NOC-AE-08002325, Commitment Change Summary Report

Commitment Change Summary Report

ML082310641
Person / Time
Site:	South Texas
Issue date:	08/11/2008
From:	Head S South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-08002325
Download: ML082310641 (8)

Text

Nuclear Operating Company South Teas ProjectElectric GeneratingStation P. Box 289 Wadsworth, Texas 77483 _

August 11 2008 N(Y-AE-0d002325 File No.: G25 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 Project Commitment Chanqe Summary Report Attached is the South Texas Project (STP) Commitment Change Summary Report for the period August 1, 2006 through July 30, 2008. 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 accordancewith the requirements of STP's Regulatory Commitment Change Process, which is consistent with the guidance in the Nuclear Energy Institute's NEI 99-04, "Guideline for Managing NRC Commitments." Additional documentation is available at STP for your review.

There are no new commitments in this letter.

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

Scott M. Head Manager, Licensing mk

Attachment:

Commitment Change Summary Report A6oof STI: 32326961

NOC-AE-08002325 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 612 East Lamar Blvd, Suite 400 Arlington, Texas 76011-4125 Mohan C. Thadani U. S. Nuclear Regulatory Commission Mohan C. Thadani Thad Hill Senior Project Manager Catherine Callaway U.S. Nuclear Regulatory Commission Jim von Suskil One White Flint North (MS 7 D1) NRG South Texas LP 11555 Rockville Pike Rockville, MD 20852 Richard A. Ratliff Ed Alarcon Bureau of Radiation Control J. J. Nesrsta Texas Department of State Health Services R. K. 7Temple 1100 West 49th Street Kevin Polio Austin, TX 78756-3189 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 Senior Resident Inspector U. S. Nuclear Regulatory Commission P. O. Box 289, Mail Code: MN116 Wadsworth, TX 77483

ATTACHMENT Commitment Change Summary Report

Attachment NOC-AE-08002325 Page 1 of 5 Condition Source Source Date of " -Original Commitment Revised Commitment Justification for Change Report Document Date Change Description Description Number 04-3365 NOC-AE- 08/05/2004 12/05/2006 NOC-AE-04001758, 08/05/04 - Response Alternative: The vendor for the analyses could not 04001758 to Request for Information on NRC Generic produce their deliverables on the needed Letter 2003 Control Room Habitability Revise the control room dose schedule.

Response to accident analyses to reflect the Generic Letter Revise the control room dose accident results of the control room inleakage 2003-01 analyses to reflect the results of the control testing. Due Date April 30. 2007.

room inleakage testing. Due Date December 31, 2005 04-12498 NOC-AE- 12/10/2007 07/09/2008 NOC-AE-07002237, 12/10/2007 - Request Submittal of letter verifying Extension of date to adopt revised ECCS 07002237 for Extension for Final Response to Generic completion and confirming sump strainer design basis is an Letter 2004-02 and Implementation of compliance will be submitted to the administrative change and has no effect Response to Revised Design Basis for ECCS Sump NRC by December 12, 2008. on plant operations. NRC approval was Generic Letter provided by telephone July 1, 2008, and 2004-02 Following completion of the 10 CIFR 50, by correspondence dated July 2, 2008.

Appendix B activities described above andb 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.

06-6838 NOC-AE- 12/03/2001 05/25/2006 Commitment for SDG allowed outage time Implementation of risk management The existing requirements for implementing 01001196 extension: actions will be based on reaching or risk management action (RMA) is simply expecting to reach the 1E-06 based on being the configuration beyond a Proposed The NRC.Safety Evaluation (SE) lists incremental core damage probability prescribed time. For the Standby Diesel Amendment to the compensatory actions for risk threshold instead of a prescribed Generator, Essential Cooling Water, and Technical extending the allowed outage times for time. This approach is consistent with Essential Chilled Water, the RMA is Specification the Standby Diesel Generators (TS the Risk Managed Technical implemented if the SSC will be inoperable 3.7.1.2 3.8.1.1), Essential Cooling Water (TS Specifications (RMTS) Guidelines. for longer than the duration of the allowed 3.7.4) and Essential Chilled Water (TS The specific requirement in the RMTS outage time prior to approval of Amendment 3.7.14). The internal memo (HS-HS- Guidelines reads: 85/72. For one inoperable MD Auxiliary 35345) documents a phone call with Feedwater pump, the RMA will be the NRC that confirms that the intent of For plant configurations in which implemented if the duration of the inoperable the SE was that the compensatory the RMAT (Risk Management condition will exceed 14 days. These times actions would be required if the outage Action Threshold) either has are prescriptive and do not take into account duration would be longer than the been exceeded (emergent the actual quantified risk of the plant original allowed outage time (i.e., event) or is anticipated to be configuration when the SSC is removed longer than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />). exceeded (either planned from service or becomes inoperable for an condition or emergent event), emergent condition.

Commitment for AFW motor-driven pump appropriate compensatory risk allowed outage time extension (ref. NOC-AE- management actions shall be Implementation of the Maintenance Rule 01001196): identified and implemented. For (MR) as described in 10CFR50.65(a)(4)

Attachment NOC-AE-08002325 Page 2 of 5 Condition Source Source Date of Original Commitment Revised Commitment Justification for Change Report Document Date Change Description Description Number preplanned maintenance requires an assessment of risk for Compensatory measures will be used activities for which the RMAT is maintenance and that the risk be managed.

to offset the increased risk of allowing anticipated to be exceeded, STPNOC has established a configuration a 28-day AOT and will be implemented RMAs shall be implemented at risk management program (CRMP) to when it is recognized that maintenance the earliest appropriate time. comply with the MR. Consistent with on a motor-driven AFW pump will last NUMARC 93-01, it establishes specific risk for more than 14 days. The RMAT is the risk management thresholds that require compensatory action action threshold and is established at if the configuration risk exceeds the Both commitments to implement 1E-06 incremental core damage compensatory actions are based on a threshold. The Non-Risk-Significant probability or 1E-07 incremental large Threshold is established at an incremental prescriptive time. early release probability. RMAs are core damage probability (ICDP) of 1E-06.

Procedure OPOP01-ZO-0006 is the risk management actions (i.e., RMA is required for configurations where the implementing procedure for the compensatory action). risk exceeds that threshold.

compensatory action requirements.

These thresholds are consistent with STPNOC is an industry pilot for a risk-the thresholds used by STPNOC in informed process for determining allowed implementing Maintenance Rule outage times for the STP Technical requirements. Specifications (TS). The risk-informed process involves the application of the STP Configuration Risk Management Program (CRMP) to calculate a risk-informed completion time (RICT) based on the time required for the risk calculated for a plant configuration to attain a threshold. The risk thresholds, the process for calculating the configuration risk, and the requirements for PRA quality are described in the Electric Power Research Institute (EPRI) Risk Managed Technical Specification Guidelines (RMTS Guidelines). The RMTS Guidelines applies the same ICDP threshold for RMA as the MR. The RMTS Guidelines also establishes a incremental large early release probability (ILERP) threshold of 1E-07.

These thresholds are known as risk management action thresholds (RMAT). The RMTS Guidelines specifically requires RMAs for conditions that exceed the RMAT:

For plant configurations in which the RMAT either has been exceeded (emergent event) or is anticipated to be exceeded (either planned condition or emergent event),

appropriate compensatory risk management actions shall be identified and implemented. For

Attachment NOC-AE-08002325 Page 3 of 5 Condition Source Source Date of Original Commitment Revised Commitment Justification for Change Report Document Date Change Description Description Number preplanned maintenance activities for which the RMAT is anticipated to be exceeded, RMAs shall be implemented at the earliest appropriate time.

This commitment change is described in the license amendment request for the risk-informed TS (NOC-AE-06002005).

Revising the STP procedure to apply thresholds consistent with the MR and the RMTS Guidelines will establish an internally consistent risk-informed process with one set of criteria that are firmly grounded in industry and regulatory precedent.

07-457-66 NOC-AE- 02/22/2007 12/12/2007 NOC-AE-07002114, Attachment 1, Page 4 For both the SFP External Makeup During revision of implementing 07002114 of 18, Table A.2-3, SFP External Spray (Table A.2-2) and SFP External procedures it was determined that the Strategy General Description, states in Spray (Table A.2-3) strategies the backup method of connecting the portable Phase 2 and 3 part: preferred source of water will be pump to draw from the identified Mitigation firewater from a yard fire hydrant, if Circulating Water locations in the Strategies ... the preferred source of water will available, since it is more easily procedure would take more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

NOC-AE- 05/14/2007 be firewater from a yard fire hydrant, deployed. Water can also be Therefore two other locations where it was 07002150 if available, since it is more easily supplied by pumping water from the deemed feasible to meet the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> deployed. Water can also be Circulating Water System below deployment time were identified. The Phase 2 and 3 supplied by pumping water from the ground piping located West of each Demineralized Water Storage Tank has a Mitigation Circulating Water System below Fuel Handling Building using the capacity of up to 1 million gallons. The Strategies - ground piping located West of each diesel driven portable pump. Other Organics Basin contains water from outage RAI Response Fuel Handling Building using the sources are the Demineralized Water activities and rain water.

diesel driven portable pump. Storage Tank located east of the Unit AE-NOC- 07/11/2007 1 Fuel Handling Building or the The capability to deploy the strategies 07001653 .- ... The strategy will be deployed within Organics Basin located southeast of within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and for at least 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 2 hours when fuel is stored in an the Unit 2 Fuel Handling Building. with onsite water sources will be met by Safety Evaluation undispersed configuration, the revised strategy. The preferred source for EA-02-026 ... The SFP External Makeup (Table of water will continue to be the firewater Similar commitments were made for the A.2-2) and SFP External Spray system from a yard fire hydrant, if SFP External Makeup Strategy (Table A.2- (Table A.2-3) strategies will be available. There are options in the

2) on, Page 2 of 18, where it stated that the capable of being deployed within 2 strategies for long term water supply by portable diesel driven pump can be hours, connecting the portable pump to draw supplied from several different long term water from the Demineralized Water sources and supplement the existing fire Water Source & Capacity: "...there Storage Tank, the Organics Basin, or the water system" to include is available over 1.2E7 gallons from Circulating Water System (CWS) below the Circulating Water System and ground piping to charge the fire header Water Source & Capacity "... 1.2E7 approximately 1 million gallons from. through a yard hydrant. The capability to gallons from the Circulating Water System." the Demineralized Water Storage set-up the portable pump to draw water

Attachment NOC-AE-08002325 Page 4 of 5 Condition Source Source Date of Original Commitment Revised Commitment Justification for Change Report Document Date Change Description Description Number Tank." from the Demineralized Water Tank into In addition, in NOC-AE-07002150, the SFP within the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> requirement has Attachment 1, Page 2 of 5, RAIs #5 and #8, been validated (CR 07-457-65). The STP clarified that both the SFP External alternate water supplies are necessary Makeup (Table A.2-2) and SFP External because there may be competing needs Spray (Table A.2-3) strategies will be for the firewater system. The equipment developed to deploy within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in necessary to use these sources is staged accordance with NEI guidance. and available. CREE 07-457-63 validates the flow rates using the Demineralized Water Tank as the water source. CREE 07-457-37 and 07-457-38 validate flow rates and capacities using the CWS which can be still be deployed but will require additional set-up time to access the CWS piping if the CWS is determined to be necessary.

The commitment in NOC-AE-07002150, Attachment 1, RAI 8 Page 2 of 7, Table A.2-3 (SFP External Spray Strategy) further clarified that the strategy will be developed to deploy within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The (implementing procedures) guidance will require that the strategy be deployed within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> when fuel is not dispersed and no later than 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> when fuel is dispersed.

While the spray strategy has been developed to ensure deployment within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, it can be deployed no later than 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> when fuel is in a dispersed configuration.

These commitments were reflected in the Safety Evaluation for AE-NOC-07001653, Appendix B sections, 2.3.1 and section 2.3.2; however, the specific sources of water were not specified in the "Evaluation" section. It is acceptable to make this change without prior NRC notification and approval. The change will be reflected in the next periodic report of commitment changes and the NRC will be advised of the change during their 2008 inspection of 15b implementation under NRC TI 2515/171.

Attachment NOC-AE-08002325 Page 5 of 5 Condition Source Source Date of. Original Commitment Revised Commitment Justification for Change Report Document Date Change Description Description Number 07-491 NOC-AE- 04/25/2002 07/30/2008 Licensee Event Report 02-001 - CRE Revised OPOP02-HE-001, Electrical Replacing the damper tables and 02001320 Ventilation System Failed to Maintain Auxiliary Building HVAC System to description in the addendum to the Positive Pressure in the Control Room remove the description and list procedure with the instructions for Control Room described above and to add communication with the control room Envelope Corrective Action #2: Revised the Electrical procedure precautions section to provides Operations with positive and Ventilation Auxiliary Building HVAC System procedure state: immediate configuration control of system System to include a description of the CRE HVAC boundaries rather than relying on a boundary, a list of fire dampers that can During normal (non-emergency) lengthy table of information.

affect CRE HVAC operability and general modes of operation, system registers precautions reminding personnel that or access panels may be'removed to The use of the dedicated individual for surrounding HVAC systems can affect CRE facilitate inspection provided the control of the damper configuration is HVAC operability. following precautions are in place. consistent with the guidance for manual actions in Regulatory Issue Summary A. Communications are 2005-20 (now in Part 9900 of the NRC established between the control Inspection Manual). The restoration room and the working group. process is simple and there are no B. In the event of an HVAC environmental conditions that would actuation to an emergency impact the ability of a dedicated individual mode, the register or access to reinstall an access cover or register.

panel is to be reinstalled Incorporation of the guidance into the immediately and secured in operating procedure makes future place. changes subject to a codified change C. Notify the Control Room that process (i.e., 10 CFR 50.59). In the access panel or register accordance with NEI 99-04, this corrective has been reinstalled. action need not be tracked as a commitment.

Note that this commitment change was not documented initially, and this justification was performed after the fact as a Condition Report action.