NOC-AE-06002049, Commitment Change Summary Report

Commitment Change Summary Report

ML062400292
Person / Time
Site:	South Texas
Issue date:	08/21/2006
From:	Head S South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-06002049, STI 32034837
Download: ML062400292 (12)

Text

Nuclear Operating Company 40 IV r-South Tras Pro/ct Ekdtnc GncUratlnStabt'on P.. Box 282 Wadsworth. T&ws 77483 ,VVV August 21., 2006 NOC-AE-06002049 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 South Texas Proiect Commitment Change Summary Report Attached is the South Texas Project (STP) Commitment Change Summary Report for the period July 14, 2005 through July 31, 2006. 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.

There are no new commitments in this letter.

If there are any questions, please contact Marilyn Kistler at 361-972-8385 or me at 361-972-7136.

Scott M. Head Manager, Licensing mkk

Attachment:

Commitment Change Summary Report 74001 STi32034837

NOC-AE-06002049 Page 2 of 2 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission Morgan, Lewis & Bockius LLP 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Mohan C. Thadani U. S. Nuclear Regulatory Commission Senior Resident Inspector Steve Winn U. S. Nuclear Regulatory Commission Christine Jacobs P. 0. Box 289, Mail Code: MN1 16 Eddy Daniels Wadsworth, TX 77483 NRG South Texas LP C. M. Canady J. J. Nesrsta City of Austin R. K. Temple Electric Utility Department E. Alarcon 721 Barton Springs Road City Public Service Austin, TX 78704 Richard A. Ratliff Jon C. Wood Bureau of Radiation Control Cox Smith Matthews Texas Department of State Health Services 1100 West 49th Street C. Kirksey Austin, TX 78756-3189 City of Austin

ATTACHMENT Commitment Change Summary Report

Attachment NOC-AE-06002049 Page 1 of 9 Condition Source Document Source Date of Original Commitment Description Revised Commitment Description Justification for Change Report Date Change Number 04-3365-8 NOC-AE-04001758 02/16/01 11/16/05 NOC-AE-04001758, 08/05/04 - Response Alternative: There are three commitment change evaluations for (Response to 03/07/06 To Request For Information On NRC Revise the control room dose this action. Commitment evaluation one extends Generic Letter 06/22/06 Generic Letter 2003 Control Room accident analyses to reflect the the original due date of December 31, 2005 to April 2003-01) Habitability results of the control room inleakage 1, 2006, evaluation two extends due date April 1, testing. Due Date December 15, 2006 to June 30, 2006, and extension three extends Revise the control room dose accident 2006. the due date June 30, 2006 to December 15, 2006.

analyses to reflect the results of the control room inleakage testing. Due Date Evaluation 1 -

December 31, 2005 During the course of performing the Loss Of Coolant Accident analysis using the Altemate Source Term (AST), itwas determined that STP also needed to confirm the post accident sump pH. An integral part of this analysis was to determine the amount of electrical cable insulation in the containment building that contains chlorides. Also, additional iodine re-evolution analyses were required as a result of the sump pH analysis.

These unforeseen extra analyses took several months that were not planned for when the commitment was made. Also, the multiple core redesigns during the 2RE1 1 outage took away Reactor Engineering resources necessary to support the required analyses.

Industry experience on the success of AST submittals has been varied. Several such submittals have been rejected by the NRC. Based on the need to be very thorough in this submittal, additional time was needed to ensure a successful submittal.

Evaluation 2 -

The submittal must provide assurance that Chapter 15 analyses not performed with AST will meet the new AST dose limits when they are converted to the AST.

This was planned to be done with simple scaling of radioisotope releases and atmospheric dispersion factors. This technique was successful with the Main Steam Line Break and the Steam Generator Tube Rupture accidents. However, since the Locked Reactor Coolant Pump Rotor and the Control Rod Ejection accidents also have postulated fuel failures, the ratioing technique was not successful. Reactor Engineering is performing explicit design calculations for these accidents to serve as bases for statements made in the submittal.

Attachment NOC-AE-06002049 Page 2 of 9 Condition Source Document Source Date of Original Commitment Description Revised Commitment Description Justification for Change Report Date Change Number Additional time is needed to ensure a thorough submittal.

Evaluation 3 -

STP personnel attended an NRC workshop on their (NRC) experience with AST submittals and the contents of Regulatory Guide 1.183 on June 22, 2006.

Also, a pre-submittal meeting with the NRC staff was scheduled for July 11, 2006.

Four additional analyses are necessary to support the AST submittal. A draft submittal is expected on July

24. After site review, the submittal is planned to be presented to the September 2006 Plant Operations Review Committee meeting. Additional time was needed to ensure a thorough submittal.

04-12498-11 NOC-AE-06001968 01/30/06 7/26/06 NOC-AE-06001968 -Supplement 2 to the By letter from NRC to NEI dated The original commitment to provide a status report

- Supplement 2 to Response to Generic Letter 2004-02 3/3/2006 and in a NRC letter to PWR was a voluntary commitment by STPNOC for the the Response to NOC-AE-05001922 - Supplement 1 to the licensees dated March 28, 2006, the purpose of keeping the NRC informed of STP's Generic Letter Response to Generic Letter 2004-02 following agreement was made progress with regard to resolution of the sump debris 2004-02 regarding responses to GL 2004-02 issues in GL 2004-02. It is not required for compliance STPNOC will provide a supplemental and associated requests for additional or to adequately respond to the GL.

NOC-AE-0S001922 08/31/05 response to Generic Letter 2004-02 upon information:

- Supplement 1 to completion of pending analyses and testing. "...for units completing their The agreement made between NEI and NRC the Response to outage to incorporate accommodates the known schedule issues and Generic Letter strainer modification in 2006 uncertainty with regard to resolution of sump design 2004-02 or earlier, information issues and establishes a mutually acceptable needed to fully address GL approach for licensees to provide the NRC with the 2004-02 will be provided to plant-specific sump design information. In addition, the NRC by December STP's analyses depend on the completion of generic 31,2006. For units installing industry work which is not complete.

strainers after 2006, information needed to fully The change was also discussed with Mohan Thadani, address GL 2004-02 will be STP's NRC Project Manager, on July 26, 2006 provided to the NRC within 90 days of outage completion but not later than December 31, 2007. STP has not completed its analysis and the You may choose to use this agreement above provides a reasonable alternative to alternative approach docketing a status report that will be of little or no consistent with your strainer value. Consequently, STP will provide the required modification schedule, or information within 90 days of completing the Unit 2 you may choose to submit a Spring 2007 outage (i.e., about July 23, 2007).

Attachment NOC-AE-06002049 Page 3 of 9 Condition Source Document Source Date of Original Commitment Description Revised Commitment Description Justification for Change Report Date Change Number response to the RAI letters originally requested..."

05-9845-1 ST-HL-AE-1060 - 2/21/84 12/20/05 ST-HL-AE-1 060 - Response to Notice of User Testing and additional material The original commitments were made during Response to Violation 83-22-02 marking requirements are not required construction in response to industry and site Notice of Violation HL&P initiated a program to review previous for materials purchased through a deficiencies.

83-22-02 and current material control practices and vendor that is currently on the to develop additional controls that can be Approved Vendor List (or a new The commitments were considered to be necessary ST-HL-AE-1110 - 7/30/84 implemented effectively. This program drew vendor added at a later date) provided at the time in order to enhance a program that was in Material Control upon work that had already been the following conditions are met: place and to put barriers in place during the Program and User accomplished by a materials control task construction phase when there were a multitude of Test Program force formed to evaluate some of the suppliers and there was a substantial amount of

1) Purchase Order requires the vendor Clarifications recommendations made by the INPO audit material being purchased and received to support to furnish documentation (e.g., the construction effort. The commitments were of STP construction activities in the fall of 1/29/88 Certified Material Test Report) further enhanced in response to an NRC ST-HL-AE-2480 - 1983. This task force completed work and attesting to the material meeting the Compliance Bulletin (87-002) that specifically Response to NRC recommended a number of improvements requirements of the applicable addressed a concern related to fasteners. Part of the Compliance in mid-January 1984. The following Bulletin 87-002: important improvements to STP material material specification; response by STPEGS committed the station to Fastener Testing to control will be undertaken. 2) Quality personnel review the additional redundant material testing to further Determine supplied documentation and verify that substantiate that the material being supplied did in Conformance With Item 1 the documentation indicates that the fact meet the material specifications required by our Applicable Material material does in fact meet the material Purchase Orders and that the vendors supplied Specifications

• Reinstitute the transfer of heat code specification requirements; documentation as to their compliance.

identifies on non-ASME safety-related 3) Material is marked by the vendor as high strength miscellaneous structural required by the material specifications The Operations Quality Assurance Plan (OQAP), in shapes and materials when this material (e.g., ASTM A325). part, provides the requirements for evaluating and is cut during site fabrication. (For ASME placing a vendor on the Approved Vendor List (AVL) material this is already being done). and the requirements for that vendor to remain on the AVL. Measures for evaluating and selecting Item 2 procurement sources are specified in procedures and include one or more of the following: 1)

• Undertake user testing on non-ASME experience of users of identical or similar products of safety-related A36 bulk shapes and plate. the prospective supplier, other utility or approved Samples of each heat received from each contractor audits/evaluations, audits/evaluations by vendor will be tested. This material will cooperative utility groups, American Society of then be hard marked (stamped) to Mechanical Engineers Certificates of Authorization, indicate that it is A36. The hard marks will STPEGS records accumulated in previous be transferred during site fabrication procurement actions, and STPEGS product activities. operating experience; 2) evaluation of the suppliers current quality records supported by documented Item 3 qualitative and quantitative information that can be objectively evaluated; 3) and source evaluation of

• Undertake user testing for hardness and the supplier's technical and quality capability as tensile strength on samples, by shipment, determined by a direct evaluation of facilities and or bulk safety-related threaded fasteners. personnel and aualitv poroqram implementation.

Attachment NOC-AE-06002049 Page 4 of 9 Condition Source Document Source Date of Original Commitment Description Revised Commitment Description Justification for Change Report Date Change Number Da I I These fasteners will be stamped to Procurement source evaluations involve a review of indicate grade (type) and class consistent technical and quality considerations to an extent with ASME III size restrictions. considered appropriate. Technical considerations include the design or manufacturing capability and Item 4 technical ability of suppliers to produce or provide the design, service, item or component. A

• Undertake user testing for hardness and documented quality assurance evaluation of a tensile strength on samples of safety- vendors quality program is performed to assure it related anchor bolts by shipment. Anchor meets the appropriate requirements of 10CFR50 bolts will be stamped to indicate material Appendix B, or where applicable, other type. Site fabrication of all anchor bolts nationally recognized codes and standards. Vendors (safety-related and non safety-related) may be placed on the AVL after passing this has been discontinued. evaluation. Each vendor on the AVL is periodically evaluated and is removed if the evaluation is ST-HIL-AE-1 110 - Material Control Program unacceptable. The OQAP also provides for the and User Test Program Clarifications acceptance of procured material and services by review of written certifications and receipt inspection Item 2 from ST-HL-AE-1060 activities. These OQAP requirements are based on STPEGS commitments to Regulatory Guide 1.33, Clarification/Change - In the event that A36 Quality Assurance Program Requirements or A500 Grade B tube steel is not uniquely (Operations), American National Standard N 18.7-identifiable to an individual heat number, 1976/ANS-3.2, Regulatory Guide 1.38, Quality then testing will be performed on a periodic Assurance Requirements for Packaging, Shipping, basis until the lot is depleted. The Receiving, Storage, and Handling of Items for frequency of testing will be established on a Water-Cooled Nuclear Power Plants, and American case basis. National Standards Institute N45.2.2-1972. There are no regulatory requirements to repeat vendor Item 3 from ST-HL-AE-1060 completed testing of material at the time of receipt. It should also be noted that the additional material Clarification/Change - The sentence in our testing is destructive testing and STPNOC therefore letter which stated in part that threaded has to actually procure more material than Is actually fasteners "will be stamped to indicated needed as the tested portion of the material is grade (type) and class" was meant to destroyed during the testing. These specification describe an existing condition and not a requirements should be deleted and discontinued.

new commitment. Currently we purchase fasteners which are marked per ASTM STPNOC also has requirements in specifications requirements. Additional marking (e.g., 3A010SS0030) which require material marking requirements imposed by our material to be applied to material. These additional 'marking' control program to preclude commingling of requirements (i.e., Cloverleaf stamp applied to safety and nonsafety class material include A36 material and Arrowhead stamp applied to A500 both hard marking and color coded zinc tube steel) were part of an 'enhancement' to our electroplating processes. program to provide additional traceability measures.

The marking requirements are not required by the In addition, for fasteners in inventory prior industry material specifications. The OQAP requires to May 21, 1984, the test sample will be that material traceability is maintained either 1 ) on defined by warehouse bin rather that by the item or 2) on records traceable to the item. Once shipment as indicated in our letter. This is material has progressed through the receiving

Attachment NOC-AE-06002049 Page 5 of 9 Condition Source Document Source Date of Original Commitment Description Revised Commitment Description Justification for Change Report Date Change Number I _ I due to the fact that shipment identity is not process and located in a class bin, we have at least maintained during storage. For future one of the OQAP methods to maintain traceability receipts, testing will be by shipment. and in many cases, we have both. The additional

'marking' of certain materials does not provide Item 4 from ST-HL-AE-1060 additional traceability that justifies the manhours allotted to this activity. Material with only the Clarification/Chanqe - We have modified Cloverleaf or the Arrowhead would not be sufficiently our testing program to eliminate laboratory traceable for use. The specification requirements for hardness testing of A36 and A193 anchor this additional marking should be deleted and bolts. ASTM does not define any hardness discontinued.

limits for A36 and A193 material, and therefore hardness test results would not be meaningful. Tensile tests are required for this material under our program and are sufficient per ASTM to verify material type.

In the event that long lead time anchor bolts do not exist in sufficient quantity to permit destructive testing per our program, we will undertake an alternate non-destructive testing program in the field to verify material type. This program will be fully documented by design specification and jobsite procedure. The program will employ the Equotip hardness tester correlated to known tensile strengths by material type and the Texas Nuclear Alloy Analyzer which is able to distinguish material types through spectographic analysis.

ST-HL-AE-2480 Response to NRC Compliance Bulletin 87-002: Fastener Testing to Determine Conformance With Applicable Material Specifications Response to Bulletin 87-02 describes details of STP's Users Test Program for bolting materials. These commitments revised and clarified the original commitment (items 3,4) in ST-HL-AE-1060.

Bulletin Action 1: Describe a) the characteristics currently examined during receipt inspection of fasteners (i.e., head markings for grade and manufacturer symbols, review of certified material test

Attachment NOC-AE-06002049 Page 6 of 9 Condition Source Document Source Date of Original Commitment Description Revised Commitment Description Justification for Change Report Date Change Number I I I I report or certificate of conformance), and b) internal controls utilized during storage and issuance from stock to assure the appropriate use of fasteners.

Response to Bulletin Action 1: The response to Action 1 for bolting materials procured by Houston Lighting & Power Company (HL&P) and Bechtel Energy Corporation (BEC) for South Texas Project Electric Generating Station (STPEGS) is described in Attachment 2.

Attachment 2 - ST-HL-AE-2480 Users Test Program In May 1984, the STPEGS implemented the Users Test Program, which requires testing samples of all safety related, 1/2 inch or greater in diameter, non-ASME bulk threaded fasteners, anchor bolts, and all-thread rod.

The Users Test Program for threaded material is specifically prescribed for the bolts, nuts, studs, and threaded rods furnished by the construction manager (BEC) to the constructor (Ebasco Constructors, Inc.) and/or contractors for use In field-assembled connections. The threaded fasteners for shop-assembled connections fumished (tightened or loose) by equipment manufacturers or component fabricators are not subject to the STP Users Test Program. The control of that threaded fastener material is covered under the supplier's Quality Assurance Program (QAP). The STP contractor for HVAC ductwork typically does not furnish the threaded fasteners for field-assembled connections. The only threaded fasteners furnished by this contractor are restricted to closure panels and other limited applications, and all those fasteners are procured under the contractor's QAP.

__________ +/- L I __________________________________________

Attachment NOC-AE-06002049 Page 7 of 9 Condition Source Document Source Date of Original Commitment Description Revised Commitment Description Justification for Change Report Date Change Number I I I Items procured to the material specifications listed below, require "User Testing" prior to being issued for field installation:

A. Threaded fasteners conforming to:

ASTM A307, GR A ASTM A325, Type I ASTM A490, Type I ASTM A449 ASTM A1 94 ASTM A563 ASTM A193 The "Users Test" program requires tests of tensile properties, hardness (if specified),

and chemical analysis per the applicable ASTM standard for these threaded fasteners.

B. Anchor bolts conforming to:

ASTM A36 ASTM A193 Tests of tensile properties, hardness (if specified) and chemical properties are required tests in the "User Test" program for anchor bolts.

C. Threaded rod conforming to:

ASTM A36 ASTM A108 ASTM A193 Tests to determine the tensile and chemical properties are required in the "Users Test" program.

ASTM A108 and galvanized all-thread rod which are purchased as catalog items are tested in the "Users Test" program to ensure adequate tensile strength and chemical properties.

Attachment NOC-AE-06002049 Page 8 of 9 Condition Source Document Source Date of Original Commitment Description Revised Commitment Description Justification for Change Report Date Change Number I I The sample size of threaded fasteners and anchor bolts tested is defined in the

.shipping iot method" of ASTM A325.

NOTE: For the initial testing of materiais in the warehouse on May 21, 1984, at least one fastener from each location was tested, or the 'shipping lot method* of ASTM A325 was utilized, whichever was greater.

The sample size of all-thread red tested is as follows:

1. Threaded rod supplied by prequalified manufacturers with traceable heat numbers: One test per year or one test per five (5) heat numbers purchased for each manufacturer whichever is greater.

2. Red furnished by companies other than the above, with traceable heat numbers:

One test per heat number.

3. Rod not traceable to manufacturer heat numbers: One test for first 250 linear feet and one test for each subsequent 1000 linear feet.

D. Fastener materials requiring User Testing are segregated and Hold Tagged.

The User Test Program coordinator assigns test numbers, maintains logs and records for accountability, selects test samples and tracks all tests until Quality Control accepts the test results. Fasteners that do not conform to test requirements are reported In accordance with approved site procedures.

Threaded fasteners are subject to tension testing of full size specimens furnished with the corresponding nuts in accordance with ASTM A370, subsection Si 1.1.4 or S1 1.1.5. This test is for the purpose of verifying the bolt, rod, or stud material and threads, and may be used in lieu of the proof-load tests prescribed for bolts by the L____________1.....J.. -,---...----.-...-. I ____________________________________________ .1

Attachment NOC-AE-06002049 Page 9 of 9 Condition Source Document Source Date of Original Commitment Description Revised Commitment Description Justification for Change Report Date Change Number Anchor bolts which are of a unique type or limited quantity, designated for a specific application, and having no surplus available for destructive testing, are non-destructively tested onsite to confirm material type.

Section IV- HL&P Receipt Inspection Program D. Performance of additional HL&P specified inspections or tests as required by the purchase order for the material or other documents.