ML082310641

Project, Units 1 and 2, South Texas Project Commitment Change Summary Report

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

Text

Nuclear Operating Company South Teas Project Electric Generating Station 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 U. S. Nuclear Regulatory Commission 612 East Lamar Blvd, Suite 400 Arlington, Texas 76011-4125 Mohan C. Thadani Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North (MS 7 D1)11555 Rockville Pike Rockville, MD 20852 Richard A. Ratliff Bureau of Radiation Control Texas Department of State Health Services 1100 West 49th Street Austin, TX 78756-3189 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704 Senior Resident Inspector U. S. Nuclear Regulatory Commission P. O. Box 289, Mail Code: MN116 Wadsworth, TX 77483 A. H. Gutterman, Esquire Morgan, Lewis & Bockius LLP Mohan C. Thadani U. S. Nuclear Regulatory Commission Thad Hill Catherine Callaway Jim von Suskil NRG South Texas LP Ed Alarcon J. J. Nesrsta R. K. 7 Temple Kevin Polio City Public Service Jon C. Wood Cox Smith Matthews C. Kirksey City of Austin 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 2003-01 -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 1 E-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 Compensatory measures will be used to offset the increased risk of allowing a 28-day AOT and will be implemented when it is recognized that maintenance on a motor-driven AFW pump will last for more than 14 days.Both commitments to implement compensatory actions are based on a prescriptive time.Procedure OPOP01-ZO-0006 is the implementing procedure for the compensatory action requirements.

preplanned maintenance activities for which the RMAT is anticipated to be exceeded, RMAs shall be implemented at the earliest appropriate time.The RMAT is the risk management action threshold and is established at 1 E-06 incremental core damage probability or 1 E-07 incremental large early release probability.

RMAs are risk management actions (i.e., compensatory action).These thresholds are consistent with the thresholds used by STPNOC in implementing Maintenance Rule requirements.

requires an assessment of risk for maintenance and that the risk be managed.STPNOC has established a configuration risk management program (CRMP) to comply with the MR. Consistent with NUMARC 93-01, it establishes specific risk thresholds that require compensatory action if the configuration risk exceeds the threshold.

The Non-Risk-Significant Threshold is established at an incremental core damage probability (ICDP) of 1 E-06.RMA is required for configurations where the risk exceeds that threshold.

STPNOC is an industry pilot for a risk-informed process for determining allowed outage times for the STP Technical 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 1 E-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." In addition, in NOC-AE-07002150, Attachment 1, Page 2 of 5, RAIs #5 and #8, STP clarified that both the SFP External Makeup (Table A.2-2) and SFP External Spray (Table A.2-3) strategies 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 /> in accordance with NEI guidance.from the Demineralized Water Tank into 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 been validated (CR 07-457-65).

The alternate water supplies are necessary because there may be competing needs for the firewater system. The equipment necessary to use these sources is staged 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-02001320 Control Room Envelope Ventilation System 04/25/2002 07/30/2008 Licensee Event Report 02-001 -CRE Ventilation System Failed to Maintain Positive Pressure in the Control Room Corrective Action #2: Revised the Electrical Auxiliary Building HVAC System procedure to include a description of the CRE HVAC boundary, a list of fire dampers that can affect CRE HVAC operability and general precautions reminding personnel that surrounding HVAC systems can affect CRE HVAC operability.

Revised OPOP02-HE-001, Electrical Auxiliary Building HVAC System to remove the description and list described above and to add procedure precautions section to state: During normal (non-emergency) modes of operation, system registers or access panels may be'removed to facilitate inspection provided the following precautions are in place.A. Communications are established between the control room and the working group.B. In the event of an HVAC actuation to an emergency mode, the register or access panel is to be reinstalled immediately and secured in place.C. Notify the Control Room that the access panel or register has been reinstalled.

Replacing the damper tables and description in the addendum to the procedure with the instructions for communication with the control room provides Operations with positive and immediate configuration control of system boundaries rather than relying on a lengthy table of information.

The use of the dedicated individual for control of the damper configuration is consistent with the guidance for manual actions in Regulatory Issue Summary 2005-20 (now in Part 9900 of the NRC Inspection Manual). The restoration process is simple and there are no environmental conditions that would impact the ability of a dedicated individual to reinstall an access cover or register.Incorporation of the guidance into the operating procedure makes future changes subject to a codified change process (i.e., 10 CFR 50.59). In accordance with NEI 99-04, this corrective 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.