NOC-AE-12002858, GSI 191 Resolution Path Schedule and Commitment Changes

GSI 191 Resolution Path Schedule and Commitment Changes

ML13025A360
Person / Time
Site:	South Texas
Issue date:	06/04/2012
From:	Rencurrel D South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
G25, GSI 191, NOC-AE-12002858, STI 33552943
Download: ML13025A360 (4)

Text

'Nuclear perating Company South Te.as Pro"/d ElectWic Genera Wjn Station P.O Box 28P Widnwort. T76w 77483 June 4, 2012 NOC-AE-12002858 STI No. 33552943 File No.: G25 IOCFR50 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 GSI 191 Resolution Path Schedule and Commitment Changes

Reference:

1. NEI letter dated May 4, 2012 from John C. Butler to Mr. William H. Ruland, "GSI-191 Current Status and Recommended Actions for Closure" (ST-AE-NOC-12002309, ML121080006).

2. STP Nuclear Operating Company letter dated December 14, 2011 to NRC Document Control Desk, "Status of the South Texas Project Risk-Informed (RI) Approach to resolve Generic Safety Issue (GSI) 191" (ST-AE-NOC-1 1002779, ML11354A386).

3. NRC Letter dated October 13, 2010 from Balwant Singal, Project Manager, to STP Nuclear Operating Company, "

SUMMARY

OF SEPTEMBER 13, 2010, CATEGORY I MEETING, VIA CONFERENCE CALL, WITH STP NUCLEAR OPERATING COMPANY-DISCUSSION OF DRAFT RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION FOR GENERIC LETTER 2004-02, "POTENTIAL IMPACT OF DEBRIS BLOCKAGE ON EMERGENCY RECIRCULATION DURING DESIGN BASIS ACCIDENTS AT PRESSURIZED-WATER REACTORS" (TAC NOS. MC4719 AND MC4720)," (ST-NOC-AE-10002034, ML102810345).

4.. STP Nuclear Operating Company letter dated June 26,2008 to NRC Document Control Desk, "Response to NRC Request for Information Regarding STPNOC Request to Extend Implementation Date for ECCS Sump Design Basis (TAC Nos.

MC4719 and MC4720)" (NOC-AE-08002328, ML081890190).

5. STP Nuclear Operating Company letter dated December 11, 2008 to NRC.Document Control Desk, "Supplement 4 to the Response to Generic Letter 2004-02" (NOC-AE-08002372, ML085520336).

Pursuant to Reference 1, STP Nuclear Operating Company (STPNOC) is notifying the NRC that At-4f STPNOC is committed to resolve GSI 191, site specifically, through a risk informed approach.

tfr A311 2

NOC-AE- 12002858 Page 2 of 3 STPNOC now plans to make a docketed License Amendment Request (LAR) submittal not later than 28 March, 2013. This commitment is listed in the attachment. As previously communicated in Reference 2:

"In the risk-informed approach, STPNOC intends to seek exemption from certain requirements of 10 CFR 50.46 based on a determination that the risk associated with the fibrous insulation in STPNOC's containment buildings is low enough to meet the requirements of Regulatory Guide (RG) 1.174, 'An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions On Plant Specific Changes to the Licensing Basis."'

The risk-informed approach will not be dependent on the results of further Westinghouse testing, analysis, nor the NRC acceptance of such testing and analysis as documented in a Westinghouse Commercial Atomic Power (WCAP) report. In addition, the risk-informed approach will not utilize previous sump strainer testing for determination of strainer head loss. As such, STPNOC does not intend to provide a response to the open Requests for Additional Information (RAIs) identified in Reference 3.

The risk-informed approach commitment made in the attachment replaces two previous commitments related to additional Westinghouse testing and WCAP reports. These commitments were made in References 4 and 5 and are listed in the attachment. There are no other regulatory commitments in this letter.

If there are any questions regarding this amendment request, please contact Jamie Paul at (361) 972-7344 or me at (361) 972-7867.

Recurrel Chief Nuclear Officer JLP

Attachment:

Regulatory Commitments

NOC-AE- 12002858 Page 3 of 3 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission Morgan, Lewis & Bockius LLP 1600 East Lamar Boulevard Arlington, TX 76011-4511 Balwant K. Singal U. S. Nuclear Regulatory Commission Balwant K. Singal John Ragan Senior Project Manager Chris O'Hara U,S. Nuclear Regulatory Commission Jim von Suskil One White Flint North (MS 8 B 1) NRG South Texas LP 11555 Rockville Pike Rockville, MD 20852 Kevin Polio Senior Resident Inspector Richard Pena U, S. Nuclear Regulatory Commission City Public Service P. 0. Box 289, Mail Code: MN16 Wadsworth, TX 77483 C. M. Canady Peter Nemeth City of Austin Crain Caton & James, P.C.

Electric Utility Department 721 Barton Springs Road C. Mele Austin, TX 78704 City of Austin Richard A. Ratliff Texas Department of State Health Services Alice Rogers Texas Department of State Health Services

Attachment NOC-AE- 12002858 Page 1 of I Regulatory Commitments Commitments to be deleted:

Commitment Current Due Date CR Action No.

When the final Safety Evaluation for 15 June, 2012 02- 5326-120 WCAP-16793, "Long Term Cooling" is issued, STP will review it for impact; and the evaluation of long term cooling will be revised as appropriate.

Testing plan and contingency options 1 April, 2013 02-5326-113 provide assurance that the GSI-191 and GL 2004-02 issues will be resolved for STP Units I and 2 by December 31, 2009.

New commitment:

Commitment Current Due Date CR Action No.

Submit a License Amendment 28 March, 2013 11-4249-7 Request (LAR) based on a risk-informed approach to resolve GSI 191 for STP.