ML070100198
| ML070100198 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 01/11/2007 |
| From: | Donohew J NRC/NRR/ADRO/DORL/LPLIV |
| To: | Sheppard J South Texas |
| Donohew J N, NRR/DORL, 415-1307 | |
| Shared Package | |
| ML070100249 | List: |
| References | |
| TAC MD3852 | |
| Download: ML070100198 (19) | |
Text
January 11, 2007 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 EMERGENCY AMENDMENT RE: ONE-TIME CHANGE TO LOSS OF POWER INSTRUMENTATION TECHNICAL SPECIFICATIONS (TAC NO. MD3852)
Dear Mr. Sheppard:
The Commission has issued the enclosed Amendment No. 176 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 December 20, 2006 (NOC-AE-06002096), as supplemented by letter dated December 28, 2006 (NOC-AE-06002101).
The amendment, for a one-time change, revised TS 3.3.2 for the loss of power (LOP) instrumentation (Functional Unit 8, loss of power) in TS Table 3.3-3, Engineered Safety Features Actuation System Instrumentation. A note is added to TS Table 3.3-3, Action 20, which is the TS-required action for inoperable LOP instrumentation, to allow a one-time provision for corrective maintenance on an inoperable Unit 1 LOP instrumentation channel when the number of operable channels are more than one less than the total number of channels. This provision expires 30 days after the amendment is approved.
A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.
Sincerely,
/RA/
Jack N. Donohew, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-498
Enclosures:
- 1. Amendment No. 176 to NPF-76
- 2. Safety Evaluation
cc w/encls: See next page
ML070100198 TS and License pages: ML070120155 OFFICE NRR/LPL4/PM NRR/LPL4/LA ITSB/BC EICB/BC OGC NRR/LPL4/BC NAME JDonohew LFeizollahi TKobetz IAhmed for AHowe AHodgdon DTerao DATE 1/11/07 1/11/07 1/10/07 1/10/07 1/11/07 1/11/07
STP NUCLEAR OPERATING COMPANY DOCKET NO. 50-498 SOUTH TEXAS PROJECT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 176 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 December 20, 2006, as supplemented by letter dated December 28, 2006, 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 attachment 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. 176, 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 by January 15, 2007.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
David Terao, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Facility Operating License No. NPF-76 and the Technical Specifications Date of Issuance: January 11, 2007
ATTACHMENT TO LICENSE AMENDMENT NO. 176 FACILITY OPERATING LICENSE NO. NPF-76 DOCKET NO. 50-498 Replace the following pages of the Facility Operating License and the Appendix A Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Insert License Page License Page TS Page TS Page 3/4 3-27 3/4 3-27
(1) The letter did not have an ADAMS accession number when the amendment was issued.
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 176 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 December 20, 2006 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML063610077), as supplemented by letter dated December 28, 2006 (ADAMS Accession No. MLXXXXXXXXX(1)), STP Nuclear Operating Company (STPNOC or the licensee) requested changes to the Technical Specifications (TSs) for South Texas Project (STP), Unit 1.
The proposed amendment is a one-time change that would revise TS 3.3.2, Engineered Safety Features Actuation System Instrumentation. The revision is for the loss of power (LOP) instrumentation (Functional Unit 8, loss of power) in TS Table 3.3-3, Engineered Safety Features Actuation System Instrumentation. A note would be added to TS Table 3.3-3, Action 20, which is the TS-required action for inoperable LOP instrumentation, to allow a one-time provision for corrective maintenance on an inoperable Unit 1 LOP instrumentation channel when the number of operable channels is more than one less than the total number of channels. This provision for corrective maintenance would expire 30 days after the amendment is approved.
2.0 BACKGROUND
AND JUSTIFICATION FOR EMERGENCY CHANGE In its letters, the licensee stated that one channel of diesel generator (DG) LOP instrumentation is currently inoperable and in the tripped condition in accordance with the TS action requirements. The corrective maintenance needed to restore the inoperable LOP instrumentation channel will require a second channel to be made inoperable and the TSs have no action for two inoperable channels; therefore, to make the second channel inoperable Limiting Condition for Operation (LCO) 3.0.3 would apply and have to be entered. LCO 3.0.3 allows 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for the licensee to make one of the two inoperable channels operable, or the licensee would be required to start shutting the unit down. The licensee stated that the corrective maintenance of the channel currently inoperable will take more than the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> allowed by LCO 3.0.3.
The licensee stated that, because of the increased exposure to a potential inadvertent engineered safety feature (ESF) actuation with having the two inoperable channels in trip of the four required to be operable for the ESF bus strip and the DG start/load, it is submitting this proposed amendment to limit the time operating in a configuration with one Train A LOP instrumentation channel in trip. It requested an expedited approval of the proposed amendment to allow facilitation of an early resolution of the Unit 1 condition.
In its letters the licensee provided the following justification for the expedited review by NRC of the proposed amendment. On December 1, 2006, the Unit 1 Train A sequencer received a strip signal from one of four channels of undervoltage and degraded voltage relays for the Train 4.16KV bus. Because sequencer actuation is a two-out-of-four logic and no signal was received from any of the other three of four channels, the strip signal received was not valid and the sequencer actuation did not occur. The licensee stated it placed the single inoperable channel in the trip condition, which is required by TS 3.3.2, and scheduled the corrective maintenance to make the channel operable by December 7, 2006, with the plan being to replace fuses. The pre-job review of the maintenance activity, however, caused the job to be rescheduled to December 14, 2006, and on December 14, maintenance personnel found indications that the potential transformer (PT) for the channel had failed.
Because of the design of the DG LOP instrumentation, the replacement of the PT will take several hours and access to the PT will require that the two channels of the Train A LOP instrumentation that share the same drawer be removed from service (i.e., the inoperable channel and the other channel in the same drawer). Since there is no TS 3.3.2 action for two inoperable channels of LOP instrumentation, LCO 3.0.3 would have to be entered, as stated above. The licensee stated that voluntary entry into LCO 3.0.3 is permissible for short durations (less than an hour) and for reasons other than operational convenience. Although this entry would not be for operational convenience, it would be for substantially longer than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The licensee is proposing to amend the TSs for two inoperable LOP channels on a bus to permit sufficient time to perform the corrective maintenance to restore the current inoperable LOP instrumentation channel to operable status.
The licensee went on to explain that even though the TSs allow continued operation with one channel of LOP instrumentation in the trip condition, operation in the configuration for an extended time exposes the plant to an invalid ESF actuation (ESF bus strip and start and load of standard diesel generator 11 (SDG11)) should another channel fail. Therefore, the corrective maintenance to restore the inoperable channel to operable status should be performed as soon as practicable. Also, this situation results in an unusual burden on the normal testing for the relays and the associated DG. With the A ESF bus LOP instrumentation failed and in trip, STP Unit 1 does not have power to the relay that provides reverse power protection to SDG11 when it is paralleled to the grid for surveillance testing. To minimize the exposure to any reverse power condition while the channel is inoperable, the licensee stated that it is running SDG11 at full load for 60 minutes (the TS requirement) instead of the normal 210 minutes (vendor recommendation). This protective relay does not affect the emergency function of the diesel to respond to any signal provided by the sequencer since it would not be paralleled to offsite power. Also, the licensee stated that it also has to perform trip actuating device operational tests (TADOTs) on the operable LOP instrument channels to be in compliance with TS surveillance requirements (SRs). Performing the TADOTs requires the inoperable channel to be bypassed while the other channel is tested. Placing the inoperable channel in bypass and restoring the channel to the trip condition after testing have the potential for a human performance error that would result in an ESF actuation that would unnecessarily challenge safety-related systems.
Because both the undervoltage and degraded voltage functions are in the tripped condition, the proposed note applies to Functional Unit 8 of TS Table 3.3-3; it is this function that includes undervoltage and degraded voltage channels (i.e., Functional Units 8.a, 8.b, 8.c).
The licensee went on to state that exigent approval of the proposed TS change is justified because the failure that caused the inoperable channel could not reasonably have been anticipated. In addition, the licensee has included the LOP instrumentation in its broad-scope risk-managed TS application, which will be the permanent TS resolution and the licensee has promptly prepared and submitted this proposed amendment to the Unit 1 TS. To minimize the time the channel is inoperable and reduce the potential for these unnecessary challenges to the DG and other ESF equipment, the licensee stated that it intends to restore the failed channel to service as early as practical and believes the potential challenges described above justify an exigent change to the TSs. Therefore, the licensee requested Nuclear Regulatory Commission (NRC) approval of the request by January 10, 2007, to allow corrective maintenance to be scheduled and performed before the next scheduled LOP instrument channel TADOT in TS Table 4.3-2, Engineered Safety Features Actuation System Instrumentation Surveillance Requirements, where the allowed surveillance test interval expires January 14, 2007.
3.0 REGULATORY EVALUATION
Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TSs as part of the license. The TSs ensure the operational capability of structures, systems, and components that are required to protect the health and safety of the public. The NRC's regulatory requirements related to the content of the TSs are contained in Section 50.36 of Title 10 of the Code of Federal Regulations (10 CFR 50.36) that requires that the TSs include items in the following categories: (1) safety limits, limiting safety systems settings, and limiting control settings; (2) LCOs; (3) SRs; (4) design features; and (5) administrative controls. In accordance with 10 CFR 50.36(c)(3), surveillance requirements are requirements relating to tests, calibration, or inspection to assure that the necessary quality of the systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.
As stated in 10 CFR 50.36(c)(2)(i), LCOs are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a[n] [LCO] of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specification... The remedial actions in the TSs are specified in terms of LCO conditions, required actions, and completion times (CTs) to complete the required actions. When an LCO is not being met, the CTs specified in the TSs are the time allowed in the TSs for completing the specified required actions. The conditions and required actions specified in the TSs must be acceptable remedial actions for the LCO not being met, and the CTs must be a reasonable time for completing the required actions.
The design of the DG LOP instrumentation is not being changed by this amendment.
Therefore, the regulatory requirements related to the design of safety-related instrumentation are not affected by the amendment.
4.0 TECHNICAL EVALUATION
4.1 Proposed TS Change In its supplemental letter, the licensee revised its proposed change to TS 3.3.2 and proposed to add the following note to TS Table 3.3-3, Action 20:
For Unit 1 Train A Loss of Power Instrumentation (Functional Unit 8.a, 8.b, & 8.c) only: In addition to the requirements of ACTION 20.b, the provision below shall apply. This provision shall expire 30 days after approval of the amendment.
With the number of OPERABLE channels more than one less than the Total Number of Channels, within one hour restore all but one channel per bus to OPERABLE status or enter applicable ACTION for the associated standby diesel generator made inoperable by the Loss of Power instrumentation.
The phrase, in the second paragraph of the above note, more than one less than the Total Number of Channels represents the condition of two, three, or four channels inoperable (i.e.,
more than one channel inoperable, where one channel inoperable is one less than the Total Number of Channels.) The Total Number of Channels is listed in TS Table 3.3-3.
With this proposed change, when the licensee makes inoperable the two LOP instrumentation channels necessary to perform the corrective maintenance on the current inoperable channel, the licensee would not be required to enter LCO 3.0.3. It would enter the above note and declare inoperable the associated DG (i.e., the DG with the now two inoperable LOP instrumentation channels). The TSs on DGs in the applicable modes (i.e., Modes 1, 2, 3, and 4) is TS 3.8.1, A.C. [Alternating Current] Sources. TS 3.8.1 allows 14 days to restore an inoperable DG to operable status before the licensee has to start shutting down the unit. The licensee has stated that the 14 days is more than enough to perform the corrective maintenance needed to restore the current inoperable LOP instrumentation channel to operable status.
The licensee has in effect proposed TS 3.3.5 Conditions B and C of the Westinghouse-improved Standard Technical Specifications in NUREG-1431 for Westinghouse pressurized-water reactors like STP Unit 1. TS 3.3.5 is the specification for the LOP DG start instrumentation, which is the same instrumentation that the amendment is addressing, and Conditions B and C address the situation where two channels of DG LOP instrumentation on the same train or bus are inoperable. This is the exact situation that will exist when the corrective maintenance is performed on the current inoperable LOP instrumentation channel and a second channel must be made inoperable.
4.2 Technical Evaluation For STP Unit 1, the licensee uses two undervoltage sensing schemes for each Class 1E 4.16 kV bus to provide two levels of undervoltage protection for the DG. The first scheme detects loss of voltage and the second scheme detects degraded voltage conditions on the bus.
Voltage signals to each scheme are provided through four potential transformers connected to each bus. Four solid-state type instantaneous undervoltage relays and four time delay relays are used for the first scheme (loss of voltage). The devices used for the second scheme (degraded voltage and sustained degraded voltage in the TSs) include four solid-state type instantaneous undervoltage relays and two sets of four time delay relays.
In the TSs, the operability requirements for the Loss of Power 4.16 kV ESF undervoltage relays and the 4.16 kV ESF degraded voltage relays are found under Functional Unit 8 in TS Table 3.3-3. The LOP 4.16 kV ESF undervoltage relays and the 4.16 kV ESF degraded voltage relays are required for the ESF systems to automatically function in any accident in which the loss of offsite power is assumed in the safety analysis. The design function of the LOP 4.16 kV ESF undervoltage relays and the 4.16 kV ESF degraded voltage relays is to provide an input to the associated ESF load sequencer when an undervoltage or degraded voltage condition is sensed from the offsite power source. The normal logic for a LOP ESF actuation is two-out-of-four channels actuating. Both the undervoltage and degraded voltage functions are currently in the tripped condition for the one LOP instrumentation channel. The proposed note applies to Functional Unit 8, which includes undervoltage and degraded voltage channels (i.e., Functional Units 8.a, 8.b, 8.c of TS Table 3.3-3).
Even though the TSs allow continued operation with one channel in the tripped condition, the licensee identified the following three concerns while in operation in this configuration for an extended period of time:
1.
The plant is exposed to an invalid ESF actuation should another channel fail, the result being an ESF bus strip and start and load of SDG11. The NRC staff agrees that inadvertent starts of the DG are an overall reliability concern related to the component and is an unnecessary challenge actuation of an ESF safety-related system.
2.
The situation would result in an unusual burden on the normal testing for the relays and the associated DG. Running the DG at full load has been decreased to 60 minutes (the TS requirement) instead of the normal 210 minutes (the vendors recommendation).
This is to minimize exposure to any reverse power condition because there is not power to the relay that provides reverse power protection to the SDG11 when it is paralleled to the grid for surveillance testing. (Although this relay does not affect the emergency function of the DG.)
3.
Placing the inoperable channel to bypass while other channels are under TADOT testing and restoring it to the trip condition has the potential for a human performance error that would result in an ESF actuation and unnecessarily challenge safety-related systems.
The note to be added states with the number of OPERABLE channels more than one less than the Total Number of Channels, within one hour restore all but one channel per bus to OPERABLE status or enter the applicable ACTION for the associated standby diesel generator made inoperable by the LOP instrumentation.
The ultimate effect of losing the LOP instrumentation function is that the associated DG cannot be automatically loaded on the bus and is, therefore, inoperable. However, in this case the DG could be manually started in the event of an accident and, therefore, remains functional and capable of performing its safety function.
The current TS 3.8.1 for STP Unit 1 allows 14 days to restore an inoperable DG to operable status before the licensee has to start shutting down the unit. The licensee has stated that there is more than enough margin in the time needed for the corrective maintenance to be performed.
4.3 Conclusion Because the proposed note, which provides the conditions and required actions for more than one channel inoperable for DG LOP start instrumentation, (1) addresses the exact situation that exists at STP Unit 1, (2) accounts for the associated DG being inoperable if the DG LOP start instrumentation is inoperable, and (3) parallels the Standard Technical Specifications for the DG LOP start instrumentation for nuclear power plants like STP Unit 1, the NRC staff concludes that the proposed note provides adequate compensatory action to assure plant safety and is, therefore, acceptable. Based on this, the NRC staff also concludes that the proposed note meets 10 CFR 50.36 and the proposed amendment is, therefore, acceptable.
5.0 EMERGENCY CIRCUMSTANCES In its application, the licensee requested an exigent amendment to revise TS Table 3.3.2, Action 20, the DG LOP instrumentation by adding a note to allow the licensee to have two inoperable DG LOP instrumentation channels on a bus for corrective maintenance without having to enter LCO 3.0.3. The basis for this request is addressed in Section 2.0, Background and Justification for Emergency Change, of this safety evaluation. A Notice of Consideration of Issuance of Amendment to Facility Operating License, Proposed No Significant Hazards Consideration Determination, and Opportunity for a Hearing for the application was published in the Federal Register on December 29, 2006 (71 FR 78468).
In its supplemental letter dated December 28, 2006, the licensee proposed a revised note that if one of the two DG LOP instrumentation channels could not be made operable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, the licensee would be required to enter TS 3.8.1 for the associated DG being declared inoperable.
The revised note allows the licensee 14 days to perform the corrective maintenance on the two inoperable DG LOP instrumentation channels where the application would have allowed only 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Because of this difference between the application and the supplemental letter, the Federal Register notice for the application does not encompass the proposed amendment requested in the supplemental letter. Through inadvertence, the NRC staff did not publish a Notice of Consideration of Issuance of Amendment to Facility Operating License, Proposed No Significant Hazards Consideration Determination, and Opportunity for a Hearing for the supplemental letter. Therefore, the amendment cannot be considered on an exigent basis in accordance with 10 CFR 50.91(6). Nevertheless, the licensee has provided sufficient information in its letters for the NRC staff to consider issuing the amendment on an emergency basis in accordance with 10 CFR 50.91(5).
In accordance with 10 CFR 50.91(5), [w]here the Commission finds that an emergency situation exists, in that failure to act in a timely way would result in derating or shutdown of a nuclear power plant,... it may issue a license amendment involving no significant hazards consideration [(NSHC)] without prior notice and opportunity for a hearing or for public comment. The NRC staffs final finding of NSHC is given in the following Section 6.0, Final No Significant Hazards Consideration, of this safety evaluation.
In addressing the exigent circumstances for its proposed amendment, the licensee stated the following:
Replacement of the PT will take several hours and access to the PT will require the two channels of the Train A LOP instrumentation that share the same drawer to be removed from service (i.e., the inoperable channel and one other channel).
Since there is no TS action for two inoperable channels of LOP instrumentation, the shutdown requirement of TS 3.0.3 would apply. Voluntary entry into TS 3.0.3 is permissible for short durations (less than an hour) and for reasons other than operational convenience. Although this entry would not be for operational convenience, it would be for substantially longer than one hour. In accordance with the reporting guidance in NUREG-1022, such an entry into TS 3.0.3 would result in a reportable condition per 10CFR50.73. To avoid this situation, STPNOC is proposing to amend the TS for LOP to permit corrective maintenance.
While the TS allow continued operation with one channel of LOP instrumentation in the trip condition, operation in the configuration for an extended time exposes the plant to an invalid ESF actuation (ESF bus strip and start and load of SDG11) should another channel fail.
This condition also results in an unusual burden on the normal testing for the relays and the associated Standby Diesel Generator (SDG). With the A ESF bus LOP instrumentation failed and in trip, STP Unit 1 does not have power to the relay that provides reverse power protection to SDG11 when it is paralleled to the grid for surveillance testing. To minimize the exposure to any reverse power condition while the channel is inoperable, STP is running SDG11 at full load for 60 minutes (T.S. requirement) instead of the normal 210 minutes (vendor recommendation). This protective relay does not affect the emergency function of the diesel to respond to any signal provided by the sequencer since it would not be paralleled to offsite power. STPNOC also has to perform trip actuating device operational tests (TADOT) on the operable LOP instrument channels in compliance with TS surveillance requirements (SR). Performing the TADOTs requires the inoperable channel to be bypassed while the other channel is tested. Placing the inoperable channel in bypass and restoring the channel to the trip condition after testing have some potential for a human performance error that would result in an ESF actuation.
Both the undervoltage and degraded voltage functions are in the tripped condition. The proposed note applies to Functional Unit #8, which includes undervoltage and degraded voltage channels (Functional Units 8.a, 8.b, 8.c).
Exigent approval of the proposed TS change is justified because the failure that caused the inoperable channel could not reasonably have been anticipated.
As explained by the licensee, STP Unit 1 has an inoperable DG LOP instrumentation channel and, therefore, in a tripped condition. Therefore, with the two-out-of-four actuation logic, there will be an ESF actuation if there is a spurious signal in any of three remaining Train A channels.
This is a precarious situation for the unit to be in and should be corrected as soon as practicable. The corrective maintenance by the licensee that is needed to return this inoperable channel to operable status will, however, require that an additional Train A channel be made inoperable. With the current TSs, the licensee would have to shut down to perform the corrective maintenance because this maintenance cannot be performed in the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> allowed by LCO 3.0.3 before the licensee would have to start shutting down the unit. The requirement to shut down the unit to perform maintenance does not come from the maintenance to be performed, but because to perform the maintenance an additional Train A instrumentation channel has to be made inoperable and the TSs would then require the plant to be shut down.
The licensee has also provided a basis that it could not have known about this situation such that it could have acted in such a manner that the emergency TS change could have been avoided. Based on this evaluation, the NRC staff concludes that the licensee has met the requirements in 10 CFR 50.91(5) such that an emergency situation exists and the proposed amendment may be issued as an emergency change to the TSs.
6.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION
In its application and supplemental letter, the licensee addressed the NSHC criteria in 10 CFR 50.92, Issuance of amendment, and provided the following NSHC for the proposed amendment:
1.
Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed change to add a note to ACTION 20 for a one-time change to allow corrective maintenance on the Unit 1 Train A loss of power instrumentation does not change the plant design basis, system configuration or operation, and does not add or affect any accident initiator.
Therefore, STPNOC concludes that there is no significant increase in the probability or consequences of an accident previously evaluated.
2.
Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed change does not change the plant design basis, system configuration or operation, and does not add or affect any accident initiator. [The proposed change does not add any new equipment or hardware to the unit, does not affect the operation of the unit, and does not affect any accident analysis for the unit.]
Therefore, STPNOC concludes the proposed change 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.
No actual plant equipment or accident analyses will be affected by the proposed change. Additionally, the proposed changes will not relax any criteria used to establish safety limits, will not relax any safety systems settings, and will not relax the bases for any limiting conditions of operation. Therefore, STPNOC concludes the proposed changes do not involve a significant reduction in the margin of safety.
The licensee concluded in its letters that the proposed amendment does not involve an NSHC.
The NRC staff has reviewed the proposed changes to the TSs in the amendment and the NSHC given in the letters. Based on its review, the NRC staff agrees with the licensee and concludes that the NSHC given above is its final determination of NSHC for the amendment.
7.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Texas State official was notified of the proposed issuance of the amendment and of the amendment being issued as an emergency change to the license in accordance with 10 CFR 50.91(5). The State official had no objections to the amendment or that the amendment was issued on an emergency basis.
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 in Section 6.0, Final No Significant Hazards Consideration, of this safety evaluation. 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: Royce Beacom Jack Donohew Date: January 11, 2007
December 2006 South Texas Project, Units 1 & 2 cc:
Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 289 Wadsworth, TX 77483 C. Kirksey/C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704 Mr. J. J. Nesrsta Mr. R. K. Temple City Public Service Board P.O. Box 1771 San Antonio, TX 78296 INPO Records Center 700 Galleria Parkway Atlanta, GA 30339-3064 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Steve Winn NRG South Texas LP 1301 McKinney, Suite 2300 Houston, TX 77010 Judge, Matagorda County Matagorda County Courthouse 1700 Seventh Street Bay City, TX 77414 A. H. Gutterman, Esq.
Morgan, Lewis & Bockius 1111 Pennsylvania Avenue, NW Washington, DC 20004 E. D. Halpin Site Vice President/
Plant General Manager STP Nuclear Operating Company P.O. Box 289 Wadsworth, TX 77483 S. M. Head, Manager, Licensing STP Nuclear Operating Company P.O. Box 289, Mail Code: N5014 Wadsworth, TX 77483 Environmental and Natural Resources Policy Director P.O. Box 12428 Austin, TX 78711-3189 Jon C. Wood Cox, Smith, & Matthews 112 East Pecan, Suite 1800 San Antonio, TX 78205 Director Division of Compliance & Inspection Bureau of Radiation Control Texas Department of State Health Services 1100 West 49th Street Austin, TX 78756 Brian Almon Public Utility Commission William B. Travis Building P.O. Box 13326 1701 North Congress Avenue Austin, TX 78701-3326 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
December 2006 South Texas Project, Units 1 & 2 cc:
Mr. Ted Enos 4200 South Hulen Suite 630 Ft. Worth, TX 76109 Mr. Glenn Adler Senior Research Analyst Service Employees International Union 1313 L Street NW Washington, DC 20005