ML050100291

Issuance of Amendment Concerning one-time Allowed Extension for Train B Essential Cooling Water

ML050100291
Person / Time
Site:	South Texas
Issue date:	01/10/2005
From:	Jaffe D NRC/NRR/DLPM/LPD4
To:	Sheppard J South Texas
Jaffe D, NRR/DLPM, 415-1439
Shared Package
ML050120483	List: ML050100291
References
TAC MC5529
Download: ML050100291 (20)

Text

January 10, 2005 Mr. James J. Sheppard President and Chief Executive Officer STP Nuclear Operating Company South Texas Project Electric Generating Station P. O. Box 289 Wadsworth, TX 77483

SUBJECT:

SOUTH TEXAS PROJECT, UNIT 1 - ISSUANCE OF AMENDMENT CONCERNING ONE-TIME ALLOWED OUTAGE TIME EXTENSION FOR TRAIN B ESSENTIAL COOLING WATER (TAC NO. MC5529)

Dear Mr. Sheppard:

The Commission has issued the enclosed Amendment No. 169 to Facility Operating License No. NPF-76 for the South Texas Project, Unit 1. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated January 6, 2005. The license amendment is issued under the provisions of Section 50.91(a)(5) of Title 10 of the Code of Federal Regulations due to the time critical nature of the amendment.

The amendment revises TS 3.7.4, Essential Cooling Water System, and the associated TS for systems supported by the Essential Cooling Water (ECW), to extend the allowed outage time for an additional 7 days for ECW Train B as a one-time change for the purpose of making repairs to the Train B ECW pump.

A copy of our related Safety Evaluation is also enclosed. The Safety Evaluation describes the emergency circumstances under which the amendment was issued and the final determination of no significant hazards. The Notice of Issuance, addressing the final no significant hazards determination and opportunity for a hearing, associated with the emergency circumstances, will be included in the Commission's next biweekly Federal Register notice.

Sincerely,

/RA/

David H. Jaffe, Senior Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-498

Enclosures:

1. Amendment No. 169 to NPF-76

2. Safety Evaluation cc w/encls: See next page

January 10, 2005 Mr. James J. Sheppard President and Chief Executive Officer STP Nuclear Operating Company South Texas Project Electric Generating Station P. O. Box 289 Wadsworth, TX 77483

SUBJECT:

SOUTH TEXAS PROJECT, UNIT 1 - ISSUANCE OF AMENDMENT CONCERNING ONE-TIME ALLOWED OUTAGE TIME EXTENSION FOR TRAIN B ESSENTIAL COOLING WATER (TAC NO. MC5529)

Dear Mr. Sheppard:

The Commission has issued the enclosed Amendment No. 169 to Facility Operating License No. NPF-76 for the South Texas Project, Unit 1. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated January 6, 2005. The license amendment is issued under the provisions of Section 50.91(a)(5) of Title 10 of the Code of Federal Regulations due to the time critical nature of the amendment.

The amendment revises TS 3.7.4, Essential Cooling Water System, and the associated TS for systems supported by the Essential Cooling Water (ECW), to extend the allowed outage time for an additional 7 days for ECW Train B as a one-time change for the purpose of making repairs to the Train B ECW pump.

A copy of our related Safety Evaluation is also enclosed. The Safety Evaluation describes the emergency circumstances under which the amendment was issued and the final determination of no significant hazards. The Notice of Issuance, addressing the final no significant hazards determination and opportunity for a hearing, associated with the emergency circumstances, will be included in the Commission's next biweekly Federal Register notice.

Sincerely,

/RA/

David H. Jaffe, Senior Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-498

Enclosures:

1. Amendment No. 169 to NPF-76

2. Safety Evaluation cc w/encls: See next page DISTRIBUTION: See next page TS: ML NRR-100 PKG.: ML ACCESSION NO: ML050100291 NRR-058 OFFICE PDIV-1/PM PDIV- SPSB/SC SPLB/SC OGC PDIV-1/SC(A) IROB/SC 1/LA NAME DJaffe DBaxley MReinhardt SJones RHoefling MWebb TBoyce DATE 1/7/05 1/7/05 1/7/05 1/7/05 1/10/05 1/10/05 1/10/05 OFFICIAL RECORD COPY

DISTRIBUTION FOR SOUTH TEXAS PROJECT, UNIT 1 - ISSUANCE OF AMENDMENT Dated: January 10, 2005 PUBLIC PDIV-1 r/f GHill (2)

RidsNrrDlpmLpdiv (HBerkow)

RidsNrrDlpmLpdiv1 (MWebb)

RidsNrrPMDJaffe RidsNrrLADBaxley RidsNrrDipmIrob (TBoyce)

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JChung JDixon-Herrity

STP NUCLEAR OPERATING COMPANY DOCKET NO. 50-498 SOUTH TEXAS PROJECT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 169 License No. NPF-76

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by STP Nuclear Operating Company* acting on behalf of itself and for Texas Genco, LP, the City Public Service Board of San Antonio (CPS), AEP Texas Central Company, and the City of Austin, Texas (COA) (the licensees), dated January 6, 2005, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (I) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

• STP Nuclear Operating Company is authorized to act for Texas Genco, LP, the City Public Service Board of San Antonio, AEP Texas Central Company, and the City of Austin, Texas, and has exclusive responsibility and control over the physical construction, operation, and maintenance of the facility.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the enclosure to this license amendment and paragraph 2.C.(2) of Facility Operating License No. NPF-76 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 169, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. The STP Nuclear Operating Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. The license amendment is effective as of its date of issuance and shall be implemented immediately.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Michael K. Webb, Acting Chief, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: January 10, 2005

ATTACHMENT TO LICENSE AMENDMENT NO. 169 FACILITY OPERATING LICENSE NO. NPF-76 DOCKET NO. 50-498 Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

REMOVE INSERT 3/4 7-13 3/4 7-13

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 169 TO FACILITY OPERATING LICENSE NO. NPF-76 STP NUCLEAR OPERATING COMPANY, ET AL.

SOUTH TEXAS PROJECT, UNIT 1 DOCKET NO. 50-498

1.0 INTRODUCTION

By application dated January 6, 2005, STP Nuclear Operating Company (STPNOC or the licensee), requested changes to the Technical Specifications (TSs) for South Texas Project (STP), Unit 1.

The proposed changes would revise TS 3.7.4, Essential Cooling Water System, and the associated TS for systems supported by the Essential Cooling Water (ECW), to extend the allowed outage time (AOT) for an additional 7 days for ECW Train B as a one-time change for the purpose of making repairs to the Train B ECW pump. Specifically, the following footnote would be added to the required ACTION statement when only two of three ECW loops are OPERABLE:

On a one-time basis, the Allowed Outage Time for Unit 1 Train B Essential Cooling Water, and for those Technical Specification systems supported by Train B Essential Cooling Water (Technical Specifications 3.5.2, 3.5.6, 3.6.2.1, 3.6.2.3, 3.7.3, 3.7.7, and 3.7.14) is extended to 14 days. This one-time extension expires January 18, 2005 at 0400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br />.

2.0 REGULATORY EVALUATION

The NRC staff finds that the licensee in Section 5.2 of its January 6, 2005, submittal identified the applicable regulatory requirements.

Since the mid-1980s, the NRC has been reviewing and granting improvements to TS that are based, at least in part, on probabilistic risk assessment (PRA) insights. In its final policy statement on TS improvements of July 22, 1993, the NRC stated that it expects that licensees, in preparing their TS-related submittals, will utilize any plant-specific PSA (probabilistic safety assessment) or risk survey and any available literature on risk insights and PSAs. Similarly, the NRC staff will also employ risk insights and PSAs in evaluating TS-related submittals. Further, as a part of the Commission's ongoing program of improving TSs, it will continue to consider methods to make better use of risk and reliability information for defining future generic TS requirements. The NRC reiterated this point when it issued the revision to 10 CFR 50.36,

"Technical Specifications," in July 1995. In August 1995, the NRC adopted a final policy statement on the use of PRA methods in nuclear regulatory activities that improve safety decision making and regulatory efficiency. The PRA policy statement included the following points:

1. The use of PRA technology should be increased in all regulatory matters to the extent supported by state-of-the-art in PRA methods and data and in a manner that compliments the NRC's deterministic approach and supports the NRC's traditional defense-in-depth philosophy.

2. PRA and associated analyses (e.g., sensitivity studies, uncertainty analyses, and importance measures) should be used in regulatory matters, where practical within the bounds of the state-of-the-art, to reduce unnecessary conservatism associated with current regulatory requirements.

3. PRA evaluations in support of regulatory decisions should be as realistic as practicable and appropriate supporting data should be publicly available for review.

In conclusion, based on the deterministic and PRA considerations discussed in this submittal, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

3.0 TECHNICAL EVALUATION

The NRC staff has reviewed the licensee's regulatory and technical analyses in support of its proposed license amendment which is described in the licensee's submittal.

The licensees January 6, 2005, submittal is risk-informed in that the licensee considered deterministic1 and probabilistic2 safety aspects. The NRC staff evaluated the deterministic and probabilistic assessments provided by the licensee.

3.1 Deterministic Evaluation 3.1.1 Description of the ECW The ECW system consists of three 50-percent capacity trains and provides cooling required for safety-related components during and after any design-basis accident such as a loss of coolant accident, loss of offsite power, or a safe shutdown earthquake. Additionally, the ECW system 1

A deterministic analysis is an assessment of the availability of safety equipment necessary to ameliorate the consequences of design basis accidents.

2 A probabilistic analysis is an assessment of the probability that given accident sequences will lead to core damage and/or a large early release of radioactivity.

functions during normal operation and other non-emergency operating modes to transfer heat loads from service equipment to the essential cooling pond. The ECW system provides cooling water to the following components during all emergency and non-emergency modes of operation:

! Standby Diesel Generator (DG) Inter-cooler

! Standby DG Auxiliary Equipment Skid Coolers (Note that the Standby DG Technical Specification allowed outage time is 14 days. Consequently, there is no need to extend the proposed AOT extension to the Standby DG.)

! Essential Heating, Ventilating and Air Conditioning Chillers (TS 3.7.14), which support the following:

-Emergency Core Cooling System (TS 3.5.2)

-Containment Spray System (TS 3.6.2.1)

-Control Room Cleanup and Filtration (TS 3.7.7)

! Component Cooling Water Pump Supplementary Cooler

! Component Cooling Water Heat Exchanger (TS 3.7.3), which supports the following:

-Emergency Core Cooling System (TS 3.5.2)

-Residual Heat Removal System (TS 3.5.6)

-Reactor Containment Fan Coolers (TS 3.6.2.3)

Heat rejection to the ECW system during either normal operation, normal shutdown, or design basis accident (DBA) conditions is accomplished by three 50-percent capacity cooling water loops, each having its own pump, motor, self-cleaning strainer, piping, valves, and instrumentation. Each loop contains one set of Standby DG heat exchangers, one Component Cooling Water (CCW) heat exchanger, one essential chiller condenser, and one CCW pump supplementary cooler. Cooling water is supplied to each of these components during all modes of operation, whether or not the particular equipment is operating. An ECW loop is required to operate whenever its corresponding CCW loop is in operation.

In the event of Loss of Offsite Power (LOOP), power to the ECW pumps is supplied by the Emergency Safety Feature (ESF) buses, which are supplied by the Standby DG. Each Class 1E ESF bus provides electrical power to its respective ECW system cooling loop.

3.1.2 Evaluation of Proposed Change to TS 3.7.4 Under the current requirements of TS 3.7.4, if a train of ECW is inoperable, the Action Statement for TS 3.7.4 requires that three trains of ECW be restored to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. The application dated January 6, 2005, would extend this 7 day AOT, for the specific case of the current Train B ECW outage, to a total of 14 days.

Section 9.2.1.2.2.3 of the South Texas Project Updated Final Safety Analysis Report, Operation Mode During and After a DBA, indicates that a minimum of two trains of ECW is required to operate following a DBA. Thus during the proposed extended AOT, sufficient ECW and ECW-supported systems capacity will be operable to safely shutdown and cooldown the plant following a DBA. Moreover, it is not likely that additional ECW Trains will become unexpectedly inoperable since (1) compensatory measures proposed by the licensee will minimize the challenge to operable equipment and (2) the inoperability experienced in the Train B ECW pump, the result of a degraded pump bearing, was not the result of sudden failure of the pump but rather the result of slow, observable degradation. While not expected, should a second ECW pump experience degradation of the type experienced in Train B, experience has shown that the degradation occurs slowly with ample time to safely shutdown the plant if needed.

3.1.2 Deterministic Conclusions Based on deterministic considerations, the NRC staff concludes that (1) sufficient ECW capacity is available during the proposed extended AOT to safely shutdown and cooldown the plant following a DBA and (2) it is not likely that additional ECW capability will become unexpectedly inoperable during the extended AOT. Accordingly, based on deterministic considerations, the proposed change to TS 3.7.4 is acceptable.

3.2 Probabilistic Evaluation 3.2.1 Risk Assessment Evaluation In evaluating the risk information submitted by the licensee, the NRC staff followed the three-tiered approach documented in Regulatory Guide (RG) 1.177, An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications.

Under the first tier, the staff determines if the proposed change is consistent with the NRCs Safety Goal Policy Statement, as documented in RG 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant Specific Changes to the Licensing Basis." Specifically, the first tier objective is to ensure that the plant risk does not increase unacceptably during the period the equipment is taken out of service.

The second tier addresses the need to preclude potentially high-risk plant configurations that could result if additional equipment, not associated with the proposed change, is taken out of service during the proposed 7-day AOT extension.

The third tier addresses the establishment of a configuration risk management program for identifying risk-significant configurations resulting from maintenance or other operational activities, and taking appropriate compensatory measures to avoid such configurations.

3.2.2 Basis and Quality of Risk Assessment The licensee used its Probabilistic Risk Assessment (PRA) model and appropriate conservative assumptions to assess the risk increase associated with operation at power for a period of 7 additional days without an operable Train B of ECW. The risk consideration included maintaining defense-in-depth and quantifying risk to determine the change in Core Damage

Frequency (CDF) and Large Early Release Frequency (LERF) as a result of the proposed 7-day AOT extension for the Train B of ECW. Also, the licensee is maintaining the continuous on-line risk management program to control the performance of other risk-significant tasks during the extended AOT period with consideration of specific compensatory measures to minimize risk. The dominant accident sequences contributing to the assessed risk increase include the occurrence of conditions due to the unavailability of and demand for the use of the Train B of ECW. Current TS allows one ECW Train to be out of service for 7 days.

The NRC staff evaluated the quality of the PRA models, major assumptions, and data used in the risk assessment. This evaluation compared the applicable findings from the NRC staffs review of the PRA with the NRCs Standardized Plant Analysis Risk Model (SPAR), Version 3.2, employing NRC PRA quantification tool, SAPHIRE version 7, and NRC Manual Chapter 0609, Appendix H for LERF, as well as findings from similar evaluations of similar plants.

3.2.3 Risk Impact of the Proposed Change (Tier 1)

An acceptable approach to risk-informed decisionmaking is to show that the proposed change to the design basis meets several key principles. One of these principles is to show that the proposed change results in a small but acceptable increase in risk in terms of CDF and LERF, and is consistent with the NRCs Safety Goal Policy Statement. Acceptance guidelines for meeting this principle are presented in RG 1.174. The licensee used its PRA model to calculate risk increases due to the AOT extension of 7 days, during which two trains of ECW were available. Both the incremental conditional core damage probability (ICCDP) and the incremental conditional large early release probability (ICLERP) were assessed. These quantities are a measure of the increase in probability of core damage and large early release, respectively, during a single outage that would last for the entire duration allowed by the proposed change. Based on the one-time extension of 7 days from January 11, 2005 to January 18, 2005, the incremental changes in CDF and LERF are summarized in the following table:

Baseline Incremental Baseline Incremental CDF Change in LERF Change in CDP LERP Prior to AOT Extension (without 92-day 9.1E-06/yr 5.2-07/yr EDG outage for 12/3-/2003 - 03/31/2004)

Increase due to the 92 days outage 2.4E-06/yr 1.8E-07/yr New Baseline CDF 1.15-05/yr 7.0E-07/yr Increase with 7-day AOT Extension (using NRC SAPHIRE V7, SPAR 3.2 2.4E-07 1.4E-08 New Baseline CDF after 7-day AOT extension based on annualized ICCDP 1.17E-05/yr 7.14E-07/yr

During the proposed extension period, the baseline total CDF and LERF have been increased by 2.4E-06/yr and 1.8ER-07/yr respectively, contributed by one time 92-day extension of the AOT under the TS 3.8.1.1 for an inoperable emergency DG as addressed in Amendment No.

149 for STP, Unit 2, issued on December 30, 2003. The new baseline values for this proposed change under TS 3.7.4 would be 1.15E-05/yr for CDF and 7.0E-7/yr for LERF. However, the increases in CDF and LERF due to the proposed AOT extension are well within the acceptable range.

3.2.4 Avoidance of High Risk Plant Configurations (Tier 2)

The licensees PRA will identify and estimate major risk contributors of plant configurations, contributing event sequences, and associated cutsets. Potential major risk contributors include plant equipment failures, human errors and common cause failures. Insights from the risk assessment would be used in identifying and monitoring the plant configurations or conditions that may lead to significant risk increases during the AOT extension. The NRC staff finds that the proposed precautions, as well as the proposed compensatory measures as addressed in the January 6, 2005, application, are adequate for preventing plant configurations or conditions that may increase risk significantly. In conclusion, there is reasonable assurance that high risk plant configuration will not occur during the proposed 7-day AOT extension.

3.2.5 Risk-Informed Configuration Risk Management (Tier 3)

The intent of risk-informed configuration risk management is to ensure that plant safety is maintained and monitored. A formal commitment to maintain a configuration risk management program (CRMP) is necessary on the part of a utility prior to implementation of a risk-informed TS. The requirement to maintain a CRMP is contained in TS 6.8.3k. This program can support the licensees decision-making regarding the appropriate actions to control risk whenever a risk-informed TS LCO is entered.

3.2. 6 Probabilistic Evaluation Conclusions The proposed 7 day extension of the AOT for the Train B of ECW results in an increase in CDF and LERF but these increases are well within the acceptable range. The NRC staff concludes that use of CRMP and other compensatory measures will effectively prevent high-risk configurations. Accordingly, from a risk perspective, the proposed change to TS 3.7.4 is acceptable.

3.3 Conclusions Regarding Change to TS 3.7.4 The NRC staff has evaluated the licensees proposed change to TS 3.7.4 and concludes that the licensees proposed 14-day AOT for ECW Train B meets the NRC staffs deterministic and probabilistic standards for such AOT extensions. Accordingly, it is acceptable to change TS 3.7.4, ACTION statement by applying the following footnote:

On a one-time basis, the Allowed Outage Time for Unit 1 Train B Essential Cooling Water, and for those Technical Specification systems supported by Train B Essential Cooling Water (Technical Specifications 3.5.2, 3.5.6, 3.6.2.1, 3.6.2.3, 3.7.3, 3.7.7, and

3.7.14) is extended to 14 days. This one-time extension expires January 18, 2005 at 0400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br />.

4.0 REGULATORY COMMITMENTS During the 7 additional days of the ECW AOT extension, the licensee has made the following commitments as contained in Attachment 2 to the January 6, 2005 application:

The following compensatory measures have already been implemented and will be continued during the maintenance on Train B ECW:

! Station Management has been briefed on this subject.

! STPNOC will not perform any planned voluntary maintenance in Unit 1 during the extended AOT (EAOT) that would increase the ICCDP.

! STPNOC will reduce the duration of maintenance on ECW Pump 1B as much as practical by using a 24-hour work schedule, dedicated project management, and dedicated support for the activity (e.g., engineering).

! STPNOC will increase station awareness via daily status meetings throughout the EAOT.

In addition to the risk management actions listed above, the following additional compensatory actions have been implemented and will be continued during the EAOT for Train B ECW:

1. STPNOC has notified the transmission/distribution service providers (TDSPs) of the condition and of the maintenance restrictions required for the STP switchyard.

2. STPNOC has installed EAOT protected train signs.

3. STPNOC will not perform any planned maintenance on required systems, subsystems, trains, components, and devices that depend on the A and C trains of equipment during the EAOT. *

4. STPNOC will not perform any planned maintenance that could result in an inoperable open containment penetration. *

5. STPNOC will purge containment only for pressure control and only for short duration. *

6. STPNOC will not perform any planned maintenance on the Unit 1 Technical Support Center Diesel Generator. *

7. STPNOC will not perform any planned maintenance on Load Center 1W. *

8. STPNOC will not perform any planned maintenance on Motor Control Center 1G8. *

9. STPNOC will not perform any planned maintenance on the Positive Displacement Charging Pump. *

10. STPNOC will ensure that no planned maintenance is performed on the Emergency Transformer or the 138KV Blessing to STP and Lane City to Bay City lines. *

11. STPNOC will ensure that no maintenance activities are performed in the switchyard that could directly cause a Loss of Offsite Power event unless required to ensure the continued reliability and availability of the offsite power sources. *

12. STPNOC will not perform any planned maintenance on the turbine-driven auxiliary feedwater pump. *

13. STPNOC has verified that the station is not under hurricane, tornado, or flood watches or warnings.

14. STPNOC has verified with the TDSP that no adverse weather conditions exist in the areas of the offsite power supplies that challenge the stability of grid.

15. STPNOC will not perform any planned maintenance on Switchgear 1L or 1K. *

16. STPNOC will consider approval of all unscheduled emergent work in accordance with the STP work process program.

• Explicitly modeled in the STP PRA.

Furthermore, the physical arrangement of the STP facility allows for the capability to cross-connect ECW trains to supply selected ECW loads and supply power to an ESF bus from a cross-train ESF diesel generator. These cross-tie capabilities are proceduralized and Operations will review these procedures prior to implementation of this amendment request.

It should be noted that STPNOC will continue to perform surveillance testing that does not increase the ICCDP.

The above compensatory measures have been entered as regulatory commitments in the licensees Commitment Management System, which complies with Nuclear Energy Institutes Document 99-04, Revision 0, "Guidelines for Managing NRC Commitment Changes." The NRC staff has reviewed the compensatory measures and how they will be controlled, and finds that the licensees commitments provide adequate assurance that safe plant operation will not be affected by the extended AOT for ECW Train B.

5.0 EMERGENCY CIRCUMSTANCES The NRCs regulations at 10 CFR 50.91 contain provisions for issuance of an amendment where the Commission finds that an emergency situation exists in that failure to act in a timely way would result in shutdown of a nuclear power plant. In such a situation, the NRC may issue a license amendment involving no significant hazards consideration without prior notice and opportunity for a hearing or for public comment. In such a situation, the Commission will not publish a notice of proposed determination on no significant hazards consideration, but will publish a notice of issuance under 10 CFR 2.106.

In this instance, an emergency situation exists in that the proposed amendment is needed to allow the licensee to preclude an unnecessary plant shutdown. In its January 6, 2005, application, the license stated that:

Beginning in mid-November 2004, ECW Train B Pump lubricating water flow started exhibiting a decreasing trend. Initially, the decreasing flow appeared to follow a declining ECW Pond temperature. When temperatures started increasing in late December without a corresponding increase in lubricating water flow, a troubleshooting plan was initiated to determine the cause of the low flow condition. A fault-tree analysis was performed in order to identify possible causes for the decreasing lubricating water flow. This analysis identified three main potential causes for the decreasing lubricating water flow. These were: (1) a lubricating water line restriction or blockage, (2) an incorrect instrumentation reading, and (3) a problem with the ECW pump itself.

Following investigation and troubleshooting efforts that included lubricating water filter replacement, ultrasonic flow measurements to validate instrument readings, and a system walkdown, it was decided to perform an inspection of the Train B pumps gland seal and lubricating water inlet lantern ring to determine if a blockage or other problem existed at the entrance to the ECW pump. On January 4, 2005 at 0400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br />, the Train B pump was declared inoperable in order to perform this work, and TS 3.7.4 was entered.

During pump gland seal disassembly, the pump packing and lantern ring showed no discernible degradation. Additionally, boroscopic inspection showed no blockages within the lubricating water line. Based upon these findings, it was determined that a pump tear-down would be required to identify and correct the decreasing lubricating flow issue.

The following conditions were identified upon disassembly of the pump:

• The middle line shaft bearing had failed

• The O-ring between the intermediate bearing housing and lower enclosure column was damaged

• The lower shaft bearing, lower shaft and shaft sleeves were damaged

• The upper shaft bearing shows signs of wear An investigation to determine the root cause(s) of the Unit 1 Train B ECW pump damage has been initiated. As discussed above, STPNOCs routine monitoring of ECW

pump operating characteristics and trends (including lubricating water flow) led to the discovery of the Train B pump damage. The Unit 1 Train A and C ECW pumps, as well as all three Unit 2 ECW pumps are OPERABLE and continue to perform well, and no adverse pump operating trends are indicated for these other ECW pumps.

STPNOC will continue to monitor ECW pump operating characteristics and trends.

Should an adverse trend become evident for one of the other ECW pumps, STPNOC will evaluate the condition and take action as necessary in accordance with the Corrective Action Program.

It is anticipated that corrective maintenance, pump rebuild, and subsequent operability testing will be completed within the existing 7-day AOT. As stated above, the A and C Trains of Unit 1 ECW and all three Trains of Unit 2 ECW remain fully OPERABLE, and no similar lubricating water flow condition exists on these trains. The anticipated parts are onsite or readily available and work will be performed on a 24-hour basis. However, as a contingency, an additional 7 days, or a total Allowed Outage Time of 14 days, is being requested should unexpected conditions be discovered during the Train B ECW system repair and testing efforts.

As demonstrated above, entry into the required action of TS 3.7.4 and associated supported TS could not reasonably have been foreseen or anticipated. Routine monitoring of ECW pump operating characteristics and trends (including lubricating water flow) led to the discovery of the Train B pump damage. Therefore, STPNOC requests approval of this license amendment application on an emergency basis by January 11, 2005 at 0400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> (the end of the current Train B AOT) in order to avoid an unnecessary Unit 1 plant shutdown.

The Commission expects its licensees to apply for license amendments in a timely fashion. In this situation, the NRC staff has determined that the licensee has explained, as set forth above, why this emergency situation occurred and why it could not avoid this situation. Based on the licensees reasons set forth above, the NRC staff has determined that the licensee could not reasonably have foreseen the inoperability of the Train B ECW pump, and could not file the application sufficiently in advance of that event. Accordingly, the NRC staff has determined that the licensee made a timely application for the amendment, has not abused the emergency provisions of 10 CFR 50.91(a)(5), and did not itself create the emergency.

6.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION

DETERMINATION The Commissions regulation at 10 CFR 50.92(c) states that the Commission may make a final determination that a license amendment involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) result in a significant reduction in a margin of safety. The NRC staff has made a final determination that no significant hazards consideration is involved for the proposed amendment and that the amendment should be issued as allowed by the criteria contained in 10 CFR 50.91. The NRC staffs final determination is presented below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

Since only one train of components is affected by the condition and single failure is not considered while a plant is in an limiting condition for operation ACTION, the operable engineered safety feature trains are adequate to maintain the plant's design basis. Thus, this condition will not alter assumptions relative to the mitigation of an accident or transient event.

Considering compensatory action and risks involved in a plant shutdown, there is no discernable risk associated with extending the AOT for the ECW system and the systems it supports for an additional 7 days.

Based on this evaluation, there is no significant increase in the probability or consequence of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different accident from any accident previously evaluated?

Response: No.

This proposed action only extends an AOT and will not physically alter the plant.

No new or different type of equipment will be installed by this action. The changes in methods governing normal plant operation are consistent with current safety analysis assumptions. No change to the system as evaluated in the STP safety analysis is proposed.

Therefore, this proposed action does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

Considering compensatory action and risks involved in a plant shutdown, there is no significant risk associated with extending the AOT for the ECW system and the systems it supports for an additional 7 days.

Based on the availability of redundant systems, the compensatory actions that have been taken, and the extremely low probability of an accident that could not be mitigated by the available systems, it can be concluded that there is no significant reduction in the margin of safety.

7.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Texas State official was notified of the proposed issuance of the amendment. The State official had no comments.

8.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has made a final finding that the amendment involves no significant hazards consideration. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

9.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: J. Chung D. Jaffe Date: January 10, 2005

South Texas Project, Units 1 & 2 cc:

Senior Resident Inspector A. H. Gutterman, Esq.

U.S. Nuclear Regulatory Commission Morgan, Lewis & Bockius P. O. Box 910 1111 Pennsylvania Avenue, NW Bay City, TX 77414 Washington, DC 20004 C. Kirksey/C. M. Canady Mr. T. J. Jordan, Vice President City of Austin Engineering & Technical Services Electric Utility Department STP Nuclear Operating Company 721 Barton Springs Road P. O. Box 289 Austin, TX 78704 Wadsworth, TX 77483 Mr. J. J. Nesrsta S. M. Head, Manager, Licensing Mr. R. K. Temple STP Nuclear Operating Company City Public Service Board P. O. Box 289, Mail Code: N5014 P. O. Box 1771 Wadsworth, TX 77483 San Antonio, TX 78296 Environmental and Natural Resources Mr. C. A. Johnson/ R. P. Powers Policy Director AEP Texas Central Company P. O. Box 12428 P. O. Box 289 Austin, TX 78711-3189 Mail Code: N5022 Wadsworth, TX 77483 Jon C. Wood Cox Smith Matthews INPO 112 East Pecan, Suite 1800 Records Center San Antonio, TX 78205 700 Galleria Parkway Atlanta, GA 30339-3064 Director Division of Compliance & Inspection Regional Administrator, Region IV Bureau of Radiation Control U.S. Nuclear Regulatory Commission Texas Department of State Health Services 611 Ryan Plaza Drive, Suite 400 1100 West 49th Street Arlington, TX 76011 Austin, TX 78756 D. G. Tees/R. L. Balcom Brian Almon Texas Genco, LP Public Utility Commission P. O. Box 1700 William B. Travis Building Houston, TX 77251 P. O. Box 13326 1701 North Congress Avenue Judge, Matagorda County Austin, TX 78701-3326 Matagorda County Courthouse 1700 Seventh Street Bay City, TX 77414 November 2004

South Texas Project, Units 1 & 2 Susan M. Jablonski Office of Permitting, Remediation and Registration Texas Commission on Environmental Quality MC-122 P.O. Box 13087 Austin, TX 78711-3087 Mr. Terry Parks, Chief Inspector Texas Department of Licensing and Regulation Boiler Division P. O. Box 12157 Austin, TX 78711 Mr. Ted Enos 4200 South Hulen Suite 630 Ft. Worth, Texas 76109