NOC-AE-07002237, Request for Extension for Final Response to Generic Letter 2004-02 and Implementation of Revised Design Basis for ECCS Sump
| ML073520021 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 12/10/2007 |
| From: | Rencurrel D South Texas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GL-04-002, NOC-AE-07002237, STI: 32225179, TAC MC4719, TAC MC4720 | |
| Download: ML073520021 (5) | |
Text
Nuclear Operating Company South TaiasPro/ecl Electric GenemtinS Station PO Box 289 Wadsworth, Texas 77483 December 10, 2007 NOC-AE-07002237 10CFR50.54(f)
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 and STN 50-499 Request for Extension for Final Response to Generic Letter 2004-02 and Implementation of Revised Design Basis for ECCS Sump (TAC Nos. MC47 19 and MC4720)
References:
- 1. NRC Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized Water Reactors," dated September 13, 2004 (ML042360586)
- 2. Letter, T. J. Jordan, STPNOC, to Document Control Desk, "90-Day Response to Generic Letter 2004-02: Potential Impact of Debris Blockage on Emergency Recirculation during Design Basis Accidents at Pressurized-Water Reactors," dated March 8, 2005 (NOC-AE-05001862, ML050770105)
- 3. Letter, T. J. Jordan, STPNOC, to Document Control Desk, "Supplement 1 to the Response to Generic Letter 2004-02," dated August 31, 2005 (NOC-AE-05001922, ML052500311)
- 4. Letter, William H. Ruland, NRC, to Anthony R. Pietrangelo, NEI, "Plant-Specific Requests for Extension of Time to Complete One or More Corrective Actions for Gen'eric Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized Water Reactors," dated November 8, 2007 (ML073060581)
In accordance with the guidance of Reference 4 for Case 2 plants, STP Nuclear Operating Company (STPNOC) requests an extension of the completion date for final review and approval activities needed to fully implement NRC Generic Letter (GL) 2004-02 corrective actions at STP Units 1 and 2 to June 30, 2008. Additional time is required to complete and document testing and to implement requirements of the STPNOC Quality Assurance Program, specifically 10 CFR 50, Appendix B activities related to design control, document control, control of purchased services and quality assurance records.
Reference 1, NRC GL 2004-02, requested that licensees take actions and provide information regarding the potential impact of debris blockage on emergency recirculation during design basis accidents. In References 2 and 3, STPNOC provided its response to GL 2004-02 stating that STPNOC will be in full compliance with the regulatory requirements discussed in the applicable regulatory requirements section of GL 2004-02 by December 31, 2007.
Plant hardware modifications developed in response to issues identified in GL 2004-02 are installed in STP Units 1 and 2 and are supporting compliance with the regulatory requirements for long term cooling following a design basis loss of coolant accident. Similarly, implementation is complete for STPNOC STI: 32225179
NOC-AE-07002237 Page 2 of 4 plant administrative procedures and processes needed to support the GL 2004-02 hardware modifications and to support the current assumptions, initial conditions and conclusions of GL 2004-02 related evaluations, including the current evaluations of design basis accident debris generation and transport, sump strainer performance, impact of chemical effects and downstream effects of debris.
Substantial plant-specific testing that supports assumptions and corresponding conclusions contained in the GL 2004-02 evaluations for STP has been performed. However, additional strainer head loss testing for chemical effects is scheduled to be completed in February 2008. In addition to the completion of the testing, there are additional actions required prior to the vendor completing a final test report that meets the requirements of the procurement specifications, including those of 10 CFR 50, Appendix B for control of purchased services and procurement document control. The test report is currently scheduled to be available in May 2008. Following receipt of the final test report from the vendor, additional actions are also required by STPNOC to complete formal verification of design inputs, assumptions and conclusions of STPNOC calculations and evaluations conducted in response to issues identified in GL 2004-02, including possible revision of the downstream effects analyses. These activities also include compliance with 10 CFR 50, Appendix B requirements for design control, document control and quality assurance records.
Based the extensive experience gained while conducting and assessing actions taken in response to issues identified in GL 2004-02 and the margin in the sump design, STPNOC believes that-the testing results, when fully documented in the test report, will fully support all corrective actions taken in response to issues identified in GL 2004-02.
Since hardware, procedures and administrative controls required to support actions taken in response to issues identified in GL 2004-02 are already implemented at STP, STPNOC has reasonable assurance that if an accident of the type described in GL 2004-02 were to occur at STP, plant systems and plant operators would respond in a manner consistent with the intent of the GL 2004-02 corrective actions, including conformance with the regulatory requirements listed in GL 2004-02. However, the plant design and licensing basis.can not be changed until all regulatory requirements affecting associated change processes are complete.
Based on the evaluation above, STPNOC has determined that STP meets the criteria for a Case 2 plant described in Reference 4 as a plant that has determined that testing and/or analyses will not be completed or are not likely to be completed by the end of 2007. The guidance directs the licensees to apply the criteria of SECY-06-0078 for the basis for the extension request. STPNOC has concluded the criteria of the SECY are met:
- Criterion 1 for a plan with a milestone schedule is satisfied as discussed above.
" Criterion 2 for mitigative measures is satisfied since hardware, procedures and administrative controls required to support actions taken in response to issues identified in GL 2004-02 are already implemented at STP.
Therefore, STPNOC requests an extension to June 30, 2008 to allow full completion of 10 CFR 50, Appendix B activities to support changing the plant design and licensing bases to be in compliance with actions taken in response to issues identified in GL2004-02.
Following completion of the testing and 10 CFR 50, Appendix B activities described above and the associated changes to the STP licensing basis, STPNOC will submit a letter by June 30, 2008, verifying completion of all GL 2004-02 corrective actions and confirming compliance with the regulatory requirements listed in GL 2004-02.
NOC-AE-07002237 Page 3 of 4 documents the commitment made to the NRC by this letter. STPNOC requests approval of the proposed extension by December 31, 2007. If you have any questions concerning this matter, please contact Mr. A. W. Harrison at (361) 972-7298, or me at (361) 972-7867.
I state under penalty of perjury that the foregoing is true and correct.
Executedon Iz-.l 07 David urrel Vice President; Engineering & Strategic Projects Awh/ : Commitment
NOC-AE-07002237 Page 4 of 4 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 Mohan C. Thadani Thad Hill Senior Project Manager Eddy Daniels U.S. Nuclear Regulatory Commission Marty Ryan One White Flint North (MS 7 Di) Harry Holloway 11555 Rockville Pike Steve Winn Rockville, MD 20852 NRG South Texas LP Senior Resident Inspector Ed Alarcon U. S. Nuclear Regulatory Commission J. J. Nesrsta P. O. Box 289, Mail Code: MN116 R. K. Temple Wadsworth, TX 77483 Kevin Pollo City Public Service C. M. Canady Jon C. Wood City of Austin Cox Smith Matthews Electric Utility Department 721 Barton Springs Road C. Kirksey Austin, TX 78704 City of Austin Richard A. Ratliff Bureau of Radiation Control Texas Department of State Health Services 1100 West 49th Street Austin, TX 78756-3189
)
Attachment I NOC-AE-07002237 Page 1 of 1 Commitment The following table identifies the action committed to by the STP Nuclear Operating Company in this document. Any statements in this submittal with the exception of those in the table below are provided for information purposes and are not considered commitments. Please direct questions regarding these commitments to S~ott Head at (361) 972-7136.
Commitment Due Date Condition Report Following completion of the 10 CFR 50, Appendix B activities 06/30/2008 04-12498-15 described above and the associated changes to the STP licensing basis, STPNOC will submit a letter verifying completion of all GL 2004-02 corrective actions and confirming compliance with the regulatory requirements listed in GL 2004-02.
Text
Nuclear Operating Company South TaiasPro/ecl Electric GenemtinS Station PO Box 289 Wadsworth, Texas 77483 December 10, 2007 NOC-AE-07002237 10CFR50.54(f)
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 and STN 50-499 Request for Extension for Final Response to Generic Letter 2004-02 and Implementation of Revised Design Basis for ECCS Sump (TAC Nos. MC47 19 and MC4720)
References:
- 1. NRC Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized Water Reactors," dated September 13, 2004 (ML042360586)
- 2. Letter, T. J. Jordan, STPNOC, to Document Control Desk, "90-Day Response to Generic Letter 2004-02: Potential Impact of Debris Blockage on Emergency Recirculation during Design Basis Accidents at Pressurized-Water Reactors," dated March 8, 2005 (NOC-AE-05001862, ML050770105)
- 3. Letter, T. J. Jordan, STPNOC, to Document Control Desk, "Supplement 1 to the Response to Generic Letter 2004-02," dated August 31, 2005 (NOC-AE-05001922, ML052500311)
- 4. Letter, William H. Ruland, NRC, to Anthony R. Pietrangelo, NEI, "Plant-Specific Requests for Extension of Time to Complete One or More Corrective Actions for Gen'eric Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized Water Reactors," dated November 8, 2007 (ML073060581)
In accordance with the guidance of Reference 4 for Case 2 plants, STP Nuclear Operating Company (STPNOC) requests an extension of the completion date for final review and approval activities needed to fully implement NRC Generic Letter (GL) 2004-02 corrective actions at STP Units 1 and 2 to June 30, 2008. Additional time is required to complete and document testing and to implement requirements of the STPNOC Quality Assurance Program, specifically 10 CFR 50, Appendix B activities related to design control, document control, control of purchased services and quality assurance records.
Reference 1, NRC GL 2004-02, requested that licensees take actions and provide information regarding the potential impact of debris blockage on emergency recirculation during design basis accidents. In References 2 and 3, STPNOC provided its response to GL 2004-02 stating that STPNOC will be in full compliance with the regulatory requirements discussed in the applicable regulatory requirements section of GL 2004-02 by December 31, 2007.
Plant hardware modifications developed in response to issues identified in GL 2004-02 are installed in STP Units 1 and 2 and are supporting compliance with the regulatory requirements for long term cooling following a design basis loss of coolant accident. Similarly, implementation is complete for STPNOC STI: 32225179
NOC-AE-07002237 Page 2 of 4 plant administrative procedures and processes needed to support the GL 2004-02 hardware modifications and to support the current assumptions, initial conditions and conclusions of GL 2004-02 related evaluations, including the current evaluations of design basis accident debris generation and transport, sump strainer performance, impact of chemical effects and downstream effects of debris.
Substantial plant-specific testing that supports assumptions and corresponding conclusions contained in the GL 2004-02 evaluations for STP has been performed. However, additional strainer head loss testing for chemical effects is scheduled to be completed in February 2008. In addition to the completion of the testing, there are additional actions required prior to the vendor completing a final test report that meets the requirements of the procurement specifications, including those of 10 CFR 50, Appendix B for control of purchased services and procurement document control. The test report is currently scheduled to be available in May 2008. Following receipt of the final test report from the vendor, additional actions are also required by STPNOC to complete formal verification of design inputs, assumptions and conclusions of STPNOC calculations and evaluations conducted in response to issues identified in GL 2004-02, including possible revision of the downstream effects analyses. These activities also include compliance with 10 CFR 50, Appendix B requirements for design control, document control and quality assurance records.
Based the extensive experience gained while conducting and assessing actions taken in response to issues identified in GL 2004-02 and the margin in the sump design, STPNOC believes that-the testing results, when fully documented in the test report, will fully support all corrective actions taken in response to issues identified in GL 2004-02.
Since hardware, procedures and administrative controls required to support actions taken in response to issues identified in GL 2004-02 are already implemented at STP, STPNOC has reasonable assurance that if an accident of the type described in GL 2004-02 were to occur at STP, plant systems and plant operators would respond in a manner consistent with the intent of the GL 2004-02 corrective actions, including conformance with the regulatory requirements listed in GL 2004-02. However, the plant design and licensing basis.can not be changed until all regulatory requirements affecting associated change processes are complete.
Based on the evaluation above, STPNOC has determined that STP meets the criteria for a Case 2 plant described in Reference 4 as a plant that has determined that testing and/or analyses will not be completed or are not likely to be completed by the end of 2007. The guidance directs the licensees to apply the criteria of SECY-06-0078 for the basis for the extension request. STPNOC has concluded the criteria of the SECY are met:
- Criterion 1 for a plan with a milestone schedule is satisfied as discussed above.
" Criterion 2 for mitigative measures is satisfied since hardware, procedures and administrative controls required to support actions taken in response to issues identified in GL 2004-02 are already implemented at STP.
Therefore, STPNOC requests an extension to June 30, 2008 to allow full completion of 10 CFR 50, Appendix B activities to support changing the plant design and licensing bases to be in compliance with actions taken in response to issues identified in GL2004-02.
Following completion of the testing and 10 CFR 50, Appendix B activities described above and the associated changes to the STP licensing basis, STPNOC will submit a letter by June 30, 2008, verifying completion of all GL 2004-02 corrective actions and confirming compliance with the regulatory requirements listed in GL 2004-02.
NOC-AE-07002237 Page 3 of 4 documents the commitment made to the NRC by this letter. STPNOC requests approval of the proposed extension by December 31, 2007. If you have any questions concerning this matter, please contact Mr. A. W. Harrison at (361) 972-7298, or me at (361) 972-7867.
I state under penalty of perjury that the foregoing is true and correct.
Executedon Iz-.l 07 David urrel Vice President; Engineering & Strategic Projects Awh/ : Commitment
NOC-AE-07002237 Page 4 of 4 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 Mohan C. Thadani Thad Hill Senior Project Manager Eddy Daniels U.S. Nuclear Regulatory Commission Marty Ryan One White Flint North (MS 7 Di) Harry Holloway 11555 Rockville Pike Steve Winn Rockville, MD 20852 NRG South Texas LP Senior Resident Inspector Ed Alarcon U. S. Nuclear Regulatory Commission J. J. Nesrsta P. O. Box 289, Mail Code: MN116 R. K. Temple Wadsworth, TX 77483 Kevin Pollo City Public Service C. M. Canady Jon C. Wood City of Austin Cox Smith Matthews Electric Utility Department 721 Barton Springs Road C. Kirksey Austin, TX 78704 City of Austin Richard A. Ratliff Bureau of Radiation Control Texas Department of State Health Services 1100 West 49th Street Austin, TX 78756-3189
)
Attachment I NOC-AE-07002237 Page 1 of 1 Commitment The following table identifies the action committed to by the STP Nuclear Operating Company in this document. Any statements in this submittal with the exception of those in the table below are provided for information purposes and are not considered commitments. Please direct questions regarding these commitments to S~ott Head at (361) 972-7136.
Commitment Due Date Condition Report Following completion of the 10 CFR 50, Appendix B activities 06/30/2008 04-12498-15 described above and the associated changes to the STP licensing basis, STPNOC will submit a letter verifying completion of all GL 2004-02 corrective actions and confirming compliance with the regulatory requirements listed in GL 2004-02.