Text

Commitment Change Summary Report
	ML042160010
Person / Time
Site:	South Texas
Issue date:	07/27/2004
From:	Head S; South Texas
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	GL-81-007, NEI 99-04, NOC-AE-04001734
	Download: ML042160010 (8)
	v • d • e

Nuclear Operating Company South Teas Pro/cd Electric Genera UO2 Station PO9Bar 289 WadmWh4J Teras 7748)

July 27, 2004 NOC-AE-04001734 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 Attached is the South Texas Project (STP) Commitment Change Summary Report for the period July 14, 2003 through July 15, 2004. 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.

This report includes two commitment changes that were not included in previous reports.

STP Nuclear Operating Company identified two commitments made in response to Generic Letter 81-7, Control of Heavy Loads that were changed in the past without being evaluated in accordance with NEI 99-04. A commitment evaluation of these changes was subsequently performed which concluded that the proposed changes were appropriate and NRC prior approval was not required. This was documented and addressed in the corrective action program. These changes are included in the attached report.

If there are any questions, please contact Robyn Savage at 361-972-7438 or me at 361-972-7136.

Scott M. Head Manager, Licensing rds

Attachment:

Commitment Change Summary Report wplnl/nrc-ap/nisc-2004/04001734 doc STY31753324

NOC-AE-04001734 Page 2 of 2 cc:

(paper copy) (electronic copy)

Bruce S. Mallett A. H. Gutterman, Esquire Regional Administrator, Region IV Morgan, Lewis & Bockius LLP U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 L. D. Blaylock Arlington, Texas 76011-8064 City Public Service U. S. Nuclear Regulatory Commission David H. Jaffe Attention: Document Control Desk U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike R. L. Balcom Rockville, MD 20852 Texas Genco, LP 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 Texas Central Company Jeffrey Cruz Jon C. Wood U. S. Nuclear Regulatory Commission Matthews & Branscomb P. O. Box 289, Mail Code: MN1 16 Wadsworth, TX 77483 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704

NOC-AE-04001734 ATTACHMENT 1 Commitment Change Summary Report

NOC-AE-04001734 ATTACHMENT 1 COMMITMENT CHANGE

SUMMARY

REPORT Page I of 5 Condition Source Document Source Date of Original Commitment Description Revised Commitment Description Justification for Change Report Date Change Number 03-925 NOC-AE-03001493 03/20/03 07/14/03 STPNOC plans to have changes made to the Revised commitment due date to modify The change in the scheduled completion date to modify LER 1-03-001 Shunt Reactor neutral over-current protective the neutral over-current protective relay the neutral over-current protective relay schemes for the relay scheme to trip the Shunt Reactor Circuit schemes for the South Bus Shunt North and South Bus Shunt Reactors was required Switcher instead of tripping the AC bus circuit Reactor. To be completed no later than because the STP Transmission Service Provider (Center breakers. Center Point Energy will implement September 15, 2003. Point Energy) could not change the protective relay this change to the scheme. This corrective scheme for the South Bus in time. The protective action will be completed by July 15, 2003 relaying scheme for the North Bus Shunt Reactor was changed in April 2003. Operation of the South Bus Shunt Reactor circuit switcher was not allowed and remained tagged out-of-service until the relaying scheme was changed. Therefore, the slip in schedule of two months did not adversely impact safety. The implementation of the change was actually completed on August 20, 2003.

02-16723-4 NRC Bulletin 80-10 10/30/86 7/25/03 Include routine sampling and analysis Include routine sampling and analysis Three systems were removed from the list for routine NRC Open Item requirements in OPCPO1-ZA-0014 for the requirements referenced to NRC Bulletin sampling and analysis and are being monitored to meet 498/8630-05 (c) following systems to identify any contaminating 80-10 in the Chemistry schedule to be NRC Bulletin 80-10 requirements. These systems Inspection Report events which could lead to unmonitored, controlled via OPCPOI-ZA-0014 for the (CCW, TGB Sumps, and Condensate Polisher 498/8630 (AE-HL- uncontrolled releases to the environment: following systems to identify any Regeneration Waste) have installed radiation monitors, 91029) Component Cooling Water (CCW), Essential contaminating events which could lead which monitor for system contamination. Procedures are Cooling Water (ECW), Turbine Generator to unmonitored, uncontrolled releases to in place to use and respond to these monitors to identify Building (TUB) Sumps, Demin Water (DW), the environment: ECW, DW, Auxiliary any contamination events and to prevent unmonitored, Auxiliary Boiler, Condensate Polisher Boiler, Fuel Handling Building (FHB) uncontrolled releases to the environment. These Regeneration Waste, and Boron Recycle System HVAC Drains, Sanitary Waste, Potable monitors meet the requirements of the NRC Bulletin 80-(BRS) and Liquid Waste Processing System Water, Plant Nitrogen, Instrument Air, 10 which allows either sampling/analysis or monitoring (LWPS) Steam Condensate. and Service Air. CCW, TGB Sumnps and programs to be used.

Condensate Polisher Regeneration Waste will be monitored using the radiation Additional systems (FHB HVAC Drains, Sanitary monitors associated with those Waste, Potable Water, Plant Nitrogen, Instrument Air, respective systems via the Radiation and Service Air ) have been added to the original Monitoring System. systems committed to for sampling and analysis. This is a result of reevaluations of NRC Bulletin 80-10 applicability performed since the initial commitment.

BRS and LWPS Steam Condensate systems have been removed from the list since they have been isolated and are no longer used.

The requirements for sampling and analysis and the reference to NRC Bulletin 80-10 are contained in the schedule itself and not in the referenced procedure. The referenced procedure controls changes to the schedule.

This has been clarified.

98-6902 NOC-AE-000176 6/01/98 01/26/04 A review of existing periodic and preventive A review of existing periodic and The change in the preventive maintenance items for the 98-16721 LER 1-98-004 11/23/98 maintenance performed on these motors was preventive maintenance performed on booster fan motors is consistent with the EPRI NP 7502, 03-16156 NOC-AE-000355 conducted. Several enhancements were these motors was conducted. Several Electric Motor Predictive and Preventive Maintenance LER 1-98-010 identified for development. These include: enhancements were identified for Guide. This guide recommends for Safety-Related

Revising the lubetinspection activity, development These include: motors, under 200 HP and less than 600 volts that

NOC-AE-04001734 ATTACHMENT I COMMITMENT CHANGE

SUMMARY

REPORT Page 2 of 5 Condition Source Document Source Date of Original Commnitment Description Revised Commitment Description Justification for Change Report Date Change Number

Developing new yearly PM activities for

Revising the lube/inspection activity. insulation resistance checks be performed at a 24 - 36 insulation resistance testing the booster fan

Developing PM activities for month frequency. No DC step voltage tests are motors. meggering the booster fan motors at a recommended for this size motor and could actually be

Developing new three year PM activities to frequency consistent with current EPRI detrimental to the motor. The PM recommendations are perform DC step voltage testing. standards. also consistent with the STP motor monitoring procedure for this size motor.

It has been determined that the insulation design and manufacturing quality of the motors was inadequate and had resulted in several motor grounds. All the booster fan motors were upgraded using STP specifications and replaced. This has improved the booster fan motor reliability. No problems have been identified during the performance of the PMs on the motors since replacement.

Additional Information:

Technical Specification (TS) 3.7.8 has been revised and allows for a 7 day LCO for the loss of one FHB exhaust ventilation train and has provisions under TS 3.7.8.d for a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months LCO when more than one FHB exhaust ventilation train is inoperable. This has eliminated the need to enter TS 3.0.3 to perform maintenance on the booster fans which was the basis for LER 98-004 and LER 98-010. The time allowed under the TS LCO's is adequate to effect repairs in the event of a booster fan failure. Procedures are in place to isolate the booster fans for maintenance.

Modifications to the FHB Exhaust Air system have been performed in both Units, which allow installation of maintenance barriers for FHB exhaust booster fan removal.

03-5296 Generic Letter 81-07 10/19/84 08/23/99 STPs response to Generic Letter 81-07 (ST- Allow use ofjib cranes for certain heavy At the time that the original control of heavy loads ST-HL-AE-1 129 HL-AE-I 129) included Table I which loads within the the reactor containment program submittal was prepared many aspects of actual ST-HL-AE-718 contained a list of overhead handling systems building. refueling outages were not fully understood. This was capable of carrying heavy loads over safe recognized in the cover letter (ST-HL-AE-1 129) which shutdown or decay heat removal equipment. In addition to the polar crane, two jib stated: As the STP design is not yet complete, there may Polar cranes were the only cranes included in cranes are installed in each reactor be a need to add or modify load handling systems. In the Table I for the reactor containment building. containment building (RCB). These event this becomes necessary, the new load handling cranes are allowed to handle certain system and modifications will consider the guidance of heavy loads with restrictions as given in Generic Letter 81-07.

procedure OPGP03-ZA-0069, Control of Heavy Loads. It was necessary to change some aspects of the original response in order to allow moe flexibility for outage activities and to enhance personnel safety since loads

_ can be moved during times of low wworker traffic inside

NOC-AE-04001734 ATTACHMENT I COMMITMENT CHANGE

SUMMARY

REPORT Page 3 of 5 Condition Source Document Source Date of Original Commitment Description Revised Commitment Description Justification for Change Report Date Change Number the containment.

The evaluation of the changes used the Guidance of Generic Letter 81-07 which concluded that the change is appropriate. The NRC recognized that actions such as this would be necessary in Generic Letter 85-11 that closed out Phase 11of NUREG 0612, Control of Heavy Loads at Nuclear Power Plants.

The STP heavy loads evaluation was sent to the NRC by letter ST-HL-AE-1 129 dated October 19, 1984, "Submittal of Revised Response to Generic Letter 81-07, Control of Heavy Loads." The STP procedure that promulgates the heavy loads program is procedure OPGP03-ZA-0069, Control of Heavy Loads. The licensing submittal and the procedure are consistent with the guidelines given in NUREG-0612. The submittal was accepted by the NRC in SER Section 9.1.5 and Appendix F.

The STP program for Control of Heavy Loads goals are to greatly reduce the chances for a load drop by using good design and maintenance and to show that a load drop could be sustained (no fuel damage or loss of safe shutdown capability) even if there was an extremely unlikely heavy load drop.

The use of the jib cranes to move heavy loads inside containment was previously evaluated in 1999 using IOCFR50.59 (USQE 99-1371-3) using the guidance of Generic Letter 81-07.

03-5296 Generic Letter 81-07 10/19/84 01/15/01 STPs response to Generic Letter 81-07, (ST- Allow use of polar crane auxiliary hoist. It was necessary to change some aspects of the original ST-HL-AE-l 129 HL-AE-1 129) page 18 of the attachment re: response in order to allow use of the polar crane ST-HL-AE-718 'Submittal of Revised Response to Generic "Three trains of RHR are provided, only auxiliary hoist to carry certain loads that were previously Letter 81-07, Control of Heavy Loads' included one of which is required for decay heat restricted to the main hoist. This allows more flexibility the following: removal. If a load weighing 15,000 lbs. for outage activities and enhances personnel safety since or more must be moved over an RHR loads can be moved during times of low worker traffic "Three trains of RHR are provided, only one of train when both redundant trains are not inside the containment. The Auxiliary Hoist is allowed which is required for decay heat removal. Ifa available (i.e. other train(s) are to carny loads less than 15,000 lbs. since it will still load must be moved over an RHR train when inoperable, or a load drop could impact maintain a safety factor of greater than 10/1. This both redundant trains are not available (i.e. all operable trains), the polar crane main change was previously evaluated in December 2000 for other train(s) are inoperable, or a load drop hoist will be used in conjunction with Revision 15 of the OPGP03-ZA-0069 using could impact all operable trains), the polar adequate interfacing lift points to ensure IOCFR50.59 (USQE 00-3225-4). Based on the crane main hoist will be used in conjunction that greater than a 10/1 safety factor is evaluation of the change using the guidance of Generic with adequate interfacing lift points to ensure provided. For loads weighing less than Letter 81-07, it was concluded that the proposed change that greater than a 10/1 safety factor is 15,000 lbs. which must be moved over was appropriate.

provided."_an RHR train when both redundant

NOC-AE-04001734 ATTACHMENT I COMMITMENT CHANGE

SUMMARY

REPORT Page 4 of 5 Condition Source Document Source Date of Original Commitment Description Revised Commitment Description Justification for Change Report Date Change Number trains are not available, the polar crane auxiliary hoist may be used in lieu of the main hoist in conjunction with adequate interfacing lift points to ensure that greater than a 10/1 safety factor is provided." _

03-5296 Generic Letter 81-07 10/19/84 02/12/04 STP's response to Generic Letter 81-07 (ST- Allow the RCP motor engineered lift to The Reactor Coolant Pump (RCP) motor lift is defined ST-HL-AE-1 129 HL-AE-1 129) page 18 of the attachment re: move over RHR equipment in the Control of Heavy Loads procedure (OPGP03-ZA-ST-HL-AE-718 "Submittal of Revised Response to Generic 0069) as an Engineered Lift that utilizes special designed Letter 81-07, Control of Heavy Loads' included Three trains of RHR ae provided, only and dedicated components among other attributes such the following: one of which is required for decay heat as special inspections and tests, personnel dedicated for removal. If a load must be moved over this activity, use of a safe load path, special "Three trains of RHR are provided, only one of an RHR train when both redundant communication during the lift, and increased attention which is required for decay heat removal. If a trains are not available (i.e. other train(s) and oversight. The change is that some components of load must be moved over an RHR train when are inoperable, or a load drop could the lift do not have a 10/1 safety factor. The electric both redundant trains are not available (i.e. impact all operable trains), the polar hoist that goes from the motor lift rig to the polar crane other train(s) are inoperable, or a load drop crane main hoist will be used in hook was designed by Ingersoll-Rand to industry could impact all operable trains), the polar conjunction with adequate interfacing standard ANSI B30.9 and has a 5/1 safety factor. The crane main hoist will be used in conjunction lift points to ensure that greater than a special lift rig was designed by Westinghouse to ANSI with adequate interfacing lift points to ensure 10/1 safety factor is provided. The RCP N14.6 and has a 5/1 safety factor.

that greater than a 10/1 safety factor is Motor Engineered Lift is an exception to provided." this 10/I safety factor requirement. The guidelines of NUREG 0612 call for decreasing the chances of a load drop by using good design, maintenance instructions, testing, and inspection of the lifting components. The standard connmercial component has a 5/1 safety factor. To achieve added assurance for routine rigging activities, redundant components (each with a safety factor of 5/1) may be used or a component with twice the capacity (safety factor of 10/1) may be used. This is for routine rigging activities. In contrast, the RCP Motor Engineered Lift is a controlled, special rigging activity. This lift is not a routine rigging activity but rather is an Engineered Lift that has special attributes as mentioned above and as given in procedure OPGP03-ZA-0069. This engineered lift utilizes dedicated components that are inspected and tested prior to lift. Incorporating these attributes into the lift decreases the chances for a load drop.

The special lift rig devices described in the submittal to the NRC are designed to ANSI N14.6 and have safety factors of 5/1. This is also true for the RCP Motor Lift Rig. This is as given in the guidelines of NUREG 0612.

The RCP Motor lift rig is a dedicated piece of rigging equipment that is utilized for the particular lift. It is tested and inspected prior to use. Similarly the electric

_ I_ _ __ _ I._ I I _ _ _ __ _ _ _ I__ I hoist made by Ingersoll-Rand per ANSI B30.16 is also a

NOC-AE-04001734 ATTACHMENT I COMMITMENT CHANGE

SUMMARY

REPORT Page 5 of 5 Condition Source Documource urce Date of Original Commitment Description Revised Commitment Description Justification for Change Report Date Change Number l dedicated piece of rigging equipment that is utilized for this particular lift. The electric hoist is load tested and inspected prior to use in moving the RCP Motor.

The control of heavy loads program philosophy also includes evaluation for the possible effects of a load drop even if it is made highly unlikely. The RCP Motor Engineered Lift includes the requirement for an available flowpath from the emergency sump and LHSI Pump to the RCS main loop piping. This method would be used to recirculate water back into the RCS piping if an unlikely load drop caused a pipe leak. The safe load path for RCP Motor movement avoids travel over or adjacent to spent fuel, calls for travel over concrete floors rather than over grating or metal decking, and minimizes travel over safe shutdown equipment.

The RCP Motor Engineered Lift contributes to managing the risk from performing the maintenance activity of replacing a RCP Motor. This would be evaluated along with other outage maintenance activities as part of a comprehensive shutdown risk assessment per procedure OPGP03-ZA-0101. The risk evaluation may call for other measures to be in place when this activity occurs.

For example, another RHR Tramin may need to be functional in addition to the one operable RHR Train.

The Risk Management group determined that the estimated conditional core damage probability was 2E-07 for the RCP Motor lift in April 2003 during outage IREI . This value indicates a very low safety significance.

The RCP Motor Engineered Lift meets the two aspects of the control of heavy loads guidelines given in NUREG 0612 of greatly reducing the chances for a load drop and of being able to sustain a highly unlikely load drop.

03-5296 Generic Letter 81-07 10/19/84 02/12/04 STP response to Generic Letter 81-07 (ST-HL- Allow use of the FHB Overhead Crane The original submittal stated that no heavy loads had ST-HL-AE-I 129 AE-1 129) states on page 4 that "...The Fuel Auxiliary Hoist 2-ton auxiliary hoist to been identified to be moved by the FHB Overhead Crane ST-HL-AE-71 8 Handling Building (FHB) overhead crane's 15- move heavy loads in the FHB truck bay. Auxiliary Hoist. Subsequently, heavy loads have been ton main hoist has been designed to meet the identified within the FHB truck bay for which the intent of Regulatory Guide 1.104, Rev. 0, i.e., "The only heavy loads that have been Auxiliary Hoist would be used. The procedure restricts single-failure proof cranes. No heavy loads identified for which the Auxiliary Hoist heavy load use of this hoist to within the truck bay.

have been identified for which the Auxiliary would be used are located within the Crane operators are trained on the use of the procedure Hoist would be used; therefore, this hoist is not FHB truck bay. No safe shutdown and the safe load paths. Since no safe shutdown addressed in this report." equipment or spent fuel is located in the equipment and no spent fuel are located in the FHB FHB truck bay. Therefore, this hoist is truck bay, the procedure change is acceptable.

not addressed in this report."

Text

Nuclear Operating Company South Teas Pro/cd Electric Genera UO2 Station PO9Bar 289 WadmWh4J Teras 7748)

July 27, 2004 NOC-AE-04001734 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 Attached is the South Texas Project (STP) Commitment Change Summary Report for the period July 14, 2003 through July 15, 2004. 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.

This report includes two commitment changes that were not included in previous reports.

STP Nuclear Operating Company identified two commitments made in response to Generic Letter 81-7, Control of Heavy Loads that were changed in the past without being evaluated in accordance with NEI 99-04. A commitment evaluation of these changes was subsequently performed which concluded that the proposed changes were appropriate and NRC prior approval was not required. This was documented and addressed in the corrective action program. These changes are included in the attached report.

If there are any questions, please contact Robyn Savage at 361-972-7438 or me at 361-972-7136.

Scott M. Head Manager, Licensing rds

Attachment:

Commitment Change Summary Report wplnl/nrc-ap/nisc-2004/04001734 doc STY31753324

NOC-AE-04001734 Page 2 of 2 cc:

(paper copy) (electronic copy)

Bruce S. Mallett A. H. Gutterman, Esquire Regional Administrator, Region IV Morgan, Lewis & Bockius LLP U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 L. D. Blaylock Arlington, Texas 76011-8064 City Public Service U. S. Nuclear Regulatory Commission David H. Jaffe Attention: Document Control Desk U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike R. L. Balcom Rockville, MD 20852 Texas Genco, LP 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 Texas Central Company Jeffrey Cruz Jon C. Wood U. S. Nuclear Regulatory Commission Matthews & Branscomb P. O. Box 289, Mail Code: MN1 16 Wadsworth, TX 77483 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704

NOC-AE-04001734 ATTACHMENT 1 Commitment Change Summary Report

NOC-AE-04001734 ATTACHMENT 1 COMMITMENT CHANGE

SUMMARY

REPORT Page I of 5 Condition Source Document Source Date of Original Commitment Description Revised Commitment Description Justification for Change Report Date Change Number 03-925 NOC-AE-03001493 03/20/03 07/14/03 STPNOC plans to have changes made to the Revised commitment due date to modify The change in the scheduled completion date to modify LER 1-03-001 Shunt Reactor neutral over-current protective the neutral over-current protective relay the neutral over-current protective relay schemes for the relay scheme to trip the Shunt Reactor Circuit schemes for the South Bus Shunt North and South Bus Shunt Reactors was required Switcher instead of tripping the AC bus circuit Reactor. To be completed no later than because the STP Transmission Service Provider (Center breakers. Center Point Energy will implement September 15, 2003. Point Energy) could not change the protective relay this change to the scheme. This corrective scheme for the South Bus in time. The protective action will be completed by July 15, 2003 relaying scheme for the North Bus Shunt Reactor was changed in April 2003. Operation of the South Bus Shunt Reactor circuit switcher was not allowed and remained tagged out-of-service until the relaying scheme was changed. Therefore, the slip in schedule of two months did not adversely impact safety. The implementation of the change was actually completed on August 20, 2003.

02-16723-4 NRC Bulletin 80-10 10/30/86 7/25/03 Include routine sampling and analysis Include routine sampling and analysis Three systems were removed from the list for routine NRC Open Item requirements in OPCPO1-ZA-0014 for the requirements referenced to NRC Bulletin sampling and analysis and are being monitored to meet 498/8630-05 (c) following systems to identify any contaminating 80-10 in the Chemistry schedule to be NRC Bulletin 80-10 requirements. These systems Inspection Report events which could lead to unmonitored, controlled via OPCPOI-ZA-0014 for the (CCW, TGB Sumps, and Condensate Polisher 498/8630 (AE-HL- uncontrolled releases to the environment: following systems to identify any Regeneration Waste) have installed radiation monitors, 91029) Component Cooling Water (CCW), Essential contaminating events which could lead which monitor for system contamination. Procedures are Cooling Water (ECW), Turbine Generator to unmonitored, uncontrolled releases to in place to use and respond to these monitors to identify Building (TUB) Sumps, Demin Water (DW), the environment: ECW, DW, Auxiliary any contamination events and to prevent unmonitored, Auxiliary Boiler, Condensate Polisher Boiler, Fuel Handling Building (FHB) uncontrolled releases to the environment. These Regeneration Waste, and Boron Recycle System HVAC Drains, Sanitary Waste, Potable monitors meet the requirements of the NRC Bulletin 80-(BRS) and Liquid Waste Processing System Water, Plant Nitrogen, Instrument Air, 10 which allows either sampling/analysis or monitoring (LWPS) Steam Condensate. and Service Air. CCW, TGB Sumnps and programs to be used.

Condensate Polisher Regeneration Waste will be monitored using the radiation Additional systems (FHB HVAC Drains, Sanitary monitors associated with those Waste, Potable Water, Plant Nitrogen, Instrument Air, respective systems via the Radiation and Service Air ) have been added to the original Monitoring System. systems committed to for sampling and analysis. This is a result of reevaluations of NRC Bulletin 80-10 applicability performed since the initial commitment.

BRS and LWPS Steam Condensate systems have been removed from the list since they have been isolated and are no longer used.

The requirements for sampling and analysis and the reference to NRC Bulletin 80-10 are contained in the schedule itself and not in the referenced procedure. The referenced procedure controls changes to the schedule.

This has been clarified.

98-6902 NOC-AE-000176 6/01/98 01/26/04 A review of existing periodic and preventive A review of existing periodic and The change in the preventive maintenance items for the 98-16721 LER 1-98-004 11/23/98 maintenance performed on these motors was preventive maintenance performed on booster fan motors is consistent with the EPRI NP 7502, 03-16156 NOC-AE-000355 conducted. Several enhancements were these motors was conducted. Several Electric Motor Predictive and Preventive Maintenance LER 1-98-010 identified for development. These include: enhancements were identified for Guide. This guide recommends for Safety-Related

Revising the lubetinspection activity, development These include: motors, under 200 HP and less than 600 volts that

NOC-AE-04001734 ATTACHMENT I COMMITMENT CHANGE

SUMMARY

REPORT Page 2 of 5 Condition Source Document Source Date of Original Commnitment Description Revised Commitment Description Justification for Change Report Date Change Number

Developing new yearly PM activities for

Revising the lube/inspection activity. insulation resistance checks be performed at a 24 - 36 insulation resistance testing the booster fan

Developing PM activities for month frequency. No DC step voltage tests are motors. meggering the booster fan motors at a recommended for this size motor and could actually be

Developing new three year PM activities to frequency consistent with current EPRI detrimental to the motor. The PM recommendations are perform DC step voltage testing. standards. also consistent with the STP motor monitoring procedure for this size motor.