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Category:CORRESPONDENCE-LETTERS
MONTHYEARTXX-9924, Forwards Responses to Questions by NRC Re Application for Amends to Licenses NPF-87 & NPF-89,by Incorporating Changes Increasing RWST low-level Setpoint from Greater than But Equal to 40% to Greater than But Equal to 45% of Span1999-10-22022 October 1999 Forwards Responses to Questions by NRC Re Application for Amends to Licenses NPF-87 & NPF-89,by Incorporating Changes Increasing RWST low-level Setpoint from Greater than But Equal to 40% to Greater than But Equal to 45% of Span ML20217M5711999-10-20020 October 1999 Forwards Insp Repts 50-445/99-15 & 50-446/99-15 on 990822- 1002.Two Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy TXX-9923, Forwards Monthly Operating Repts for Sept 1999 for CPSES, Units 1 & 2,per Plant TS 5.6.4.No Failures of Challenges to PORVs of SV for Units Occurred1999-10-15015 October 1999 Forwards Monthly Operating Repts for Sept 1999 for CPSES, Units 1 & 2,per Plant TS 5.6.4.No Failures of Challenges to PORVs of SV for Units Occurred ML20217E7951999-10-12012 October 1999 Forwards COLR for Unit 1,Cycle 8,per TS 5.6.5 ML20212L2891999-10-0101 October 1999 Discusses Closeout of GL 97-06, Degradation of Steam Generator Internals. Purpose of GL Was to Obtain Info That Would Enable NRC to Verify That Condition of Licensee SG Internals Comply with Current Licensing Bases TXX-9922, Forwards Revised COLR, for Cycle 5 for Unit 21999-10-0101 October 1999 Forwards Revised COLR, for Cycle 5 for Unit 2 ML20216J5571999-10-0101 October 1999 Provides Final Response to GL 98-01,suppl 1, Y2K Readiness of Computer Sys at Npps ML20212G0721999-09-24024 September 1999 Forwards Rev 4 to Augmented Inservice Insp Plan for CPSES, Unit 1. Future Changes & Revs to Unit 1 Augmented Inservice Insp Plan Will Be Available on Site ML20212H0461999-09-24024 September 1999 Forwards Rev 6 to CPSES Glen Rose,Tx ASME Section XI ISI Program Plan for 1st Interval on 990820 ML20212F7481999-09-24024 September 1999 Forwards SER Authorizing Relief from Exam Requirement of 1986 Edition ASME Code,Section XI Pursuant to 10CFR50.55a(a)(3)(ii) for Relief Request A-3 & 10CFR50.55a(g)(6)(i) for Relief Requests B15,16,17 & C-4 ML20212F1041999-09-23023 September 1999 Requests That NRC Be Informed of Any Changes in Scope of Y2K System Deficiencies Listed or Util Projected Completion Schedule for Comanche Peak Steam Electric Station,Units 1 & 2 ML20212E6661999-09-21021 September 1999 Advises That Info Contained in Application & Affidavit, (CAW-99-1342) Re WCAP-15009,Rev 0, Comache Peak Unit 1 Evaluation for Tube Vibration Induced Fatigue, Will Be Withheld from Public Disclosure ML20212D9111999-09-16016 September 1999 Informs That on 990818,NRC Completed Midcycle PPR of CPSES & Did Not Identify Any Areas in Which Performance Warranted Insp Beyond Core Insp Program.Core Insp Plan at Facility Over Next 7 Months.Insp Plan Through March 2000 Encl ML20212A7601999-09-14014 September 1999 Forwards Insp Repts 50-445/99-14 & 50-446/99-14 on 990707-0821.Four Violations Occurred & Being Treated as Ncvs.Conduct of Activities Was Generally Characterized by safety-conscious Operations & Sound Radiological Controls TXX-9921, Suppls 981221 LAR 98-010 to Licenses NPF-87 & NPF-89, Clarfying Conditions of Use Re Analytical Methods Used to Determine Core Operating Limits,Per Telcon with NRC1999-09-10010 September 1999 Suppls 981221 LAR 98-010 to Licenses NPF-87 & NPF-89, Clarfying Conditions of Use Re Analytical Methods Used to Determine Core Operating Limits,Per Telcon with NRC ML20211P3761999-09-0707 September 1999 Ack Receipt of Ltr Dtd 990615,transmitting Rev 30 to Physical Security Plan,Per 10CFR50.54(p).No NRC Approval Is Required ML20211L9871999-09-0303 September 1999 Forwards Rev 31 to Technical Requirements Manual. All Changes Applicable to Plants Have Been Reviewed Under Util 10CFR50.59 Process & Found Not to Include Any USQs TXX-9915, Responds to 990701 & 0825 RAI Telcons Re Spent Fuel Pool Temp,Per LAR 98-008,which Requested Increase in Spent Fuel Storage capacity.Marked-up Page 4-1 of CPSES Fuel Storage Licensing Rept, Encl1999-09-0303 September 1999 Responds to 990701 & 0825 RAI Telcons Re Spent Fuel Pool Temp,Per LAR 98-008,which Requested Increase in Spent Fuel Storage capacity.Marked-up Page 4-1 of CPSES Fuel Storage Licensing Rept, Encl ML20211K2231999-08-31031 August 1999 Forwards Txu Electric Comments of Rvid,Version 2 ML20211J3801999-08-27027 August 1999 Forwards Corrected TS Page 3.8-26 to Amend 66 to Licenses NPF-87 & NPF-89,respectively.Footnote on TS Page 3.8-26 Incorrectly Deleted ML20211G7301999-08-26026 August 1999 Forwards Revs 29 & 30 to CPSES Technical Requirements Manual (Trm). Attachments 1 & 2 Contain Description of Changes for Revs 29 & 30 Respectively ML20211G1081999-08-26026 August 1999 Responds to NRR Staff RAI Re Util Mar 1999 Submittal for NRC Review & Approval of Changes to CPSES Emergency Classification Procedure ML20211G3441999-08-25025 August 1999 Forwards Response to NRC RAI on LAR 98-010 for Cpses,Units 1 & 2.Communication Contains No New Licensing Commitments Re Cpses,Units 1 & 2 ML20211B2861999-08-18018 August 1999 Forwards Insp Repts 50-445/99-13 & 50-446/99-13 on 990720- 23.No Violations Noted.Insp Included Implementation of Licensee Emergency Plan & Procedures During Util Biennial Emergency Preparedness Exercise ML20211C4661999-08-18018 August 1999 Discusses Proprietary Info Re Thermo-Lag.NRC Treated Bisco Test Rept 748-105 as Proprietary & Withheld It from Public Disclosure,Iaw 10CFR2.790 ML20210U3981999-08-17017 August 1999 Forwards Monthly Operating Repts for July 1999 for CPSES, Units 1 & 2,per TS 6.9.1.5.No Failures or Challenges to PORVs or SVs for Plant Occurred ML20211C0991999-08-17017 August 1999 Forwards Rev 3 to ASME Section XI ISI Program Plan,Unit 2 - 1st Interval, Replacing Rev 2 in Entirety ML20211C4571999-08-16016 August 1999 Forwards Omitted Subj Page of Contractor TER TXX-9919, Forwards Relief Request A-3,Rev 1 to Unit 1 ISI Program,Per Conversations Between NRC & Txu Electric on 9908021999-08-16016 August 1999 Forwards Relief Request A-3,Rev 1 to Unit 1 ISI Program,Per Conversations Between NRC & Txu Electric on 990802 ML20210R6561999-08-13013 August 1999 Forwards Response to NRR 990805 Telcon RAI Re License Amend Request 98-010,to Increase Power for Operation of CPSES Unit 2 to 3445 Mwth & Incorporating Addl Changes Into Units 1 & 2 TS ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210S6411999-08-12012 August 1999 Informs That Wg Guldemond,License SOP-43780,is No Longer Performing Licensed Duties.Discontinuation of License Is Requested ML20210R2221999-08-12012 August 1999 Forwards Insp Repts 50-445/99-10 & 50-446/99-10 on 990510-0628.Violations Noted & Being Treated as Ncvs, Consistent with App C of Enforcement Policy ML20210N1101999-08-0404 August 1999 Provides Supplemental Info to Util 990623 License Amend Request 99-005 Re Bypassing DG Trips.Info Replaces Info Contained in Subject Submittal in Attachment 2,Section II, Description of TS Change Request ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20210J2301999-08-0202 August 1999 Forwards Amend 96 to CPSES Ufsar.Replacement of FSAR Figures with Plant Process Flow Diagrams Meets Intent & Requirements of NRC Reg Guide 1.70,Rev 2 ML20210J6071999-08-0202 August 1999 Forwards line-by-line Descriptions of Changes in Amend 96 to CPSES UFSAR Transmitted by Util Ltr TXX-99166,dtd 990802. Replacment of FSAR Figures with Plant Process Flow Diagrams Meets Intent & Requirements of NRC Reg Guide 1.70,rev 2 TXX-9916, Notifies NRC That CPSES Units 1 & 2,improved TS Implemented on 9907271999-08-0202 August 1999 Notifies NRC That CPSES Units 1 & 2,improved TS Implemented on 990727 TXX-9918, Forwards CPSES 10CFR50.59 Evaluation Summary Rept 0008,for 970802-990201 & CPSES Commitment Matl Change Evaluation Rept 0003,for 970802-9906301999-08-0202 August 1999 Forwards CPSES 10CFR50.59 Evaluation Summary Rept 0008,for 970802-990201 & CPSES Commitment Matl Change Evaluation Rept 0003,for 970802-990630 ML20210K2321999-07-29029 July 1999 Forwards Insp Repts 50-445/99-12 & 50-446/99-12 on 990530-0710.No Violations Noted ML20210G5861999-07-29029 July 1999 Forwards fitness-for-duty Program Performance Data for Six Month Period of Jan-June 1999 ML20210J0121999-07-27027 July 1999 Forwards Summary of Methodology for Determination of NDE Measurement Uncertainty,In Response to Recent Discussions with NRC Re LAR 98-006 Concerning Rev to SG Tube Plugging Criteria TXX-9917, Provides Info Re Augmented Inservice Insp Plan,Which Requires Periodic Insp of Rv Head & Internals Lifting Devices at CPSES1999-07-26026 July 1999 Provides Info Re Augmented Inservice Insp Plan,Which Requires Periodic Insp of Rv Head & Internals Lifting Devices at CPSES ML20210F3121999-07-26026 July 1999 Responds to GL 99-02, Laboratory Testing of Nuclear-Grade Activated Charcoal, ML20210D8231999-07-23023 July 1999 Forwards Safety Evaluation of Relief Requests Re Use of 1998 Edition of Subsections IWE & Iwl of ASME Code for Containment Insp ML20210D3211999-07-21021 July 1999 Provides List of Estimates of Licensing Actions,In Response to Administrative Ltr 99-02,dtd 990603 ML20210C2931999-07-21021 July 1999 Supplements 880323 Response to NRC Bulletin 88-02, Rapidly Propagating...Sg Tubes, Non-proprietary WCAP-15010 & Proprietary Rev 0 to WCAP-15009, CP Unit 1 Evaluation for Tube Vibration... Encl.Proprietary Rept Withheld ML20209H0111999-07-16016 July 1999 Forwards Relief Request C-4 to CPSES Unit 2 ISI Program for Approval ML20210C3331999-07-16016 July 1999 Forwards Exam Repts 50-445/99-301 & 50-446/99-301 on 990618- 24.Exam Included Evaluation of Six Applicants for Senior Operator Licenses ML20209H2551999-07-16016 July 1999 Forwards ISI Summary Rept for Fourth Refueling Outage of CPSES Unit 2 & Containment ISI Summary Rept for Fourth Refueling Outage of CPSES Unit 2,per ASME Boiler & Pressure Vessel Code,Section Xi,Paragraph IWA-6230 1999-09-07
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARTXX-9924, Forwards Responses to Questions by NRC Re Application for Amends to Licenses NPF-87 & NPF-89,by Incorporating Changes Increasing RWST low-level Setpoint from Greater than But Equal to 40% to Greater than But Equal to 45% of Span1999-10-22022 October 1999 Forwards Responses to Questions by NRC Re Application for Amends to Licenses NPF-87 & NPF-89,by Incorporating Changes Increasing RWST low-level Setpoint from Greater than But Equal to 40% to Greater than But Equal to 45% of Span TXX-9923, Forwards Monthly Operating Repts for Sept 1999 for CPSES, Units 1 & 2,per Plant TS 5.6.4.No Failures of Challenges to PORVs of SV for Units Occurred1999-10-15015 October 1999 Forwards Monthly Operating Repts for Sept 1999 for CPSES, Units 1 & 2,per Plant TS 5.6.4.No Failures of Challenges to PORVs of SV for Units Occurred ML20217E7951999-10-12012 October 1999 Forwards COLR for Unit 1,Cycle 8,per TS 5.6.5 ML20216J5571999-10-0101 October 1999 Provides Final Response to GL 98-01,suppl 1, Y2K Readiness of Computer Sys at Npps TXX-9922, Forwards Revised COLR, for Cycle 5 for Unit 21999-10-0101 October 1999 Forwards Revised COLR, for Cycle 5 for Unit 2 ML20212G0721999-09-24024 September 1999 Forwards Rev 4 to Augmented Inservice Insp Plan for CPSES, Unit 1. Future Changes & Revs to Unit 1 Augmented Inservice Insp Plan Will Be Available on Site ML20212H0461999-09-24024 September 1999 Forwards Rev 6 to CPSES Glen Rose,Tx ASME Section XI ISI Program Plan for 1st Interval on 990820 TXX-9921, Suppls 981221 LAR 98-010 to Licenses NPF-87 & NPF-89, Clarfying Conditions of Use Re Analytical Methods Used to Determine Core Operating Limits,Per Telcon with NRC1999-09-10010 September 1999 Suppls 981221 LAR 98-010 to Licenses NPF-87 & NPF-89, Clarfying Conditions of Use Re Analytical Methods Used to Determine Core Operating Limits,Per Telcon with NRC ML20211L9871999-09-0303 September 1999 Forwards Rev 31 to Technical Requirements Manual. All Changes Applicable to Plants Have Been Reviewed Under Util 10CFR50.59 Process & Found Not to Include Any USQs TXX-9915, Responds to 990701 & 0825 RAI Telcons Re Spent Fuel Pool Temp,Per LAR 98-008,which Requested Increase in Spent Fuel Storage capacity.Marked-up Page 4-1 of CPSES Fuel Storage Licensing Rept, Encl1999-09-0303 September 1999 Responds to 990701 & 0825 RAI Telcons Re Spent Fuel Pool Temp,Per LAR 98-008,which Requested Increase in Spent Fuel Storage capacity.Marked-up Page 4-1 of CPSES Fuel Storage Licensing Rept, Encl ML20211K2231999-08-31031 August 1999 Forwards Txu Electric Comments of Rvid,Version 2 ML20211G1081999-08-26026 August 1999 Responds to NRR Staff RAI Re Util Mar 1999 Submittal for NRC Review & Approval of Changes to CPSES Emergency Classification Procedure ML20211G7301999-08-26026 August 1999 Forwards Revs 29 & 30 to CPSES Technical Requirements Manual (Trm). Attachments 1 & 2 Contain Description of Changes for Revs 29 & 30 Respectively ML20211G3441999-08-25025 August 1999 Forwards Response to NRC RAI on LAR 98-010 for Cpses,Units 1 & 2.Communication Contains No New Licensing Commitments Re Cpses,Units 1 & 2 ML20210U3981999-08-17017 August 1999 Forwards Monthly Operating Repts for July 1999 for CPSES, Units 1 & 2,per TS 6.9.1.5.No Failures or Challenges to PORVs or SVs for Plant Occurred ML20211C0991999-08-17017 August 1999 Forwards Rev 3 to ASME Section XI ISI Program Plan,Unit 2 - 1st Interval, Replacing Rev 2 in Entirety TXX-9919, Forwards Relief Request A-3,Rev 1 to Unit 1 ISI Program,Per Conversations Between NRC & Txu Electric on 9908021999-08-16016 August 1999 Forwards Relief Request A-3,Rev 1 to Unit 1 ISI Program,Per Conversations Between NRC & Txu Electric on 990802 ML20210R6561999-08-13013 August 1999 Forwards Response to NRR 990805 Telcon RAI Re License Amend Request 98-010,to Increase Power for Operation of CPSES Unit 2 to 3445 Mwth & Incorporating Addl Changes Into Units 1 & 2 TS ML20210S6411999-08-12012 August 1999 Informs That Wg Guldemond,License SOP-43780,is No Longer Performing Licensed Duties.Discontinuation of License Is Requested ML20210N1101999-08-0404 August 1999 Provides Supplemental Info to Util 990623 License Amend Request 99-005 Re Bypassing DG Trips.Info Replaces Info Contained in Subject Submittal in Attachment 2,Section II, Description of TS Change Request TXX-9918, Forwards CPSES 10CFR50.59 Evaluation Summary Rept 0008,for 970802-990201 & CPSES Commitment Matl Change Evaluation Rept 0003,for 970802-9906301999-08-0202 August 1999 Forwards CPSES 10CFR50.59 Evaluation Summary Rept 0008,for 970802-990201 & CPSES Commitment Matl Change Evaluation Rept 0003,for 970802-990630 ML20210J2301999-08-0202 August 1999 Forwards Amend 96 to CPSES Ufsar.Replacement of FSAR Figures with Plant Process Flow Diagrams Meets Intent & Requirements of NRC Reg Guide 1.70,Rev 2 ML20210J6071999-08-0202 August 1999 Forwards line-by-line Descriptions of Changes in Amend 96 to CPSES UFSAR Transmitted by Util Ltr TXX-99166,dtd 990802. Replacment of FSAR Figures with Plant Process Flow Diagrams Meets Intent & Requirements of NRC Reg Guide 1.70,rev 2 TXX-9916, Notifies NRC That CPSES Units 1 & 2,improved TS Implemented on 9907271999-08-0202 August 1999 Notifies NRC That CPSES Units 1 & 2,improved TS Implemented on 990727 ML20210G5861999-07-29029 July 1999 Forwards fitness-for-duty Program Performance Data for Six Month Period of Jan-June 1999 ML20210J0121999-07-27027 July 1999 Forwards Summary of Methodology for Determination of NDE Measurement Uncertainty,In Response to Recent Discussions with NRC Re LAR 98-006 Concerning Rev to SG Tube Plugging Criteria TXX-9917, Provides Info Re Augmented Inservice Insp Plan,Which Requires Periodic Insp of Rv Head & Internals Lifting Devices at CPSES1999-07-26026 July 1999 Provides Info Re Augmented Inservice Insp Plan,Which Requires Periodic Insp of Rv Head & Internals Lifting Devices at CPSES ML20210F3121999-07-26026 July 1999 Responds to GL 99-02, Laboratory Testing of Nuclear-Grade Activated Charcoal, ML20210C2931999-07-21021 July 1999 Supplements 880323 Response to NRC Bulletin 88-02, Rapidly Propagating...Sg Tubes, Non-proprietary WCAP-15010 & Proprietary Rev 0 to WCAP-15009, CP Unit 1 Evaluation for Tube Vibration... Encl.Proprietary Rept Withheld ML20210D3211999-07-21021 July 1999 Provides List of Estimates of Licensing Actions,In Response to Administrative Ltr 99-02,dtd 990603 ML20209H2551999-07-16016 July 1999 Forwards ISI Summary Rept for Fourth Refueling Outage of CPSES Unit 2 & Containment ISI Summary Rept for Fourth Refueling Outage of CPSES Unit 2,per ASME Boiler & Pressure Vessel Code,Section Xi,Paragraph IWA-6230 ML20209H0111999-07-16016 July 1999 Forwards Relief Request C-4 to CPSES Unit 2 ISI Program for Approval ML20209G0721999-07-13013 July 1999 Forwards Monthly Operating Repts for June 1999 for CPSES, Units 1 & 2,per TS 6.9.1.5.No Failures or Challenges to PORVs of SV Occurred During Reporting Period ML20209F0681999-07-0909 July 1999 Informs That Effective 990514,TU Electric Formally Changed Name to Txu Electric.Change All Refs of TU Electric to Txu Electric on Correspondence Distribution Lists ML20209E0421999-07-0909 July 1999 Forwards Response to NRC Request for Addl Info on LAR 98-010.Attachment 1 Is Affidavit for Info Supporting LAR 98-010 ML20209B6021999-06-30030 June 1999 Submits Second Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Readiness Disclosure for Reporting Status of Facility Y2K Readiness Encl ML20195J6981999-06-15015 June 1999 Provides Addl Info Related to Open Issue,Discussed in 990610 Conference Call with D Jaffe Re ISI Program Relief Request L-1 Submitted by Util on 980220 ML20196A4921999-06-15015 June 1999 Forwards Rev 30 to Physical Security Plan.Rev Withheld,Per 10CFR73.21 ML20195J0491999-06-14014 June 1999 Submits Response to RAI Re Implementation of 1.0 Volt Repair Criteria ML20195J0651999-06-14014 June 1999 Submits Response to RAI Re GL 95-07, Pressure Locking & Thermal Binding of Safety Related Power Operated Gate Valves 05000445/LER-1999-001, Forwards LER 99-001-00, Some Electrical Contacts for RCS Pressure Relief Valves Were Not Included in Surveillance Testing Procedures. New Licensing Commitments Identified in Attachment 11999-06-0808 June 1999 Forwards LER 99-001-00, Some Electrical Contacts for RCS Pressure Relief Valves Were Not Included in Surveillance Testing Procedures. New Licensing Commitments Identified in Attachment 1 ML20195F0091999-06-0808 June 1999 Forwards Response to RAI Re Units 1 & 2 ISI Program for Relief Requests E-1 & L-1.Communication Contains No New Licensing Basis Commitments Re Cpses,Units 1 & 2 ML20207E1921999-05-28028 May 1999 Submits Updated Request for NRC Staff to Review & Approve Certain Changes to CPSES Emergency Plan Submitted in 981015 & s Prior to Changes Being Implemented at CPSES ML20207E1711999-05-28028 May 1999 Supplements 990526 LAR 99-004 as TU Electric Believes Extingency Exists in That Proposed Amend Was Result of NOED Granted to Prevent Shudown of CPSES Unit 1 ML20207D9841999-05-26026 May 1999 Requests That NRC Exercise Enforcement Discretion to Allow Cpses,Unit 1 to Remain in Mode 1,power Operation,Without Having Performed Svc Test,Per SR 4.8.2.1d on Unit 1 Battery BT1ED2 ML20195B6351999-05-25025 May 1999 Submits Response to RAI Re GL 95-07, Pressure Locking & Thermal Binding of Safety Related Power Operated Gate Valves TXX-9912, Forwards Txu Electric (Formerly TU Electric) CPSES Emergency Preparedness Exercise Scenario Manual for 990721-22,Graded Exercise1999-05-21021 May 1999 Forwards Txu Electric (Formerly TU Electric) CPSES Emergency Preparedness Exercise Scenario Manual for 990721-22,Graded Exercise ML20206U1981999-05-20020 May 1999 Forwards Form 10K Annual Rept,Per 10CFR50.71(b). Communication Contains No New Licensing Basis Commitments Re Cpses,Units 1 & 2 ML20196L1931999-05-20020 May 1999 Forwards MOR for Apr 1999 for Cpses,Units 1 & 2.During Reporting Period There Have Been No Failures or Challenges to Power Operated Relief Valves or Safety Valves TXX-9911, Forwards non-proprietary & Proprietary Responses to RAI Re LAR 98-010 by Incorporating Attached Changes Into CPSES Unit 2 OL NPF-89 & CPSES Units 1,OL NPF-87 & 2 TS to Increase Licensed Power.W & Caldon Proprietary Responses Withheld1999-05-14014 May 1999 Forwards non-proprietary & Proprietary Responses to RAI Re LAR 98-010 by Incorporating Attached Changes Into CPSES Unit 2 OL NPF-89 & CPSES Units 1,OL NPF-87 & 2 TS to Increase Licensed Power.W & Caldon Proprietary Responses Withheld 1999-09-03
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Log # TXX-99087 File # 10013 Ref. # 10CFR50.54q nlELECTRIC April 7,1999 C. lance'thavy Senior Mce President
& PrincipalNuclear Officer U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION CHANGES TO CPSES EMERGENCY PLAN REF: (1) TU Electric letter logged TXX-98207 from C. L. Terry to the NRC dated October 15,1998 (2) Telephone conversations on March 24 and April 1,1999, between TU Electric representatives and Messrs. Tim. L. Polich, David H. Jaffe and Ed Fox of NRR Gentlemen:
- The purpose of this letter is to respond to a NRR staff request for additional information concerning TU Electric's October 1998 submittal for NRC review and approval of changes to the CPSES Emergency Plan (Reference 1). The request for additional information was discussed in telephone communications between TU Electric and the NRR staff as documented above (Reference 2).
The attachments to this letter provide the additional information in the form of revised change descriptions and/or justifications (Attachment 1) and supplemental plan changes ;
(Attachment 2). ' As discussed in the referenced telephone communications, the enclosed l informatioil is intended to support, modify and/or clarify those changes previously requested in TU Electric's letter TXX-98207. ,
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9904140022 990407 PDR ADOCK 05000445 F PDR _
COMANCllE PEAK SILAM E1.ECTRIC STATION P.O. Box 1002 Glen Rose, Texas 76043-1002
r-TXX-99087 Page 2'oT 2 If there are any questions concerning this information, please contact Mr. Norman Hood, Emergency Planning Manager, at (254) 897-5889.
This communication contains no new licensing basis commitments regarding CPSES Units 1 and ?.
l Sincerely, C. L Terry By:
D. R. Woodlan l Docket Licensing Manager l CLW/grj Attachments l
c- Mr. E. W. Merschoff, Region IV Mr. J. l. Tapia, Region IV (clo)
Ms. G. M. Good, Region IV Resident inspectors, CPSES (clo)
Mr. D. H. Jaffe, NRR l
Mr. E. Fox, NRR 1
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7 -.
Attachment 1 to TXX-99087 Page'1 of'6 DESCRIPTION AND JUSTIFICATION OF PROPOSED CHANGES TO THE CPSES EMERGENCY PLAN NOTE: The additional information provided in this attachment is annotated by bold print, strikeovers and change bars on the original description and justifications of proposed changes as submitted with letter TXX-98207 on Octouer 15, 1998. Only those original plan changes that were of concern to l the NRR reviewer and were discussed on March 24 and April 1. 1999, are further addressed in this attachment.
P. 1 2. Section 1.1.2 " Response" Change
Description:
Add a sentence that the Shift Manager (Emergnecy Coordinator) has the
- authority to call in any portion of the augmentation staff specified in Table 1.1 as may be required for emergency response (see supplemental plan change in Attachment 2).
Justification:
This statement clarifies that the Shift Manager has the standing general authority to call in any needed augmentation staff resources that may be required at the first signs of an emergency (i.e., prior to an Alert classification when onshift augmentation is " automatically required" via the staffing requirements of Table 1.1).
P. 1-10. Section 1.2.2 " Local Services Support" Change
Description:
Delete the sentence "The following organizations are the local support groups which have agreed to provide services if requested:" and the six (6) organizations immediately following in bullets. Revise the preceding i
sentence which refers to letters of agreements in Section 15.0. Appendix H.
to add the words "which identifies the local services support crganizations" l Justification:
t 1 This information is identified for deletion because it is redundant to information provided in Appendix H. Section 1.2.2 continues to state that letters of agreements are maintained with each local services support agency. Section 1.2.2 is also clarified to identify these local agencies by I reference to Appendix H which provides a list of the letters of agreement !
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a Attachment 1 to TXX-99087 Page 2 of'6 l maintained and includes those local support agencies being deleted from l Section 1.2;2. In addition. Section 15.0, Appendix H " Letters of Agreement" ;
is revised to add general functional statements of the support provided by each listed agency or organization (See supplemental plan change in Attachment 2).
Table 1.1 " Staffing Requirements For Emergencies" )
Change Descriptions:
! 1. Revise the task of providing technical support to the onshift STA by changing the " additions within minutes of Alert" column requirements to delete the Engineer responding at 40-minutes and add one additional member to the TSC Engineering Team responding at 70-minutes. This change effectivelv moves this technical support from a 40-minute response to a 70- ,
minute response. '
I
- 2. Revise footnote annotations of (*) and (**) to (a) and (b). respectively.
- 3. Add footnote (c) as applicable to the onshift minimum staffing column. This footnote allows. upon exercising certain compensating actions. a temporary exception to the onshift minimum staffing requirements due to unforseen circumstances (e.g. . personal illness).
- 4. Rey;"9 The tcMa entry under 0NSHIFT for the functional area of Com unications to change "I&C Technician" to " Communicator".
Justifications:
- 1. This change is related to one aspect of guidance found in NUREG-0654/ FEMA-REP-1 (Rev.1). Table B-1 " Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies", which recommends that the onshift STA position be supported within about 30-minutes with one additional individual who can provide technical support in the area of core / thermal hydraulics. ;
The CPSES Emergency Plan is currently approved for a 40-minute support j response.
The justification for allowing the change to a 70-minute responder (support would come via the TSC Engineering Team) is based on the following:
i a) The current understanding of the development and timing of reactor core degradation / melting during a postulated severe accident is documented in NUREG-1465 " Accident Source Terms for Light-Water Nuclear Power Plants" i published in 1994. NUREG-1465 information postulates that significant core l
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Attachment 1 to TXX-99087 Page3ofi j degradation / melting first occurs at longer times post-accident than previously believed (i.e. as postulated in the reactor safety study of WASH-1400, published in 13/5, which is one basis for NUREG-0654. Table B-1 response timing). NUREG-1465 contends that, for PWRs. during the first 30-minutes only a small fraction of the core inventory of radionuclides could be released into containment, and the onset of significant fuel damage occurs at over an hour post-accident. This more current understanding of the timing sequence for PWR post-accident core damage (i.e., damage occurs after a longer time period po:t-accident that previously believed) acts to l increase the creditable planning basis for the time from the initiating event to start of atmospheric release and therefore reduces the immediacy for providing augmented technical support. Additionally. it is recogr.ized l that information for quantifying fuel damage would not be required, or l available, until some time after the TSC is expected to be activated. For l example. NUREG-0737. Supp. 1. recognizes that determicing the level of fuel damage requires chemistry data / analysis and provides the expectation that j this sampling / analysis be completed within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> from the decision to do j l
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l b) The CPSES TSC Engineering Team (which would be increased from 3 to 4 members and assume this responsibility) would have sufficient personnel j resources to take on this technical support and " staffed / activated in a time frame (within 70 minutes of Alert) adequate to meet the required support needs (see item above). Additionally, the description of the TSC Engineering Team in Section 1.1.2.2 "CPSES Emergency Response Organization (ER0)" is revised to reflect four (4) augmenting technical support engineers, state that the TSC is located in close proximity to the Control Room (less than one minute transit time), and that contact is made with the Control Room, staff for providing assistance and if necessary or requested, that an engineer (s) can promptly relocate to the Control Room (See supplemental plan change in Attachment 2). The current Section 1.1.2.2 description of the TSC Engineering Team specifies the technical support available to the Control Room. This support includes " engineering data analysis ircluding core thermal hydraulics".
c) The recent development and availability of the CPSES Emergency Response Guidelines and Severe Accident Management Guidelines enhance the resources immediately available to the onshift operating crew and serve to make the initial response to a severe accident situatMn more manageable. The availability of these guidelines reduces the level and/or immediacy of augmentation support that may be required from the STA.
d) Since NUREG-0654 was issued in Novem a r. 1980, the accident assessment capabilities of nuclear power plants (ir:luding that for CPSES in the area of core / thermal hydraulic evaluation) have been greatly enhanced by the installation and application of new sy.. ems / equipment such as the Safety
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Attachment 1 to TXX-99087 Page' 4 of' 6 Parameter Display System (SPDS) anc the Radiation Monitoring System (PC-11 at CPSES). Parameters such as core exit thermocouple temperature, reactor vessel water level, containment radiation level, etc., are easily monitored and trended using these systems. These systems are readily available to assist Control Room staff in the early stages of an accident and were not accounted for in minimum staffing considerations of NUREG-0654. Table B-1.
- 2. This change enhances table readability and reduces the potential for misinterpretation.
- 3. This footnote addition allows a temporary exception to minimum staffing that is consistent with similar provisions allowed for the onsbift crew in the CPSES Technical Specifications and FSAR. Proposed footnote @ is intended to be used by the onshift staff, especially during backshift or weekends, in response to certain situations such as sudden illness, family emergency, or in the case of the CPSES pre-identified onshift medical responders (i.e. ,
Chemistry Technicians). to allow care for, or transport of, injureu plant personnel to the hospital. Similar temporary staffing exceptions are already allowed by eithe- the CPSES Technical Specification Administrative Controls (6.2.2), FSAR (Table 13.1 2) or the regulations of 10 CFR 50.54(m)(2)(I) note 1 for the minimum staffing of onshift Radiation Protection Technicians, Chemistry Technicians, Fire Brigade members or licensed operators.
1 These temporary exception criteria are recognized precedences with the NRC for allowing short time absence from required minimum onshift staffing to accommodate unforseen situations (e.g., unexpected individual sickness, accident. etc.). The short exception period proposed (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) and the i related compensatory measures (replacement call-in), coupled with the very small chance of an exception being exercised coincident with a declared i emergency event, make this change reasonable for ANY onshift position when I weighed against the benefit to an affected individual and the rather onerous logistics that would otherwise be required to meet 24-hours-a-day minimum staffing. It is inconsistent with the established precedences to not be able to apply some form of tem [arary exception criteria. It is also not practical or reasonable to add several additional personnel to the prescribed minimum staffing complement just to cover the remote chance that an individual will have to leave the site via a subject absence.
As an example in support of this discussion, a recent CPSES off-hours event occurred in which one of the two required onshift Radiation Protection Technicians had a family emeigency and left the site aft. ' getting supervision concurrence and promptly calling for a replacement Radiation Protection Technician. In this event the position was vacant for about 1
, hour (consistent with Operations procedures and the TS allowance) but was a literal noncompliance with the CPSES Emergency Plan's Table 1.1 minimum j staffing requirements. '
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Attachment 1 to TXX-99087 Page'5 of'6 The footnote limits the subject temporary exception criteria for use only during normal operations and specifically states that it is not applicable during declared emergencies.
- 4. This change is for clarification as the onshift I&C Technician becomes the dedicated communicator during an emergency (see supplemental plan change in Attachment 2).
P.12-2, Section 12.2.4 " Radiological Monitoring Drills" Change
Description:
Revise to provide consistency with other statements in the CPSES Emergency Plan and change the scope of monitoring activities to be performed in drills by CPSES personnel assigned to radiological monitoring teams.
Justification:
This change provides consistency with statements in CPSES Emergency Plan Sections 1.0 and 1.2.4 and clarifies that CPSES personnel assigned to radiological monitoring teams shall participate in annual drills for performance of air sampling / beta-gamma exposure rate determinations and should participate in drills to collect other environmental samples.
The proposed change takes partial exception to annual drills for sampling / analyzing some environmental sample media (NUREG-0654 criteria N.2.d) by implying that CPSES personnel are not required to-ccllect/mcnitor analyze media other than air (i .e., water vegetation and soil). -These-The environmental media of water, vegetation and soil are primarily a responsibility of State monitoring personnel. The State of Texas (Bureau of Radiation Control (BRC)) and CPSES have had discussions on this l responsib'lity and have agreed that the State has the lead for collecting / analyzing these sample media. If actcr. veg:.tation and 001' l CPSES personnel should only maintain an assistance capability in this area in order to assist. if necessary. State agencies duriv an Ingestion Pathway phase. This position is consistent with guiaance provided in NUREG-0654. Appendix 5 "Glosiary" which clarifies responsibilities that must be assigned among various organizations and states, in part: "Where the guidance in this document indicates a function that must be performed, emergency planners it all levels, must decide and agree among themselves, <
which organization is to perform such function."
Accordingly, as proposed in changes to Section 12.2.4, the plan states that CPSES personnel participate in drills to demonstrate the collection of water, vegetation, and soil. This is in addition to CPSES required annual
Attachment 1 to TXX-99087 l 1
Page 6 of6 drills for collecting and analyzing air samples and performing beta-gamma exposure rate determinations.
In Section 1.2.4 " State Agencies", the CPSES Emergency Plan currently states that the State of Texas (BRC) has the capability and responsibility to monitor and analyze environmentai samples. This is consistent with the agreement between CPSES and the BRC that the BRC has the primary ,
responsibility for collecting and analyzing the environmental media of water, vegetation and soil.
P. 0-4, Appendix 0 " Definitions" l
Change
Description:
I Add a definition titled " Periodic Definitions" that defines the terms
~ monthly", " quarterly".~ semi-annual or semi-annually", ~12 =ths", and I
" annual or annually" as used in the CPSES Emergency Plan.
Justification:
Change adds a definition of each frequency term used in describing events / tasks that are required to be performed on a regular periodic basis. ,
This change is added for clarification. The definitions added are specific '
to use in the CPSES Emergency Preparedness Program and are to be used in meeting timely implementation / maintenance of those periodic CPSES Emergency Plan requirements that are tracked and/or scheduled by the CPSES Emergency Planning or Nuclear Overview Department action item tracking systems. These definitions have been reviewed for consistency with guidance documents. The proposed definitior, of " annual" is consistent with information documented in NRC Inspection Report 50-445/446 95-21. Section 4.1.
The proposed periodic definition of "12 months" was withdrawn by TV Electric as discussed in the referenced telephone conversations (see suoplemental plan change in Attachment 2). It was concluded that the proposed TV Electric definition was inconsistent with the regulations and would probably require an exemption.
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