ML071090255

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Closeout Letter Addressing Responses to Generic Letter 2003-01, Control Room Habitability
ML071090255
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 05/04/2007
From: Donohew J
NRC/NRR/ADRO/DORL/LPLIV
To: Sheppard J
South Texas
Donohew J N, NRR/DORL/LP4, 415-1307
References
GL-03-001, TAC MB9858, TAC MB9859
Download: ML071090255 (6)


Text

May 4, 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, UNITS 1 AND 2 - CLOSEOUT LETTER ADDRESSING RESPONSES TO GENERIC LETTER 2003-01, CONTROL ROOM HABITABILITY (TAC NOS. MB9858 AND MB9859)

Dear Mr. Sheppard:

By letter dated June 12, 2003 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML031620248), the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2003-01, Control Room Habitability, to licensees of operating pressurized-water and boiling-water reactors to (1) alert licensees that applicable regulatory requirements may not be met and existing technical specification surveillance requirements may not be adequate, (2) emphasize the importance of reliable, comprehensive surveillance testing to verify control room habitability (CRH), (3) request information that demonstrates the control room complies with the current licensing basis, design basis, and applicable regulatory requirements, and that suitable control measures are in place to maintain this compliance, and (4) collect the requested information to determine if additional regulatory action is required. By letters dated August 11 and December 9, 2003; August 5, 2004; and June 6, 2006 (NOC-AE-03001565, -03001635, -04001758, and -06002018, and ADAMS Accession Nos. ML032270466, ML033500387, ML042260183, and ML061630230, respectively), STP Nuclear Operating Company (the licensee) responded to the GL for South Texas Project Electric Generating Station (STP), Units 1 and 2. The STP, Units 1 and 2, have separate control rooms.

The GL requested that the licensee confirm for the units that the control room meets the applicable habitability regulatory requirements and that the CRH systems are designed, constructed, configured, operated, and maintained in accordance with the facilitys design and licensing basis, with emphasis on the following: (1) determination of the most limiting unfiltered and/or filtered inleakage into the control room and comparison to values used in your design bases for meeting control room operator dose limits from accidents (GL 2003-01, Item 1a),

(2) determination that the most limiting unfiltered inleakage is incorporated into your hazardous chemical assessments (GL 2003-01, Item 1b), and (3) determination that reactor control capability is maintained in the control room or at the alternate shutdown location in the event of smoke (GL 2003-01, Item 1b). The GL further requested information on any compensatory measures in use at the units to demonstrate CRH, and the plans to retire them (GL 2003-01, Item 2).

J. Sheppard In the above letters, the licensee reported the results of a Component Test of the control room using tracer gas, in accordance with Regulatory Guide 1.179 and American Society for Testing Materials (ASTM) Standard E741, Standard Test Method for Determining Air Change in a Single Zone by Means of a Tracer Gas Dilution, for the units and stated the following:

For Unit 1, the tested value for inleakage into the control room envelope (CRE), was 9.4 standard cubic feet per minute (scfm), which was less than the value of 10 scfm assumed in the design basis radiological dose analyses for CRH.

For Unit 2, the licensee did not conduct an ASTM E741 tracer gas test of the control room. It instead conducted component testing and determined that the most limiting unfiltered in leakage into the CRE, was zero scfm which is less than the value of 10 scfm assumed in the design basis radiological dose analyses for CRH. However, by letter dated June 6, 2006, the licensee committed to perform an integrated ASTM E741 tracer gas test on the Unit 2 control room and report the results of the test to the NRC by December 31, 2007. Although the test has been performed, the results have not yet been submitted at this time.

The licensee also stated in its letters that there are no offsite or onsite storage or transportation of chemicals that pose a credible hazard to CRH and, thus, engineered controls for the control room are not required at the units to ensure CRH against a hazardous chemical threat.

Therefore, the amount of unfiltered inleakage is not incorporated into the hazardous chemical assessment for the control room. The hazardous chemical analyses demonstrated that neither onsite or offsite hazardous chemical sources within the vicinity of the control room would reach toxicity limits inside the CRE within 6 minutes following nasal detection by operators, which meets the Regulatory Guide 1.78 recommendation that states operators should be able to don breathing apparatus within 2 minutes. No credit is taken for isolation of the ventilation system although manual isolation remains available to the operators for defense in depth. The reactor control capability is maintained from either the control room or the alternate shutdown station in the event of smoke entering the control room.

The GL requested that the licensee assess the STP Technical Specifications (TSs) to determine if the TSs verify the integrity of the CRE, including ongoing verification of the inleakage assumed in the design-basis analysis for CRH, and in light of the demonstrated inadequacy of a delta () P measurement to alone provide such verification (GL Item 2003-01, Item 1c). In response to the GL, by letter dated March 21, 2007 (NOC-AE-07002135, ADAMS Accession No. ML070940408), the licensee stated that it would submit a license amendment request by July 6, 2007, to adopt the TSs regarding CRH in NRC-approved Technical Specification Task Force Traveler 448, Revision 3 (TSTF-448R3) using the NRC consolidated line item improvement process.

The licensee also stated that it does not use compensatory measures to demonstrate CRH for the units, is committed to the general design criteria (GDC) in Appendix A to Part 50 of Title 10 of the Code of Federal Regulations (10 CFR Part 50), as documented in the STP Final Safety Analysis Report, and has acted to ensure continued compliance with the CRH design and licensing basis. These statements support the conclusion that the units are required to meet the GDC regarding CRH.

J. Sheppard Based on the above, the NRC staff concludes that the licensees response to GL 2003-01 for STP is acceptable and no further action is required. This letter closes out the subject TACs for STP, Units 1 and 2. If you have any questions regarding this correspondence, contact Mohan Thadani at 301-415-1476.

Sincerely,

/RA/

Jack Donohew, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499 cc: See next page

J. Sheppard May 4, 2007 Based on the above, the NRC staff concludes that the licensees response to GL 2003-01 for STP is acceptable and no further action is required. This letter closes out the subject TACs for STP, Units 1 and 2. If you have any questions regarding this correspondence, contact Mohan Thadani at 301-415-1476.

Sincerely,

/RA/

Jack Donohew, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499 cc: See next page DISTRIBUTION:

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Accession No.: ML071090255 OFFICE NRR/LPL4/PM NRR/LPL4/LA PGCB/BC SCVB/BC NRR/LPL4/BC NAME JDonohew LFeizollahi CJackson RDennig THiltz DATE 4/24/07 4/19/07 4/26/07 5/3/07 5/4/07 OFFICIAL RECORD COPY

March 2007 South Texas Project, Units 1 & 2 cc:

Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 289 Wadsworth, TX 77483 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704 J. J. Nesrsta/R. K. Temple E. Alercon/Kevin Pollo 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/Christie Jacobs Eddy Daniels/Marty Ryan NRC Energy, Inc.

211 Carnegie Center Princeton, NJ 08540 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 STP Nuclear Operating Company South Texas Project Electric Generating Station 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 C. T. Bowman General Manager, Oversight STP Nuclear Operating Company P.O Box 389 Wadsworth, TX 77483 Marilyn Kistler Sr. Staff Specialist, Licensing STP Nuclear Operating Company P.O. Box 289, Mail Code 5014 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 South Texas Project, Units 1 & 2 March 2007 cc:

Mr. Ted Enos 4200 South Hulen Suite 422 Ft. Worth, TX 76109 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 Ken Coates Plant General Manager STP Nuclear Operating Company South Texas Project Electric Generating Station P.O. Box 289 Wadsworth, TX 77483 Mr. Terry Parks, Chief Inspector Texas Department of Licensing and Regulation Boiler Division P.O. Box 12157 Austin, TX 78711