 9043, O pacedure has been implemented at S1TEGS control is no longer part d the VEIIPFogram at part dthe oaiginal serpe d Genmc Letter 83 28

" Relaxation of Staff whidi establishes a single pogram fw reaip, STPEGS. Ven&r QA manuals are reviewed in cr 90-03, whidi addressed Ven&r Tedimcal Ibsition in Generic review, statusing, and distribution of ven&v. aacrdance with Quality Department Procedures Infamation. They were induded in the criginal Letter 83 28 Item 2.2 supplied technical information and quality controlling the addi' ion cr retention of vendas on response since they were mentioned in the Part 2. "Venar assurance manuals a[plicable to SITEGS. This the Approved Ven&rs List (AVL). pacedure, even though the procedure never Interfaa fa Safety- Foadur: arplies to

• Quality Assurance povided guidance on their review and anuoval.

Related conponents~ manuals.. 2. The VEI1P at STTEGS no longer provides a The commitment is geserved since Vener QA AP 3595 24 month review d ven&r manuals. Issues manuals were and are reviewed as part of the

2. Response Page 4"When a ven&w is no longer assodated with ven&us uk no longer povide venda inclusion and evaluation mxiated with available to Favide suppst fw safety-related surport fw safety-related equipment are the Approved Ven&rs List maintenance by the equipment, the SlTEGS VETIP povides for addressed in the following manner: Quahty Department under the purview of their review of the agplicable venda manuals at least a) Ven&r manuals are updated as part of the pocedures.

once every 24 months. In addition, sudi ven&r plant mo&ficatim pacess at SlTEGS and are docunents affeding maintenance cr repair a maintained anrrent with plant configuration 2. The review d ven&w manuals fa ven&rs permanent plant equipment may be revised as dianges by this poass. which no longer support safety-related equipment necessary by S1TEGS to ensure appopiate b) Ven&r manuals may also be uplated provided no tedinical guidance.1he comnntnent maintenance and repair pograms are in place". independent d plant configuration c knges. Such is geserved and enhanad since the intent is to d anges require a perfamana dimpad enmare that the manuals remain arrent with the assessments to goadures and other configuration plant configuration and operatirg and information. maintenance experience. The programs oc aribed c) STPEGS is cperated and maintained using ermre that all manuals remain mrrent noyu:t plant pacedures. These pacedures are often those assodated with ven&rs who no longer devekred using ven&w manuals as an input. supprt their equipment.

While the nnhfication pouss Fovides review fa mnfiguration changes, plant pacedures are also updated by the owner organizations based on STTEGS operating and maintenaam experience.

d) The STTEGS Operating Experiena Review aganization povides fm identification d industry events and trends affecting ven&r manua3. This allows venir mantrals to be updated to refied industry experience.

97 7310 lbactional 5/1/92 9/29/97 111 Imtiatives to Ingrove Equipment Initiatives in the area of radiological control and The commitment references a specific hthium EHectiveness Perfamance c:RadiologicalControls ALARAindudeinp' --- 1-.of alithium metrol pogram (Modified Lithium Control).

Assessment Initiatives in the area d radiological cmtrols and metrol pogram designed to reduce Crud levels in STP is dianging to a different lithium matrol in AE-4083 ALARA include inplementation of a nvxlified the Reacta Coolant System and assadated Unit I (has no spdfic title yet). This lithium lithium control pogram. The %xhfied Lithium piping, . . The lithium control program and control program will be nure effective than the Contror pogram and ultra filtration are elenrnts Ultra filtration... Modified ControlFogram in redudng general of the ongoing source redudzon effart. omusion which will reduce plant crud levels.

This in turn will help keep plant doses ALARA.

The diance is also addressed by USQE 97-0040.

wptnt/nrc-apVnisc-980382.&x STI: 30783903

ATTACHMENT 1 COMMITMENT CHANGE

SUMMARY

REPORT Page 6 of 12 Condition Source Document Scum Date of Change Original Cmmutnrnt Desaipson Revised hw-=' Descnpaion Justafication fcr Qiange Report Date Number -

97 9330 1R 90-33 11/6/90 7/14/98 In response to a noncited violation identified in OPGN4-ZE-0304, Rev. I will delete the Original NDE poadure non-cxxnpi-111 92595 Inspection Repcut 90-33, STP committed to the afcrementioned commitments. Responsibility fa occurred over 7 years ago during the 2REOI following: the manual NDE fcr the ISI program has been refueling outage. Since that time, Engineering delegated to the Quality NDE Group by NDE level III Contractws and, later, Quality I. QC will train vendar NDE tedmidans giw to Entneering. The Quality NDE Gruup performs NDE Group staff have povided otssite training cada agi ticable refueling outage on QC NDE the NDE themselves or hires ven&T NDE to ven&r tedmicians on STPISI NDE pacedures fcr manual ISI NDE tediniques in tedmidans to perform the exams. The NDE is poadures and equipment and perfctmed accordance with QAP 1.4, Indoctrination and perimned to Quality NDE pacedures using monitaing of ven&r tedmicians for poadure Training dPasonner(see 53.4 and 5.4.7 of Quality equipment and materials. Ven&w NDE cxxnpliana with good results. Existing Quahty OPGPO4-ZE4)304, Rev. 0). QAP-l/4 has been tedmidans are trained on site on the applicable poadure fw training and certification of NDE superceded by OPQP02-ZA-0004. Quality NDE pomdures befwe being assigned to personnel (to be revised per cornpliana with good perfwm NDE in the plants. This ensific results. Existing Quality poadure fa training

2. ISI Responsible Engineer or his designee will aunmitment to on ote training of ven&w NI)L and certification of NDE personnel (to be revised monita manual NDE ted nicians for Focedure personnel, including referencing d the sourm per CR 97-9330-5) and CTC ven&r namitoring  !

<xuuplianm on a sanpling basis (see 53.5 and document SPR 900451, will be incorporated in poadure requirements Fovide adequate metrols 5.4.8 of OPGPO4-ZE-0304, Rev. O. the next revision of OPQP05-ZA-0001, over future manual NDE operations for the ISI

• Qualification and Certification of pogrant Nondestructive Examination Personner(CR 97-9330-5). OPQP02-ZA-0004,ladactrination and Training d Quahty Personnel"is not applicable to the training of NDE personnel The Quality NDE Group staff serves as the Contract Tedmical coordinata (CTC) fa the vendcr NDE pardiase ader; these CIC duties indude monitoring the ven&r fcr tedinical cornpliance with the Quality NDEFocedures. Therefore, other existing station pocedures either attrendy gro ide (<r I will pmide) the training and monitcaing  ;

requirements peviously committed to in SPR 90045I and the cited sections of OPGPO4-ZE-0304,Rev.O.

97-11727 GL 85-11 Completion 6/28/85 9/1I/97 Beginmng on page 13 of the attadunent to ST- The following changes /darificatsons will be made At the time that the wiginal heavy loads submittal of Phase II of and IIL-Ae1129: to the above. mas pepared, many aspects of the details of

" Control dIIcavy 10/19/8

• To gevent loads from being carried over the actual refueling outages were not fully Imads at Nudear 4 reactor vessel, the polar crane will be egripped 1. The interlock will be in effect ONLY when the understcxxi. This was remgnized in the cover Power Plants" and with an interlock to prevent the trolley from reacts head is renmed frorn the vessel letter in which we state "As the STP design is Letter ST-IIL- moving within a given radius of the reacta not yet cxmplete, there may be a need to add or AEl129 and NUREG vessel (the zone of the interlock is shown in 2. Additional loads other than the internals lift sig untify load handling systems. In the event this '

0612 figure 38). Ileavy loads that are requred to and the upper internals will be required to pass becmrs neessary, the new load handling system pass within the interlock zone (with <w without through the interixk ame. and unhfications to existing load handling the head in plaa on the vessel) are the upper systems will consider the guidana d Generic and lower internals, the in. service inspection rig, 3. The key for bypassing the polar aane letter 8 l-07". We now recogi.ize that it is the integrated head package, the stud ca rier interlock will be under the <xmtrol of the shift nexessary to change sone aspects of the response rack containing twelve studs. nuts, and wasfers, supervisor or his designee. to suppm our outage plans and to reflect how the stud tensners, and the Internals Lift Rig. outages naast in faa be performed. Iir exanple, wp/nl/nrc-aphnisc-980382. doc

• STI: 30783903

ATTACHMENT 1 e COMMITMENT CHANGE SUhniARY REPORT Page 7 of12 n-tition Source Dtninent Source Date d Change Original Cm..mw thison Repat D8e Revised the Descrpmn Justifh:stion fa Qiange Number

• The polar mane is used only during dantdown 4. During rapid refueling, bypass d the intalock it is neassary to bypass the interlock gdace m and refuehng. Once the integrated head mill be pernatted fa loads other than the O<ing shielding and to groced refuehog personnel. In parhae is renmed, the only loads required to fixture. addition, NLTEG-0612 crmsiders the load block be carried through the intalock while fuel is in a heavy load that should be addressecL Based on the vessel are the internals liA rig whidiis 5. The intalocks will be test 4 ONLY after the our analysis d these changes using the guidana regiured to diange the O<ings and the urper interlock has been reinmalled d Generic Letter 81-07 it is concluded that a antanals if they are removed separately frorn the sigmficant hazard condition does not exist anJ the IIIP, proposed dianges are appropriate. The htC

• The intalocks are active at all times unten recognued that actions sudi as this would be bypassed by key. The bypass will be in effect as necessary in Generic Letter 85-11, which ekned C long as the key is inserted. The key cannot be out Phase II dthe NUREG-0612 effort.

rernoved without reactivating the interlock.

• An integrated head package (IIIP) dr9 analysis which is arphcable to STP was paferrned by Westinghouse letter NSG 1101 dated June I1,1976 on the RESSAR-41 docket. This analysis determined that dropping the head would not result in an unacceptable degree d core damage, it reaived NRC aptroval on November 30,1976.

• Tis internal liA rig is shown on figure B-3. It is 14 feet in dianrter and 30 feet high. Because d its size and shape, it is impossible fw it to hit the fuel The effeds d a drop d this rig onto the vessel are enveloped by the Westinghouse llead Drm Analysis since the rig is nnxh lights than the IIIP.

• The effeds d a drop d the urper internals are also enveloped by the Westinghouse IIcad Drcy Analysit

• The lower internals and inservice inspection rig are moved only when all the fuel has been renmed frorn the vessel

• The key to the vesselinterlock will be unda the control d the tefueling directcr. The interlodc will be bypassed to remove the IIIP. Once the IllPis removed from the vessel and clears the area above the vessel, the intalock will be restwed.

• During rapid refueling, bypass will only be pennitted fa replaament of the O-rings.

During nonrapid refueling b3pass will be permitted to rerrrwe the internals as well. The up/nl/nre-aphnisc-98V)382 doc STI:30783903 w -

ATTACHMENT 1 L COMMITMENT CHANGE

SUMMARY

REPORT Page 8 of12 Condition Scurce Dtuiment Seine Date of Change OriginalComnntment Description Revised Cannutnrnt Desaipion Justification fw Change Report N*

P'unber interlock will be bygmssed to replace the IllP.

Administrative & Testing Requirements

• The key tw bypassing the vessel interlod of the polar crane mill be metrolled by the refueling director and released only upon groper authorizatiat Procedures mill also metrol the use and bypass of the interlock; additional technical specifications are not warranted.

• The interlod boundaries mill be tested before the interlocks are bypassed and following replacement of the IIIP. The tests will be run without load on the crane hook.

97-20232 ST-IIL-AE-5664 5/28S 7 7/1768 Plant Management has directed that a'l Plant Management has directed that a!! Ptucedure diange fw OPS 193-XC-0002A would AE-5664 individuals on an entry team be briefed on individuals on an entry team be briefed on allow use of a certification for RCB entries in acxrpance aiteria required fa the control of acceptance aiteria required for the control of ader to eliminate the required SRO briefing. All loose debris in the Reactor C-*i=~ar Building loose ibris in the Rem = Containment Building personnel who are not astified and the team in Modes 1,2,3, and 4. Eadi team is assigned a in Modes 1,2,3, and 4. Eadi team is assigned a leader will be required to obtain the briefing grior Team Leader who is responsible fir ensuring Team Leader utio is responsible fa ensuring to the fast entry Jaring the shift This relieves the con 1piiance with the requirements of Tedinical w.A v with the requirements of Tedinical SRO of unneassary briefing and infwms Speafications. The Shift Supervisor a his Specifications. The Shift Supervisa er his personnel of requirements by certifying them fa designee conducts a fwmal briefing of individuals designee aeducts a formal briefing d all RCB entry.

on the entry teant The briefing 4a are nersonnel to enter containment that do not have a part of the surveillana pacedure and povide current 4389 certzfication.

• Partial Containment specific topcs and material to be grovided to tne Insmction." and fm the desienated team leader entry teant The Fem = nar=i=a-ar Building grim to the first entry durine the shift. The inspection procedure was revised to include these briefing iwa are part of the survesH-requirements on Agil 17,1997. proadure and grovide specific topics and maternal to be povided to the entry teant 1he Reacts thi=a-ae Building inspection poadure was revised to include these e-m.m.a on Arvil 17,1997.

98-7657 111 94315 9/2868 11/23S8 The following " Additional Information" is given For ST-IIL-AE-5098:" Reviews of coupleed, These statenents are not actual comnntments.

AE-5098 6/20 S 5 in ST-IIL-5098:" Reviews d all completed, time time directed, calibrations are performed in They are statements d fact that were accatrate at AE-5646 5/867 directed, calibrations are perfumed in acxxrdance acowdanm with Station Procedures, including the the tirre d writing. These statenrats were n x with station pacedure OPGP03-ZA4503, Preventive Maintenance. Plant Surveillana, and necessary. Presently, our monitsing efforts are

" Equipment IIistory Program" and are reflected in Maintenance Rule Programs." fir ST-lil AE- focused on risk-based uiteria that may not the equipment histay database." Also,in ST-HI- 5646: Eliminate the statement in its entirety. include a review of"all" calibrations, work orders AE-5646, the following statement is made- and peventive maintenance activities. Reviews

" Aback end analysis of all Work Orders and of documents associated with tid significant and Preventative Mamtenance activities is performed non-risk significant components will be perfarned by the equipment history group in the Reliability i as newssary to sugprt piant programs.

Engineering division." l ,

wp!nl/nre-aphniscw980382. doc STI: 30783903

ATTACIBIENT 1 .- ,

COMMITMENT CHANGE

SUMMARY

REPORT Page 9 of12 Condition Sourte Document Sowa Date d Gange Original Comnatment Desaiption Revised enn-mmann Descripuon Just.fication for Cbge Repot Date Nunher -

98-10151 ST-III-AE-l364 9/19/85 7/2/98 STP will prmide the NRC with written Commitment Deleted This ---- --- originatedinletterdated AB 1364 amfirmanon from the manufacturer regarding the September 17,1985 (ST-HI AE-1364) as part d DG panels location and mnunting from a the resolutwo of open items during wiginal vibmion standpcint. hoensing. Ilow the - - -- n a was resolved with de NRC is unknown, but since the Operating Lacense for both Units were issued, the matter is no toeger a concern ir the NRC. The deletion of this sentence from the UFSAR does not diange the designmoL_ L dplant equipment, involve any in~W"_= to the facility, cr any dianges to plant pr=whos Consequently,the deletion dthe - -- n - has no bearing on the current design and <peration of STP and, therefore, does acs change the intent of the UPSAR.

98-14003 IIR 88-035 6/17/88 12/7/98 AII ASME Section XI punp and valve All ASME Seaion XI putnp and valve data from The original ~~=ak=w=* did not ensure that AE-2682 surveillancu test paaages are reviewed by the surveillana test packages is entered into a a timely review was conducted on the Section XIIST Coordinator. Requests f r conputerized IST Database pogram when it is survei"a- data. Several data packages inaensed frequency testing are initiated following received frcan Operations. Following data entry were review d by the system engineer but this review fcr pun 1ps with parameters in the alent into the program, it is reviewed and verified by trending results were act evaluated pict to range and fcr valves exceeding the trend lirtuts. A the Seaion XI Cocrdinata. During this review, missing an increased frequency test cr prior second review d the surveillaw packages is punps with parameters in the alert range and to taking credit for a survallaw that was conducted by the system engineas. The review d valves exceeding the trend limits are placed on not perfctmed. By using the new IST test packages by the IST cocrdinatcr and the inaeased frequency by the Section XI Database, the conpanent data will be subsequent review and evaluation of the pad =ges Coordinata. entered within a few days of performaw by the agnbant system engaaect will ensure that The Database cm .25 the acaptance aPF0Fiate arrective actions are inplemented. cr% e endi cariconent and will alert the Seci.,s XI Coordinator that further action is required. The review by the Seaion XI Cocrdinator ensures that increard frequency swww.Js are identified 1he Condition Repcrting Process has been incxrpcrated into the punp and valve programp ocedures. This willFmide system engineering the Mae== required to ensure that apprgriate corrective actions have been 6 *-- crA Additionally, this poust all identify when a aunponent has been removed from inaeased frequency testing.

90-16563 ST-NOC-AE-97 4/2S8 10/16/98 Both documents cite the following ua6me, A one tune exception is needed to allow one tube Contacted NRC on 10/16/98. NRC was ST-NOC-AE-74 2/16/98 made es part of the submittal to the NRC to be plugged withet perfctming rotating infarrned d our plan to plug the tube without requestiiche since agroved liceme =me=d-a* pancake cxul eumination (RPC). This eaception , 'orming RFC and they amepted our plan. At for Unit 2 voltage-based repair aiteria: " Bobbin is needed because the equipment neassary to = m. request of the NRC, STP comnutted to two coil flaw indications creater than 1.0 voit shall be pesfcrm the examination has already been l follow-up actions- 1. Discuss this tube in the 90 wyfal/ arc-aphnisc.98YJ382. doc STI: 30783903

1 L - m ATTACHMENT 1 -

t COMMITMENT CHANGE

SUMMARY

REPORT .

Page 10 of12

~~~Cuadmon Source Document Smece Date of namee OriginalCoesnatment Desa:pnom Revised Commitment Desmptaon Justification fu nange Report . Das Number . -

naspected by a rotatang p==caka coil probe (or removed from the steam generatas. Reinstalling day APC repost and 2. Address our plans for equivalcat) to evaluate the presemoe of detectable the meassary equipment would take an estimated future inspedian relative to axial fracep== cold .

ODSCC and to confirm that the dtur====r 1.5R of dose to the workers, and the demon has leg cracknagla the 90 day APC report. it corromaa medianism occurring is axially onented already been made to plug the tube.

ODSCC"(see section 1.2 of the W f -.s report SG-984)1 004 attadied to both lesers).  !

The NRC Safety Evalestion Repcat ST.AE. t NOC-000258,9/24/98 states"the licensee has '

prcposed to follow the requested adioms of GL 95 05 for inplementing the 4 L.2 -  !

plugging aiteria. 'Ibe : . --

methodologies are documented in a teduncal I support Jamment, *Weeingew=ne: Steam  !

Generator report' amonpanying the TX rvedment request." -

98 19265 ER 944)I1 4/18/94 12/8/98 Carecsive Acnoar . The Work Risk Assessment (WRA) poass and The following will describe how ER 94-AE-4770 5. Expanded administrative metrois have beca fwm in OPGP03-ZA43090 have been gevioasly 01Icarective actions 5,6, & 7 stated above, are  !

implemented to screen activities on aduataca risk aeshted with meenag the above LER careceive mrrently being met at STPEGS. The informanoa systerm or pacedures pia to use (ongatag). actions. The poposed disage is to revise how we levided below is intended to supprut removing i

6. Comprehensive screening of surveillaaoe tests nieet the above LER v ' - - - be removing die mr _.e fw the WRA p== the WRA will be perfwmed fa actuation risk and the WRA fem as weII as the list of rif Mtive form, and list of risk sensitive symems from inerpmation of mr . _ fape-4est ^

systenu from OPGP03-ZA4)090, Work Proms: OPGP03-ZA41090, Work Proass Program briefings /+6y oversight based on speafic Programin revimos 20- f risk (omscing). 5. Expanded Ne castruis have

7. liigh and nudmm risk activities that have been haplesmented to screen activi6es em been sdieduled will be reviewed and maangement ace==ei== risk systemas er precedures prior to attention will be inneased (ongceng) use (engedag),

Surveill==a procedures, whidieffectESF  !

==* ion w rencem trip circuitry, have beca i revised to indude a WRA as part of the pruadure body. The Conduct of Operations Giudehme povides spedfic gewi==re on how and when to perform pe-job bnefings for the operances stait .

'The Maintenaam department expedarica is to have enda - -- - crew brief endijob in the shop pria to etw.ining work start approval i In addition to the admunstrative and unplementing controls didated by the Condud of Operations Guideline and---i- : i-. for plant .

persammel, S'ITEGS has developed, and is an the I pouss ofimplemeanng a Graded Quality Assurance pogram whidiinvolves ,

pihatat risk-ranking of plant structures, symems, w u-%.e (SSCs). Revision 20 of upfal/arump\ misc 593Y)382. doc STI: 30783903

ATTACHMENT I -

COMMITMENT CHANGE

SUMMARY

REPORT Page 11 of 12 -  ;

Condition Source Docunent Smece Date of Gange Original Cermutment Descripuen Revised Cmurutment DescrWon Justif. canon fa Onage Report M Number _

OPGP03-ZAm,WorkPromasProgiar . iill l inmrpwate these tods into the wak proc-ss. The SSC risk <anking (along with critical attr butes fm cada couponent) will be incxrpcTated iuso the Master eqmpment Dau. base (MED) for review and evaluauen by plant personnel _1his infammuon will automancelly printmt on work crders and preventative mainteamare (PM) tasks issued faimpf- h SSCs that are risk-raeked as high or medium will remive additional attenuon and conards in acardance with the d:reamn provided in the above grocedure. In summary, the S'll'Ixis @ ire has been %W to inocrporate risk evaluations N reviews into  ;

daily business grocesses and acsivities.

6. C- , hdve screening of survemance tests alg be perfornoed for actuetten risk and hcus ' _ et requireements for pre-test t briefhngs/supervisvy everdght based on  !

speddle risk (engebg). ,

Risk sensitive surveillance tests have been revised to inocuporate agivopnate risk a ---& '

e- , and nowincludei@_ ;.s fw '

projob bneling and superviswy oversight as needed.

7. High and snedhne risk activities that have been scheduled wfIl be reviewed and nianagesment attentica will be increased (W

1 STPEGS is in the tracess of inplemenung a Graded Quality Assurana grogram that involves risk rankings of plant struaures, systems, and mme (SSCs) risk significance. Revision 20 of OPGP03-ZA-0090, Work Promss Program will inonrpcrate these tools and grocesses into the i normal wcrk promss flow. Plant gersonnel will ,

incorporate the SSC risk rankings into the Master '

Equipment Database for easy viewing and access.

SSCs that are ranked high a medium risk will  !

receive speaal anennon in acxxrdance with the guidelines specified in the afxive tracedure. -

i wi dal/nrc-apVnisc-980382. doc STI: 30783903 ,

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_ _ _ _ _ _ _ . _ . . _ _ _ _ u__._________ _ _ ___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ . _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _

ATTACIBENT 1 -

COMMITMENT CHANGE

SUMMARY

REPORT Page 12 of 12 Condition Source D-a S wrce Date of Change Originale,.mmem Desmpuan Reptr. Date Revised enm ~'=* 11w Jusufication for nsage Number Risk sensitive naivities are dismssed and dosely Miowed during the wwk sdneduling and screening gromss. The SITEGS wwk sdieduling gromss has been enh=W toindude w a apgrova's of weekly wwk sdiedules, Senior Reacaw Opera vs as wwk start authorities, and the use dswk window cowdinators to develm - - : :=, and cowdinate the weekly w<rk th hta la additics the use afgre-job briefings prior to plant wwk activities is stremed tiroughout the STP organization.

In sununary, the STITGS culture has been dunged to incorpwate risk evaluations and reviews into daily business gnumsses and adivities.

I wpfathe>aphnisc>980382. doc STI: 30783903

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1 ATTACHMENT 2 Condition Report Engineering Evaluation Form CR 97-5740 wp/nihrc-aphnia:-98V1382.&r STI: 30783903

Rev. 2 Page 17 of 17 OPGP04-ZA-0002 Cendition R: port Engineering Evalutti:n Program Form 1 Condition Report Engineering Evaluation Form (Sainple) Page1of1

' 1 of 6 CR No. CR 97-5740-5 Page

1. Identify the appropriate CR Category Engineering Action Engineering Report C Engineering Change Unclassified

2. Reason for change:

Enhancement Administrative Nonconformance

3. NCR Disposition:

Use-As-Is Repair Rework Invalidate Reject (NF&A Only)

4. Change Type:

O MajorMOD Non-Design Change Minor MOD Procedure Change Minor Change Ternporary MOD C Paper Change Other Actionfrask/Sub-Task /No. Owner Dept Description 97-5740-5-1 C.Rowland DED Evaluate slipping the periodicity to beyond 5 years to 2RE06 for MOVS C2CCMOV0404 & C2CSMOV0001C.

5. Disposition / Evaluation:

See attached page for continuation.

6. (9, f-&97 7. m blyff]

?rclpare / Date / Supe'rvib>r / Date l

l

CR 97-5740-5 Page 2 of 6 Engineering Action DESCRIPTION:

Evaluate rescheduling the Diagnostic Testing of 2 GL 89-10 MOV's beyond the five year interval for periodic diagnostic testing (Ref: GL 89-10 Closure Letter ST-AE-HI-94133, Dated 3/7/95)

DISCUSSION:

The MOV QC package initial /date (test package closure date) for C2CCMOVMM was June 21,1994 for testing conducted July 17,1993 and for C2CSMOV0001C was June 24,1994 for testing conducted April 18,1993. He next scheduled testing for these MOVs is during the Unit 2,2RE06 outage set to start October 3,1998. his causes the periodicity of test to be 5 years 2 months and 16 days for C2CCMOV04M and 5 years 5 months and 15 days for C2CSMOV0001C. his does not rneet the "at least every five years to verify acceptable capability margin" in the referenced closure letter for GL 89-10.

He test package closure date was used to start the periodic testing interval which resulted in the two Unit 2 MOVs being scheduled beyond the required five year diagnostic test interval. For these two MOVs, the test package closure date and the actual test date are considerably different because of a decision to concentrate on Unit I and delay atti Unit 2 test activities during the extended shutdown of both units.

Maintenance has implemented corrective actions for the GL 89-10 MOVs insuring all future test periodicity requirements reflect actual test dates and not package closure dates. Diagnostic testing of MOV's C2CSMOV0001C AND C2CCMOVM04 was added to the Unit 2 Mode 5 & 6 forced outage list. If a forced outage occurs prior to 2RE06 the diagnostic tests could be performed. Static test parameters were provided to support performance of the tests, should a forced outage occur.

STP does not anticipate a forced outage prior to 2RE06, therefore, this evaluation is intended to justify the extension of testing beyond the five year requirement for these two MOVs and allow testing in 2RE06.

C2CCMOV0404:

C2CCMOV0404 is a SMB-000-5-IllBC Limitorque actuator mounted on a 12 inch Ilills McCanna butterfly valve. This normally open containment isolation MOV located outside the containment accepts coolant from the reactor coolant pumps thermal isolation barriers and motor air coolers, the reactor coolant drain tank and excess letdown heat exchangers. Its safety function is to close on a Phase B isolation signal.

System configuration will not permit dynamic testing of this MOV however,5 identical Unit 1 MOVs were tested very close to the 97 psi MEDP for this MOV. %ese dynamic tests provided thejustification needed to not perform a dynamic test on C2CCMOV0404. He highest measured close torque of the 5 dynamically tested MOVs was 464 ft-lbs compared to the close DVAC (Degraded Actuator Voltage Capacity) of 698.8 ft-lbs for C2CCMOV04M. C2CCMOV0404 is limit closed and opened so the limiting torque is the DVAC rating in the close direction.

De torque range for the 5 dynamically tested MOVs was 426 - 464 ft-lbs not including instrument error. He calculated DVAC rating margin for C2CCMOV0404, using the highest dynamic torque from the 5 tests, is [(698.8 - 464)/464](100) =

$0.6 percent not including instrument error. Adding instrument error, the margin becomes [(632.1 - 464)/464)(100) = 36.2 percent. Considering these calculations the MOV is expected to function without any problems or concerns during the 2 months 16 days past the five years required test periodicity.

%e DVAC margin of 36.2% it adequate to ensure continued MOV performance based on maintenance history. The 18 month maintenance cycle insures satisfactory MOV perfonnance between the test cycle. Maintenance history for the dynamically tested MOV does not indicate any significant degradation in performance between recorded test intervals. He soft seats in the MOVs are expected to harden however, the increased hardness occurs over time and the effect on valve torque requirements is minimal..

CR 97-5740-5 Page 3 of 6 l Engineering Action l C2CSMOV0001C':

l C2CSMOV0001C is a SB-00-15 Limitorque actuator mounted on an 8 inch Westinghouse gate valve in train C of the three i train containment spray system. ne normally closed containment isolation MOV is located outside the containment and j

l isolates the containment spray pump 2C from the spray header. %e safety function of this MOV is to automatically open upon receipt of a "HI-3" signal to allow flow to the containment spray rings and to close providing containment isolation of the CS pump discharge line when the pump is stopped following an accident. j System configuration will not permit dynamic testing, however, five identical dynamically tested MOVs justify the operability of C2SIMOV0001C. De open/close MEDP for the five dynamically tested MOVs is 360/100 psi, which 37/43.4 psi higher  !

than the MEDP for C2SIMOV0001C. The valve factor used to set up the C2CSMOV0001C was the desien valve factor with l

5 percent degradation. ne valve factors recorded during the 5 dynamic tests were considerably lower than the design valve factor.

Adjusting the valve factor for C2CSMOV0001C to plus 25% of the highest dynamic test value (Ref: Attachment 2 to ST-HL.

AE.4966 " Dynamic Testing Program of GL 89-10 MOV's") results in a lower valve factor (i.e., from an arbitrary  !

I 0.509/0.589 open/close to 0.405/0.4375). his new valve factor lowers the required minimum open thrust of 8630 lbs to 7398 lbs and provides a calculated DVAC margin of [(10679 - 7398)/7398](100) = 44.4 percent in the open direction. He l actuator rating close thrust margin is [(14000 - 401I)/4011](100) = 249 percent (DVAC is not limiting). Adding instrument error the open thrust margin becomes [(9747 - 7398)n398)(100) = 31.8 percent and the close thrust margin becomes

[(13474 - 4011)/100](100) = 235 percent. Considering these calculations the MOV will perform its safety function without any concerns during the 5 months 15 days past the five year required periodicity.

l De open thrust margin of 31.8% is adequate to ensure continued MOV performance based on maintenance history.

l Lubrication degradation allowance over 18 months is 5 percent. he 18 month maintenance cycle verifies the lubrication in the actuator and re-applies lubricant to the stem restoring the MOV to its baseline condition. Maintenance history for the  ;

dynamically tested MOV does not indicate any significant degradation in performance between test intervals.

Additionally, an argument can be made that since Unit 2 did not close the breaker until July 1,1994, after being down since February 3,1993, the test interval clock would not start running until after the plant re-started making the periodicity

acceptable.

Conclusions:

1. He Limitorque MOV Actuator Lubrication Procedure, OPMP05-ZE-0312, is performed on 18 month intervals and this keeps the actuators in excellent condition without significant degradation in performance between diagnostic tests that normally occur within the 5 year interval.

2. Rese 2 MOVs have adequate actuator margin tojustify this one time delay of the static testing beyond the five year periodicity. Considering these conclusions engineering recommends extending the diagnostic testing for C2CCMOVMN and C2CSMOV0001C to the 2RE06 outage.

3. These MOVs will have less than five years operating time since the last diagnostic test, therefore, the periodicity meets the five year or less intent without extending the periodicity, l

l i

l

Pagejoff2 OPGP05-ZA-0002 Rev. 5 Page 35 of 41 10CFR50.59 Evaluations Form i 10CFR$0.59 Screening Form (Sample) Page 1 of 3 OUNIT#1 O UFSAR CN O DESIGNCHANGE @ OTHER

@ UNIT #2 TPNS # 2R202TCC0404 and 2N102XCS0001C System two-letter designator or Structure name CC & CS UNIT 1 O UNIT 2 g BOTH O ORIGINATING DOCUMENT NO. CR 97-5740-5 REV. NO. O e

DESCRIPTION OF CHANGE Rescheduling the diagnostic testing periodicity less than 6 rnonths beyond 5 years, for MOVs C2CCMOV0404 & C2CSMOV0001C, to the 2RE06 outage.

PRELIMINARY SCREENING YES NO

1. Does the proposed change represent a change to the Plant Technical Specifications? O E

2. is an Unreviewed Safety Question known to be associated with the subjed change? O E NOTE: If *YES" to either questions 1 or 2 refer to OPGP05-ZN-0004 Does the proposed change represent

3. A change to only correct a typographical, editorial or drafting error? O E

4. A change which is identical to and addressed in its entirety by an existing approved 10CFR$0.59 Screening /USQE of NRC approved licensing submittal?

O E

5. A spare or replacement part/ component change with an equivalent part/cornponent? O 8 (See Section 2.3 for a definition of equivalent)

6. A configuration change within existing design specircations? O E If all answers to the above questions are "NO" perform the final screening and mark N/A in the approval blocks below.

If the answer to,any question (3) through (6) is "YES* a final screening is not necessary.

Sign approval blocks below and discard pages 2 and 3.

Provide a justification and references if any of items (3) through (6) is answered "YES".

N/A The UFSAR requires revision per OPGPOMN@047 O S The Condition Report Action for changing the UFSAR is N/A .

Prepared by: N/A N/A Originator Date Approved by: N/A N/A Qualified Reviewer Date a

1 Pagefoff OPGP05-ZA-0002 Rev. 5 Page 36 of 4I

. 10CFR50.59 Evaluations Form i 10CFR50.59 Screening Form (' Sample) Page 2 of 3 Originating Document No. CR 97-5740-5 Rev.No.O FINAL SCREENING In response to the questions below, if the change involves something that is not descrited in the SAR and is notpart of the licensing basis, the 2{D* is appropriate. However, this decision must be dea documented with adequate technical justircation for each question and the sections reviewed of applicable documents and a attributes reviewed should be indicated. The listing of attributes and documents for 10CFR50.59 screening can be found Addendum 5.

Inter disdpline Coordination Required? O YES @ NO If *yes", obtain appropriate concurrence.

O Risk and Reliab.T:ty Analysis O ThermalHydraulics O Reactor Engr.

O Civil O Mech O Elect O EQ O Other YES NO

1. Does the subject of this review involve a change to the facility as described in the Safety Analysis Report? O E The subject of this review is the scheduling of the diagnostic testing periodicity beyond 5 years, for MOVs C2CCMOV0404 and C2CSMOV0001C, to the 2RE06 outage. The SAR does not address the periodicity of testing for the GL 89-10 MOV test program.

The periodicity of diagnostically testing MOVs is not a change to the facility as described in the Safety Analysis Report. The site maintenance program provides a basis to justify no significant deterioration of the actuators is expected to occur due to the extended test frequency.

1

2. Does the subjed of this review involve a change to the procedures as described in the Safety Analysis Report? Refer to OPAP01 ZA-0103.

0 0 This is not a change to any of the procedures as described in the Safety Analysis Report.

Page/2 ofI OPGP05-ZA-0002 Rev. 5 Page 37 of 41

. 10CFR50.59 Evaluations Form i 10CFR50.59 Screening Form (Sample) Page 3 of 3 Originating Document No. CR 97-5740 Rev.No. 0 YES NO

3. Does the subject of tiis review propose the conduct of test or experiments not described in the Safety G Analysis Report?

The scheduling of the MOV daDnostic testing does not propose the conduct of any tests or experiments.

4. Does the proposed change affect Condihons or bases as9sned h the Safety Analysis Report or safety-related functons of equipment / systems, even though the proposed change does not entaR any physka!

O E change in existing structures, systems, or res as described h the SAR?

1he scheduung of diagnostic testing for V0404 and C2CSMOV0001C sughtly greater than 5 years wIs not effect sie MOVs atsty to perform its safety related function. The reschedtding or diagnostic te* ting wlR not affect cordtions or bases assumed in the Safety Analysis Report of or safety-related functions of equipment / systems, even ticogh the proposed change does not ental any physical change in existing stuctures, systems or procedures as described in the SAR.

If any answeris affirmative, complete the screening form and perfomt an Unreviewod Safety Question Evaluation.

If all answers are negative, no Unreviewed Safety Question Evaluation is required.

The UFSAR requires revision per OPGP05-ZN-0004? O 5 The Condition Report Action for changing the UFSAR is Det.

Prepare by: C. Rowland d 6-44-f/

-, originaw Dam Apptwed by: J. B. Cottam L.

h (7

[ / Quakfled Rev6 ewer / 'I Dans A